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  • ACOEM Urges EPA to Lower Ozone Standard

    December 13, 2010

    The Honorable Lisa Jackson
    Administrator
    U.S. Environmental Protection Agency
    1200 Pennsylvania Avenue, N.W.
    Washington, DC 20460

    Dear Administrator Jackson:

    I am writing on behalf of the American College of Occupational and Environmental Medicine (ACOEM). In January 2010, your Agency announced a proposed rule strengthening the national ambient air quality standard (NAAQS) for ground level ozone. The rule proposed a reduction in the NAAQS from an 8-hour “primary” standard of 0.075 parts per million (set in 2008) to a level within the range of 0.060 to 0.070 ppm. As we have stated previously, we strongly encourage 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 0.075 ppm 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 5,000 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,

    Natalie P. Hartenbaum, MD, MPH, FACOEM
    President