The latest chapter in EPA vs environmental science saga

The latest saga of EPA’s divorce proceedings against environmental science is unfolding this week at the hearings of the Clean Air Scientific Advisory Committee (CASAC) on particulate air pollution.

CASAC is mandated under the Clean Air Act to be an integral part of the required five year review of each National Ambient Air Quality Standard (NAAQS). Under the Clean Air Act, the EPA administrator sets standards “requisite to protect public health.” Further it is required that the standards “accurately reflect the latest scientific knowledge.”

By law, CASAC has seven members appointed by the EPA administrator. But with just seven members it clearly does not have the breadth and depth of expertise to fully and accurately distill the growing body of knowledge about increasingly complex and changing processes that lead to the effects of air pollutants. Accordingly, CASAC has long relied on scrutinizing the key issues based upon input from subcommittees of knowledgeable experts.

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But EPA has suddenly terminated the subcommittees assembled to provide input to CASAC on both particulate and ozone pollution. As a former chair of CASAC, and former EPA assistant administrator for research and development appointed by President Reagan, I have watched this and other EPA processes to build policy on sound science be admired and emulated worldwide. That is, until the current administration.  

These CASAC subcommittees especially are needed for help in setting the ozone and particulate standards. These standards are the only outdoor standards, which we now exceed in significant parts of our country. The science underlying ozone and particulate formation is far more complicated than that for other NAAQS pollutants such as carbon monoxide or lead.

Rather than being directly released from readily identifiable sources, all of the ozone and much of the particulates we breath form in the atmosphere through processes that depend heavily on complex chemical and physical interactions. For both ozone and particulates there are multiple precursor sources, including in both cases fossil fuel emissions from power sources and transportation.

The pollutants can also interact with each other. For example, photochemical oxidation leading to ozone may also increase the toxicity of hydrocarbon particulates. Disentangling this multiplicity of pollutants and interactions in relation to the health effects literature requires a breadth and depth of expertise that is not achievable with only a seven member panel who are also responsible for providing advice on multiple other pollutants and on the diverse welfare endpoints involved in secondary standard determinations.

I strongly doubt that we could get the needed advice from the seven-member CASAC committee for simpler pollutants, such as carbon monoxide and lead for which the sources and endpoints are relatively clear-cut and for which little new science needs to be considered. Further, unlike ozone and particulates, there are simple blood tests to define the extent of human exposure. It is manifestly impossible to ask CASAC to meet its congressionally mandated Clean Air Act requirements without scientific input from experts in the many fields pertinent to understanding the impacts of ozone and particulates.

Understanding what EPA leadership is doing with CASAC needs to be put in the context of their overall goal of divorcing scientific processes from policy judgments. This goes well beyond their head in the sand attitude to global climate change and other significant environmental threats. One approach has been to change any advisory committee membership so as to downplay expertise.

The new selection criteria focuses on the usual politically motivated distributional issues. It also disqualifies any academic receiving funding from EPA, but not personnel from state or local agencies. The success in divorcing consideration of scientific expertise affects all agency advisory processes but is nowhere more evident then in the new CASAC committee appointed in October. This committee now contains four state or local agency personnel — perhaps by coincidence all from states with Republican governors to whom they ultimately report. Of the remaining three members, one is a consultant, one is from the U.S. military and one is an academic scientist. Individually, they appear to have expert but often overlapping qualifications. But none of them has particular expertise in epidemiology, a core discipline in providing evidence linking exposure levels to adverse health endpoints

When the CASAC membership was adjusted to avoid independent academic experts, it was hoped that the scientific integrity of the process would be maintained through the public input of the expert subcommittees. Cunningly, EPA’s Acting Administrator Andrew Wheeler’s action has removed that 40-year-old prop from the science advice edifice. Also with the goal of divorcing science from policy, but not yet successful, EPA leadership is currently using transparency as a sham pretext to discard much of the scientific literature supporting the protection of public health from environmental pollutants

Stay tuned for the next episode of EPA vs. science.

Bernard D. Goldstein, M.D., is a professor emeritus and dean emeritus at the University of Pittsburgh Graduate School of Public Health. He was chair of the EPA Clean Air Scientific Advisory Committee and the Environmental Protection Agency assistant administrator for research and development under President Reagan.