September 6, 1973
Page 28681
AIR POLLUTION RESEARCH: EPA'S COMMITMENT
Mr. MUSKIE. Mr. President, the Nation's Capital continues to experience its longest and worst air pollution alert. This alert emphasizes again the importance of cleaning up our air and getting the best data possible to determine the health dangers of air pollution.
When Congress enacted the Clean Air Act Amendments of 1970, we recognized that they would have significant impact on the lives of all Americans. In that legislation we placed high priority on protection of the health of all our citizens, and recognized that adjustments in our lifestyles would be necessary to achieve the goal of clean, healthful air.
Since enactment of this far-reaching statute, questions have been raised as to the necessity of the stringent measures proposed and adopted to achieve clean air and the adequacy of the health and air quality monitoring data upon which those stringent regulations are based. Various parties have presented estimates indicating the billions of dollars of cost or the billions of dollars of savings to the American public which might result from implementation of the Clean Air Act. On the one hand the law has been called a $66 billion mistake and on the other it has been suggested that consumers could save as much as $150 billion if Detroit offered an alternative, cleaner auto engine.
Some have argued that lesser controls on air pollution sources would achieve adequate levels of air quality – that EPA's data is faulty, its monitoring methods questionable, and its health standards invalid.
Because of the questions raised and the overwhelming ramifications of regulations under this act, the Committee on Public Works has initiated a comprehensive study by the National Academy of Sciences of the data supporting the health standards and a separate study examining the social and economic impact of auto emission standards. Thus, the Congress is doing its part to assure that the legislation will not have unreasonable or unnecessary side effects.
However, while new information is critical in this matter, it has come to my attention that the Environmental Protection Agency – the Agency charged with prime responsibility to implement this law – is cutting back its data gathering efforts. At a time when tough questions are being raised about the validity of data on which its present actions are based, EPA is reducing its ability to justify its actions.
If this is the case, Mr. President, and the evidence I have suggests that it is, I am appalled. Such a policy would be a gross derogation of responsibility by the Environmental Agency. It is inconceivable to me that, on the one hand, officials of EPA are suggesting that implementation of some requirements of the Clean Air Act, particularly the transportation controls, may be unreasonable, while, on the other hand, EPA is cutting back efforts to assure that the health standards which make the allegedly unreasonable regulations necessary are fully supportable by available evidence.
It is equally inconceivable that the Agency would plan to reduce the long term data base accumulated through the continuous air monitoring program by eliminating that activity in a number of cities.
I would hope this is not the case. I would hope that the long term welfare of our citizens will not be sacrificed to short term budgetary expediency. But, as I have said, the evidence is strong that EPA has been undercutting its own health research and air quality monitoring efforts.
First, though EPA's health research budget is limited, the Agency has continued to provide millions of dollars to the auto industry and the oil companies – industries regulated by EPA – for health studies upon which EPA, in part, bases regulation of those industries. Such a relationship is highly improper and poses serious questions of conflict of interest which were discussed in some detail in the August 24 issue of Science magazine.
Second, the Subcommittee on Air and Water Pollution recently received evidence that even the presently inadequate support for research into the health effects of air pollution is being cut back. This evidence is derived from direct examination of the EPA budget, and it is pinpointed in a recent memo from the Director of EPA's health research program. Discussing the cutbacks, his memo notes:
These figures are given at this time to document the lack of commitment to our Agency to the intent of the Presidential Initiatives program and to the health program in general. These substantial budgetary reductions have occurred in the face of mounting criticism of the health basis for our air quality standards, and in view of appeals both from within and outside the Agency for more scientific and credible air quality standards. The declining level of support suggests that the Agency is not responsive to these criticisms.
These cutbacks are particularly appalling in light of the multibillion-dollar implications of the Clean Air Act regulatory programs which I have already mentioned.
