Abstract

BACKGROUND AND AIM: In 2020 the US Environmental Protection Agency (EPA) decided to retain the National Ambient Air Quality Standards (NAAQS) for fine particles (PM2.5), despite very strong evidence of an association between long- and short-term exposure to PM2.5 and numerous adverse health outcomes below the current standard. The ISEE North American Chapter (NAC) submitted a public comment in strong opposition to this EPA decision. Furthermore, ISEE NAC members also scheduled a teleconference with the Office of Management and Budget at the White House to express our continued concern about the unwarranted changes the EPA made to the Clean Air Scientific Advisory Committee and the NAAQS review process. METHODS: ISEE NAC and the NAC Policy Committee have set up a rigorous process to prepare and submit public comments in response to proposed EPA rules. One or two Policy Committee members prepare the first draft of the comment. Subsequently, the full Policy Committee edits and approves. Finally, the ISEE NAC Executive Council reads, edits, and approves the comment. A member of the Policy Committee submits the approved comment accompanied with pdfs of papers referenced in the comment. RESULTS:In June 2020, ISEE NAC submitted a four-page comment on EPA’s decision to retain the PM2.5 standards. This decision was contrary to the state of the science and EPA’s Integrated Science Assessment (ISA), which clearly demonstrates that deaths and cardiovascular events, such as heart attacks, are produced by PM2.5 below 12 µg/m3 (the previous standard) and, hence, the Administrator’s decision violated the Clean Air Act requirement to use the “best available science” and set standards “to protect public health with an adequate margin of safety.” CONCLUSIONS:In this case study, we will describe the process activities and issues raised by the ISEE NAC Policy Committee during the EPA setting of the US PM2.5 standard in 2020 and future prospects. KEYWORDS: Particulate Matter, Policy, Air Pollution

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