United States
Environmental Protection
Agency

EPA/600/R-23/375
January 2024
www.epa.gov/isa

Integrated Science
Assessment for Lead

Appendix 12: Process for Developing the Pb
Integrated Science Assessment

January 2024

Center for Public Health and Environmental Assessment
Office of Research and Development
U.S. Enviromnental Protection Agency


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DISCLAIMER

This document has been reviewed in accordance with the U.S. Environmental Protection Agency
policy and approved for publication. Mention of trade names or commercial products does not constitute
endorsement or recommendation for use.

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DOCUMENT GUIDE

This Document Guide is intended to orient readers to the organization of the Lead (Pb) Integrated
Science Assessment (ISA) in its entirety and to the sub-section of the ISA at hand (indicated in bold). The
ISA consists of the Front Matter (list of authors, contributors, reviewers, and acronyms), Executive
Summary, Integrated Synthesis, and 12 appendices, which can all be found at https://assessments.epa.gov/
isa/document/&deid=3 59536.

Front Matter

Executive Summary

Integrated Synthesis

Appendix 1. Lead Source to Concentration

Appendix 2. Exposure, Toxicokinetics, and Biomarkers

Appendix 3. Nervous System Effects

Appendix 4. Cardiovascular Effects

Appendix 5. Renal Effects

Appendix 6. Immune System Effects

Appendix 7. Hematological Effects

Appendix 8. Reproductive and Developmental Effects

Appendix 9. Effects on Other Organ Systems and Total (non-Accidental) Mortality
Appendix 10. Cancer

Appendix 11. Effects of Lead in Terrestrial and Aquatic Ecosystems
Appendix 12. Process for Developing the Pb Integrated Science Assessment

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CONTENTS

DOCUMENT GUIDE 	12-iii

LIST OF TABLES 	12-v

LIST OF FIGURES 	12-vi

ACRONYMS AND ABBREVIATIONS	12-vii

APPENDIX 12 PROCESS FOR DEVELOPING THE Pb INTEGRATED SCIENCE
ASSESSMENT 	12-1

12.1	Introduction	12-2

12.2	Documentation	12-2

12.2.1.	Literature Database: Health and Environmental Research Online	12-2

12.2.2.	Study Quality Documentation: Health Assessment Workspace Collaborative	12-3

12.3	Overview of the Process Steps for Developing Integrated Science Assessments	12-3

12.4	Relevance and Scope	12-5

12.4.1.	Atmospheric Sciences	12-5

12.4.2.	Exposure, Toxicokinetics, and Biomarkers	12-6

12.4.3.	Health 	12-7

12.4.4.	Welfare—Effects on Terrestrial and Aquatic Ecosystems	12-11

12.5	Literature Search	12-15

12.5.1. Title and Abstract Screening	12-17

12.6	Study Selection: Full-Text Screening and Evaluation of Studies	12-20

12.6.1. Individual Study Quality	12-20

12.7	Peer Review and Public Participation	12-28

12.7.1.	Request for Information	12-28

12.7.2.	Integrated Review Plan	12-29

12.7.3.	Peer Input	12-29

12.7.4.	Internal Technical Review and Clearance	12-30

12.7.5.	Clean Air Scientific Advisory Committee Peer Review	12-30

12.8	Quality Assurance and Quality Control	12-32

12.9	Conclusion	12-32

12.10	References	12-33

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LIST OF TABLES

Table 12-1	Population, Intervention, Comparison, Outcome, and Context statement to define the

parameters and provide a framework for identifying relevant atmospheric science studies_

12-6

Table 12-2 Population, Exposure, Comparison, Outcome, and Study Design statement to define the
parameters and provide a framework for identifying relevant experimental studies	

12-8

Table 12-3 Population, Exposure, Comparison, Outcome, and Study Design statement to define the

parameters and provide a framework for identifying relevant epidemiologic studies	12-10

Table 12-4 Level of Biological Organization, Exposure, Comparison, Endpoint, and Study Design
statement to define the parameters and provide a framework for identifying relevant
ecological studies	12-13

Table 12-5 Scientific considerations for evaluating the strength of inference from studies on the health

effects of Pb	12-24

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LIST OF FIGURES

Figure 12-1 General process for developing Integrated Science Assessments.	12-4

Figure 12-2 Literature flow diagram forthe Pb Integrated Science Assessment. 	12-17

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ACRONYMS AND ABBREVIATIONS

AQCD

Air Quality Criteria Document

NHANES

BLL

blood lead level



CASAC

Clean Air Scientific Advisory

ORD



Committee

Pb

CI

confidence interval

PbB

FRN

Federal Register Notice

PECOS

GFR

glomerular filtration rate



HAWC

Health Assessment Workspace
Collaborative

PICOC

HERO

Health and Environmental Research

PM



Online

PQAPP

IQ

intelligence quotient



IRP

Integrated Review Plan

QA

ISA

Integrated Science Assessment

QAPP

LECES

Level of Biological Organization,

QC



Exposure, Comparison, Endpoint, and

RBC



Study Design

SWIFT-AS

LOD

limit of detection

U.S. EPA

NAAQS

National Ambient Air Quality
Standards



NASGLP

North American Soil Geochemical
Landscapes Project



National Health and Nutrition

Examination Survey

Office of Research and Development

lead

blood lead concentration
Population, Exposure, Comparison,
Outcome, and Study Design

Population, Intervention, Comparison,
Outcome, and Context

particulate matter

Program Quality Assurance Project
Plan

quality assurance

Quality Assurance Project Plan

quality control

red blood cell

SWIFT-Active Screener

United States Environmental Protection
Agency

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APPENDIX 12 PROCESS FOR DEVELOPING THE Pb

INTEGRATED SCIENCE ASSESSMENT

Summary of Public Resources for the 2024 Pb ISA

This appendix describes the process for developing the Lead (Pb) Integrated Science
Assessment (ISA), including literature search and screening methods; peer input and peer review; and
public participation. This table summarizes the publicly available resources related to this ISA and its
development. Readers looking for Federal Register Notices (FRNs) may search http://
www.regulations.gov by either the document citation number (the reference number to the specific
FRN) or the Docket ID number (reference number for the overall docket that may house multiple
FRNs, as well as public comments in response to those FRNs).

2024 Pb ISA

https://assessments.epa. aov/isa/document/&deid=359
536

Clean Air Scientific Advisory
Committee

https://casac.epa.aov/ords/sab/f?p=113:1

Federal Register Notices

http://www.requlations.qov



Document Citation: 85 FR 40641

Request for Information



Docket ID: EPA-HQ-OAR-2020-0312-0001

Integrated Review Plan,

Document Citation: 87 FR 13732

Volume 2

Docket ID: EPA-HQ-OAR-2020-0312-0010



Document Citation: 87 FR 27147

Peer Input Workshop



Docket ID: EPA-HQ-ORD-2020-0701-0001

Pb ISA External Review

Document Citation: 88 FR 19302

Draft

Docket ID: EPA-HQ-ORD-2020-0701

Integrated Review Plan

https://www.epa.qov/naaqs/lead-pb-standards-

planninq-documents-current-review

ISA Preamble

https://cfpub.epa.qov/ncea/isa/recordisplav.cfm?deid=

310244

Literature

https://hero.epa.qov/hero/index.cfm/proiect/paqe/proie

ct id/4081

Peer Input Workshop

https://cfpub.epa.qov/ncea/isa/recordisplav.cfm?deid=

354420

Study Quality Evaluations

https://hawc.epa.qov/assessment/100500318/

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12.1 Introduction

Integrated Science Assessments (ISAs) provide the scientific foundation for the review of the
primary (health-based) and secondary (welfare1-based) National Ambient Air Quality Standards
(NAAQS). ISAs contain a synthesis and evaluation of the most policy-relevant science using methods and
approaches described in the Preamble to the Integrated Science Assessments (U.S. EPA. 2015b). hereafter
"Preamble," which provides an overview of the ISA development process. The 2024 Pb ISA builds upon
the conclusions and scientific evidence from the 2013 Pb ISA (U.S. EPA. 2013a) and prior Air Quality
Criteria Documents (AQCDs) for Pb from 1977 (U.S. EPA. 1977). 1986 (U.S. EPA. 1986). and 2006
(U.S. EPA. 2006). and includes recent literature published since September 2011, the literature cutoff date
of the 2013 Pb ISA. In March 2022, the United States Environmental Protection Agency (U.S. EPA)
released the first two volumes of the Integrated Review Plan (IRP) for the Pb NAAQS review. Volume 2
of the IRP (U.S. EPA. 2022) identifies policy-relevant issues (i.e., those intended to frame the review and
focus it on the critical scientific and policy questions related to the adequacy of the standards) and
describes key considerations in the U.S. EPA's development of the Pb ISA. Volume 2 was made available
for public comment and a consultation with the U.S. EPA's Clean Air Scientific Advisory Committee
(CASAC) Pb Review Panel at a public meeting on April 8. 2022. The 2024 Pb ISA has been developed
by U.S. EPA scientists in the Office of Research and Development (ORD), other U.S. EPA scientists with
relevant experience, and external authors from ICF, a U.S. EPA contractor. The general ISA development
steps are presented in Figure 12-1, though particular details can vary across assessments. This appendix
supplements the 2015 ISA Preamble (U.S. EPA. 2015b) and Volume 2 of the IRP (U.S. EPA. 2022). and
further describes the process of developing the 2024 Pb ISA, including methods for documentation,
literature review, study quality evaluation, public engagement, and quality assurance (QA).