Third, in addition to reducing efforts in health research, EPA also is undercutting its monitoring efforts. EPA is planning to close four of its continuous air monitoring program stations. These stations, established about 10 years ago, have provided a critical base for analysis of monitoring data, new monitoring techniques, and air quality trends. These stations are vital to determining the success or failure of air pollution control programs. Closing these stations will terminate this valuable point of reference and severely limit any historical perspective on air pollution. Future discussion of air quality trends and development of new and better monitoring techniques will be severely undercut because of the lack of this important base of experience. Further, by closing the monitoring stations, EPA deprives itself of necessary experience in the monitoring field – experience which it can communicate to State and local governments to help improve their monitoring techniques. This is particularly important because States and localities continue to have the prime responsibility for air quality monitoring and assessment.
Finally, and perhaps of greatest concern, the subcommittee has received new evidence of office of Management and Budget interference in EPA regulatory determinations. This latest effort relates to EPA's responsibility to develop health effects data and to publish air quality and emission control regulations based on that health effects data.
At the direction of OMB, and after several recent EPA studies of the matter, the Department of Health, Education, and Welfare is to be given the prime responsibility to study health effects of sulfur oxides. Apparently the Office of Management and Budget does not like the results of the studies which EPA has provided.
Apparently, the Executive Office of the President, which proposed creation of the Environmental Protection Agency, no longer believes EPA capable of accomplishing its mission. I can only conclude that this OMB mandated study is designed to justify a weaker sulfur oxides regulatory policy.
As I noted, EPA has only recently completed studies indicating that present standards of sulfur oxide control are fully justified and that even stricter standards will be necessary. I placed one of these studies in the CONGRESSIONAL RECORD of April 4. The National Academy of Sciences has also studied the sulfur oxide matter and is doing so again at the request of the Committee on Public Works as part of the general review of health effects data.
Taken alone, any of these bits of evidence of the administration's declining commitment in the health effects research and data gathering area would be enough for serious concern. Taken together these points of evidence raise very serious questions of the administration's commitment to this program at a time when the health effects and monitoring data are being used to justify regulations which have multi-billion dollar implications for the American people.
Mr. President, I hope that EPA will not act to reduce its efforts to develop health effects and air quality data – that EPA will continue to provide us with the best and most comprehensive data base possible so that we can fairly make critical policy decisions relating to protection of the environment.
At this point, Mr. President, I ask unanimous consent that there be included in the RECORD documents which I have received discussing the problems of EPA's commitment in this area.
There being no objection, the material was ordered to be printed in the RECORD, as follows:
AUTO POLLUTION: RESEARCH GROUP CHARGED WITH CONFLICT OF INTEREST
One of the first issues that Russell Train, the nominee for administrator of the Environmental Protection Agency (EPA), will have to decide if and when he takes office, will be what to do about that agency's role in automotive pollution research. Train's predecessor, William Ruckelshaus, promised Congress that he would reassess some of the agency's close research ties with the auto and oil industries it regulates.
At issue is EPA's participation in a key research organization, called Coordinating Research Council-Air Pollution Research Advisory Committee (CRC-APRAC), which has sponsored much of the research that has been important to federal regulation in the battle to clean up the nation's air. CRC-APRAC is supported by the auto industry, the oil industry, and the EPA.
However, a few months ago Ruckelshaus promised Congress:
"If it [EPA participation in CRC-APRAC] gives the appearance to you and possibly to others that this has compromised our position, we will have to cease this association.
An internal review is under way at EPA, and a report is due soon.
Because three-fourths of the $20 million that the group has spent to date has come from the American Petroleum Institute (API) and the Motor Vehicles Manufacturers' Association (MVMA), with only the remaining fourth from the government, CRC-APRAC has been accused by public interest lobbyists and members of Congress as having a pro-industry bias. Moreover, because it puts the regulated industries in bed with the agency that regulates them, the arrangement, says the pollution guru of Congress, Senator Edmund Muskie (D-Me.), poses a serious conflict of interest for EPA.
The APRAC group is one wing of CRC, a major trade organization which, for over half a century, has been a vehicle for getting the oil and engine suppliers together on some common problems. The APRAC group is unusual to CRC and to other trade research organizations in general because it receives large amounts of federal funding and routinely has federal officials participating in its decisions. The arrangement grew up in the late 1960's, when auto pollution was first becoming recognized as a national issue and when research funds for EPA's predecessor in the field, the National Air Pollution Control Administration (NAPCA), were scarce. Now, however, critics argue that EPA should be pursuing a "Caesar's wife" policy and keep itself above suspicion in its regulation of the auto industry, and that the CRC-APRAC tie is compromising.
