- The Washington Times - Friday, November 30, 2012

Fewer than 1 in 5 Americans has any use for cigarettes nowadays, but here’s why the Obama Environmental Protection Agency (EPA) has made smoking important to us all.

The EPA plans to issue in mid-December more stringent air-pollution standards for fine particulate matter (PM2.5), soot and dust roughly the width of a human hair. The agency has determined that any exposure to PM2.5 can cause death within hours or days of exposure, and there is no safe exposure to PM2.5. Those claims are not without controversy.

The Clinton EPA first began regulating PM2.5 in 1997, setting an average daily limit of 15 micrograms per cubic meter of air. Now the Obama EPA wants to tighten the average daily limit to somewhere between 12 and 13 micrograms per cubic meter, even though the average U.S. air purity is at 10 micrograms per cubic meter and falling.

The EPA says the new standard will bring health benefits worth $88 million to $5.9 billion annually while costing just $2.9 to $69 million per year.


More than 98 percent of those claimed benefits are based on the EPA’s assertion that PM2.5 kills people and each death costs society about $9 million, regardless of age, remaining life expectancy, health status and income prospects.

So what’s all this got to do with smoking cigarettes?

The average adult inhales about 11,000 liters of air per day, equivalent to 11 cubic meters of air. Keeping in mind that indoor levels of PM2.5 easily can exceed outdoor levels. Assuming someone inhales average outdoor air all day, that person would inhale about 240 micrograms of PM2.5.

The EPA says smoking a single cigarette can expose a smoker to 10,000 to 40,000 micrograms of PM2.5. It would take a nonsmoker breathing average outdoor air something between 40 and 160 days to inhale as much PM2.5 as someone smoking a single cigarette.

To make this more interesting, let’s say someone smokes one half-pack of cigarettes per day for just one year. That person would have inhaled between 36.5 million micrograms and 146 million micrograms of PM2.5 during that year. It would take a nonsmoking average-air breather 417 to 1,668 years to inhale as much PM2.5 as the smoker.

What’s the practical significance of this thought experiment? Although smoking is not a healthful activity, the health risks associated with it are a matter of dose — i.e., the more one smokes, the greater the risk of health problems.

However, as reported in an October 2003 study published in the American Medical Association’s Archives of Internal Medicine, the risk of sudden death among those who smoked as long as 10 years was zero.

If you can smoke for 10 years and have zero chance of sudden death, you can breathe average U.S. air for thousands of years with zero risk of sudden death. Given that the “worst” U.S. air has, perhaps, twice the level of PM2.5 as average U.S. air, you even could breathe the “worst” U.S. air for thousands of years with zero risk of sudden death.

Therefore, the EPA’s claim that PM2.5 is killing people and the nation stands to reap billion of dollars’ worth of health benefits from its new rule are without merit.

What’s the harm of cleaner air? Aside from the perpetuation of EPA junk science, as there likely are no health benefits from the rule, any cost is simply too much. While the EPA has capped compliance costs at a seemingly paltry $69 million per year, the agency has omitted mention of the more significant costs.

The proposed rules are national standards for air quality and, as such, do not prescribe specific emissions limits for, say, industrial facilities, vehicles, agricultural burning or residential wood-burning. The EPA, however, can punish states that fail to meet the standards by withholding the state’s federal highway money.

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