Thursday, April 05, 2007

Medical experts urge tougher smog standards

April 4, 2007

The Honorable Stephen L. Johnson
Administrator
U.S. Environmental Protection Agency
1200 Pennsylvania Ave., N.W.
Washington, D.C. 20460

Re: Broad Scientific Consensus to Lower Ozone Air Quality Standard and Close the Rounding Loophole

Dear Administrator Johnson:

We, the undersigned scientists, doctors, and public health professionals, are writing to express strong support for a revised primary eight-hour ozone ambient air quality standard at a level that reduces the health burden experienced by the nation's population as the result of exposure to ozone air pollution. The National Ambient Air Quality Standards must accurately reflect the state of the science and fulfill the Clean Air Act's mandate of protecting the public health, including those most vulnerable to the effects of air pollution, with an adequate margin of safety.

We note that the EPA's panel of expert science advisors, the Clean Air Scientific Advisory Committee (CASAC), has reviewed the scientific evidence in the EPA Criteria Document and Staff Paper and has unanimously recommended that "the primary 8-hr NAAQS needs to be substantially reduced to protect human health, particularly in sensitive subpopulations" (CASAC letter to Administrator Johnson, dated October 24, 2006). We also agree with their unanimous conclusion that “there is no scientific justification for retaining the current primary 8-hour NAAQS.” Expert opinion, including recommendations by EPA staff scientists in the final Staff Paper, holds that retaining the current standard would put large numbers of people at risk for respiratory effects, asthma exacerbations, emergency room visits, hospital admissions, and mortality.

The Clean Air Scientific Advisory Committee has further recommended that EPA close the “rounding loophole” which allows areas with concentrations up to 0.085 ppm to escape regulation under the current standard of 0.08 ppm, a position that we fully endorse.

The Clean Air Scientific Advisory Committee has further unanimously recommended an eight-hour primary ozone standard in the range of 0.060 ppm to 0.070 ppm. The Committee specifically expressed its recommendation to the third decimal place to avoid the rounding loophole. This recommendation was unanimously reconfirmed in a March 5, 2007 meeting of the Committee.

Such strongly worded consensus statements are unusual for this panel of scientists, which is deliberately selected to represent a variety of viewpoints. These unambiguous, unanimous recommendations to your office reflect the strong body of scientific literature indicating significant harm to adults and children from exposures to ozone at and below the current standard of 0.08 ppm (effectively 0.085 due to rounding).


Controlled human exposure studies of healthy adults have repeatedly demonstrated reduced lung function, increased respiratory symptoms, changes in airway responsiveness, and increased airway inflammation following 6.6 hour exposures to 0.08 ppm ozone. Recent studies demonstrate that some of the people tested experience these adverse effects at concentrations of 0.06 ppm and below. Multiple field studies have shown adverse health effects of ozone exposures below 0.08 ppm on children, especially worsening of respiratory status in asthmatics. In addition, a series of recently published meta-analyses and primary national-scale epidemiological studies have documented consistent associations between premature mortality and ozone exposures below the current eight hour standard of 0.08 ppm.

In conclusion, we strongly and solemnly request that you follow the recommendations of the Clean Air Scientific Advisory Committee and reduce the eight-hour primary ozone standard to a range between 0.060 and 0.070 ppm.
Thank you for considering our views.
Sincerely,

Jonathan I. Levy, Sc.D.
Associate Professor of Environmental Health and Risk Assessment
Harvard School of Public Health

Kent Pinkerton, Ph.D.
Director of the Center for Health and the Environment
University of California at Davis

William Rom, M.D., M.P.H.
Sol and Judith Bergstein Professor of Medicine and Environmental Medicine
Director of the Division of Pulmonary and Critical Care Medicine
New York University School of Medicine




Additional signatories

Jerrold L. Abraham, M.D.
Professor of Pathology
Director of Environmental and Occupational Pathology
SUNY Upstate Medical University

Joseph Adams, M.D., F.A.C.P.
Greater Baltimore Medical Center
Towson, Maryland

Robert Aris, M.D.
Associate Professor of Medicine
Division of Pulmonary and Critical Care Medicine
University of North Carolina at Chapel Hill

Ed Avol, M.S.Department of Preventive MedicineUniversity of Southern California

John M. Balbus, M.D., M.P.H.
Health Program Director
Environmental Defense
Adjunct Associate Professor
Johns Hopkins Bloomberg School of Public Health

