The Lung Association’s misleading air quality scare for the Pittsburgh region

Summary: Once again, on April 24 the American Lung Association (ALA) launched its annual fear-mongering assault on the Pittsburgh region with dire warnings about the health risks of the region’s air pollution. As we have noted in previous Policy Briefs, the ALA is more than a little disingenuous in several respects. This Policy Brief reviews in depth major problems with the ALA’s latest report.

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The ALA report on the Pittsburgh region comes up short in several ways. First, it fails to mention that readings in all but one of the region’s air quality monitors measuring particulate matter (pm2.5) concentrations are below the Environmental Protection Agency’s (EPA) maximum annual average guidelines with many well below. Second, it fails to mention that the EPA limits on pm2.5 have declined massively over the years, dropping from an annual average of 60 micrograms per cubic meter (mcg/m3) of air in 1970 to 15 in 1997 to 12 in 2012.  Meanwhile, Pittsburgh’s air has seen equally large declines in pm2.5 concentrations.

And most telling is that the ALA violates EPA rules in calling the region’s air some of the worst in the nation based on monitor readings near known generators of particulate matter. Monitors are located specifically in such areas.

Here is the EPA guidance from their Air Quality Survey reports on monitor readings. “The values shown are the highest among the sites in each area. Data from exceptional events are included.  This summary is not adequate in itself to numerically rank CBSAs (core-based statistical area) according to their air quality.  The EPA monitoring data represent the quality of air in the vicinity of the monitoring site and, for some pollutants, may not necessarily represent urban-wide air quality (emphasis added).”

Consider that the region is being maligned primarily for measurements in Allegheny County where 14 EPA air quality monitors average 9.1 mcg/m3 in the 2018 readings. While three monitors in the county posted readings just under the 12 mcg/m3 limit, only one registered a reading over the maximum at 13.2 mcg/m3 and that occurred at one of three monitors located in Liberty Borough near the coke works.

One of the three Allegheny County monitors with a reading of just under 12 was in Lawrenceville while two others in Lawrenceville were under 9, well below the EPA guidelines for annual average concentration. Meanwhile, measurements in Allison Park (7.2) and McDonald (8.1) were well under the EPA guideline. Further north in Armstrong two monitors at the same county location averaged 7.4 mcg/m3, a far cry from the maximum guideline.

Then, too, in Westmoreland County two Greensburg monitors averaged 5.3 mcg/m3. No other air quality monitors are sited in the large county. In Washington there are seven monitors, four at the Charleroi waste treatment plant. Only one monitor at the treatment facility registered a reading close to 12 at 11.7. Three other monitors away from the plant in other parts of the county averaged 7.3 mcg/m3.  One monitor in Fayette County posted a measurement of 8.1. There are no monitors in Butler County. However, given the readings at Allison Park, and at the one location in Armstrong County, it seems very likely Butler would show quite good measurements as well.  Beaver County has four monitors all at the exact same location in Beaver Falls that averaged 10 mcg/m3 with one monitor at 11.8 and the other three below 10.

Even more disturbing is that New Castle and Weirton are included in the ALA’s 7th worst regional air quality ranking. Lawrence County has no monitors and Brooke County, home of Weirton’s two monitors, posted measurements between 8 and 9 mcg/m3.

In short, neighborhoods in Allegheny County and other surrounding counties are being tarred with the brush of measurements at a handful of monitors with readings above an annual average of 11 mcg/m3 and only one out of compliance (above 12) in Liberty Borough. This unfair maligning of areas away from the offending monitors, by lumping them in with the areas in proximity to those monitors, is detrimental because of the taint it puts on them and almost certainly hurts their ability to recruit new businesses.

What’s worse, the ALA is on notice by the EPA not to do what they are doing in maligning the whole region based on monitors located in areas likely to have heavier concentrations. This is especially unwarranted when it is very easy to look at monitors in other nearby neighborhoods to see that the EPA is well justified in the warning against assigning bad air quality to areas not being monitored or to areas that are monitored but have good readings simply because they happen to be in the same metro area or CBSA as the monitors with near maximum guideline measurements.

But it gets worse. Consider the comments reported on the accompanying April 24 release of the ALA’s diatribe against the Pittsburgh-New Castle-Weirton region.

Quoting from the Post- Gazette article of that date, the writer of the story led with, “The Pittsburgh region’s bad air history isn’t history after all, according to the American Lung Association’s 20th annual “State of the Air” report released Wednesday.”

