Disregarding and misrepresenting recommendations from their own scientists, the Environmental Protection Agency (EPA) recently finalized new air pollution standards that do not sufficiently protect public health. The new rules apply to fine particulate matter pollution, sources of which include agricultural activity, vehicle exhaust, and emissions from coal-fired power plants. Over 2,000 recent studies have linked particulate matter exposure to heart disease, respiratory ailments, and premature death.

Particulate Matter & Public Health
Fine particulate matter (or PM 2.5) consists of particles less than 2.5 micrometers in diameter, or about one third the diameter of a human hair. Sources of PM 2.5 pollution include agricultural activity, vehicle exhaust, and emissions from coal-fired power plants.

PM 2.5 has a profound effect on public health. It can easily become trapped in the human body and can have negative consequences for a person’s health. Over 2,000 peer-reviewed studies published since the current PM 2.5 standards went into effect in 1997 link fine particle pollution to strokes, heart disease, respiratory ailments, and premature death.

For example, one study showed that for each decrease of one microgram of soot per cubic meter of air, death rates from respiratory and cardiovascular diseases decrease by three percent (1). The EPA estimates that PM 2.5 kills 20,000 people and hospitalizes many more each year. It is important that fine particulate matter standards are low enough to prevent these severe negative health effects.

In 2005, the EPA’s Clean Air Scientific Advisory Committee (CASAC) recommended fine particulate standards with a maximum daily limit between 30 and 35 micrograms per cubic meter and an average annual limit between 13 and 14 micrograms. While the EPA’s initial proposal and final ruling lowers the maximum daily standards from 65 to 35 micrograms, they leave the average annual standard at 15 micrograms. According to the CASAC scientists, the average annual limit has a much more significant effect on public health.

A study funded by the EPA and the National Institutes of Health published in the Journal of the American Medical Association in March 2006 concluded that even an exposure level of 13.4 micrograms of PM 2.5 would put 11.5 million elderly Americans at increased risk of cardiovascular and respiratory disease. "These findings provide compelling evidence that fine particle concentrations well below the national standard are harmful to the cardiovascular and respiratory health of our elderly citizens," said National Institute of Environmental Health Sciences Director David A. Schwartz.(2)

The proposed standard does little to reduce the burden of death and disease from fine particle pollution. The number of people protected by the proposed standards increases by a mere 15 percent (from 56 million to 65 million). Meanwhile, more than 165 million people live in areas with PM 2.5 levels above levels research shows can adversely affect health.

Scientists Speak Out: EPA Misrepresented Scientific Research
By releasing this proposal the EPA is ignoring the recommendations of CASAC and its own staff scientists. It is highly unusual for the agency to disregard this committee’s advice.

Prior to the final ruling, CASAC wrote a letter to the EPA Administrator Stephen Johnson to re-explain the science behind their recommendations and to urge him to reconsider the proposed standards, a move that was unprecedented. A second scientific advisory committee, the Children’s Health Protection Advisory Committee, also wrote a letter to the EPA administrator claiming that the proposed standards did not adequately protect public health.

Furthermore, CASAC members alleged that the EPA had "twisted" or "misrepresented" the panel’s recommendations on a number of issues related to the proposed standards. According to the Los Angeles Times, Bart Ostro, an epidemiologist for the California Environmental Protection Agency, charged that "the EPA had incorporated 'last-minute opinions and edits' by the White House Office of Management and Budget that 'circumvented the entire peer review process.'" Ostro also said that the White House changes were "very close to some of the letters written by some of the trade associations" (3).

The Philadelphia Inquirer also weighed in on this issue: "reports have surfaced showing that the White House worked to cast doubt on the scientific need for tougher standards, making dozens of changes to the EPA's draft standards before the policy was made public. For instance, the White House removed a sentence from the policy stating that the air-quality standards 'may have a substantial impact on the life expectancy of the U.S. population'" (4).

The Final Rule
In September 2006, the EPA Administrator Johnson issued a final ruling that left the proposed levels unchanged.  No EPA administrator has disregarded CASAC’s advice in its almost 30 year history. 

To justify his decision to ignore the committee’s recommendations, Johnson stated that there had been disagreement within CASAC and that their endorsement of the stronger standards had not been unanimous.  However, 20 out of 22 members of CASAC's Particulate Matter Review Panel and 7 out of 7 standing members of the committee had voted in favor of the original recommendations. 

