Commentary: Flawed Scientific-Evidence Standards Delay Diesel Regulations

Abstract

Of 188 government-monitored air toxics, diesel particulate matter (DPM) causes seven times more cancer than all the other 187 air toxics combined, including benzene, lead, and mercury. Yet, DPM is the only air toxic not regulated more stringently under the Clean Air Act, as a hazardous air pollutant (HAP). One reason is that regulators use flawed standards of scientific evidence. The article argues (1) that DPM meets all six specified evidentiary criteria, any one of which is sufficient for HAP regulation and (2) that regulators’ standards of evidence for denying HAP status to DPM (no DPM unit-risk estimate, inadequate dose-response data, alleged weak mechanistic data) err logically and scientifically, set the evidence bar too high, delay regulation, and allow 21,000 avoidable DPM deaths annually in the U.S.

Keywords:

• cancer
• cause
• diesel
• hazardous air pollutant
• particulate matter
• PM
• unit risk estimate