Our Lethal Air

Integrated Science Assessment for Particulate Matter (External Review Draft, 2018)

United States Environmental Protection Agency

Letter to EPA Administrator on the EPA’s Integrated Science Assessment for Particulate Matter, April 11, 2019

Review by the Chartered Clean Air Scientific Advisory Committee
Smog in Prayagraj, Uttar Pradesh, India, January 2019
Bloomberg/Getty Images
Smog in Prayagraj, Uttar Pradesh, India, January 2019

In December 1952 a dense, choking, particle-laden fog settled on London and didn’t budge for four days. So many people suffered respiratory problems, heart attacks, and strokes that the city ran out of hospital beds. Coroners and undertakers could barely keep up with the flow of bodies. A government analysis in the immediate aftermath estimated that the atmospheric muck—mostly produced by the burning of low-quality coal to heat homes—caused nearly four thousand deaths. In 2002 a more thorough analysis concluded that the “Great Smog” had killed 12,000 people, most of them over forty-five or very young.

Gary Fuller dedicates The Invisible Killer, his new book about the persistent global scourge of air pollution, to the smog’s victims, who “have no memorial.” But, as his own book makes clear, one could argue that their memorial is the United Kingdom’s Clean Air Act. Passed in 1956, in direct response to what Fuller calls “the UK’s greatest peacetime disaster,” it restricted the use of dirty heating fuels and established “smoke-free” zones where only smokeless fuels could be burned. Despite its flaws and halting implementation, the law heralded a new era of government action to clean up outdoor air, driven by the growing recognition that air pollution was more pervasive, more deadly, and more human-caused than had been assumed.

During the same period, people across the United States, from Los Angeles to Pittsburgh to New York, were growing tired of chronic coughs, driving with headlights on during noontime haze, and perpetually dusting soot from their windowsills. Under public pressure, politicians passed a series of modest clean air laws in the 1950s and 1960s. These paved the way for the 1970 Clean Air Act, a sweeping piece of legislation that required the newly created Environmental Protection Agency to use the best available science to set and enforce limits on six major pollutants at levels that would allow “an adequate margin of safety…requisite to protect the public health.”

Slowly, power utilities, car manufacturers, and other polluters were compelled to meet these new limits. The law gave the EPA the authority to control vehicle tailpipe emissions and fuel additives, and to require new power plants and industrial facilities to use the best available pollution-control technology. States were responsible for enforcement, overseeing permitting and issuing fines—but if states failed to meet air quality standards, the federal government could take over with its own plan. Gradually, overall levels of particulate matter, ozone, and other pollutants in the air began to decline. By the 1990s, many people in the US and other wealthy countries thought that sun-blotting soot and smog were hazards safely surmounted in the onward march of progress, concerns of a past era like polio or cholera.

It turns out the threat had simply become less visible. Nearly…


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