12.2 Documentation

12.2.1. Literature Database: Health and Environmental Research Online

To improve transparency, studies considered in the development of the ISAs are documented in
the U.S. EPA Health and Environmental Research Online (HERO) database. The publicly accessible
HERO project page for the 2024 Pb ISA contains the references that were considered for inclusion and
provides bibliographic information and abstracts. Within HERO, each reference has a unique HERO ID

'Under The Clean Air Act section 302(h) (42 U.S.C. § 7602(h)), effects on welfare include "effects on soils, water,
crops, vegetation, manmade materials, animals, wildlife, weather, visibility, and climate, damage to and
deterioration of property, and hazards to transportation, as well as effects on economic values and on personal
comfort and well-being."

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number. References can be viewed individually or filtered by appendix, discipline, or the draft in which
they are referenced.

Inclusion and exclusion decisions for references at each stage of screening are recorded by a
tagging system and are documented in the HERO database. A two-step screening process (title and
abstract screening and full-text screening) was used for this ISA; subsequent sections of this appendix
discuss the screening process in greater detail. References that passed through title and abstract screening
are tagged in HERO as "Title-Abstract Screening Included." Inclusion and exclusion decisions from full-
text screening of references passing through title and abstract screening are tagged in HERO as "Full-Text
Screening Included." References identified from sources other than literature searches were also screened
using the same discipline-specific criteria, and inclusion and exclusion decisions for these references are
also documented in HERO. Specific data about concentrations, experimental design, and results are
reported within the appendices.

12.2.2. Study Quality Documentation: Health Assessment Workspace
Collaborative

Reference-specific information about study quality is documented in the U.S. EPA Health
Assessment Workspace Collaborative (HAWC) for select health studies and can be accessed through the
HAWC project page for this ISA. All decisions about full-text screening are additionally documented in
the HERO database and on the publicly available HERO project page for this ISA. See Section 12.6 for a
more detailed discussion about study quality.

12.3 Overview of the Process Steps for Developing Integrated
Science Assessments

As described in the Preamble and shown in Figure 12-1, developing an ISA consists of the
following steps: literature search and study selection; evaluating study quality; developing initial draft
materials for peer-input consultation; evaluating, synthesizing, and integrating evidence; and developing
scientific conclusions and causality determinations (U.S. EPA. 2015b).

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Literature Search and
Study Selection

*

Evaluation of Individual Study Quality

After study selection, the quality of individual studies is evaluated by EPA or outside experts in the fields of
atmospheric science, exposure assessment, dosimetry, animal toxicology, controlled human exposure studies,
epidemiology, ecology, and otherwelfare effects, considering the design, methods, conduct, and documentation of
each study. Strengths and limitations of individual studies that may affect the interpretation of the study are
considered.

*

Develop Initial Sections

Review and summarize new study results as well
as findings and conclusions from previous
assessments by category of outcome/effectand
by discipline, e.g., toxicological studiesoflung
function.

Peer Input Consultation

Review of initial draft materials by scientists
from both outside and within EPA in public
meeting orpublic teleconference.

*

Evaluation, Synthesis, and Integration of Evidence

Integrate evidence from scientific disciplines - for example, toxicological, controlled human exposure, and
epidemiologic study findings for a particular health outcome. Evaluate evidence for related groups of endpoints or
outcomes to draw conclusions regarding health orwelfare effect categories, integrating health orwelfare effects
evidence with information on mode of action and exposure assessment.



Development of Scientific Conclusions and Causal Determinations

Characterize weight of evidence and develop judgments regarding causality for health or welfare effect categories.
Develop conclusions regarding concentration- or dose-response relationships, potentially at-risk populations,
lifestages, or ecosystems.

it	

Draft Integrated Science Assessment

Evaluation and integration of newly published studies
after each draft.

Clean Air Scientific Advisory Committee

Independent review of draft documents for scientific
quality and sound implementation of causal
framework; anticipated review of two drafts of ISA in
public meetings.

Public Comments

Comments on draft ISA solicited by EPA

Final Integrated Science Assessment

Source: Modified from Figure II of the Preamble to the Integrated Science Assessment (U.S. EPA. 2015b).

Figure 12-1 General process for developing Integrated Science Assessments.

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12.4 Relevance and Scope

As a synthesis and evaluation of the most policy-relevant science, the 2024 Pb ISA includes
information on atmospheric science, exposure assessment, experimental health studies, epidemiologic
health studies, and studies of effects on terrestrial and aquatic ecosystems. For the 2024 Pb ISA, "policy-
relevant" science is described in Volume 2 of the IRP (U.S. EPA. 2022) as referring to "scientific
information and analyses intended to address key questions related to the adequacy of the standards."
Those "key questions" are also laid out in Volume 2 of the IRP. As stated in the Preamble (U.S. EPA.
2015b). "The key policy-relevant questions included in the IRP serve to clarify and focus the NAAQS
review on the critical scientific and policy issues, including addressing uncertainties discussed during the
previous review and newly emerging literature." The sections below describe the approaches and scoping
statements used to identify relevant studies in each discipline. The use of scoping statements to define
study relevance is consistent with recommendations by the National Academies of Sciences, Engineering,
and Medicine for improving the design of risk assessment through planning, scoping, and problem
formulation to better meet the needs of decision makers (NASEM. 2018).

12.4.1. Atmospheric Sciences

Studies were considered relevant for inclusion in the 2024 Pb ISA if they were judged to provide
original data and to substantially advance the understanding of Pb emission sources; atmospheric and
environmental processes (including chemistry and transport); measurement and estimation methods; or
recent concentrations and trends. This approach to determining study relevance required judgments about
whether a subject area of the research had the potential to inform policy specific to the NAAQS, and
whether a study published in the area provided sufficiently original results to add to the existing body of
knowledge.

Table 12-1 shows the relevance criteria used for broadly identifying recent environmental
research advances and knowledge gaps. These criteria are based on the approach described by Mengist et
al. (2020). who formulated a Population, Intervention, Comparison, Outcome, and Context (PICOC)
statement that designated the population as the population of scientific research work itself and the
outcome as the assessment of its knowledge and gaps.

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Table 12-1 Population, Intervention, Comparison, Outcome, and Context

statement to define the parameters and provide a framework for
identifying relevant atmospheric science studies

Concept	Application

Population Include policy-relevant scientific research on Pb source emissions, environmental processes
(including chemistry and transport), measurement and estimation methods, and concentration
and trends.

Intervention Assess policy-relevant scientific advances and knowledge gaps.

Comparison Evaluate emissions, concentrations, and their rates of change across sources, atmospheric and
environmental processes, measurement and estimation methods, long-term temporal scales,
seasons, diurnal cycles, geographic regions, and urban and neighborhood spatial scales.

Outcome Identify policy-relevant scientific advances and knowledge gaps.

Context	Focus on policy-relevant research performed in the United States or Canada; for some topics,

research performed outside of the United States or Canada can be excluded if sources or
concentrations are not relevant to the United States or if the body of research is very large; for
other topics, if source and concentration differences are not relevant to the topic or the number of
publications is very small, non-U.S. research can be included.

Pb = lead.

12.4.2. Exposure, Toxicokinetics, and Biomarkers

The following guidelines were used to judge the relevance of studies examining Pb exposures,
toxicokinetics, and biomarkers. Studies were included if they provided original data and substantially
advanced understanding of Pb exposure through environmental media and other pathways; Pb
toxicokinetics including uptake, distribution, metabolism, and elimination from the body; Pb biomarker
measurement techniques; Pb biomarker concentration trends; and the relationships between Pb in
environmental media and Pb biomarker concentrations, including biokinetic and empirical modeling of
those relationships.

Exposure studies pertaining to the U.S. population and U.S.-based Pb sources were preferred.
Studies were included from outside the United States if these studies were judged to have important
findings, with a focus on studies from Canada, western Europe, and Australia (i.e., areas with study
populations and air quality characteristics most similar to the United States). If it was deemed that studies
from the United States, Canada, western Europe, or Australia were not adequate (i.e., little to no
information that advanced understanding of a particular topic was found), then it was necessary to
consider all studies regardless of geographic location. For Pb toxicokinetics and biomarker measurement
techniques, studies, regardless of geographic location, were considered since the physical location in
which a study took place may have less bearing on results. Finally, although exposures in relation to Pb in
ambient air and originating from air-related sources are the focus of the appendix, studies containing Pb
concentrations in other media (soil, dietary sources, consumer products, occupational sources, and
ammunition) were included because cumulative body burden can occur as a result of contributions from

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multiple exposure pathways (e.g., ingestion of Pb-containing soil by children) and the origin of Pb can be
difficult to determine as stemming from an air-related source.

12.4.3. Health

Relevance for studies that evaluate the relationship between Pb exposure and health effects was
assessed using scoping statements that define the relevant Population, Exposure, Comparison, Outcome,
and Study Design (PECOS). Discipline-specific PECOS statements for epidemiologic and experimental
studies (i.e., animal toxicology studies) were developed to establish inclusion criteria based on the
objectives of the review, facilitating identification of the most relevant literature to inform the Pb ISA
(Table 12-2 and Table 12-3). In some cases, PECOS statements differ by health outcome depending on
well-established areas of research; gaps in the literature; and inherent uncertainties in specific
populations, exposure metrics, comparison groups, and study designs identified in the 2013 Pb ISA.
Additionally, some epidemiologic PECOS statements were further refined to emphasize the strongest
recent epidemiologic studies that address key uncertainties from the previous review; these PECOS
refinements are identified and described in detail in the relevant appendices. The use of PECOS
statements is widely accepted and often applied in the health disciplines for systematic review in risk
assessment. PECOS statements for the 2024 Pb ISA can also be found in each health effects appendix.

