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 U.S. ENVIRONMENTAL PROTECTION AGENCY

 CLEAN AIR SCIENTIFIC ADVISORY

 COMMITTEE (CASAC) LEAD REVIEW PANEL

 PUBLIC MEETING

 HILTON GARDEN INN RALEIGH-CARY

 CARY, NORTH CAROLINA 27518

 FEBRUARY 5, 2013

Court Reporter:

Wanda L. Greenlee, CCR

Missouri CCR #1188

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711 North Eleventh Street

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(314) 644-2191
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1 (WHEREIN, meeting convenes at 8:32 a.m.)

2 MR. YEOW: So good morning. I'm Aaron

3 Yeow. I'm the designated federal officer of the DFO for

4 this public meeting of the Clean Air Scientific Advisory

5 Committee Lead Review Panel. I'd like to convene and open

6 this public meeting with a short statement.

7 The panel's meeting today and tomorrow is

8 to conduct a peer review of EPA's draft of integrated

9 science assessment for lead and draft policy assessment

10 for lead. I'd personally like to acknowledge and

11 congratulate Dr. Christopher Frey for being selected as

12 the new chair of the charter CASAC.

13 CASAC is a federal advisory committee. And

14 by EPA policy, its meetings and deliberations are held as

15 public meetings that meet the requirements of the federal

16 advisory committee act, also known as FACA. Through the

17 charter CASAC, the panel's empowered by law to provide

18 advice to the administrator.

19 Consistent with the requirements of FACA

20 and with EPA policies, the deliberations of the panel are

21 conducted in public -- at meetings for which advanced

22 public notice is given. The discussions and substantive

23 deliberations of the panel, its interactions with the

24 public and the agency are conducted in sessions where I,

25 as the DFO, am present to ensure that the requirements of
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1 FACA are met.

2 This includes requirements for open

3 meetings for maintaining records of deliberations of the

4 panel, making available to the public summaries of

5 meetings and providing opportunities to the public

6 council.

7 We did not receive any written public

8 comments, and we do not have any registered public

9 speakers. However, there will be an opportunity for the

10 public to provide clarifying remarks toward the end of the

11 discussion of the ISA and, of course, at the end of the

12 discussion of the PA.

13 So for that -- I think on our agenda we --

14 and Chris can cover this while we're on the agenda. But

15 at the end of the discussion of ISA today, so that will be

16 at noon, there will be an opportunity for the public to

17 provide clarifying remarks on the ISA.

18 So just notify me by e-mail or come up to

19 me, I would say probably by 11:30, to let me know if you

20 would like an opportunity for that. Minutes of this

21 meeting are being taken to summarize discussions and

22 action items in accordance with the requirements under

23 FACA. These minutes will be certified by the chair once

24 completed.

25 I want to remind all in attendance today of
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1 the status of this panel's compliance with federal ethics

2 laws. The SAB staff office has determined that there are

3 no issues of conflict of interest or an appearance of a

4 lack of impartiality for any of the advisory panel members

5 participating in this review.

6 And as many of you know, Dr. Vanessa Vu,

7 our previous SAB staff office director, has retired. And

8 Dr. Christopher Zarba here is our acting director now, and

9 we also have Mr. Thomas Brennan as our deputy director.

10 So I'd now like to turn the meeting over to

11 Mr. Thomas Brennan, deputy director of the SAB staff

12 office, then over to Dr. Christopher Zarba, acting

13 director of the SAB staff office, and then over to

14 Dr. Christopher Frey, chair of the CASAC.

15 MR. BRENNAN: All right. Thanks, Aaron.

16 I'm Tom Brennan. I'm the deputy director of the SAB's

17 advisory board. I'd like to thank the panelist for taking

18 time out of their personal and professional lives to

19 provide this public service. We very much appreciate your

20 efforts. Getting science advice from the CASAC is really

21 important to the agency and ultimately to the American

22 public. So, again, thank you very much for your efforts

23 and for your energy.

24 And I'd like to thank the EPA team that

25 made this possible. All the hard work it takes to get to
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1 a moment like this, and I know how hard they've all

2 worked, and that also is appreciated.

3 Like Aaron said, this is our first meeting

4 without Vanessa. And, you know, Vanessa had a 30-plus

5 federal career, 30-plus years and the last ten as our

6 director. And Aaron and I and a couple of other people

7 said -- you know, had the moment this morning like, What

8 would Vanessa do? And we kind of smiled. And we said,

9 You know, we just can't do it the way she did it. So we

10 just had to let it go.

