Lung Association Comments on Fifth Draft of Integrative Synthesis, September 30, 2004
The American Lung Association has filed a formal objection to EPA’s dropping of several key tables from the fifth draft of the Integrative Synthesis of the PM Criteria Document.
EPA dropped an appendix from the chapter which contained three tables presenting “Key Quantitative Estimates of Relative Risk for Particulate Matter-Related Health Effects
Based on Epidemiologic Studies of U.S. and Canadian Cities.” The tables included important information not found in such a succinct form in
earlier chapters.
Specifically, the tables detailed effect size estimates, by health endpoint, from the key North American epidemiological studies, and identified the mean concentration levels and ranges in these studies for each pollutant of
concern: PM10, PM2.5, and PM10-2.5. Included in these tables were the results of the studies deemed so important that they were subject to extensive reanalyses.
In comments to EPA, Joseph Bergen, Executive Vice President of the Lung Association stated: “The information in these tables is absolutely critical to the purpose of the CD and to the interpretation of the scientific evidence. Early on, the Lung Association advocated for the Criteria Document to include information on
the concentration levels recorded in epidemiological studies.”
The information detailed in the tables clearly indicates that adverse health effects—
morbidity and mortality—are occurring at levels below the current 24- hour and annual
average standards for PM2.5.
A copy of the comments is attached.
Attachments
- ALA Comments on PM CD, September 30, 2004
- ala-comments-on-fifth-draf.pdf
ALA Comments on Fifth Draft of Integrative Synthesis Chapter