12.4.3.1. Experimental Studies

For experimental studies (specifically animal exposure studies), the relevance evaluation focused
on studies with appropriate study designs and relevant exposure concentrations (Table 12-2). The scope
of the experimental evidence used for the 2024 Pb ISA encompassed studies of nonhuman mammalian
animal species with exposures that are relevant to the range of human exposures (blood Pb levels [BLLs]
up to 30 (ig/dL, which is about one order of magnitude above the 95th percentile of the 2011-2016
National Health and Nutrition Examination Survey [NHANES] distribution of BLLs in children) (Eganet
al.. 2021).

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Table 12-2

Population, Exposure, Comparison, Outcome, and Study Design



statement to define the parameters and provide a framework for



identifying relevant experimental studies

Concept

Application

Population

Laboratory nonhuman mammalian animal species (i.e., mouse, rat, Guinea pig, minipig, rabbit,



cat, dog; whole organism) at any lifestage (including preconception, in utero, lactation,



peripubertal, and adult stages).

Exposure

Oral, inhalation, or intravenous routes administered to a whole animal (in vivo) that results in a



BLL of 30 pg/dLor below.ab

Comparison

A concurrent control group exposed to vehicle-only treatment or untreated control.

Outcome

Cancer and noncancer health outcomes including cardiovascular, dermal, developmental,



endocrine system, gastrointestinal, hematological, hepatic, immunological, metabolic syndrome,



musculoskeletal, neurological, ocular, renal, reproductive, or respiratory effects.

Study

Controlled exposure studies of animals in vivo.

Design



BLL = blood lead level; Pb = lead.

aPb mixture studies are included if they employ an experimental arm that involves exposure to Pb alone.

This level is approximately an order of magnitude above the upper end of the distribution of U.S. young children's BLLs. The
95th percentile of the 2011-2016 NHANES distribution of BLL in children (1-5 years; n = 2,321) is 2.66 |jg/dL (Egan et al.. 2021).
and the proportion of individuals with BLLs that exceed this concentration varies depending on factors including housing age,
geographic region, and a child's age, sex, and nutritional status.

12.4.3.2. Epidemiologic Studies

To identify the most relevant epidemiologic literature, the body of evidence from the 2013 Pb
ISA was considered in the development of the PECOS statements. Specifically, the scope of the current
assessment is informed by well-established areas of research, gaps in the literature, inherent uncertainties
in specific populations, exposure metrics, comparison groups, and study designs identified in the 2013 Pb
ISA. The evaluation of epidemiologic studies focused on the association between exposure to Pb (as
indicated by Pb levels in blood, bone, and teeth; validated environmental indicators of Pb exposure; or
intervention groups in randomized trials and quasi-experimental studies) and an ensemble of health
effects, including effects on the nervous system, cardiovascular effects, and reproductive and
developmental outcomes (Table 12-3). Emphasis was placed on studies conducted in non-occupationally
exposed populations, but recent longitudinal studies of occupational exposure to Pb published since the
literature cutoff date for the 2013 Pb ISA were considered insofar as they addressed atopic that was of
particular relevance to the NAAQS review (e.g., longitudinal studies designed to examine recent versus
historical Pb exposure). Additionally, the following types of epidemiologic studies are generally
considered to fall outside the scope and are not included in the ISA: review articles (which typically
present summaries or interpretations of existing studies rather than bringing forward new information in
the form of original research or new analyses); Pb poisoning studies or clinical reports (e.g., involving
accidental exposures to very high amounts of Pb described in clinical reports that may be extremely
unlikely to be experienced under ambient air exposure conditions); and risk or benefit analyses (e.g., that
apply existing concentration-response functions or effect estimates to exposure estimates for differing

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cases). Although review articles are not typically included in the health sections of the ISA, they are
identified and tracked during the literature searching and study selection phase of the assessment. These
reviews are often consulted to ensure that all relevant literature has been identified and to track key issues
related to a particular evidence base.

For some health outcomes for which the evidence assessed in the 2013 Pb ISA supported a
"causal" relationship, the epidemiologic PECOS statements were refined in order to further emphasize the
strongest recent epidemiologic studies that address the key uncertainties from the previous review and the
scientific questions in Volume 2 of the IRP (U.S. EPA. 2022). These PECOS refinements, which are
identified and described in detail in the relevant appendices, generally focus on the most informative
study designs and relevant BLLs, and emphasize control for important potential confounders that were
identified in the 2013 Pb ISA. Studies that met the broader PECOS criteria in Table 12-3, but were no
longer relevant under the refined criteria were still included in evidence inventories that summarize key
study details, including study population, exposure assessment, confounders, and select results.

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Table 12-3 Population, Exposure, Comparison, Outcome, and Study Design statement to define the parameters
and provide a framework for identifying relevant epidemiologic studies

Population: Any human population, including specific populations or lifestages that might be at increased risk of a health effect.

Exposure: Exposure to Pba as indicated by biological measurements of Pb in the body, with a specific focus on Pb in blood, bone, and teeth; validated environmental
indicators of Pb exposure, or intervention groups in randomized trials and quasi-experimental studies.

Comparison: Populations, population subgroups, or individuals with relatively higher versus lower levels of the exposure metric (e.g., per unit or log unit increase in the
exposure metric, or categorical comparisons between different exposure metric quantiles).

Outcome

Nervous System

Cardiovascular

Renal

Immune

Hematological

Reproductive

Developmental

Cancer

Other

Nervous system

Cardiovascular

Renal

Immune system

Hematological

Reproductive

Developmental

Cancer

Effects on the

effects including

effects including

effects

effects including

effects including

effects, including

effects, including

incidence,

hepatic system,

cognitive function

coronary heart

including

immunotoxicity,

disruption of

altered age of

adverse

mortality, or

gastrointestinal

(e.g., IQ decrement),

disease,

elevated

systemic

heme synthesis

puberty onset,

pregnancy

related

system,

externalizing and

hypertension

serum

inflammation, and

and RBC

reduced fertility,

outcomes (e.g.,

biomarkers.

endocrine

internalizing

and increased

creatinine

immune-based

function.

poor semen

reduced fetal



system, bone

behaviors,

blood pressure,

levels and

diseases.



quality or

growth, preterm



and teeth, ocular

psychopathological

and

lower





motility, and

birth, small for



health, and

effects, sensory

cardiovascular-

GFR.





miscarriage.

gestational age,



respiratory

organ function, motor

related mortality.









birth defects), as



system.

function, and











well as postnatal





neurodegenerative











developmental





diseases.











effects.





Study Design: Epidemiologic studies consisting of longitudinal and retrospective cohort studies, case-control studies, cross-sectional studies with appropriate timing of
exposure for the health endpoint of interest, randomized trials, and quasi-experimental studies examining interventions to reduce exposures.

GFR = glomerular filtration rate; IQ = intelligence quotient; Pb = lead; RBC = red blood cell.

aThe focus was on populations with nonoccupational Pb exposures, though recent longitudinal studies of occupational exposure to Pb were considered insofar as they addressed a topic that
was of particular relevance to the NAAQS review (e.g., longitudinal studies designed to examine recent versus historical Pb exposure).

bStudies that estimate Pb exposure by measuring Pb concentrations in particulate matter with a nominal mean aerodynamic diameter less than or equal to 10 |jm (PM10) and particulate matter
with a nominal mean aerodynamic diameter less than or equal to 2.5 |jm (PM25) ambient air samples are only considered for inclusion if they also include a relevant biomarker of exposure (e.g.,
Pb in blood, bone, or teeth). Given that size distribution data for Pb-PM are fairly limited, it is difficult to assess the representativeness of these concentrations to population exposure [Section
2.5.3 (U.S. EPA. 2013a1l. Moreover, data illustrating the relationships of Pb-PM10 and Pb-PM2.5 with blood Pb levels are lacking.

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12.4.4. Welfare—Effects on Terrestrial and Aquatic Ecosystems

For welfare effects (i.e., on terrestrial and aquatic ecosystems), scoping statements defining the
Level of Biological Organization, Exposure, Comparison, Endpoint, and Study Design (LECES) were
used. U.S. EPA developed the LECES based on the PECOS with some concepts substituted to provide a
better fit with ecological science. In the LECES, "population" (PECOS) is replaced with "level of
biological organization" (LECES) and "outcome" (PECOS) is replaced with "endpoint" (LECES). A
LECES statement was developed for terrestrial and aquatic ecosystems.

For research evaluating ecological effects, emphasis was placed on recent studies published since
the literature cutoff date of the 2013 Pb ISA that: (1) evaluated effects at concentrations at or near current
environmental concentrations of Pb in soil, water, and sediment and (2) investigated effects on species,
subspecies, or study populations of algae and plants, microbes, invertebrates, or vertebrates at any
lifestage or in any biological community or ecosystem. Exposure concentrations, endpoints, and study
types considered for the 2024 Pb ISA that inform understanding of the ecological effects of Pb in
terrestrial and aquatic systems are summarized further in the LECES statement (Table 12-4). For
exposure concentrations, guidelines were used when screening studies for inclusion. These guidelines
took into consideration data that was current at the time of the 2013 Pb ISA on Pb concentrations in soils,
water, and sediments in the United States (Table 1-1 from the 2013 Pb ISA). The concentration guideline
for literature screening in the 2024 Pb ISA is approximately one order of magnitude higher than upper
bound values from available environmental surveys for soils, water, and sediment (refer to the footnotes
in Table 12-4). For soil, the concentration guideline for screening of terrestrial studies of Pb exposure and
effects was set at approximately 230 mg Pb/kg of soil, although higher concentrations were considered if
the study added new information on a mechanism of action, or if the higher concentration was part of a
series that contributed exposure-response information and included other concentrations below 230 mg
Pb/kg. For aqueous exposures, the concentration guideline for study screening was approximately 10 |ig
Pb/L, although higher concentrations were considered if the study added new information on a
mechanism of action or if the higher concentration was part of a series that contributed exposure-response
information. For sediments, the concentration guideline for study screening was approximately 300 mg
Pb/kg dry weight or lower. Studies at very high concentrations of Pb in soils, water, and sediments were
excluded unless they were part of a series in an experimental exposure-response study and at least one
concentration in the test series was in the ranges stated above (Table 12-4).

