Update on NOx and SOx National Ambient Air Quality Standards

John R, Balmes, MD UCSF, UC Berkeley, and the California Air Resources Board

Outline
Clean Air Act NO2
Health Effects Status of NAAQS

SO2
Health Effects Status of NAAQS

Clean Air Act of 1970

Required that National Ambient Ambient Air Quality Standards (NAAQS) be set to protect public health and welfare, New Source Performance Standards to promote cleaner technology, and motor vehicle and hazardous emissions standards. U.S. Environmental Protection Agency established to implement this act and Clean Water Act.

Regulation of Criteria Air Pollutants

The EPAs Office of Air Quality Planning and Standards is responsible for setting standards (NAAQS) for pollutants which are considered harmful to people and the environment. These standards are supposed to be based on sound science and are required to have an adequate margin of safety to protect public health. The EPA carefully reviews the scientific evidence regarding important air pollutants
Formerly published in Criteria Documents before issuing or revising NAAQS for the six so-called criteria pollutants. Now, more abbreviated documents called Integrated Scientific Assessments (ISAs).

Criteria Pollutants
Ozone Nitrogen dioxide Sulfur dioxide Particulate matter Carbon monoxide Lead

Regulation of Criteria Air Pollutants

Two types of NAAQS:
Primary standards protect against adverse health effects, with an adequate margin of safety, including the health of "sensitive" populations such as asthmatics, children, and the elderly. Secondary standards protect against welfare effects, such as damage to farm crops and vegetation and damage to buildings.

EPA requires air monitoring for criteria pollutants. Regions that have concentrations of the pollutant that are higher than the NAAQS are designated non-attainment areas.

Regulation of Criteria Air Pollutants

State Implementation Plans (SIPS) are designed to bring air quality into attainment with the NAAQS. States may designate to regional agencies authority to develop and enforce air pollution control plans. When states or regions are in persistent nonattainment or SIPS are deemed inadequate, the EPA can cause federal funds to be withheld (e.g., funds for highway construction).

Review of NAAQS
The EPA Criteria Documents (now ISAs) have traditionally reviewed three types of health effects research:
Toxicological studies Controlled human studies Epidemiological studies

The EPA reviews of the NAAQS are supposed to be timely; the current deadline is every 5 years.

Review of NAAQS
EPA follows a multi-step process for review of the NAAQS.
Development of an Integrated Scientific Assessment that synthesizes new research on health and environmental effects; Preparation of a Risk and Exposure Assessment (REA) document that includes:
A careful assessment of how the public is exposed to the pollutant; A quantitative risk assessment that estimates health effects at the current and various alternative standards; An assessment of the policy implications of the scientific information in the ISA and discussion of the possible ranges for air quality standards.

Publication of proposed standards in the Federal Register; Promulgation of final NAAQS.

These steps each entail the review of public comments.

Review of NAAQS
In addition, an EPA advisory panel of outside experts, known as the Clean Air Scientific Advisory Committee (CASAC), convenes public meetings to review drafts of the ISA, the REA, and the proposed standards. This influential panel typically must "reach closure" before EPA moves to the next step of the process. EPA staff make changes in the draft documents to satisfy the concerns raised by CASAC.

Review of NAAQS
Clean Air Scientific Advisory Committee
The congressionally mandated CASAC panel has seven standing members, and about a dozen additional consultants added specifically for specific review of each standard. The members of CASAC are typically drawn from academia and from industry research organizations, and include a state air quality official. The expertise of the panel members ranges from toxicology to agricultural effects to air quality monitoring. The Committee has enormous influence on EPA's standard-setting process.

Oxides of Nitrogen
Combustion of most fuels produces oxides of nitrogen (NOx).
These emissions are primarily in the form of NO which is oxidized in the atmosphere to NO2. The conversion rate depends on the ambient concentrations of NO and O3. If O3 is present, the conversion is very rapid.

Nitrogen dioxide is the most stable and most abundant of NOx compounds in the atmosphere.

Nitrogen Dioxide (NO2)

NO2 is an oxidant gas like ozone, but not as potent. NO2 reacts with H2O to form HNO3 (nitric acid). NO2 is an important precursor of ozone.

Sources of NOx

Health Effects of NO2

Increased risk of lower respiratory illness in children associated with indoor exposures to oxides of nitrogen Increased risk of both bacterial and viral experimental infections in NO2-exposed animals

Asthma

NO2 and Asthma

CONTROLLED HUMAN EXPOSURE STUDIES Increased nonspecific airway responsiveness Enhanced airway narrowing after inhaled allergen

NO2 and Asthma

EPIDEMIOLOGICAL STUDIES Multiple studies have shown associations between exposure and lower respiratory symptoms in children with asthma. Several studies have also shown associations between exposure and ER visits or hospitalizations for asthma.

