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(CASAC) Peer Review of EPA's Integrated Science Assessment

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Dr. Richard SchlesingerComments on SOx ISA – 2 nd DraftOverall, the 2 nd draft improves on the 1 st in integrating the various disciplines. However,there is still room for improvement in some <strong>of</strong> the sections as noted below. In manycases, the various disciplines are not really integrated but rather separate discussions <strong>of</strong>each are just placed in the same section. A true integration would interweave the epi withmechanistic support from the controlled studies.The inclusion <strong>of</strong> a section on mixtures, i.e., 3.1.5, is an improvement, but it is not clearwhy that section was placed where it was. I think that a section on mixtures and thepotential for interaction related to all health outcomes from SO2 for all exposurescenarios should be developed and placed at the end <strong>of</strong> the chapter prior to theConclusions.Table 5-3 is excellent and provides a very nice summary overview <strong>of</strong> the conclusions <strong>of</strong>the ISA and comparison to the previous Criteria Document.Specific Issues1. Section 3.1.3 is titled, Respiratory Effects Associated with Peak Exposure. Inreality, this is a discussion <strong>of</strong> studies that involve exposures for 1 hr or less tosingle levels <strong>of</strong> SO2 without any baseline in animal and human clinicalevaluations. Thus, the use <strong>of</strong> the term peak may be misleading since this mayimply some higher level relative to some lower baseline. This section should alsobe renumbered as follows:3.1.3.1 Clinical Studies3.1.3.2 Animal Studies2. Section 3.1.4 discusses Epi studies and this should be reflected in the sectionheading. Furthermore, lines 7-21 on page 3-17 should be moved to section 3.1.2.3. Section 3.1.4.3 is an attempt to integrate animal, human clinical and epi studies.4. Page 3-48, lines 15-17. The inconsistency may be due to the fact that the specificnature <strong>of</strong> the interaction may depend upon the specific co-pollutant.5. Section 3.1.6 seems to be out <strong>of</strong> place here. Perhaps the material could beintegrated into other sections.40

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