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  • ACOEM Comments on EPA Ozone Air Quality Standards

    March 17, 2015

    The Honorable Gina McCarthy
    Administrator
    U.S. Environmental Protection Agency
    1200 Pennsylvania Avenue
    Washington, DC 20460

    Re: EPA Docket No: EPA-HQ-OAR-2008-0699

    Dear Administrator McCarthy:

    I am writing on behalf of the American College of Occupational and Environmental Medicine (ACOEM) to provide comments to the U.S. Environmental Protection Agency on the proposed Ozone National Ambient Air Quality Standards.

    Based on an extensive body of scientific evidence, EPA is proposing to update both the primary ozone standard, to protect public health, and the secondary standard, to protect the public welfare. Both standards would be 8-hour standards set within a range of 65 to 70 parts per billion (ppb). EPA is seeking comment on levels for the health standard as low as 60 ppb.

    We support the lowering of the ozone standard in order to protect the health of the American public including sensitive populations of children, the elderly, and those with respiratory and other conditions that make them more vulnerable to the effects of ozone.

    There is sufficient scientific evidence that lowering the ambient concentration of ozone below 70 parts per billions will provide additional protection through reduced morbidity and mortality in the form of respiratory symptoms, emergency room visits, and hospitalizations. Although we understand the economic concerns concomitant with lowering the ozone standard, we do not wish to place at risk the health and lives of all citizens who remain exposed to this toxic air pollutant. We believe that an economic analysis of the long-term health benefits of lowering the ozone standard fully justifies such action on the part of your Agency and we urge that you do so.

    ACOEM represents more than 4,500 physicians and other health care professionals specializing in the field of occupational and environmental medicine. Founded in 1916, ACOEM is the nation's largest medical society dedicated to promoting the health of workers through preventive medicine, clinical care, disability management, research, and education.

    Thank you for your consideration of these comments.

    Sincerely,

    Kathryn Mueller, MD, MPH, FACOEM
    President