Public Health Policy Implications: NO2

The current primary NAAQS for NO2 is an annual arithmetic mean value not to exceed 0.053 ppm.
This NAAQS has not been changed since it was promulgated in 1971.

Based on the data re: NO2 exposure and both lower respiratory infection in children and asthma exacerbations, is an annual average the best way to protect public health?

NO2 ISA
The strongest evidence for an association between NO2 exposure and adverse human health effects comes from epidemiologic studies of respiratory symptoms and ED visits and hospital admissions. This conclusion is based on numerous studies, including panel and field studies, multi-pollutant studies that control for the effects of other pollutants, and studies conducted in areas where the whole distribution of ambient 24-h avg NO2 concentrations was below the current NAAQS level of 0.053 ppm (53 ppb) (annual average).

NO2 ISA
Evidence from human clinical studies, especially for airway hyperresponsiveness in asthmatic individuals, was generally supportive of the epidemiologic evidence. The epidemiologic and experimental evidence together show coherence for effects of NO2 exposure on host defense or immune system effects providing plausibility and mechanistic support for respiratory symptoms and ED visits for respiratory disease.

NO2 REA
Exposure Assessment
NO2 air quality in 18 locations around the country was used as a surrogate for exposure. Exposures were estimated for persons with asthma based on time spent in microenvironments in Atlanta, GA.

Risk Assessment
Occurrences of NO2-related respiratory ED visits in Atlanta were estimated.

NO2 REA
Over 20 million people in the U.S. have asthma. NO2-related airway hyperresponsiveness has the potential to increase asthma symptoms and worsen asthma control. The majority of asthmatics may experience increased airway responsiveness following short-term NO2 exposures between 0.1 ppm and 0.3 ppm.

NO2 REA
Atlanta could experience 6 or more exposures to NO2 concentrations greater than or equal to 0.1 ppm; ~ 60% of Atlanta asthmatics could experience at least one exposure to NO2 concentrations to 0.3 ppm. The experimental evidence provides support for an averaging time of shorter duration than 24 hours (e.g., 1h) while the epidemiologic evidence provides support for both 1-h and 24-h averaging times. The scientific evidence reasonably supports a range of standard levels from 50 ppb to 200 ppb, with strong support for a level 100 ppb.

Given current air quality, virtually all asthmatics in

Sulfur Dioxide (SO2)

Generated primarily from combustion of sulfurcontaining coal and oil Also a constituent of diesel exhaust

SO2 Emission Sources

SO2
The NAAQS for SO2 was established in 1971 and is a 24-hour standard of 0.14 ppm, not to be exceeded more than one time per year, and an annual standard of 0.03 ppm. This allows for relatively high short-term peak exposures. People with asthma are not protected from exacerbations caused by brief exposures.

SO2
SO2 can induce acute bronchospasm in asthmatic subjects at relatively low concentrations and short exposure durations.

SO2 ISA
The ISA concludes that there is sufficient evidence to infer a causal relationship between respiratory morbidity and short-term exposure to SO2. The strongest evidence is from human exposure studies demonstrating increased respiratory symptoms and decreased lung function in exercising asthmatics exposed for 5-10 minutes to 200 ppb SO2. Supporting this conclusion is a larger body of epidemiological studies published since the last review observing associations between 1-hour SO2 concentrations and respiratory symptoms, ED visits, and hospital admissions.

SO2 REA
Exposure assessment
SO2 air quality levels were used as a surrogate for exposure. Exposures were estimated for persons with asthma living in Greene County and St. Louis, MO based on time spent in various microenvironments, as well as time spent at elevated ventilation rates (i.e., exercising).

Risk assessment
A quantitative risk assessment for lung function responses associated with 5-minute exposures to characterize SO2-related health risks was conducted.

SO2 REA
Over 20 million people in the U.S. have asthma. 5-30% of exercising asthmatics will experience moderate or greater lung function decrements following exposure to 200- 300 ppb SO2 for 5-10 minutes. In St. Louis, ~ 46% (48,000) of asthmatics would be expected to experience at least one SO2 exposure concentration 200 ppb while at elevated ventilation rates.

SO2 REA
Taken together, the scientific evidence and the risk and exposure information suggest that the current annual SO2 standard does not provide adequate protection from the health effects associated with shorter-term exposures to SO2. The evidence and exposure and risk information reasonably support a 1-hour daily maximum standard within a range of 50-150 ppb.

Conclusions
The Clean Air Act requires that air quality standards be established to protect the public health with a reasonable margin of safety. Persons with asthma represent a sizable subgroup that is more susceptible to adverse effects of NO2 and SO2. EPA staff, with the concurrence of CASAC, will be recommending new NAAQS for both NO2 and SO2 that are designed to protect asthmatics from adverse health effects.