Within a few days of when the rule was finalized, CASAC members again voiced their objections in a letter to Johnson emphasizing that “there is clear and convincing scientific evidence that significant adverse human-health effects occur” at the new PM 2.5 standard and that it “does not provide an ‘adequate margin of safety … requisite to protect the public health’ (as required by the Clean Air Act).” 

The letter also noted that CASAC’s recommendations “were consistent with the mainstream scientific advice that EPA received from virtually every major medical association and public health organization that provided their input to the Agency, including the American Medical Association, the American Thoracic Society, the American Lung Association, the American Academy of Pediatrics, the American College of Cardiology, the American Heart Association, the American Cancer Society, the American Public Health Association, and the National Association of Local Boards of Health.”

The EPA Considered Industry Costs, Not Health Effects
The Clean Air Act requires the EPA to create National Ambient Air Quality Standards (NAAQS) for PM 2.5 and several other pollutants that protect human health based on the best available science, particularly the health of "vulnerable groups" including children and the elderly. When considering safe levels of pollution in the air that we breathe, the EPA is only allowed to consider health effects. Nothing else can be considered, including economic, or even environmental, effects. According to its own scientific advisors, the EPA did not use the best available public health science in issuing the new standards. 

Furthermore, an EPA analysis recently made public shows that an annual limit of 14 micrograms per cubic meter would result in high costs to industry. According to a recent Harvard study, appropriate tightening the annual PM 2.5 pollution standard would save an estimated 10,000 to 12,000 lives per year (5). 

Dr. Phillip Hopke and Dr. Bernard Goldstein, both members of CASAC, have warned that the EPA’s standards open up the agency to lawsuits by not setting the standard based on the best available science.

Rural Areas and Some Industry Exempted
A second rule sets standards for a larger air pollutant—coarse particulate matter. But these standards only apply in urban centers. This effectively exempts smaller towns and rural areas with populations under 100,000 from monitoring.

In addition, under the rule, the EPA won’t monitor coarse particulate matter levels in non-urban areas. In their letter to Stephen Johnson, CASAC had urged the EPA to keep monitoring particulate matter pollution in both rural and urban areas to help inform critical future research in this area.

Furthermore, the coarse particulate matter standards will not apply to all mining and agricultural operations—major beneficiaries of a relaxed rule.

The Future: Reducing the Role of Science
Most troubling of all, the EPA has proposed changes to the NAAQS that would challenge the Clean Air Act’s requirement of basing air pollution standards on the best available science. An EPA working group has recommended that the Staff Paper, a document which identifies the most policy-relevant science and presents results from quantitative risk assessments, be replaced by a "narrowly focused policy assessment document" that should "reflect the agency's views."(6) If these changes are adopted, future rulemakings on many types of air pollution would be subject to a lesser scientific standard. Click here for more information on this proposal.  

A Pattern of Political Interference in Science
In this case, the White House Office of Management and Budget stepped in to distort the science behind the health effects of fine particulate matter. This case is yet another example of where political appointees have seemingly misused science for political reasons.

Disregard for and misuse of science has proven to be a problem at the Environmental Protection Agency—on issues like mercury pollution and climate change—and at other federal government agencies that depend on independent scientific information to protect our health, safety, and environment.

We depend on our government to protect public health based on the best available scientific information. The new particulate matter standards do not reflect this principle and may seriously endanger public health.

Notes:
(1) Laden, F., et al. “Reduction in Fine Particulate Air Pollution and Mortality: Extended Follow-up of the Harvard Six Cities Study.” American Journal of Respiratory and Critical Care Medicine. 173 (2006): 667-672.
(2) NIEHS press release, Accessed 10/23/2006 at http://www.niehs.nih.gov/oc/news/particle.htm
(3) Wilson, Janet. “EPA Panel Advises Agency Chief to Think Again.” Los Angeles Times. February 4, 2006.
(4) “Time to Speak Up for Clean Air.” Editorial. Philadelphia Inquirer. March 8, 2006.
(5) Nesmith, Jeff. “EPA Advisors Unhappy over Air Particulates Decision.” Cox News Service. January 14, 2006.   
(6) CASAC comments on the NAAQS proposal, accessed 10/23/2006 at http://www.epa.gov/sab/pdf/casac_initial_comments_epa_naaqs_proc_rev_2006_final_ltr.pdf