Lung Association Suggests Refinements to EPA’s PM Risk Assessment Methodology, February 27, 2002

EPA has proposed to develop a quantitative risk analysis for inclusion in the Staff Paper on particulate matter.

The risk analysis is an important component of the Staff Paper because it can enhance understanding of the potential magnitude of PM health effecs and elucidate the effect of alternative levels and forms of the National Ambient Air Quality Standards.

The results of the risk assessment are highly sensitive to inputs and assumptions. The American Lung Association® filed comments on February 27, 2002suggesting refinements to the proposed methodology.

The Lung Association comments focused on:

– the need to broaden the geographic scope of the analysis

– support for the use of long-term studies for the mortality risk assessment

– the need to analyze alternative forms of the standard

– the need to broaden the analysis of morbidity effects

– opposition to exclusion of certain monitors form the analysis of air quality

– support for projecting risks down to background levels

– support for a coarse particle risk analysis

A copy of the comments is attached.

Attachments

2-27-02 ALA RA Comments
alacommentspm-riskass.doc
ALA Comments on PM Risk Analysis Methodoloy