Kevin Stewart, the ALA’s director of environmental health for advocacy and public policy said:

“Residents of Pittsburgh and the metro area should be aware that we’re breathing unhealthy air, driven by local emissions, upwind sources, and extreme heat as a result of climate change, placing our health and lives at risk.”

The article went further to include the following: “According to the Lung Association, both ozone and particle pollution are dangerous to public health and can increase the risk of premature death and serious health effects such as lung cancer, asthma, cardiovascular damage, and developmental and reproductive harm.”

The problem for the ALA is that the health experience in states with widely disparate pollution levels does not match up with its rhetoric. Nor do the health statistics and pollution levels match up in Pennsylvania.

According to statistics from the latest Centers for Disease Control (CDC) data, the U.S. death rate from lung cancer was 41 deaths per 100,000 people; for Pennsylvania, the statewide rate at 43 was very close to the national rate. Within Pennsylvania the age-adjusted (adjusted to account for age distribution in the county) deaths per 100,000 population ranged widely from 32 in Snyder County to a high of 59.5 in Forest County, followed closely by Potter County at 58. None of these counties has air quality monitors that are usually placed in areas with known or suspected pollution problems.

Allegheny County, with its all-monitor average of 9.1 mcg/m3, had a lung cancer death rate of 48 per 100,000. Across the state in Philadelphia, the eight-monitor average was 8.6 mcg/m3 and the age adjusted lung cancer death was 55.7 per 100,000.

Surprising and shocking perhaps to the ALA, California, with six of the nation’s 10-worst polluted metro areas in terms of ozone and long-term particle concentrations, had only 30 age-adjusted lung cancer deaths per 100,000 people according to CDC data, far below the national rate of 41. By county, the results are just as fascinating.

In most heavily populated California counties, the lung cancer death rates are near the state level or lower even though pollution, in all but San Diego and Santa Cruz, is far worse than in Allegheny County with its 48 deaths per 100,000 and 9.1 mcg/m3 particle concentration averaged over 14 monitors. The following list shows large population California counties with their lung cancer death rates (cdr) in deaths per 100,000 and particle concentrations (pc) in mcg/m3:

Alameda County (cdr 31 or 35 percent lower than Allegheny; pc 13 or 43 percent higher than Allegheny). Marin (cdr 24.8, pc 11.1); Santa Clara (cdr 27.3, pc 11.2); Santa Cruz (cdr 26.8, pc 7.2);  Los Angeles (cdr 28.6, pc 11.7);  San Diego (cdr 32.9, pc 9.0); San Francisco (cdr 32.1, pc 11.7); Orange (cdr 29.8, pc 10.2); San Bernardino (cdr 36.5, pc 11.2); Fresno (cdr 33.8, pc 14.5). These ten counties have a combined population total of 24,851,300 or 63 percent of the state count. Their average death rate (unweighted by county population) was 30.3, and the average long term pm2.5 concentration was 11.1 with both LA and San Francisco averaging 11.7 which is near the EPA compliance limit of 12. The average for the monitors in the Pittsburgh region was 8.1 and there are no readings for Butler County or most of the municipalities within the counties that are miles away from the monitoring sites.

Several California counties had long-term particle readings far above Allegheny County but lung cancer rates in the range of Allegheny County or much lower. For example, Tulare County had a pm2.5 concentration of 17.3, nearly double Allegheny but only 36.5 lung cancer deaths per 100,000.

Just as interesting, the Asthma and Allergy Foundation of America (AAFA) in 2018 ranked the worst cities for asthma sufferers and the worst cities for air quality in terms of ozone and particulate matter pollution. Their ranking puts seven California metros in the worst 10 metros in the nation for air quality. But ironically none of those are among the Foundation’s worst 50 areas for asthma sufferers.

And to add to the irony of California’s comparatively low lung cancer death rates and the state’s below national incidence of asthma, ALA lung disease data for 2018 show that California also has a much lower rate of Chronic Obstructive Pulmonary Disease (COPD) at 3.4 percent than did Pennsylvania (5.8 percent).

Statistics from Maine provide still more pollution and lung disease data that call into question the ALA’s hyperbolic and maligning comments about the Pittsburgh area’s air quality and health.

