My name is Thom Golab, and I serve as president of the American Council on Science and Health. Particulate air pollution has been one of our topics of concern over the years.

In building a republic, not a democracy, the Founding Fathers asked people to give their elected representatives the authority to speak on their political behalf. That’s what we do when we elect a member of Congress.

One of the cornerstones of the republic is the idea that the government must always be accountable to the people. Citizens need to know the actions of their representatives, the use of their tax dollars, and how the government handles various issues. This prevents politicians from abusing their power or misusing taxes since the people can always hold their leaders accountable. In short, Americans quickly decided that sunshine and transparency were necessary to guarantee good government.

These same rules must apply to the unelected bureaucracy that Congress has entrusted in handling our interests. But as the bureaucracy has grown, it has become more powerful, overshadowing the very laws Congress established for the various agencies. And they have become less transparent to both Congress and the public. To address this, in 2009, the Department of Justice’s Office of Information Policy issued FOIA Guidelines requiring all agencies to reaffirm the government’s “commitment to accountability and transparency.” Among other things, the Guidelines stressed the importance of proactive disclosures and timely responses to FOIA requests. Agencies were also instructed to take steps, including the greater use of digital technology, to ensure an effective system for responding to requests. The Guidelines also emphasized that FOIA is everyone’s responsibility and highlighted the key roles played by FOIA professionals and agency Chief FOIA Officers, who must report each year to the Department of Justice.

In May 2020, as directed by President Trump’s Executive Order, the U.S. Environmental Protection Agency (EPA) announced its first-ever proposed rule to establish consistent requirements and procedures for issuing guidance documents.

President Biden’s chief science officer touted the need for transparency

“By making research publications, study data, analytical software and code, and study protocols more readily available for inspection and reuse as Federal science agencies are currently doing.”

But the Biden administration has made known that under its leadership, the “Transparency Rule” would not be followed.

This is a disgrace—a disgrace to America, to the Constitution, and the People.

The EPA bureaucracy has avoided transparency at all stages, be it taxpayer-funded research or the use of this research to create onerous and very often unnecessary regulations. They have avoided “Obama-era” FOIA guidelines by hiding taxpayer-funded research at universities (who are not bound by FOIA requests) and through a non-governmental Health Effects Institute, which serves as a conduit for taxpayer-funded research and is not accountable to Congress or taxpayers.

The EPA bureaucracy has avoided independent voices and skeptics. And now we are before CASAC, which is composed primarily of academics from the research sector who are heavily funded and therefore indebted by the bureaucracy this committee was created to oversee.

Now, as to the matter of tightening the regulations surrounding particulate matter and ambient air quality, as described in the Ozone National Ambient Air Quality Standards (NAAQS)

Rule Summary

On December 23, 2020, the EPA reviewed the full body of currently available scientific evidence and exposure/risk information and decided to retain the existing ozone NAAQS. EPA’s decision is based on its judgment that the current NAAQS protect public health with an adequate margin of safety, including the health of at-risk populations, and protect the public welfare from adverse effects. The existing primary and secondary standards, established in 2015, are 0.070 parts per million (ppm), as the fourth-highest daily maximum 8-hour concentration, averaged across three consecutive years.

Particulate Matter (PM2.5) Trends

Using a nationwide network of monitoring sites, EPA has developed ambient air quality trends for particle pollution, also called Particulate Matter (PM). PM2.5 describes fine inhalable particles, with diameters that are generally 2.5 micrometers and smaller. Under the Clean Air Act, the EPA sets and reviews national air quality standards for PM. Air quality monitors measure concentrations of PM throughout the country. EPA, state, tribal and local agencies use that data to ensure that PM in the air is at levels that protect public health and the environment.

Nationally, average PM2.5 concentrations have decreased over the years, and the nation is on track for continued improvement of the clean air that we already enjoy.

The only locations in the entire nation with potentially questionable PM2.5 levels are in Southern California, impacted by vehicular emissions and far from heavy industry. Improving that situation would require a detailed investigation of specific PM components and their sources. A purely bureaucratic response from Washington will not do the job. Efficient regulation requires local solutions.

