Review of the Air Quality Criteria Document for Particulate Matter

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P 8-81, L 9: “Interaction” should be “interactions”.P 8-82, L 16 to P 8-83, L 8: It is astonishing that these field studies of whole air (urban andotherwise) are cited as contributing to our understanding of the co-pollutant issue, while wellcharacterizedcombustion emission studies are not cited at all! These studies provide very littleuseful information. With regard to the topic of the section, they are basically ecologicalepidemiology studies with very few subjects of the wrong species. In line 26-27, it is stated that“extrapolation is hampered” by a lack of exposure characterization. What an understatement!Considering all the problems with these studies, it is questionable whether they merit inclusion atall. As in all air pollution studies, but especially true for studies of co-pollutant interactions, ifyou don’t know the exposure, you don’t know anything.P 8-83, L 21-22: I disagree with this statement. The key to plausibility is not knowing thecomponents and the individuals at risk. The key is to plausibility is understanding the linkagebetween the two (ie, a plausible mechanism).P 8-85, L 13-14: This sentence contrasts with the earlier statement on page 8-63 that metalshave been established as a key (it actually implied metals were the only key) contributor tohealth impacts of PM via reactive oxygen species. It is stated that the ROFA studies haveimportant implications, but it doesn’t state what the implications are.P 8-86, L 5-14: This section on “bioaerosols” only talks about endotoxin. What about all theother bioaerosols? Endotoxin is seldom, if ever, actually a “bioaerosol”. It is a contaminant ofairborne PM. Pollen proteins, plant debris, and many other airborne materials of biologicalorigin are not mentioned.P 8-86, L 20: First, “PM is responsible” should be PM are the responsible”. Second, there otherhealth effects of concern for diesel PM in addition to the adjuvant effect. Why not mention themin this chapter?8-87, L 29: It should say “animals with certain types of compromised health”, or “animals withcompromised cardiorespiratory health” or some such wording. Not all types of compromisedhealth would be expected to affect susceptibility to inhaled PM (a broken toe, as an extreme, butillustrative example).P 8-88, L 3-6: This closing statement needs work. First, validation of animal models is asimportant as identification, and this important point is overlooked in the section, and too oftenoverlooked by researchers. Second, what is the connection between making “solid progress” andthe fact that large numbers of people are needed for epidemiology studies? Would our progressbe less solid if fewer numbers of people sufficed for epidemiologists? The author probably has acouple of good thoughts here, but it’s not clear that they belong in the same sentence.P 8-88, L 12-13: This sentence is trite. I think we can go beyond saying that there “may be”multiple mechanisms to state that research to date clearly indicates that there “are” multiplemechanisms.Chapter 9 Integrative Synthesis - General Comments:In general, the chapter is well-developed, and with some modest editing, will serve well as anintegrated synthesis. With minor editing, it will hit approximately the right level of detail, andgive appropriate attention to making the major points and drawing conclusions.Some additional attention needs to be given to this chapter to accommodate the fact that manypeople will read only this chapter. It proposes to be a synthesis of all of the Criteria Documentexcept the environmental effects. First, one wonders why the environmental effects couldn’tA - 29
also be summarized. Second, the chapter needs some additional definitions, attention toterminology, and figures in order to better serve as a stand-alone summary.There are inaccuracies in this chapter that carry over from the same problems in precedingchapters. There are also sentences scattered throughout the chapter that don’t make sense aswritten. This may have resulted from attempts to condense more expanded information inpreceding chapters, but it needs to be corrected.Specific comments:P 9-3, L 14-15: While it is true that the term “aerosol” is often used incorrectly, why not use thecorrect terminology in the CD? “Aerosol” and “particle” are not the same thing. This chapterperpetuates the error.P 9-4, L 16-18: It is stated that the nuclei mode is only distinguishable in remote areas or nearsources. Elsewhere, it is stated that the nuclei mode is not observed in remote areas. Becausethe nuclei mode is short-lived, it presumably would be found only near sources; thus, if it is inremote areas, there must be sources there. These facts need to be reconciled so the chapterpresents a consistent story.P 9-4, L 20-21: I have heard emission scientists distinguish “nanoparticles” as being in the 50nm or less size range. Does the Agency care to set forth any criteria for these terms? Thatwould be a useful service.P 9-9, L 1 and 5: Wouldn’t PM formed by condensation also be called “secondary”? That is,not all secondary PM is formed by “chemical reactions”, right (or do you call condensation achemical reaction)?P 9-14, L 11-12: It is not clear if you are saying that these species exist, or should exist, orpossibly exist, or what.P 9-15, L 6: This statement conflicts with P 9-10, L 19-20 that states that nuclei mode particlesare not found in rural areas. Let’s settle on one story and stick to it.P 9-15, L 28-29: The meaning of this sentence is not clear. The point about not being able tocharacterize particles because of lack of reference standards is not clear.P 9-16, L 3: It should be “data ----are needed”. Data is a plural word.P 9-16, L 31: The point about particle-bound water is not clear. In fact, the whole issue ofparticle-bound water is not clear. Presumably, water is associated with some PM in theatmosphere. If so, then water is part of the particle, and you want to know the mass and numberof particles, and their health effects, with water, not without. I can see how you would want toavoid data that include the accumulation of water by particles after collection, but why wouldyou only want to know the mass of particles with no water?P 9-18, L 1-2: It would provide useful perspective to give a typical portion of PM mass thatcannot be speciated at present. It is often the majority of mass, not a tiny portion. That would bea surprise to most people.P 9-20, L 3-4: State the time period of the children’s health study, or the information here is notuseful.P 9-21, L 5-6: It is not clear what you mean by saying that the amplitude of the peaks is smallerthan the daily means. That is not intuitive, and the reader (eg, me can’t understand yourstatement.A - 30
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Review of the Air Quality Criteria Document for Particulate Matter

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