The alleged conflict of interest which Muskie and others see in EPA's tie with CRC-APRAC, however, may be only the tip of the iceberg. Almost without exception, when a research scientist is funded by CRC-APRAC, he is already taking money from both the industry being regulated and the regulator. But this potential conflict is further tangled by the fact that many of CRC-APRAC's contractors, separately, depend on the auto or oil industry for a major share of their business. Some take money not only from the industry, but from EPA too. What emerges is not a clear-cut line between scientists working for EPA and those working for industry, but, instead, a murkier set of in-group relationships. Small wonder then, that, after 5 years of national effort, many apparently simple technical questions relating to auto emissions control remain hotly disputed.
Of CRC-APRAC's foes, the best-known is Muskie. In hearings last April on the EPA postponement of the 1975 emissions control deadline that was imposed by the 1970 Clean Air Act, the Maine Democrat challenged the objectivity of studies done by a researcher who has done much of CRC -APRAC's work on the health effects of carbon monoxide (CO), Richard D. Stewart of the Medical College of Wisconsin in Milwaukee. Stewart had found evidence that the average level of carboxyhemoglobin – an indicator of CO poisoning – in the blood of nonsmokers across the country was below 2 percent, which is the safe limit now used in federal regulation. (Stewart also found carboxyhemoglobin in the blood of smokers to be higher than that in nonsmokers.) Muskie, illustrating why CRC-APRAC researchers are accused of bias, pointed out that Stewart's work had been overseen by a typical CRO-APRAC panel, headed by a man from the General Motors Corp. (GM), with people from Phillips Petroleum Co., Marathon Oil Co., another GM man, and one EPA representative, who, Muskie added sarcastically, was "slightly outnumbered." Muskie also waved a full page Chrysler Corp. ad publicizing Stewart's results, and he said, "Chrysler is the one automobile manufacturer which has attacked the health basis of the 1975 standards. It is that information which is going to be peddled around the country for the purpose of attacking the basis of the 1970 Act."
(In fact, Stewart's findings, as written up by Associated Press and carried in newspapers across the country, were interpreted as evidence of the heavy influence of smoking in CO poisoning, a finding which other researchers on health effects – such as John Goldsmith of the California State Health Department – believe may be valid but nonetheless distracting from the main point: that susceptible people, involuntarily exposed to CO from auto exhaust, suffer adverse health effects.) Muskie listed other panels of CRC-APRAC where big auto and oil companies are generously represented, while EPA employees are outnumbered – sometimes by 12 to 1. He argued that the auto companies take advantage of EPA's support of CRC-APRAC to give its work credibility, and then publicize their own interpretations of it.
"The shadow of EPA's involvement can be used and will be used to give the aura of credibility, official credibility, to statements made by Chrysler like this, challenging the health basis of the act ... I say the answer is to provide adequate funds and not lean upon industry to do the job."
Whether or not EPA is really an equal partner in CRC-APRAC hinges on the extent to which it exerts an influence on the group's deliberations. The CRC-APRAC's full-time officers, general manager Milton K. McLeod and project manager Alan Zengel stated in interviews that most of the group's decisions are made by the APRAC committee, which has 6 EPA representatives out of a total of 21 members. The APRAC committee decides, without formal outside review, what work shall be undertaken, and who shall be appointed to the many subpanels, such as the one Muskie listed during the hearings, which supervise the research work itself. As to the government officials being outnumbered, McLeod and Zengel admitted (and EPA officials confirmed) that the panels often make decisions by voting, and that sometimes EPA people vote one way with the industry voting the other.