 

 

 

 

I have three main scientific issues:

1. If, as many taxpayer-funded researchers claim, diseases caused by ozone and PM2.5 are on the rise, yet the EPA’s measurements of ozone and PM2.5 show there to be a drop in ozone and PM2.5; then clearly, these diseases can’t be caused by ozone and PM2.5. The data show there to be an inverse relationship.
2. If the EPA’s measurements of ozone and PM2.5 show them to be falling (and NASA’s satellite images corroborate these measurements), then the regulations are working, and we should continue to let the existing regulations continue to do their job. It makes no sense to waste taxpayer funds on studies linking certain diseases to ozone and PM2.5.
3. Regulations intended to protect public health depend on accurate measures of human exposure, but we spend up to 90% of our lives indoors and even more for the most vulnerable among us, notably infants and the frail elderly. EPA has an office for indoor air quality; it seems disconnected from the EPA epidemiologists and rule-makers. Indoor PM2.5 includes cigarette smoke, cooking fumes, pet dander, household dust, but only a fraction of the outdoor air pollution that infiltrates indoors. While outdoor PM2.5 levels tend to be relatively uniform (except near traffic), this is far from the case within the residences in the areas covered by outdoor monitoring. This situation not only threatens public health, but it invalidates all of the outdoor epidemiological studies on which EPA rulemaking has been based.          

We believe the CASAC would be well advised to focus on the adequacy of EPA research that may affect us all rather than tweaking regulations based upon purely local concerns.

To request to speak at the February 25th CASAC meeting, please email Aaron Yeow at the EPA.  Here’s his email: [email protected]

CASAC page: Meeting | US EPA
Federal Register Notice: 2022-00110.pdf (govinfo.gov)

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(Photo: iStock)

Last year my husband and I started transitioning our home off of fossil fuels, with the goal of making our home net zero. We got a heat pump to heat and cool our home, we replaced our gas water heater with a heat pump water heater, and we installed solar panels. Now the only thing in our home using gas is our *flaming* stove. And it’s really starting to give us gas pains.

Not only is it polluting our indoor air, but it’s polluting the environment. And with two little girls who love to “help” us cook, we’re constantly worried about tiny fingers getting burned.

We’re now shopping for an induction stove—the most environmentally conscious, efficient, and dare I say, coolest way to cook. Here’s everything you need to know about why we’re firing our gas stove and switching to induction.

Why we need to ease off the gas

The gas industry has pumped a lot of money into convincing us that gas stoves are the superior way to cook. But the more we learn about the health and environmental impacts of natural gas, the less “natural” it seems.

So-called natural gas is mainly methane—a potent greenhouse gas that has 84 to 86 times the global warming potential of CO2 over a 20-year period. Oil and gas facilities are responsible for nearly 44 percent of Canada’s methane emissions and 26 percent of the country’s GHG emissions.

“I think something people overlook is where this natural gas is coming from,” says Dr. Melissa Lem, president-elect of the Canadian Association of Physicians for the Environment.

Most of Canada’s natural gas is mined in northern B.C. through a process called hydraulic fracturing, or “fracking.” A well is drilled down to rock formations where natural gas deposits are, and a slurry of chemicals, water and sand is blasted in, fracturing the rock. Some of the toxic soup stays underground, and some returns to the surface, where it’s stored in open frac ponds. One fracking well can use and pollute more than 10 million litres of fresh water—most of which is permanently removed from the water cycle. Not to mention contaminating the air and soil. With more than 20,000 fracking wells in B.C., the damage is mind boggling.

“It’s a highly polluting process that’s destroying farmland, using up huge amounts of clean water, and exposing farmers, families, and Indigenous peoples to high levels of pollutants in northern B.C.,” says Lem.

And once natural gas is piped to our homes, it continues to pollute. In 2018, natural gas was responsible for 36.7 megatons of residential CO2-equivalent emissions.

Are gas stoves bad for the climate?

Every time you turn on a burner or heat up your oven, your gas range produces carbon dioxide. It’s estimated that gas stoves in the U.S. emit 6.8 million tons of CO2 each year—the climate impact of 1,889,915 gas-powered cars. Natural Resources Canada estimates that in 2018, gas stoves in Canada emitted 370,000 tonnes of CO2.

Gas stoves also emit unburned methane, through leaks and incomplete combustion. A recent study led by Stanford University measured methane emissions from gas stoves inside 53 U.S. homes, and found that the average stove (burner plus oven) emits 649 grams of methane each year. With more than 40 million U.S. households cooking with gas, researchers estimate the total emissions from gas stoves to be 28.1 gigagrams of methane per year. Based on a 20-year timescale for the lifetime of methane, that’s like adding another 500,000 cars to the roads.

