If the Environmental Protection Agency (EPA) adopts the advice of its Clean Air Scientific Advisory Committee (CASAC), now led by former American Petroleum Institute consultant Tony Cox, it will be virtually impossible to prove particulate pollution, known as particulate matter (PM) or soot, harms public health, despite the vast array of studies that show otherwise.
A paper published today in Science—by Dr. Gretchen Goldman, the research director for the Center for Science and Democracy at the Union of Concerned Scientists and Dr. Francesca Dominici, a leading PM expert at the Harvard T.H. Chan School of Public Health—shows why the CASAC Chair’s recommendations are flawed. A draft letter from the advisory committee calls for the EPA to only consider studies that directly show that a change in particulate pollution levels or change in regulation will result in a change in health impacts.
In the Science paper, Goldman and Dominici point out that it’s not possible or ethical to expose people to harmful levels of PM in scientific experiments, so the EPA’s current process for establishing health risks relies on the weight of evidence, including causation studies, but also many other kinds of studies. The CASAC Chair’s recommendation, according to the paper, would “place a nearly unattainable burden of proof on the scientific community.”
Cox himself has developed a model that seeks to establish a direct link between pollutants and health effects, while removing all other factors, but the paper points out that the approach has not been fully vetted by the scientific community.
If the EPA adopts CASAC’s position at its public hearing on March 28, it would have profound long-term ramifications for numerous federal regulations, including the mercury and air toxics standards and the Clean Power Plan, whose health benefits, when monetized, are largely due to the PM reductions. Removing the justification for these regulations would allow EPA to roll them back.
To read Goldman’s Scientific American post, which puts the issue into context, click here.