{"id":65399,"date":"2014-11-25T16:15:39","date_gmt":"2014-11-25T21:15:39","guid":{"rendered":"https:\/\/junkscience.com\/?p=65399"},"modified":"2015-11-01T11:29:16","modified_gmt":"2015-11-01T16:29:16","slug":"fact-sheet-epas-claim-that-its-coal-plant-co2-rules-will-save-lives-by-reducing-particulate-matter-emissions-is-false","status":"publish","type":"post","link":"https:\/\/junkscience.com\/2014\/11\/fact-sheet-epas-claim-that-its-coal-plant-co2-rules-will-save-lives-by-reducing-particulate-matter-emissions-is-false\/","title":{"rendered":"FACT SHEET: EPA\u2019s Claim That Its Coal Plant CO2 Rules Will Save Lives By Reducing Particulate Matter Emissions Is False"},"content":{"rendered":"<p>You may submit this information <a href=\"http:\/\/www2.epa.gov\/carbon-pollution-standards\/how-comment-clean-power-plan-proposed-rule\">to EPA by December 1, 2014 as a public comment<\/a>. A PDF of this fact sheet is <a href=\"https:\/\/junkscience.com\/wp-content\/uploads\/2014\/11\/epa-pm-health-claims-debunked-112514.pdf\">here<\/a>.<!--more--><\/p>\n<p><strong>EPA\u2019s Claim.<\/strong> The EPA <a href=\"https:\/\/www.federalregister.gov\/articles\/2014\/06\/18\/2014-13726\/carbon-pollution-emission-guidelines-for-existing-stationary-sources-electric-utility-generating\">proposed<\/a> 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 <a href=\"http:\/\/www2.epa.gov\/carbon-pollution-standards\/fact-sheet-clean-power-plan-overview\">6,600 premature deaths annually<\/a>.  These deaths would not be prevented by reducing CO2 emissions but instead by accompanying reductions in emissions of \u201cfine particulate matter\u201d (PM2.5) \u2014 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.<\/p>\n<p>EPA\u2019s position is that that:<\/p>\n<ul>\n<li>ANY inhalation of PM2.5 can cause death;<\/li>\n<li>Death from PM2.5 may occur within hours of inhalation (i.e., \u201cshort-term\u201d or literally \u201csudden death\u201d) and that;<\/li>\n<li>Long-term (i.e., years or decades) exposure to PM2.5 can cause premature death.<\/li>\n<\/ul>\n<p>EPA claims that natural and manmade PM2.5 causes as many as <a href=\"http:\/\/epahumantesting.com\/the-most-toxic-substance-on-earth\/\">500,000 deaths annually<\/a>.<\/p>\n<p>In support its claim that PM2.5 kills, <a href=\"http:\/\/epahumantesting.com\/the-most-toxic-substance-on-earth\">EPA points to \u201cthousands\u201d of epidemiologic (statistical studies of human populations), toxicologic (experiments on animals) and clinical (experiments on humans) studies<\/a>.   EPA further claims that the agency\u2019s conclusions have been endorsed by its Clean Air Act Scientific Advisory Council (CASAC), a board of outside science advisors. <\/p>\n<p><strong>Scientific Reality:<\/strong> PM2.5 does not kill anyone. The EPA\u2019s claims of PM2.5 lethality rank among the most nonsensical, fraudulent and readily disprovable scientific claims ever.<\/p>\n<p><strong>EPA\u2019s three bodies of research.<\/strong> EPA claims the PM2.5-mortality hypothesis is supported by existing epidemiology, toxicology and clinical studies. This is false.<\/p>\n<ul>\n<li><strong>Epidemiology.<\/strong> EPA <a href=\"https:\/\/junksciencecom.files.wordpress.com\/2014\/07\/epa-memo-in-opp-to-tro-062614-copy.pdf\">admitted<\/a> 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: \u201cepidemiologic studies do not generally provide evidence of direct causation.\u201d 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.<\/li>\n<li><strong>Toxicology.