11 But her attention to detail and her

12 commitment to these FACA committees, this one, the SAB and

13 the council was really remarkable. And she definitely

14 left a legacy and an imprint on all of those that worked

15 for her. So we're definitely going to miss her, and we're

16 thinking about her today. And happy for her retirement.

17 But, also, very excited to introduce our --

18 like Aaron said, our new director, Christopher Zarba. And

19 I know he'd like to say a few words, so I'll just turn it

20 over to Chris.

21 MR. ZARBA: Thanks, Tom and Aaron. First

22 of all, it's Mr. Christopher Zarba.

23 MR. BRENNAN: Oh, I'm sorry.

24 MR. ZARBA: I earned it the hard way. I

25 asked Aaron for a few minutes just to introduce myself to
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1 you. I think today is Day 8 in my position as acting

2 director of the SAB. I thought it would be worth just

3 spending a few minutes to give you a little bit about who

4 I am, why I'm here and what I hope to accomplish.

5 I've been with the agency for over 30 years

6 too, and I've worked in a variety of programs within the

7 office of water, within the Superfund, in and out of the

8 water and ORD a few times. I was chief of staff to the

9 research office for 3 AA's.

10 And over the last seven or eight years,

11 I've been both acting director and director of the

12 National Center for Environmental Research. That's the

13 extra grants portion of the research program. And

14 hopefully some people here have received star grants.

15 So it's a job that I really enjoy. About

16 the only thing that I've been consistent through my career

17 is that I've worked very closely with the SAB throughout

18 my entire career. And very early in my career I had the

19 pleasure of working with Dr. Herb Allen here. We were

20 both on the other side of the fence in developing new

21 types of criteria for the office of water. It was a very

22 unique time that we had a very interesting mix of

23 academics, ORD scientists, program office and contractors.

24 We took on what I consider some of the

25 toughest remaining environmental issues left, and it was
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1 an amazing process. I wish I was, at that time, bright

2 enough to see the value of the SAB; I wasn't. But I had

3 very good advisors and coaches, and I lived the experience

4 of taking on very difficult issues. We had the -- a

5 variety of people who were against what we were doing.

6 We worked very hard. We used the SAB in

7 all the best sense. We knew we were going to be in front

8 of the SAB. We planned our research knowing that we would

9 have to pass that test before we even got to the SAB. We

10 had consultations. We listened to the advice. We

11 followed the advice we got from the SAB. And I had the

12 pleasure of using the SAB findings when the inside EPA

13 would call every month and say, you know, according to so

14 and so, so and so, they said this.

15 And I would always have my SAB report and

16 could take quotes right out of it, saying, Well, according

17 to the Science Advisory Board -- and this is the truth.

18 And I was amazed at how powerful having that document in

19 my hand was and how effective it was in helping the agency

20 make real changes. So according to Vanessa, I drank the

21 Kool-Aid early on in life, and I've always been an

22 advocate for that.

23 And most recently, in the interim, we

24 worked with the SAB on the state awards, and I've been an

25 advocate for getting the environmental justice technical
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1 guidance in front of the SAB. So it's a thrill to be

2 here. When I was in the interviews they asked me, you

3 know, why I wanted the job and was I not happy where I was

4 at. I said, No. I actually loved the job I was at. I

5 had a great boss and a great staff. And I really would be

6 thrilled if they didn't give me the job, I could get to go

7 back to that job I really loved.

8 Well, then they said, Well, why do you want

9 this job? And I said, Because I know of no place where a

10 handful of people can have more of an impact on the

11 effectiveness and the credibility of the agency than the

12 SAB. And I absolutely believe that.

13 So I'm here for selfish reasons. I want to

14 be part of that. I know what it feels like to make a

15 difference. So I'm here because I really believe in the

16 SAB, and I want to do what I can to keep that -- what

17 Vanessa has kept going, to keep it going and even bring

18 some new ideas to the table.

19 I think the challenges for the agency are

20 going to be tougher in the future. Money is getting

21 short. The scrutiny is going to get tougher, and I think

22 we always have to be looking at how we can do things

23 better.

