What's At Stake?

EPA Set to Abandon 30 Years of Air Quality Control

The Clean Air Act requires the EPA to regulate all air pollutants that pose a threat to public health and welfare by establishing the National Ambient Air Quality Standards (NAAQS). The EPA is required to apply the best available science to update the standards every five years. [1]

Six highly dangerous air pollutants are monitored under these standards: ozone, nitrogen dioxide, sulfur dioxide, carbon monoxide, particulate matter, and lead. Federal regulation over the last three decades has reduced the quantity of lead in people's blood by over 78 percent; this stands as one of the crowning achievements of the Clean Air Act. [2]

Ingestion or inhalation of even low levels of lead poses severe risks to humans. Lead poisoning damages the major organs and causes osteoporosis, high blood pressure, heart disease, anemia, memory problems, and seizures. Children are at the greatest risk, as low levels of lead can cause lowered IQ levels and learning deficits. [3]

Successful Attempts to Reduce Lead Exposure
The Centers for Disease Control (CDC) has revised its standards repeatedly and now defines the lead poisoning threshold at 10 µg /dL (micrograms of lead per deciliter of blood), although it recognizes that there is no evidence for a level of lead exposure that could be considered safe. [4]

The EPA's efforts to reduce lead air pollution have been one of the greatest successes of the Clean Air Act. In 1978, the EPA mandated a quarterly average for the maximum lead concentration of 1.5 µg/m3 (micrograms of lead per cubic meter of air), corresponding with the then current CDC value of 30 µg /dL. Environmental solutions aimed at achieving this limit, such as the elimination of lead from automobile gasoline, resulted in the overall levels of lead pollution decreasing by 94 percent between 1980 and 1999. [5]

Current Challenges to Health
Industrial sources such as boilers and process heaters, iron and steel foundries, and lead smelters are now the primary sources of lead pollution, and have only reduced their emissions by six percent since 1988. The worst remaining mobile source is leaded aviation fuel. [6]

While overall lead concentrations have decreased dramatically since the 1970s, communities in the vicinity of industrial sources of lead still suffer dangerously high levels of lead air pollution, and the outdated EPA monitoring system has not adapted to address this new threat. In 1990, based on the best available science, EPA scientists made several recommendations to address pollution control in these "hot spots":

Strengthen the standard for the maximum lead concentration in air in order to reduce childhood lead poisoning in affected areas.
Set standards based on monthly averages, instead of three month averages, to better monitor dangerous short term increases.
Measure lead levels near pollution sources every day instead of every six days.

Unfortunately, the EPA declined to heed these recommendations. In fact, no significant changes have been made since the EPA began regulating lead in 1978. This stands in stark contrast to the CDC's continued application of new and developing science to reevaluate and update its lead poisoning thresholds.

Rolling Back Protections
The EPA has already failed to apply the best available science to protect public health. What’s more, the agency has proposed eliminating control of lead pollution under the Clean Air Act entirely.

A December 2006 EPA Staff Paper draft states that the EPA acknowledges that a wide array of harmful health consequences can result from blood lead levels of 5 µg /dL and possibly lower. [7] Incredibly, despite recognizing that there is no known safe level of exposure, this draft report suggests that a final EPA review will "evaluate removing lead from the criteria pollutant list and assess whether the revocation of the lead NAAQS is an appropriate option." [8]

A decision to completely remove lead regulation would set lead air quality control back 30 years. Science does not support the revocation of the lead NAAQS; industry does. Lobbying groups representing battery makers, smelters, and refiners have all pressured the administration to remove lead regulation from the Clean Air Act. [9]

Shutting Science Out of Decision-Making
In 2005, EPA Deputy Administrator Marcus Peacock announced a new streamlined policy for setting the NAAQS which removes the independent assessment by scientific experts and injects political determinations much earlier in the decision-making process. [10] This policy is being applied for the first time in the lead NAAQS review. [11]

Under the new rules, high-level political appointees are involved right from the start, working with staff scientists to create a document containing "policy-relevant science" that "reflects the agency's views" instead of the independent scientific paper that staff scientists have put together in the past. Under previous rules, staff scientists worked with the Clean Air Science Advisory Committee to create a scientific assessment of risks and recommend appropriate standards. Only after the scientific review was complete would the administrator create the final policy.

