EPA needs to consider COVID-19 for its standards
The Aug. 9 Insight piece by Michael Wilner, “At EPA, Virus Disrupts Research, Raises Questions Over Air Quality Impact,” unfortunately allows Environmental Protection Agency Administrator Andrew Wheeler to sidestep responsibility for the impact of COVID-19 on air pollution standards. Mr. Wheeler failed to consider COVID-19 when proposing a fine particulate air pollution standard — a standard particularly pertinent to Pittsburgh-area residents.
Mr. Wheeler is quoted as dismissing studies relating air pollution to COVID-19 deaths by saying that the findings are not conclusive because of difficulties with COVID-19 death statistics. I do not disagree. But Mr. Wheeler ignores the very strong public health mandate in the Clean Air Act, which requires that air pollution standards have an “adequate margin of safety” in order to “address uncertainties associated with inconclusive scientific and technical information.”
Further, the administrator is to set the margin of safety “even if the risk is not precisely identified as to nature or degree.”
Congress also specified the factors that should be considered in setting the margin of safety, including the size of the sensitive population and the nature and severity of the effects. For both COVID-19 and fine particles, the sensitive populations include the elderly and those with pre-existing lung and heart disease. It should be no surprise that a virus that viciously attacks the lungs and heart is more likely to be fatal to those whose lungs and heart are compromised because of air pollution.
There was ample time to consider COVID-19 in its margin of safety for the proposed fine-particle standard before its release in late April. Instead, for the first time, the language supporting the proposed standard contains no consideration of factors that might affect the margin of safety. The EPA needs to consider COVID-19 in its final particulate standard and forthcoming ozone standard rather than contravene congressional intent.
BERNARD D. GOLDSTEIN, M.D. Professor and Dean Emeritus University of Pittsburgh Graduate School of Public Health
Oakland