Rebecca Bascom, M.D., M.P.H.
Professor of Medicine
Penn State University, College of Medicine

William S. Beckett, M.D., M.P.H.
Professor of Environmental Medicine and Medicine
University of Rochester School of Medicine

Kenneth A. Berkowitz, M.D., F.C.C.P.
Associate Professor of Medicine
New York University Medical Center

Jonathan A. Bernstein, M.D., F.A.A.A.A.I.
Professor of Clinical Medicine
Division of Immunology/Allergy
University of Cincinnati

Kent J. Bransford, M.D.
Monterey Bay Oncology
Monterey, California

Katherine L. Bright, M.D.
Associate Professor of Pediatrics
University of Kentucky

Arezoo Campbell, Ph.D.
Assistant Professor of Pharmaceutical Sciences
Western University of Health Sciences




Lung Chi Chen, M.D.
Associate Professor
Department of Environmental Medicine
New York University School of Medicine

David Chong, M.D.
Associate Professor of Medicine
New York University School of Medicine

David C Christiani, M.D., M.P.H.
Professor of Medicine
Harvard Medical School
Professor of Occupational Medicine and Epidemiology
Harvard School of Public Health

Devra Davis, Ph.D., M.P.H.
Professor of EpidemiologyDirector of the Center for Environmental Oncology
University of Pittsburgh Cancer Institute

Dorr G. Dearborn, Ph.D., M.D.
Professor of Pediatrics
Chairman of the Department of Environmental Health Sciences
Case Western Reserve University

George L. Delclos, M.D., M.P.H.
Director of the Division of Environmental and Occupational Health Sciences
University of Texas

Ralph J. Delfino, M.D., Ph.D.
Epidemiology Division
University of California at Irvine

Anthony J. DeLucia, Ph.D.
Professor of Surgery
Adjunct Professor of Environmental Health
East Tennessee State University

Richard D. Dey, Ph.D.
Professor and Chair of the Department of Neurobiology and Anatomy
Director of the Center for Respiratory Biology and Lung Disease
West Virginia University

Jefferson H. Dickey, M.D.
Bodkhe Dickey Health Associates
Franklin Medical Center
Greenfield, Massachusetts

Douglas W. Dockery, Sc.D.
Professor of Environmental Epidemiology
Chair of the Department of Environmental Health
Harvard School of Public Health

Lisa Doggett, M.D., M.P.H.
Austin, Texas

Martin Donohoe, M.D., F.A.C.P.
Lecturer in the Department of Community Health
Portland State University

Harold J. Farber, M.D.
Specialist of Pediatric Pulmonology and Medical Director of the Pediatric Asthma Care Management Program at Kaiser Permanente
Vallejo, California

Karl Fields, M.D.
Professor of Family Medicine
University of North Carolina

Jonathan M. Fine, M.D.
Research Associate Professor
New York University School of Medicine

Henry Jay Forman, Ph.D.
Professor and Founding FacultySchool of Natural Sciences
University of California, Merced

Mark W. Frampton, M.D.
Professor of Medicine and Environmental Medicine
University of Rochester Medical Center

Erica Frank, M.D., M.P.H.
Professor of the Department of Health Care and Epidemiology
University of British Columbia

Michael Friedman, M.D.
Chennai, India

George Friedman-Jiménez, M.D.
Director, Bellevue/NYU Occupational and Environmental Medicine Clinic
New York University School of Medicine


John R. Froines, Ph.D.
Professor of Occupational and Environmental Health
University of California at Los Angeles

Frank Gilliland, M.D., Ph.D.
Professor in the Department of Preventive Medicine
Keck School of Medicine
University of Southern California

Lynn Goldman, M.D., M.P.H.
Professor of Environmental Health Sciences
Johns Hopkins University

Bob Gould, M.D.
Associate Pathologist at Kaiser Hospital
San Jose, California

Roni Grad, M.D.
Associate Professor of Pediatrics
University of Alabama at Birmingham

Tee L. Guidotti, M.D., M.P.H.
Chair of the Department of Environmental and Occupational Health
Director of the Division of Occupational Medicine and Toxicology (Dept. of Medicine)
The George Washington University Medical Center

David C. Hall, M.D.
Specialist in Child and Adolescent Psychiatry
Seattle, Washington

Winifred J. Hamilton, Ph.D., S.M.
Assistant Professor in the Departments of Medicine and Neurosurgery
Baylor College of Medicine