24 So I know I've only been here for eight

25 days, but I want to give you a few ideas of the kind of
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1 things I'm thinking about and would like to have dialogue

2 with the staff, with other parts of the agency and with

3 you-all about what we can do in the future to make the SAB

4 as effective as possible.

5 And one of those areas is on the perception

6 or the reality of the balance in the panels. So Part 1 of

7 that would be there are things we do -- and much of this

8 I've just learned in the last week -- in the SAB, staff,

9 to ensure we have a balanced panel.

10 Much of what we do is not shared. So the

11 public will not know the steps that we have taken, whether

12 they were successful or unsuccessful in sharing a balanced

13 panel. And I think there's value in the public knowing,

14 whether we were successful or not, the things that the

15 science advisory board tried to do to make sure that panel

16 was balanced.

17 Secondly, I think we need to do more

18 outreach to ensure that when we do have open season in

19 getting the panel members that it's not good enough just

20 to see who applies. That I personally and others on the

21 staff will be going out to different groups through our

22 conversations about how they can serve and why it's

23 important and encouraging people to do so.

24 Another area that I think is right for

25 improvement, and I think this is maybe where I would be
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1 most effective, is in encouraging all parts of the agency

2 to identify areas early on where an SAB involvement would

3 be most beneficial.

4 Right now, in many cases, it's a volunteer.

5 If you think you need a review, you can go to the SAB.

6 And all too often, those areas, those efforts that the

7 agency's taking on that are in the most need of review are

8 the least likely to step up to the plate.

9 And some of you know that ORD has gone

10 through a massive reorganization. We now are structured

11 quite different. We have a national program directors.

12 These are Title 42 super-grade positions, and they play a

13 very different role at integrating science across the

14 Office of Research & Development across the agency.

15 And I think those Title 42 national program

16 directors and others across the agency can help us do a

17 better job of identifying early on those areas where we

18 need an SAB review to actually send away teams to those

19 organizations to have consultations with them and get them

20 into the process sooner so the risks of having problems

21 down the road are less. And also to get to their

22 management that if they are reluctant, that we can make

23 the case early on why they need to be thinking about this

24 and the risks are limited.

25 So those are just some of the things I'm
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1 thinking about. Obviously, I've got more homework to do

2 on that. We'll be talking to a lot of people. But I

3 think a collection of those things -- and there's probably

4 others that we can pursue that -- to help keep the SAB as

5 effective and based as possible.

6 So that's a quick summary. I guess I've

7 got a couple of minutes, Aaron, for a few questions or

8 comments. Is that okay?

9 MR. YEOW: (Nodded head.)

10 MR. ZARBA: Does anybody have any

11 questions?

12 (No response.)

13 MR. ZARBA: Well, it's a pleasure to be

14 here. It's nice to see familiar faces, and there's some

15 new faces that I hope to get acquainted with. Sir.

16 DR. VON LINDERN: I have a comment.

17 MR. ZARBA: Sure.

18 DR. VON LINDERN: First, we all certainly

19 miss Vanessa, and she did a great job. And so -- but I'm

20 heartened by your comments. And I'll have some comments

21 within my comments that reflect why. And that's because

22 having been here for almost 40 years on these committees,

23 I think the process has lost something during those years

24 that you discussed, and I'm happy to see that someone is

25 going to bring those back because this is a wonderful
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1 process that serves far beyond these documents. And the

2 criteria documents that were produced were seminal for

3 globally and every country for effecting a good elect

4 policy.

5 And I'd especially like to comment on the

6 balance of the panel because I miss the industry. We

7 don't have the other side here like we used to, and we

8 don't have the -- you know, the code and the frank civil

9 discussions around the facts that this, this forum brought

10 out.

11 And I'm heartened by your comments that the

12 agency can go back to that kind of process where the board

13 really serves as a place to work out the issues that the

14 country faces so that EPA can respond in more ways than

15 just a single document. So thanks.

16 MR. ZARBA: All right.

17 DR. FREY: Good morning. This is a

18 seasoned panel, and I guess I want to echo some of the

19 things we've heard earlier in terms of welcoming

20 everybody. Welcome, of course, to the panel members who

21 have devoted a lot of time. And you're all very busy

22 people, but this is obviously an important public service.

23 So it is a quite valuable service to the nation that we're

24 engaged in.

