New book holds the EPA’s feet to the fire

by Charles G. Battigmilloy-epa-book

Steve Milloy is one persistent gentleman. Combining his legal and statistics education, he has spent most of his years ferreting out the false use of statistical techniques in the field of epidemiology. He continues the same quest in his latest book “Scare Pollution: Why and How to Fix the EPA” (2016) Bench Press . This is his sixth such book since “Science-Based Risk Assessment: A Piece of the Superfund Puzzle” (1995).

 

Just what is epidemiology? One definition:

“the science concerned with the study of the factors determining and influencing the frequency and distribution of disease, injury, and other health-related events and their causes in a defined human population for the purpose of establishing programs to prevent and control their development and spread.”

Milloy notes that “The key to the value of epidemiology as an investigative tool is that a researcher must be looking for a relatively high rate of a relatively rare event in a human population… Epidemiologic results are essentially correlations and, as we all learn in Statistics 101, correlations do not equate to causation.” The “devil is in the details” aphorism comes to life as Milloy exposes the EPA’s use of any minute level of correlation as evidence of statistically significant correlation to justify its definition of Clean Air standards.

Milloy’s latest book documents his multiple attempts in multiple formats to hold the EPA to basic standards of ethical epidemiologic theory and practice. His book details the quixotic nature of that quest.

An executive order by President Richard Nixon in 1970 unified federal environmental activities into a single new organization, the U.S. Environmental Protection Agency. Though the EPA was never officially organized by Congress as a Presidential cabinet-level department, Nixon’s new federal bureaucracy undertook the writing and implementation of Clean Air Act (1963) laws. This unique status of the EPA as an all- powerful federal agency lacking cabinet-level status continues to present. It has developed itself into a self-perpetuating rouge agency which defies congressional oversight attempts, as Milloy documents. From its $1 billion annual budget and 4,000 employees in 1970, the EPA expanded into a $6 billion annual budget with 16,000 employees by 1991.

Milloy began working on a variety of environmental issues involving the EPA in 1990. However, his quest for truth in statistics in identifying such impacts on human health has identified one issue at the top of the pile of EPA “malfeasance” actions. That is the matter of air quality standards.

Milloy:” When EPA began regulating PM in 1971, it regulated relatively large pieces of dust and soot that were anywhere from 25 to 45 millionths of a meter (one to two thousandths of an inch) in diameter. In 1987, EPA revised its rules to focus on smaller bits of dust and soot that were 10 millionths of a meter in diameter (about half the width of a human hair)—so-called PM10 (pronounced P-M-ten). In November 1996 under Administrator Browner, EPA proposed to regulate even smaller bits of dust and soot, particles that were 2.5 millionths of a meter in width—so-called PM2.5 (pronounced P-M-two-point-five).5

The EPA’s PM2.5 proposal wasn’t particularly interesting except that the agency claimed its regulation of PM2.5 would save 20,000 lives per year, or in EPA parlance, prevent 20,000 premature deaths. Who knew that outdoor air in America was killing anyone, let alone due to something called PM2.5, which is both a naturally occurring and manmade substance?”

Quoting Milloy: “This is a type of air pollution that the EPA calls

‘fine particulate matter,’ or PM2.5 (pronounced P-M-2-point-5). PM2.5 is very small dust or soot in the air, some of which is released by natural sources like volcanoes and forest fires and some of which is manmade. The EPA’s view of PM2.5 essentially is that it is the most toxic substance known to man. There is no safe exposure to PM2.5 and any exposure can kill you within hours—according to the EPA, that is. Fittingly, PM2.5 has been central to the EPA’s regulatory agenda for the past 20 years. The EPA’s most prominent, burdensome and expensive regulations all are based on it. PM2.5 is an issue that the EPA has exploited to exercise complete control over the energy, transportation and industrial sectors—in short, a large and vital part of the U.S. economy.”

Thus while a major effort has been undertaken by skeptical scientists (i.e. traditional fact-verifying scientists) to disprove EPA claims that fossil fuel usage and CO2 production are driving catastrophic global warming and global climate change, the agency has been toiling away in the background using air quality standard-making as the more effective destructive tool in its regulatory zeal to control our energy production and usage at all levels.

What EPA claim is at the center of power for its regulatory onslaught? It is linked to September 22, 2011 when EPA Administrator, Lisa Jackson, testified before a subcommittee of the House Energy and Commerce Committee.

Administrator Jackson stated: “Particulate matter causes premature death. It doesn’t make you sick. It’s directly causal to dying sooner than you should…If we could reduce particulate matter to levels that are healthy, we would have an identical impact to finding a cure for cancer.” At the time that would have been almost one in four deaths in America. Yet there were no standardized criteria to identify such a “cause of death” at autopsy, nor a way to separate out other contributing factors.

The Clean Air Act bars the EPA from considering costs when setting air quality standards. The Supreme Court has held that the EPA can only set air quality standards based on scientific determinations that provide an adequate margin of safety so as to protect the public health. With no limits on the economic costs of its air pollution remedies, the EPA had the potential to ratchet down PM standards to levels below natural background levels. A succession of presidential regimes attempted to put some rational cost limits in place. The last one standing is from September 1993, when then-President Clinton cancelled Executive Order 12291 of President Reagan, and replaced it with his own Executive Order 12866, which only required that “the benefits of the intended regulation justify its costs.”

Merely a passing challenge to the EPA was this issue of cost benefits of their air quality standards. As Milloy explains: “Economists have a methodology called ‘contingent valuation’ that fabricates values virtually out of the imaginations of randomly selected and surveyed people. The EPA then estimated that by reducing PM2.5, albeit indirectly, as many as 11,000 lives would be saved every year—with every life worth $9 million or so, the EPA estimated the benefits of the rule to be worth as much as $90 billion per year. And since $90 billion in benefits is a lot more than $11 billion in costs, EPA had solved its cost-benefit problem. Never mind that the $90 billion in costs were imaginary in nature while the $11 billion costs were actual in nature.” Problem solved.

Criticism by Milloy and others of the EPA’s refusal to provide the original data used to make such claims, lead to independent studies by Milloy and by James Enstrom (UCLA) of actual hospital admissions in California. When patient admissions were cross-checked with particulate matter levels, no statistical correlation was found. Smoggier air was not killing the elderly or young. The Clean Air act only mandated healthy air; it did not mandate esthetically pleasing pristine air.

Faced with mounting criticism of its air pollution claims based solely on epidemiological studies, which were merely statistical computer trolling of data of dubious quality, the EPA ventured into human subject testing. Milloy documents the use of human subjects, both young and old, in gas chamber experiments funded by the EPA at the University of North Carolina, the University of Michigan, the University of Washington, the University of Rochester, the University of Southern California and Rutgers University. Aiming to prove its claim of “death by any level of particulate matter” in ambient air, Milloy documents that such experiments were unethical and in defiance of the Nuremberg Code. In spite of numerous articles in the press, Congressional hearings, and appeals to state boards of medicine by Milloy, none of the perpetrators have been punished.

Milloy:

“The EPA has become quite simply a part of the federal government that is a law unto itself. It holds itself above the rules of science and, worse, above the rules of law, even where there is some relevant statutory language. Between its political and ideological bent and fat wallet, the EPA has established an enormous base of support it can call on whenever threatened. It has gotten away with the PM2.5 charade because no one has ever seriously tried to put a stop to it.”