Seven of Maine’s counties that cover two thirds of the state’s population have air quality monitors. The highest annual average reading for pm2.5 was posted by the monitors in Oxford County at 6.3 mcg/m3; the lowest was Hancock at 3.5. For the seven counties the annual average was 5.0 mcg/m3, far below California and Pennsylvania readings. Ozone levels are also very low compared to California.

However, notwithstanding the very good air quality compared to most of the country, Maine has higher lung cancer death rates, asthma and COPD incidence than Pennsylvania and California. The state’s lung cancer death rate, according to the CDC’s latest data, is 50.3 per 100,000 population compared to the nation’s 41, Pennsylvania’s 43, and California’s 30.

The highest death rate in a Maine county with a monitor was Oxford at 61.2. Four other monitored counties with pm2.5 concentrations of 5 mcg/m3 or just above had lung cancer deaths averaging 55 per 100,000. Maine’s asthma incidence for adults, as a fraction of the state’s population, is 9.8 percent—well above California’s 6.0 percent and worse than Pennsylvania’s 8.3 percent. Asthma and COPD data are taken from ALA’s “Estimated Prevalence and Incidence of Lung Disease” 2018 report. Though these are estimates, the ALA chooses to publish them and they are consistent with other data from the AAFA and the CDC.

All the statistics presented for Maine, California and Pennsylvania point to a very important conclusion. Obviously, prevalence of lung diseases in specific geographic areas is the result of far more determinative factors than simply the air quality readings at EPA monitors. The extreme examples of California—with its overall worst metro area air quality yet better than national lung disease statistics—and Maine’s very good air quality but bad lung disease statistics suggest strongly that the ALA take a closer look at its long-running assault on Pittsburgh air and warnings about health effects. This is especially true in light of its violation of the EPA’s admonition not to apply very localized monitor readings to extensive geography within the metro area.

What is in evidence is statistical malpractice. The failure to do more investigation into the differences in lung disease prevalence that do not track as it claims with pollution levels is unprofessional.

Lung Association Needs to Take a Deep Breath of Reality

Summary: The American Lung Association has released its annual “State of the Air” report for 2018.  As expected, the organization criticizes our nation’s air quality in general and continues to smear Pittsburgh in particular.  It blames climate change as a reason for increased levels of air pollution nationwide and calls for a continued fight against climate change and greater enforcement of the Clean Air Act.  Against this backdrop, it ranks regions around the country in terms of particle pollution (soot) and rates the Pittsburgh region as eighth worst in the country.

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The U.S. Environmental Protection Agency (EPA) places air quality monitors in locations around the country and reports the monitor readings on its website.  Using the EPA data and the EPA’s “critical values” of air pollutants, the Lung Association produces and publishes its regional rankings and warnings.

The Pittsburgh region, as designated by the Lung Association, is comprised of 12 counties in three states:  Jefferson in Ohio; Brooke and Hancock in West Virginia and Allegheny, Armstrong, Beaver, Butler, Fayette, Indiana, Lawrence, Washington and Westmoreland in Southwest Pennsylvania.

Within these 12 counties there are a total of 19 monitors providing 29 readings for particle pollution (PM2.5).  This shorthand designation refers to particulate matter that is less than 2.5 micrometers in diameter and is typically the result of combustion of organic compounds. Some monitoring locations produce several readings including Steubenville, Jefferson County, and Greensburg, Westmoreland County, with three readings at each monitor. In Allegheny County the Lawrenceville and Liberty Borough monitors each provide two readings.  As do monitors in Beaver County (Beaver Falls), Washington County (Washington City and Hillman State Park) and Brooke County (Weirton). Some counties have multiple monitors reading for PM2.5 (Allegheny, Washington, Jefferson and Brooke) while some counties (Butler, Fayette, Indiana and Lawrence counties) have no monitors.

The EPA has set the critical level for PM2.5 at 12.0 micrograms per cubic meter of air (annual mean of a monitor’s readings averaged over three years) for primary standards.  This level is selected as necessary to protect the health of “sensitive” populations such as asthmatics, children and the elderly.  For secondary standards, which provides protection against decreased visibility and damage to animals, crops, vegetation and buildings, the critical level is set at 15.0 micrograms per cubic meter of air.