25 I do want to echo that, you know, in the
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1 retirement of Vanessa, I think she's been a tremendous

2 mentor to me. And I certainly conveyed to her directly my

3 high regard for her and best wishes for her retirement.

4 And I think that's likely to be a shared view among many

5 of us.

6 But I am happy to welcome Mr. Brennan and

7 Mr. Zarba here today. It's wonderful that they're here to

8 share their time with us. And I think some of the

9 comments Mr. Zarba made and that Dr. von Lindern picked up

10 on are, in fact, quite encouraging. And there are a few

11 remarks I have that I think will touch on some of these

12 issues as well.

13 What I would like to do is, we

14 traditionally have a brief round of introductions, just to

15 go around the table for the panel members to just say

16 their name and affiliation so we know who's here. And I

17 would like to do that.

18 And then I'll talk a little bit about the

19 -- I actually want to take a minute to talk about the

20 charter of CASAC because this brings up some issues that

21 follow onto what Mr. Zarba had to say and that also will

22 help frame our discussion over these next day and a half.

23 And then we'll talk about the agenda specifically.

24 So let me go ahead and go around the table,

25 starting with Dr. Johnson, if you -- and if each of you
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1 would just say your name and affiliation.

2 DR. JOHNSON: Chris Johnson, Department of

3 Civil and Environmental Engineering at Syracuse

4 University.

5 MR. POIROT: I'm Rich Poirot. I'm with the

6 Air Program and the State of Vermont Agency of Natural

7 Resources.

8 DR. CANFIELD: I'm Rick Canfield, Cornell

9 University, Division of Nutritional Sciences.

10 DR. KORRICK: I'm Susan Korrick, Department

11 of School Public Health and Department of Environmental

12 Health.

13 DR. KOSNETT: Michael Kosnett, the Division

14 of Clinical Pharmacology and Toxicology at the University

15 of Colorado School of Medicine, also a member of the

16 Department of Environmental and Occupation Health at the

17 Colorado School of Public Health.

18 DR. FREY: This reminds me. One of the

19 real purposes of this is to get you practicing using the

20 microphones. So make sure you use the microphone.

21 DR. VON LINDERN: He brings that up right

22 in front of me. I'm Ian von Lindern. I'm an

23 environmental engineer with TerraGraphics Environmental

24 Engineering from Moscow, Idaho.

25 DR. POUNDS: I'm Joel Pounds, Assistant
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1 Toxicology Department at the Pacific Northwest National

2 Laboratory.

3 DR. LANNO: Roman Lanno, Ohio State

4 University, Department of Evolution, Ecology and

5 Organismal Biology.

6 MR. ALLEN: George Allen from NESCAUM in

7 Boston.

8 DR. CORY-SLECHTA: I'm Deborah Cory-Slechta

9 from the University of Rochester Medical School.

10 DR. HAYS: Sean Hays from Summit Toxicology

11 located in Allenspark, Colorado.

12 DR. ALLEN: I'm Bert Allen from the

13 Department of Civil and Environmental Engineering and the

14 University of Delaware.

15 DR. RABINOWITZ: I'm Michael Rabinowitz.

16 I'm retired as a geochemist, but MBL lets me still use the

17 e-mail address.

18 DR. WASSERMAN: Gail Wasserman, Child

19 Psychology, Columbia University.

20 DR. HOPKE: Phil Hopke, Institute for

21 Sustainable Environment, Department of Chemical and

22 Biomolecular Engineering at Clarkson University.

23 DR. WEITZMAN: Michael Weitzman from the

24 Departments of Pediatrics Environmental Medicine and

25 Psychiatry, NYU School of Medicine.
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1 DR. DAVIDSON: Cliff Davidson from the

2 Department of Civil and Environmental Engineering at

3 Syracuse University.

4 DR. FREY: Okay. And I'm Chris Frey from

5 the Department of Civil Construction and Environmental

6 Engineering at North Carolina State. So thanks again to

7 all the members of the panel. We have a tremendous depth

8 and breadth of multidisciplinary expertise on this panel,

9 and so I -- it's always a privilege to serve with such an

10 esteem group of people.

11 I wanted to take a minute to talk about the

12 charter of CASAC, just to review it briefly. CASAC is a

13 scientific technical advisory committee, and it's

14 chartered under the Clean Air Act, Section 109-D. So our

15 mandate kind of stems from a statute or -- of federal law.

