Understanding the Ozone Standard and Principles of Public Health

Source: flickr/tofuttibreak

Source: flickr/tofuttibreak

Last week, the U.S. Environmental Protection Agency (EPA) unveiled a proposal to update our national air quality standards for ground-level ozone, more commonly known as smog, from the current 75 parts per billion level to 65 to 70 parts per billion. Smog is a dangerous air pollutant linked to asthma attacks and other serious heart and lung diseases. That’s why EPA is also seeking comments on establishing a health standard of 60 parts per billion, a level that would provide the strongest public health protections for Americans according to scientific record. But despite the overwhelming scientific evidence of the health benefits of a more protective ozone standard, the Texas Commission on Environmental Quality (TCEQ), publicly opposes it.

Sixty to 70 parts per billion is the health-based range recommended by the Clean Air Scientific Advisory Committee, an independent panel of the nation’s leading scientists. The panel of scientists formed its recommendation based on an examination of bedrock scientific evidence and the requirement under the law to protect those most vulnerable.

In deconstructing TCEQ’s position on ozone, one can focus on a few key elements that stray from the mainstay of accepted public health principles:

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  1. Failure to protect sensitive individuals

One of the most sensitive health outcomes from ozone exposure is a decrease in lung function. And despite numerous human studies, supported by epidemiological data and animal models, examining the adverse health effects of ozone exposure and decreased lung function, TCEQ toxicologists believe a more protective health standard isn’t warranted. The agency goes so far as to suggest that variability in the lung function of healthy individuals is ample reason to deny health protections to sensitive individuals.

Source: Bruce Lanphear

Source: Bruce Lanphear

One example of why it is necessary for public health policies to protect the end “tails” of a distribution in a population was outlined recently by Bruce Lanphear. Dr. Lanphear explained the importance of protecting the “tails” of the population using the example of lead exposure and IQ.

It is a known fact that exposure to lead can result in a reduction of IQ, correlated with increases in violent and delinquent behavior. This fundamental research led to the removal of lead from gasoline and paint. The concept is that while a 5-point loss in IQ might not affect an individual’s ability to live a productive life, a 5-point shift in the population-level means IQ would have profound implications for society, including a dramatic increase (from 6 million to 9.5 million in the figure above) in those who would be rendered unable to care for themselves, as well as a reduced number of “gifted” individuals (from 6 million down to 2.4 million). Just as the social burdens of a shift in average IQ are dramatic, the same principle applies to the health outcomes in a society exposed to ozone.

  1. Issue of exposure

TCEQ argues that because people spend time inside that they rarely, if ever, have the opportunity to breathe concentrations of ozone that would cause harm. TCEQ’s solution to avoiding adverse health outcomes from ozone is to simply stay inside – hardly an adequate position to take on a ubiquitous public health threat. While the issue of personal exposure is interesting, it does not alleviate the public health threat that exists from outdoor ozone, especially for those who work outside and who spent a lot of time outdoors, like children.

  1. Cost estimates cited by TCEQ are unfounded and unjustified

By law, the issue of cost is not allowed to be factored into setting a health-based standard. Even if costs were allowed to be considered, the conclusion remains that clean air is good for the economy. In an analysis by the TCEQ, the agency has demonstrated that Houston’s GDP has actually increased while ozone concentrations have gone down. Further, the EPA’s cost-benefit analysis, covering a 30-year time span, shows that the Clean Air Act has returned benefits 30 times greater than the cost of implementation.

  1. Communicating risk to the public

The issue of the health implications of ozone comes down to the fact that people have a right to know about the quality of air they are breathing. If we have decades’ worth of research, including controlled human exposures demonstrating adverse health effects below the current standard in healthy individuals, the public needs to know it. Families need to be armed with the best information possible so they can take the appropriate steps to protect loved ones from environmental hazards like ozone. The citizens of Texas deserve a state environmental agency that will do its job in conveying the health risks associated with ozone and other harmful pollutants.

Public health protection is an immense responsibility, one that should not be taken lightly. Our nation has the ingenuity and the determination to follow the medical science in order to protect our children and communities from dangerous smog pollution. We call upon the Texas Commission on Environmental Quality to reassess its priorities and commit to protecting Texans’ health, instead of serving as an obstruction to it.

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