The Clean Air Act 1970 is the law by which the Environmental Protection Agency (EPA) regulates air pollutants. The act has been amended, but it remains the enabling legislation for federal air pollution standard setting. The original law included language that specifically directed EPA to regulate air pollution without regard to economic impacts: protection of human health was to be the only concern of the agency when setting standards for ambient levels of air pollutants.

Ozone, particulate matter, nitrogen dioxide, carbon monoxide, sulfur dioxide and lead were specifically named in the 1970 legislation as pollutants to be regulated by national ambient air quality standards (NAAQSs) set by EPA. Each NAAQS was to be reviewed by the agency every five years, and revised if necessary to keep current with prevailing scientific understanding of pollution and health. Since 1970, individual NAAQSs have changed only twice: in 1979 and 1987.Reviews of NAAQSs have been done during this period, although the ozone standard was not reviewed in the late 1980s despite the law's requirement.

In November 1996, EPA proposed to tighten the NAAQSs for fine particulate matter (PM) and for ground level ozone. PM consists of fine particles suspended in air--PM looks like dust, haze or sooty smoke. It comes from emissions from all kinds of combustion, as well as from the air pollutants sulfur dioxide, nitrogen oxides, and volatile organic compounds. Ground level ozone forms when sunlight acts on nitrogen oxides and volatile organic compounds emitted from industrial plants and motor vehicles, as well as other sources.

The proposed standard for PM would control particles of 2.5 microns or smaller (PM 2.5) in concentrations of 50 micrograms per cubic meter per day. The current standard for PM is for PM of 10 microns or smaller at 150 micrograms per cubic meter per day. (EPA's proposal included maintenance of the PM 10 standard, while adding the new PM 2.5 standard.) The proposed standard for ground level ozone (0.08 parts per million per hour) would be a substantial reduction from the current 0.12 parts per million per hour standard. The newly proposed ozone standard is identical to a standard that was proposed under the Clean Air Act in the early 1970's, when the pollution-control technology industry was in its infancy.

In announcing the proposed changes, EPA Administrator Carol Browner said," In the Clean Air Act, Congress required EPA to review and incorporate the best available science into public health standards to protect Americans from air pollution. The EPA proposal would provide new protection to nearly 133 million Americans, including 30 million children."

EPA estimates that many health benefits would be realized from adopting the proposed new standards. The principal beneficiaries, in the agency's estimation, would be the elderly (especially those with heart and lung disease), those with lung disorders (including asthma), and children. Benefit measures cited by the agency include lives saved (20,000), fewer hospital admissions (9000) and "even greater reductions in emergency room admissions," fewer cases of chronic bronchitis (60,000), fewer incidents of aggravated coughing and difficult breathing in children (250,000), and fewer incidents of aggravated asthma in children (250,000), and fewer cases of "significant breathing problems" (1.5 million).

The agency arrived at these conclusions in consultation with the Clean Air Scientific Advisory Board, a scientific review body mandated by Congress under the Clean Air Act 1970. Separate panels (one for each pollutant) of advisors were convened to review the scientific literature. Eighty-six studies of PM and human health were reviewed; 185 of the latest studies on ozone and health were surveyed.

Strong reservations about the proposed standards were voiced by those whose pollutant-related activities would be affected by the new rules. _Environmental Science & Technology_, a publication of the American Chemical Society, noted that industry groups from utilities, oil refiners, manufacturers and others had "formed a coalition and approached members of Congress and several federal agencies with pleas that the standards be left alone." A high-ranking official of the American Petroleum Institute wrote in the Washington [DC] Times:"The new standards are unnecessary and would impose high costs on Americans everywhere while providing little apparent benefit." Mobil Corporation, in an ad in The Wall Street Journal, expressed skepticism that the new standards would result in significant improvements in human health and the environment. The NRDC reported that the changes were under attack by a "500-member industry coalition, 100 Members of Congress, and a dozen Governors." The American Chemical Society, in contrast, reported that the chemical industry was not overly concerned about the changes.

In announcing the proposed new standards, EPA opened a public comment period. This period was extended for an additional period in order to allow stake-holders to file comments. Excerpts of the comment submitted by HEAL's Governing Board can be found in " From HEAL," this issue.