[The APRAC group consists of: C. M. Heinen, Chrysler Corp., chairman; J. W. Blattenberger, Cities Service Oil Co.; D. L. Block of Ford Motor Co.; C. E. Burke of American Motor Corp.; R. A. Colt of Shell Oil Co.; R. E. Eckhardt of Esso Research and Engineering Co.; E. F. Fort of International Harvester Co.; D. G. Levine of Esso Research and Engineering Co.; E. D. Marande of Ford Motor Co.; C. E. Moser of Texaco Inc.; E. H. Scott of Standard Oil of Ohio; P. D. Strickler of Gulf Research and Development Co.; C. S. Tuesday of General Motors Corp.; R. B. Welly of Jeep Corp ; D. W. Innes of Ford Motor Co.; and, from the Environmental Protection Agency, A. P. Altshuller, J. F. Finklea, R. E. Harrington, Kay Jones, Eric Stork, and H. L. Wiser.]
However, not only do the oil and auto companies appear to dominate much of CRC-APRAC's decision-making, but the groups which CRC-APRAC selects to perform its research, in turn, depend for their livelihoods on business with these same industries. The most obvious example is that part of CRC-APRAC's work is funded by fuel companies and performed by fuel companies, and deals with matters in which they have a vital interest. CRC-APRAC has given a total of approximately $1 million to three oil companies: Esso Research and Engineering Co., a subsidiary of Standard Oil of New Jersey, which is studying the effectiveness of two well-known emission control devices, thermal reactors, and dual catalysts; Ethyl Corp., where changes in fuel volatility, a suggested means for lowering harmful emissions, are under study; and Phillips Petroleum Co. One of the major decisions EPA' must make is whether short-term measures, such as altered fuels, and add-on gadgets, such as the dual catalyst, can be substituted by Detroit for a major switch to a new type of auto engine with new fueling requirements.
In addition to funding oil companies directly, CRC-APRAC supports other contractors who, in turn, depend on oil and auto companies for a major share of their business – a situation that again raises the question of their stake in the outcome of the research. The largest CRC-APRAC contractor is TRW Systems, which has gotten $3.3 million from that group. Despite its reputation among scientists as an aerospace firm, the parent company, TRW Inc., in fact does approximately 40 percent of its worldwide business (its annual sales are $1.6 billion) making and marketing vehicle parts. Thus, it is very much an interested party in federal regulations affecting the auto industry. TRW Systems, the research arm of this giant, has studied all aspects of vehicle maintenance and inspection for CRC-APRAC. The issue of vehicle maintenance and inspection has been a bone of contention between the industry and the government ever since the 1970 act passed Congress. According to Charles Heinen of Chrysler Coro., and CRC-APRAC's chairman, the auto manufacturers have been arguing that strict maintenance and inspection policies to keep existing auto antipollution equipment clean would serve to meet emission standards. But EPA standards setters have countered that such a policy, emphasizing maintenance, would deemphasize the need to improve the quality of the original equipment installed in the car. They have said that this would therefore shift the burden of the clean car from the manufacturer to the owner or his garage mechanic.
The second largest recipient of CRC-APRAC money has been Scott Research Laboratories, Inc., one of the country's leading makers of air pollution measuring equipment. In the last 3 years, Scott has done about half its business, or about $3.8 million, with auto and fuel companies and their trade associations. Additionally, CRC-APRAC over the same period has spent an added $1.1 million at Scott.
One of Scott's major projects for CRC-APRAC has been studies of vehicle use patterns, or what EPA regulators term "driving cycles." A driving cycle is a package of information on when and where various types of vehicles – trucks, cabs, cars, and others – are used, at what speeds they are run, at what temperatures, and so forth. Data on actual vehicle use, which in turn go into making up the EPA driving cycle, has been a central issue to many ongoing disputes over emissions control, since one of EPA's standards setting jobs is to determine the driving cycles, which in turn determine the performance standards that manufacturers must make their engines meet.
According to Malcolm Smith, one of Scott's principal investigators on the vehicle use studies, at the termination of the CRC-APRAC sponsored work, the auto industry took the data to EPA and used it to argue that existing federal "driving cycles" be reexamined,but EPA refused.
