Protect Public Health: EPA Should Tighten PM Standard

Jun 23, 2020

by Rachel McIntosh-Kastrinsky

The US EPA is required to review the fine particulate matter (PM2.5) standard every five years to consider whether it should be changed based on new scientific evidence. In April, EPA decided the standard did not need to change in contrast to the many recent studies showing adverse health impacts below the current standard. This includes one just put out by the EPA itself noting years of life lost for heart failure patients.

“By deliberately ignoring the recommendation of his staff and experts in PM science, the [EPA] Administrator has explicitly chosen to shirk his responsibility to protect the health of the American public,” says Daniel Costa, Sc.D., Former Director of US EPA National Program in Air, Climate, and Energy Research Program.

Clean Air Carolina strongly supports the tightening of the current National Ambient Air Quality Standard (NAAQS) for PM2.5 based on the clear evidence. Choosing not to revise to a more protective standard puts thousands of Americans at risk of adverse health outcomes, including death.

Please consider submitting formal comments urging EPA to update their PM2.5 standards to better protect our health. All public comments are due Monday, June 29. You can read our formal comments below.

—Clean Air Carolina Formal Comments—

June 8, 2020

Dr. Scott Jenkins
Senior Health Scientist
Health and Environmental Impacts Division
Office of Air Quality Planning and Standards
U.S. Environmental Protection Agency
Mail Code C504–06
Research Triangle Park, NC 27711

Re: Review of the National Ambient Air Quality Standards for Particulate Matter, Docket ID No. EPA-HQ-OAR-2015-0072

Dear Dr. Jenkins,

The Clean Air Act (CAA) and its Amendments (CAAA) mandate the use of the latest science in establishing National Ambient Air Quality Standards (NAAQS) for particulate matter (PM) and other so-called criteria pollutants. That science has been the foundation of 50 years of EPA policies to clean and protect the air we breathe.

The Administrator’s proposal, submitted on April 14, 2020, refuses to improve the NAAQS for PM and does not follow in the tradition of the NAAQS review and decision process as required under the CAA. The normal review process typically takes years to complete, but the Administrator’s deeply flawed process was done in a matter of months. This is insufficient time to consider the full body of diverse scientific evidence. Historically, the agency assembles a panel of expert scientists to help review the recent research and recommend appropriate pollution limits. This time, EPA Administrator Wheeler disbanded the expert panel and restricted the review of scientific studies using a Clean Air Scientific Advisory Committee (CASAC) that was unqualified, by their own admission, to independently review the collective science. As such, Clean Air Carolina feels strongly that the NAAQS as proposed does not adequately protect public health. As argued in greater length below, Clean Air Carolina supports a tighter standard as defined by the CASAC and PM Review Panel: the annual PM2.5 standard should be 8 µg/m3 and the 24-hour standard should be strengthened to 25 µg/m3.

Particulate matter has been shown repeatedly over the last 30 years to pose a real and imminent threat to public health with increases in mortality and morbidity at all exposure levels. Additionally, breathing PM can trigger asthma attacks[1]; cause lung cancer[2]; increase the risk of heart attacks and strokes[3]; damage lung tissue and airways[4]; increase hospital visits for respiratory and cardiovascular problems[5]; and contribute to cognitive decline such as dementia[6]. Evidence is mounting that PM may also impact pregnancy and birth outcomes, such as preterm birth, low birth weight, and fetal and infant mortality[7]; and as summarized and determined as causal – PM is deadly at levels below the current NAAQS of 12 µg/m3.[8] The 2019 Integrated Science Assessment (ISA) delineates the science that has led legitimate experts to conclude that PM impacts can be discerned at levels significantly below the current NAAQS. Indeed, the EPA science and policy staff who compiled and dissected the new science formally recommended a strengthening of the NAAQS to protect public health and save lives.

Presented at the 2019 ISA were U.S. and Canadian studies that provide striking, new evidence of premature deaths with PM2.5 levels at, or in some cases below 8 µg/m3.[9] Likewise, two expansive studies of U.S. adults on Medicare (over age 65) have shown that premature death occurs after daily particulate matter exposure within the current 24-hour NAAQS of 35 µg/m3 as well as with the annual below 12 µg/m3.[10],[11]

However, what is of particular concern is that the retention of the current NAAQS eradicates any margin of safety which is explicitly called for in the CAA. People with heart disease, high blood pressure, coronary artery disease, congestive heart failure and lung cancer and those who are obese (often among those in the Medicare elderly population) face an augmented risk that is simply ignored in Administrator Wheeler’s current proposal.[12] New evidence[13] shows that black, Asian, and Hispanic persons, and persons who were eligible for Medicaid (i.e., those of lower socioeconomic status), also have a higher estimated risk of death from any cause in association with PM2.5 exposure than the general population. These studies are notable among the ISA studies reviewed in composite, emphasizing the inadequacy of the current levels of the NAAQS and their failure to protect public health.

