“Community water fluoridation is the process of adjusting the fluoride content of fluoride-deficient water to the recommended level for optimal dental health, which is currently recommended at 0.7 parts fluoride per million parts water.” emphasis added
American Dental Association, Topic Update 7/14/2023, archive copy
Contents
- Summary Points
- City of Lincoln’s Response to Request for Information
- Lancaster County Response to Request for Information
- State Response to Request for Information
- References & Links
- Children’s Health Defense Fluoride Articles

According to the Nebraska Department of Environment & Energy, July 2023, “The amount of fluoride currently prescribed in [the water supply regulations] is based on an outdated CDC recommendation regarding optimum fluoride levels (0.9 – 1.0 ppm). In 2015 CDC updated their recommended optimum level to 0.7 ppm.”
The American Dental Association, Topic Update 7/14/23 says, “Community water fluoridation is the process of adjusting the fluoride content of fluoride-deficient water to the recommended level for optimal dental health, which is currently recommended at 0.7 parts fluoride per million parts water.” and recommends unfluoridated water for infant formula through at least age 12 months.
Calculated fluoride values for the City of Lincoln in July and August 2023 ranged from 0.88 – 0.90 mg/L, exceeding the recommended level of both the CDC and the American Dental Association.
Join the conversation by contacting your dentist, the City Council, the Lancaster County Board of Health & County Commissioners, the Nebraska Department of Health & Human Services – Public Health, and your State Senator.
Let’s sunset water fluoridation in Nebraska – support safer topical application
Lincoln’s naturally occurring water fluoride level ranges from 0.4 to 0.5 ppm.
- Fluoride & IQ: The U.S. DHHS National Toxicology Program Review and other studies indicate a link between fluoride exposure and cognitive health
- Infant Formula: The American Dental Association supports breast-feeding and recommends unfluoridated water for infant formula to reduce risk of tooth mottling, called fluorosis
- Essential to consider all fluoride sources: WHO Guidelines for Drinking-water Quality, consider all fluoride exposure from beverages, food, and environment
- Unsettled questions about fluoride exposure safety: National Academies of Science – National Research Council 2006 report of Fluoride in Drinking Water
A Benchmark Dose Analysis for Maternal Pregnancy Urine-Fluoride and IQ in Children, 2020:
A benchmark concentration for maternal urinary fluoride of 0.29 ppm was associated with a 1-point decrease in IQ scores of preschool-aged boys and girls
A 5-minute video showing how a small drop in IQ effects the overall population
Little Things Matter, (accessed 25 July 2023)
Dietary fluoride intake during pregnancy and neurodevelopment in toddlers: A prospective study in the progress cohort
A 0.5 mg/day increase in overall dietary fluoride intake was associated with a 3.46-point lower cognitive outcome in boys
U.S. Department of Health & Human Services National Toxicology Program
Monograph on the State of the Science Concerning Fluoride Exposure and Neurodevelopmental and Cognitive Health Effects: A Systematic Review September 2022
“1.5 ppm is consistently associated with lower IQ in children. More studies are needed to fully understand the potential for lower fluoride exposure to affect children’s IQ.”
Journal of the American Dental Association, January 2011
“… the greater the amount of fluoride intake during tooth development in any person, the greater the prevalence of fluorosis development… Practitioners should be aware that children are exposed to multiple sources of fluoride during the tooth development period. Reducing fluoride intake from reconstituted infant formula alone will not eliminate the risk of fluorosis development. It also is important that clinicians provide advice to parents regarding the proper use of fluoridated toothpastes along with the informed prescription of fluoride supplements. The panel acknowledges and encourages clinicians to follow the American Academy of Pediatrics’ guidelines for infant nutrition, which advocate exclusive breastfeeding to age 6 months and continued through at least age 12 months unless specifically contraindicated. Human breast milk has been shown to have consistently low levels of fluoride.”
The City of Lincoln Water Quality Report 2022
NE DHHS Title 179 Public Water SystemRules & Regulations Governing Fluoridation of Water Supplies:(pg 309)
Appendix A to Title 179 NAC 14– Fluoride 4 ppm MCLG,
Major Sources in drinking water: Erosion of natural deposits; Water additive that promotes strong teeth; Discharge from fertilizer and aluminum factories.
