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The U.S. EPA's Clean Air Scientific Advisory Committee's subcommittee on Particulate Matter (CASAC-PM) advises the EPA Administrator on setting National Ambient Air Quality Standards. Although the Committee and staff are qualified and dedicated, the process could be improved in the interest of the public good.
The current EPA focus is too narrow. Isolating individual pollutants, not considering PM composition, ignoring health tradeoffs, and imposing national standards, are problematic. This focus may lead to overregulation of some technologies, industries, and regions.
The Risk Assessment process should be changed from a focus on individual PM mass fractions to a focus on the health-related consequences of PM standards. The public must live with all of the consequences of new standards, including unintended adverse consequences.
The process is linear without opportunities to discuss compliance feasibility, economic hardships, or unintended health effects that vary regionally. Such limited advice can mislead the EPA Administrator and the public with respect to the adequacy of the scientific advice provided by CASAC.
Although the CASAC-PM scientific advisory process is efficient and consistent with EPA's mandate, it is flawed.
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