S. Katharine Hammond, Ph.D., C.I.H.
Professor and Chair of Environmental Health Sciences
University of California at Berkeley

Michael R. Harbut, M.D., M.P.H., F.C.C.P.
Clinical Assistant Professor of Medicine
Wayne State University School of Medicine

Ira Helfand, M.D.
Specialist in Emergency Care
Leeds, Massachusetts


Howard Hu, M.D., M.P.H., Sc.D.
Chair and Professor of Environmental Health Sciences
University of Michigan

Kazuhiko Ito, Ph.D.
Assistant Professor of Environmental Medicine
New York University School of Medicine

Dan Jaffe, Ph.D.
Professor of Environmental Science
University of Washington-Bothell

Sarah Jordan, M.D., M.S.P.H.
Specialist in Family Care Medicine at the Siler City Community Health Center
Piedmont Health Services, Inc.
Siler City, North Carolina

Patrick L. Kinney, Sc.D.
Associate Professor
Department of Environmental Health Sciences
Mailman School of Public Health at Columbia University

Howard M. Kipen, M.D., M.P.H.
Professor of Environmental and Occupational Medicine
Chief of the Clinical Research and Occupational Medicine Division
University of Medicine and Dentistry of New Jersey

Jane Q. Koenig, Ph.D.
Professor of Environmental Health
University of Washington

Dana L. Kornfeld, M.D.
Clinical Associate Professor of Pediatrics
George Washington University Medical Center

Ana Krieger, M.D., F.C.C.P.
Assistant Professor
New York University School of Medicine

Nino Kuenzli, M.D., Ph.D.Associate Professor
Department of Preventative Medicine
University of Southern California Center for Research in Environmental Epidemiology
Barcelona, Spain


Francine Laden, Sc.D.
Assistant Professor of Environmental Epidemiology
Harvard University

William Lambert, Ph.D.
Associate Professor
Department of Public Health and Preventive Medicine
Oregon Health and Science University

Joyce C. Lashof, M.D.
Professor Emerita of Public Health
University of California at Berkeley

Robert S. Lawrence, M.D.
Professor of Environmental Health Sciences and Health Policy
Director of the Center for a Livable Future
Johns Hopkins University

Eric Leibert, M.D.Clinical Assistant Professor of Medicine New York University School of Medicine

George Leikauf, Ph. D.
Professor of Environmental Health and Pulmonary and Critical Care Medicine
University of Cincinnati

Deborah Leiner, M.D., F.A.A.P.
Clinical Associate Professor of Pediatrics
University of North Carolina at Chapel Hill
Chair of the North Carolina Pediatric Society Environmental Health Group
Greensboro, North Carolina

Louis S. Libby, M.D.
Specialist in Pulmonology and Chief Medical Officer at the Oregon Clinic
Portland, Oregon

Michael Lipsett, M.D., J.D.
Associate Clinical Professor
Department of Epidemiology and Biostatistics
University of California, San Francisco

Alan H. Lockwood, M.D.
Professor of Neurology and Nuclear Medicine
Adjunct Professor of Communicative Disorders and Sciences
State University of New York at Buffalo


Frank Martiniuk, PhD
Research Associate Professor
New York University School of Medicine

Rob S. McConnell, M.D.
Professor of Preventive Medicine
Keck School of Medicine, University of Southern California

Siobhan McNally, M.D., F.A.A.P.
Specialist in Pediatrics
Pittsfield, Massachusetts
Co-chair of the Massachusetts Section of the American Academy of Pediatrics Committee on Environmental Health

Peter H. Michelson, M.D.
Department of Pediatrics
Division of Pulmonary and Sleep Medicine
Duke University

Jana Milford, Ph.D., J.D.
Associate Professor of Mechanical Engineering
University of Colorado at Boulder

Albert Miller, M.D.
Professor of Medicine
New York Medical College
Director of Pulmonary Medicine
Caritas Health Care
Jamaica, NY

Shelly L. Miller, Ph.D.
Associate Professor
Environmental Engineering Program in the Department of Mechanical Engineering
University of Colorado at Boulder

John S. Munger, M.D.
Assistant Professor of Medicine and Cell Biology
New York University School of Medicine

Bonnie A. New, M.D., M.P.H.
Beacon Medical Management for Industry
Coordinator of Health Professionals for Clean Air
Houston, Texas




