TODAY’S STUDY: THE SCOURGE OF SOOT

Sick of Soot; How the EPA Can Save Lives by Cleaning Up Fine Particle Air Pollution
November 2011 (American Lung Association, Clean Air Task Force and EarthJustice)

Introduction

The U.S. Environmental Protection Agency (EPA) must soon update national health standards for fine particulate matter air pollution (PM2.5), commonly referred to as soot—a major cause of premature death and a widespread threat to those who suffer from lung and heart disease. The national health standards are critical tools that drive the cleanup of soot pollution across the country.

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According to the EPA, fine particle pollution:

➤ Causes early death (from both short- and long-term exposure);
➤ Causes cardiovascular harm (e.g., heart attacks, stroke, heart disease, congestive heart failure);
➤ Likely causes respiratory harm (e.g., worsened asthma, worsened COPD, inflammation);
➤ May cause cancer; and
➤ May cause developmental and reproductive harm.

The EPA will choose an updated national health standard from a range of possible options. In April 2011, staff scientists at the EPA made a series of recommendations to Administrator Lisa Jackson. These recommendations were based on a review of current research on the health effects of PM2.5, conducted by the EPA National Center for Environmental Assessment and vetted by the Clean Air Scientific Advisory Committee (CASAC), an independent body that offers technical advice to the EPA on ambient air quality standards. Health Benefits of Alternative PM2.5 Standards,1 a new analysis prepared for the American Lung Association, Clean Air Task Force and Earthjustice, examines these and other options and estimates the life- and cost saving potential for each scenario of reduced soot pollution.

Based on the analysis, the options currently under consideration at the EPA are not strong enough to protect public health with an adequate margin of safety. These organizations recommend that the EPA adopt a health standard at the strongest end of the range of options considered by the analysis—an annual standard of 11 micrograms per cubic meter (μg/m3) and a daily standard of 25 μg/m3.

Meeting this standard could prevent as many as 35,700 premature deaths every year, in addition to delivering major reductions in harm to people with heart and respiratory disease. Overall, the nation could benefit by as much as $281 billion every year from reduced costs associated with premature death and disease.

The Clean Air Act requires the EPA to follow science and protect public health. To comply with the law, it should adopt the PM2.5 health standard recommended by this report.

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Findings and Recommendation

If the EPA strengthens the current standard of 15 μg/m3 annually and a daily limit of 35 μg/m3 to the recommendation of this report—an annual limit of 11 μg/m3 and a daily limit of 25 μg/m3—the analysis2 predicts that, every year, Americans will be spared from as many as:

➤ 35,700 premature deaths;
➤ 2,350 heart attacks;
➤ 23,290 visits to the hospital and emergency room;
➤ 29,800 cases of acute bronchitis;
➤ 1.4 million cases of aggravated asthma; and
➤ 2.7 million days of missed work or school due to air pollution-caused ailments.

These health benefits—which are estimates based on improvements relative to current air quality conditions—far outweigh the benefits from any standard the EPA is currently considering.

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Overall, the number of premature deaths that could be avoided every year from the most protective standard is equivalent to the size of a sold-out crowd at Fenway Park, Boston’s historic baseball stadium. The same epidemiological study used in Figures 1, 2 and 3 found that the current standard—15 μg/m3 (annual) and 35 μg/m3 (daily)—could prevent up to 5,240 premature deaths every year. Strengthening the soot standard to 13 μg/m3 (annual) and 35 μg/m3 (daily), the weakest option that the EPA is considering, could prevent 2,950 additional premature deaths and be important progress. Yet, adopting the standard recommended by this report could prevent an additional 30,460 premature deaths every year—more than 10 times the current number. To maximize the potential of these important health protections to prevent premature death and illness, it is clear that the EPA must set a strong soot standard of 11 μg/m3 (annual) and 25 μg/m3 (daily).

The health benefits bring major financial benefits as well. Strengthening the annual PM2.5 standard to 11 μg/m3 and the daily standard to 25 μg/m3 will lead to economic benefits for the American public of $281 billion every year from reduced costs associated with premature death and disease.

While health benefits will be distributed across the nation, 10 major metropolitan areas stand to benefit significantly.

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To estimate these health and economic benefits, recent air quality data from the EPA’s monitoring network were incorporated into the same computer modeling program that the agency uses in its own regulatory impact analyses. This analysis, however, goes beyond the findings published in the EPA’s Quantitative Health Risk Assessment for Particulate Matter 6 in several important respects:

➤ It is national in scope. The EPA’s analysis only focuses on 15 urban areas in the continental U.S.
➤ It examines a wider range of daily and annual health standard combinations than the EPA has considered.
➤ It uses more current data. The air quality monitoring data used in this report comes from 2007–2009, whereas the EPA risk assessment, which was completed in 2010, relied on older data from 2005–2007. The more current data used in this report are closer to today’s actual air quality conditions. Air quality has improved considerably in recent years due to a number of factors, including cleaner cars entering the fleet and the economic downturn. Consequently, it should be easier for the nation to meet the health standard recommended by this report because current conditions are in fact closer to that standard than the EPA’s older modeling has shown.

