By: Elizabeth Bechard, Senior Policy Analyst, Moms Clean Air Force
Date: October 20, 2023
About: Docket ID EPA-HQ-ORD-2023-0435: Comments on the Integrated Science Assessment for Ozone
To: Environmental Protection Agency
On behalf of Moms Clean Air Force, thank you for the opportunity to respond to this notice. We offer the following comments in response to the call for information regarding the design and scope of the review of the national ambient air quality standards for ozone:
Ozone poses a significant threat to public health. As an organization of 1½ million parents and caregivers committed to protecting children’s right to breathe clean air, we are particularly concerned about the impacts of ozone on childhood and prenatal health. Researchers and medical professionals have long known that ozone can trigger and exacerbate childhood asthma. And a growing body of research also links ozone to troubling adverse birth outcomes, such as preterm birth, low birth weight, and stillbirth. Communities of color and low-income communities are disproportionately impacted by the health harms of ozone for numerous reasons: they are more likely to live in communities overburdened by air pollution; they may be more vulnerable to health threats because of lack of access to health-protective factors, like access to health care, grocery stores, and good jobs; and they often have higher rates of chronic health conditions that can predispose them to greater risk.
As the letter from the EPA’s Clean Air Scientific Advisory Committee to Administrator Regan in June 2023 made clear, a robust body of current science indicates that our present ozone standards do not adequately protect public health. In the June 2023 letter, all but one of the CASAC members concluded “that the scientific evidence indicates that the level of the current primary standard is not sufficiently protective of public health. CHE studies demonstrate adverse effects in healthy adults near or below the current standard of 70 ppb.”
In reviewing the upcoming Integrated Science Assessment, we ask that all relevant science regarding ozone and public health be carefully reviewed and considered, particularly science that (1) addresses the impacts of ozone on health during pregnancy and childhood; and (2) addresses ozone-related health disparities affecting communities of color and other systematically marginalized groups.
In addition, we ask that the EPA completes the Integrated Science Assessment in a timely manner. According to the Clean Air Act, the ozone NAAQS must be reviewed every 5 years; by law, this review must be completed by December 31, 2025. Any further delay will threaten the well-being of millions of children and families around the country, including the more than 100 million people in the US who live in counties with F grades for ozone pollution, according to the American Lung Association 2023 State of the Air Report.
Finally, we offer the following recent studies for consideration in the science assessment:
- Association of air pollution and heat exposure with preterm birth, low birth weight, and stillbirth in the US: a systematic review (2020) https://jamanetwork.com/journals/jamanetworkopen/fullarticle/2767260
- Ozone exposure during early pregnancy and preterm birth: a systematic review and meta-analysis (2021) https://pubmed.ncbi.nlm.nih.gov/33989623/
- Ambient air pollution and stillbirth: an updated systematic review and meta-analysis of epidemiological studies (2021) https://pubmed.ncbi.nlm.nih.gov/33689950/
- The short-term effect of ozone on pregnancy loss modified by temperature: findings from a nationwide epidemiological study in the contiguous United States (2023) https://pubmed.ncbi.nlm.nih.gov/37549698/
Respectfully,
Elizabeth Bechard, on behalf of Moms Clean Air Force