I encourage readers to read Milloy’s book and share the dismay attendant to such overt manipulation of science and the political system by an essentially rogue agency. It is a fond hope that the Trump administration will restore science to its rightful place in federal policy making, and restore our trust in the regulations imposed on us.


Charles G. Battig, M.S., M.D., Heartland Institute policy expert on environment; VA-Scientists and Engineers for Energy and Environment (VA-SEEE).  His website is www.climateis.com

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128 thoughts on “New book holds the EPA’s feet to the fire

      • self-perpetuating rouge agency or self-perpetuating rogue agency or maybe both. Amusing slip.

        However, what this article says about false promotion of PM2.5 is far more important. PM2.5 is the new ‘global warming’. This is intended be used to remove our right to autonomous personal transport.

        Further proof of why the federal EPA needs disbanding.

    • Lipstick on a pig? Or perhaps this refers to the usual necessary touch ups one needs when presenting oneself at the political curbside so-to-speak to advertise oneself as a very accommodating date for the right price – an activity the EPA seems to have mastered.

  1. Amazon, here I come. This will be a page turner for this reading-glassed, nerdy, red-headed leprechaun.

  2. My small company was told by the EPA that because we were so small, we would have to give them $500,000 up front, so that they would have the money to pay our future fines. Fines we don’t have. For a product that is cleaner than competing products made by larger firms, who don’t have to pay the up front charge. For a product that produces only 1.3 pounds of NOx pollution over its entire lifetime. Insanity in the guise of ideology in the role of authoritarianism.

    • A farm near (relatively) my area proudly states that they are NOT certified organic. Apparently they would have to stop using an extremely safe and environmentally friendly spray (arguably the best in each category) in order to be certified – because the spray is dispensed using a device that contains plastic.

      Pesticides that kill all the bugs are acceptable for organic certification, but one that spares beneficial bugs is verboten. Yet another reason I do not take the organic food movement seriously.

    • Doc: Prepay a fine? Or is that a payment for a permit to emit for something other than NOx? HAPs perhaps?

      I know it’s hard to disclose a lot, but your post leaves things out, and wants me knowing more.

  3. Much of the environmental movement was founded in protest against dirt, in water and the air. Now that most of it has been cleaned up, the bureaucrats need to justify their jobs. They have done this by continuing to tighten air quality standards. To justify this they have funded friendly scientists who provide studies generating the correct results to ensure that standards become tighter and tighter, regardless of the weakness of the scientific arguments and the costs to society. It is time for scientifically literate politicians (if there are any) to stop this outrageous impost on people’s standard of living. The air quality problem has been solved and the standard-setting bureaucracy should be disbanded.

    • “The air quality problem has been solved” … written by someone who hasn’t lived in LA for any length of time.

      • I’ve lived in LA for over 60 years, and the problem was solved when catalytic converters were installed a long time ago. I remember smog in the 50’s and 60’s. The air is nothing like that today. I haven’t even heard someone say the word smog out here in decades.

      • Very little of what you see today as “smog” in LA is from human sources. Do you know how the Great Smoky Mountains got their name? Go learn something. (Hint: Not from smoke.)

        There are concepts called “diminishing returns” and “asymptotic behavior”.. Spend X to remove 90% of pollution from urban air. Then, spend 10X more to remove only the next 5%. You could spend 1000X more and not remove the next 2%. But, “Even a single life …”

        “How much is enough, Gordon?”

      • Answering brians356: I know! I know! The “smoke” is caused by the Terpenes and Monoprenes emitted by the trees on hot summer days. What did I win?

    • By “friendly”, I think you mean “compliant”, which basically means “unfriendly to the truth”.

  4. “PM2.5 essentially is that it is the most toxic substance known to man. There is no safe exposure to PM2.5 and any exposure can kill you within hours”

    It’s a Group 1 carcinogen. How can it possibly kill someone in hours? Makes me wonder if this guy knows what he is talking about.

    And carcinogens cause cancer at any concentration. Lower concentrations, lower rates; Higher concentrations, higher rates. Pretty simple, it’s just math.

    • And carcinogens cause cancer at any concentration
      =================
      false. The linear-no-threshold (LNT) model is a false model. At low doses there may be a beneficial cancer preventing effect, similar to what we find with low doses of other toxins. for example: vaccination, allergy treatment, mithridatism.

      Residential Radon Appears to Prevent Lung Cancer
      https://www.ncbi.nlm.nih.gov/pmc/articles/PMC3315166/

      “The proportion B(x) (benefit function) of ANP beneficiaries increases as the average radon level x increases to near the Environmental Protection Agency’s action level of 4 picocuries/L (approximately 150 Bq m−3). As the average level of radon increases to somewhat above the action level, ANP beneficiaries progressively decrease to zero (B(x) decreases to 0), facilitating the occurrence of smoking-related lung cancers as well as those related to other less important risk factors. Thus, residential radon does not appear to cause lung cancer but rather to protect, in an exposure-level-dependent manner, from its induction by other agents (e.g., cigarette-smoke-related carcinogens).

      The linear-no-threshold (LNT) model is widely used for assessing the risk of cancer (including lung cancer) from low-level exposure to ionizing radiation and was initially adopted on the basis of high-dose data for mutation induction being misrepresented as an LNT function of radiation dose (Calabrese 2011). New low-dose data invalidate the LNT model for mutation induction (Ogura et al. 2009; Cuttler 2010). A hormetic relationship was obtained.”

      • In toxicology, carcinogens are assumed LNT until there is evidence to the contrary, you don’t just make it up. What is a published source for a safe threshold for very small particles in the lung?

        However, we are not really talking about thresholds here; the EPA limit is 35 µg/m3. To experience that and more, go to Mainland China where PM2.5 is routinely over 50 µg/m3 and people walk around with masks on. It had to be lowered for the Olympics…at least for a few weeks. In Eugene, Oregon it goes over that occasionally, and you really don’t want to be outside. So a rant about the PM2.5 standard seems silly.

      • So a guy calling himself ‘ReallySkeptical’ believes everything his political masters tell him without question, and when offered evidence that what he’s been spoonfeed isn’t true, simply repeats his assertions while ignoring everything else.

        I honestly couldn’t be less impressed if you stuck your fingers in your ears and screamed ‘The EPA is Always Right!!!’ over and over.

        As to Beijing, have you perhaps noticed that, in addition to the pm2.5, they also have hazardous levels of pm5 and even pm10, not to mention ozone, sulfur and nitrogen oxides, and all the other real pollution that US cities cleaned up decades ago?

        You might want to consider that you are doing skepticism wrong. >¿<

      • That assumption is incorrect. Living things on this rock are electrochemical fuel cells in nature. Successful living things all have mechanisms to eliminate or reduce the threat of chemical poisoning. Below the threshold, which will vary from chemical to chemical and from life-form to life-form, there will be no harm demonstrable, whether short term (aka acute) or longer term (chronic) within the fixed natural life span of said organisms (they all have these, too).

    • There are some pretty dangerous compounds: Perfluoroisobutene – Wikipedia
      https://en.wikipedia.org/wiki/Perfluoroisobutene
      Perfluoroisobutene (PFIB), also known as 1,1,3,3,3-pentafluoro-2-(trifluoromethyl)prop-1-ene, is a fluorocarbon alkene. It is a hydrophobic reactive gas with boiling point at 7 °C. It is a strong electrophile. PFIB is about 10 times as toxic as phosgene. Its inhalation can lead to pulmonary edema, which may be fatal.

