UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. O.C. E0460
January 5, 1983
OFFICE OF
THE AOfHINISTRATO"
Mrs. Anne M. Gorsuch
Administrator
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, B.C. 20460
Dear Mrs. Gorsuch;
The Clean Air Scientific Advisory Committee (CASAC)
recently reviewed the Office of Research and Development's
(ORD) program to' support criteria pollutant research for
Gases and Particles (GAP) and has prepared recommendations for
improving that research program. The major pollutants reviewed
were participate matter and sulfur dioxide. CASAC*s review
stemmed from its evaluation of the Air Quality Criteria
Document 'for Sulfur Oxides'/Parti'culates (SOX/PM} which led
to the identification of significant information needs relative
to standard setting for these pollutants. The Committee
recognizes that in the past decade new- data bases useful for
standard setting for sulfur oxides and particulates have been
developed. For example* the understanding of particulate
matter h'as evolved to such an extent that re-directing control
of particulates to a size cut smaller than Total Suspended
Particulates represents a reasonable and scientifically
defensible public health policy choice.
_•* «* * '
*
At the same time* the last decade in air pollution
research has been a period of" many missed opportunities. •>
During the review of the Air Quality Criteria Document for
SOX/PM it became apparent that much of the data base for
these pollutants comprised the same set of information upon
which the original standards for these pollutants were based.
At a time when the Agency is considering significant revisions
to the existing standards for these pollutants it is faced
with serious gaps in the scientific literature* This is
especially true for epidemiological studies for sulfur dioxide
and for particulates where some of the most reliable data were
developed in Great Britain over twenty years ago. Given the
tremendous differences in contemporary American particulate
exposures compared with conditions existing in 'Britain at
that time, there is a great need to gather and interpret up
to date American epidemiological data. The more dated the
epidemiological data sets, the greater is the need for more
complete information for use in the next five year cycle of
standard setting.
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CASAC addressed four components of the Gases and Particles
research program. These included control technology, environ-
mental 'processes and effects, "health effects, and monitoring.
• The"Committee concluded that development of monitoring and
control technology systems had made appropriate progress in
.'recent •yea'rs. ~''Important gaps in pollutant modelling and in
umder'Standing "pollutant contributions to welfare effects
...remain. However, the research area in GAP most in need of
:development ' and 'support is health effects.
In general, EPA's health effects research program.for
"Qarses and ""Parti~cl.es is'unbalanced. "A balanced research program
to"support "primary ambient Standards'development'can "be compared
"to 'a stool ;that '"requires three legs to maintain an upright
-position. ; "The"three legs of a research program for primary
ambient standards consists of "1) controlled exposures of
human volunteers,.2J•in vitro and in vivo laboratory experiments,
'and 3)' epidemiology. " "These 'three legs must be kept in balance.
Both human clinical and animal'toxicological'"research have
been supported with resources sufficient to maintain a viable
program in the period of limited resources of the past few
years. .The ..research .productivity of the Health Effects
'Research Laboratory's '(HE'RL) "animal inhalation program enjoys
a particular ^reputation. ,fqr ..scientific excellence. Among
"the' 'h~uWn~'""d:riri'ic;al "arid "animal toxicological research needs
identified, CASAC recommends that a higher priority be assigned
to aero'so'ls "arid' 'to c'cjirtbinatloris .of gases and particles. Further
work .is jaejeded in ,.evaluat_ing'" the short-term ...response of
iasthiia'ti"cs~ aiid' '"ot'K'e'lF'selis'iti've. .groups. ""Both .th_e. J3f.fxce of
;R'esvearch and.Development" '(GRD.}."."ahd the Office o'f."ki~r "duality
'J'.ia'riifirtg' "anlf ;st7and"ard1s; =(OKQPS) should develop a.p'lan to identify
_'which'jls:sues 'are ;to_J>ei'^s^u4ied _a_nd w|\ich.,' health._eji4point,s .are to
b,e' ~ '
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•_; ; j'./Tt ; seems, thai: "l£PX:i"~srv e{3'id¥mio'logical research program has
yef'tb "recover .from the 'fallout associated .w_ith Co_ng,ressional
and; other injyeS'tie[atiQns. Vf ' "the" 'Commurii'ty Health "arid Environ-
meritaj*1 •SurvVi'l'land'e ''System ('CHESS.}"'.. :' ISimilarly, it is clear
'that: 'EPA-HE'RL: will" :not_.sobn r.e"-e.;stabiish .a .major fn-house
'epidemio'logica'l' 'ret search" "program' to evaluate pollutant's such
a;s; 'sulfur oxl;d;'e;s' 'a'htf' .pa'rticuLates. The support p!f ., epidemiology,
however, is._.,a key part, . of ' EPA"'"s;. research"' ;iiri^si6n.~ ""'.'
