Warning that EPA’s move to revise standards for particulate matter (PM) and ground-level ozone have “huge implications in terms of public health and the environment,” one of the nation’s leading experts on air pollution has urged policy-makers to “wait for the necessary science and bypass political expediency.”
Addressing a recent Washington Roundtable on Science and Public Policy sponsored by the George C. Marshall Institute, Robert F. Phalen warned of the dire consequences likely to result if science is not allowed to drive public health policy. The “great victories” science has achieved in controlling infections, nutritional problems, and heart disease, will be jeopardized, Phalen said, if premature actions take precedence over sound scientific research.
Phalen’s remarks are presented in “Living and Dying in Dirty Air: What the Science Tells Us,” a recent publication of the Marshall Institute.
Phalen is director of the Air Pollution Health Effects Laboratory, professor of Community and Environmental Medicine, and professor of Occupational and Environmental Health at the University of California, Irvine. His remarks coincided with EPA’s continued efforts to implement its controversial new standards on ozone and PM. The new rules are expected to throw nearly 700 counties across the country out of compliance with national air quality standards.
Phalen contends that EPA made a fundamental error in developing its new standards, relying on epidemiologic data that show only a weak association between exposure to increased amounts of PM and premature mortality. “It is important to note that these studies (particularly the frequently-cited Schwartz-Dockery-Arden study) relate to increments of change in air pollution, and not to levels,” he explained. “These increments are determined by averaging the three previous day’s air pollution levels and then comparing it to what you have on the day in question. This distinction between increments of change and levels is important, because the standards for particulate matter that have been proposed are for levels, but they are based on epidemiology which relates to increments.”
“One has to do with an incremental change in an aspect of the environment that may be causing a health problem, while the regulations are addressing what the levels should be in the environment,” he continued. “These are very different things.”
Having confused increments of change with levels of exposure, EPA compounded its error by placing so much stock in weak epidemiologic associations that may be nothing more than spurious, Phalen observed. His eight years’ experience as chairman of the Human Subjects Ethics Committee at the University of California School of Medicine taught him that, “Early associations were very rarely valid in the long term.”
Phalen reserved his harshest comments for EPA’s claim that the new standards will reduce asthma rates in children. Noting that genetic predisposition is the major cause of the disease, Phalen pointed out that a host of substances, in varying combinations, actually trigger the attacks. Those substances are mostly proteins (especially foreign proteins), pollens, molds, danders, insect dusts, many kinds of foods, and certain medications, such as aspirin.
“Claiming that the proposed air regulations will significantly decrease asthma is not only not responsible, but it can endanger lives, because people will not look at the real causes of asthma, and the real problems will be exacerbated. This is akin to false cancer cures–if people pursue them, they won’t seek the treatment that might really help them.”
Phalen contends that EPA failed to address other important questions in creating its new standards. How do the theoretical benefits of the new regulations stack up against the very real costs of the agency’s action? The nation’s dairy industry, a major contributor to public health, may be driven out of business as a consequence of the new standards, Phalen said. Cows, he noted, are not clean: They produce ammonia, which produces nitrates in the air. Phalen reported that representatives of California’s dairy industry are already contemplating leaving the state, which will be hard hit by EPA’s new rules.
The dairy industry is not the only “polluter” health-conscious Americans should worry about if the standards go into effect, Phalen warned. Society derives enormous benefits from diesel engines, which also produce air-borne particulates. Diesel engines transport food from farms to market; they power trains, ships, mining, and construction equipment. Power plants, too, emit particles and contribute to ground-level ozone–but they also heat and cool homes, workplaces, and hospitals.
“Science can be ignored, the needed research not be done, and decisions be made on other grounds,” Phalen concluded. “Personal or political fortune, advocacy, or politics, could determine health policy in this country. I’m really afraid of the position we are in right now.”