AG 2007 10 15 - Laserfiche WebLink

Home Browse Search

Dr. Morton Lippmann Final Review Comments - M. Lippmann Ozone Staff Paper -Jan. 2007 Draft General Comments: 1) This Jan. 2007 "final" draft reflects the prior recommendations of CASAC, and is substantially improved. 2) Even though the Jan. 2007 Staff Paper is considered to be fmal, there are some technical defects in Chapters 2 and 3 that I think may warrant notation in an Errata. I also have some serious concerns about what is riot in Chapter 6 that I feel should have been, and I recommend that they be addressed when the Notice of Intent to establish the next Ozone NAAQS is prepared. These are addressed below as some Specific Comments. Specific Comments on Chapters 2 & 3.: 1) p. 2-6, Table 2-2: The entries for 2002, 2003, & 2004 are identical. This cannot be correct. 2) p. 3-3, Para. 3, line 6: change "a role for one or a group" to "a specific role for any one, or any group". 3) p. 3-22, Para. 1, line 1: insert "cross-sectional" before "study." 4) p. 3-22, Para. 1, lines 8-10: change to "116). In a longitudinal analysis of lung function development of 4th, 7th, and 10th grade students over four yeazs, Gauderman et al., (2000) found no association with 03 exposure. Further longitudinal analyses by the same group". 5) [I cannot understand why previous requests to get this citation right have been ignored]. 6) p. 3-37, Para. 2, lines 7-9: The labeling of the body of evidence on ozone-related mortality as being only "highly suggestive", and needing additional research on underlying mechanisms to become more fully established before it can be used in standard setting, sets the bar faz higher than those used previously for ozone effects and, for that matter, for most, if not all, of the effects associated with other NAAQS pollutants. The only justification that I can see for this reluctance to use the evidence provided in this Staff Paper is that there are so many other effects to rely on that it is not needed in reaching the Staff recommendations in Chapter 6. The problem, at least for me, is that not considering the substantial evidence for short-term mortality attributable to ozone in ambient air sets a bad precedent for future NAAQS reviews. Comments on Chapter 6: 1) What is included in this chapter, while prolix and repetitious, provides largely reasonable summations, conclusions and recommendations. However, in my view, Chapter 6 greatly understates the public health impacts of exposures that can be expected to occur at any of the exposure scenarios under the three levels options that were considered for this C-19