a "cos¥iy "in~h.ou'se:
p^r.^[grKm"'alrrea;(5y exist. The Agency '."s partial
s.u,PPP j t;;, olf ; :thje. Harvard" "Six''" Cities studies",' and' it's sponsorship
'bf""t'h'e 'Uri'i'v'efsi'ty of Pittsburgh's Center of Excellence, are
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examples of effective means of generating epidemiological
data needed, by the Agency. The development of well defined
and well managed cooperative agreements between extramural
contractors and EPA provides a mechanism whereby the quality
of research can be optimized.
EPA should support, more extramural epidemiological
research. This could best be done by maintaining a small
scientific group within the agency that can: 1} establish
needs for epidemiological data in consultation with the OAQPS
and ORD scientists and managers; 2) prepare and issue requests
for research applications addressed to the Agency's need for
population response data; and 3) arrange for appropriate peer
review of the research applications received*
Such'an epidemiological program should receive a fair
share of the GAP research budget in relation to the Agency's
regulatory information neads. ^The Agency should also place
more of an emphasis on epidemiological research as a means
of developing a more balanced health effects research program.
Another important aspect of a balanced health effects
research program is long-range research that goes beyond
immediate regulatory needs and identifies new and emerging
health related issues. Up -until FY-83, these needs have
been effectively addressed by EPA's extramural grants program,
which has funded peer reviewed unsolicited research proposals.
CASAC is particularly concerned, about the lack of funds for new
grants in FY-83.
s*~
•CASAC also reviewed the GAP program for its adequacy in
planning and supporting research related to environmental
processes and,effects. It identified three broad areas of
research needed to support standard setting. They include:
1} Modelling. More source - receptor oriented relationship ;
modelling is needed for individual pollutants and for certain
easily quantified pollutant effects such as light extinction
as related to visibility. 2) Assessment of Agricultural
Losses from Air Pollutants, An excellent program, NCLAH
(National Crop Loss Assessment Network) is underway and
should receive continued support. More emphasis should be
placed on research involving interactions of ozone and other
pollutants and with other stresses such as temperature, soil
moisture, and relative humidity. 3) Effects of Air Pollution
on Timber and National Ecosystems. A program to determine
biomass losses both to commercial production and natural
ecosystems has been started. The approach is sound, the
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data should; be highly., valuable /.'-after C.A.S AC urges continuance
"of this program. "Correlated with ambient,, air quality conditions
each- year"; " the prog-ram should generate some results useful for
getting standard's.... -'_." ,..".""' " ..... ~ " ' -
... In summary ,.ithe_Committee, is., concerned .that ^any of the
most" important research';'fteeds",'r"iTa'fc,e3"' to" sulfur oxides and
"parti palate .matter, .are not ""be ing., met, particularly in the
area'-'Qf "health effects research- .This factor will delay the
resolution" of major scientific" disputes "that arise during
•the standard ^setting' process. The Committee hopes that its
••recommendations'"^iil'''pfove'''t4seful " to both, you and the Congress
'during the course, of .developing .the .'..GAP research budget for
Fiscal'-" Year ':::l§84l:'"r' ""• '"'""
Bernard D. Goldstein, Chairman
Clean'Air "Scientific Advisory
Committee
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