Amendments to the Clean Air Act were passed in 1990 that require EPA to prepare two reports. One covers the costs incurred so far in regulating air pollution under the Clean Air Act. The other was to estimate the costs of the new stricter proposed standards for ozone and PM. In the first report, EPA claimed that the controls implemented under the Clean Air Act since 1970 had returned $45 for each $1 spent. Administrator Browner emphasized this point, saying, "Over the past generation, the gross domestic product has increased 99%, while emissions of the nation's six major air pollutants declined by 29%. Clearly, we do not need to choose between our health and our jobs. Economic growth and environmental protection can go hand in hand. A healthy economy helps us achieve a healthier environment; a healthy environment helps to build a stronger economy."

EPA noted in late 1996 that audited air quality data indicate that the largest gains in improved air quality have come from reductions in sulfur dioxide (down 37% in the last 10 years, with a 17% reduction in the last year audited), that nitrogen dioxides had had their largest single-year drop in 1994-95, that lead levels remained very low in all urban areas, and even particulate matter declined slightly. (For ozone, the ten year trend was downward, although 1995's hot summer resulted in an upward bump in ozone levels for that year.)

At the same time, however, EPA and others have noted that not everyone has benefited equally from these improvements. In 1995, 80 million Americans lived in counties that did not meet existing air quality standards for at least one air pollutant regulated under the Clean Air Act (down from 115 million in 1992, 121+ million in 1988).

Despite the Clean Air Act's requirement that air pollution be regulated for health only, without regard for economic consequences, a new law passed by Congress in 1996 (the Small Business Regulatory Enforcement Fairness Act) may make EPA's report on projected costs of the new standards crucial for its final implementation. The new law enables Congress to veto any new rule that will cost more than $100 million per year to implement. EPA estimates that the new PM 2.5 standard would cost $14 billion per year. Anti-regulatory sentiment, which includes industry self-interest, states concerned about tourism, and even "no regulation without representation" concerns, may have more political weight than the concerns of environmentalists and others who support federal regulation of air pollutants.

Supporters of reductions in air pollution for the sake of human health remain convinced of the soundness of their position. Opponents remain unconvinced that the currently-available science justifies the proposed new standards. A decision on the new rules is expected by late 1997. And even if the rules are approved, they would not go into effect immediately: The proposed rule for ozone would be fully in effect by the year 2000, while the deadline for the new PM standard would be 2002.

                                    -- Public Information Committee, Human Ecology Action League, Inc., (HEAL®)

Staff, The Human Ecologist
 

At a Glance

Perspective: Environment and health

Quotable (1)

• "Problems with human health and problems within the environment are , in most cases, so intertwined as to be inseparable. Problems within the environment may not become apparent until many years after their initiation or until human health is affected. Resolving these problems requires an understanding of the relationships between individual components of the environment. In other words, it is necessary to encompass all areas of environmental health, so that human health issues may be recognized before major health problems become established. Only when all areas of environmental health are considered can the interdependence of the environment and human life be recognized." --Gary E.R.Hook and George Lucier, Editors-in-chief, _Environmental Health Perspectives_ . In _Twenty Years of Environmental Health Research_ ( Washington DC: DHHS-PHS-NIH-NIEHS 1993).

Quotable (2)

• The Agency for Toxic Substances and Disease Registry noted, "Exposures to toxic substances can affect children's growth and development, and many harmful substances can be more easily absorbed by children's immature body tissues, causing severe illness...."

Air pollution and health

• Pollutants...
• 30,000 to 100,000 US facilities emit air toxics. Such facilities include chemical plants, steel mills, utilities, refineries, textile and furniture manufacturing operations, pulp and paper mills, dry cleaners, and others. J.Dexter Peach, _Toxic Substances: EPA 's chemical testing program has not resolved safety concerns._ US GAO, June 1991
• 15,000 airborne chemicals totaling billions of pounds annually may harm human health or the environment. Peach, US GAO, 1991
• 1000 (MAXIMUM) of these chemicals have been evaluated by federal agencies; little is known from any source about non-cancer health effects of these chemicals. Peach ,US GAO, 1991
• 13 million tons of sulfur dioxide emissions were released into the air by electric utilities alone in 1994. P.F. Guerrero, _ Air Pollution: allowance trading offers an opportunity to reduce emissions at less cost._ US GAO , December 1994
• 13 million woodstoves were in use in the US in the early 1990's, with 800,000 additional stoves sold each year. [Woodstoves are a significant source of particulate air pollution on the US west coast.] A.J. Frank, Case studies in environmental medicine: taking an exposure history. ATSDR 1992, 1994
• 56 million tons of wood are burned for fuel in the US annually. L. Curtis, _The Human Ecologist _ #65, 1995
• ...and People
• Studies have shown about a 1% increase in total deaths per day for each 10 microgram increase in concentration of particulate matter (PM 10) per cubic meter of air. Strongest associations between death rate and pollution concentration were found for cardiac disease and respiratory disease. D.W. Dockery et al., Acute respiratory effects of particulate air pollution. Ann Rev Public Health 15:107-132 (1994)
• Studies have also shown about a 1% increase in hospital admissions and emergency room visits for respiratory distress for each 10 microgram increase in PM 10 concentration. Strongest associations were observed between asthma and pollutant concentrations ( 3.4 % increase in ER visits, 1.9% increase in admissions). Dockery et al. 1994
• 5000 Americans die of asthma each year. American Lung Association 1994
• 50,000 to 60,000 deaths each year have been attributed to particulate air pollution. Harvard School of Public Health, 1993
• 4.2 million US children have asthma, an increase of over 30% in the last 15 years. American Lung Association, 1996
• 80% of Los Angeles children examined post mortem in 1990 had subclinical lung damage. California Air Resources Board, 1996
• Damage to children's lungs from air pollution can impede lung development and may lead to chronic lung disease later in life. American Lung Association 1995
• 23.8 million children attend public schools with inadequate or unsatisfactory heating, ventilating and air conditioning systems. GAO 1995