One of the largest contractors to CRC-APRAC has been the Stanford Research Institute at Menlo Park, California, which has received $1.3 million in the last 5 years. John Eikelman, SRI coordinator of environmental research says that a major portion of SRI's industrial environmental research has been with the petrochemical industry, including measuring pollutant damage to vegetation, identification of crude oil in spills, and other work. SRI has also worked on catalytic emission control systems and auto parts for various other industry sponsors. For CRC-APRAC one principal researcher, Harris Benedict worked on a nationwide assessment of damage to crops attributable to air pollution; but even this work illustrates how the thrust of CRC-APRAC research, despite its intrinsic interest and merit, keeps coming back to regulatory issues in which EPA is involved up to its ears.
The SRI researchers surveyed dollar value losses to corn, citrus, and other food crops and to ornamental plants, indexed them geographically, and came up with an overall annual loss estimate of $132 million, far less than a previous estimate of $500 million. The finding that air pollution doesn't do as much damage to crops – which after all are mostly in rural parts of the country – as had been feared has proved useful in arguing against cleaning up every single automobile in the nation; it indirectly strengthens the hand of those who want a geographic national pollution control strategy limited to urban areas, where air pollution is worst. Another SRI-performed study found that soil is a natural "sink" or absorber of CO. This is a finding which clearly affects the debate over whether overall CO levels are increasing or decreasing, and, hence, over the urgency of man's need to reduce them. Both studies, then, have a link, albeit indirect, to EPA's regulatory role.
CRC-APRAC's research program must be viewed in light of the fact that some of it is performed by the oil companies themselves, some by groups who depend or have depended heavily on oil and auto companies for their business – both of which have some stake in the regulatory game. A third pattern among CRC-APRAC contractors, and one that further muddles the issue of who works for whom, is that many of the smaller CRC-APRAC contractors also take money from the American Petroleum Institute and the Motor Vehicle Manufacturers' Association directly, from the oil and auto industries, and in some cases, from the government, too. An all-in-the family pattern appears to characterize the winning and losing of pollution research contracts. For example, Smith, at Scott Laboratories, noted that after EPA declined to accept the industry's interpretation of its surveys of vehicle use to reexamine the driving cycles, Scott was able to continue the work through MVMA sponsorship anyway. Another case was that of Wilbur Smith Associates, an international transportation consulting firm, which had research and development contracts simultaneously with EPA and with CRC-APRAC. According to one of the researchers there, Wilbur Smith Associates has subcontracted a part of its work to a Bedford, Mass., aerospace firm GCA Corp., which, oddly enough has in addition held its own contract directly with CRC-APRAC. Many of the principal investigators interviewed remarked that these overlapping, interlocking contract awards were typical of the auto emission research business, and some added that it was also a characteristic of the aerospace-Defense Department business in which many of these investigators previously worked. In fact, several major university centers for air pollution work are conspicuously absent from the list of 40-odd CRC-APRAC contractors, whereas about 14 of the contractors are firms prominent in the aerospace field. Many of the investigators interviewed said they personally had done aerospace work: "I got tired of making bomb calculations," said one. "Working on environmental problems seemed to be a good thing to do," said another. But an EPA official who sits on some CRC-APRAC panels offered a less sanguine view: "The only thing worse than an unemployed aerospace engineer," he quipped, "is an unemployed aerospace engineer who has gone to work on the environment. "
Interviewed about the soundness of policies which appear to encourage researchers to take money from both EPA and the auto and oil industries, many of the investigators retorted, "How else would you do it?" Many pointed out that just giving more money to EPA – with a proviso that EPA get out of CRC-APRAC – which is what Muskie's staff is considering doing – would not solve the problem, since EPA has as much stake in the outcome of the research as the industry does. A California air pollution expert, however, made another suggestion which others echoed: that a separate government body, serving in effect as a third party to the controversy, become the prime sponsor of auto emissions research. "I'm amazed that parts of HEW [the Department of Health, Education, and Welfare] have been overlooked in all this. Why shouldn't they build up a capability in the NIEHS [National Institute of Environmental Health Sciences]? ... They're good. They'd be ideal ... But they've been ignored."
– DEBORAH SHAPLEY.
U.S. ENVIRONMENTAL PROTECTION AGENCY,
Research Triangle Park, N.C.,
July 27, 1973.