Health effects language: Some people who drink water containing fluoride in excess of the MCL over many years could get bone disease, including pain and tenderness of the bones. Fluoride in drinking water at half the MCL or more may cause mottling of children’s teeth, usually in children less than nine years old. Mottling, also known as dental fluorosis, may include brown staining and/or pitting of the teeth, and occurs only in developing teeth before they erupt from the gums.
The Fluoride Debate: The Pros and Cons of Fluoridation
Conclusion: Since the fluoride benefit is mainly topical, perhaps it is better to deliver fluoride directly to the tooth instead of ingesting it.
Fluoride Toxicity (7/28/2023)
“For optimal dental health, the World Health Organization recommends a level of fluoride from 0.5 to 1.0 mg/L (milligrams per liter), depending on climate.[6] Fluorosis becomes possible above this recommended dosage. As of 2015, the United States Health and Human Services Department recommends a maximum of 0.7 milligrams of fluoride per liter of water – updating and replacing the previous recommended range of 0.7 to 1.2 milligrams issued in 1962. The new recommended level is intended to reduce the occurrence of dental fluorosis while maintaining water fluoridation.[7]”
Citation [6] page decommissioned Archived (PDF) from the original on 2015-02-17. Retrieved 2013-09-01.WHO Expert Committee on Oral Health Status and Fluoride Use (1994). Fluorides and oral health (PDF). WHO technical report series 846. Geneva: World Health Organization. ISBN92-4-120846-5.
Archived 1994 World Health Organization, Fluoride and Oral Health
Relating to the fluoride dose as dependent on the amount of water ingested, “The level of 1.0 mg/L should be seen as an absolute upper limit, even in a cold climate, and 0.5 mg/L, now used in Hong Kong and recommended in the Gulf States, may be an appropriate lower limit.
Wold Health Organization Guidelines for Drinking-water Quality 2017
Referencing the need to filter very high naturally occurring fluoride levels, “There is no evidence to suggest that the guideline value of 1.5 mg/l set in 1984 and reaffirmed in 1993 needs to be revised. Concentrations above this value carry an increasing risk of dental fluorosis, and much higher concentrations lead to skeletal fluorosis. The value is higher than that recommended for artificial fluoridation of water supplies, which is usually 0.5–1.0 mg/l.
In setting national standards or local guidelines for fluoride or in evaluating the possible health consequences of exposure to fluoride, it is essential to consider the average daily intake of water by the population of interest and the intake of fluoride from other sources (e.g. from food and air). Where the intakes are likely to approach, or be greater than, 6 mg/day, it would be appropriate to consider setting a standard or local guideline at a concentration lower than 1.5 mg/l.”

Profits in public and residential water treatment


Summary Points
- Nebraska’s required fluoride level is too high: the specified fluoridation range of 0.8 – 1.5 ppm is above both CDC and WHO recommendations, 0.7 ppm and 0.5 – 1.0 ppm respectively. (4)(5)(6)
- NE DHHS regulations give communities 12 months to notify the public if levels exceed 2.0 ppm (6)
- The position that ingesting fluoride helps less fortunate children and adults with problems of tooth decay was proven wrong: Dr. Weston A. Price, Chairman of The Research Commission of The American Dental Association, documented in his 1939 book Nutrition and Physical Degeneration that mineral and vitamin levels determine incidence of dental caries, not fluorine content of the water supply. Dr. Price wrote that fluorine content cannot compensate for diets “terribly deficient in many minerals and vitamins.” (See Research Document Pg 6)
- Fluoridated drinking water does not save Medicaid spending: as proven by the research of Dr. Weston Price, dental caries, in addition to overall disease, are a symptom of a nutrient-deficient diet, not a single chemical deficiency. Fluoride’s primary effect is topical, not systemic and there is no difference in tooth decay between fluoridated and non-fluoridated countries. (See Research Document Pg 5-6)
- A safe exposure level for fluoride in pregnancy has not been established: study recommends revising water fluoridation regulation level of 0.7 mg/L based on strong evidence of prenatal neurotoxicity at levels of 0.2 mg/L or slightly below. (1)
- Fluoride level of 1.5 ppm is consistently associated with lower IQ in children, more studies needed for affects of lower exposures: as reported by the U.S. DHHS National Toxicology Program’s report on the toxicity of fluoride. Three public water systems in Nebraska report levels above 1.5 ppm. (2)(3)