16 And under the CASAC charter, which is

17 submitted to congress periodically, our charter is that we

18 will review the criteria published under Section 108 of

19 the Clean Air Act and the national primary and secondary

20 ambient air quality standards and recommend to the

21 administrator any new National Ambient Air Quality

22 Standards and revisions of existing criteria and standards

23 as may be appropriate. And I think, in some ways, this

24 has been our main focus as a panel.

25 We also advise the administrator in areas
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1 where additional knowledge is required to appraise the

2 adequacy and basis of existing new or revised standards.

3 We will describe the research efforts necessary to provide

4 the required information. We will advise the

5 administrator on the relative contribution to air

6 pollution concentrations of natural as well as

7 anthropogenic activity.

8 And we will advise the administrator of any

9 adverse public health, welfare, social, economic or energy

10 effects which may result from various strategies for

11 attainment and maintenance of standards.

12 And the reason I mention this is that I

13 think we tend to focus on some of these more than others,

14 and there is some broader discussion that I don't think

15 will be fully resolved at this meeting about how CASAC

16 should, I guess, operationalize to maybe more fully

17 address its full charter.

18 So I think we tend to focus quite a bit on

19 the review of existing standards and revisions among the

20 existing standards. But we do have the charter to

21 recommend any new national standards, if we choose to do

22 so. We certainly can advise the administrator on areas

23 where new knowledge is needed. And that includes advising

24 on research, if that's, you know, relevant to a particular

25 panel or, you know, review topic.
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1 And I think in this context of lead, of

2 course, we talk quite a bit about the relative

3 contribution to air concentrations of natural and

4 anthropogenic and even legacy issues and multimedia

5 issues. So I think we address that nicely.

6 In the context of this panel, with the last

7 part of our charter, which is advising -- essentially

8 regarding implementation of a standard, we've had quite a

9 bit of discussion about the measurement methods for

10 monitoring of lead.

11 And one might argue that's an

12 implementation issue, but we also do have the charter to

13 advise of adverse effects which could result from

14 strategies for attainment and maintenance of a standard.

15 I will note that typically, you know,

16 panels like this require a foundation of something to

17 review that usually originates from the agency. And I

18 think this is an ongoing discussion about what would we

19 like to do going forward to more fully address our

20 charter, especially regarding implementation.

21 And I should mention this is a public

22 comment that came up in the context of the ozone review

23 panel, and so it is something that we've had some

24 administrative discussion on within CASAC. And I'm

25 anticipating, and maybe this is something we can confirm
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1 that -- at the July meeting of the ozone panel, which will

2 include all seven members of the statutory CASAC that we

3 will have an opportunity for some discussion with EPA on

4 some of these issues.

5 I want to point out that the strategy that

6 we use -- or the procedures we use here in terms of an

7 ISA, an REA, a PA, integrated science assessment, risk and

8 exposure assessment, policy assessment, are not

9 specifically mandated under the Clean Air Act or under

10 their charter, but these are operationally ways that we

11 receive information from the EPA and we provide feedback.

12 And I mention that, in part, because

13 there's no specific obligation on the part of the panel to

14 formally approve any of these documents, and it's also not

15 necessarily that our sole charter is to review such

16 documents. Our charter is broader than that.

17 So there may be some issues that come up in

18 the conversation here that go beyond the documents. And

19 as long as they're within our charter, I would tend to

20 support those discussions. So I just wanted to orient you

21 a little bit.

22 And this is kind of a complex issue of our

23 scope. And as the incoming chair of CASAC, this is

24 something that I wanted to kind of review both with the

25 charter CASAC, which I've done, and also with the panels.
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1 And as another comment, as I'm sure has

2 been explained when each of you agreed to serve on the

3 panel, there's a slight distinction between the panel and

4 the statutory CASAC. Just like in SAB there's a

5 distinction between panels and the formal SAB.

6 So in a sense, this panel is advisory to

7 CASAC and includes two CASAC members on the panel. But I

8 will tell you that seven-member CASAC relies very heavily

9 on these panels to provide the science advice.

10 So going forward, looking beyond this day

11 and the next day, we will have a process of developing the

12 written response to charge questions to the ISA and the

13 policy assessment and a draft letter to the administrator

14 on each of those that will eventually undergo what's

15 called a quality review by the chartered CASAC.

