Tell EPA to Consult Children's Health Protection Advisory Comm. about proposed carbon monoxide rule
- by: www.COconundra.info
- recipient: EPA Administrator Lisa Jackson
EPA has not asked its Children's Health Protection Advisory Committee (CHPAC) to comment on its proposed carbon monoxide (CO) rule, even though fetuses and children are more sensitive than adults to CO exposure at any level.
Both the CHPAC chair and its EPA staff are resisting efforts to put this important issue on the agenda of the committee's March 30 meeting. This is CHPAC's last chance to discuss EPA's CO standards before the EPA deadline for public comments expires April 12. EPA has asked CHPAC in the past to comment on EPA rules about other National Ambient Air Quality Standards for particulates, lead and ozone.
EPA Administrator Lisa Jackson should formally ask the CHPAC to comment on the proposed CO rule. Please sign this petition asking her to do so.
And please sign our other petition which asks EPA to lower the limits for CO exposure, at http://www.thepetitionsite.com/2/tell-epa-to-lower-carbon-monoxide-exposure-limits/
Both the CHPAC chair and its EPA staff are resisting efforts to put this important issue on the agenda of the committee's March 30 meeting. This is CHPAC's last chance to discuss EPA's CO standards before the EPA deadline for public comments expires April 12. EPA has asked CHPAC in the past to comment on EPA rules about other National Ambient Air Quality Standards for particulates, lead and ozone.
EPA Administrator Lisa Jackson should formally ask the CHPAC to comment on the proposed CO rule. Please sign this petition asking her to do so.
And please sign our other petition which asks EPA to lower the limits for CO exposure, at http://www.thepetitionsite.com/2/tell-epa-to-lower-carbon-monoxide-exposure-limits/
Petition to consult EPA's Children's Health Protection Advisory Committee
We the undersigned organizations and individuals concerned with the health of fetuses and children,
Concerned in particular with the risks posed to fetuses and children by exposure to carbon monoxide (CO), to which children have long been recognized by EPA as more sensitive and susceptible than adults at all levels of exposure (1),
Concerned about the public health implications of peer-reviewed studies documenting that fetuses and children face statistically significant risks of increased morbidity and mortality from the following causes, all of which are associated with very small increases in average outdoor CO exposures (of 1ppm or less), and within current ambient ranges of just 0 to 5ppm, and all far below EPA's current 8-hour average outdoor limit of 9ppm:
* Respiratory mortality in both neonates (2) and children (3)
* Low birth weight (4)%
* Pre-term birth (5)
* Cardiac birth defects, including Tetralogy of Fallot (6) and ventricular septal birth defects (7), for which CO is already recognized as an environmental risk factor by CDC's National Center on Birth Defects and Developmental Disabilities (8)
* Asthma, including asthma-related ER visits (9) and hospitalizations (10)
Concerned that EPA's new proposed National Ambient Air Quality Standards (NAAQS) for CO are based, as in past reviews of the CO NAAQS, only on reducing the risk of angina in adults with heart disease (11), and not on any consideration of the greater risks posed by CO to fetuses and children,
and in particular the risk of birth defects, for which epidemiological evidence is supported by animal studies of CO's teratogenicity (12),
Concerned by your conclusion that EPA's proposed CO rule is not subject to Executive Order 13045 regarding the Protection of Children from Environmental Health and Safety Risks "because the Agency does not believe the environmental health or safety risks addressed by this action present a disproportionate risk to children" (13),
Concerned that EPA's Office of Children's Health Protection (OCHP) did not seek comment from or even inform its federally chartered Children'a Health Protection Advisory Committee (CHPAC) about EPA's current CO NAAQS rulemaking, even though EPA's OCHP has sought and received comments in the past from CHPAC on other NAAQS rulemakings that affected the health of children, including those on lead, ozone and particulates (14),
Concerned that the staff of EPA's OCHP now refuse to even add any discussion of EPA's CO rulemaking to the agenda of the only remaining CHPAC meeting that will be held before EPA's April 12 deadline for public comments (15),
Do hereby petition EPA Administrator Lisa Jackson to formally request comments on EPA's proposed CO NAAQS rule from CHPAC before its next meeting on March 30 and 31, 2011, and to grant CHPAC an extension to prepare comments should this be requested.
References cited in Petition to US EPA Administrator Lisa Jackson
1. Protect Your Family and Yourself from Carbon Monoxide Poisoning, US EPA Indoor Environments Division, Office of Air and Radiation, EPA-402-F-96-005, October 1996.
2. Ritz B, Wilhelm M, Zhao Y. Air pollution and infant death in southern California, 1989-2000.Pediatrics. 2006 Aug;118(2):493-502.