- Cost to treat a questionable need: As noted in the 2022 Omaha MUD Water Quality Report, the Missouri and Platte Rivers have naturally-occurring fluoride in the range of 0.3 to 0.5 parts per million (ppm). What is the cost to increase the naturally-occurring fluoride level the 0.2 – 0.4 ppm up to the CDC recommended level of 0.7 ppm? (7)
- Increased susceptibility to harms: Similar to harms from non-ionizing magnetic and radio frequency fields, body metabolism and recovery strength varies based on a variety of factors like age, pregnancy, nutrient deficiencies, disease state, and overall toxic load from foods, beverages, and industrial pollution. What may be considered a less harmful dose of fluoride for one individual may be toxic for another. “Evidence reviewed about 15 years ago suggested that sufficient information was available to warrant further consideration of the possible adverse effects of fluoride exposure with an emphasis on vulnerable populations.” National Research Council 2006 (See Research Document Pg 8)
- Historical view of public policy, consensus-based, profit-driven public relations campaigns based on a politically motivated working hypothesis have been very successful in shaping public policy. Contagion theory has had similar effects on how the public perceives health care and food. Here are three examples highlighting the healing world of personal accountability versus a world of fear. (See Research Document Pg 9)
- Antoine Béchamp vs Louis Pasteur – terrain versus germ theory
- Del Bigtree vs Neil deGrasse Tyson – evidence and logic versus consensus-based science
- Steve Kirsh vs Mark Bailey et al. – working hypothesis in the debate on virus as a contagion

A tale of two dentists in the 1930’s and 1940’s, nutrient-dense food or medicine?
Dr. Weston A. Price traveled the world to study and write about the healthy teeth of people living on traditional diets. Then, as now, many dentists were convinced that modern food processing, particularly of flour and sugar, were largely to blame for increased incidents of cavities in the early 1900’s.


Dr. Trendley Dean, WWI Army veteran and dentist, became a key figure at the National Institutes of Health and, with support of the American Dental Association, had a key role in transforming fluoride’s medical image from tooth disfigurer to a cavity preventative. He, and others, secured his claim by writing articles about the necessity of medicating public water supplies with fluoridating chemicals.
References & Links
- A Benchmark Dose Analysis for Maternal Pregnancy Urine-Fluoride and IQ in Children, 2020: “As a safe exposure level for fluoride in pregnancy has not been established, we used data from two prospective studies for benchmark dose modeling…. Evidence reviewed about 15 years ago suggested that sufficient information was available to warrant further consideration of the possible adverse effects of fluoride exposure with an emphasis on vulnerable populations (National Research Council 2006). Only now has thorough prospective epidemiology evidence become available on populations exposed to fluoridated water (about 0.7 mg/L) or comparable exposure from fluoridated salt. The prospective studies offer strong evidence of prenatal neurotoxicity and should inspire a revision of water-fluoride regulations based on the benchmark results, especially for pregnant women and young children… These findings, using a linear concentration dependence, suggest an overall [benchmark concentration level] BMCL for fluoride concentrations in urine of approximately 0.2 mg/L or slightly below that level.” https://pubmed.ncbi.nlm.nih.gov/33173917/ and https://fluoridealert.org/studytracker/39766/
- U.S. Department of Health & Human Services National Toxicology Program 2023 (See Research Document Pg 2):
- “1.5 ppm is consistently associated with lower IQ in children. More studies are needed to fully understand the potential for lower fluoride exposure to affect children’s IQ.” https://ntp.niehs.nih.gov/whatwestudy/assessments/noncancer/ongoing/fluoride https://ntp.niehs.nih.gov/ntp/about_ntp/bsc/2023/fluoride/documents_provided_bsc_wg_031523.pdf
- Nebraska cities or villages that fluoridate to concentrations above 1.5 ppm ;
- As reported to CDC in 2022 – Verdel 1.7, Winnebago Kelley Project and Winnebago Village 1.6
- World Health Organization, Fluoride and Oral Health, 1994(See Research Document Pg 6); “Relating to the fluoride dose as dependent on the amount of water ingested, “The level of 1.0 mg/L should be seen as an absolute upper limit, even in a cold climate, and 0.5 mg/L, now used in Hong Kong and recommended in the Gulf States, may be an appropriate lower limit.” https://en.m.wikipedia.org/wiki/Fluoride_toxicity#cite_ref-WHO-TRS-846_6-0 Archive – https://web.archive.org/web/20120123194052/http://whqlibdoc.who.int/trs/WHO_TRS_846.pdf
- CDC U.S. Public Health Service recommendation for community water fluoridation, 2015 (See Research Document Pg 7);
“PHS now recommends an optimal fluoride concentration of 0.7 milligrams/liter (mg/L).”
