What's Wrong with the National Ambient Air Quality Standard (NAAQS) for Fine Particulate Matter (PM 2.5)?

Associations between airborne concentrations of fine particulate matter (PM 2.5) and mortality rates have been investigated primarily by ecologic or semiecologic epidemiology studies. Many investigators and regulatory agencies have inferred that the weak, positive association often observed is causal, that it applies to all forms of airborne PM 2.5, and that current ambient levels of PM 2.5 require reduction. Before implementing stringent regulations of ambient PM 2.5, analysts should pause to consider whether the accumulated evidence is sufficient, and sufficiently detailed, to support the PM 2.5 National Ambient Air Quality Standard. We take two tacks. First, we analyze the toxicologic evidence, finding it inconsistent with the notion that current ambient concentrations of all forms of fine particulate matter should affect pulmonary, cardiac, or all-cause mortality rates. More generally, we note that the thousands of forms of PM 2.5 are remarkably diverse, yet the PM 2.5 NAAQS presumes them to be identical toxicologically, and presumes that reducing ambient concentrations of any form of PM 2.5 will improve public health. Second, we examine the epidemiologic evidence in light of two related examples of semiecologic associations, examples that both inform the PM–mortality association and have been called into question by individual-level data. Taken together, the toxicologic evidence and lessons learned from analogous epidemiologic associations should encourage further investigation of the association between particulate matter and mortality rates before additional regulation is implemented, and certainly before the association is characterized as causal and applicable to all PM 2.5.