16 Okay. So then this segways into the

17 agenda. And I'll go through that, and then I'll pause and

18 see if there are any questions before we get into the next

19 part of the agenda.

20 But the agenda, we have a pretty aggressive

21 agenda. This morning, before lunch, we plan to finish our

22 review and discussion of the third external review draft

23 of the integrated science assessment. So in our

24 discussions, as I think we're well-aware, we have a lead

25 discussant on each charge question and several additional
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1 discussants.

2 And for purposes of preparing the response

3 to charge questions and the letter, it's critically

4 important that any points that we would put in those

5 written documents have been discussed in public.

6 And that's just a Federal Advisory

7 Committee Act requirement. So we cannot make any written

8 recommendations to the administrator that was not

9 presented in public and embedded in a discussion with this

10 group.

11 So anything that you think is important

12 that should rise to the level of a sentence or a paragraph

13 in the response to the charge question that goes to the

14 administrator, please bring it up.

15 On the other hand, if you have things that

16 are, you know, typos or minor editorial revisions, please

17 do not bring those up because we need to manage our time

18 efficiently.

19 I think we've all been through this

20 process. I think we're all pretty well calibrated on

21 what's important and what needs to be discussed. So I

22 don't think I need to belabor that.

23 But we do have a pretty aggressive agenda

24 for about 20 minutes per charge question on the ISA after

25 the EPA's presentation. So just be mindful of that as you
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1 make your comments. And it's important that we have

2 enough time to discuss the policy assessment, which we

3 will hear a presentation on after lunch. And then we will

4 begin to discuss the responses to charge questions on

5 that.

6 I think -- I'm sure I'm not misrepresenting

7 the EPA's hopes and expectations that if all goes well,

8 the EPA would hope that this is the last external review

9 draft of the ISA. And -- but it's important to point out

10 that EPA is proposing that this first external review

11 draft of the policy assessment is the only version that we

12 would be reviewing and that the next version, they

13 propose, would be the final version. And so EPA is

14 proposing, in fact, that this would be our last

15 face-to-face meeting as the lead review panel for this

16 review cycle.

17 So it's especially important that we give

18 EPA the full benefit of our advice on the policy

19 assessment, and we can reserve judgment on whether we feel

20 we've reached closure on that as we get to the end of that

21 discussion.

22 But just please be mindful that -- you

23 know, if things go as some hope, then this would be our

24 last opportunity to provide detailed feedback. And I will

25 say, in terms of advising the administrator on the lead
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1 standard, this is our kind of big opportunity to advise

2 the administrator on the indicator, level of form and

3 averaging time of the lead standard, both for the primary

4 and secondary standards. And so in some sense, that's the

5 bottom line culmination of everything we've been doing

6 over the last couple of years.

7 Okay. Let me pause and just ask, Are there

8 any questions? Yes, Dr. Allen.

9 DR. ALLEN: Can I change the tone for one

10 second?

11 DR. FREY: Sure.

12 DR. ALLEN: First of all, I promised our

13 chair that if I decide this meeting should be terminated

14 early, I will do it by making a motion.

15 Secondly, I do want to thank some of the

16 committee members specifically for the help that they

17 rendered at the last meeting. It's sometimes useful to be

18 on a panel that has a number of physicians on it in

19 attendance. And that was quite helpful, and I do thank

20 everybody for that, for their help.

21 DR. FREY: Yes. Thank you. Well, we're

22 delighted you're here too. Any other comments or

23 questions before we move on?

24 (No response.)

25 DR. FREY: Okay. All right. Excellent.
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1 With that, we are now at the point in the agenda where EPA

2 will deliver a presentation on revisions to the draft by

3 an integrated science assessment, and that's followed by a

4 public comment. I am -- we don't have any public

5 commenters listed, so I think we're still okay on time.

6 We would like to start the charge question discussion at

7 9:30.

8 There is an opportunity for public comment,

9 by the way, at the end of each of our major agenda items.

10 So at the end of the morning we do have an opportunity for

11 clarifying comments from the public regarding the ISA.

12 And then we have opportunities for public comments

13 tomorrow afternoon after our discussions to the policy

14 assessment.

