EPA’s Questionable Behavior

EPA’s Questionable Behavior

In two Policy Briefs earlier this year and in several Briefs in the past few years, we have questioned the EPA and the American Lung Association for their methodology in claiming that the Pittsburgh region has some of the worst air quality in the country. But beyond their silly argument that above EPA guideline readings at one pollution monitor in the area is sufficient to label the entire region as out of compliance, there are concerns about the claims over the relationship of air quality to health and mortality rates.

As we noted in May, the air quality in Los Angeles has for many years been ranked as among the worst if not the worst in the country while the air quality in Laramie, Wyoming is ranked as being some of the least polluted in the nation. If air quality is the exceptionally important determinant of health and mortality the Lung Association and the EPA constantly insist it is, then age specific death rates in Los Angeles ought to be worse than the national rates and much higher than the Laramie rates. But for virtually every age group, especially the older ages which should be showing the effects of years of prolonged exposure to high pollution, Los Angeles mortality rates are much lower than the national rates and measurably lower than Laramie rates.

The Lung Association has proffered no answer to this obvious challenge to their claims but does not even indicate it is interested in producing an explanation. Ditto the EPA.

And it gets worse. The EPA has a guideline for mortality from pollution known as the Maximum Individual Carcinogenic Risk, defined as the estimated risk of contracting cancer for person exposed to a pollutant 24 hours per day, 7 days a week, and 52 weeks a year for 70 years. Clearly, as we noted in August Brief, there hasn’t been and never will be a study to evaluate such conditions. It is simply not feasible. So, the estimate has to be produced by epidemiological statistical studies that inevitably require a lot of assumptions and interpolations that cannot get at possible causalities and mechanisms of the harmful effects of pollutants.

Obviously, it would be a violation of all known protocol prohibitions to subject human beings to high level of air pollutants in a controlled environment where they might suffer harm-especially in light of the EPA claims that the pollutants are known to cause harm and death.

But that has not prevented the EPA from doing just that. Tests have been happening since 2004. These experiments are now the subject of a lawsuit by an asthmatic individual who was negatively affected by the experiment. A study documenting the violations of human experimentation prohibitions and the less than straightforward recruitment of volunteers is available on the web. http://epahumantesting.com/summary.

The logical inconsistency of the EPA’s testing is stunning. They claim the tested pollutants are extremely hazardous and yet they are in need of proof so badly they are willing to subject elderly and unhealthy subjects to tests involving as much as twenty times normal concentrations of pollutants. Their argument is that it is for the greater good to learn the mechanisms of possible deleterious health effects. But what is more stunning is that testing in 2010 and 2011 involving 41 subjects only two showed negative effects, one serious. A person with known pre-existing heart problems had to be hospitalized. No mention in the report that the bulk of the test subjects showed no clinical effects. What hypocrisy.