In addition to the biological effects described in the LECES statement, other topics within scope
included how chemical and biological modifying factors affect bioavailability in terrestrial, freshwater,
and saltwater environments, as well as studies that address key uncertainties and limitations in the
evidence identified in the 2013 Pb ISA. Site-specific studies in non-U.S. locations that do not contribute
to novel insights into Pb biogeochemistry or effects are considered outside of the scope of the 2024 Pb

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ISA. Studies on mine tailings, biochar, industrial effluent, sewage, ship breaking, bioremediation of
highly contaminated sites, and ingestion of Pb shot, fishing tackle, or pellets are also outside the scope of
the 2024 Pb ISA due to the high concentration of Pb and lack of a connection to an air-related source or
process.

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Table 12-4 Level of Biological Organization, Exposure, Comparison, Endpoint, and Study Design statement to
define the parameters and provide a framework for identifying relevant ecological studies

Level of Biological Organization: Species or subspecies, study populations of vegetation, microbes, invertebrates, or vertebrates, at any
lifestage, or any biological community or ecosystem in terrestrial environments present in the United States or similar to those in the United States.

Exposure: Short or long-term Pb concentrations in exposure media (e.g., soil or diet) that are most relevant to environmental concentrations of Pb
in the United States.3 For soil, the guideline for screening of terrestrial studies of Pb exposure and effects was defined as a concentration of
approximately 230 mg Pb/kg,b with higher concentrations considered if the study elucidates a mechanism or is an acute exposure and at least one
concentration in the test series is in the range described above. Analytically verified exposure concentrations preferred; nominal concentrations
considered in some cases.

Terrestrial

Comparison: A comparison to an unexposed laboratory control, a reference population, or site with no detectable exposure or with lower Pb
exposure.

Endpoint: Species or population effects including effects on growth, reproduction or development, neurobehavioral effects, reduced survival or
fitness, carbon fixation and photosynthesis. At higher levels of biological organization endpoints include changes in community composition,
altered ecosystem processes and functions, such as productivity, community composition, or shifts in genotypes or species, species extirpation,
declines in total number of species or biomass, or decreased species richness.

Study Design: Laboratory, mesocosm, observational or experimental field or gradient studies, or mechanistic modeling studies that estimate the
effect of Pb on an organism, biological population, community, or ecosystem whose processes may be represented quantitatively (e.g., in a
dynamic or steady state).

Level of Biological Organization: Species and subspecies, study populations of vegetation, microbes, invertebrates, or vertebrates, at any
lifestage, or any biological community or ecosystem in freshwater or saltwater environments and transition zones present in the United States, or
similar to those in the United States, excluding the open ocean.

Exposure: Short or long-term Pb concentrations in exposure media (e.g., water, sediment, or diet) that are most relevant to environmental
concentrations of Pb in the United States.3 For freshwater or saltwater, the guideline for screening of Pb exposure and effects was defined as a
concentration of approximately 10 |jg Pb/Lc with higher concentrations considered if the study elucidates a mechanism plausibly relevant at lower
concentrations. For sediments, exposure concentration of approximately 300 mg Pb/kg, dry weight.d For dietary pathways, at least one
experimental group (prey) exposed to approximately 10 |jg Pb/L (aqueous guideline for screening) prior to a feeding study. If a study provides
Aquatic toxicity data on a previously untested organism grouping (such as Class, Order, Family) or for lower concentration studies of an organism with a
protected status, studies were included even if concentrations exceeded the guideline. Analytically verified exposure concentrations preferred;
nominal concentrations considered in some cases.

Comparison: A comparison to an unexposed laboratory control, a reference population, or site with no detectable exposure or with lower Pb
exposure.

Endpoint: Species or population effects including effects on growth, reproduction or development, neurobehavioral effects, reduced survival or
fitness, carbon fixation and photosynthesis. At higher levels of biological organization endpoints include changes in community composition,
altered ecosystem processes and functions, such as productivity, or shifts in genotypes or species, species extirpation, declines in total number of
species or biomass, or decreased species richness.

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Study Design: Laboratory, mesocosm, observational or experimental field or gradient studies or mechanistic modeling studies that estimate the
effect of Pb on an organism, biological population, community, or ecosystem whose processes may be represented quantitatively (e.g., in a
dynamic or steady state).

Pb = lead.

aStudies on mine tailings, industrial effluent, land-applied sewage sludge, ship breaking, bioremediation of highly contaminated sites, and ingestion of Pb shot or pellets are not
within the scope of the ISA due to a high concentration of Pb or lack of a connection to an air-related source or process. Generally excluded are studies of metal mixtures for which
a specific effect of Pb was not separated unless conducted in biological systems with limited experimental evidence. Lastly, most site-specific studies conducted outside of North
America that do not contribute novel insights on Pb biogeochemistry or effects are excluded.

bThe guideline for screening of terrestrial studies of Pb exposure and effects is based on the values reported for soils of the conterminous United States in the 2013 United States
Geological Survey report "Geochemical and mineralogical data for soils of the conterminous United States" (Smith et al.. 2013). This survey was conducted between 2007 and 2013
and sampled three soil horizons (surface, A, and C) at 4,857 nonurban, non-near-road sites. The Q1, median, mean, and Q3 values in surface soil (0-5 cm) for 4841 locations for
which Pb data was available in North American Soil Geochemical Landscapes Project (NASGLP) were 13.5, 18.1, 25.8, and 23.9 mg Pb/kg soil. The Q1, median, mean, and Q3
values in the A horizon (relevant for plants, invertebrates, and microorganisms as well as burrowing mammals and reptiles) for 4,841 locations for which Pb data was available in
NASGLP were 13.2, 17.8, 22.2, and 23.2 mg Pb/kg soil. The 230 mg Pb/kg soil concentration guideline is approximately one order of magnitude higher than the Q3 values from the
survey.

°The guideline for screening of Pb concentration in water is based on United States Geological Survey National Water Quality Assessment sampling for which the 2006 Pb AQCD
reported summary statistics as of the time (U.S. EPA. 2006). The 99th and 95th percentile dissolved Pb values were 5.44 |jg/L and 1.1 |jg/L, respectively (see Table 6-2 in the 2013
Pb ISA) (U.S. EPA. 2013a). A more relevant upper bound value for dissolved Pb would be closer to 1 |jg/L, and 10 |jg/L is one order of magnitude above that value. As dissolved
Pb concentrations in saltwater would be expected to be no higher—and generally, lower—than concentrations in freshwater (due to odds of greater proximity of freshwaters to
anthropogenic sources and less access to mixing), an upper bound for saltwater would reasonably be expected to be lower than that for freshwater concentrations.

dThe guideline for Pb screening in sediment is based on an older survey of urban and reference lake sediments across the United States. (Mahler et al., 2006) and further
supported by evidence from more recent regional survey data. A median 1990s concentration for 35 U.S. sites (Table 2 of (Mahler et al.. 2006)) of 73 mg Pb/kg was reported and
the paper concluded that Pb had decreased since 1970s, with the 1990s median being 40% lower than the 1970s median. For saltwater, Kim et al. (2004) reported samples in a
lower Delaware coastal saltmarsh that would be expected to have much less historic and non-air contamination. The concentrations for the upper depths (0 to 5 cm), dated to reflect
the 90s through the early 2000s, range from 20 to 30 mg/kg. Thus, 30 mg/kg appears to be a more appropriate upper bound value for freshwater and saltwater sediments, and 300
mg Pb/kg is one order of magnitude above that value.

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12.5 Literature Search

The U.S. EPA uses a structured approach to identify relevant studies for consideration and
inclusion in the ISAs. The search for relevant literature in this review began with publishing a Request for
Information FRN (July 7, 2020, 85 FR 40641). This FRN announced the initiation of this Pb NAAQS
review and invited the public to submit relevant research studies and data that have been published,
accepted for publication, or presented at a public scientific meeting since January 1, 2011, providing
overlap with the 2013 Pb ISA wherein the literature considered extended to September 2011. Literature
submitted by the public in response to this FRN can be viewed in the U.S. EPA's HERO database. U.S.
EPA reviewed these studies for relevance following the literature screening process described in this
appendix.

In addition to the Request for Information FRN, the U.S. EPA applied systematic review
methodologies to identify peer-reviewed scientific literature relevant to the 2024 Pb ISA. The literature
searching and screening methodology used for the 2024 Pb ISA generally followed the process depicted
in Figure 12-2. The process began with a combination of keyword searches and citation network searches
to find relevant literature in PubMed and Web of Science published between September 2011 and
December 2020. This literature search strategy was designed to maximize precision2 and recall3 for each
discipline (i.e., health, welfare effects, atmospheric sciences, and exposure). The literature then went
through two levels of screening to identify relevant studies: (1) title and abstract screening using SWIFT-
Active Screener (SWIFT-AS), and (2) full-text screening if the peer-reviewed paper was deemed
potentially relevant after title and abstract screening.