3. Concei%uFFFD%uFFFDo GM, Miraglia SG, Kishi HS, Saldiva PH, Singer JM. Air pollution and child mortality: a time-series study in S%uFFFDo Paulo, Brazil. Environ Health Perspect. 2001 Jun;109 Suppl 3:347-50.
4. Maisonet M, Bush TJ, Correa A, Jaakkola JJ. Relation between ambient air pollution and low birth weight in the Northeastern United States. Environ Health Perspect. 2001 Jun;109 Suppl 3:351-6.
5. Wilhelm M, Ritz B.Local variations in CO and particulate air pollution and adverse birth outcomes in Los Angeles County, California, USA. Environ Health Perspect. 2005 Sep;113(9):1212-21.
6. Gilboa SM, Mendola P, Olshan AF, Langlois PH, Savitz DA, Loomis D, Herring AH,Fixler DE. Relation between ambient air quality and selected birth defects, seven county study, Texas, 1997-2000. Am J Epidemiol. 2005 Aug 1;162(3):238-52. Epub 2005 Jun 29.
7. Ritz B, Yu F, Fruin S, Chapa G, Shaw GM, Harris JA. Ambient air pollution and risk of birth defects in Southern California. Am J Epidemiol. 2002 Jan 1;155(1):17-25.
8. CO listed by CDC%u2019s National Center on Birth Defects and Developmental Disabilities as an environmental risk factor for Tetralogy of Fallot at http://www.cdc.gov/ncbddd/birthdefects/TetralogyOfFallot.html and for ventricular septal defects at http://www.cdc.gov/ncbddd/birthdefects/VentricularSeptalDefect.html
9. Thompson AJ, Shields MD, Patterson CC. Acute asthma exacerbations and air pollutants in children living in Belfast, Northern Ireland. Arch Environ Health. 2001 May-Jun;56(3):234-41.
10. Lee JT, Kim H, Song H, Hong YC, Cho YS, Shin SY, Hyun YJ, Kim YS. Air pollution and asthma among children in Seoul, Korea. Epidemiology. 2002 Jul;13(4):481-4.
11. US EPA National Ambient Air Quality Standards for Carbon Monoxide; Proposed Rule (section II.C). Federal Register, 76(29), 2/11/11, 8158-8220. Online at http://edocket.access.gpo.gov/2011/pdf/2011-2404.pdf
12. Singh J, Aggison L Jr, Moore-Cheatum L. Teratogenicity and developmental toxicity of carbon monoxide in protein-deficient mice.Teratology. 1993 Aug;48(2):149-59.
13. US EPA National Ambient Air Quality Standards for Carbon Monoxide; Proposed Rule (Appendix G). Federal Register, 76(29), 2/11/11, 8158-8220. Online at http://edocket.access.gpo.gov/2011/pdf/2011-2404.pdf
14. CPHAC comments to EPA Administrators regarding proposed NAAQS rules on particulates in 2006, ozone in 2007, and lead in 2008 are online at http://yosemite.epa.gov/ochp/ochpweb.nsf/content/CHPAC_Comments.htm
15. Telephone calls and email correspondence in February and March 2011 from Albert Donnay to US EPA OCHP staff Martha Berger and Michael Firestone and CHPAC chair Dr. Pamela Shubat.
Sign PetitionSign PetitionWe the undersigned organizations and individuals concerned with the health of fetuses and children,
Concerned in particular with the risks posed to fetuses and children by exposure to carbon monoxide (CO), to which children have long been recognized by EPA as more sensitive and susceptible than adults at all levels of exposure (1),
Concerned about the public health implications of peer-reviewed studies documenting that fetuses and children face statistically significant risks of increased morbidity and mortality from the following causes, all of which are associated with very small increases in average outdoor CO exposures (of 1ppm or less), and within current ambient ranges of just 0 to 5ppm, and all far below EPA's current 8-hour average outdoor limit of 9ppm:
* Respiratory mortality in both neonates (2) and children (3)
* Low birth weight (4)%
* Pre-term birth (5)
* Cardiac birth defects, including Tetralogy of Fallot (6) and ventricular septal birth defects (7), for which CO is already recognized as an environmental risk factor by CDC's National Center on Birth Defects and Developmental Disabilities (8)
* Asthma, including asthma-related ER visits (9) and hospitalizations (10)
Concerned that EPA's new proposed National Ambient Air Quality Standards (NAAQS) for CO are based, as in past reviews of the CO NAAQS, only on reducing the risk of angina in adults with heart disease (11), and not on any consideration of the greater risks posed by CO to fetuses and children,
and in particular the risk of birth defects, for which epidemiological evidence is supported by animal studies of CO's teratogenicity (12),
Concerned by your conclusion that EPA's proposed CO rule is not subject to Executive Order 13045 regarding the Protection of Children from Environmental Health and Safety Risks "because the Agency does not believe the environmental health or safety risks addressed by this action present a disproportionate risk to children" (13),
Concerned that EPA's Office of Children's Health Protection (OCHP) did not seek comment from or even inform its federally chartered Children'a Health Protection Advisory Committee (CHPAC) about EPA's current CO NAAQS rulemaking, even though EPA's OCHP has sought and received comments in the past from CHPAC on other NAAQS rulemakings that affected the health of children, including those on lead, ozone and particulates (14),
Concerned that the staff of EPA's OCHP now refuse to even add any discussion of EPA's CO rulemaking to the agenda of the only remaining CHPAC meeting that will be held before EPA's April 12 deadline for public comments (15),
Do hereby petition EPA Administrator Lisa Jackson to formally request comments on EPA's proposed CO NAAQS rule from CHPAC before its next meeting on March 30 and 31, 2011, and to grant CHPAC an extension to prepare comments should this be requested.
