Uploaded February 2025 | Updated September 2026, 1 hour ago
EPA's expert witness on risk assessment in the fluoride trial, Dr. Stanley Barone, admitted under oath that for studies finding IQ loss at a certain level of exposure, the standard risk assessment approach that EPA would use is to divide the level of exposure where studies find harm by 10 to reach a level low enough to prevent harm to more sensitive members of a population.
"An uncertainty factor of ten, which is appropriate for all life stages, inclusive of all life stages and vulnerabilities, would be the benchmark MoE." - Dr. Stanley Barone, EPA Risk Assessment Expert
This is based on the finding that for any toxic substance, a few percent of people will typically be at least 10-times more sensitive than the average person. A dose that is 10-times less than what causes harm in average sensitivity people will cause harm in the more sensitive people.
EPA considers this a "protective approach" because under TSCA it must protect all people, not just people of average susceptibility to any particular toxic chemical.
It is generally accepted, even by the dental lobby, that there is evidence of fluoride's neurotoxic effects at 1.5ppm in water.
If EPA were to enact fluoride regulations consistent with how it regulates other toxic chemicals, according to Dr. Barone, EPA should be using at least a 10x safety factor to account for sensitive subpopulations exposed to fluoride in water.
1.5ppm fluoride in water (observed effect) divided by 10 (MoE, safety factor) = 0.15ppm safe level of fluoride in water.
Explanation of Terms:
Benchmark MoE = "Margin of Exposure (MoE)". This term is synonymous with EPA's regulatory language of "Margin of Safety", "Uncertainly Factor", and "Safety Factor", meaning the number EPA divides by (usually 10) to account for sensitive subpopulations in a chemical's risk assessment. This provides a margin of safety for all consumers.
BMCL = A lower confidence limit on the dose of a chemical that produces a biological effect.
LOAEL = The lowest-observed-adverse-effect level (LOAEL) is a term used by the EPA to describe the lowest dose of a substance that causes harmful health effects.
NOAEL = No-Observed-Adverse-Effect Level (NOAEL). The highest exposure level at which there are no biologically significant effects of a chemical.
EPA's expert witness on risk assessment in the fluoride trial, Dr. Stanley Barone, admitted under oath that for studies finding IQ loss at a certain level of exposure, the standard risk assessment approach that EPA would use is to divide the level of exposure where studies find harm by 10 to reach a level low enough to prevent harm to more sensitive members of a population.
"An uncertainty factor of ten, which is appropriate for all life stages, inclusive of all life stages and vulnerabilities, would be the benchmark MoE." - Dr. Stanley Barone, EPA Risk Assessment Expert
This is based on the finding that for any toxic substance, a few percent of people will typically be at least 10-times more sensitive than the average person. A dose that is 10-times less than what causes harm in average sensitivity people will cause harm in the more sensitive people.
EPA considers this a "protective approach" because under TSCA it must protect all people, not just people of average susceptibility to any particular toxic chemical.
It is generally accepted, even by the dental lobby, that there is evidence of fluoride's neurotoxic effects at 1.5ppm in water.
If EPA were to enact fluoride regulations consistent with how it regulates other toxic chemicals, according to Dr. Barone, EPA should be using at least a 10x safety factor to account for sensitive subpopulations exposed to fluoride in water.
1.5ppm fluoride in water (observed effect) divided by 10 (MoE, safety factor) = 0.15ppm safe level of fluoride in water.
Explanation of Terms:
Benchmark MoE = "Margin of Exposure (MoE)". This term is synonymous with EPA's regulatory language of "Margin of Safety", "Uncertainly Factor", and "Safety Factor", meaning the number EPA divides by (usually 10) to account for sensitive subpopulations in a chemical's risk assessment. This provides a margin of safety for all consumers.
BMCL = A lower confidence limit on the dose of a chemical that produces a biological effect.
LOAEL = The lowest-observed-adverse-effect level (LOAEL) is a term used by the EPA to describe the lowest dose of a substance that causes harmful health effects.
NOAEL = No-Observed-Adverse-Effect Level (NOAEL). The highest exposure level at which there are no biologically significant effects of a chemical.
