Testimony
of
Dr.
John
R.
Balmes
on
behalf
of
the
American
Thoracic
Society
I
am
John
Balmes,
MD,
Professor
of
Medicine
at
the
University
of
California,
San
Francisco
and
Professor
of
Environmental
Health
Sciences
at
the
University
of
California,
Berkeley
School
of
Public
Health.
I
am
an
attending
Physician
in
Pulmonary
and
Critical
Care
Medicine
at
San
Francisco
General
Hospital
and
I
conduct
research
on
the
health
effects
of
air
pollution.
I
am
presenting
comments
today
on
behalf
of
the
American
Thoracic
Society.
The
American
Thoracic
Society
is
a
medical
professional
society
with
over
13,000
members
who
are
dedicated
to
the
prevention,
diagnosis,
treatment
and
research
of
respiratory
illnesses.
The
American
Thoracic
Society
is
deeply
concerned
about
air
pollution,
both
as
an
underlying
cause
of
respiratory
illness
and
its
ability
to
cause
exacerbations
of
pre­
existing
respiratory
illness.

The
American
Thoracic
Society
will
submit
extensive
formal
comments
on
several
issues
in
the
EPA
proposed
rule.
However,
today,
I
will
limit
my
comments
to
issues
surrounding
the
proposed
standard
for
coarse
thoracic
particles.
This
standard
is
precedent­
setting
because
by
focusing
on
urban
areas
only,
it
assumes
that
sources
of
particles
outside
of
urban
areas
do
not
convey
any
increased
risk
to
health.

The
ATS
is
extremely
disappointed
that
EPA
has
proposed
that
the
coarse
thoracic
particle
standard
apply
to
urban
areas
only.
We
see
this
as
a
major
flaw
in
the
proposed
rule.
It
is
true
that
there
is
less
research
on
the
health
effects
of
exposure
to
coarse
thoracic
particles
than
on
those
of
fine
particles.
However,
there
is
no
research
that
shows
rural
particles
are
safe.
I
repeat,
there
is
no
research
showing
that
rural
particles
are
safe.

In
fact,
the
limited
available
evidence
seems
to
show
adverse
health
effects
from
exposure
to
coarse
particles
found
in
more
rural
areas.
For
example,
work
done
here
in
California
by
Cal/
EPA
investigators
using
data
for
a
10­
year
period
from
the
rural
Coachella
Valley
showed
a
greater
cardiovascular
mortality
risk
for
coarse
particles
than
for
fine
particles.
In
addition,
a
series
of
toxicological
studies
by
Becker
et
al.,
some
of
which
have
been
supported
by
U.
S.
EPA,,
have
demonstrated
greater
cytotoxicity
and
proinflammatory
effects
of
coarse
particles
than
fine
particles.
We
also
note
that
PM10
in
rural
areas
will
contain
particles
from
urban­
type
sources
­­
diesel
engines,
highways,
power
plants
and
other
industrial
facilities.
Limiting
application
of
the
daily
coarse
particle
standard
based
on
geographic
population
areas
is
not
supported
by
the
available
scientific
data.

Recommendation:
The
EPA
daily
coarse
thoracic
particle
standard
should
apply
to
both
urban
and
rural
areas.
The
ATS
is
also
deeply
concerned
about
the
EPA
proposal
to
stop
monitoring
coarse
thoracic
particles
in
rural
areas.
The
EPA
is
correct
in
recognizing
there
are
limited
data
on
the
health
effects
of
coarse
particles
in
rural
areas.
However,
the
appropriate
response
to
limited
data
is
not
to
stop
monitoring
altogether.
Rather
than
addressing
the
need
for
more
data,
suspending
monitoring
of
coarse
particles
would
ensure
that
there
will
be
a
continuing
lack
of
data
on
the
health
effects
of
exposures
to
coarse
particles
in
rural
areas.
EPA's
proposal
to
suspend
monitoring
in
rural
areas
is
the
equivalent
of
the
ostrich
burying
its
head
in
the
sand.

Recommendation:
EPA
should
continue
monitoring
of
coarse
particle
exposures
in
rural
areas.

The
ATS
is
equally
concerned
about
the
proposed
exemptions
of
particles
emitted
from
mining
and
agricultural
activities.
Again,
there
is
no
scientific
basis
for
saying
these
particles
are
safe
to
breathe.
In
fact,
mine
generated
dust
would
be
expected
to
contain
relatively
high
concentrations
of
silica
and
metals
that
are
known
to
be
toxic.
In
addition,
mines
and
agriculture
both
use
diesel
equipment
that
generates
toxic
particles.
Excluding
mine
and
agriculture­
sourced
particles
may
be
good
for
business
but
it
is
not
good
for
health
Recommendation:
EPA
should
regulate
all
coarse
thoracic
particles,
regardless
of
source.

The
American
Thoracic
Society
strongly
believes
that
federal
air
quality
standards
must
be
based
on
a
careful
review
of
the
available
scientific
knowledge.
The
role
of
the
Clean
Air
Scientific
Advisory
Committee
in
the
air
quality
standard­
setting
process
is
critical
to
ensure
such
a
careful
review.
In
the
case
of
the
proposed
PM
standard,
the
EPA
Administrator
has
chosen
to
reject
the
recommendations
of
CASAC
on
the
basis
that
the
committee
did
not
adequately
review
the
available
scientific
data.
While
the
ATS
respects
the
authority
of
the
Administrator
to
reject
the
advice
of
CASAC
for
policy
reasons,
it
is
a
dangerous
precedent
for
the
Administrator
to
do
so
by
impugning
the
integrity
of
the
committee's
scientific
review.
The
review
of
scientific
knowledge
conducted
through
the
Clean
Air
Act
process
that
leads
to
a
CASAC
recommendation
is
the
most
careful
and
deliberative
review
conducted
in
the
field
of
environmental
health.
CASAC
members
are
highly
qualified
scientists
who
are
thoroughly
vetted.
They
are
the
best
people
to
judge
the
state
of
scientific
knowledge
on
the
health
effects
of
a
criteria
pollutant.
For
an
EPA
administrator
to
cast
aspersions
on
the
quality
of
CASAC's
scientific
judgment
is
akin
to
stating
that
there
is
insufficient
scientific
evidence
of
global
warming.

Recommendation:
EPA
should
accept
the
recommendations
of
its
own
highly
qualified
scientific
advisory
committee.
On
behalf
of
the
entire
membership
of
the
American
Thoracic
Society,
I
would
like
to
thank
the
EPA
staff
for
the
opportunity
to
comment
on
this
important
rule.
