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Review of the Air Quality Criteria Document for Particulate Matter

Review of the Air Quality Criteria Document for Particulate Matter

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% deposition, more than 7 months would be needed to deposit 5 mg <strong>of</strong> <strong>the</strong> ironoxide particles in <strong>the</strong> lung since only about 20 mg would be deposited in a day).p. 8-16 The concentration stated in <strong>the</strong> table <strong>for</strong> <strong>the</strong> Madden et al. study should be 1000mg in 0.5 ml.p. 8-17 For <strong>the</strong> Watkinson et al. study, what were <strong>the</strong> nose-only inhalationconcentrations?p. 8-18, Table 8-5 Given <strong>the</strong> low exposure <strong>of</strong> 10 mg/m 3 <strong>for</strong> 4 hours in <strong>the</strong> Ohtsuka et al. study,this paper warrants expanded discussion in <strong>the</strong> text.p. 8-24 The symbol <strong>for</strong> <strong>the</strong> geometric standard deviation is not as it appears in <strong>the</strong> tablebut ra<strong>the</strong>r should be <strong>the</strong> Greek symbol s. The same statement can be made <strong>for</strong>Table 8-7.p. 8-28, Table 8-7 This reviewer finds it <strong>of</strong> great interest that intertracheal instillation <strong>of</strong> ROFA in<strong>the</strong> Watkinson et al. study showed effects but inhalation <strong>of</strong> 15 mg/m 3 six hoursper day <strong>for</strong> three days <strong>of</strong> <strong>the</strong> same compound showed no effects.p. 8-29, l. 11 20 In <strong>the</strong> Killingsworth et al. Studies using monocrotaline-MCT, mortality andchanges in MIP-2 were noted. What human condition does this model mimic?p. 8-32, l. 6 19 This paragraph comes across as if <strong>the</strong> Godleski et al. HEI Report is consideredpeer reviewed and <strong>the</strong> study by Muggenberg et al. appearing in an InhalationToxicology Supplement from <strong>the</strong> PM 2000 Meeting is not peer reviewed. Thefact that <strong>the</strong>se studies differed in <strong>the</strong>ir findings is what should be emphasizedbecause Godleski used concentrated ambient particles and Muggenberg usedhigh concentrations <strong>of</strong> ROFA. If EPA has criteria <strong>for</strong> what <strong>the</strong> agency considerspeer reviewed versus not peer reviewed, <strong>the</strong>se criteria should be so stated andapplied uni<strong>for</strong>mly throughout <strong>the</strong> <strong>Criteria</strong> <strong>Document</strong>.p. 8-31, l. 18 19 The statement is made that <strong>the</strong> different findings between <strong>the</strong> dog studiesillustrate <strong>the</strong> difficulties in extrapolating animal toxicological data to humanhealth effects. The sentence falls short in that it fails to note that lack <strong>of</strong>understanding <strong>of</strong> mechanism <strong>of</strong> action is <strong>the</strong> primary problem wi<strong>the</strong>xtrapolating animal results that are disparate in nature to humans.p. 8-33, l. 6 9 The results from <strong>the</strong> Gordon et al. study are interpreted in this paragraph tosuggest that day-to-day changes in particle composition may play an importantrole in <strong>the</strong> systemic effects <strong>of</strong> inhaled particles. This is an overinterpretation <strong>of</strong>p. 8 34, l. 4 14 In addition to <strong>the</strong> potential mechanisms discussed in this paragraph, <strong>the</strong> role <strong>of</strong>endo<strong>the</strong>lins should be mentioned. Vincent et al. (Inhalation Toxicology <strong>of</strong>Ambient <strong>Particulate</strong> <strong>Matter</strong>: Acute Cardiovascular Effects <strong>of</strong> ResuspendedEHC-93 Urban Particles in Wistar Rats. Final Report to <strong>the</strong> Health EffectsInstitute <strong>for</strong> <strong>the</strong> Collaborative Study 98-32, In Press, 2001) have shown thatparticles can affect endo<strong>the</strong>lin 1 and 3 more than 30 hours post exposure.p. 8-37, l.10 Replace <strong>the</strong> word although with <strong>the</strong> word after.p. 8-41, l. 18 Broad statements such as what Nell et al. made in <strong>the</strong>ir article on suggestingthat <strong>the</strong> rise in <strong>the</strong> U.S. prevalence rate <strong>for</strong> allergic rhinitis may be related toincreased diesel emissions in addition to o<strong>the</strong>r combustion sources is highlyspeculative. Anyone can suggest a material is <strong>the</strong> culpritive agent <strong>for</strong> an effectbut <strong>the</strong> emphasis in a criteria document ought to be on <strong>the</strong> pro<strong>of</strong> <strong>for</strong> suchrelationships based upon experimental data.p. 8-46, l. 13 The astronomically high carbon black exposure level used by Jakab producedno effect on susceptibility to bacterial infection in contrast to high exposurestudies with titanium dioxide. Comparing such results implies that a particle isnot a particle and that composition or <strong>the</strong> nature <strong>of</strong> <strong>the</strong> particle is important <strong>for</strong><strong>the</strong> effects on <strong>the</strong> host. The <strong>Criteria</strong> <strong>Document</strong> does not put as much emphasison pointing out concepts such as this as what might be appropriate.p. 8-61, l. 3 Round 11.9-fold to 12-fold. Such rounding is undoubtedly more in accord with<strong>the</strong> accuracy <strong>of</strong> <strong>the</strong> data.p. 8-62, l. 3 The concept discussed here that a combination <strong>of</strong> several components ra<strong>the</strong>rthan a single metal in PM is likely responsible <strong>for</strong> cellular effects is worthbringing <strong>for</strong>ward as one <strong>of</strong> <strong>the</strong> major conclusions that can be gained fromexamining <strong>the</strong> toxicological data on PM.p. 8-67, l. 4 The Lee et al. studies described here involved sulfuric acid aerosolconcentrations so high as to make <strong>the</strong> results <strong>of</strong> little value to <strong>the</strong> discussion <strong>of</strong>A - 9

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