As we weather through months of stay-at-home orders and adjustments to life as usual, we encounter yet more evidence that outside factors affect the margin of safety patently ignored by the Administrator in his proposal. Studies have long shown varying degrees of enhanced risk to infection with air pollution. Now there is early evidence that air pollution, notably PM, may increase vulnerability to COVID-19 infections and may additionally increase the severity of the disease if individuals get sick. Recently, a study from Harvard’s School of Public Health found that an increase of only 1 µg/m3 in PM2.5 is associated with an 8% increase in the COVID-19 death rate.[14]  This is an early study but it shows the sensitivity of 21st century epidemiology which has been built on a foundation of hundreds of other studies carefully reviewed by the science community in peer review, the EPA ISA and policy staff, and by expert panels not selected for political alliance to the current administration in Washington.

In summary, Clean Air Carolina strongly supports the tightening of the current NAAQS for PM2.5 based on the clear evidence in EPA’s own ISA and the recommendation of EPA staff and expert panels. Choosing not to revise to a tighter NAAQS puts thousands of Americans at risk of adverse health outcomes, including death.

If you have questions please do not hesitate to reach out to us. Thank you for giving your utmost consideration to these comments.

Sincerely,

June Blotnick
Executive Director

[1] U.S. EPA. Integrated Science Assessment for Particulate Matter, December 2019. EPA/600/R-19/188.

[2] World Health Organization International Agency for Research on Cancer. Hamra GB, Guha N, Cohen A, Laden F, Raaschou-Nielsen O, Samet JM, Vineis P, Forastiere F, Saldiva P, Yorifuji T, and Loomis D. Outdoor Particulate Matter Exposure and Lung Cancer: A Systematic Review and Meta-Analysis. Environ Health Perspect. 2014: 122: 906-911.

[3] U.S. EPA. Integrated Science Assessment for Particulate Matter, December 2019. EPA/600/R-19/188.

[4] U.S. EPA. Integrated Science Assessment for Particulate Matter, December 2019. EPA/600/R-19/188.

[5] U.S. EPA. Integrated Science Assessment for Particulate Matter, December 2019. EPA/600/R-19/188.

[6] Peters R, Ee N, Peters J, Booth A, Mudway I, Anstey KJ. Air Pollution and Dementia: A Systematic Review. J Alzheimers Dis. 2019;70(s1):S145-S163. doi: 10.3233/JAD-180631.

[7] Liang Z, Yang Y, Qian Z, Ruan Z, Chang J, Vaughn MG, Zhao Q, Lin H. Ambient PM2.5 and birth outcomes: Estimating the association and attributable risk using a birth cohort study in nine Chinese cities. Environment International. Volume 126, May 2019, Pages 329-335

[8] U.S. EPA. Integrated Science Assessment for Particulate Matter, December 2019. EPA/600/R-19/188. . World Health Organization International Agency for Research on Cancer. Hamra GB, Guha N, Cohen A, Laden F, Raaschou-Nielsen O, Samet JM, Vineis P, Forastiere F, Saldiva P, Yorifuji T, and Loomis D. Outdoor Particulate Matter Exposure and Lung Cancer: A Systematic Review and Meta-Analysis. Environ Health Perspect. 2014: 122: 906-911.

[9] Shi I., et al. 2016. Low Concentration PM2.5 and mortality; estimating acute and chronic effects in population-based study. Environmental Health Perspectives, 124(1)46-52; Szyszkowicz M. 2009. Air pollution and ED visits for chest pain, American Journal of Emergency Medicine. 27(2): 165-168; Steib DM, et al. 2009 Air pollution and emergency department visits for cardiac and respiratory conditions: A Multi-city time series analysis. Environmental Health: A Global Science Access Source. 8(25):25; Weichenthal S. et al. 2016 Ambient PM2.5 and risk of emergency room visits from myocardial infarction: Impact of regional PM2.5 oxidative potential: a case-crossover study. Environmental Health. 15:46.; Weichenthal et al., 2016. ”PM 2.5 and emergency room visits for respiratory illness: effect modification by oxidative potential.” AJRCCM. 194(5): 577-586.

[10] Di Q, Dai L, Wang Yun, Zanobetti A, Choirat C, Schwartz JD, Dominici F. Association of Short-Term Exposure to Air Pollution with Mortality in Older Adults. JAMA, online December 26, 2017, doi: 10.1001/jama.2017.17923

[11] Di Q, Wang Yan, Zanobetti A, Wang Yun, Koutrakis P, Choirat C, Dominici F, Schwartz JD. Air Pollution and Mortality in the Medicare Population. N Engl J Med 2017; 376:2513-2522

[12] U.S. EPA. Integrated Science Assessment for Particulate Matter, December 2019. EPA/600/R-19/188.

[13] Di Q, Wang Yan, Zanobetti A, Wang Yun, Koutrakis P, Choirat C, Dominici F, Schwartz JD. Air Pollution and Mortality in the Medicare Population. N Engl J Med 2017; 376:2513-2522

[14] Wu X, Nethery RC, Sabath MB, Braun D, Dominici F. Exposure to air pollution and COVID-19 mortality in the United States: A nationwide cross-sectional study, 2020. medRxiv 2020.04.05.20054502; doi: https://doi.org/10.1101/2020.04.05.20054502

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