ACOEM Supports Policy Assessment for the Review of the National Ambient Air Quality Standards for Particulate Matter

March 4, 2020
The Honorable Andrew Wheeler Administrator
Environmental Protection Agency
1200 Pennsylvania Avenue, N.W.
Washington, DC 20460
Dear Administrator Wheeler:
On behalf of the American College of Occupational and Environmental Medicine (ACOEM) I am pleased to have the opportunity to respond and support the Policy Assessment for the Review of the National Ambient Air Quality Standards for Particulate Matter (PA).
The PA recommends the tightening the annual primary PM2.5 NAAQS from its existing level of 12 micrograms per cubic meter (ug/m3) down to a level between 8 ug/m3 and 12 ug/m3. This would be required to ensure the standard meets the air law threshold for protecting human health.
Evidence continues to build that inhaling too many fine particles – those with aerodynamic diameters of 2.5 microns of less (PM2.5) – carries important health risks and related costs. Many of the illnesses, indeed deaths, related to PM2.5 occur at annual average exposure concentrations lower than those considered acceptable by the World Health Organization (12 mcg per cubic meter). Direct evidence from research has shown a broad spectrum of ill effects (Pope et al, 1995).
Some of the most recent reports on health effects associated with lower PM levels include:
  • The current national standard for PM2.5 does not protect against death from ischemic heart disease, stroke, or respiratory diseases, including lung cancer (Apte et al, 2015).
  • More recently, a study of over 4.5 million US military veterans over a median duration of 10 years expanded the list of cause-specific mortality associated with PM2.5 exposures to include chronic renal disease, hypertension, dementia and pneumonia. Over 95% of this mortality burden was attributable to PM2.5 levels below the current EPA guidelines. This burden was disproportionately borne by black and socioeconomically disadvantaged veterans. (Bowe et al, 2019).
  • Higher inhaled concentrations of PM2.5 were followed by more rapid declines in both immediate recall and new learning among older women without baseline cognitive impairment. (Youhan et al J, 2019).
  • Even glaucoma, with thinning of the retina’s macular ganglion cell layer and risk of disability, is more likely in residents of places with exposures to higher PM2.5 levels, including those below annual mean values of 10 mcg/cubic meter. (Chua SYL et al, 2019).
  • Diabetes: “Even within EPA guidelines for PM2.5 exposure limits, those with the highest exposure showed a 20% increase in diabetes prevalence compared to those with the lowest levels of PM2.5, an association that persisted after controlling for diabetes risk factors.” (Pearson et al, 2010).
  • Cleaner air is associated with fewer deaths from emphysema. (Kravchenko et al, 2014).
  • Cleaner air results in less childhood asthma (Garcia, 2019), and a new chronic disease can mean years of worse quality of life, productivity and higher expenses. (Thurston, 2019).
  • Controlling PM 2.5 emissions could result in $100 billion of benefits annually in terms of premature deaths, costs of cardiovascular and respiratory hospital admissions, and lost or restricted workdays.” (Davidson K et al, 2007).
On behalf of ACOEM I urge you to support the recommendations of the EPA staff, which has based their recommendations on years of sound scientific evidence as outlined above. ACOEM is the premier national medical association representing more than 4,000 occupational and environmental medicine physicians and other related health professionals who champion the health of workers, the safety of workplaces, and the quality of the environment. ACOEM has many members with vast experience in environmental health, who stand ready to work constructively with EPA in crafting future rules to assure a high level of public trust and confidence in the evidence basis for the development of critically important environmental regulatory policy. Please contact me if you would like our assistance.
Thank you for your consideration of these comments.

Stephen A Frangos, MD, MPH, FACOEM
Apte HS, Marshall JD, Cohen AJ, Brauer M. Addressing global mortality from ambient PM2.5. Environ Sci Technol 2015; 49: 8057-8066.
Balmes JR. Do we really need another time-series study of the PM2.5-mortality association? New Engl J Med 2019;381(8):774-776.
Balmes J. Don’t Let a Killer Pollutant Loose. Op-Ed. The New York Times. April 14, 2019.
Bowe B, Xie Y, Yan Y, Al-Aly Z. Burden of cause-specific mortality associated with PM2.5 air pollution in the United States. JAMA Network Open 2019;2(11):e1915834.
Chua SYL, Khawaja AP, Morgan J et al. The relationship between ambient atmospheric fine particulate matter and glaucoma in a large community cohort. Investig Ophthal & Visual Sci 2019;60(14):4915-4923.
Davidson K, Hallberg A, McCubbin D, Hubbell B. Analysis of PM2.5 using the Environmental Benefits Mapping and Analysis Program (BenMAP). J Toxicol Environ Health A. 2007;70(3- 4):332-346.
Garcia E et al., Association of changes in air quality with incident asthma in children in California, 1993-2014. JAMA 2019;321:1906-1915.

Kravchenko J, Akushevich I, Abernathy AP, Holman S, Ross WG Jr., Lyerly HK. Long-term dynamics of death rates of emphysema, asthma, and pneumonia and improving air quality. Int J Chron Obstruct Pulmon Dis 2014;9:613-627.
Pearson JF, Bachireddy C, Shyamprasad S, Goldfine AB, Brownstein JS. Diab Care 2010;33(10):2196-2201.
Pope CA III et al. Particulate air pollution as a predictor of mortality in a prospective study of
U.S. adults. Amer J Respir Crit Care Med 1995;151:660-674.
Thurston GD, Rice MB. Air pollution exposure and asthma incidence in children. Demonstrating the value of air quality standards. JAMA 2019;321:1875-1877.
Younan D, Petkus AJ, Widaman KF, et al. (N=18) Brain 2019 Online 11/20/19,