Comments
on
USEPA
PM
Proposal
March
8,
2006
Bart
Ostro,
Ph.
D.,
Chief
Air
Pollution
Epidemiology
Section
Office
of
Environmental
Health
Hazard
Assessment
California
EPA
Proposed
EPA
Standards
Ignore
Best
Available,
Peer­
reviewed
Science
°
EPA
overstates
the
uncertainty
and
misrepresents
the
scientific
consensus
°
EPA
needs
to
incorporate
the
findings
from
recent
long­
term
exposure
studies
°
EPA
needs
to
consider
the
public
health
costs
of
less
stringent
standards
and
the
delay
in
attainment
EPA
has
overstated
the
uncertainty
and
misrepresented
the
scientific
consensus
°
FRN
includes
statements
not
supported
by
either
the
EPA
Staff
Paper
or
CASAC
review
°
FRN
minimizes
multi­
year,
independent
HEI
reanalysis
of
ACS
and
Harvard
6­
City
data
°
FRN
contradicts
itself:

p2631
 
education
not
a
confounder
in
ACS
p2652
 
ACS
can't
be
used
since
potential
confounding
or
effect
modification
of
education
not
taken
into
account
EPA
needs
to
incorporate
the
findings
from
recent
long­
term
exposure
studies
P
2652
 
the
Administrator
believes
the
principal
basis
for
selecting
the
appropriate
level
of
an
annual
standard
should
be
the
evidence
provided
by
the
long­
term
studies,
in
conjunction
with
judgments
concerning
whether
and
over
what
range
of
concentrations
reported
associations
are
likely
causal 
New
Studies
on
Long­
term
PM2.5
Exposure
°
ACS
in
LA
(
Jerrett
2005)

°
Mortality
from
heart
failure,
cardiac
arrest,

ischemic
heart
disease
(
Pope
2004)

°
Cardiovascular
mortality
(
Laden
2006)

°
Mortality
in
the
Netherlands
(
Hoek
2002)

°
PM2.5
and
CP
mortality
in
SDA
women
(
Chen
2005)

°
Increased
carotid
intima­
media
thickness
(
Kunzli
2005)

°
Plaque
development
in
animals
(
Sun
2005)
PM2.5
Concentrations
in
LT
Studies
(
ug/
m3,
mean
minus
one
s.
d.)

°
Pope
(
95):
13.1
°
Pope
(
02,04):
1979
­
1983:
16.5
°
Pope
(
02,04):
1999
­
2000:
11
°
Chen
(
05):
19.2
°
Filleul
(
05):
~
13
BS
°
Sun
(
05):
10.6
(
3.4):
7.2
°
Dockery
(
93):
mean
=
18
°
Laden
(
06):
mean
=
14.8
PM2.5
Concentrations
in
LT
Studies
(
ug/
m3,
mean
minus
one
s.
d.)

°
Pope
(
95):
13.1
°
Pope
(
02,04):
1979
­
1983:
16.5
°
Pope
(
02,04):
1999
­
2000:
11
°
Chen
(
05):
19.2
°
Filleul
(
05):
~
13
BS
°
Sun
(
05):
10.6
(
3.4):
7.2
°
Dockery
(
93):
mean
=
18
°
Laden
(
06):
mean
=
14.8
(
NOTE:
Recent
exposures,
monitor
sites,
treatment
of
confounders)
EPA:
Long­
term
Studies
Too
Uncertain
National
Research
Council
(
2002):

P
126:
Even
great
uncertainty
does
not
imply
that
action
to
promote
or
protect
public
health
should
be
delayed 
The
potential
for
improving
decisions
through
research
must
be
balanced
against
the
public
health
costs
incurred
because
of
delay
in
the
implementation
of
controls.
EPA
Needs
to
Consider
the
Public
Health
Costs
of
Their
Decisions
°
New
studies
(
with
better
exposure
metrics)

indicate
that
PM2.5
effects
on
mortality
may
be
twice
as
high
as
ACS
study.

°
Using
ACS,
OEHHA/
ARB
analysis
indicates
that
moving
from
current
levels
to
12
µ
g/
m3
results
in
6,500
fewer
premature
deaths
per
year
in
California.
Therefore,
based
on
the
available
scientific
evidence,

we
urge
that
EPA
promulgate
lower
standards
than
those
originally
proposed
for
both
fine
and
coarse
particles