Keyword searches were developed for each appendix using strings of relevant search terms to
capture literature relevant to Pb and the topics in each appendix. For human health search results,
automatic topic classification, a process that uses machine learning to classify references based on a set of
already identified relevant papers, was then used to separate epidemiologic references from experimental
references. In addition to keyword searches, topic-specific citation network searches for all disciplines
were used to identify publications that cite references included in the 2013 Pb ISA. This approach allows
for relevance ranking: given a set of seed references from the 2013 Pb ISA, the more seed references that
a new reference cites, the more likely that new reference is to be relevant. In addition, a small number of
references were also identified for consideration in the 2024 Pb ISA through identification of relevant
literature by U.S. EPA expert scientists; recommendations received in response to the Request for
Information and the Peer Input Workshop; and by review of citations included in previous assessments or
in newly identified literature. Reviewers during the Peer Input Workshop were asked to provide a list of

Precision is the proportion of relevant references relative to all references retrieved in a literature search.
3Recall is the proportion of relevant references identified by screening, relative to the total number of relevant
references that exist.

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additional references (if any) that the U.S. EPA should consider for the ISA, including those published
since the initial literature search.

Following the 2022 Peer Input Workshops and prior to the release of the External Review Dra ft,
the U.S. EPA updated the initial literature searches. These searches were conducted in response to
comments received on the IRP Volume 2 from the CASAC consultation, and feedback received during
the Peer Input Workshops. The updated literature searches targeted key, policy-relevant topics (i.e.,
"scientific information and analyses that address key questions related to the adequacy of the standards"
(U.S. EPA. 2022)) most informative to reviewing the Pb NAAQS to ensure that literature published since
the cutoff date of the initial literature searches was captured. For the selected health effects (i.e., nervous
system, cardiovascular, and reproductive and developmental health effects) the updated literature search
captured epidemiologic and experimental literature published between December 2020 and June 2022.
For effects of Pb in terrestrial and aquatic ecosystems, the updated literature search included the date
range of August 2020 to June 2022 and focused on studies reporting effects on growth, reproduction, and
development or survival. For atmospheric sciences, the same search strings used for the original search
were applied to the date range of August 2020 to June 2022. The U.S. EPA then conducted title and
abstract and full-text screening steps to these additional references.

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Pb = lead.

Figure 12-2 Literature flow diagram for the Pb Integrated Science
Assessment.

12.5.1. Title and Abstract Screening

Consistent with the 2020 Ozone ISA (U.S. EPA. 2020b). the U.S. EPA used SWIFT-AS to
perform the first-level screening of the search results for relevance, based on the title and abstract.

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SWIFT-AS is a web-based literature screening software application that uses machine learning to allow
screeners to efficiently screen literature for relevance (Howard et al.. 2020). It ranks search results by
descending likely relevance using a bag-of-words approach and Latent Dirichlet Allocation, trained by
both the scrccner's inclusion and exclusion decisions and a positive training set, when supplied (Howard
et al.. 2016). The U.S. EPA used such a set of "seed references" (references known to be relevant from
the 2013 Pb ISA). As references are screened and tagged as relevant or not relevant, the ranking model is
further trained to sort the remaining literature, pushing predicted relevant literature to the top of the queue
of references to be screened. U.S. EPA screened literature until SWIFT-AS estimated that 95% of
relevant literature was included, a threshold considered comparable to human error rates (Howard et al..
2020; Cohen et al.. 2006).

12.5.1.1. Atmospheric Science

Initial literature related to air quality, atmospheric chemistry, fate, and transport discussed in
Appendix 1 of the 2024 Pb ISA, Lead Source to Concentration, was identified using a strategy consistent
with the approach described in Volume 2 of the IRP (U.S. EPA, 2022). The search involved both a
citation network search and a keyword search component. For all air sections (Appendix 1, Sections 1.2,
1.3.1, 1.3.4. 1.4. and 1.5). the citation network search identified all publications that cited any references
from the 2013 Pb ISA chapter, Ambient Lead: Source to Concentration (U.S. EPA, 2013a), and a
keyword search was developed to capture additional relevant publications in the Web of Science database
that did not cite any 2013 Pb ISA references. The search string was tested to confirm it would achieve
greater than 99% recall when applied to the 2013 Pb ISA chapter references. Literature for the fate and
transport sections on soil and water (Appendix 1, Sections 1.3.2 and 1.3.3) was obtained in a similar
manner, using the citation network and keyword searches used for terrestrial and aquatic ecosystems
(Section 12.5.1.4). SWIFT-AS was used for title and abstract screening with seed references from the
2013 Pb ISA. Decisions about inclusion or exclusion were guided by the PICOC statement (Table 12-1).

After the Peer Input Workshop (Section 12.7.3), the literature search was updated using the same
two search strings originally applied to the Web of Science database for references published after the
original cutoff date. Consistent with the initial literature search, the U.S. EPA screened these additional
studies for relevance using SWIFT-AS; decisions about relevance were guided by the PICOC statement.

12.5.1.2. Exposure Assessment

Initial literature related to ambient Pb exposure, toxicokinetics, and biomarkers discussed in
Appendix 2 of the 2024 Pb ISA, Exposure, Toxicokinetics, and Biomarkers, was identified using a
keyword search strategy consistent with the approach described in Volume 2 of the IRP (U.S. EPA.
2022). This search involved both a citation network search and a keyword search. The citation network

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search was designed to identify all publications that cited any references from Chapter 3: Exposure,
Toxicokinetics, and Biomarkers of the 2013 Pb ISA (U.S. EPA, 2013a).

Two separate keyword searches were developed to capture additional relevant publications that
did not cite any 2013 Pb ISA references from the Web of Science and PubMed databases, respectively.
The inclusion and exclusion terms used for each search were developed independent of one another to
maximize the relevance for each database. Given the extensive overlap between publications that
contained information on Pb exposure, biomarkers, and toxicokinetics, both keyword searches were
performed on all topics in the appendix. Results from both searches were combined and literature was de-
duplicated.

SWIFT-AS was used for title and abstract screening. The SWIFT-AS algorithm was initially
trained using references from Chapter 3: Exposure, Toxicokinetics, and Biomarkers of the 2013 Pb ISA
(U.S. EPA, 2013a) as seed references. Literature tags were developed to organize results by subsection.
Judgments of inclusion and exclusion were based on guidelines described in the Relevance and Scope
section above (Section 12.4.2).

Following the 2022 Peer Input Workshop, peer input reviewers determined that the U.S. EPA had
identified most of the relevant literature. Suggested additions were screened for relevance and judgments
of inclusion and exclusion were based on guidelines described in the Relevance and Scope section above
(Section 12.4.2).

12.5.1.3. Health

Epidemiologic and experimental studies (i.e., animal toxicology studies) examining health effects
from Pb exposure were targeted using a broad keyword search and citation network search strategy
consistent with Volume 2 of the IRP (U.S. EPA, 2022). U.S. EPA screened the identified literature for
relevance against PECOS statements for each health endpoint (see Section 12.4.3), using SWIFT-AS.
The SWIFT-AS algorithm was trained initially using seed references from the 2013 Pb ISA (U.S. EPA,
2013a).

During this first phase of screening, the U.S. EPA tagged experimental studies reporting health
outcome-related literature that potentially informs the biological or chemical events associated with
phenotypic effects, including in vitro, in vivo (by various routes of exposure), ex vivo, and in silico
studies. Although these studies do not necessarily meet PECOS criteria, they were tracked as a
supplemental evidence stream to inform biological plausibility.

Following the 2022 Peer Input Workshop, the U.S. EPA updated the literature search for the
following health outcome categories using the same keyword and citation network search strategy:
nervous system effects (Appendix 3); cardiovascular effects (Appendix 4); and reproductive and
developmental effects (Appendix 8). The updated literature search focused on key, policy-relevant health

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outcomes for which a substantial body of recent literature conducted at relevant Pb biomarker levels was
expected, as suggested by results from the initial search. Consistent with the initial literature search, the
U.S. EPA screened these additional studies for relevance using SWIFT-AS and the PECOS statements.

12.5.1.4. Welfare—Effects on Terrestrial and Aquatic Ecosystems

Studies potentially relevant to Pb effects in terrestrial or aquatic ecosystems (freshwater and
saltwater) were identified using a broad keyword search and citation network search strategy consistent
with the approach described in Volume 2 of the IRP (U.S. EPA, 2022). The U.S. EPA screened the
identified literature for relevance against LECES statements using SWIFT-AS (Table 12-4). The SWIFT-
AS algorithm was trained initially using seed references from the 2013 Pb ISA (U.S. EPA, 2013a).
Studies that were not within the scope of the ISA or that did not meet the criteria for inclusion based on
title and abstract screening (Section 12.4.4 and Table 12-4) were excluded from further consideration.
Following the 2022 Peer Input Workshop, the U.S. EPA updated the literature search and screened
additional studies in SWIFT-AS for relevance using the LECES statements.

12.6 Study Selection: Full-Text Screening and Evaluation of
Studies

The U.S. EPA performed a second level of screening based on assessment of the full text of the
references remaining after the first-level screening (title and abstract). The U.S. EPA continued to use
relevance criteria outlined in Section 12.4 during full-text screening. Studies selected for inclusion based
on relevance were evaluated for study quality, as described below.