- State of Nebraska DHHS Title 179 Public Water System Rules & Regulations Governing Fluoridation of Water Supplies, 0.8 – 1.5 ppm (See Research Document Pg 4);
- Ch 1 003.01 – “the fluoride ion content of the water available to users, as prescribed by the State Department of Health, shall be in the range of 0.8 to 1.5 parts per million, the recommended optimal level being 1.0 to 1.3 parts per million.”
- Ch 2-002.04A “Community water systems experiencing fluoride levels above 2.0 milligrams per liter must notify the public as required”
- Ch 4 -010.01 – “Public notice must be provided as soon as practical but no later than 12 months from the day the water system learns of the exceedance.” https://dhhs.ne.gov/Documents/Title-179-Complete.pdf
- Fluoridation of select Nebraska cities, as reported to CDC for 2022, mg/L = ppm; https://nccd.cdc.gov/DOH_MWF/Reports/FlStatus_Rpt.aspx
- 0.7 ppm Douglas County MUD, CDC 0.70 mg/L, Omaha MUD 2022 report 0.571 – 0.806 ppm
- 0.8 – 1.5 ppm Lincoln, CDC 0.70 mg/L, City of Lincoln 2022 reports 0.899 – 0.901 ppm
- Kearney, CDC 0.70 mg/L
- Blair, yes, CDC reports 0.70 mg/L, Blair Annual Quality report event viewer requires password. https://www.blairnebraska.org/2347/Annual-Water-Quality-Report
- 0.7 ppm Douglas County MUD, CDC 0.70 mg/L, Omaha MUD 2022 report 0.571 – 0.806 ppm
- Chemicals used;
- Lincoln, hydrofluorosilicic acid sold by Hawkins, Inc. annual purchase 350,000 pounds/year, $69,580
- Fluoride Mandate: Nebraska State Statute 71-3305 mandates for cities or villages over one thousand or more inhabitants (See Research Document Pg 3);
- Cities or villages (with some exceptions) shall add fluoride as “provided in the rules and regulations of the Department of Health and Human Services unless such water supply has sufficient amounts of naturally occurring fluoride as provided in such rules and regulations” https://nebraskalegislature.gov/laws/statutes.php?statute=71-3305
- Larger Nebraska communities that do not fluoridate;
- Grand Island, Hastings, North Platte, Norfolk, Scottsbluff, Beatrice, Lexington, York – Passed in 2008 after mandate Plattsmouth, Wisner, 2010 Saunders County, Wahoo (after approving fluoridation in 2008) https://nccd.cdc.gov/DOH_MWF/Reports/FlStatus_Rpt.aspx
- NE DHHS Oral Health Surveillance System Report, 2011 – 2020Nebraska communities with high levels of naturally occurring fluoride; none, all non-fluoridated communities have concentrations at 0.50 or below. https://nccd.cdc.gov/DOH_MWF/Reports/FlStatus_Rpt.aspx
- Nebraska industries emitting fluoride pollution;
- none, all non-fluoridated communities have concentrations at 0.50 or below. https://nccd.cdc.gov/DOH_MWF/Reports/FlStatus_Rpt.aspx
- Nebraska industries emitting fluoride pollution;
- Public utilities, corn and mineral production https://fluoridealert.org/researchers/overview-tri/ (see new link to EPA’s TRI Program site https://www.epa.gov/toxics-release-inventory-tri-program)

Additional Links
- Hujoel PP, Zina LG, Moimaz SA, Cunha-Cruz J. Infant formula and enamel fluorosis: a systematic review. J Am Dent Assoc. 2009 Jul;140(7):841-54. doi: 10.14219/jada.archive.2009.0278. PMID: 19571048.
