FACT SHEET: EPA’s Claim That Its Coal Plant CO2 Rules Will Save Lives By Reducing Particulate Matter Emissions Is False

You may submit this information to EPA by December 1, 2014 as a public comment. A PDF of this fact sheet is here.

EPA’s Claim. The EPA proposed on June 2, 2014 to reduce carbon dioxide (CO2) emissions from coal-fired power plants by reducing the amount of coal burned. EPA claims this rule will prevent up to 6,600 premature deaths annually. These deaths would not be prevented by reducing CO2 emissions but instead by accompanying reductions in emissions of “fine particulate matter” (PM2.5) — dust or soot particles much smaller in diameter than the width of a human hair. As the rule would reduce CO2 emissions by reducing the amount of coal burned, it would similarly reduce PM2.5 emissions. The EPA views this reduction in PM2.5 emissions as a health benefit.

EPA’s position is that that:

• ANY inhalation of PM2.5 can cause death;
• Death from PM2.5 may occur within hours of inhalation (i.e., “short-term” or literally “sudden death”) and that;
• Long-term (i.e., years or decades) exposure to PM2.5 can cause premature death.

EPA claims that natural and manmade PM2.5 causes as many as 500,000 deaths annually.

In support its claim that PM2.5 kills, EPA points to “thousands” of epidemiologic (statistical studies of human populations), toxicologic (experiments on animals) and clinical (experiments on humans) studies. EPA further claims that the agency’s conclusions have been endorsed by its Clean Air Act Scientific Advisory Council (CASAC), a board of outside science advisors.

Scientific Reality: PM2.5 does not kill anyone. The EPA’s claims of PM2.5 lethality rank among the most nonsensical, fraudulent and readily disprovable scientific claims ever.

EPA’s three bodies of research. EPA claims the PM2.5-mortality hypothesis is supported by existing epidemiology, toxicology and clinical studies. This is false.

• Epidemiology. EPA admitted in federal court that its epidemiologic studies on PM2.5 prove nothing by themselves. In 2012 litigation in which EPA attempted to justify its experiments on humans with PM2.5, EPA admitted doing the experiments because: “epidemiologic studies do not generally provide evidence of direct causation.” The purpose of the human experiments, according to EPA, was to develop a medical or biological explanation (i.e., the direct causation) that would support the merely statistical (and, by the way, controversial) results of the PM2.5 epidemiology studies.
• Toxicology. No laboratory animal has ever died from PM2.5 in an experimental setting — even though animals have been exposed to levels of PM2.5 as much as 100+ times greater than human exposures to PM2.5 in outdoor air.
• Clinical studies. EPA has tested a variety of air pollutants — including very high exposures to PM2.5 — on over 6,000 human volunteers. Many of these volunteers were elderly or already health-compromised — the very groups EPA claims are most susceptible to dying from PM2.5 exposures. EPA has admitted that there have been no deaths or any dangerous adverse events clearly caused by these PM2.5 exposures. PM2.5 exposures in these experiments have been as high as 21 times greater than allowable by EPA’s own air quality rules.

EPA’s claim about PM2.5 causing death is not supported by the results from these research disciplines, individually or collectively.

Real-world evidence that PM2.5 does not cause sudden or long-term death. Everyone is constantly and unavoidably exposed to PM2.5 from both natural and manmade sources. Natural sources include dust, pollen, mold, pet dander, forest fires, sea spray and volcanoes. Manmade sources primarily are smoking, fossil fuel burning, industrial processes, wood stoves, fireplaces and indoor cooking. Indoor exposures to PM2.5 can easily exceed outdoor exposures — by as much as a factor of 100.

Although EPA claims that almost 25% of annual U.S. deaths are caused by PM2.5, no death has ever been medically attributed to PM2.5.

Despite much research, there is no generally accepted medical or biological explanation for how PM2.5 could possibly cause death.

Much higher exposures to PM2.5 than exist even in the “worst” outdoor air are not associated with sudden death. The level of PM2.5 in average U.S. outdoor air — air that EPA claims can cause sudden death — is about 10 millionths of a gram (microgram) per cubic meter. In one day, a person breathing such air would inhale about 240 micrograms of PM2.5. In contrast, a cigarette smoker inhales approximately 10,000 to 40,000 micrograms of PM2.5 per cigarette. A marijuana smoker inhales 3.5-4.5 times more PM2.5 — i.e., 35,000 to 180,000 micrograms of PM2.5. Typical water pipe or “hookah” smokers inhale the equivalent PM2.5 of 100 cigarettes per session. There is no example in published medical literature of these various types of short-term smoking causing sudden death despite the very high exposures to PM2.5. Sudden death is also not associated with other high PM2.5 exposures and environments like mines, indoor wood burning, smoking areas or extremely poor quality urban air, for example, in Chinese cities.

The EPA’s claim that PM2.5 causes long-term death is grounded in two long-term epidemiologic studies: the “Harvard Six Cities’ Study and the “American Cancer Society” (ACS) study. Both studies are controversial for many methodological reasons. The controversy cannot be resolved as EPA refuses to release and/or refuses to compel release of key data used in the studies to independent researchers for purposes of re-analysis and replication. For results to be considered to be scientifically credible, they must be capable of being independently replicated.

A large analysis of the recent daily air quality and daily death data from California for 2007-2010 reports no association between PM2.5 and death.

Finally, if EPA really believed that PM2.5 was as deadly as the agency claims, then the agency would be legally and ethically compelled to stop conducting experiments in which human subjects, including the elderly and health compromised, are made to inhale PM2.5 at levels up to 21 times higher than EPA air pollution standards allow. The agency, however, has refused to cease conducting these experiments.

But hasn’t EPA’s CASAC reviewed and approved EPA’s claims about PM2.5 and death? As pointed out by House Space, Science and Technology Committee chairman Lamar Smith (R-Tex.), “The EPA’s regulatory process today is a closed loop. The agency funds the scientific research it uses to support its regulations, and it picks the supposedly independent (but usually agency-funded) scientists to review it.” These “independent” reviewers are on the EPA payroll in amounts of tens of million of dollars. EPA’s refusal to make its key data available to the public and the obvious conflicts of interest render CASAC review not credible.

A PDF version of this fact sheet (updated as of 11-25-14) is available here.