Take Action
The EPA should fulfill its mandate of protecting the air we breathe under the Clean Air Act. They have recognized that the best available science shows that low levels of lead can have severe health effects, yet they have not updated the lead air pollution threshold since 1978, and are even considering rescinding lead pollution control altogether. Tell the EPA that it must continue to use the best available science in protecting the air we breathe from dangerous lead pollution.

[1] Clean Air Act, with 1990 amendments: Section 108 (42 U.S.C. 7408) and Section 109 (42 U.S.C. 7409)
[2] Environmental Protection Agency, "EPA's Efforts to Reduce Lead," online fact sheet, accessed 19 January 2007
[3] Environmental Protection Agency, "Addressing Lead at Superfund Sites: Human Health," online fact sheet, accessed 19 January 2007
[4] Centers for Disease Control and Prevention, "Why Not Change the Blood Lead Level of Concern at this Time?" online fact sheet, accessed 19 January 2007
[5] "EPA's Efforts to Reduce Lead"
[6] ibid.
[7] Environmental Protection Agency’s National Center for Environmental Assessment, “Air Quality Criteria Document for Lead (Final),” Section 8.4, October 2006, Accessed 19 January 2007 and Environmental Protection Agency, “Review of the National Ambient Air Quality Standards for Lead: Policy Assessment of Scientific and Technical Information” OAQPS Staff Paper – First Draft, December 2006, Accessed 19 January 2007, page 85.
[8] Environmental Protection Agency, “Review of the National Ambient Air Quality Standards for Lead: Policy Assessment of Scientific and Technical Information” OAQPS Staff Paper – First Draft, December 2006, Accessed 19 January 2007, page 247.
[9] Union of Concerned Scientists, "Should Air Pollution Rules be Based on Politics?"
[10] Memo from EPA Deputy Administrator Marcus Peacock, "Process for Reviewing National Ambient Air Quality Standards," December 7, 2006, accessed December 19, 2006.
[11] Battery Council International, "Review of the Process for Setting National Ambient Air Quality Standards," 12 July 2006, accessed 23 January 2007 and Heilprin, John, "EPA May Drop Lead Air Pollution Limits," Associated Press, 6 December 2006.