15 So if anyone is interested in making public

16 comment, please contact Dr. Aaron Yeow to get on the --

17 there's a list. I'm sorry, Mr. Yeow. We're promoting

18 many people, I guess, or giving out degrees today. So

19 Mr. Aaron Yeow. Okay. With -- and I'm going to turn the

20 mic over briefly to Dr. -- or Mr. Yeow and then to

21 Dr. Vandenberg.

22 MR. YEOW: I forgot to mention, Dr. Philip

23 Goodrum will be joining us by the phone sporadically, so

24 just to let you know that. And Dr. Stubblefield was not

25 able to participate. Okay, John.
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1 DR. VANDENBERG: Thank you very much. My

2 name is John Vandenberg, and I'm the director of the

3 Research Triangle Park Division of the National Center for

4 Environmental Assessment. And I also would like to extend

5 our appreciation to the panel for an incredible amount of

6 work. This is a significant effort from very busy people,

7 and your expertise and your pre-meeting comments have

8 been, as always, very helpful to us. We appreciate that.

9 As expected, this is, perhaps, our last

10 meeting with you in terms of discussing the integrated

11 science assessment, which I have my fingers and toes

12 crossed here. And we very much want to use this

13 opportunity to say how much we appreciate your time and

14 expertise.

15 I'd also like to extend my welcome to Chris

16 Zarba for joining the SAB staff. It's tough shoes to

17 follow for Vanessa. I think the entire time I've worked

18 with CASAC has been with Vanessa, and so it's -- we

19 welcome you. Of course, Chris, I've known you for many,

20 many years. So I appreciate that. I'm glad that Tom's

21 here. And, of course, Aaron, the sustained support from

22 you is very much appreciated.

23 While I'm thinking about thanking people, I

24 would like to note the staff along the back and along the

25 walls here, our principal EPA people -- not all, but
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1 they've been fundamental to the development of this

2 document, both the folks within the Office of Research and

3 Development as well as the colleagues in the Office of Air

4 Quality Planning and Standards and also General Council.

5 I had the pleasure last week of presenting

6 to a workshop in the European Commission and then the

7 European Provident about the way this process works with

8 CASAC, with the agency, both with Office of Research and

9 Development, with Office of Air and Radiation and with

10 OGC.

11 And it was used as a model both by myself

12 as well as Janet McCabe, who is the deputy assistant

13 administrator for the Air Office, as how science and

14 policy can work well together with a great benefit of

15 external peer review. And it was highlighted both by me,

16 by Janet McCabe and also by John Sammut who was there, who

17 was Chris's predecessor as the chair of the CASAC, that he

18 presented to the European Parliament members as, again, an

19 example of how the United States was doing this because we

20 benefit so much from having scientific expertise and

21 perspectives from CASAC.

22 So it was very well received by the

23 audience that were just principally Europeans looking at

24 how they can look at this year, which is the year of err

25 in the European Union as a way to move forward in terms of
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1 their standards as well. It's a lot of what's going on in

2 Europe as well now. They're looking at what we do here

3 very much.

4 So what I would like to do to move forward

5 is, in addition to introducing the staff on the sides and

6 in the back, is also Mary Ross is to the side. She is the

7 branch chief for the group that develops the integrated

8 science assessments. And then Ellen Kirrane who's our

9 team leader for lead assessment as well. So I'm very

10 pleased and honored to be working with these people as

11 well with all of you on the CASAC.

12 Where we are in terms of the timeline is

13 we're meeting today to discuss the third draft and your

14 comments on that, moving towards final revisions later

15 this summer, is what we anticipate. Again, we very much

16 benefit from the written comments and the summary letter

17 that the CASAC will provide to the administrator in moving

18 towards that.

19 It takes several months to consider your

20 comments. We already have gone through them and find a

21 number of very, very helpful points, many of which we, you

22 know, immediately embraced as these are helpful to improve

23 the documents. So we're excited about the benefit we get

24 from your perspective as well as this anticipated end of

25 the timeline for us.
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1 What this doesn't show, which you'll be

2 seeing later today, is the rest of the story in terms of

3 the development of the further timeline, which is the

4 policy assessment and the final rulemaking of the Office

5 of Research and Development staff. We stay involved in

6 this all the way through the very end. So while we may

7 not be prominent in the discussions that go forward, we

8 are very much supportive of the agency's rulemaking

9 procedures.

10 This is the team. Again, you can see it's

11 a large team. It takes a lot of people to create a

12 document, to review a document. In some sense, you're our

13 external team here. Again, we appreciate those efforts.

