ALA Comments on Ozone Criteria Document, 4-29-05

The American Lung Association has filed extensive comments on EPA’s first draft Criteria Document on Ozone.

Given the serious lack of federal funding for ozone health research over the last eight years, the large number of new scientific studies available for review in the draft Criteria Document (CD) is impressive. The draft CD is thorough and inclusive of almost all major new studies of interest, including relatively recent publications. “We agree with the fundamental conclusion that short-term exposures to ozone are causally related to respiratory mortality and morbidity,” state the comments. The comments note some specific omissions which should be covered, and cite some important recent studies that should be included in the next draft.

In addition, the comments raise concerns with the cautious interpretation of the recent literature. “We find that evidence of serious adverse effects is sometimes downplayed. Some major new studies including those with policy significance are excluded. Emerging evidence of potential effects of ozone on new health endpoints such birth defects and genotoxicity are minimized. A series of new toxicological studies demonstrating remodeling of the airways is relevant to consideration of chronic effects. Major advances have been made in assessing the long-term effects of ozone since the last review, but this body of work is characterized as a ‘very limited database,’” state the comments.

The comments are attached.

Attachments

ALA Comments on Ozone Criteria Document
final-ala-comments-on-ozon.pdf
Comments on First Draft CD, 4-29-05