Anna Nolan, M.D.
Assistant Professor of Medicine
Division of Pulmonary and Critical Care
New York University School of Medicine

George T. O’Connor, M.D., M.S.
Professor of Medicine
Boston University School of Medicine

Marie S. O’Neill, Ph.D.
Assistant Professor of Epidemiology and Environmental Health
University of Michigan

Peter Orris, M.D., M.P.H.
Professor and Director, Occupational Health Services Institute
University of Illinois School of Public Health

Cindy L. Parker, M.D., M.P.H.
Instructor in the Department of Environmental Health Sciences
Johns Hopkins University

Jerome A. Paulson, M.D., F.A.A.P.
Associate Professor of Pediatrics and Public Health
Co-Director of the Mid-Atlantic Center for Children's Health and the Environment
George Washington University

Jennifer L. Peel, Ph.D.
Assistant Professor of Epidemiology
Department of Environmental and Radiological Health Sciences
Colorado State University

Arnold C.G. Platzker, M.D.
Professor of Pediatrics
Division of Pediatric Pulmonology
University of Southern California

Jenny E. Pompilio, M.D.
Practitioner of Internal Medicine
Hillsboro, Oregon

Joan Reibman, M.D.
Associate Professor of Medicine and Environmental Medicine
New York University

Don Richardson, M.D.
Brevard, North Carolina

Beate Ritz, M.D., Ph.D.
Professor of Epidemiology, Environmental Health Sciences, and Neurology
Vice Chair of the Department of Epidemiology
University of California at Los Angeles

Jonathan Samet, M.D., M.S.
Professor and Chair of Epidemiology
Johns Hopkins Bloomberg School of Public Health

Brian S. Schwartz, M.D., M.S.
Professor of Environmental Health Sciences, Epidemiology, and Medicine
Johns Hopkins University

Joel Schwartz, Ph.D.
Professor of Environmental Epidemiology
Harvard University

Katherine M. Shea, M.D., M.P.H.
Adjunct Professor of Maternal and Child Health
University of North Carolina at Chapel Hill

Dean Sheppard, M.D.
Professor of Medicine
Director of the Lung Biology Center
University of California at San Francisco

Carl M. Shy, M.D.
Professor Emeritus of Epidemiology
University of North Carolina at Chapel Hill

Constantinos Sioutas, Sc.D.
Professor in the Department of Civil and Environmental Engineering
Co-director of the Southern California Particle Center
University of Southern California

John D. Spengler, Ph.D.
Akira Yamaguchi Professor of Environmental Health and Human Habitation
Harvard University

Helen Suh, S.B., M.S., Sc.D.
Associate Professor of Environmental Chemistry and Exposure Assessment
Harvard University

Tim K. Takaro, M.D., M.P.H., M.S.
Associate Professor
Faculty of Health Sciences
Simon Fraser University

Duncan C. Thomas, Ph.D.
Director of the Biostatistics Division
Department of Preventive Medicine
University of Southern California

Catherine Thomasson, M.D.
Practitioner of Internal Medicine
Center for Student Health and Counseling
Portland State University

George D. Thurston, Sc.D.
Associate Professor of Environmental Medicine
New York University

Doris Tse, Ph.D.
Associate Professor of Medicine
New York University School of Medicine

Arthur Upton, Ph.D.
Professor of Environmental and Community Medicine
Rutgers University

Judith A. Voynow, M.D.
Associate Professor of Pediatrics
Division of Pediatric Pulmonary Medicine
Duke University

Bailus Walker Jr., Ph.D, M.P.H.
Professor of Environmental and Occupational Medicine and Toxicology
Howard University

Virginia M. Weaver, M.D., M.P.H.
Associate Professor
Division of Occupational and Environmental Health
Johns Hopkins University

Ronald H. White, M.S.T.
Associate Scientist
Department of Epidemiology
Deputy Director of the Risk Sciences and Public Policy Institute
Johns Hopkins University

Michelle Wilhelm, Ph.D.
Assistant Professor In Residence
Department of Epidemiology
University of California at Los Angeles

Peter Wilk, M.D.
Specialist in Psychiatry
Sebago, Maine

Antonella Zanobetti, Ph.D.
Research Scientist
Department of Environmental Health
Harvard University

Junfeng (Jim) Zhang, Ph.D.
Professor and Acting Chairman
Department of Environmental and Occupational Health
University of Medicine and Dentistry of New Jersey

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