<\/strong> <a href=\"http:\/\/www.epa.gov\/ncea\/pdfs\/partmatt\/Dec2009\/PM_ISA_full.pdf\">No laboratory animal has ever died from PM2.5 in an experimental setting<\/a> \u2014 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. <\/li>\n<li><strong>Clinical studies.<\/strong> EPA has tested a variety of air pollutants \u2014 including very high exposures to PM2.5 \u2014 on over 6,000 human volunteers. Many of these volunteers were elderly or already health-compromised \u2014 the very groups EPA claims are most susceptible to dying from PM2.5 exposures. <a href=\"https:\/\/junksciencecom.files.wordpress.com\/2014\/06\/epa-irb-app-6000-volunteers.pdf\">EPA has admitted that there have been no deaths or any dangerous adverse events clearly caused by these PM2.5 exposures<\/a>.  PM2.5 exposures in these experiments have been as high as 21 times greater than allowable by EPA\u2019s own air quality rules.<\/li>\n<\/ul>\n<p>EPA\u2019s claim about PM2.5 causing death is not supported by the results from these research disciplines, individually or collectively.<\/p>\n<p><strong>Real-world evidence that PM2.5 does not cause sudden or long-term death.<\/strong> 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 \u2014 <a href=\"http:\/\/www.epa.gov\/air\/basic.html\">by as much as a factor of 100<\/a>.  <\/p>\n<p>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. <\/p>\n<p>Despite much research, there is no generally accepted medical or biological explanation for how PM2.5 could possibly cause death. <\/p>\n<p>Much higher exposures to PM2.5 than exist even in the \u201cworst\u201d outdoor air are not associated with sudden death. The level of PM2.5 in average U.S. outdoor air \u2014 air that EPA claims can cause sudden death \u2014 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 href=\"http:\/\/www.atsjournals.org\/doi\/full\/10.1164\/rccm.200802-334OC - .U7QmVhaHffg\">a cigarette smoker inhales approximately 10,000 to 40,000 micrograms of PM2.5 per cigarette<\/a>.   A marijuana smoker inhales <a href=\"http:\/\/www.drugscience.org\/Petition\/C2B.html\">3.5-4.5 times more PM2.5 \u2014 i.e., 35,000 to 180,000 micrograms of PM2.5<\/a>.  Typical water pipe or \u201chookah\u201d smokers <a href=\"http:\/\/www.fic.nih.gov\/News\/GlobalHealthMatters\/march-april-2014\/Pages\/nih-hookah-waterpipe-tobacco-smoking.aspx\">inhale the equivalent PM2.5 of 100 cigarettes per session<\/a>.  There is <a href=\"http:\/\/www.washingtontimes.com\/news\/2012\/nov\/30\/whats-epa-smoking\/\">no example<\/a> 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 <a href=\"http:\/\/www.msha.gov\/S&amp;HINFO\/BlackLung\/2011-172NIOSH.pdf\">mines<\/a>,  indoor wood burning, <a href=\"https:\/\/junksciencecom.files.wordpress.com\/2014\/07\/hook-bar-pm-study.pdf\">smoking areas<\/a>  or extremely poor quality urban air, for example, in <a href=\"http:\/\/www.washingtontimes.com\/news\/2013\/jan\/22\/chinas-bad-air-puts-the-lie-to-epa-scare-tactics\/\">Chinese citie<\/a>s. <\/p>\n<p>The EPA\u2019s claim that PM2.5 causes long-term death is grounded in two long-term epidemiologic studies: the \u201cHarvard Six Cities\u2019 Study and the \u201cAmerican Cancer Society\u201d (ACS) study. <a href=\"http:\/\/www.foxnews.com\/story\/2001\/02\/02\/epa-secret-science\/\">Both studies are controversial for many methodological reasons<\/a>.  The controversy cannot be resolved as <a href=\"http:\/\/science.house.gov\/press-release\/smith-subpoenas-epa-s-secret-science\">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<\/a>.  