      This stuff can cause bloody frothy lungs in some species at less than 0.5 ppm. (I once analyzed 4 liter pressurized gas bombs that were over 80 ppm–carefully).

      • H2S has an LD50 of 30 ppb! in many marine organisms. Essay Shell Games in ebook Vlowing Smoke. Is how the ocean ‘acidification’ deaths of corals was invented by Australian researchers then popularized by Seattle Times. Neither of my written correction requests to Seattle Times, Australian researcher Fabricius, nor Nature elicited any response. Thus does Clisci academic misconduct thrive. Details in essay Shell Games in ebook Blowing Smoke.

    • PM2.5 is not a carcinogen. It is a diameter. Is an inch a carcinogen? How about a parsec?

      A PM2.5 particle has an ‘aerodynamic diameter’: a particle that casts a shadow equal in area to that of a 2.5 micron diameter circle. They are of different shapes, densities and composed of materials from condensed cooking oil to wind blown dust to asbestos fibres. It only refers to a size. There is PM1.0 and PM0.01.

    • Reallyskeptical- You started your quote in mid-sentence (intentionally?). Milloy stated:

      “The EPA’s view of PM2.5 …” then the rest of your quote. He is saying that’s the effect of the way the EPA regulates PM2.5.

      And of course it is not true that carcinogens cause cancer at any concentration. There are thresholds.

      • Worse yet, for people looking for cures, cancer is a complicated syndrome composed of many causes operating on many systems where the pathology is made manifest over a few final common pathways.

    • Really Skeptical,
      I have been reading Steve Milloy’s articles and books for a long time now, and I can assure you that he knows what he is talking about. Before you dismiss him based on someone else’s partial quote, you need to read some of his articles on the subject. I’m sure his new book is a good source as well. The basis for his claim of “can kill you within hours” is based on EPA findings. They have stated that even a few hours exposure to PM2.5 at any level will cause your premature death. No statement of odds or risks. As far as the EPA is concerned, it is a certainty. Then they go on to expose people to it in a sealed room to prove their point. Which means they either don’t believe it, or they are criminals.

      But don’t take my word for it. Do the research. Just keep your eyes (and mind) open.

      • I’m just a little bit confused. If PM2.5 is a measurement of size, what substances were Lisa Jackson talking about. I suspect that there are all sorts of things out there that can erode into such small particles, some might be toxic in quantity, some might not be in quantity, but at what concentration in the atmosphere would be a toxic level of PM2.5 to ever be a problem. I am a geologist who decided working with stone was more to my liking than the oil patch. I spent 40 years surrounded by clouds of stone dust produced by grinders, saw blades, and pneumatic carving hammer and chisels. If I was working with a stone that produced silicate dust or possible asbestos, I’d wear a particle mask, but I seriously doubt they would filter out PM2.5 sized particles. Breathed limestone dust for years and years–all sized particles. 70 years old and retired to the ranch now, but I can assure you–my lungs are very low on the list of physical issues my 40 year career produced.

      • This article is silly because it doesn’t actually describe the form of the 24-hr PM2-5 National Ambient Air Quality Standard(NAAQS). The article focuses on hyperbolic testimony of a political appointee. The fact of the matter is that EPA only appears to tighten up the standard based on all the epidemiology black box nonsense and lower the standard to 35 ug/m^3. Sounds tough, but what they don’t say is that they then at industry lobbyist request make the standard next to impossible to actually violate. The actual form of the standard is (the 98th percentile of the daily average averaged over a 3-year period) can’t exceed 35 ug/m3. So tell me how a probabilistic standard relates to any acute health effects.
        I think I will skip the book.

    • No, he’s merely putting into words the claims made by the EPA. They include as “excess deaths” those that occur as soon as exposure to PMs happens. It is the EPAs usage, not Milloy’s.

      And the PMs are not causing death by cancer.

      And carcinogens do not cause cancer at any concentration.

    • The dying earlier, aka “premature death” to PM2.5 has not been attributed to cancer by the USEPA. It’s from still unquantified response by human biological systems. The primary evidence used to set the standard is based on a relatively small reduction of forced expiratory volume (FEV1).

      There’s a lot we don’t know. Mr. Malloy knows a lot about that.

      Diesel pm which has declared a carcinogen is a related story, but there’s no US standard for that.

  5. It has developed itself into a self-perpetuating rouge agency…

    More like a verde agency (or, merde agency, depending on your viewpoint). Although, with the controlling socialist political climate, rouge agency is probably accurate.

  6. Really Sceptical: Jan 16, 2.49pm
    “PM2.5 essentially is that it is the most toxic substance known to man. There is no safe exposure to PM2.5 and any exposure can kill you within hours”

    The actual passage carries on ” – according to the EPA, that is”. I suspect Steve Milloy DOES know what he’s talking about.

  7. PM2.5 is so small that it tends to get exhaled when it’s inhaled. And no, it’s not just math. Most carcinogens are ineffective below a threshold dosage. That’s why researchers had to feed saccharin to rats at concentrations hundreds of times higher than normal human diet to give rats cancer. [It turned out to be total nonsense: “the effect is seen only in rats, not in mice, hamsters, guinea pigs, or monkeys” http://www.sweetenerbook.com/assets/blogs/Saccharin-and-cancer.pdf%5D It’s never “just math.” Math is what brought us the infamous hockey stick.

    • “PM2.5 is so small that it tends to get exhaled when it’s inhaled.”

      This not so. PM2.5 tends to be caught very efficiently in the upper and middle levels of the respiratory system. The efficiency with which Particulate matter is trapped in the lungs varies greatly with size and it is not at all linear. There are presentations available from NYSERDA showing this. As particles get really (small 10-20 nanometers) they reach the lungs by diffusion and the capture efficiency is very low. Most are breathes out again. See a NYSERDA graph.

      The idea that PM is ‘equitoxic’ is the root of most of the evil associated with the quixotic claims for health impact. Equitoxicity is valuable when painting broad strokes over all premature deaths and entire populations. It has no specific meaning for particles of a certain size. Many pollutants are individually regulated because they are toxic: Cr6 for example.

      The idea that all PM2.5 is equally toxic is baseless and anything calculated on that basis has no medical validity. It is only useful for directing health expenditure at the national level.

      • the cbw division of the us military determined that 3microns (2.5 if it’s gov’t work) is the most efficient size for pulmonary absorption of toxic materials.
        the way you ‘weaponize’ a chemical or biological warfare agent is prepare it so it’s dispersed as this size of particulate.
        i no longer have the documents on this reasearch cuz it was on paper and many years ago…

      • Gnomish

        It should be under 4 microns. 3 would bring the ‘benefit’ of being small enough to go deep and large so as to have a significant payload.

    • PM2.5 is big by conventional standards. These days PM0.02 is all the rage. These nanoparticles (diameter 20 nanometres) are so light they are not weighed. They are counted and the pollution is given in counts. They can pass through the nasal membranes and flesh and move directly into the brain. They can also ride around inside red blood corpuscles. Little is known about their toxic effect. They are produced in vast numbers by burning biomass and diesel engines.

  8. Low doses of PM2.5 may actually protect against higher levels due to Hormesis. By reducing PM2.5, the EPA may actually be harming human health, unless they first identify the Hormesis dose response model.

    The Hormetic Dose-Response Model Is More Common than the Threshold Model in Toxicology
    http://toxsci.oxfordjournals.org/content/71/2/246.full

    “The threshold model has long been used by regulatory agencies such as the FDA and EPA in establishing acceptable exposures to non-carcinogens… The present study, which was designed to assess the capacity of the threshold model to predict responses of doses below apparent toxicological thresholds, demonstrated that not only was the threshold model unable to adequately account for the data, but also that the responses were consistent with the hormetic model.”