Subject: Substantial Decline in Agency Support for the Air Health Programs.
From: Carl M. Shy, M.D., Acting Director, HSL.
To: Director, NERC/RTP.
Beginning with fiscal year 1973, a Presidential Initiative of $5.0 million per year for five years was added to the air health program. Under the New Technology Opportunities program, the Domestic Council recognized the need for a stronger health information base for your national air quality standards. The $5.0 million add-on was given with the understanding that these monies would fund new programs and would not be used in place of regular Agency support for the health program.
As shown in Table 1, the Agency has failed to support the air health program at the FY '72 level of support (the year preceding the Presidential add-on). In FY '73, the air health program budget was approved at a funding level which was $895,000 below the FY '72 base. In FY '74, the approved budget is $1,590,000 below the FY '72 base. (These figures deduct the $5.0 million Presidential add-on). If the annual inflation rate of 5.5 percent is included in the calculations, the anticipated total annual budgets for fiscal year 1973 and 1974 should have been $11,668,000 and $12,001,000 respectively. Thus, with inflationary increases, the actual FY '73 budget is $2,241,000 below the FY '72 base. In two years, these sums represent a decline of $3,254,000 in Agency support for the air health program when compared with the 1972 base year. Thus, while $10,000,000 should have been added to the program under the Presidential Initiative, only $6,746,000 was actually added, or 32.5 percent less than required to maintain the FY '72 program level with a $5.0 million add-on.
These funding reductions have been matched by even greater manpower reductions, as shown in Table 2. The air health program has been reduced from an approved 208 positions in FY '72 to 170 and 161 positions in FY '73 and FY '74 respectively. Not only was there no increase in manpower to manage the $5.0 million Presidential add-on, but an 18 to 23 percent manpower reduction was experienced as compared with the FY '72 base year.
If the Agency's funding relationship with the Coordinating Research Council must be severed, $297,000 in additional health funds must be provided to maintain the projected FY '74 level of effort.
Very recently, new responsibilities and monies were allocated to the Fuels and Fuel Additives Registration program element. Among these resources were $970,000 and no man-years for health research of fuel and fuel additive hazards. This effort represents an entirely new responsibility, will not be directed towards the primary air quality standards for which the Presidential add-on was appropriated and thus does not contribute to the support base of fiscal year 1972.
These figures are given at this time to document the lack of commitment of our Agency to the intent of the Presidential Initiatives program and to the health program in general. These substantial budgetary reductions have occurred in the face of mounting criticism of the health basis for our air quality standards, and in view of appeals both from within and outside the Agency for more scientific and credible air quality standards. The declining level of support suggests that the Agency is not responsive to these criticisms.
ENVIRONMENTAL PROTECTION AGENCY,
July 9, 1973.
Reply to Attn of: OD/QAEML.
To: Matthew Bills, Director; Data and Information Research Division.
Subject: CAMP and Equivalency Operations.
This is to confirm our telecon of Friday, July 9, concerning both CAMP and Equivalency Operations.
1. As you know, the results of PAG II indicate that CAMP operations are to be reduced drastically. To that end we are currently making the initial steps to close the CAMP stations in Cincinnati, Denver, Chicago, and Philadelphia. Before closing these stations however, QAEML will make every effort to relocate the responsibility for the operations of these stations to the appropriate Regional Office. If the Regional Offices are agreeable, then the CAMP operations will be continued; if not, the CAMP operations in the aforementioned cities will be closed.
2. The placing of resources into the "Method Equivalency Program" seems to be bouncing back and forth like the proverbial rubber ball. As it stands now, equivalency operations will not be funded in FY 1974. If this continues to be the case, then QAEML will have no choice but to discontinue its activities in the equivalency area. This in turn makes the following actions mandatory,
a. Alert OPE and the EPA steering committee dealing with equivalency not to publish the "Equivalency Document" since no resources will be available to implement it.
b. Alert the Office of Air and Water Programs, the Regional Administrators and the Division Directors of the Surveillance and Analysis and Air Programs in each Region that the "Equivalency Document" will not be published. This will necessarily mean that EPA and Regional Offices will have to develop some other mechanism to give advice to state agencies on what analytical instrumentation to purchase for the analysis of air pollutants in support of State implementation Plans. In addition, the problem of inter-relatability of data resulting from different analytical measurement techniques (such as occurred with the recent NO2 problem), will also have to be addressed.
c. To be fair to the air pollution instrument manufacturers across the nation, an article should be published in various trade and scientific journals notifying them of EPA's intent of not publishing the equivalency document. Only in this manner can all instrument companies be adequately and equally informed that EPA will not place any restrictions on the performance of air monitoring instruments they produce.
