January 24, 2023
6 min read
Bender reports that she is the national vice president of healthy air at the American Lung Association.
The U.S. Environmental Protection Agency has proposed changing National Ambient Air Quality standards for fine particulate matter to improve respiratory health, but this update could be stronger, according to the American Lung Association.
“It’s a matter of health, and it’s a matter of environmental justice,” Laura Kate Bender, national assistant vice president of healthy air at the American Lung Association, told Healio.
The current standard for annual fine particulate matter (PM2.5) is 12 µg/m3. The EPA has proposed reducing it to a level between 9 µg/m3 and 10 µg/m3, although it will also take public comments on reducing it to between 8 µg/m3 and 11 µg/m3.
Also, the EPA does not have any plans to change the current 24-hour PM standard of 35 µg/m3, although the Clear Air Scientific Advisory Committee recommends a 25 µg/m3 level. The EPA will take comments about this standard as well.
Healio spoke with Bender to find out how particulate matter impacts asthma, why the American Lung Association doesn’t think the EPA’s proposals go far enough in protecting people with asthma, and how the association believes these problems can be solved.
Healio: How does fine particulate matter clinically impact patients with asthma?
Laura Kate Bender
Bender: Fine particulate matter is tiny bits of stuff in the air. It can come from a variety of sources, including a lot of the same sources as other types of air pollution, such as power plants; vehicles, including diesel trucks; wildfires; wood stoves; and any kind of burning. It can impact anyone’s health but, for people with asthma, it can cause exacerbations. Exposure can cause people with asthma to need to seek treatment and raise the likelihood of ED visits. Then that comes with a whole host of other health impacts.
Healio: Could you summarize the EPA’s proposals and what they mean for air pollution?
Bender: The National Ambient Air Quality Standards are a critical part of how the Clean Air Act works. Essentially, these standards are required to match what the science shows as healthy, so they cover six different pollutants. Fine particulate matter is one of the areas that these standards govern. Essentially, they set a national health-based limit on how much particle pollution can be in the air.
The reason it works so well is because that limit has to be health-based. It requires the EPA to look at the science and figure out what level that particle pollution needs to be reduced to ensure that people are healthy, and that requirement protects human health with an adequate margin of safety. That margin of safety is especially critical for people with asthma or other risk factors that make them more vulnerable to the health impacts of particulate matter.
Another requirement in the law is that these standards need to be updated. The EPA has to review these standards every 5 years because when Congress passed the Clean Air Act, they knew the science would change. Over the past several years, the science has shown that particle pollution is more dangerous than previously thought, both at lower levels and in more ways. With particle pollution, we’ve had continually tighter standards over time as the science has shown that that was needed.
Although the EPA is supposed to review the standards every 5 years, in practice, it usually takes longer. This time around, the previous administration completed its review and decided not to update the standards. The American Lung Association and other health and medical groups strongly opposed that. We looked at the science and said it was clear that the current particle standards are out of date with what the science shows is needed to protect human health. We achieved a very specific call for the standards to be tightened.
Now, the current administration has embarked on a review process to re-examine the decision of the previous administration not to tighten them. And the short answer is that we are disappointed.
Healio: How do the EPA’s proposals fall short of the American Lung Association’s recommendations?
Bender: The EPA went through a long process to look at the science. It has an independent panel of scientific advisors called the Clean Air Scientific Advisory Committee that reviewed the science in coordination with experts and recommended that the standards be set at a more protective level than what the EPA proposed. They called for the EPA to strengthen two measures of how they regulate particle pollution. There is the 24-hour standard, which is how much particle pollution can spike in any given 24-hour period, and the annual standard, which is the day in, day out level of particles that is healthy to breathe.
We have been calling for the EPA to set the annual standard at 8 µg/m3. That is the level that, based on the science, would meet the Clean Air Act requirements. It would protect human health with an adequate margin of safety, especially for people with asthma. We also called on the EPA to strengthen the 24-hour standard to 25 µg/m3. That’s because there are places that get short-term spikes that might not get cleaned up adequately under the annual standard.
Most of the Clean Air Scientific Advisory Committee members agree that the EPA should strengthen the standard to a range of 8 µg/m3 to 10 µg/m3 for the annual standard and tighten the 24-hour standard to a range of 25 µg/m3 to 30 µg/m3. In both cases, most of the scientific advisors on the committee recommended ranges that go down to the protective levels that we’re calling for.
The EPA’s proposal fell short of that.
Healio: How significant are these differences between the EPA’s proposals and the American Lung Association’s recommendations?
Bender: When the EPA issued their proposal, they also conducted a regulatory impact analysis to look at the health impacts of these changes. We want 8 µg/m3 for the annual standard. They proposed 9 µg/m3 to 10 µg/m3. According to the EPA, a standard of 10 µg/m3 would prevent 1,700 premature deaths, whereas a standard of 9 µg/m3 would prevent 4,200 and a standard of 8 µg/m3 would prevent up to 9,200 premature deaths. That’s a big difference in terms of health impact.
Setting these standards is just the beginning. Once the EPA finalizes its health-based standard for particle pollution, that’s when implementation starts, and communities across the country whose air isn’t meeting the standard start planning to reduce pollution to clean up and meet the standard. The difference between the EPA’s proposal and ours is a missed opportunity. We know that 8 µg/m3 offers the most health benefits based on the EPA’s own analysis.
Healio: Now that the EPA has made these proposals, what is the next step in this process?
Bender: The EPA has kicked off a 60-day public comment period. It also will include a virtual public hearing, and it will be a big opportunity for the American Lung Association, for health and medical organizations that we work with and the whole environmental and health community to weigh in and call on the EPA to finalize standards at the levels we’re calling for — 8 µg/m3 and 25 µg/m3. We’ll be out in force, not only sharing the health science that justifies that position, but also highlighting the personal stories of people we work with who are impacted by particles and who want to see the standard tightened.
This is a particularly important issue for communities that have a polluting source nearby. These more protective standards are critical to ensuring that they finally have the cleanup that they have been waiting for. So, I think you’ll see a lot of public engagement.
After that, the EPA will finalize the standards, and we’re hoping to see them in August. They certainly need to do it without delay. The EPA needs to move quicker than ever to make sure the standards actually get finalized, because then the implementation process kicks in, and that’s a years-long process that requires states to monitor their air quality, work with the EPA to determine which areas are not meeting the standard, and then write and implement plans to clean up pollution.
Healio: How can physicians address these issues?
Bender: I always encourage medical professionals to be advocates, and I can say that from all of my interactions with decision-makers, physicians should not underestimate the power of their expert voice, whether it’s anonymously relaying stories about how their patients have been impacted, or using their own expertise to dig into the medical literature. They are vital, and decision-makers respect their voices.
So, get engaged in this process. Whether it’s by submitting a public comment to the EPA in support of the strongest possible standards, testifying at a virtual public hearing, or even getting involved at the local level. Because once these standards are finalized, those communities that have unhealthy levels of particles will be working on their cleanup plans, and there’s public engagement opportunities there as well.
Read More:Particulate matter air pollution standards need to be stronger