    • This really is at cross purposes to quite a bit of recent allergy/immunology study that appears to show that people, and kids in particular, need more dirt, bugs, and exposure when they are very young. It stimulates the immune system, which needs early stimulation or later it goes berserk with asthma, allergies, and other reactions. Did the EPA investigate in any way the effects of small particles on the immune system and its develpment? Reducing pollution below ambient levels might cause more problems than it solves. They should be required to find the relevant research. At least it should be legal. The research into the effects of 2.5P was illegal, unethical, and useless.

    • philohippous
      Indeed what you say is linked to why low dose irradiation is good for health, increasing lifespan and decreasing cancer incidence in mice. Immune stimulation from radiation, linked to heat shock proteins and other pathways, boosts the immune system in a highly repeatable way. It should be standard radiation biology but due to politics it is not.

  9. I don’t want to say that we should look more favorably on particulate pollution, but I DO want to say that to warp the attitude about particulates to somehow demonize CO2 as a … “pollutant” … seems clearly erroneous, especially considering this:

    http://www.co2science.org/education/book/2011/55BenefitsofCO2Pamphlet.pdf

    Also, consider how this so called “CO2 pollutant” operates within the human body in critically important ways.

    Since, the concentration of this gas is nowhere near toxic (any more than the concentration of water on the planet is toxic), continuing to profile CO2 as a “pollutant” is sheer mythology posing as concern for human health.

    • I think we should understand that all living things take in potentially toxic substances in food, water and air. Millions of years of evolution mean that organisms have developed mechanisms to deal with many toxins. To assume that an infinitesimal dose of anything is deadly seems idiotic to me. Humans are relatively long lived, partly because we have good systems for separating and expelling garbage.

      • @JH: “To assume infinitesimal doses of anything is deadly seems idiotic” to me, too. But then, like you probably, I read Wildavsky’s “But Is It True?” — which pretty much exposes the EPA zero-emissions death cult for what it is, “political science” (to coin a phrase).

        Prof. Wildavsky showed that past chemical scares — among them panics over asbestos, dioxin and DDT exposures — were the result of flawed studies, of findings drawn from inconclusive research, and of environmentalists’ drum-beating: Fears of these molecules were grossly inflated, Wildavsky found; he concluded that the old adage still applies — “the dose makes the poison.”

      • Well, Richie, strictly speaking it is the dose and the route of administration. 50mg of morphine taken by mouth may not be enough for you to get enough in the blood stream to have any general analgesic effect. 50 mg injected directly into the intrathecal space may be enough to kill you.

    • To illustrate the beneficial role of CO2 in human physiology, I have spliced together passages from pages 286 and 287, omitting extensive reference citations at the ends of sentences …

      FROM:

      Paul Grossman (1983). Respiration, Stress, and Cardiovascular Function. PSYCHOPHYSIOLOGY, 20:3
      https://www.researchgate.net/profile/Paul_Grossman2/publication/16786982_Respiration_Stress_and_Cardiovascular_Function/links/56bfa0c608ae2f498ef7ff34.pdf
      [downloaded 01/17/2017]

      … more proof that labeling CO2 as a “pollutant” makes about as much sense as labeling H20 or O2 as a “menace” to civilization.

  10. I very much enjoyed this book and did not put it down till done. So much of what should now happen to the EPA under new management (perhaps the first real management they’ve seen in decades) is described clearly in Steve’s book. I highly and unreservedly recommend this. It is the antidote to anything printed, stated or filmed by the usual scoundrels including the Nobel laureate Algoricle who can’t predict his own fragrant emissions.

  11. As with radon etc., we have evolved with PM2.5 and worse. so it seems rouge/vertes do not agree with evolution. Probably think the moon landings were fake too…..nutcases, and some work for Barclays too. that figures.

  12. The UK has The Environment Agency – whose incompetence, waste and toxicity is the stuff of legend – and it has nearly as many staff as the US-EPA.

    go figure

    • I was recently studying UK rivers (by way of relaxation from climate). Then I started reading time and time again about the EA’s refusal to dredge rivers that then flooded – and guess what the EA then had the gall to blame – yep “global warming”.

  13. The United Nations doctrine of Agenda 21 Agenda 2030 regarding “sustainability” fits in beautifully with organisations such as the EPA.
    In my country, in 2004, a Environmental Court appeal, which of which I was the defenant, was ruled against me – causing a great personal expense to myself.

    The government agency here, (the equivalent of the US EPA), bank rolled the complainants, (which is an example of government corruption here), and furthermore the judge in his decision allowed the appeal saying that “he saw no sustainability in this application”.

    I thought this was very strange at the time because the application was to allow 50 hectares of eroding coastline to be restored and reforested.

    Now I know that this was Agenda 21 and the land still remains eroding into the sea and wind parched with no hope of ever regaining its forest.

    Anyway this is a case of an environmental agency gone berserk with the tax payers cash and a green mislead or corrupt judge.

    So I am now a poorer and wiser man – but my message is :- No matter which country you are in you will find Agenda 21 – 2030 and as far as “Green” values, (And I thought restoring a native forest was about as green as one could get), these Agenda do not recognise that at all.

    They are, no doubt, looking at a bigger picture.

    Cheers

    Roger

    http://www.rogerfromnewzealand.wordpress.com

    • In our local nature reserve, they cut down an area of woodland that had been such at least 150 years because it wasn’t “natural”. This is the mentality of the eco-fascist: even nature must be changed to fit in with their views.

  14. You could actually fingerprint the PM2.5 and even smaller particle by analyzing the structure. Depending on the location, natural sources of PM2.5 could be much higher than from man made sources. PM2.5 could be generated from sea spray, it could come from dust storms, forest fires, volcanoes and microbial actions. PM2.5 and smaller particles provide an important natural function one of which is to provide the nucleus for rain drops to form. Without the nucleation actions catalyzed by very small particles, the world could be very humid.

    • But why bother? The correlations are way below anything that should be taken seriously in epidemiology, and there is non known biological mechanisms for PMs to kill us.

      The exposures are also false – the claimed excess deaths may not have actually been exposed to the harmful concentrations. It’s the classic Exposure Fallacy.

      This is all truly utter junk.

  15. Steve Milloy is probably right about most of his facts. Based on the sources of some of his funding, however, it seems possible that some of his opinions are somewhat biased. I won’t link to his Wikipedia page because it seems biased against him. When I googled some stories about Milloy, the results seemed to indicate that he tended to support a corporate agenda. Anyway, I have trouble believing that he is a dispassionate observer. That’s OK. Every side of a controversy deserves to be properly represented. That’s just fundamental justice. We just have to be aware of what’s going on. Caveat emptor.

    • I wouldn’t believe much of what Wikipedia says on a political subject. It has a peculiarly poor editorial policy, under which John Howard, the then Prime Minister of Australia, had his page fraudulently hacked to contain outright falsehoods. The response of Wikipedia? If you don’t like it rewrite it.

    • Sorry, but that’s a bit dumb. Corporations have every right to defend themselves from junk science that threatens their livelihood, and those of their employees and shareholders.

      It’s a big step from that to lying or being biased.

      And unless you have a saint or two with money (which seems a possible contradiction), who are you going to get funds from that doesn’t have – in your eyes – an agenda?