Is cooking with gas bad for your health?

Burning gas produces pollutants you don’t get with electric or induction stoves. The most concerning is nitrogen dioxide (NO2), a reddish-brown gas that is associated with respiratory symptoms like wheezing, shortness of breath, and chest tightness—especially in children with asthma. Homes with gas stoves can have more than twice the NO2 as those with electric ranges, with levels exceeding Health Canada’s residential indoor air quality guidelines. Lem says that most existing Canadian gas ranges don’t meet the long-term exposure limits for NO2.

“It’s almost impossible to meet safe indoor air quality guidelines with a gas stove,” says Lem.

Gas stoves also emit carbon monoxide (CO), a tasteless, odourless, and colourless gas that inhibits oxygen intake. Although a carbon monoxide detector will go off at dangerous concentrations, low levels of carbon monoxide can cause fatigue, and are harmful to people with underlying medical conditions.

Gas stoves are known to elevate carbon monoxide in the home. In one Portland University study, half of the homes with gas stoves tested had carbon monoxide readings above 9 parts per million (ppm), the long-term exposure limit in the U.S. (Health Canada’s long-term exposure limit is 10 ppm.) Another 15 percent were well above Canada’s 1-hour exposure limit of 25 ppm.

Cooking food with any type of stove produces particulate matter, a mixture of solids and aerosols. Gas stoves, however, emit twice as much as electric or induction. That’s because particulate matter is created from the flame itself.

According to the World Health Organization, “Chronic exposure to particles contributes to the risk of developing cardiovascular and respiratory diseases, as well as of lung cancer.” Fine particulate matter, which is made up of particles 2.5 microns or less, is especially dangerous; it can travel deep into the lungs and enter the bloodstream.

Liu Sun is a researcher with Health Canada who has studied the effectiveness of ventilation on removing particulate matter. She says it’s important to use a range hood (with any stove) that vents outdoors, versus the type that recirculates the air. Using a good range hood for the entire time you’re cooking, and up to 15 minutes afterward, can remove up to 80 percent of particles. But that still leaves 20 percent.

“Even though we can have the option of running our range hood, it doesn’t guarantee all the air pollutants can be vented out,” says Sun.

If you’re a healthy adult with a good ventilation system, a gas stove isn’t necessarily going to make you sick. But if you have respiratory or heart issues—or if you have children in the house—an induction stove is a healthier option. And, in general, if you want to substantially reduce the indoor air pollution from cooking, the healthiest and safest bet is an induction cooktop.

What is induction?

With gas and electric stoves, a burner or element produces heat, which travels through cookware to heat food or liquids indirectly. Induction technology, on the other hand, uses electromagnetic energy to heat pots and pans directly. An electric current passes through a coiled copper wire under the cooktop, creating a magnetic current throughout the cookware to produce heat. The stovetop doesn’t get hot—only the cookware.

You can buy a slide-in induction range, or you can have an induction cooktop set into your countertop. An induction range from Home Depot costs between $1,595 and $6,095, though for professional-grade induction ranges, you can spend upwards of $10,000.

Induction technology is compatible with stainless steel, cast iron, and enamelled iron, but aluminium and copper typically don’t work (although there is now magnetized copper cookware for induction). Check your pots and pans with a magnet: if it sticks, your cookware will work.

What are the benefits of induction?

Besides making your home healthier and more environmentally friendly, induction cooktops are praised by chefs for how safe, responsive, versatile, and easy to clean they are. Whether you want to boil water in a flash or simmer soup for hours, induction cooktops are extremely versatile.

Energy efficiency

Because induction cookware is heated directly, very little heat is wasted—making induction technology extremely efficient. Induction can deliver 80 to 90 percent of its electromagnetic energy to the cookware. Gas, on the other hand, only converts 38 percent of its energy, and electric converts 70 percent.

Safety

With an induction cooktop or range, the cooktop itself doesn’t get hot—only the cookware does. So there’s no risk of burning yourself on a hot stove (a huge bonus if you have kids).

Speed

Induction is super responsive, so it can change temperature almost instantly. With induction, you can boil water almost twice as fast than with a gas stove.

