WSJ Op-Ed Denies Health Benefits From Lowering Smog-Forming Ozone Pollution

EPA To Finalize New Smog Pollution Standards. As required under the Clean Air Act, the U.S. Environmental Protection Agency (EPA) will soon update the National Ambient Air Quality Standards (NAAQS) with a more stringent standard for ground-level ozone, the primary component of smog. The EPA proposed in November 2014 to strengthen the ozone standard from its current level of 75 parts per billion (ppb) to between 65 and 70 ppb, “based on extensive recent scientific evidence” about the harmful effects of the pollutant. The updated standards, which will be finalized by October 1, are expected to bring immense public health benefits. From an EPA press release:

If the standards are finalized, every dollar we invest to meet them will return up to three dollars in health benefits. These large health benefits will be gained from avoiding asthma attacks, heart attacks, missed school days and premature deaths, among other health effects valued at $6.4 to $13 billion annually in 2025 for a standard of 70 ppb, and $19 to $38 billion annually in 2025 for a standard of 65 ppb. [EPA.gov, 11/26/14; EPA.gov, accessed 9/3/15]

WSJ Published Op-Ed Claiming “No Detectable Causal Relation” Between Ozone Reductions And Improved Public Health. The Wall Street Journal published a September 1 op-ed by Anthony Cox, president of consultant company Cox Associates, headlined: “The EPA's Next Big Economic Chokehold; Lowering ozone -- from cars, trucks, factories and power plants -- in the name of an imaginary health benefit.” In the op-ed, Cox criticized the EPA's forthcoming smog regulation as overly expensive (citing a study from the National Association of Manufacturers, which several policy experts have debunked) and denied the public health benefits expected to come from the rule. From the op-ed:

The agency is likely to introduce stringent new standards for ground-level ozone, arguing that a lower allowable level of ozone--an important component of smog--will reduce asthma in the U.S., among other claimed health benefits. Yet the EPA ignores decades of data and studies, some under the agency's auspices, that reveal no detectable causal relation between past reductions in ozone and better public health, including reductions in asthma cases.

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Fortunately, there is abundant historical data on ozone levels and asthma levels in U.S. cities and counties over the past 20 years, many of which have made great strides in reducing ambient levels of ozone by complying with existing regulations. It is easy to check whether adverse outcomes, from mortality rates to asthma rates, have decreased more where ozone levels have been reduced more. They have not. Even relatively large reductions in ozone, by 20% or more, have not been found to cause detectable reductions in deaths and illnesses from cardiovascular and respiratory illnesses, contrary to the EPA's model-based predictions.

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The cynical use of asthma patients to promote a pro-regulation political agenda that won't actually help them undermines the credibility of regulatory science and damages the public interest. [The Wall Street Journal, 9/1/15; 9/1/15; Media Matters, 8/31/15]

Experts Denounce WSJ Op-Ed

American Lung Association's Janice Nolen: Cox's Perspective Is “Completely Outside Of Scientific Understanding.” Janice Nolen, Assistant Vice President of National Policy at the American Lung Association (ALA), noted that Cox cited just two studies to support his claim out of “a thousand or more studies that have been done looking at the issue of what effects ozone has on human health.” Nolen said that Cox's conclusion runs counter to the “overwhelming evidence” that ozone triggers asthma attacks, among other adverse health impacts, and called his perspective “completely outside of scientific understanding.” She also compared Cox's study with the EPA's review of health impacts linked to ozone pollution, noting that the EPA review is based on multiple studies and is reviewed by a team of independent scientists. From a phone interview with Media Matters (lightly edited for clarity):

The studies that [Cox] has pulled out are two from a thousand or more studies that have been done looking at the issue of what effects ozone has on human health. And there are studies that have looked at this for multiple cities, over years, in different places around the globe, in places where the ozone standard was being met, in places where it even had cleaner air. And the evidence is overwhelming that ozone triggers asthma attacks.

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There is a team of independent scientist who help EPA scientists evaluate each study and see what are the things that may have interviewed or complicated the question or led it to be a more valid or less valid study, or a study that had certain things that made it harder to be representative of the larger picture. And they look at multiple studies. And they look at studies that cover large cities, multiple cities, over multiple decades. And the overwhelming conclusion is that asthma attacks are triggered by ozone pollution ... so his perspective is completely outside of scientific understanding. It has been established for decades.