      • Corporations have every right to defend themselves from junk science …

        I think I said that. On the other hand, it is entirely fair to view their defence of themselves as biased. As you point out, they do have a vested interest.

    • Why is funding only evil when it is from corporations. Why isn’t billions of government funding in pursuit of a specific agenda evil as well?

  16. Everyone take a deep breath and read this. There is SO much misinformation about this topic it is worth spending a minute to get some basics. Appeal to authority: I deal with this matter daily.

    Particulate Matter is characterised in groups of sizes. PM2.5 doesn’t mean one size, it means ‘everything smaller than…’ in that case, 2.5 microns. Thus PM10 includes all PM2.5 in the description. PM1.0 is a subset of both.

    A normal life expectancy is ’86 years’. Anyone who dies before that is said to have ‘died prematurely’. It does not mean there was a single cause of death, there may have been multiple contributing factors. A Global Burden of Disease GBD looks at all the people who died in an entire country, born after 1930 (86 years ago) and assigns contributions to all those deaths to more than sixty causes, one of which is exposure to PM2.5. Another is suicide, and car accidents, and choking on a gob stopper, Darwin Award winners and so on. This analysis is for people who are already dead, and all the things that affected the total deceased population since 1930.

    The ‘prematurity’ of a death is measured in months or years before attaining the age of 86. Simple enough. The ‘premature death’ of one or more people can be ‘assigned’ a contributing cause without any one person dying from it. It is a calculated contributing factor. It is a reasonable way to direct public health funding for a whole country. It says nothing about any particular person. It certainly says nothing about a living person who might die in 50 years.

    The article contains at least one error mixing ‘deaths’ with ‘premature deaths’. So please learn the difference and don’t let journalists delete the word ‘premature’ and get away with it.

    Quote:
    “The EPA’s PM2.5 proposal wasn’t particularly interesting except that the agency claimed its regulation of PM2.5 would save 20,000 lives per year, or in EPA parlance, prevent 20,000 premature deaths. Who knew that outdoor air in America was killing anyone, let alone due to something called PM2.5, which is both a naturally occurring and manmade substance?””

    See the switcheroo? It will not ‘save 20,000 lives’ at all. It will remove what is considered to be a contributing cause of 20,000 premature deaths, ie the shortening of 20,000 lives, not the ’cause of death’ of 20,000 people. Completely different!

    So how much shorter are these lives? Could be a month. Could be five years. It depends on many confounding factors like inoculation history, nutrition, access to clean water, gender, age of first exposure and so on.

    The fact is there is little data available anywhere in the world on specific health outcomes from inhaling PM2.5. These shortened lives – premature deaths – are modeled. Expert medical teams are consulted and the GBD allocated by committee.

    Readers may recall the claim that the Nanticoke coal fired power station in Ontario ’caused 1600 deaths’ in Toronto each year. Someone replied, ‘show me the bodies.’ The claim actually was ‘contributes to the premature death of 1600 people per year’. But that’s all. How much, they didn’t say. Maybe it was a week each.

    Thus for statistical purposes, everyone who dies of any cause before the age of 86 is said to have died prematurely and the list of statistically contributing causes, including suicide and car accidents and murder and blood poisoning extends to more than 60 ’causes’.

    A contributing cause of a premature death is not a cause of death. Further, no one know what influence a reduction in PM2.5 will have on today’s population because they haven’t died yet. ALL claims to specific health outcomes for particular diseases like upper respiratory tract infection URTI or lung cancer resulting from a change in the chemical profile of the PM2.5 have to make so many assumptions that the ‘deaths’ predicted have been described by experts as ‘killing by assumptions’. You can’t predict the shortening of future lives because we don’t know what future exposure those people will experience. We can only make guesses about past lives. Who can prove the health outcome difference caused by removing all exposure to PM2.5 from a village person born in 1930, starting in 1945?

    You think that’s difficult? Try predicting the health outcome for someone born in 1990 exposed to 90% less PM2.5 from 2015 onwards and who passes away at the age of 80 following a stroke. How much of the 6 missing years was attributable to the PM2.5 exposure between 1990 and 2015? 4%? Make your own guess. Maybe by then the life expectancy will have increased to 99 throwing off all predictions.

    Add to that ‘equitoxicity’ and zero threshold ideas and you soon have Feynman’s elephant’s wiggling trunk.

    • Even contributing authors for articles available via the World Bank don’t get it quite right:

      “Air pollution is recognized today as a major health risk. Exposure to air pollution, both ambient and household, increases a person’s risk of contracting a disease such as lung cancer, stroke, heart disease, and chronic bronchitis. According to the latest available estimates, in 2013, 5.5 million premature deaths worldwide, or 1 in every 10 total deaths, were attributable to air pollution.”

      https://alankandel.scienceblog.com/2017/01/15/though-an-intensifying-global-bad-air-problem-not-all-doom-and-gloom-world-bank-report-shows/

      They were not ‘attributable to air pollution’. Air pollution was a contributing factor in the premature death of 1 in 10 people. And not the premature deaths of the other 9.

      “Air pollution has posed a significant health risk since the early 1990s, the earliest period for which global estimates of exposure and health effects are available.”

      Estimates. Killing by assumptions. But the population cohort for which the estimates were made were born between 1930 and 2015. Even where medical investigations have been made relating some form of air pollution to specific diseases cannot be translated across the whole world because there are more than sixty other confounding factors.

      Are you getting the picture? Premature deaths are assigned by statisticians based on past events. Totally shutting off exposure to all PM2.5 will not have a predictable future outcome even though there is likely to be benefit for everyone.

      We can confidently say, ‘Reducing all types of air pollution is a good thing, based on what we know about the past.’

    • Here is something from another article that demonstrates the problem:

      “According to the latest available estimates, in 2013, 5.5 million premature deaths worldwide, or 1 in every 10 total deaths, were attributable to air pollution.”

      No, not one in ten are attributable! It means air pollution (not just PM2.5) contributed to the one tenth of premature deaths, not that it ’caused their deaths’. And nothing was contributed to the other nine out of ten premature deaths.

      “Air pollution has posed a significant health risk since the early 1990s, the earliest period for which global estimates of exposure and health effects are available.”

      Not before that? Bunk. LA smog, London smog…

      And that risk is based on the GBD as spread over all deaths of people born after 1930, including WWII. Data only from 1990. Now you see how much must be assumed to get these numbers.

      Be vigilant. These are examples of completely misrepresented number created for limited purposes in the field of health policy. They are not used in body counts and death certificates.

      I know a lady who smoked well into her 90’s. She died post-maturely. Was that caused by smoking cigarettes?

      • And yet, the way the EPA wishes it’s statements to be read is that “contributing to premature death” is equivalent to “causing death”.

        The correct response when confronted with a scary claim such as “contributing to premature death”, is with questions such as:
        – contributing how?
        – contributing how much?
        – how premature?
        – how much did the victim’s quality of life suffer as a result of this exposure?

        Finally, you need to have a sense of proportion. These are tiny particles at tiny concentrations. People breathing them in can’t even sense them. They are present in just as large a concentration naturaly, as man-made. Is it really reasonable to be beggaring ourselves to control something that is naturally occurring?

      • Read the description of the area around Ironbridge as being like Dante’s description of hell with the red glow of the furnaces and the constant pall of smoke. Considerably earlier than London smog. I was totally outclassed by a historian friend who pointed out that this was even worse and easily provable so in the iron age when there were almost non stop charcoal furnaces going to the extent that many of the tools show the pollution levels would be way off the legal scale now.