Precision

Induction heats pots and pans evenly, so you don’t get any hot or cold spots. And you don’t need to shift the pan around while you’re cooking. You can also maintain an even, precise temperature. If you want to simmer a sauce or melt chocolate, induction can work at a very low temperature and not cause anything to burn.

Maintenance

One of my biggest pet peeves about my gas stove (besides emissions and safety) is cleaning it. With induction, the cooktop never gets hot—so any spills or splatter don’t bake on, and you can wipe them off easily as soon as you’re done cooking.

What if I can’t switch to induction yet?

Don’t panic if you can’t fire your gas stove just yet. Not everyone can afford to go out and buy a new stove, and if you rent, switching is not likely an option. Or if your gas stove is still relatively new, you might want to wait until it reaches its end of life. The good news is, there are ways to use your gas stove less, reducing your exposure to air pollutants and producing less GHG emissions.

Try doing more of your cooking with electric appliances like a microwave, toaster oven, pressure cooker, or air fryer. And if you want to try induction with minimal investment, you can buy a single burner induction cooktop for around $50, like the TILLREDA cooktop from Ikea.

“Part of a just transition is making sure that people who are exposed to the most pollution are thought about first in the transition,” says Andee Krasner, program manager of Climate and Health at the Greater Boston Physicians for Social Responsibility. “And one way that we can do that is these single induction burners as we transition away from the larger gas stoves. Because you can have one or two and it works just as well as having a full stove.”

When you do use a gas stove, make sure to properly ventilate. If your range hood doesn’t vent to the outdoors, change the filters often. If you don’t have a range hood, open a window.

“Whether you’re a healthy adult or not, you need to ventilate your stove,” says Krasner. “Electric or gas, because you want to make sure you vent that particulate matter out.”

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As surges of COVID-19 cases driven by the highly infectious Omicron variant recede, parts of the United States, Canada, and Europe are moving swiftly to lift constraints on a pandemic-fatigued public. Sweden, Denmark, and Norway have abolished nearly all ­COVID-19–related restrictions in recent weeks, and the United Kingdom announced it would do the same this month, dropping even the legal requirement that people quarantine after testing positive for SARS-CoV-2. In the United States, despite persistently high numbers of COVID-19–related deaths and busy hospitals, 10 governors, many known for being cautious in their pandemic response, last week announced immediate or impending ends to their states’ indoor or school mask mandates.

Some of those moves came with assertions that it’s time to “live with the disease” and treat the coronavirus as endemic—a stable, enduring figure in the panoply of human pathogens, alongside cold viruses and influenza. That suggestion troubles many scientists, who warn it is eroding governments’ commitment to tracking and responding to the pandemic—which could leave countries flying blind and unprepared for any new variant.

“Endemic delusion is probably what captures it the best,” says Kristian Andersen, an infectious disease researcher at Scripps Research who has been especially critical of recent moves by his home country of Denmark, which include an announcement that as of this month COVID-19 would no longer be categorized as a “socially critical disease” even though related death and hospitalization rates were still climbing there.

Still, many scientists acknowledge the challenges of steering public restrictions during the reign of the more infectious but generally less severe Omicron variant, when some of the metrics that previously guided policy have become less informative. For example, how meaningful are case counts as mild and asymptomatic infections increase and unreported at-home tests become ubiquitous? How much do incidental findings of COVID-19 in patients hospitalized for other conditions pollute the official numbers?

“The challenge for each and every health authority is to figure out, well, what should we track?” says Michael Bang Petersen, a political scientist at Aarhus University.

Denmark’s recent moves are a case in point. Petersen, a pandemic adviser to the Danish government, supports its decision to lift measures such as limits on nightlife hours, caps on attendance at indoor public events, and mandatory face masks or proof of vaccination for indoor venues. He argues the government could no longer justify the economic, social, and constitutional trade-offs of those restrictions amid promising signs, such as numbers of intensive care unit (ICU) patients that remain stable and below the health system’s capacity.

Andersen, however, calls keeping hospitals from overflowing “a pretty low bar.” Bringing down overall cases, and thereby reducing transmission, remains key, he argues, to minimizing risks of Long Covid and protecting the elderly and immunocompromised from infection.

