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July 11, 2001 Project Manager for Particulate Matter RE: Comments on Air Quality Criteria for Particulate Matter (External Review Draft) The Children's Environmental Health Network (Network) submits these comments about the Environmental Protection Agency's (EPA) draft criteria document on particulate matter (PM). The Network is a national multi-disciplinary project dedicated to protecting children from environmental toxicants. Our sole mission is to protect the fetus and the child from environmental hazards and to promote a healthy environment, through education, research, and policy. The Network commends EPA for the comprehensive review of the recent scientific literature in the draft Criteria Document. We strongly support EPA's approach of focusing on new developments in the scientific literature since the last Criteria Document was published in 1996. We hope that the agency moves expeditiously, based on the science summarized in these documents, to adopt and implement improved standards that will better protect the health of all U.S. residents, especially children, most especially those in low income and/or minority communities who face greater risks. The risk to our children from exposure to air pollutants argues for prompt and effective action. This report is particularly relevant in light of the commitments the agency has made, such as those made in its report, Environmental Health Threats to Children. The EPA agenda contained in that report begins with: “as a national policy, [to] ensure that all standards EPA sets are protective enough to address the potentially heightened risks faced by children -- so as to prevent environmental health threats wherever possible -- and that the most significant current standards be re-evaluated as we learn more.” This Criteria Document clearly outlines the need for improved PM standards, especially if our goal is to protect the health of the nation's children. As the EPA stated in Environmental Health Threats to Children, “It is essential that our national pollution control standards protect our nation's most valuable future resources, placing children at the center of our protection efforts...” We urge the EPA to continue to do just that. Children are especially susceptible to air pollution. The airways of young children are smaller than those of adults. Inhalation of air pollutants that would produce only a slight response in an adult can result in potentially significant obstruction in the airways of a young child. Children have increased oxygen needs compared to adults, they breathe more rapidly and inhale more pollutants per pound of body weight than adults, and they often spend more time engaged in vigorous outdoor activities than adults. Since the agency's last review of the particulate matter standard, a wealth of new studies have been published which continue to underscore the connection between air pollutants and harm to children's health and which makes a strong case that the short-term fine particle standard needs to be strengthened. Attached are comments providing more detailed analysis of specific chapters of the Criteria Document, developed by Henry Gong, Jr., M.D., Professor of Medicine and Preventive Medicine, Keck School of Medicine, University of Southern California; Joel N. Kline, M.D., Associate Professor, Division of Pulmonary Medicine, University of Iowa; and W. Gerald Teague, M.D., Professor of Pediatrics at Emory University School of Medicine. Their comments illustrate several key points relevant to each chapter reviewed:
Additionally, it should be emphasized that, as cited by Dr. Teague, U.S. and Mexican children experience adverse health effects with exposure to PM10 at airborne levels common in urban regions. Children with asthma, estimated at 3-11% of the pediatric population, are especially at risk. These findings support the need for additional action, beyond the call for additional research mentioned above. For example, our lack of knowledge about children' exposures emphasizes the need for PM monitoring networks capable of providing data on real-life exposures of children, especially children at greatest risk and/or children living in areas anticipated to have highest levels of these pollutants. Most importantly, these findings underscore our responsibility to decrease the PM levels to which children are exposed. In general, the Network commends the EPA for the comprehensive review of the scientific literature contained in the Criteria Document, which will provide a sound foundation for the next steps in formulating regulatory recommendations. The Network urges the agency to make the improvements suggested in our comments to further refine this outstanding document. We look forward to seeing the information provided in this document lead to stronger protections of the health of the nation's children. Sincerely,
Cc: The Honorable Christine Todd Whitman Attachments: |