      • Crispin –

        My understanding of the PM2,5 issue is that the attribution comes neither from directly observable medical effects, nor from counting ‘premature’ deaths, but rather from the linking of EXCESS deaths co-incident with an exposure to particulates – for example, living near a set of traffic lights on a busy road, or during a ‘smog inversion’. (This might be the origin of the ‘any exposure can kill you within hours’ quote). It’s a particular branch of epidemiology which is much questioned, but I think most people accept it has some validity.

        There’s work to do but my inclination is to accept it, in the absence of contrary evidence. It’s regarded as very important in Europe because the big issue is now about particulates (and also nitrogen oxides) emitted by the diesel cars that we have been bullied into buying because of the fear of the greater CO2 emission from petrol(gasoline) equivalents.

        As to the LNT approach, I’m unable to give an informed opinion but I do note that as we get cleaner and cleaner air, we become less and less tolerant of the smaller pollutions which remain (and even, perhaps, imaginary pollutions). Most people have no way to assess this – to them pollution is pollution.

        As far as the book goes, it does sound a bit too much like a polemic rather than a discussion. A good way for an author to reap sales, I think. So I am unlikely to buy it. I did read ‘Silent Spring’ as a young lad, and for many years it had a large effect on me. If I knew then what I know now….

      • Hivemind you have it exactly correct.

        Dave Cage, the city of Ulaanbaatar, much studied and many interventions made, had PM2.5 numbers over 5000 from time to time. The cause was incomplete combustion of coal, and the cure is the complete combustion of coal – not replacing it with something else. There is nothing else and it is -35C outside. Modern air quality is fabulous compared with what people lived through before.

        mothcatcher, these two are not related. Excess deaths refers to noting a statistically different number of actual deaths ‘because of something’ compared with a smooth continuum of deaths in the presence or absence of that ‘something’.

        The Global Burden of Disease (GBD) is the key to making claims of ‘attribution’. It is a claim, it is not necessarily real, that is why it is an ‘attribution’ not a ’cause’. The committee attributes 4% of this and 3% of that to the ‘death’. The death is real. The attribution is opinion.

        Now, is all attribution avoidable? Can we generate ‘avoidance’ based on ‘attribution’? Logically, no. The attribution was in the first place an educated and carefully made guess. It was not a cause because we don’t know the cause of all deaths in India, for example, and all the contributing factors since 1930. Even if we did, we know nothing about the future contributions to the death of people born yesterday. You catch my drift? You can’t know something for which you only have ‘general description’ which is why GBD number attribute multiple contributions to deaths on a national basis – called a cohort. You could infer and attribute contributions for a cohort smaller than the whole population if you have a lot of relevant data. Asbestos is a pretty good example. The people exposed to it were studied in great detail, and carefully considered safety measures have been legislated. There is no such study available from ‘PM2.5’ because it has thousands of sources, and the complete control of it is impossible.

        Look at how hollow the claims are: PM2.5 could be any of thousands of ‘species’. Literally anything that is not a gas: sunflower oil, black carbon, condensed sea water, coffee, bacon splatter… The only thing to be done is to assume equitoxicity for all of them then attribute PM2.5 as a class of materials to the total number of deaths based on a few indicative measurements made here and there. What does this tell you about the dangers posed by coal combustion in Ulaanbaatar and the direct medical consequences? A lot of people smoke there. Indoor household air pollution (HAP) is far higher than outside because of the cigarettes. It is just harder to see. So you can go to the clinics in Ulaanbaatar and check who comes in with what. That is sound. But you cannot use GBD attributions to claim that those appearing in the clinic were sickened by PM2.5 from coal smoke. That is jumping the shark. GBD numbers, upon which the ‘premature deaths’ numbers are entirely based, do not make any specific medical claims!

        There is a reasonably analogy with vehicles. Suppose you test all vehicles and fuel consumptions and come up with an equitoxic equivalent of a ‘national fuel consumption per vehicle’ covering everything from 18-wheelers and golf carts. That is a ‘real number’. Now, you go to buy a car. You ask the dealer what the fuel consumption is. He replies: the EPA says we are allowed to claim it is [national average]. Would you accept that as a rational answer? No, it is irrational to make such a claim. Similarly PM2.5 health impact claims are similarly illogical. The car uses fuel, no doubt. The PM2.5 is real, no doubt, but even claiming premature deaths because if it is already to be on a slippery slope. To claim it is the cause of 1 in 10 deaths is obviously untrue. Maybe ‘blatant misrepresentation’ is a more appropriate term.

    • You have also to consider trade-offs. For instance, Beijing has wicked pollution but its citizens live longer than most other Chinese. link

      It would be a rational decision for people living in Tibet to move to Beijing. They would be expected to live more than ten years longer in spite of the pollution.

      The caption on my favourite cartoon is as follows:

      Something’s just not right, our air is clean, our water is pure, we all get plenty of exercise, everything we eat is organic and free-range, and yet nobody lives past thirty. link

      As you point out, it is a bad error to consider only one thing to the exclusion of everything else.

      • The ‘pollution’ in Beijing is not nearly as bad as in many other places and I am not sure why media like the BBC choose to misrepresent it so often. There was a picture of a city in Shangong prov used, instead of one of the usual carefully selected Beijing pictures. The WHO ambient air quality numbers (targets 1, 2 and 3) are literally cooked up and no one knows what the influence of low levels of PM2.5 exposure will do to health.

        Reality check: Beijing is in the middle, sort of, of a low, flat, wet plain. Look at a map. It is barely 100 yards above sea level. It is a foggy place and surrounded by mountains on two sides (North and West). The annual average PM2.5 level is a tiny fraction (<1/10th) of the levels in other lesser known cities in the world. So what is up with the continuous references to what the air quality used to be like in Beijing? It is obvious there is another agenda. The media present Beijing as a poster child (meaning exploitable natural resource) for prosecuting the war on coal. Coal is almost universally vilified as a ‘dirty smoky fuel’. It is claimed that burning it creates ‘smoke’ with no explanation of what ‘smoke’ is (it is unburned fuel).

        So the two go together: pictures of smog, wherever it is from, are taken and filed to pull out on bright sunny days when it is time to piss into the coal pile. I go to Beijing frequently and have for several years. It is often cloudy, foggy, smoggy and sunny – just like other big cities (except it is really big). The ‘worst days’ are when the farmers in Hebei province, which surrounds the province of Beijing, burn their crop wastes creating 3 or 4 days of really bad air, depending on the wind speed and direction. It makes for impressive brownish photos which if taken in the morning, have the fog added. That is not from ‘burning coal’ it is from burning good ‘ol renewable biomass. Badly. If you burn coal or biomass properly there is no smoke at all – zero. Now what? The excuse, the villain, is gone without a puff of smoke, and we are left to look for the actual problems and actual solutions.

        It is frequently foggy in Beijing in the morning because it is a humid place and the temperature drops at night. Big surprise, right? I believe this is known to happen in SF and LA. Go to LA and take a photo of a foggy morning with the sun barely poking through and post it on the internet labelled, “typical LA smog produced by burning coal ‘. People will believe it. Oh wait, for LA it is charcoal combustion. Yeah, that’s right. More than half the PM2.5 I LA is from restaurants cooking with charcoal. So post the photo and blame the fog on restaurants, then call for all of them to be shut down to save ‘thousands of people from a premature death’. From fog.