In the United States, governors cited various metrics to justify recent decisions to lift or let expire indoor mask mandates. California Governor Gavin Newsom noted stable hospitalization rates and a 65% reduction in cases since Omicron’s peak in announcing the state’s mandate would end this week. But leaders also face political and economic pressures. States’ moves may be driven largely by the public’s impatience with restrictions, says epidemiologist Dustin Duncan of Columbia University.

“Even people who recognize the importance of masking, social distancing, all that stuff, may be more amenable to take more risk,” he says. “At the same time, to me, going maskless just seems egregious.” Indeed, the U.S. Centers for Disease Control and Prevention has held firm in recommending masks for indoor public spaces in areas of high transmission—which is nearly all of the country.

“I do feel it is on the early side” to lift indoor mask requirements in most states, says Emory University epidemiologist Jodie Guest—though recommendations may be a better option than requirements as case numbers plummet, she adds.

Still, with the United States logging more than 2000 daily deaths last week, “We cannot say we are at a level that’s tolerable to live with this virus,” Guest says. Her team has been developing rough guidelines for when a true endemic stage of COVID-19 has been reached: daily case rates below 30 per 100,000, ICUs below 80% of capacity, vaccination rates of at least 75%, and fewer than 100 COVID-19 deaths a day nationwide.

Deciding when to end mask requirements in schools is especially difficult, in part because of continued (but hard to prove) concerns the coverings impede learning and social development. “If you ask a bunch of scientists, ‘Should kids wear face masks in school?’ you’re probably going to get a lot of disagreement,” Andersen notes, “and I don’t know who is right.”

Guest says she doesn’t have as clear a sense of the numerical thresholds that could determine when schools should stop mandating masks. “I would be hesitant [to remove requirements] right now,” she says, adding the step could soon be justified in parts of the country.

Data to inform such debates may become less available or reliable if governments pivot too soon to an endemic view of the coronavirus, scientists say. As pandemic restrictions in Denmark relax, “people are becoming less motivated to get tested and we are beginning to downscale our test system,” Petersen says.

Some governments are limiting efforts to find and report cases. Sweden, long an outlier among European countries for its laissez-faire approach to the pandemic, ended widespread testing at mobile centers as cases declined from their Omicron peak. The United Kingdom is reportedly weighing ending free public testing for the virus in the coming weeks. Meanwhile, the Canadian province of Saskatchewan last week switched from providing daily to weekly reports of COVID-19 cases. And Tennessee last month joined several states already reporting case counts weekly. “Daily case counts matter,” Guest says. “Every time I lose the ability to have a number, it makes me nervous.”

Official counts are already becoming less meaningful as the reliance on at-home test increases, making other surveillance approaches all the more important. Last week, researchers took to Twitter in outrage after a U.K. news report claimed the United Kingdom might not continue to fund a long-
running study in which the Office for National Statistics (ONS) conducts repeated antibody surveys and SARS-CoV-2 testing of more than 100,000 randomly selected households. “What that’s meant is that you’ve had a way of seeing the prevalence in your population that does not depend on people accessing testing,” says Christina Pagel, a health services researcher at University College London.

Discontinuing the ONS study would also obscure data on asymptomatic cases, differences in disease burden between different ethnic and occupational groups, and the impact of Long Covid, Pagel says. She suspects the outcry will sway the U.K. government, which responded in the news report by saying no funding decision had been made and it “obviously” wanted to “maintain our world-leading surveillance capacity” for COVID-19.

But in the growing number of “back to normal” messages, Pagel sees leaders ignoring obvious next steps to protect public safety. Even researchers who aren’t speaking up to defend specific restrictions are urging governments to step up their COVID-19 fight, rather than scale it back. They want aggressive new pushes to reach the unvaccinated, distribute rapid tests, and make COVID-19 treatments much more accessible, for example. “Frankly, I don’t really think that 2 to 3 weeks more of a mask mandate is going to make much difference in the long run,” says KJ Seung, a health policy adviser at Partners In Health. “More alarming to me is that our public health system doesn’t seem to have any plan for dealing with the next surge.”

“I don’t particularly want to be in a future where I get COVID twice a year,” Pagel adds. Averting that future may mean adaptations such as technologies to improve indoor air quality and strong virus surveillance that can be ramped up at the first sign of another surge. “Why would we not make that effort?” she wonders. “It’s almost like having that conversation is considered a failure.”

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