If you have any questions concerning the above topics, do not hesitate to call. We assume that the actions outlined above will be carried out by the Headquarters staff since "equivalency" is now a "policy decision" and no longer a "field problem."
THOMAS R. HAUSER,
Deputy Director, Quality Assurance and Environmental Monitoring Laboratory.
DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE,
July 17, 1973.
To: Dr. David P. Ran, Director, NIEHS,
Through: Director, NIH.
From: Assistant Secretary for Health. Subject: Health Effects of Sulfur Oxides in the Ambient Air.
Attached is copy of a letter from the Director of the Office of Management and Budget to Secretary Weinberger requesting the Department of Health, Education, and Welfare to take the lead in a cooperative study with the Environmental Protection Agency to examine the existing scientific information on this subject.
I regard this request as very important and urgent and ask that you assume leadership responsibility for the Department. You should feel free to call upon any of the existing resources in the Department for such assistance as may be necessary. Please let me know, through Dr. Ian Mitchell, if any assistance from this level is needed.
You should feel free to contact the Environmental Protection Agency directly following receipt of this memorandum.
CHARLES C. EDWARDS, M.D.
OFFICE OF MANAGEMENT AND BUDGET,
Washington, D.C., June 22, 1973.
Hon. CASPAR W. WEINBERGER,
Secretary of Health, Education, and Welfare,
Washington, D.C.
DEAR MR. SECRETARY: In order to document our current understanding of the health effects of sulfur oxides in the ambient air, I request the Department of Health, Education, and Welfare, to take the lead in a cooperative study with the Environmental Protection Agency to examine the existing scientific information on this subject.
We are particularly interested in an assesment of the adequacy of current information on the ambient levels of sulfur oxides to ascertain the extent to which human health is affected. If a definitive statement cannot be provided on the basis of current information an outline of the types of studies necessary to provide a definitive level should be developed. Assuming that additional studies may be necessary, we would appreciate receiving an estimate of the time required and costs to complete the additional studies.
Your report should specifically address the following areas to the extent that available information permits:
1. The extent of the demonstration of a cause-and-effect relationship between exposure to sulfur oxides and adverse health consequences, including the issue of dose-effect relationships.
2. The degree to which the findings in number 1 are supported by epidemiological, clinical, and experimental or laboratory studies, including matters of agreement or disagreement among the findings produced by the various study approaches.
3. The variable susceptibility to adverse effects of sulfur oxides among different population groups.
4. A quantification of health effects in relation to various levels of exposure.
5. The relationship between various levels of sulfur oxide exposure and costs in terms of impaired health, including the costs of care and loss of productivity among those who are or may be adversely affected by exposure to sulfur oxides.
Dr. Ian Mitchell of your staff has discussed the scope of the study with Robert Rings of OMB staff. I would like to receive your report by October 10, 1973.
Sincerely,
ROY L. ASH, Director.
DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE,
June 17, 1973.
To: Assistant Secretary for Health.
From: The Secretary.
Subject: Health Effects of Sulfur Oxides in the Ambient Air.
As you are aware, the Director of the Office of Management and Budget has asked the Department of Health, Education, and Welfare to take the lead in a cooperative study with the Environmental Protection Agency to examine the existing scientific information on this subject.
Copy of OMB's request and my response to OMB's request are attached. I shall appreciate it if you will see that the Department provides the fullest possible assistance to NIEHS in meeting the needs of OMB in this matter.
SECRETARY OF HEALTH, EDUCATION, AND WELFARE,
Washington, D.C., July 17, 1973.