Red Flag -----------------------------------------------------------------------

Pesticide Misuse Makes Homes Unlivable, Taxpayers Pick Up Tab

Illegal spraying in November and December 1996 of the restricted use pesticide methyl parathion in Mississippi, Louisiana, and Alabama resulted in emergency relocation of 1120 residents from 278 households in Mississippi, and closure of 8 day-care centers, one restaurant and two hotels. The pesticide was applied indoors by applicators who promised long-term control of cockroaches and termites.

This was not the first time methyl parathion has been illegally applied indoors--with similar consequences. In 1994, similar contamination of homes and businesses with methyl parathion occurred in Lorain, Ohio, resulting in 859 relocation and decontamination of 232 homes--at a cost of $20 million. In 1995, some residences in Detroit Michigan were also illegally sprayed with methyl parathion; 20 people had to be relocated, at a cost of $2 million. Estimated cost to clean up the 1996 contamination is $50 million.

Methyl parathion is a nervous system poison. If used indoors, it can cause flu-like symptoms such as nausea, vomiting, headaches and diarrhea. High exposures to methyl parathion can lead to convulsions, cardiac arrest and death.

Legal use of methyl parathion is restricted to particular outdoor agricultural applications. Each year in the US, about 4.5 million pounds of the pesticide are used on cotton, soybeans, field corn, peaches, wheat, barley, and rice. Most of this use is concentrated in Alabama, Arkansas. Louisiana, Mississippi, Nebraska, and Texas. "EPA does not believe approved uses of the pesticide pose unreasonable risks because it degrades and dissipates when properly applied outdoors to agricultural crops," according to EPA. (Methyl parathion applied indoors is not degraded by sunlight and rain, as it is outdoors. If applied indoors, it can persist for months--or years.) Methyl parathion is undergoing re-registration review at EPA, along with other older pesticides, and the agency says it "may impose additional risk reduction measures in the future, if warranted."

Meanwhile, in response to the recent spate of illegal use of the pesticide, methyl parathion's manufacturer agreed to recall all unopened containers of the emulsifiable concentrate form of the pesticide. (Note: Mixtures containing methyl parathion and microencapsulated formulations of methyl parathion were not covered by the recall.) EPA planned to cancel all existing registrations for emulsifiable methyl parathion and issue new registrations, requiring that the emulsifiable formulation of the pesticide be marketed only with a disagreeable odorant (to warn consumers), in tamper-resistant containers marked with and bar-codes that can be traced.
Trade names of methyl parathion include Nitrox, Dithon 63, Ketokil 52, Seis-tres 63, Metaspray 5E, and Paraspray 6-3.

Notes and Comment

Who is vulnerable to the effects of environmental exposure?

"HEAL's purpose and goals concern the effects of environmental exposure on health, not just for those who have already been adversely affected, but also for those portions of the general public who are potentially at high risk for adverse effects from...environmental exposure[s] by virtue of their age, state of health and immune status, state of development, and other characteristics....

[The Governing Board] believe[s] that a list of high-risk groups includes the following:

• the chemically sensitive
• women of childbearing age
• pregnant women and their fetuses
• all children under 15 years of age
• the immune-impaired
• the chronically-ill
• the poor
• all those whose employment involves work with or around [hazardous materials]"

--from the HEAL Governing Board comments to the US Department of Agriculture, May 1993