For results to be considered to be scientifically credible, they must be capable of being independently replicated. <\/p>\n<p>A large <a href=\"https:\/\/junkscience.com\/2013\/12\/26\/epa-air-pollution-scare-debunked-by-best-data-set-ever-assembled-on-particulate-matter-deaths\/\">analysis<\/a> of the recent daily air quality and daily death data from California for 2007-2010 reports no association between PM2.5 and death.  <\/p>\n<p>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 <a href=\"http:\/\/www.washingtontimes.com\/news\/2012\/apr\/24\/did-obamas-epa-relaunch-tuskegee-experiments\/\">inhale PM2.5 at levels up to 21 times higher than EPA air pollution standards allow<\/a>.  The agency, however, has <a href=\"http:\/\/www.washingtontimes.com\/news\/2013\/feb\/13\/milloy-federal-judge-overturns-epa-human-experimen\/\">refused<\/a> to cease conducting these experiments. <\/p>\n<p><strong>But hasn\u2019t EPA\u2019s CASAC reviewed and approved EPA\u2019s claims about PM2.5 and death?<\/strong> As <a href=\"http:\/\/online.wsj.com\/articles\/lamar-smith-what-is-the-epa-hiding-from-the-public-1403563536\">pointed out<\/a> by House Space, Science and Technology Committee chairman Lamar Smith (R-Tex.), \u201cThe EPA&#8217;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.\u201d  These \u201cindependent\u201d reviewers are on the EPA payroll in amounts of <a href=\"http:\/\/www.washingtontimes.com\/news\/2012\/mar\/7\/clearing-the-air-on-the-epa\/\">tens of million of dollars<\/a>.  EPA\u2019s refusal to make its key data available to the public and the obvious conflicts of interest render CASAC review not credible.<\/p>\n<p>A PDF version of this fact sheet (updated as of 11-25-14) is available <a href=\"https:\/\/junkscience.com\/wp-content\/uploads\/2014\/11\/epa-pm-health-claims-debunked-112514.pdf\">here<\/a>.<\/p>\n","protected":false},"excerpt":{"rendered":"<p>You may submit this information to EPA by December 1, 2014 as a public comment. A PDF of this fact sheet is here.<\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"open","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"jetpack_post_was_ever_published":false,"_jetpack_newsletter_access":"","_jetpack_dont_email_post_to_subs":false,"_jetpack_newsletter_tier_id":0,"_jetpack_memberships_contains_paywalled_content":false,"_jetpack_memberships_contains_paid_content":false,"footnotes":"","jetpack_publicize_message":"","jetpack_publicize_feature_enabled":true,"jetpack_social_post_already_shared":true,"jetpack_social_options":{"image_generator_settings":{"template":"highway","enabled":false},"version":2}},"categories":[10,17],"tags":[],"class_list":["post-65399","post","type-post","status-publish","format-standard","hentry","category-air-quality","category-epa"],"jetpack_publicize_connections":[],"jetpack_featured_media_url":"","jetpack_sharing_enabled":true,"jetpack_shortlink":"https:\/\/wp.me\/p6SqJi-h0P","_links":{"self":[{"href":"https:\/\/junkscience.com\/wp-json\/wp\/v2\/posts\/65399","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/junkscience.com\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/junkscience.com\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/junkscience.com\/wp-json\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"https:\/\/junkscience.com\/wp-json\/wp\/v2\/comments?post=65399"}],"version-history":[{"count":0,"href":"https:\/\/junkscience.com\/wp-json\/wp\/v2\/posts\/65399\/revisions"}],"wp:attachment":[{"href":"https:\/\/junkscience.com\/wp-json\/wp\/v2\/media?parent=65399"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/junkscience.com\/wp-json\/wp\/v2\/categories?post=65399"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/junkscience.com\/wp-json\/wp\/v2\/tags?post=65399"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}