From:
"
Johnston,
A.
Todd"
[
ajohnston@
nma.
org]

Sent:
07/
26/
2006
12:
21
PM
To:
Michael
Catanzaro
Subject:
Assessment
of
New
Studies
on
Coarse
PM
Mike,

As
you
know,
we
do
not
believe
the
scientific
data
indicates
that
regulation
of
coarse
PM
is
warranted
under
the
NAAQS.
CASAC
and
EPA
Staff
repeatedly
characterized
the
science
supporting
PMc
regulation
as
"
weak,"
and
"
uncertain."
This
is
reflected
in
the
agency's
proposal
where
the
agency
contemplates
an
"
alternative
view"
of
the
science
and
discusses
the
option
of
not
adopting
a
coarse
PM
standard.

We
understand
that
EPA
is
now
pointing
to
a
number
of
"
newer"
studies
to
support
its
claim
that
coarse
PM
should
be
regulated.
We
asked
Dr.
Jonathan
Borak,
with
Yale
University's
School
of
Medicine,
to
review
and
provide
comment
on
those
studies.
Thus
far,
he
has
been
able
to
review
three:

*
Schins
RPF
et
al.
(
2004):
Inflammatory
effects
of
coarse
and
fine
particulate
matter
in
relation
to
chemical
and
biological
constituents.
Toxicology
and
Applied
Pharmacology
195:
1­
11.

*
Veranth
JM
et
al.
(
2004):
Inflammatory
cytokines
and
cell
death
in
BEAS­
2B
lung
cells
treated
with
soil
dust,
lipopolysaccharide,
and
surfacemodified
particles.
Toxicological
Sciences
82:
88­
96.

*
Veranth
JM
et
al.
(
2006):
Correlation
of
in
vitro
cytokine
responses
with
the
chemical
composition
of
soil­
derived
particulate
matter.
Environmental
Health
Perspectives
114:
341­
349.

With
respect
to
these
studies,
Dr.
Borak
concludes:
"
these
studies
indicate
the
complexity
of
understanding
the
physiological
response
to
particulate
exposures.
They
explore
the
underlying
mechanisms
that
might
explain
those
responses,
but
their
study
methods
do
not
reflect
the
reality
of
human
inhalational
exposure,
they
administered
doses
that
far
exceeded
those
associated
with
realistic
ambient
exposures,
and
they
can
not
be
readily
extrapolated
to
such
ambient
exposures .
These
studies
may
provide
a
basis
for
better
understanding
particulate
toxicity
and
they
certainly
deserve
follow­
up
study,
but
they
can
not
currently
serve
as
the
basis
for
setting
human
exposure
limits."

Dr.
Borak's
written
comments
are
attached
for
your
review.

Dr.
Borak
will
continue
to
look
at
these
and
other
studies
recently
identified
in
the
interagency
review
process
recent,
and
EPA's
recent
Federal
Register
notice,
as
supporting
the
proposition
that
a
coarse
PM
NAAQS
is
necessary
to
protect
public
health.
We
submit
that
an
objective
reading
of
the
science
does
not
support
EPA's
theory.
At
issue
here
is
whether
the
science
meets
the
legal
standard
for
setting
a
NAAQS.
We
believe
that
the
weakness
and
arbitrariness
of
the
underlying
facts
and
science
renders
the
body
of
evidence
in
support
of
a
standard
incapable
of
meeting
the
legal
requirement
for
setting
a
standard
for
ambient
exposure
to
coarse
particles.

I
will
forward
the
results
of
his
additional
assessments
as
soon
as
possible.

Todd
Johnston
National
Mining
Association
202­
463­
2668