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	What's At Stake? EPA Set to Abandon 30 Years of Air Quality Control The Clean Air Act requires the EPA to regulate all air pollutants that pose a threat to public health and welfare by establishing the National Ambient Air Quality Standards (NAAQS). The EPA is required to apply the best available science to update the standards every five years. [1] Six highly dangerous air pollutants are monitored under these standards: ozone, nitrogen dioxide, sulfur dioxide, carbon monoxide, particulate matter, and lead. Federal regulation over the last three decades has reduced the quantity of lead in people's blood by over 78 percent; this stands as one of the crowning achievements of the Clean Air Act. [2] Ingestion or inhalation of even low levels of lead poses severe risks to humans. Lead poisoning damages the major organs and causes osteoporosis, high blood pressure, heart disease, anemia, memory problems, and seizures. Children are at the greatest risk, as low levels of lead can cause lowered IQ levels and learning deficits. [3] Successful Attempts to Reduce Lead Exposure The Centers for Disease Control (CDC) has revised its standards repeatedly and now defines the lead poisoning threshold at 10 µg /dL (micrograms of lead per deciliter of blood), although it recognizes that there is no evidence for a level of lead exposure that could be considered safe. [4] The EPA's efforts to reduce lead air pollution have been one of the greatest successes of the Clean Air Act. In 1978, the EPA mandated a quarterly average for the maximum lead concentration of 1.5 µg/m3 (micrograms of lead per cubic meter of air), corresponding with the then current CDC value of 30 µg /dL. Environmental solutions aimed at achieving this limit, such as the elimination of lead from automobile gasoline, resulted in the overall levels of lead pollution decreasing by 94 percent between 1980 and 1999. [5] Current Challenges to Health Industrial sources such as boilers and process heaters, iron and steel foundries, and lead smelters are now the primary sources of lead pollution, and have only reduced their emissions by six percent since 1988. The worst remaining mobile source is leaded aviation fuel. [6] While overall lead concentrations have decreased dramatically since the 1970s, communities in the vicinity of industrial sources of lead still suffer dangerously high levels of lead air pollution, and the outdated EPA monitoring system has not adapted to address this new threat. In 1990, based on the best available science, EPA scientists made several recommendations to address pollution control in these "hot spots": Strengthen the standard for the maximum lead concentration in air in order to reduce childhood lead poisoning in affected areas. Set standards based on monthly averages, instead of three month averages, to better monitor dangerous short term increases. Measure lead levels near pollution sources every day instead of every six days. Unfortunately, the EPA declined to heed these recommendations. In fact, no significant changes have been made since the EPA began regulating lead in 1978. This stands in stark contrast to the CDC's continued application of new and developing science to reevaluate and update its lead poisoning thresholds. Rolling Back Protections The EPA has already failed to apply the best available science to protect public health. What’s more, the agency has proposed eliminating control of lead pollution under the Clean Air Act entirely. A December 2006 EPA Staff Paper draft states that the EPA acknowledges that a wide array of harmful health consequences can result from blood lead levels of 5 µg /dL and possibly lower. [7] Incredibly, despite recognizing that there is no known safe level of exposure, this draft report suggests that a final EPA review will "evaluate removing lead from the criteria pollutant list and assess whether the revocation of the lead NAAQS is an appropriate option." [8] A decision to completely remove lead regulation would set lead air quality control back 30 years. Science does not support the revocation of the lead NAAQS; industry does. Lobbying groups representing battery makers, smelters, and refiners have all pressured the administration to remove lead regulation from the Clean Air Act. [9] Shutting Science Out of Decision-Making In 2005, EPA Deputy Administrator Marcus Peacock announced a new streamlined policy for setting the NAAQS which removes the independent assessment by scientific experts and injects political determinations much earlier in the decision-making process. [10] This policy is being applied for the first time in the lead NAAQS review. [11] Under the new rules, high-level political appointees are involved right from the start, working with staff scientists to create a document containing "policy-relevant science" that "reflects the agency's views" instead of the independent scientific paper that staff scientists have put together in the past. Under previous rules, staff scientists worked with the Clean Air Science Advisory Committee to create a scientific assessment of risks and recommend appropriate standards. Only after the scientific review was complete would the administrator create the final policy. Take Action The EPA should fulfill its mandate of protecting the air we breathe under the Clean Air Act. They have recognized that the best available science shows that low levels of lead can have severe health effects, yet they have not updated the lead air pollution threshold since 1978, and are even considering rescinding lead pollution control altogether. Tell the EPA that it must continue to use the best available science in protecting the air we breathe from dangerous lead pollution. [1] Clean Air Act, with 1990 amendments: Section 108 (42 U.S.C. 7408) and Section 109 (42 U.S.C. 7409) [2] Environmental Protection Agency, "EPA's Efforts to Reduce Lead," online fact sheet, accessed 19 January 2007 [3] Environmental Protection Agency, "Addressing Lead at Superfund Sites: Human Health," online fact sheet, accessed 19 January 2007 [4] Centers for Disease Control and Prevention, "Why Not Change the Blood Lead Level of Concern at this Time?" online fact sheet, accessed 19 January 2007 [5] "EPA's Efforts to Reduce Lead" [6] ibid. [7] Environmental Protection Agency’s National Center for Environmental Assessment, “Air Quality Criteria Document for Lead (Final),” Section 8.4, October 2006, Accessed 19 January 2007 and Environmental Protection Agency, “Review of the National Ambient Air Quality Standards for Lead: Policy Assessment of Scientific and Technical Information” OAQPS Staff Paper – First Draft, December 2006, Accessed 19 January 2007, page 85. [8] Environmental Protection Agency, “Review of the National Ambient Air Quality Standards for Lead: Policy Assessment of Scientific and Technical Information” OAQPS Staff Paper – First Draft, December 2006, Accessed 19 January 2007, page 247. [9] Union of Concerned Scientists, "Should Air Pollution Rules be Based on Politics?" [10] Memo from EPA Deputy Administrator Marcus Peacock, "Process for Reviewing National Ambient Air Quality Standards," December 7, 2006, accessed December 19, 2006. [11] Battery Council International, "Review of the Process for Setting National Ambient Air Quality Standards," 12 July 2006, accessed 23 January 2007 and Heilprin, John, "EPA May Drop Lead Air Pollution Limits," Associated Press, 6 December 2006. Go Back