Lung Association: CD & Staff Paper Don’t Define Levels at which Health Effects Occur, July 11, 2001
The American Lung Association® criticized EPA’s draft Criteria Document and Staff Paper for failing to provide a clear analysis and discussion of the air pollution levels at which adverse effects were observed in health studies, in comments filed July 11, 2001.
The comments also included an original analysis which demonstrate that neither the annual average standards nor the 24-hour standard protect people in many cities from dangerous short-term excursions of air pollution.
When EPA estalished fine particle standards in 1997, it premised the decision to set weak 24-hour standards on the assumption that the 24-hour standards would work in tandem with the annual average standards, and that the annual average standards would be the controlling standards.
In other words, the assumption was that the annual average standards would be sufficient to protect against high short-term concentrations. This assumption is now proven false by the American Lung Association® analysis.
The laxity of the 24-hour standard is underscored by EPA’s 1999 rulemaking to establish a level for public notification of unhealthy concentrations under the Air Quality Index (AQI) program. Under this regulation, localities must notify the news media and the public that air quality has reached levels unhealthy to sensitive populations when 24-hour PM2.5 concentrations exceed 40.5 micrograms per cubic meter.
In contrast, the 24-hour NAAQS for fine particles in 65 micrograms per cubic meter.
A copy of the American Lung Association’s detailed written comments and its analysis are attached.
Attachments
- Unprotected areas
- analysis2.xls
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- ALA Comments on CD and Staff Paper 7/11/01
- pm-criteria-document-comme.doc
ALA Comments on CD and Staff Paper 7/11/01
