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DECISION OF THE ADMINISTRATOR OF THE ENVIRONMENTAL PROTECTION AGENCY REGARDING SUSPENSION OF THE 1975 AUTO EMISSION STANDARDS
WEDNESDAY, APRIL 18, 1973
Washington, D.C. The subcommittee met at 10 a.m., pursuant to recess, in room 4200, Dirksen Office Building, Hon. Edmund S. Muskie (chairman of the subcommittee) presiding. Present: Senators Muskie, Randolph, Biden, Buckley, and Domenici. Senator MUSKIE. The committee will be in order. I understand that Mr. Ruckelshaus will be delayed 45 minutes this morning and that he will be with us a little later. In the meantime, we will take the opportunity to get into some of these emission-health questions in which we are interested.
We have with us this morning again Dr. Greenfield, Assistant Administrator for Research, and his associates.
Would you present them for the record, Dr. Greenfield, and then
Dr. GREENFIELD). We might have a small statement to make just to clarify the paper to your staff. It describes the pyramidial approach in determining the adverse health effects. We might go through that,
Senator MUSKIE. Why don't you proceed and introduce your colleagues.
Dr. GREENFIELD. On my right once again is Dr. Finklea, who is Director of the National Environmental Research Center at Research Triangle Park, N.C. On his right is Dr. Davis Shearer, head of our Surveillance Division.
On my left is George Allen, from the Office of Enforcement and General Counsel. On his left is Mr. Eric Stork, from the Office of Air and Water Programs.
I will turn it over to Dr. Finklea at this point to go through a threepage document.
Dr. FINKLEA. Mr. Chairman, we have a three-page handout.
Beginning with the first one, we would like to consider what sort of 1 adverse effects might be considered upon public health. We have a pyramid. The width of the pyramid represents the proportion of the population affected. The pyramid extends from death or mortality at the top, which affects a rather small portion of the population, down to a pollutant burdens. The legislation does stress our need to protect the public health and we run into a great deal of controversy as to what constitutes an adverse effect on public health.
There is usually no disagreement that increased mortality, either the rate of daily mortality from usual causes, or an increase in deaths from a cause directly attributable to any pollutants, constitutes an adverse effect. Similarly, there is usually little doubt that an increase in the severity or frequency of a usual disease or of a disease that in itself can be attributed to a pollutant is an adverse effect.
Where we get into difficulty and get into discussion is whether or not a change in physiology or a change that you can examine under the microscope or biochemically in animal systems or in the humans, constitutes an adverse effect.
Within the agency, the scientists concerned with these matters feel that those changes in the way the body functions, which indicate an increased risk for disease or death, so-called pathophysiologic changes. are in themselves an adverse health effect. There are undoubtedly other changes which are of uncertain significance. These indicate that a polIntant has made the body function in a different way. But whether or not this different functioning is an adverse effect on health is often a rery difficult problem to decide.
I think many of the controversies surrounding our present efforts to improve environmental quality are based upon the need to protect public health and involve this problem of defining an adverse health effect.
To illustrate this, perhaps we could move on to the second figure.
Senator MUSKIE. On the first chart, to try to put it in layman's terms, es hat you have said is any change in body functions which raises the risk of poor health effects is an adverse effect in terms of the policy that is now written into the law?
Dr. FINKLEA. No, sir. I said the law as written now defines a need to protect public health without a precise definition of what constitutes an adverse effect.
Senator Muskie. Would you try to summarize the two? The controversy revolves now around the two concepts you have just described. I want to be sure I understand those two concepts and the difference between them.
Senator RANDOLPH. Mr. Chairman, I must go to the floor. I will return later. But at this point could I ask one question?
Senator MUSKIE. Of course.
Senator RANDOLPH. I know that you realize that in the 1970 act we made provision, statutory provision, for the health effects from pollutants. You know that that is written into the basic law. As that research goes forward within the Environmental Protection Agency. I believe, Mr. Chairman, that until this time and I suggest that it be done now-a status report has not been received specifically on what has been done by EPA in contrast with other groups in this area. Are you using the National Institutes of Health?
Dr. GREENFIELD. Senator, we have prepared a preliminary document of that sort because under the law and under the policy of the agency We are constantly trying to update and get these criteria under which the standards are set. We have a preliminary document which looks at what underlies the standards up to this point and what new in formation has come about since the standards were set, and essentially where we stand today. We simply can make that available, if you so desire.
Senator RANDOLPH. Mr. Chairman, the reason I ask this is not in any wise to criticize what has been done.
I am sure you are carrying out the provisions of the act from the standpoint of your research, study and review. But I think it would be helpful to us to know exactly how this is being accomplished with the National Institutes of Health, with certain doctors within our own employ, and with certain outside expertise. I think it is very important that we not overlook the health effects from pollutants as provided for in the 1970 act.
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I take this opportunity to bear down on this point because I think it is vital to our overall understanding of what happens on several fronts. This is one of those important fronts from the standpoint of the pollution of the air.
Dr. FINKLEA. Senator, we couldn't agree with you more. We feel that health effects are probably one of the key items in terms of environmental protection. It is evidenced in our whole research program. It constitutes a very large portion of our research money. In fact, we have devoted one of our main research centers to that subject, and that is evidence of it as well.
In addition, as you probably know, while the Environmental Protection Agency does not have all the environmental health effects funds in the Government under its purview, we must work and we do work very closely with the other agencies like NIH in attempting to satisfy our requirements.
Senator RANDOLPH. Thank you for your responses.
Figure 1 is a pyramid with six layers in which you undertake to identify five broad areas of concern as we try to identify adverse health effects. The top layer is the smallest and involves mortality effects, which are clearly health effects.
Second, below that, are morbidity effects, which are clearly adverse health effects.
The third layer are pathophysiologic changes, which I gather you also identify as clearly adverse health effects. It is the fourth layer which you are now discussing?
Dr. FIXKLEA. Yes, sir. The distinction between the third and fourth layers
Senator MUSKIE. Would you restate that distinction and try to do it in a way that a layman can understand what the distinction is?
Dr. FIXKLEA. The third layer, the layer labeled "pathophysiologie changes," are changes in the way that the body functions which are clearly a risk factor for later disease.
Senator MUSKIE. You have no doubts about that layer at all?
The layer below are changes in body functions whose significance is uncertain at the present time. We would not know whether these were perhaps of no consequence, perhaps even beneficial, or perhaps detrimental. So these are changes. They are effects that can be observed but their significance is unclear.
Senator MUSKIE. Xow could you give is something illustrative?
Dr. FINKLEA. To turn to the second page and think about the layers of effects in relation to carbon monoxide, we can see that the apex of the pyramid that carbon monoxide induced heart attack, which would clearly be adverse effects. Such effects have been reported in studies from California where levels of ambient carbon monoxide is very high. They have not been observed in cities where ambient levels are about the present primary ambient air quality standard. It is unclear whether there is an effect of this sort, but I bring this to your attention as an illustrative problem, as a problem about which there is current controversy.