Keep in mind that critical levels have changed dramatically over the years since the Clean Air Act was implemented in 1971.  For PM2.5   the original level, set in 1971, was 75.0 micrograms per cubic meter of air calculated on an annual geometric mean as the primary standard—the secondary standard was set at 60.0.  The critical level was lowered to 15.0 in 1997 and calculated as an annual mean averaged over three years for both primary and secondary standards. In 2012, the primary level was set at 12.0 micrograms per cubic meter.

The point being that the standards have been tightened over the years to reflect the major improvement in air quality overall across the country and in the Pittsburgh region.  In fact, according to EPA data, the national trend in PM2.5 has decreased by 42 percent nationwide from 2000 to 2016, falling from an annual average of 13.4 to 7.8.  In the Northeast region of the country, which includes Pittsburgh, PM2.5 levels have dropped by 45 percent going from an average of 13.8 in 2000 to 7.6 in 2016.  These data belie the Lung Association’s claim of deteriorating air quality due to climate change. Just more hyperbolic fear mongering.

The latest Lung Association ranking places the Pittsburgh region as eighth worst of 187 regions for annual particle pollution.  It does, however, note that the region’s overall air quality has improved since 2000.  For example, readings from a line chart in the Association’s report puts the three-year average in 2000-02 at slightly above 21parts per cubic meter while for 2014-16 the average was under 13. Note however that the actual numerical values are not presented in the report.  The report does note that the annual particle pollution level has been reduced by 8.6 micrograms per cubic meter of air (a 40 percent decline)—a fact that somehow eluded local media coverage.

Furthermore, recent readings from the area’s monitors show an interesting result that points to deliberate misuse of the data by the Lung Association.  Of all 19 monitors and 29 three-year average readings there were only two monitors with particle counts above the critical limit of 12.0 per cubic meter of air—the Liberty Borough monitor (two readings of 12.9 and 13.1) and the Steubenville monitor (one of its three readings at 12.7).  The other 26 particle count readings in the 12-county region were below the critical level, including the other two from the Steubenville monitor (10.3 and 9.8).  In fact, the average of all 29 readings (the three-year annual average for each monitor) for the three-state, 12-county area is just 9.9, well below the critical level of 12.0 and contradicts the Lung Association’s chart showing an area-wide level of over 12.0.  This amounts to deliberately and falsely labeling the region as out of compliance. Indeed, how can Butler and Indiana be lumped in when no monitor readings are available in these counties?  There is no excuse for this level of statistical and reportorial malpractice.

Earlier Policy Briefs noted, and it is worth repeating, the Liberty monitor is in close proximity to U.S. Steel’s Clairton Coke Works.  Another point that is being overlooked is how much better the readings from this monitor are compared to 10 years ago.  Looking at the three-year annual average, the two readings from 2004-06 this monitor came in at 20.2 and 21.1.  Thus, in 10 years the readings show the levels of PM2.5 were reduced by 35 percent and 38 percent, respectively.

Amazingly, the Lung Association’s report assigns Allegheny County a failing grade on its particulate matter levels due to the readings at the Liberty monitor. The other seven monitors and their eight readings in the County were well in compliance, averaging 9.6 particles per cubic meter.  Allegheny County was the only one of the 12 to receive to receive a “fail” for its level of particle pollution.

Regarding the other monitor showing levels above the acceptable amount, the Steubenville monitor, located on the Ohio River and not too far from industrial sites, had a three-year average reading of 15.1 a decade ago (only one reading was taken at that time).  PM2.5 levels have been reduced by 16 percent at this monitor and it bears repeating that only one of three readings from this monitor were above the acceptable level of 12.0 (12.7).

The Lung Association’s latest report, and the headlines that immediately followed, give the impression that air quality in the Pittsburgh area has gotten worse over the last few years.  But, in fact, the opposite has been true.  Only one of the 12 counties in the region received a failing grade—Allegheny County.  And, as was noted above, that was based on the readings from just one of the eight monitors stationed around the county.  The other seven are consistently reporting air that is well below the critical level.  Even at the offending monitor the levels are just above the critical level—a critical level that has been lowered dramatically over the years including down from 15 parts per cubic meter five years ago.  The Lung Association’ smear campaign is unjustified and does not reflect the progress the area has made in improving its air quality.

How much money will the folks charged with trying to attract businesses have to spend to offset the annual barrage of misleading news about the area’s air quality?  What will Amazon think? Presumably they and other companies are smart enough to have studied the Lung Association’s air quality analysis and commentary and found them to be seriously flawed and misleading.

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.