        When the media are themselves transformed into unelected political actors, you could say, ‘bought’ – literally, it takes more effort to get to the truth of any matter.

      • Crispin in Waterloo January 17, 2017 at 10:39 am

        The ‘pollution’ in Beijing is not nearly as bad as in many other places …

        That may be true. On the other hand, my family China expert (fluent Mandarin, lives half time in Henan) says its bad. He tells of having been in a taxi where the driver had to creep along because he could hardly see beyond the hood.

    • everyone who dies of any cause before the age of 86 is said to have died prematurely
      =====================
      so what is causing people to live past 86? Is it exposure to PM2.5? What is the magic ingredient in the environment causing some people to live longer?

      Next we will be hearing that people that are shorter than average have stopped growing prematurely due to exposure to premature shortness.

      The problem of course isn’t anything to do with toxins, it is due to averages. People live longer and shorter lives for the same reason some people are shorter and some are taller than the average because that is the nature of averages.

      • If we were to ban all causes of “premature death” without regard for the costs of that ban or the benefits of the “threat” then we need to close down all highways immediately.

      • ferdberple

        Well by definition half of the people live past 86 and half don’t in any country where 86 is the average. So taking what one country achieves supposedly predicts what all other people should mirror. All those who live longer than 86 years died post-maturely, even if that is ‘not yet’.

        They do not look for reasons why people live longer, only shorter. When you are 100 they ask you, What is the secret to a long life? People answer, whiskey, smoking the right cigars, screwing around, fasting, running when they were a teenager – anything at all because no one knows.

        The problem is with ‘risks’. Stress and lack of meditation are probably major contributors to shortening a life. People who marry live longer, as do people who never have sex, but I repeat myself.

        When I was young, I thought 65 was ancient – people retired at that age! They dropped dead after a few years. 75 was ancient.

        I went to see a house for sale and the fully copasetic white-haired 82-year old said, look around, if you need me I will be in the livingroom with my mother! Dang! She was, too, correction, 103.

        Nix on the ‘averages’ explanation. People are the cause of averages, not the result of them.

        George Daddis:
        If we were to ban the attributed causes of all premature death we would have to stop living. Who would want to live in a world without any risks? You couldn’t eat because eating carries with it a risk of poisoning and choking. You couldn’t take a dump because of the real risk of a rat swimming up the sewer and jumping up to bite your ass with infected incisors.

        At the moment, the GBD people have us all dying of attributed causes. Real causes are so ‘individual’, downright narcissistic. How dare you die of something rare and specific? Get with the program.

        There is something called the Household Air Pollution Intervention Tool, HAPIT. It turns random thoughts into money. The first four words sound like sealer for a leaky window. I believe the last word refers to the person who created it.

    • Also elided over is that life expectancy is itself a statistical artifact. I don’t have an actual life expectancy. I have a life span. I am now in my 59th year of life span (begins at conception, aka the instant when my dad’s sperm’s nucleus combines with my mom’s egg’s nucleus). I also live one hour at a time. Irreversible cessation of metabolism is the death of the body. It will come at any hour from now to 61 years from now.

    • You mention talcum powder—that has netted women millions by tying it to ovarian cancer. Observation is anything can cause cancer and anything can be very lucrative if it kills you or otherwise annoys you.

      • The talcum -> ovarian cancer doesn’t pass the sniff test. Got a rebuttal reference? I’d love to read it.

      • brian356: I just said it netted women millions, not that I agreed. I believe we have little to no idea what causes cancer and the only use for the studies is to win personal injury lawsuits and scare people.

        This is the one “explanation” I found: “It has been suggested that talcum powder might cause cancer in the ovaries if the powder particles (applied to the genital area or on sanitary napkins, diaphragms, or condoms) were to travel through the vagina, uterus, and fallopian tubes to the ovary.”
        This is from http://www.cancer.org/cancer/cancercauses/othercarcinogens/athome/talcum-powder-and-cancer.
        It was reported that in the 70’s that talcum powder was found in ovarian tumors. I cannot verify this through any actual study, just statements by attorneys and bloggers. Also, early talcum powder had some asbestos—another money maker for personal injury lawyers.

        (If Anthony finds my opinions offensive, so be it. My parent died of lung cancer, too.)

      • Sheri, it occurred to me you might mistake my question as a challenge. Just the opposite, I’m right alongside you, asking questions and raising eyebrows. The theory doesn’t pass the sniff test, not yourself, the ‘umble narrator!

  17. If something reduces a life by 1second, it causes a premature death. By the EPA’s calculation as it appears to be written, if that caused 3,600 deaths a year, the cost of these total of 1hour of human life would be $32billion.

    Now go ask a dying person whether they would accept dying an hour early in return for $32billion for their heirs.

    • Scottish

      You are on the right track. They calculate lost life years, and disability adjusted lie years (DALYs). A DALY is a year living with a disability caused by the medical condition. These numbers are cooked up. They have a vague use for creating health policy. A large number attributed to a particular cause will influence mitigating expenditure. It is reasonable as long as the extrapolations are not taken too far.

      • DALY Disability Adjusted Life Year (one year at the end of life spent in a disabled condition)
        aDALY avoided DALY (people died but not in a disabled condition).

        DALYs are not measured and reported, they are generated based on epidemiological studies and opinions fashionable at the time.

  18. “Milloy documents the use of human subjects, both young and old, in gas chamber experiments funded by the EPA at the University of North Carolina, the University of Michigan, the University of Washington, the University of Rochester, the University of Southern California and Rutgers University.”

    I find that deeply chilling.

  19. I was a child in the era of the London smogs of the 1950’s and was quite active in the clean air movement. I felt it had achieved all that was needed by about 1960’s with smokeless zones and the introduction of electrostatic precipitators in power stations. The additions of suphur scrubbers to cure acid rain was still in the region of desirable if a slight luxury and in hindsight not as necessary as claimed. CO2 was wrong from the word go as no one knew for certain if the temperature changes were cause or effect anyway.
    The fact the temperature system is inherently stable means the distinct probability is that CO2 is the result of temperature not the cause of it. The belief in a tipping point suggests climate science does not include adequate training in feedback systems.
    If science is to become trustworthy again any grant for any premise must have a minimum of one tenth of that to disprove it. Every doubt cast should make a greater funding for the dissident and a reduction for the proponent. That way there is no fine for integrity as at present.

  20. Steve Goddard has been promoting this for some time, so I checked its claims out…

    The author is basically in denial that PM 2.5 is causing any health problems. He has only to look at China – I know he sort of did, but the Chinese stats on the huge number of deaths were kept secret until very recently.

    This book I’m afraid is deeply wrong about how pollution affects human health.

    • Total nonsense. it’s not small PM that is causing problem in China, as we all know.

      If you were actually interested in facts and actually checked the claims out, you would do some research and see that there is no known biological mechanism for damage, let alone death, that the relative risks are far below what would be accepted for such studies normally, and that the exposures that people are supposed to be dying from cannot be shown to have actually taken place.

      If you had any further interest, you would see that a number of studies have serious methodological flaws, including a recent one that needed reported exposures to shift the figures from a negative relative risk (i.e. PMs make you more healthy) to the desired tiny positive relative risk.

      But of course expecting all of that is too much.

    • If PM2.5 kill human, they surely kill rodents as well. Very easy and quite cheap to test. Much cheaper than gazing humans. And much more reliable proof than messy statistics out of China.