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Why the Environmental Protection Agency Must Act Now

The Clean Air Act directs the EPA to review particulate matter standards every five years to consider the latest scientific evidence and ensure that public health is being adequately protected.7 The last review ended in October 2006, which means the EPA should have completed the current review by October of this year.

To follow the Clean Air Act, the EPA needs to act promptly and choose the most protective standards. Despite recent improvements to air quality, soot still poses a major threat to public health. As a result, the existing standards—an annual limit of 15 μg/m3 (established in 1997) and a daily limit of 35 μg/m3 (revised in 2006)—fail to protect the public from serious, life-threatening risks.

Powerful evidence for this conclusion showed up in the EPA’s most recent review of the scientific research on particulate matter.8 The agency enlisted the help of a panel of expert scientists, the Clean Air Scientific Advisory Committee (CASAC), to review the evidence—in particular, studies published between 2002 and 2009.

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From this review, the agency concluded that fine particle pollution:

➤ Causes early death (both short- and long term exposure);
➤ Causes cardiovascular harm (e.g., heart attacks, stroke, heart disease, congestive heart failure);
➤ Likely causes respiratory harm (e.g., worsened asthma, worsened COPD, inflammation);
➤ May cause cancer; and
➤ May cause developmental and reproductive harm.

In April 2011, the EPA’s scientific staff recommended to the administrator that the PM2.5 health standards be strengthened to adequately protect against avoidable death and disease.9 But none of these recommended standards (see red bars in Fig. 1 and Fig. 2) go far enough. To best protect public health, the agency should pursue the standard recommended by this report: an annual limit of 11 μg/m3 and a daily limit of 25 μg/m3.

The EPA’s pending action is also required by a 2009 court decision won by Earthjustice on behalf of the American Lung Association, Environmental Defense Fund and National Parks Conservation Association. The court ruled the soot standards adopted in 2006 by the Bush Administration deficient, and sent them back to the EPA to ensure adoption of standards adequate to protect public health. The court concluded that the EPA had ignored the advice of its own scientists—the Clean Air Scientific Advisory Committee—who recommended that the annual average PM2.5 standard needed to be strengthened to prevent sickness and premature death…

Given the high dangers associated with short and long-term exposure to PM2.5, the EPA needs to set a strong standard to protect health, namely an annual limit of 11 μg/m3 and a daily limit of 25 μg/m3. The evidence is even stronger now than in 2006 when the EPA failed to follow the recommendations of the CASAC to set a much more protective annual standard.

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The Clean Air Act and EPA’s Responsibility to Protect Public Health

The Clean Air Act provides a science-based approach to set and meet public health standards that has allowed the nation to achieve much cleaner air. The daily (24-hour) standard for fine particle pollution works in combination with the annual standard to set the official goals for cleaning up soot pollution levels all across the nation. Once the EPA sets the standards, the federal government and the states work to develop a plan to cut soot pollution sufficiently to meet the standards.

The Clean Air Act requires that the EPA protect public health with an adequate margin of safety. In setting or revising the health-based air quality standards, the EPA cannot consider the economic impact of the standard—only the impact on public health.

Instead, economic factors are used in determining how to clean up the pollution. The Clean Air Act allows the EPA to consider costs in setting some pollution control requirements and states develop local plans to determine the best way to cut pollution in each community.

Predictions that strong clean air standards will drag the economy down have consistently proven false. Total emissions of six major air pollutants, including particulate matter, have decreased by more than 41 percent over the past 20 years — in no small part because of the Clean Air Act—while gross domestic product (GDP) over the same period increased by more than 64 percent.50 Additionally, the economic benefits of reducing soot and smog pollution are projected to reach $2 trillion in 2020.51

Given the mandate to protect public health, it is clear that the EPA must set standards that provide the greatest protection, which means going beyond the options currently under consideration. The EPA should set an annual standard of 11 μg/m3 coupled with a daily standard of 25 μg/m3.

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Summary

The EPA is required by the Clean Air Act to protect public health with an adequate margin of safety. To do so, the agency should strengthen the national standard for fine particulate matter to an annual standard of 11 μg/m3 coupled with a daily standard of 25 μg/m3. This standard could prevent as many as 35,700 premature deaths every year, significantly more than any of the standards that the EPA is currently considering. It will also prevent illness, tens of thousands of hospital visits and millions of days of lost productivity, while providing up to $281 billion annually in benefits associated with reducing premature death and disease.