References cited in Petition to US EPA Administrator Lisa Jackson
1. Protect Your Family and Yourself from Carbon Monoxide Poisoning, US EPA Indoor Environments Division, Office of Air and Radiation, EPA-402-F-96-005, October 1996.
2. Ritz B, Wilhelm M, Zhao Y. Air pollution and infant death in southern California, 1989-2000.Pediatrics. 2006 Aug;118(2):493-502.
3. Concei%uFFFD%uFFFDo GM, Miraglia SG, Kishi HS, Saldiva PH, Singer JM. Air pollution and child mortality: a time-series study in S%uFFFDo Paulo, Brazil. Environ Health Perspect. 2001 Jun;109 Suppl 3:347-50.
4. Maisonet M, Bush TJ, Correa A, Jaakkola JJ. Relation between ambient air pollution and low birth weight in the Northeastern United States. Environ Health Perspect. 2001 Jun;109 Suppl 3:351-6.
5. Wilhelm M, Ritz B.Local variations in CO and particulate air pollution and adverse birth outcomes in Los Angeles County, California, USA. Environ Health Perspect. 2005 Sep;113(9):1212-21.
6. Gilboa SM, Mendola P, Olshan AF, Langlois PH, Savitz DA, Loomis D, Herring AH,Fixler DE. Relation between ambient air quality and selected birth defects, seven county study, Texas, 1997-2000. Am J Epidemiol. 2005 Aug 1;162(3):238-52. Epub 2005 Jun 29.
7. Ritz B, Yu F, Fruin S, Chapa G, Shaw GM, Harris JA. Ambient air pollution and risk of birth defects in Southern California. Am J Epidemiol. 2002 Jan 1;155(1):17-25.
8. CO listed by CDC%u2019s National Center on Birth Defects and Developmental Disabilities as an environmental risk factor for Tetralogy of Fallot at http://www.cdc.gov/ncbddd/birthdefects/TetralogyOfFallot.html and for ventricular septal defects at http://www.cdc.gov/ncbddd/birthdefects/VentricularSeptalDefect.html
9. Thompson AJ, Shields MD, Patterson CC. Acute asthma exacerbations and air pollutants in children living in Belfast, Northern Ireland. Arch Environ Health. 2001 May-Jun;56(3):234-41.
10. Lee JT, Kim H, Song H, Hong YC, Cho YS, Shin SY, Hyun YJ, Kim YS. Air pollution and asthma among children in Seoul, Korea. Epidemiology. 2002 Jul;13(4):481-4.
11. US EPA National Ambient Air Quality Standards for Carbon Monoxide; Proposed Rule (section II.C). Federal Register, 76(29), 2/11/11, 8158-8220. Online at http://edocket.access.gpo.gov/2011/pdf/2011-2404.pdf
12. Singh J, Aggison L Jr, Moore-Cheatum L. Teratogenicity and developmental toxicity of carbon monoxide in protein-deficient mice.Teratology. 1993 Aug;48(2):149-59.
13. US EPA National Ambient Air Quality Standards for Carbon Monoxide; Proposed Rule (Appendix G). Federal Register, 76(29), 2/11/11, 8158-8220. Online at http://edocket.access.gpo.gov/2011/pdf/2011-2404.pdf
14. CPHAC comments to EPA Administrators regarding proposed NAAQS rules on particulates in 2006, ozone in 2007, and lead in 2008 are online at http://yosemite.epa.gov/ochp/ochpweb.nsf/content/CHPAC_Comments.htm
15. Telephone calls and email correspondence in February and March 2011 from Albert Donnay to US EPA OCHP staff Martha Berger and Michael Firestone and CHPAC chair Dr. Pamela Shubat.
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