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There are always opponents to cleaning up pollution who will argue that the science isn't solid, that we need to do more research, among other things that they're going to argue. And it inevitably is wrong. The research is solid, and this probably is as established a link as anything. [Phone call with Media Matters, 9/3/15]

Johns Hopkins' Greg Diette: Cox's Point Is A “Distraction” From Real Health Impacts Of Ozone. Dr. Greg Diette, Professor of Medicine, Epidemiology and Environmental Health Sciences at the Johns Hopkins Bloomberg School of Public Health, told Media Matters that the op-ed cherry-picks two studies and wrongly focuses on asthma incidence (the number of people that have asthma), which he called a “clever way to shift attention away from the abundant data on the health issues related to ozone.” From a phone interview with Media Matters:

[Cox] has picked on one thing, which is asthma incidence, which is not where the strongest signal comes from. It comes more from people dying and people getting sick and going to the hospital, and things of that sort.

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The point that Mr. Cox is making is really a distraction, to say that because asthma incidence didn't go down while ozone was going down that therefore lowering ozone can't help human health. If you're paying attention that sounds like something you should worry about but it really isn't. It doesn't change the fact that people die on days with high ozone. It doesn't change the fact that people end up in the emergency room, or miss school or miss work. 

Diette also dismissed the two studies cited in the op-ed -- one was written by Cox himself and has “basically the same thesis” as his op-ed, and the other Diette called a “circumstantial” review that “does not detract from the overall, really strong robust evidence” of the health impacts of ozone. [Phone call with Media Matters, 9/3/15]

Diette: “We're Way Beyond” Talking About Whether Ozone Affects Human Health. In June, Diette responded to a similar claim Cox made at a congressional hearing on the EPA's new ozone proposal:

What [Cox] is describing about there not being any benefit is not a mainstream view. There is strong consensus among people who actually take care of sick patients with asthma and other lung diseases that ozone is harmful, it causes illnesses, it causes them to die. It's in our guidelines to tell people to avoid the outside when there's high-ozone days. It's not made up stuff, this is based on science, I just want to clarify that as well.

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This isn't really something that in 2015 we should be talking about, whether ozone affects human health. We're way beyond that. [YouTube, 6/17/15]

Indiana University's Stephen Jay: Op-Ed “Is A Sad And Shallow Screed,” Cox And WSJ “Should Be Ashamed.” Stephen Jay, a professor of medicine and public health, and past founding chair of the IU (Indiana University) Richard M. Fairbanks School of Public Health, told Media Matters that the op-ed's “pejorative” headline “presages the lack of evidence-based conclusions that follow. The article is a sad and shallow screed.” Jay continued:

Here is a brief critique:

Line 5: “Yet the EPA [ignores decades of data and studies, some under the agency's auspices, that reveal no detectable causal relation between past reductions in ozone and better public health, including reductions in asthma cases]” is false, baseless, misleading.

Paragraph 3 is simple cherry picking and failure to apply rigorous research and statistical analyses in research. To suggest that ALA and [the Natural Resources Defense Council (NRDC)] are “advocacy and lobbying” groups and therefore must be incorrect in presenting unscientific opinions, is silly. Both ALA and NRDC are evidence based organizations. For example, the ALA has the American Thoracic Society, the largest such respiratory research organization in the world--they inform ALA and ALA positions are advocating science based as opposed to conjectures and opinions. Same for NRDC in my experience.

Paragraph 4 is senseless. The wealth of research regarding O3 and human disease has been funded by [the National Institutes of Health (NIH)] and other science based organizations. The NIH and EPA support the independent research that is found in the peer reviewed literature. Further the EPA and NIH work closely in research eg NIEHS at NIH has the NIH-EPA Centers of Excellence on Environmental Health Disparities Research. The NIH and EPA regularly collaborate -it's part of the mission of DHHS and its agencies to work across artificial agency boundaries to seek best science and truth.

Paragraph 5 is nonsensical. There is much science that shows ambient O3 levels cause respiratory disease related ER admissions, physician visits, hospitalizations... etc.

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The science has confirmed what clinicians have known since the 'Sulfurous Fog' and such that blanketed London in 1952, and Donora, PA decades ago. The statement “even if it hasn't done so in the past” represents 'malpractice' in health reporting, Cox should be ashamed as should WSJ for running this article. [Statement to Media Matters, 9/2/15]

Yale's Jesse Berman: Cox “Overlooks” Health Impacts Other Than Asthma Associated With Ozone Exposure. Dr. Jesse Berman, a postdoctoral associate at Yale's Institute for Biospheric Studies who has published several studies on the health impacts of ozone, told Media Matters:

The author places an emphasis on the rise in asthma cases and compares this with declining ozone concentrations. Asthma is a notably complex disease that can be caused or driven by a variety of pollutants or environmental conditions, of which ozone is only a single component. However, ozone is most closely associated with exacerbating existing asthma, not causing new asthma cases. It is this susceptible population of people who already have asthma that are at most risk. Additionally, the author appears to overlook that ozone exposure has been associated with a number of other adverse health outcomes, besides asthma exacerbations. Elderly individuals, those with compromised immune systems, individuals with [chronic obstructive pulmonary disease (COPD)], young children, and even healthy individuals who spend lots of time outdoors (e.g. runners, cyclists) are all at high risk from ozone exposure. [Statement to Media Matters, 9/3/15; Google Scholar, accessed 9/3/15]

Health Specialist Indra Frank: Contrary To What Cox Says, EPA Proposal “Will Bring The Ozone Standard Into Better Alignment With Science.” Dr. Indra Frank, Environmental Health Project Director at Hoosier Environmental Council, said in a statement to Media Matters:

Dr. Cox expresses concern that EPA's current proposal “undermines the credibility of regulatory science”; however, it could perhaps more accurately be argued that the current proposal will bring the ozone standard into better alignment with the science. The last time the standard was revised was in 2008. At that time EPA's Clean Air Science Advisory Committee unanimously recommended that the EPA set the ozone standard between 60 and 70 ppb based on their review of 1700 studies on the health effects of ozone.

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Since the last revision of the standard in 2008, there have been more than 1,000 additional studies on ozone and health, including studies showing harm at the current ozone standard of 75 parts per billion. Only a small subset of the scientific literature is cited in [Cox's] reply. [Statement to Media Matters, 9/3/15]

Ohio Environmental Council's Trish Demeter: Questioning Link Between Ozone And Health “Is Like Questioning Gravity.” Trish Demeter, managing director of Energy & Clean Air Programs at the Ohio Environmental Council, told Media Matters:

[T]he author is cherry picking a few, obviously absurd, studies to back up his claims. He selects snippets from reports to convey the impression that the science behind the connection between human health and ozone is not decided. But in reality, the connection is well-founded.

His conclusion is way out of the mainstream. The new EPA standard for ozone is founded in simple logic: Bad air days make it harder to breathe, and exacerbate respiratory and cardiopulmonary illnesses. Cleaning up the causes of bad air days absolutely benefits human health.

Questioning the link between ozone pollution and human causes, especially asthma, is like questioning gravity. Numerous reputable studies, from numerous reputable organizations have demonstrated the linkage. There simply is no factual basis to the claim that ozone is not connected to human health. [Statement to Media Matters, 9/3/15]

Clean Air Watch's Frank O'Donnell: Author “Cherry-Pick[ed] Studies.” Frank O'Donnell, president of Clean Air Watch, told Media Matters in a statement (emphasis original):

The author is certainly cherry-picking studies. Contrast for example, [a] study which found direct health benefits from reduced pollution levels. He ignores the clear directive of EPA's independent science advisers, who concluded UNANIMOUSLY that current smog standards are too weak to protect public health. [Statement to Media Matters, 9/3/15; The New England Journal of Medicine, 3/5/15]

Sierra Club's Terry McGuire: It's “Blatantly False,” “Ludicrous” To Say There's No Benefit To Stronger Ozone Standards. The Sierra Club's Terry McGuire told Media Matters:

The science behind the need for stronger ozone standards is not up for debate. This reminds me, you'll find a handful of scientists who still say there's no such thing as climate change, and there's no proof that climate change is real. There's always going to be that handful of scientists that are outliers.

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The thing about ozone, and why we have this whole process of reviewing every five years, is that the more we learn about pollutants, the more we learn about how dangerous it is. So what we're learning now is it's not just pulmonary health -- it's not just affecting our lungs -- it's also cardiovascular, neurological, all sorts of other effects on the body, our nervous system -- that suite of negative health impacts is pretty expansive. So I think it's pretty shocking to see someone come and ask why. To say there's no benefit to stronger ozone standards is just blatantly false. There's no truth to that ... it's a ludicrous assertion and does not match up with the overwhelming body of medical literature that exists.

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The science is really clear here that [ozone] is a dangerous pollutant. These assertions to the contrary are really dangerous. Trying to sow these seeds of doubt to sway decision makers and the public, it's a pretty insidious, blatantly false attack on public health protections. [Phone call with Media Matters, 9/3/15]

EPA Spokesperson Responded To Cox's Op-Ed By Pointing To Over A Thousand Studies Showing Health Impacts Of Ozone. When asked to comment on Cox's op-ed, a spokesperson for the EPA told Media Matters:

EPA uses a rigorous and transparent framework to evaluate the causal nature of air pollution's effects on public health or the public welfare.  For ozone, a significantly expanded body of scientific evidence, including more than 1,000 new studies since EPA last reviewed the standards, shows that ozone can cause a number of harmful effects on health and the environment. For example, exposure to ozone can cause respiratory system effects such as difficulty breathing and airway inflammation. For people with lung diseases such as asthma and COPD (chronic obstructive pulmonary disease), these effects can lead to emergency room visits and hospital admissions.