12.6.1. Individual Study Quality

After selecting studies for inclusion based on relevance, individual study quality was evaluated by
considering the design, methods, conduct, and documentation of each study, but not the study results. For
ISAs, the overall individual study quality evaluation process is described in the Preamble (U.S. EPA.
2015b). which outlines a base set of questions for consideration when evaluating the scientific quality of
studies, intended for use in both human health and ecological studies:

• Were the study designs, study groups, methods, data, and results clearly presented in relation to
the study objectives to allow for study evaluation? Were limitations and any underlying
assumptions of the design and other aspects of the study stated?

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•	Were the ecosystems, study site(s), study populations, subjects, or organism models adequately
selected, and are they adequately defined to allow for meaningful comparisons between study or
exposure groups?

•	Are the air quality, exposure, or dose metrics of adequate quality and are they sufficiently
representative of or pertinent to ambient air?

•	Are the welfare effect measurements meaningful, valid, and reliable?

•	Were likely covariates or modifying factors adequately controlled or taken into account in the
study design and statistical analysis?

•	Do the analytical methods provide adequate sensitivity and precision to support conclusions?

•	Were the statistical analyses appropriate, properly performed, and properly interpreted?

Worldwide, formal methods for individual study quality evaluation are much better developed for
human health research than for ecological, atmospheric, and exposure studies. The study quality approach
for health and welfare are described further below. For the 2024 Pb ISA, atmospheric and exposure
studies were considered acceptable if they were published in a peer-reviewed journal, though further
scrutiny was applied during full-text screening of exposure studies to identify whether the exposure
assessment methods were clearly described; the selected exposure assessment methods were appropriate
for the research question evaluated; the assumptions of the method(s) were clearly stated; the
uncertainties and limitations of the methods were clearly stated; and QA testing had been performed. No
studies in the atmospheric or exposure, toxicokinetics, and biomarkers appendices were deemed to have
unacceptable study quality.

Study quality was a final step in full-text screening to decide whether to include a study in the
ISA. Any references that did not pass the study quality review and deemed uninformative for the purposes
of this assessment were excluded from the ISA. Studies that passed both the relevance screening and the
study quality evaluation were included in the ISA. The combination of approaches described in this
section are intended to produce a comprehensive collection of pertinent studies needed to address the key
scientific issues that are examined in the ISA.

12.6.1.1. Health

As described in the Preamble (U.S. EPA. 2015b). causality determinations are informed by
integrating evidence across scientific disciplines (e.g., exposure, animal toxicology, epidemiology) and
related outcomes, and by judgments of the strength of inference in individual studies. For health
outcomes, study quality is evaluated using a uniform approach that considers study strengths and
limitations, including the possible roles of chance, confounding, and other biases that may influence
results. The process for individual study quality evaluation has been refined by discipline with each

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successive ISA based on input and feedback from numerous reviews by CAS AC. Recent IS As have
developed study quality criteria tables to provide clarity on important aspects of study quality for health
outcomes and serve as the foundation for the review of individual health studies (U.S. EPA, 2020b, 2019,
2017, 2016). These aspects describe the characteristics of study elements (e.g., study design, exposure
assessment, potential confounding factors) that can increase or decrease confidence in the study results.
Where possible, study elements, such as exposure assessment and confounding (i.e., bias due to a
relationship with the outcome and correlation with exposures to Pb) are tailored to address factors specific
to health studies of Pb exposure. Thus, judgments on the ability of a study to inform the relationship
between an air pollutant and health vary depending on the specific pollutant being assessed.

Table 12-5 describes the aspects considered in evaluating study quality of animal toxicological
and epidemiologic studies considered for inclusion in the 2024 Pb ISA. The specific aspects of each
domain listed in Table 12-5 are consistent with current best practices for reporting or evaluating health
science data.4 Additionally, the aspects are compatible with published U.S. EPA guidelines related to
cancer, neurotoxicity, reproductive toxicity, and developmental toxicity (U.S. EPA, 2005, 1998, 1996,
1991). These aspects were not used as a checklist to determine if a study should be included or excluded;
the presence or absence of particular features in a study did not necessarily lead to the conclusion that a
study was less informative or should be excluded from consideration in the ISA. Instead, reviewers
considered each element of a study and made a final binary judgment (include or exclude) based on
overall study quality. Study quality considerations for individual studies may be discussed within the
health appendices of the 2024 Pb ISA in instances when specific aspects affect the interpretation of a
study, either increasing or decreasing confidence in study results. Importantly, judgments were made
without considering the outcome of a study (e.g., whether an adverse health outcome was observed), and
these aspects were not used as criteria for determining the causal relationship between Pb exposure and
health effects. As described in the Preamble (U.S. EPA, 2015b), causality determinations were based on
judgments of the overall strengths and limitations of the collective body of available studies and the
coherence of evidence across scientific disciplines. Table 12-5 is not intended to be a complete list of
aspects that define a study's ability to inform the relationship between Pb and health effects, but it
describes the major aspects considered in the 2024 Pb ISA to evaluate studies.

A limited number of studies have been excluded based on consideration of the study quality
aspects described in Table 12-5. For example, specific epidemiologic studies have been excluded due to
the evaluation (solely) of univariate models; lack of statistical power to detect an association; and
inadequate or missing description of methods. In addition, specific toxicological studies were excluded
from consideration because observed effects could not be reliably attributed to Pb exposure; application
of an experimental model that was not intended for use with animals; reporting data that directly conflict
with results of different experiments described in the same publication without explanation, along with

4For example, the National Toxicology Program (NTP) Office of Health Assessment and Translation (OHAT) approach
(Rooney et al., 2014), Integrated Risk Information System (IRIS) Preamble (U.S. EPA, 2013b), ToxRTool (Klimisch et al.,
1997), Strengthening the Reporting of Observational Studies in Epidemiology (STROBE) guidelines (von Elm et al., 2007),
aand Animal Research: Reporting of In Vivo Experiments (ARRIVE) guidelines (Kilkenny et al., 2010).

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mislabeled figures, which together reduce confidence in the conclusions of the study; and for conducting
experiments performed in animals that were not approved by an institutional animal care and use
committee.

To document the study quality evaluation for a subset of the most policy-relevant health studies, a
narrative approach was used to provide nuanced and transparent documentation of the strengths and
limitations that support expert judgment for individual studies. Narrative reviews were completed for
epidemiologic studies of Pb exposure and full-scale IQ in children, which played a significant role in the
development of the Policy Assessment in the 2016 Pb NAAQS review. The study quality tables (Table
12-5) were used to develop prompting questions for each study domain designed to assist in the narrative
documentation of study quality, ensuring the inclusion of consistent information across reviewers. The
narrative reviews, along with the prompting questions, were recorded in HAWC and can be accessed on
the HAWC project page.

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Table 12-5 Scientific considerations for evaluating the strength of inference
from studies on the health effects of Pb

Study Design

Epidemiology

Inference is stronger for studies that clearly describe the primary and any secondary aims of the study, or specific
hypotheses being tested. Information including the age of the population studied, study period, and study location is
used to aid in the interpretation of findings because Pb exposure has declined over time and exposures vary
depending on proximity to Pb sources.

For observational studies of Pb exposure and health outcomes, inference is considered to be stronger for
prospective cohort studies and case control studies nested within a cohort (e.g., for rare diseases) than other case
control, cross sectional, or ecologic studies. Cohort studies can better inform the temporality of exposure and effect.
Other designs can have uncertainty related to the appropriateness of the control group or validity of inference about
individuals from group level data. Study design limitations can bias health effect associations in either direction.

Animal Toxicology

The primary and any secondary objectives of the study, or specific hypotheses being tested should be clearly
described. Studies should include appropriately matched control exposures (e.g., to clean filtered air, time matched).
Studies should use experimental conditions that provoke little concern for uncontrolled variables or different practices
across groups. Groups should be subjected to identical experimental procedures, conditions, and animal care (e.g.,
housing and husbandry).

Study Population/Test Model

Epidemiology

There is greater confidence in results for study populations that are recruited from and representative of the target
population. Studies with high participation and low dropout over time that is not dependent on exposure or health
status are considered to have low potential for selection bias. Clearly specified criteria for including and excluding
subjects, and the reporting of baseline information on participants that are lost to follow up can aid assessment of
selection bias. For populations with an underlying health condition, independent, clinical assessment of the health
condition is valuable, but self-report of physician diagnosis generally is considered to be reliable for respiratory and
cardiovascular diseases.3 Comparisons of groups with and without an underlying health condition are more
informative if groups are from the same source population. Selection bias can influence results in either direction or
may not affect the validity of results but rather reduce the generalizability of findings to the target population.

Animal Toxicology

The animal species and strain used for toxicology investigations must be appropriate for the study goals and have
relevance to a corresponding outcome in humans. Ideally, studies should report species, strain, substrain, genetic
background, age, sex, and weight. Where applicable, approval of study protocols by appropriate institutional animal
care and use committees must be obtained. Unless data indicate otherwise, PECOS-relevant laboratory nonhuman
mammalian species and strains are considered appropriate for evaluating effects of Pb exposure. It is preferred that
the authors test for effects in both sexes across multiple lifestages and report the result for each group separately.

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Pollutant

Epidemiology

The focus is on studies evaluating Pb exposure.

Animal Toxicology

Studies should focus on the effects of Pb exposure on health outcomes; however, information from mixture studies in
which Pb is a component may be informative if the study employs a Pb-only treatment arm with appropriate control
group. Ideally, studies should report the source, purity, and form of Pb (e.g., lead acetate) used.

