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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