On the eve of the fifth anniversary of the establishment of NAAQS for fine particles on July 18, 1997, the American Lung Association® filed comments on EPA’s third external review draft of the Criteria Document for Particulate Mater.
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EPA has proposed to develop a quantitative risk analysis for inclusion in the Staff Paper on particulate matter.
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“The current fine particle standard of 65 micrograms per cubic meter does not protect Denver area residents from the acute health effects of PM2.5 and does not require any reduction in fine particle emissions in the Denver region,” states a letter to EPA from the City and County of Denver’s Department of Environmental Health.
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“Suggestions have been made by some that PM-induced mortality strikes the “weakest” individuals, who might have died within a short period anyway. See, e.g., Brief of American Trucking Associations in American Trucking Assns. v. Browner, Sup. Ct. No. 99-1426, at 13, 19.”

“This attempt to impose a crude social Darwinism on the Clean Air Act is morally repugnant and must be rejected,” states Howard Fox, Earthjustice Attorney, in comments filed with EPA July 12, 2001.
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The California Air Resources Board (CARB) is calling for EPA to consider a one-hour standard for PM, and to establish continuous monitoring requirements to enforce it.
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“Public health professionals have a history of taking appropriate actions to protect the public’s health when the scientific evidence is sufficient to warrant serious concern. We’ve learned the value of not waiting until absolutely conclusive evidence is available,” testified Dr. Cindy Parker, MD, MPH, of Physicians for Social Responsiblity (PSR) before CASAC on July 23, 2001.
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Children are especially susceptible to air pollution. The airways of young children are smaller than those of adults, explain comments filed by the Children’s Environmental Health Network (CEHN) on EPA’s draft PM Staff Paper.

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“Strong air quality standards are the first step to alleviate the suffering of children, the elderly, and people with heart conditions and respiratory diseases such as asthma…” stated Anthony J. DeLucia, PhD, President-Elect of the American Lung Association® in testimony before EPA’s Clean AIr Scientific Advisory Committee.
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The American Lung Association® believes new scientific information supports reaffirming the annual average fine particle standard, strengthening the 24-hour fine particle standard, and setting meaningful new standards for coarse particles, according to testimony presented before the Clean Air Scientific Advisory Committee (CASAC) meeting on July 23, 2001.
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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.
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