      Many pollens are PM10, while the biggest bacteria are PM2. Most people, including greenies and Griff, would find it mad to make rules against plants and bacteria, so PM2.5 are just “fine” for EPA to don’t appear nuts.

      • The EPA was going to set an even lower PM2.5 level than exists now, but it would have banned farming. No kidding. Ploughing makes a lot of PM2.5. Fortunately even the EPA is aware that it is pointless knowing which side of your bread is buttered if there is no butter.

    • Griff: IF China had only PM of 2.5 and no other factors, your belief might in some way make sense. However, China is the poster child for pollution run-amok. It has no place in a discussion of “low” pollution levels. And, yet, there you toss it.

      How things affect human health is a huge, chaotic system that we have little knowledge of the interactions therein. Current “effects” are political or legally lucrative. If tomorrow it was proven that pure water was a carcinogen, that research would be buried and the study authors fired. It’s all about what one WANTS to be true, not was is true.

  21. Crispen and others here are dead on with the analysis of the EPA’s shenanigans. To add my two cents…

    The EPA’s PM 2.5 program is following the pattern established when the EPA decided to make Radon a hazard. Their initial cut at Radon called for 0 to 5,000 deaths/year. This did not grab the public’s attention so they revised their calculations using a most dubious method of calculation. The new calculation called for 10,000 deaths/year and the original range of 0-5000 disappeared from their pronouncements. Note in the original calculation that zero deaths were in the range. Lo and behold, the10K deaths pronouncements did not seem to grab the public’s attention, so they started pronouncing there were 20K deaths/year – without any supporting documentation or calculations! I looked hard for any supporting documentation for the 20K claim and found none. However, the 20K grabbed the public’s attention and the EPA’s Radon Program grew exponentially. Notice the similarity of the PM 2.5 number of projected deaths to the Radon Program’s 20K? Amazing! Magic! Necromancy!

    With the exception of the so-called Health Physicists working in EPA sponsored radon programs, not a single Health Physicist whom I know (about 300-400) believes that the EPA’s Radon regulations have any validity. Health Physicists are THE experts at radiation effects and radiation safety. The EPA refused to listen to us and we could not get our voice out to the public. So when you sell your home and have to pay the Radon testing fee, remember the above and be angry. If you want to know how to cheat the test ( + or – ) it is really, really easy. To get a low Radon count, simply cover the measuring device’s opening. To get a high Radon count, find an old Radium dial hand (just one) and place it in the device’s opening for no longer than 15 minutes – this will typically give near a 20 pCi/L reading. Think the folks selling testing and mitigation haven’t figured out the latter cheating technique?

    • aGrimm

      Perfect! What a great story. I just read that exposure to a small amount of radon gas is health-protective. The same as to a small amount of ionising radiation (multiple studies). The poison is in the dose.

      • Crispin: the thing that is lost to the public, and the EPA, when discussing low dose assault on a biological entity is that biological entity’s amazing ability to respond. We are assaulted by radiological, chemical, mechanical and biological attacks every second of our life. To exemplify by drawing on my rad knowledge, it is clear that any radiation interaction causes a change – for example: molecular ionization or molecular excitation. However at low doses most of the changes have no long term effect. For example a water molecule in the body can be ionized into H+ and OH- via radiation interaction. The better percentage of the time, these ions get back together and reform the water molecule. No harm, no foul. But if a DNA chemical bond is broken, then the organism has to find a way to repair or eliminate the error. At low doses the assaults are relatively far apart and the organism’s repair mechanisms can handle these assaults. If the damage is too great, typically the organism will remove the cell and replace it with another. Present health physics thinking is that low doses of radiation will more than often have a beneficial effect is because the organism’s repair mechanisms are exercised in the process and thereby better able to respond to the next assault. An imperfect analogy, but one most folks can grasp, is the body’s response to exercise. Exercise creates lactic acid in a cell. It is harmful in large quantities. The cell’s response to rid itself of lactic acid improves with further exercise. We all know that exercise is good for us, but how many know that it would kill us if the cells did not “exercise” their repair mechanisms? I believe the recent reversal of dietary advice on peanut butter is another example of where the so-called experts lost sight of the body’s amazing ability to respond to toxins. If you haven’t seen the reversal, the experts are now saying that children should be introduced to peanut butter at an early age to help develop a resistance to peanut allergies.

        It is a conundrum when an entire population may statistically benefit from low dose assaults, but a single individual may succumb to the assault. It becomes a question of where do we draw the line. My attitude is that life is a crap-shoot anyway, so I go with the best odds in my favor. If my odds of a longer life are improved with a little bit of radiation, I say go for it!

  22. Government should be an impartial arbitrator. The EPA does not fail at this – it is the opposite of this. It makes up its own science, its own rules for its own conduct, and it irresistibly enforces the regulations upon regulations that it makes while ignoring the law. So, what’s not to like?

  23. A basic rule of thumb is that phrases like “…prevent 20,000 premature deaths” are probably used to disguise a very small risk as expressed through the key epidemiological concept of relative risk (RR) or variants. A tiny RR can be made so much more dramatic when the population at risk is large by turning it into an expected value (often incorrectly as well). RR itself reflects the fact that the claim “Epidemiologic results are essentially correlations” has not been true since the early 1970s and the models of DRCox.

    • Since we really have no idea how long someone would live, “premature deaths” is nonsensical. If the particulate matter is non-existent and you get hit by a bus, you’re still dead and that is the full length of your lifetime. Nothing “premature” about it. In some places, dying at 40 is not “premature”. The love of statistics and their wonderful ability to prove everything and nothing all at the same time.

      What are epidemiologic results based on?

      • Sheri

        By definition, dying before 86 (the average life expectancy in a highly develop nation – which does not include the USA) is ‘premature’. That is what the definition of ‘premature’ is.

        When someone is hit by a bus and dies, their death is spread as a ‘Risk’ over all the other people who died for any reason. Taken as total population, we all are exposed to a small risk of dying by being hit by a bus. It is a lot like spreading bets over a lot of gamblers, but of course someone always wins the jackpot.

      • Crispin: This from the CDC (https://www.cdc.gov/mmwr/preview/mmwrhtml/00001773.htm) makes it sound a bit more complicated. If we use the average age of Americans at death, it’s 78, higher for women, lower for men according to the World Bank graph that comes up on Google. We then have to ask what is included in that statistic—if you live to 65, how much longer are you likely to live? Are childhood and infant death included? I note you reported the US is not included in the 86 year value—interesting.

        If we use 78 as the goal so to speak, my mother and father both had premature deaths, as did my aunt, my uncle and my grandmother. That’s a remarkable percentage of relatives who died prematurely. I understand you’re just giving me the number—I’m not disagreeing that this is one of the statistical values used. It’s just that it makes no sense whatsoever in reality. Throw in the attempted determination of how much particulate matter was involved over that 78 or 86 years and you’re in the realm of fantasy in determining premature deaths.

  24. Error in this text:

    “Never mind that the $90 billion in costs were imaginary in nature while the $11 billion costs were actual in nature.”

    Should be:

    Never mind that the $90 billion in benefits were imaginary in nature while the $11 billion costs were actual in nature.”

  25. Charles G. Battig,

    Thanks for the introduction to Steve Milloy’s book “Scare Pollution: Why and How to Fix the EPA” (2016) Bench Press .

    I’ll secure, read, and add this to my reference collection soon!

  26. If you want to see strong critiques of the studies that purport to show harm from PM2.5, go to Matt Briggs’ website:

    wmbriggs.com

    and type “PM2.5” into the site search window.

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