To fluoridate or not to fluoridate? That is a question that may soon be weighed across the United States.
The future of U.S. community water fluoridation programs hinges largely on the National Toxicology Program’s (NTP’s) six-year systematic review, a report that takes a critical look at the available science but has become mired in government interference and controversy.
Draft releases of the report—revealed as part of an ongoing lawsuit—affirm the science that links fluoride to lower intelligence in children. The report’s findings support multiple studies concluding that fluoride is a neurodevelopmental toxin.
The report, or monograph, is significant because it assesses all research and studies regarding the neurotoxic effects of fluoridated water exposure and raises questions about long-term health effects.
A two-year delay in the release of this pivotal monograph has become a major element in an ongoing lawsuit brought against the Environmental Protection Agency (EPA) by the Fluoride Action Network (FAN), which seeks to ban chemical fluoride additives from the U.S. public drinking water supply.Between September 2019 and February 2022, the report went through five separate peer-review processes and three revised draft iterations that incorporated all suggestions and comments from all five peer-review processes.
Despite the extensive peer reviews and draft revisions, internal Centers for Disease Control and Prevention (CDC) emails revealed government officials blocked the release of the May 2022 draft that was considered final by the NTP.
Court documents show that an undisclosed working group then started a review process to “adjudicate” undisclosed comments made by “agency subject matter experts.”
The NTP’s Controversial Findings
The National Toxicology Program (NTP) is an interagency government program run by the Department of Health and Human Services to protect the American public from toxins. The NTP is under the department’s National Institute for Environmental Health Sciences.Dr. Kristina Thayer, director of the NTP Office of Health Assessment and Translation, told the board that the review would evaluate fluoride exposure and the potential for developmental neurobehavioral effects. She highlighted findings from the 2006 National Research Council report and a 2015 review done for Ireland’s Department of Health, which highlighted potential neurological effects.
The NTP’s review on fluoride looked at data from more than 500 studies on fluoride exposure and neurotoxicity that included more than 150 human studies as well as non-human mammal and vitro studies.

Out of the studies reviewed, 29 of the human studies were rated high quality and the report included a meta-analysis of more than 50 studies on fluoride exposure and children’s IQ.
The meta-analysis in the most recent version of the NTP draft review concluded that “52 of 55 studies reported an inverse association between fluoride exposure and children’s IQ.”
In other words, the more fluoride children are exposed to, the lower their IQ. The estimated drop, based on a range of studies, is approximately seven IQ points.
Till stressed that just a five-point decrease in a population’s IQ would increase the number of people classified as intellectually disabled to 9.5 million from 6 million and the number of people considered gifted would drop to 2.4 million from 6 million.
Another concerning finding in the review is that there is no obvious safe threshold for fluoride exposure.
Till stressed that data in the NTP report show that there is a drop in children’s IQ even between the lower ranges from zero to 2.0 mg/L of urinary fluoride levels. Measurement of fluoride levels in urine is a method used for the estimation of fluoride exposure levels.

“The potential for adverse health effects of early-life exposure to fluoride are of huge public health significance,” she said.
“Human epidemiological evidence supports a conclusion of ’moderate confidence' that fluoride is a developmental neurotoxin,” Kall said.
Confidence ratings in the report range between one and four, with four being the highest confidence. Moderate confidence is three out of four.

