Update #3 on EPA's CO Rulemaking

[Guest guest]

Contents of Update #3 on EPA's CO Rulemaking

=====================================

New Information

Status of Comments

Status of Petition

--Albert Donnay MHS

Consulting Toxicologist, CO Analyst

and Environmental Health Engineer

adonnay@...

NEW INFORMATION

=================

At a press conference on March 16, EPA Administrator was

personally presented with a petition asking her to request comments on

the CO rule from EPA's Children's Health Protection Advisory Committee

(CHPAC).

She told the media that " Certainly we can include an outreach to CHPAC

on this rule or any other rules. It's an open public comment period

and so we welcome their input.” Unfortunately, she made no such

request, and the committee staff in EPA's Office of Children's Health

Protection refused to include any time on the agenda for consideration

of the CO rule.

When CHPAC met on March 30 and 31, I presented public testimony

comparing EPA's history of consulting CHPAC about National Ambient Air

Quality Standards under the Bush administration (comments requested on

3 of 4 proposed rules regarding ozone, particulates and lead) with the

Obama administration (comments requested on 0 of 7 proposed rules so

far).

I recommended that CHPAC members ask the committee staff to notify

them of new proposed rules affecting the health of children and to

include time on future agendas to discuss them. A few CHPAC members

spoke out in favor of this request when the chair finally allowed a

few minutes of open discussion the next day. But EPA staff remain

opposed, claiming that CHPAC comments are not necessary for proposed

rules on which the Clean Air Scientific Advisory Committee is already

required by law to comment.

Another reason EPA may not have wanted CHPAC to comment on the CO rule

is that Administrator had already certified that Executive

Order 13045 (regarding the Protection of Children From Environmental

Health and Safety Risks) did not apply to this rulemaking " because the

Agency does not believe the environmental health or safety risks

addressed by this action present a disproportionate risk to children. "

Children, of course, are much more sensitive than adults to--and

thus at greater risk from--CO exposures at any level, as EPA has long

acknowledged in other documents.

STATUS OF COMMENTS

====================

Several organizations have said they will submit comments or sign on

to comments of others, including:

Alliance of Nurses for Healthy Environments

American College of Chest Surgeons

American Thoracic Society

American Lung Association

Asthma and Allergy Foundation of America

Chemical Sensitivity Disorders Association

Childrens' Environmental Protection Alliance

Green Cleaning Network

NJ Environmental Health Association

and

Physicians for Social Responsibility,

(which will invite other organizations and medical/public health

professionals to sign on to its comments later next week).

As of April 1, only 10 comments on the CO rule had been posted in the

EPA docket at

http://www.regulations.gov/#!searchResults;dct=PS;rpp=25;po=0;s=EPA-HQ-OAR-2008-\

0015

3 are anonymous and either incoherent or blank.

2 are from organizations concerned only with the burden on them of

proposed new CO monitoring requirements (the American Association of

State Highway and Transportation Officials, and Indiana Dept of

Environmental Management)

2 are from organizations that support the proposed rule and especially

EPA's decision not to give any weight to any epidemiological data

(Alliance of Automobile Manufacturers and Texas Commission on

Environmental Quality)

2 are from college students required by their teachers to submit comments

1 from Safe Air for Everyone is concerned only about the health impact

of CO exposures from the deliberate burning of grasslands in Western

states,

1 from EPA's Tom McCurdy is concerned only with a critical error in

EPA's ABEX modeling program.

PETITION

========

The online petition to EPA for individuals to sign at

http://www.thepetitionsite.com/2/tell-epa-to-lower-carbon-monoxide-exposure-limi\

ts/

has now been signed by 113 people. It will be submitted to EPA on April 12.

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