- Release of NTP’s Fluoride Toxicity Report, March 15, 2023
- A judge’s ruling forced the Department of Health and Human Services to release the National Toxicology Program’s report on the toxicity of fluoride. Attorneys’ with the Fluoride Action Network negotiated this release of information.
- Scroll down to find March 15, 2023 post
“This review finds, with moderate confidence, that higher fluoride exposure (e.g., represented by populations whose total fluoride exposure approximates or exceeds the World Health Organization Guidelines for Drinking-water Quality of 1.5 mg/L of fluoride) is consistently associated with lower IQ in children. More studies are needed to fully understand the potential for lower fluoride exposure to affect children’s IQ.” A reviewer’s related comment, regarding limited studies at lower exposures, “as there are few studies that provide evidence of this for exposures in the low range. This is not to say that there is no association at these lower levels, there may very well be an association; just that these results cannot be generalized to lower levels of exposure. This is true with other neurotoxins as well, for example, we know that the associations between lead and IQ scores is even steeper at the lower levels of exposure, but early studies where exposure was high were not able to discern those associations.” Emphasis added.
DRAFT NTP Monograph on the State of the Science Concerning Fluoride Exposure and Neurodevelopmental and Cognitive Health Effects: A Systematic Review, September 2022
Page 13, Released March 15, 2023
City of Lincoln’s response to the fluoride exposure liability and neurodevelopmental and cognitive health effects:
Requested opinion: 4/11/2023, the following request was made to Mayor Gaylor Baird regarding the recent posting of the city’s 2022 Water Quality Report and the March 15, 2023 release of the DHHS National Toxicology Program’s Monogram on the State of the Science Concerning Fluoride Exposure and Neurodevelopmental and Cognitive Health Effects (NTP report). The email requested the Mayor’s opinion on the NTP report as it relates to fluoridation of the city’s water supply and the potential liability the city may incur from the findings. A hearing was held the same day in the ongoing federal lawsuit against the U.S. Environmental Protection Agency over the use of neurotoxic fluoridation chemicals. https://ntp.niehs.nih.gov/whatwestudy/assessments/noncancer/ongoing/fluoride/index.html, https://fluoridealert.org/articles/tsca-lawsuit-hearing-this-tuesday/
Response by City of Lincoln Transportation and Utilities
April 11, 2023
“Fluoridation of Lincoln’s water has been done since 1970. As we understand, fluoridation started following a vote of the people which is how communities dealt with deciding on this topic many years ago. In 2008, the State of Nebraska passed a law preventing communities with populations over 1,000 to repeal fluoridation. So, that leaves Lincoln being required to continue fluoridating its water and would require an act of the Nebraska Legislature to reverse.
It has been widely accepted that fluoridation prevents tooth decay and is supported by the American Dental Association. The Lincoln Water System must follow State of Nebraska drinking water regulations which currently requires a minimum fluoride level in its water supply.
If Federal regulations should require discontinuing use of fluoride, legislation would be necessary in Nebraska legislature and Lincoln would then follow the new Nebraska law.”
City of Lincoln, NE, Water Quality Report 2022 – see link to the city contract for Hawkins, Inc. on page 9.
Fluoride: Highest test result – 0.901 ppm, Range or Test Results – 0.899-0.901 ppm, Sample Date – 2022, Highest Level Allowed – 4 ppm, MCL Goal – 4 ppm.
Footnote: Fluoride is added in treatment to bring the natural fluoride level of about 0.4 ppm to the State recommended level of 0.8 – 1.5 ppm. LWS continuously monitors the fluoride level in the water.