Exposure Assessment or Assignment

Epidemiology

General population studies using Pb biomarkers (e.g., blood, bone, or tooth Pb concentrations) are emphasized. The
most useful biomarker of exposure is one that reflects the exposure timing and duration that is appropriate to the
underlying pathogenetic processes (e.g., recent, cumulative over lifetime, or cumulative over a developmental^
sensitive window).

Blood Pb concentration (PbB) is typically measured in venous or capillary blood specimens using a variety of
laboratory analytical techniques. Validated analytical methods with lower LODs, such as inductively coupled plasma
mass spectrometry or graphite furnace atomic absorption spectrometry, are preferred. Capillary blood Pb
determinations have greater potential for contamination during collection, resulting in greater measurement error,
particularly at concentrations approaching the LOD. While PbB is most commonly measured in samples of whole
blood, the small fraction of Pb in plasma (<1%) is the more toxicologically active fraction of the circulating Pb.

Bone Pb is most commonly measured in the tibia, calcaneus, patella, or finger bone via X-ray fluorescence. Recent
studies favor measurement of the patella for estimating trabecular bone Pb, because it has more bone mass and
may afford better measurement precision than the calcaneus. Bone measurements are typically expressed in units of
|jg Pb per g bone mineral. This convention may potentially introduce variability into the bone Pb measurements
related to variation in bone density. Notably, lower bone mineral density is associated with greater measurement
uncertainty in bone Pb, which can have important implications for studies in populations for whom low bone mineral
density is more common (e.g., older women).

Measurements of Pb in hair, saliva, nails, urine, and feces suffer from high interlaboratory variability, low
reproducibility, and a lack of reliable reference values. A more detailed discussion of exposure biomarkers can be
found in Appendix 2.

Animal Toxicology

For this assessment, the administration of Pb by oral, inhalation, or intravenous routes are considered relevant.
Studies that resulted in measured blood Pb levels <30 |ig/dl_ will be used in the health section narratives.15 Studies
should characterize Pb concentration, environmental temperature and relative humidity, and/or have measures in
place to adequately control the exposure conditions. All studies should include exposure control groups (e.g., dosing
vehicle, or no Pb treatment) that are appropriate to the route, duration of exposure, and study design. Studies should
randomize assignment to exposure groups and, where possible, conceal allocation to research personnel. Blinding of
research personnel to study group may not be possible due to animal welfare and experimental considerations;
however, differences in the monitoring or handling of animals in all groups by research personnel should be
minimized.

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Outcome Assessment

Epidemiology

Inference is stronger when outcomes are assessed or reported without knowledge of exposure status. Knowledge of
exposure status could produce artifactual associations. Confidence is greater when outcomes assessed by interview,
self-report, clinical examination, or analysis of biological indicators are defined by consistent criteria and collected by
validated, reliable methods. Independent, clinical assessment is valuable for incidence of disease, but report of
physician diagnosis has shown good reliability. Validated questionnaires for subjective outcomes such as symptoms
are regarded to be reliable,0 particularly when collected frequently and not subject to long recall. For biological
samples, the stability of the compound of interest and the sensitivity and precision of the analytical method is
considered. If not based on knowledge of exposure status, errors in outcome assessment tend to bias results toward
the null.

Animal Toxicology

Endpoints should be assessed in the same manner for control and exposure groups (e.g., time after exposure,
evaluation methods/procedures, endpoint evaluation) using valid, reliable methods. Wherever possible, the limit of
detection for quantitative assays should be given. For each experiment and each experimental group, including
controls, precise details of all procedures carried out should be provided. Time of the endpoint evaluations is a key
consideration that will vary depending on endpoint evaluated. Endpoints should be assessed at time points that are
appropriate for the research questions. Additionally, in order to preclude reporting bias, studies should report results
for all experimental procedures conducted. All animals used in a study should be accounted for, and rationale for
exclusion of animals (e.g., attrition) or data should be specified and reasonable given the study design.

Other Potential Confounding Factorsd

Epidemiology

Factors are considered to be potential confounders if demonstrated in the scientific literature to be related to health
effects and correlated with Pb. Not accounting for confounders can produce artifactual associations; thus, studies
that statistically adjust for multiple factors or control for them in the study design are emphasized. Less weight is
placed on studies that adjust for factors that mediate the relationship between Pb and health effects, which can bias
results toward the null. Confounders vary according to study design and health effect of interest, and may include,
but are not limited to the following: socioeconomic status, parental caregiving, race (as a proxy measure for a
complex set of social factors), age, medication use, smoking status, noise, urbanicity, and environmental and/or
occupational exposures.

Animal Toxicology

Preference is given to studies using experimental and control groups that are matched for individual level
characteristics (e.g., strain, sex, body weight, litter size, and food and water consumption) and time varying factors
(e.g., seasonal and diurnal patterns).

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Statistical Methodology

Epidemiology

Multivariable regression models that include potential confounding factors are emphasized. Studies of pollutant
mixtures can be informative if health effects of exposure to Pb, presumably a component of the mixture, are also
examined separately. Such studies can provide insight into potential modification of the criteria pollutant's effect by
other individual pollutants or by a broader pollutant mixture. Models with interaction terms aid in the evaluation of
potential confounding as well as effect modification. Sensitivity analyses with alternate specifications for potential
confounding inform the stability of findings and aid in judgments of the strength of inference from results. In the case
of multiple comparisons, consistency in the pattern of association can increase confidence that associations were not
found by chance alone. Statistical methods that are appropriate for the power of the study carry greater weight. For
example, categorical analyses with small sample sizes can be prone to bias results toward or away from the null.
Statistical tests such as correlation coefficients, t tests, and chi-squared tests are not considered sensitive enough for
adequate inferences regarding Pb health effect associations. For all methods, the effect estimate and precision of the
estimate (i.e., width of 95% CI) are important considerations ratherthan statistical significance.

Animal Toxicology

Statistical methods should be clearly described and appropriate for the study design and research question (e.g.,
correction for multiple comparisons). Specific sample sizes are not criteria for inclusion or exclusion; ideally, the
sample size should provide adequate power to detect hypothesized effects. Because statistical tests have limitations,
consideration is given to both trends in data and reproducibility of results. Results should be presented quantitatively
in the appropriate format for the data (e.g., continuous data ideally should not be presented as categorical or
dichotomized) and separately by sex and cohort.

CI = confidence interval; LOD = limit of detection; Pb = lead; PbB = blood lead concentra

aMurqia et al. (2014); Weakley et al. (2013); Yang et al. (2011); Heckbert et al. (2004); Barr et al. (2002); Muhaiarine et al. (1997);
Toren et al. (1993).

bStudies not including a blood lead biomarker were tracked during study screening but were not included/evaluated in the health
section narratives.
cBurney et al. (1989).

dMany factors evaluated as potential confounders can be effect measure modifiers (e.g., season, comorbid health condition) or
mediators of health effects related to Pb (e.g., comorbid health condition).

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12.6.1.2. Welfare—Effects on Terrestrial and Aquatic Ecosystems

Generally, the field of study quality evaluation is much more robust for human health research
than for ecological research. However, study quality is still very important for ecological research, and
U.S. EPA staff have relied on the criteria listed in the Preamble as criteria for reviewing the quality of
individual studies within the 2024 Pb ISA. A limited number of studies were excluded based on
consideration of these study quality questions and application of the LECES statement. The main reasons
studies were eliminated: exposure concentrations that exceeded concentration guidelines, as specified in
the LECES (Table 12-4); no report of Pb concentration; Pb was part of a mixture of metals with no testing
of the independent effect of Pb; a lack of statistical testing for endpoints of interest; inadequate or missing
description of methods; or inadequate study design.

12.7 Peer Review and Public Participation

Peer review is an important component of any scientific assessment, as formalized in the
guidance found in the U.S. EPA's Peer Review Handbook (U.S. EPA. 2015a). The 2024 Pb ISA follows
the policies and procedures identified therein. Additionally, the 2024 Pb ISA is designated as a Highly
Influential Scientific Assessment, which is defined by the Office of Management and Budget's Final
Information Quality Bulletin for Peer Review (hereafter, "Peer Review Bulletin") as:

A subset of Influential Scientific Information that is a scientific assessment (i.e., an evaluation of a
body of scientific or technical knowledge, which typically synthesizes multiple factual inputs,
data, models, and assumptions and applies the best professional judgment to bridge uncertainties
in the available information) that "could have a potential impact of more than $500 million in any
year on either the public or private sector" or "is novel, controversial, or precedent-setting, or has
significant interagency interest."

(https://obamawhitehouse.archives.gov/omb/memoranda fV2005 m05-03A.

As such, there are additional review and transparency steps required in the release of this information
(e.g., public comment). These review and public participation steps are described in the subsequent
sections.

12.7.1. Request for Information

Consistent with the Preamble (U.S. EPA. 2015b). a Request for Information was published in the
Federal Register on July 7, 2020 (85 FR 40641). The purpose of this Request for Information was
announcing the beginning of the review cycle of the air quality criteria and the Pb NAAQS and inviting
the public to submit relevant research studies and data that had been published, accepted for publication,
or presented at a public scientific meeting since January 1, 2011. The public was given 60 days to respond

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to this FRN; the U.S. EPA received eight comments via the Federal eRulemaking Portal

(http ://www. regulations .gov. Docket ID: EPA-HQ-OAR-2020-0312). Literature submitted by the public

in response to this FRN can be viewed in the U.S. EPA's HERO database.

