Pollution Types, Standards and Impacts
Current Regulatory Standards and GAF Permits for PM Pollution Are Not Protective of Public Health in West Dallas
PM pollution is tiny pieces of soot from engines, boilers, and furnaces as well as small flecks of dust or sand.
PM particles are so tiny they can go deep into your lungs and even into your blood stream and affect every organ in your body. We often can’t see PM pollution. That’s why we need air monitors to tell us what we’re breathing.
Research over the last 25 years has failed to establish a “safe level” of exposure to Particulate Matter. That is, there appears to be no level of exposure to PM that can’t result in a human health harm. These harms can occur in any organ in the body since microscopic particles of PM can pass through the lungs into the bloodstream.
Even low-level and short periods of PM exposure, even at levels below-regulatory standards, PM is capable of causing some degree of permanent human health harm. Chronic exposure to higher levels can result in significant harm and early death.
Since 2000, studies have linked exposure to PM pollution to Heart Attacks, Strokes, COPD, Adult on-set and pediatric Asthma, Diabetes, Blindness, Infertility, Low-birth weights, Birth Defects, Autism, Parkinson’s Disease, Dementia, Loss of IQ, Anti-social behavior and early death.
EPA regulations for PM pollution have yet to catch-up to the most recent science about the toxicity of the pollutant. The current annual limit of 12 μg/m3 was adopted in 2012, and it as well as the Agency’s 24-hour standard have been proven to be insufficiently protective over the last decade.
A 2015 study by the Harvard T.H. Chan School of Public Health found higher death rates among the elderly associated with PM pollution despite the fact that, “the harmful effects from the particles were observed even in areas where concentrations were less than a third of the current standard set by the Environmental Protection Agency (EPA).”
Another Harvard School of Public Health report published in 2017 provided even more proof that current EPA standards were not protecting public health. It concluded that even relatively small increases in PM and ozone pollution were enough to trigger increases in mortality by 7 to 14% among those 65 and older – even though these were under regulatory levels. Black men were exposed to more, and higher, levels of PM than the rest of the population.
“There was a significant association between PM2.5 exposure and mortality when the analysis was restricted to concentrations below 12 μg per cubic meter, with a steeper slope below that level. This association indicated that the health-benefit-per-unit decrease in the concentration of PM2.5 is larger for PM2.5 concentrations that are below the current annual NAAQS than the health benefit of decreases in PM2.5 concentrations that are above that level…Moreover, we found no evidence of a threshold value — the concentration at which PM2.5 exposure does not affect mortality — at concentrations as low as approximately 5 μg per cubic meter; this finding is similar to those of other studies.”(Qian Di et al. 2017).
A 2019 study links the deaths of 200,000 military veterans to long-term exposure to ultra-fine particle pollution at levels below current Environmental Protection Agency standards. “In this study, 99.0% of the burden of death due to non-accidental causes were associated with PM 2.5 levels below the current EPA guidelines…. The burden of death associated with PM2.5 was disproportionally borne by Black individuals and socioeconomically disadvantaged communities.”(Bowe et al. 2019).
A 2020 Australian study found that even exposures to PM2.5 that fell below global standards were hazardous, “Our study supports recent evidence that there is no safe level of air pollution — finding an increased risk of cardiac arrest despite air quality generally meeting the standards”. (Zhao 2020).
In 2021 the World Health Organization (WHO) revised its standards for PM exposure downward, adopting a 24-hour standard of 15 ug/m3 and an annual standard of 5 ug/m3. According to WHO scientists, the reviews of the scientific literature leading to the organization’s new standards “provide clear evidence of the damage air pollution inflicts on human health, at even lower concentrations than previously understood” (WHO 2020).
WHO scientists also concluded “PM2.5, fine particulate matter of 2.5 micrometres or less in diameter, is the most dangerous pollutant because it can penetrate the lung barrier and enter the blood system, causing cardiovascular and respiratory disease and cancers. It affects more people than other pollutants and has health impacts even at very low concentrations.”
…recent studies and large research programmes consistently show that the adverse effects of air pollution are not only limited to high exposures; harmful health effects can be observed all the way down to very low concentration levels, with no observable thresholds below which exposure can be considered safe” (Hoffman et al 2021).
In June 2021, the EPA announced that it would review its own PM standards, but has not done so yet. A previous and controversial review in 2020 found evidence “supporting revising the level of the annual standard for the PM NAAQS to below the current level of 12 micrograms per cubic meter”(EPA 2021).
In doing so, the agency said that scientific evidence, air quality analyses, and the risk assessment for particulate matter can “reasonably be viewed as calling into question the adequacy of the public health protection afforded by the … standards.” (The Hill 2021).
It’s very likely that this new round of reviews will prompt EPA to lower its PM exposure standard to below levels GAF currently claims are “safe.”
Because it’s made up of heavier than air particles, PM pollution often doesn’t travel as far and is concentrated much closer to its source than gaseous air pollution like smog. The 30.1 tons of PM pollution GAF reported in 2020 represents approximately 8 pounds of PM for the 7,500 residents living within a mile radius of GAF. Every pound of PM contains millions of microscopic particles. Every particle has slightly different chemical compositions.
Documented levels of PM pollution around GAF have exceeded all of the revised WHO standards as well as the proposed EPA standards, much less the current EPA standard. West Dallas has a chronic PM pollution problem. GAF is West Dallas’ largest PM polluter – by far. Removing it as a source would decrease ambient PM levels significantly in the neighborhood surrounding the factory.
Science has concluded it is impossible for GAF to do business in West Dallas without harming the surrounding population with its substantial PM pollution. The Dallas Board of Adjustment should come to the same conclusion.
Scroll through the sheets below to read about the other pollutants of concern besides just Particulate Matter (PM) pollution:
GAF's Gotta Go! 