UPHE’s Comments to the EPA: Reject the White House’s Proposal
Below are the comments UPHE submitted to the EPA recently on the White House’s proposal to disqualify much of the world’s research on the health consequences of air pollution.
Representing 450 physicians and 3,000 members of the lay public, Utah Physicians for a Healthy Environment wish to comment on the proposed change in the way EPA evaluates scientific research. For 13 years we have carefully searched the medical literature for research on air pollution. The conclusions we have drawn and research we have evaluated to reach those conclusions are in the attached document, organized according to organ systems and disease categories.
The message from thousands of studies done throughout the world is that air pollution contributes significantly to four of the five leading causes of death, and precipitates almost as many diseases as smoking cigarettes. In fact, given the number of people that smoke, and the fact that virtually everyone ends up breathing air pollution, the later is, overall, a larger public health hazard.
Furthermore, this research clearly establishes that there is no safe level of air pollution. Every bit of it, even at levels far below the current standards for PM2.5 and ozone, is hazardous, and increases community mortality rates. More specifically, particulate air pollution increases community mortality about 1% for every 1 ug/m3 of chronic PM2.5 exposure. The mortality precipitated by ozone is somewhat less, but important nonetheless.
A recent study of 4.5 million US veterans found that 99% of the deaths related to air pollution occur in populations where the air pollution levels meet the EPA’s current standards.
It is well established that both ozone and particulate pollution cause lung disease, heart disease, neurologic and psychiatric disorders, poor pregnancy outcomes, impaired fetal development, still births, and birth defects, virtually every type of cancer, endocrine disorders like type II diabetes, reduced kidney function, arthritis, immunosuppression, and increased vulnerability to a wide variety of infections.
To disqualify the type of research targeted by this proposal would be scientifically indefensible, inappropriate, and only serves to undermine the clean air standards which are already too weak and should be strengthened. This proposal seems to be a cynical capitulation to the demands of industry and manufacturers, rather than a gesture intended to increase transparency, fine tune the science, or more accurately address your mandate, which is to protect public health.
We urge you to immediately and unequivocally reject this proposal.
Dr. Brian Moench
President, Utah Physicians for a Healthy Environment
Read this article by Inside Climate News for more information on how nearly 40 top scientific organizations and academic institutions jointly submitted a letter to the agency:
In a letter submitted to the EPA, the American Association for the Advancement of Science, the world’s largest scientific society, and a wide array of other professional groups and universities, strongly opposed the rule, which they said is “not about strengthening science, but about undermining the ability of the EPA to use the best available science in setting policies and regulations.”