12.7.2. Integrated Review Plan

Following the Request for Information, the U.S. EPA prepared a multi-volume IRP: Volume 1
provides background information on the air quality criteria and standards for Pb; Volume 2 addresses the
general approach for the review and planning of the ISA; and Volume 3 is the planning document for
quantitative analyses considered in the policy assessment. Volume 2 of the IRP (U.S. EPA. 2022). which
describes the plan for developing the ISA, was discussed by CASAC at a public meeting on April 8.
2022. Availability of Volume 2 of the IRP for public comment was announced in the Federal Register on
March 10, 2022 (87 FR 13732). The public was given the opportunity to respond, and the U.S. EPA
received one public comment via the Federal eRulemaking Portal (http://www.regulations.gov. Docket
ID: EPA-HQ-OAR-2020-0312-0010).

Following the April CASAC public meeting, documentation of the meeting and written
comments from individual CASAC members were sent to the U.S. EPA Administrator in a letter dated
April 22, 2022 (https://casac.epa.gov/ords/sab/f?p=l 13:12:17516491975646::: 12).

12.7.3. Peer Input

The role of peer input is described in the Preamble, as well as the Peer Review Handbook (U.S.
EPA. 2015a. b). After a thorough literature search and screening process, the U.S. EPA developed
preliminary draft appendices for initial peer input. Causality determinations had yet to be developed. Peer
input is a process that allows the U.S. EPA to gather early-in-the-process feedback from subject-matter
experts, internal and external to the U.S. EPA, to ensure that the ISA captures relevant new literature and
is focused on the most policy-relevant findings. Peer input serves as a supplement to other peer-review
mechanisms and does not replace a thorough external peer review by CASAC.

Peer input for the 2024 Pb ISA occurred as a series of four webinar workshops, which the U.S.
EPA announced in an FRN on May 6, 2022 (87 FR 27147, Docket ID: EPA-HQ-ORD-2020-0701). The
four workshops were organized by subject: Effects of Pb in Terrestrial and Aquatic Ecosystems;
Epidemiologic and Toxicological Evidence for Health Effects of Pb Exposure; Ambient Pb: Source to
Concentration; and Exposure, Toxicokinetic, and Pb Biomarkers. Workshops were facilitated by U.S.
EPA's contractor, ICF. Peer input reviewers were selected by ICF, with input from U.S. EPA, in
accordance with U.S. EPA's Peer Review Handbook (U.S. EPA. 2015a).

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Peer input reviewers were given the following charges:

•	Correct technical errors and identify critical gaps.

•	Consider how clearly and logically the appendices and content within the sections are organized.

•	Indicate how accurately scientific information is characterized, whether advances in knowledge in
the recent literature have been adequately highlighted, and whether emphasis has been placed on
the most informative, policy-relevant literature.

•	Identify any key studies missing, (including those published after the early 2021 literature search
dates for the draft materials), especially any associated with the effects of Pb from ambient air.
Provide full citations for suggested references.

•	Indicate any specific issues that should be considered or highlighted that will be important for
integrating evidence across disciplines.

There were additional topic-specific charge questions. Peer input reviewers were not asked to correct
typos or grammatical errors.

During the workshops, peer input reviewers affirmed that the U.S. EPA included the relevant
literature, though some additional studies were identified for U.S. EPA's consideration. Following the
workshop, the U.S. EPA considered comments and incorporated revisions based on the reviewers"
feedback. Suggested studies were screened for relevance as described for the initial literature searches and
incorporated if they met the inclusion criteria (see Sections 12.4 and 12.5.1).

12.7.4. Internal Technical Review and Clearance

The U.S. EPA guidelines, such as the U.S. EPA's Peer Review Handbook (U.S. EPA. 2015a).
recommend an internal technical review process prior to any external dissemination of scientific
information. Consistent with this guidance, the draft ISA was reviewed by U.S. EPA subject-matter
experts. Following the technical review, the U.S. EPA revised the document based on the reviewers"
comments prior to submitting this document for formal U.S. EPA clearance. This final document was
cleared for public release following clearance policy and procedures.

12.7.5. Clean Air Scientific Advisory Committee Peer Review

CASAC served as the official peer review mechanism for the 2024 Pb ISA. Two sections of the
Clean Air Act, Sections 108 and 109 [42 U.S.C. 7408 and 7409], govern the periodic review and
establishment of the NAAQS (U.S. EPA. 2020a). With respect to CASAC, Section 109(d)(2) addresses
the appointment and advisory functions of an independent scientific review committee. Section

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109(d)(2)(A) requires the Administrator to appoint this committee, which is to be composed of "seven
members including at least one member of the National Academy of Sciences, one physician, and one
person representing State air pollution control agencies." Section 109(d)(2)(B) states that the independent
scientific review committee periodically "shall complete a review of the criteria... and the national
primary and secondary ambient air quality standards... and shall recommend to the Administrator any
new... standards and revisions of existing criteria and standards as may be appropriate..." Since the early
1980s, this independent review function has been performed by CASAC. More information on the
CASAC peer review can be found on the U.S. EPA CASAC website.

The draft ISA was released for public comment and CASAC review on March 31, 2023. It was
posted on U.S. EPA's website and its availability was announced in a Federal Register Notice (88 FR
19302). CASAC met on June 13-14. 2023. to review the draft ISA, and met virtually on August 23-24.
2023. to further discuss its consensus comments. The final CASAC letter was sent to the U.S. EPA
Administrator on September 18, 2023. The letter conveyed the committee's consensus advice as well as
comments from individual committee members. The Administrator responded to CASACs letter on the
draft ISA on October 30, 2023. CASAC's letter and U.S. EPA's response are viewable on CASAC's
website.

CASAC, in its letter, found the ISA "to be a comprehensive assessment of the available science
relevant to understanding the health and welfare effects of lead (Pb)" (EPA-CASAC-23-003;
https://casac.epa.g0v/0rds/sab/r/sab apex/casac/activitv?p 18 id=2637&clear=l8&session=22281838571
132#report). CASAC shared recommendations for strengthening and improving the ISA and noted that
"with these recommended changes, the [ISA] will serve as a scientifically-sound foundation for the
agency's review of the National Ambient Air Quality Standards (NAAQS) for Pb." The CASAC
recommended clarifying text to strengthen the characterization of health and exposure evidence as well as
revisions to the causality determinations for some health outcomes. In response to that advice, the U.S.
EPA revisited the evidence supporting the draft determinations for several outcomes, including adult
cognitive function, pregnancy and birth outcomes, female reproductive function, immune system effects,
and mortality. In addition, across the exposure and health appendices, the U.S. EPA clarified the lines of
evidence and rationales that support causality determinations; bolstered the ISA's characterization of the
strengths and limitations of various study designs, analytic approaches, and exposure biomarkers;
expanded discussion of the relationship of particle size to exposure pathways, absorption of Pb into the
blood, and models of Pb exposure-blood Pb relationships; and improved consistency in how the ISA
characterizes study results.

CASAC expressed general agreement with the U.S. EPA's characterization of the sources, fate
and transport, and measurement of Pb, as well as its effects on terrestrial and aquatic biota. In response to
CASAC's advice on Appendix 1 (LeadSource to Concentration), the U.S. EPA included additional
figures on emission and concentration trends; added more detail on aviation gas and fire emissions;
expanded the discussion of monitoring requirements and the Pb monitoring network; and recognized

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monitoring needs and interventions related to high daily concentrations identified by CASAC. In response
to CASAC's advice on ecological effects, the U.S. EPA provided additional clarification on a few specific
topics as indicated, edited other content for brevity, and revisited the evidence supporting the draft
causality determination for neurobehavioral effects in freshwater invertebrates.

12.8 Quality Assurance and Quality Control

QA helps ensure that the U.S. EPA conducts high-quality science that can be used to inform
policymakers, industry, and the public. Agency-wide, the U.S. EPA Quality Program provides the
framework for planning, implementing, documenting, and assessing work performed by the Agency, and
for carrying out required quality assurance and quality control (QA/QC) activities. Additionally, the
Quality Program covers the implementation of the U.S. EPA Information Quality Guidelines and the U.S.
EPA Environmental Information Quality Policy and Procedures (U.S. EPA. 2023a. b, 2002). The 2024 Pb
ISA follows all Agency guidelines to ensure a high-quality document.

For the ISA Program, management of quality assurance is documented in a Program Quality
Assurance Project Plan (PQAPP), which describes the technical approach and QA/QC procedures
associated with the ISA Program. QA objectives and measurement criteria detailed in the PQAPP have
been employed in developing the 2024 Pb ISA. QC checks were conducted on numerical entries
throughout the ISA. At a minimum, numerical values from every fifth citation were verified for accuracy
by an independent U.S. EPA staff member against the original source, and any errors were subsequently
corrected. Furthermore, the U.S. EPA's HERO database has its own QC processes, as documented in
HERO's Quality Assurance Project Plan (QAPP).

The 2024 Pb ISA is classified as QA Category A, which requires at least one audit to be
completed. During assessment development, the Pb ISA underwent two Technical System Audits in July
2022 and July 2023 by an independent contractor, Neptune and Company, Inc. The auditor identified no
major findings and verified that QC procedures were adequately performed and documented in
accordance with QA procedures.

12.9 Conclusion

This appendix describes the overall process of developing the Pb ISA: literature search and
screening methods; study quality evaluation; peer input and peer review; documentation; and QA.

Overall, the U.S. EPA has a robust set of policies and procedures in place to ensure the highest quality
products. In developing the 2024 Pb ISA, the U.S. EPA has followed all the appropriate processes and
endeavored to add additional steps as practicable and needed (e.g., use of SWIFT-AS, scoping statements,
and documentation of individual study quality).

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