American Public Health Association Cites Deficiencies in Risk Analysis, 4-6-05
EPA’s draft risk assessment systematically underestimates the risk associated with particulate matter air pollution, according to testimony before the Clean Air Scientific Advisory Committee by Dr. John Balbus, on behalf of the American Public Health Association (APHA).
The top four criticisms of the draft risk analysis reasons cited by APHA are:
Number 4: It limits itself to too few geographic areas;
Number 3: It only uses a single day lag, instead of a distributed lag;
Number 2: The sensitivity analysis uses unsupportable thresholds; and
Number 1: It ignores significant health endpoints.
“These (and other) flaws are carried forward to recommend standards that do not sufficiently protect the public’s health, such as the false choice between tightened annual or 24 hour standards for PM2.5. Similar flaws lead to a recommendation to keep the thoracic particulate standard at the same level as under the current PM10 standard,” stated Dr. Balbus.
A full copy of the statement is attached.
Attachments
- Statement of American Public Health Association, 4-6-05
- apha-comments.pdf
Presentation by Dr. John Balbus at CASAC Meeting