Studies have also found short-term that ozone exposure is likely to cause premature death from lung or heart diseases. In addition, new studies provide stronger evidence than was available in previous reviews that long-term exposure to ozone is likely to result in a variety of harmful respiratory effects, including premature death from respiratory causes. Asthma is a complex disease, and there are a number of environmental and genetic factors that contribute to the onset and development of asthma. These are well characterized in the medical literature. [Statement to Media Matters, 9/3/15]

Experts Also Explain How Op-Ed Author Falsely Conflated Asthma Attacks With Asthma Rates

Cox Claimed EPA Wrongly Using Asthma “To Promote A Pro-Regulation Political Agenda That Won't Actually Help Them.” In his WSJ op-ed, Cox claimed that proponents of the updated smog rule wrongly “claim that cutting ozone in the future will reduce asthma,” and that “the Obama White House blames increasing numbers of asthma patients on climate change.” He concluded: “The cynical use of asthma patients to promote a pro-regulation political agenda that won't actually help them undermines the credibility of regulatory science and damages the public interest.” [The Wall Street Journal, 9/1/15]

ALA's Nolen: Cox Is “Completely Confusing Incidence Of Asthma ... With Asthma Attacks.” ALA's Janice Nolen explained to Media Matters:

He is completely confusing incidence of asthma, in other words new cases of people with asthma, with asthma attacks. And the evidence is overwhelming about the link between ozone causing asthma attacks. He's conflating it causing new cases of people to have asthma which is a different question altogether.

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The overwhelming evidence shows -- and has been researched for three or four, at least, different reviews of the science -- that one of the most well-established relationships is that exposure to ozone triggers asthma attacks. [Phone call with Media Matters, 9/3/15]

Dr. Indra Frank Expanded On The Difference Between Asthma Rates And Asthma Attacks. Dr. Indra Frank stated to Media Matters:

[Dr. Cox] does not take into account the distinction between the asthma rate and the incidence of asthma attacks. The asthma rate is what percent of the population has a diagnosis of asthma. The incidence of asthma attacks refers to the number of attacks among those who have a diagnosis of asthma. An asthma attack is an episode of constricted airways and difficult breathing that is disabling and can be severe enough to be life threatening. In the US there are approximately 500,000 hospitalizations for asthma each year (Silverman, 2010). A person who can control their asthma through reduced exposures to respiratory irritants and regular use of medications may have very few asthma attacks. If asthma in a population is well controlled, there is a lower incidence of asthma attacks.

Ozone increases the incidence of asthma attacks among those who already have a diagnosis of asthma. Ozone is a highly reactive molecule and it is through this reactivity that it is a potent irritant of the respiratory tract (McDonnell, 2012). By irritating and inflaming the respiratory tract, it triggers asthma attacks. Higher ozone levels have been shown to increase the number of asthma attacks and the number of emergency room visits (Ito, 2007) and hospital admissions for asthma (Silverman, 2010). [Statement to Media Matters, 9/3/15]

Harvard's Jonathan Levy: Increased Asthma Cases “Means That The Benefit Of Ozone Reductions Are Greater Because There Are More Vulnerable Individuals.” Dr. Jonathan Levy, adjunct professor of Environmental Health at Harvard T.H. Chan School of Public Health, stated to Media Matters:

[Cox] is conflating causation of asthma with exacerbation of asthma, and EPA does not base its NAAQS decision or its regulatory impact analysis on the assumption that ozone causes asthma. In fact, the fact that asthma rates are increasing means that the benefit of ozone reductions are greater because there are more vulnerable individuals. His argument therefore has no relation to the evidentiary basis for the ozone standards. [Statement to Media Matters, 9/3/15]

Clean Air Watch's O'Donnell: Industry Opponents “Deliberately Muddle The Issue Of Asthma.” Clean Air Watch's Frank O'Donnell's statement to Media Matters further criticized Cox (emphasis original):

Industry opponents of tougher smog standards and their friends deliberately muddle the issue of asthma.  No one has ever claimed that air pollution CAUSES asthma.  In fact, experts cannot pin down a single cause.  However, high ozone levels CAN and DO trigger asthma attacks. So dirty air makes the suffering worse for children and adults who already have asthma. [Statement to Media Matters, 9/3/15]