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Suggested Citation:"Attachment C." National Academies of Sciences, Engineering, and Medicine. 2021. Review of the Revised NTP Monograph on the Systematic Review of Fluoride Exposure and Neurodevelopmental and Cognitive Health Effects: A Letter Report. Washington, DC: The National Academies Press. doi: 10.17226/26030.
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ATTACHMENT C

This attachment summarizes the substantive issues raised in the committee’s previous report (NASEM 2020) concerning the general systematic review methods and the evaluation of the human evidence. Because NTP decided to base its conclusions on the human evidence, it did not re-evaluate the animal evidence to address the committee’s previous concerns. Instead, it added a disclaimer to the revised monograph and left the original text unchanged. For that reason, the committee’s concerns regarding the animal evidence are not listed here.

Committee Issue on Methods and Communication NTP Response
Role of OHAT Handbook unclear NTP added foreword to monograph and text to protocol to clarify relationship.
Details missing from protocol NTP added text to protocol and monograph to clarify literature search strategy and to clarify assessment of animal data.
Absence of exclusion–inclusion criteria from protocol No information provided.
Lack of justification for some decisions NTP added information to the monograph on SWIFT-Active screener to justify approach.
Inconsistencies between protocol and monograph NTP clarified text in protocol and monograph concerning critical confounders to evaluate.
Communication concerning how monograph can be used (or not) to inform water fluoridation concentrations No information provided.
Committee Issue on Evaluation of Human Evidence NTP Response
Potential for Biased Selection of Studies NTP conducted supplemental searches of Chinese databases and identified additional studies.
Lack of Independence of Studies NTP revised the monograph to indicate the multiple publications on the same population. However, when conducting the meta-analysis, NTP included more than one publication for a single study population in at least one case.
Inconsistent Application of Risk-of Bias Criteria NTP added Appendix 4.
Evaluation of Confounding Insufficient, Difficult to Understand, or Applied Inconsistently NTP revised text to identify clearly key confounders that applied to all study populations. NTP added Appendix 4.
Possibility of Exposure Misclassification NTP added Appendix 4.
Need for Further Consideration of Failure to Blind Examiners NTP added Appendix 4.
Flawed Measures of Neurodevelopmental and Cognitive Outcomes NTP verified lower risk-of-bias studies that did not provide direct evidence of imprecision or lack of blinding.
Lack of Rigorous Statistical Review NTP examined studies identified by committee and included discussion in Appendix 4.
Suggested Citation:"Attachment C." National Academies of Sciences, Engineering, and Medicine. 2021. Review of the Revised NTP Monograph on the Systematic Review of Fluoride Exposure and Neurodevelopmental and Cognitive Health Effects: A Letter Report. Washington, DC: The National Academies Press. doi: 10.17226/26030.
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Need to Juxtapose Results across Broadly Comparable Studies NTP conducted subgroup analyses as part of meta-analysis to address heterogeneity in the data and further analyze consistency of data.
Need to Consider Conducting Meta-Analysis NTP updated meta-analyses and conducted new meta-analysis using individual-level exposure data.
Lack of Support for Conclusion that Effects Occur at Higher Fluoride Doses NTP conducted dose–response analysis as part of meta-analysis.
Suggested Citation:"Attachment C." National Academies of Sciences, Engineering, and Medicine. 2021. Review of the Revised NTP Monograph on the Systematic Review of Fluoride Exposure and Neurodevelopmental and Cognitive Health Effects: A Letter Report. Washington, DC: The National Academies Press. doi: 10.17226/26030.
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Page 21
Suggested Citation:"Attachment C." National Academies of Sciences, Engineering, and Medicine. 2021. Review of the Revised NTP Monograph on the Systematic Review of Fluoride Exposure and Neurodevelopmental and Cognitive Health Effects: A Letter Report. Washington, DC: The National Academies Press. doi: 10.17226/26030.
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Page 22
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 Review of the Revised NTP Monograph on the Systematic Review of Fluoride Exposure and Neurodevelopmental and Cognitive Health Effects: A Letter Report
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In 2019, the National Toxicology Program (NTP) released the draft monograph Systematic Review of Fluoride Exposure and Neurodevelopmental and Cognitive Health Effects. Given the controversies surrounding the risks and benefits associated with fluoride exposure and to ensure the integrity of its evaluation, NTP asked the National Academies of Sciences, Engineering, and Medicine to review the draft monograph. The 2020 report Review of the Draft NTP Monograph Systematic Review of Fluoride Exposure and Neurodevelopmental and Cognitive Health identified deficiencies in the analysis of various aspects of some of the studies and in the analysis, summary, and presentation of the data in the draft monograph, provided many suggestions for improvement, and concluded that NTP had not adequately supported its conclusions.

At the request of NTP, Review of the Revised NTP Monograph on the Systematic Review of Fluoride Exposure and Neurodevelopmental and Cognitive Health Effects determines whether substantive concerns raised in the 2020 report have been sufficiently addressed by revisions of the monograph and whether the evidence presented by NTP in the revised monograph supports its conclusions.

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