Hon. ROY ASH,
Director,
Office of Management and Budget,
Washington, D.C.
DEAR MR. ASH: Thank you for your letter of June 22 requesting that the Department of Health, Education, and Welfare take the lead in a cooperative study with the Environmental Protection Agency to examine the existing scientific information on the health effects of sulfur oxides in the ambient air.
I am asking the Assistant Secretary for Health to have the Director of the National Institute of Environmental Health Sciences take the lead for the Department in this endeavor and to call upon whatever resources may exist in the Department to assure a thorough and timely examination of the issues raised in your letter.
Sincerely,
/s/
Secretary.
SECRETARY OF HEALTH, EDUCATION, AND WELFARE,
Washington, D.C.,
July 17,1973.
Hon. ROBERT W. FRI,
Acting Administrator,
Environmental Protection Agency,
Waterside Mall,
Washington, D. C.
DEAR MR. FRI: Enclosed is a copy of f letter I received on June 28 from the Director of the Office of Management and Budget requesting the Department of Health, Education, and Welfare to take the lead in a cooperative study with the Environmental Protection Agency to examine the existing scientific information on the health effects of sulfur oxides in the ambient air. I have asked the Assistant Secretary for Health to assign leadership responsibility for the Department to the Director of the National Institute of Environmental Health Sciences and to provide him with all necessary resources available in the Department.
We look forward to working closely with the Environmental Protection Agency on this subject. The Director of the National Institute of Environmental Health Sciences will be in touch with the Environmental Protection Agency in the very near future to ensure prompt initiation and timely completion of the study.
Sincerely,
/s/
Secretary.
U.S. ENVIRONMENTAL PROTECTION AGENCY
August 2,1973.
Subject: OMB-DHEW Review of Sulfur Oxide.
From: Director, NERC-RTP.
To: Assistant Administrator, ORD, Laboratory Directors, Dr. G. Hueter.
1. Present were Bob Riggs, OMB, Bill Dickinson of OMB, Dr. Millman of Dr. Edwards' office, Dr. Whittenberger of Harvard School of Public Health and Dr. Norton Nelson of New York University.
2. Mr. Riggs recounted that Senate Subcommittee on Air and Water Pollution will begin hearings in mid-September. OMB is concerned about economic impact of Clean Air Act of 1970. OMB feels it is mandatory to explain benefits of sulfur oxide control. OMB must have formal progress report by 15 September. OMB forecasts major power shortages in mid-West during summer of 1975 because of low sulfur deficit of 200xl06 tons of fuel or 1000MW of power. OMB or Congress also plan to conduct further studies of transportation controls (DOT), of fuel availability with Federal Power Commission, and adverse effects on welfare through quality of life review. OMB is tending to advocate state or regional secondary air quality standards rather than national standards. NOx problem still rests with EPA.
3. Dr. Finklea gave the Committee the following materials:
Sulfate task force report.
Air quality criteria for sulfur oxides.
CHESS monograph.
Revised SO2 chapter on vegetation.
Short sulfur oxides summary.
EPA program paper on assuring that public health is protected by the mobile source emissions control program.
EPA review of primary ambient air quality standards.
Epidemiological study of chronic bronchitis with special reference to effect of air pollution by Tsunetoski.
4. Dr. Finklea will send copy of Waddell reports on costs of clean air.
5. Dr. N. Nelson suggested that since EPA was being critically reviewed by the OMB effort, EPA should not be represented. Dr. Rail and Dr. Whittenberger equivocated. Dr. Nelson suggested that Ben Ferris, Frank Spicer, Lester Breslow, Ian Higgins, Bob Frank, Ipsen, and George Hutchinson participate. Dr. Carnow and Dr. John Goldsmith would serve as "resource persons" as might Warren Winkelstein, David Bates, Peter Macklin, David Anderson, Mary Amdur and Dick Rilley.
6. The group will be briefed at NERC-RTP on 8/13 and 8/14. The next meetings will take place in Washington on 8/22 and 8/23, and on 9/6 and 9/7. The RTP meeting will be in room M303 at 9:00 a.m.
JOHN F. FINKLEA, M.D.