Kall noted that a moderate ranking is where serious scientists start asking some very hard questions around safety, such as “If there is that level of confidence, shouldn’t we be implementing some changes around exposure to this [fluoride]”?
Kall also stressed that the review revealed people are exposed to enough fluoride to experience harm, according to the research.
Unprecedented Delays, Lack of Transparency
What’s unique about the NTP—normally—is its track record of transparency. A large number of their most recent reports had a public peer-review process lasting a few days, and court documents note that drafts of NTP reports were always provided to the public.The names of the BSC working group and agency comments were disclosed per court order and subpoena although agency names attached to the comments were redacted.
Subsequent to the release, plaintiffs’ attorneys reached an agreement with the EPA’s attorneys that they would provide them a “key” that would unlock the redacted sections and identify the agencies corresponding to comments and criticisms.
The Epoch Times has obtained a copy of the redacted agency names which include: Centers for Disease Control and Prevention (CDC), National Institute of Dental and Craniofacial Research (NIDCR), National Institute of Environmental Health Sciences (NIEHS), U.S. Food and Drug Administration (FDA), Eunice Kennedy Shriver National Institute of Child Health and Human Development (NICHD), Office of the Assistant Secretary for Health (OASH), National Institutes of Health/Office of the Director (NIH/OD)
Although actual employee names were not obtained, plaintiff attorney Michael Connett told The Epoch Times in an email that “the main criticisms came from the CDC and NIDCR.” Both agencies promote water fluoridation program in the U.S.
A Timeline of the NTP Fluoride Report
The timeline of events for the NTP report on fluoride is as follows:2016: The NTP publishes its first report on fluoride, titled “Systematic Literature Review on the Effects of Fluoride on Learning and Memory in Animal Studies.”
September 2019: The NTP publicly releases a draft of its second report on fluoride, titled “Systematic Review of Fluoride Exposure and Neurodevelopmental and Cognitive Health Effects.” The review looks at both animal and human studies, but focuses more on human studies.
September 2019–March 2020: The second report draft is peer-reviewed by the National Academies of Sciences, Engineering, and Medicine (NASEM).
September 2020: The NTP incorporates NASEM’s suggestions from the peer review and released a revised report.
September 2020–February 2021: A second peer review is conducted by NASEM on the revised 2020 report.
July 2021–July 2022: The report is reviewed by various Department of Health and Human Services entities.
November 2021: The NTP incorporates NASEM’s comments from the second-round peer process and completes another revised 2021 draft.
November 2021–February 2022: The 2021 draft undergoes a peer-review process by five external nongovernment scientists.
January 2022: The NTP states, “Pending general reviewer agreement with our document, we anticipate public availability of a revised final state of the science report by the end of March.”
May 2022: The NTP incorporates all comments from all five external peer reviewers and completes a finalized copy of the report. It decides to publicly release the report on May 18, 2022.
June 2022: Government officials decide to put the report on “hold,” according to emails obtained via the Freedom of Information Act.
October 2022–May 2023: Another review is done by an undisclosed working group set by the NTP’s board to adjudicate 325 comments and criticisms on the report received from external peer reviewers and federal agency experts.
March 15, 2023: After months of legal motions, subpoenas, extensive negotiations, and a court order, the National Institute for Environmental Health Sciences publicly releases the NTP’s final report that was intended to be published in May 2022. The final report include a September 2022 marked-up “working” draft with reviewers’ comments and NTP authors’ responses, with names redacted.
The September 2022 NTP version was for the most part identical to the May 2022 version with very few, if any, meaningful changes although it does contain extensive comments from some of the agency reviewers along with NTP’s responses.
The Story of Asbestos
Kall noted that the last time major delays like this were witnessed in the process of an NTP review was with the now-highly regulated cancer-causing substance asbestos. However, “the delays have been much worse with the NTP report on fluoride,” he said.Similarly to the chemical fluoride additive, asbestos is big business in the United States.
Government Interference
Many doctors, scientists, and experts witnessing the prolonged process say the government has tried to quash and dilute the report for political purposes. The possibility that a major public health program had unintended side effects is no doubt a significant issue for those that supported it as mounting evidence of neurotoxicity came to light.“We have set May 18, 2022, for publication of the monograph. The monograph will be posted to the NTP website, and we will email a notice of the posting to NTP listserv subscribers,” Mary Wolfe told CDC officials in a May 11, 2022, email. Wolfe is the deputy director for policy and communication at the Division of Translational Toxicology, which functions somewhat like a communications arm for the NTP.
Several back-and-forth emails ensued from CDC official Karen Hacker regarding clarification around whether the report publication had National Institutes of Health clearance and whether it also would be going through a Health and Human Services interagency review.
Later that same day, Wolfe clarified, “My reply noted that we believe the current findings, as stated in the monograph, reflect the scope of our evaluation and the available scientific literature, and no revision is needed.”
Hacker pushed back, wanting to set up a meeting as soon as possible “to discuss the rollout and messaging.”
Then something happened behind the scenes that wasn’t captured in the emails released.
A June 3, 2022, email from Nicole Johnson, associate director for policy, partnerships, and strategic communications at the CDC Division of Oral Health, stated, “The latest we heard (yesterday) is that ASH Levine [Assistant Secretary of Health Rachel Leland Levine] has put the report on hold until further notice.”
One Step Closer to Publication
After the forced release of the draft, two public meetings were held, one on May 4 and the other on May 16, where the NTP’s board of counselors voted unanimously to accept the recommendations of their working group and move forward with the completion process.NTP Director Richard Woychik, who is also director of the National Institute for Environmental Health Sciences, is now ultimately responsible for deciding on the final publication. He said in his closing remarks that he will be working with the members of the working group and the NTP authors to make revisions and try to get the report to publication as quickly as possible, hopefully in the next several weeks.
Woychik mentioned that he would also be consulting with their partner organizations, the U.S. Food and Drug Administration and the CDC, in the finalization process.