HEAL's Governing Board Comments on Proposed Changes in EPA Standards for Ozone and Particulate Matter, February 1997 Excerpts

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"In recent years we have dedicated much of our attention to the effects of low-level chemical exposures on human health. We have concentrated our attention on the issue of multiple chemical sensitivities (MCS), from which may of our members suffer. However, we are also concerned about other environment-related disorders, including asthma, chronic headaches, and severe allergy.... We take it as a given that the ambient environment is the setting in which all other exposures take place. General ambient conditions provide the background to which all additional exposures are added. Thus HEAL and its membership have always had a keen interest in, and concern about, the healthfulness of ambient environmental conditions."

"It is evident that the debate over the agency's proposed changes in the ozone and particulate matter NAAQSs will be fierce. Many segments of society have considerable stakes in how these pollutants are regulated. We believe that it may be very important to bear in mind that, no matter what decisions are made regarding these regulations, there will be a price to be paid."

"An example of how failing to reduce pollution levels will ultimately be costly can be clearly seen in asthma, We think that if the current standards are left unchanged, the current trends in asthma incidence and severity will continue. This would mean a continuation of increasing numbers of cases of asthma, asthma onset at younger ages, more severe and difficult-to-control asthma, and asthma with greater morbidity (and perhaps mortality). In this scenario, the cost of doing nothing includes increased healthcare costs, loss of quality of life for those affected, failure to meet social and economic goals as young asthmatics fail in academic achievement and worker productivity, increased disability-related costs, and decreased tax revenues collected."

"We are particularly concerned about the life-long medical, social and economic costs of early-onset asthma. In 1992, an economic evaluation of asthma published in _The New England Journal of Medicine_ put the 1990 cost of asthma at $6.1 billion. Missing from that analysis was the effect of poor academic achievement and decreased worker productivity on private savings rates and tax revenues (including worker contributions to Social Security and Medicare). If asthma cases increase, asthma attacks increase, and the cost of healthcare continues to rise at even a modest rate, the cost of pollutant-related asthma could be very high indeed. The cost is very significant if only a portion of all asthma-related healthcare and other costs are attributed to preventable environmental exposures."

"The relationship between asthma and pollutants--particularly ozone and, to a lesser degree particulate matter -- has been more fully explored than the relationship between other lung diseases and pollution. ...Subtle chronic health effects have not been so widely discussed, yet these less-familiar effects may become facts of life for many Americans if current pollution levels are not reduced."

"For instance, we are concerned about the effects of current levels of ozone and particulate matter on the nation's aging population. As the "baby boom" generation ages, there will be an increasingly large population susceptible to "nonspecific airway hyper-responsiveness" manifested as bronchospasm in response to irritant inhaled pollutants. Healthcare costs can be anticipated to increase for this entire cohort of Americans, simply as a function of their age. Additional healthcare costs as the result of increased rates of lung disease in this population could have a dramatic impact on healthcare costs at a time when the workforce is shrinking due to worker retirement."

"Not only breathing difficulties, but also increased incidence of cardiovascular disease (and related increased susceptibility to air pollutant effects) can be anticipated in this very large group of Americans as it ages. In particular, aging asthmatics who develop cardiovascular disease may challenge both efforts to provide effective treatment, and healthcare cost-containment."

"We believe that improved environmental conditions will help to protect the vulnerable, including the very young, the very old, and the genetically-susceptible. We think that such improvements will also help preserve function in those whose health is already impaired such as the allergic, the asthmatic, the sensitive and the immune-impaired. We know that these protections are costly,--but we also strongly believe that the cost of not offering these protections is even higher."

"We are aware that revising the NAAQSs has been highly controversial since passage of the Clean Air Act in 1970.... We [also] believe that healthy citizens are necessary to achieve the nation's goals in education, global competitiveness, fiscal heath an environmental stewardship."

--The Human Ecology Action League, Inc., October 1996

At a Glance 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

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 a HEAL Governing Board comment to the US Department of Agriculture,
May 1993.