14 The ISA has been revised in consideration

15 of your comments on the second draft, and Ellen Kirrane

16 will be going through the revisions -- the highlights of

17 those revisions to give you some level of detail.

18 One of the things that has changed here --

19 there's a number of things that keep changing -- is we're

20 trying to give somewhat more detail in terms of what we

21 have done in terms of changing the document.

22 And in our response back to your comments

23 in the second draft, we've provided some pointers, if you

24 will, pointing to where we have made specific changes in

25 certain sections to help you in your review. It's a
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1 substantial document, and we thought that would be helpful

2 to you. Again, I thank Dr. Frey for his suggestions to be

3 a little bit more specific than we have been in the past.

4 In terms of the legislative historical

5 background, as an example, we have added more of the pre

6 -- earlier history, if you will, as one of the comments

7 that we will see. And, again, I think that this provides

8 us with a coherent and comprehensive historical document

9 that reflects both the state of the science as it is now,

10 but also gives that context of how we've gotten here in

11 terms of the state of the science of lead for many, many

12 decades now. It's really quite an amazing story.

13 What I would like to do now is turn to my

14 colleague here, Ellen Kirrane, and she will go through and

15 highlight the major revisions that we've made to the

16 different chapters of the document. Ellen.

17 DR. KIRRANE: Thank you. So we have gotten

18 conclusions now from specific health endpoints in this

19 draft, and this is representative of a pretty major change

20 to the document. And we'll be considering ways to

21 optimize the endpoint groupings in light of today's

22 discussion as well as the written comments.

23 And we've also enhanced critical review of

24 the studies as well as the transparency of the application

25 of the framework for causal determinations. We've updated
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1 Chapters 1 and 2 reports to reflect the changes that were

2 made to Chapters 5 and 7. But I'll cover more of the

3 details of those revisions when I talk about the later

4 chapters, even though the comments were received in these

5 chapters.

6 With regard to Chapters 1 and 2, we've

7 revised the language in the executive summary to be a

8 little bit more accessible to a non-technical audience and

9 added more cross-references because I think the Document

10 16 pages, hopefully it helps navigate.

11 So starting with Chapter 3, we've added a

12 lot more cross-references. And what we did was focus on

13 references between Chapters 3 and specifically 4.1 of

14 Chapter 4, which is the exposure section. For the source

15 section, we revised to clarify the relative contribution

16 of different sources of lead.

17 For example, we had Figure 3-5 that shows

18 point source facilities and airports estimated to emit a

19 half of ton or more per year when comparing the two.

20 And Figure 3.6, we have five-year totals,

21 in tons, for mining, production and imports and exports.

22 That was something that was done in the 1986 AQCD, and

23 we're able to update those figures.

24 For the Section 3.4, the monitoring

25 section, we have expanded both the table and the
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1 discussion of PM samples available for lead sampling.

2 In Section 3.5, the section on Ambient Air

3 lead Concentrations, we have moved a lot of the detail to

4 the appendix to improve the readability and brought back

5 modified versions of the tables that compare the

6 co-located lead measurements for different sampling size

7 cuts. We also have both the Pearson and the Spearman

8 correlation coefficients in the text sections of the

9 appendix that go with the section, lead in a

10 Multipollutant Context, and we've streamlined the

11 background section to focus on natural background.

12 Moving on to Chapter 4. This is the

13 chapter on Exposure, Toxicokinetics and Biomarkers. We've

14 clarified differences between the size distributions and

15 ambient air and lead and soil and dust. We've also

16 expanded the discussion of the contribution of air-related

17 exposure to total lead exposure; included more links

18 between Chapter 3 and Chapter 4, again.

19 We've expanded the discussion of the

20 relationship between lead exposure and biomarkers, and

21 also expanded discussion of blood lead, air lead

22 relationship as well as the uncertainties relating to

23 those air-to-blood slopes.

24 This is an example of a new figure that was

25 included in Chapter 4. The figure on the left actually
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1 appeared in the first and the second drafts of the lead

2 ISA. It's Figure 4-11. And it shows a rapid decline in

3 the blood concentrations and subsequent return to baseline

4 levels following a period of elevated lead exposure.

5 And to respond to CASAC comments that the

6 ICRP lead biokinetics model wasn't consistent with

7 literature showing persistently elevated blood lead

8 following a period of high exposure. We added Figure

9 4-12. And this figure, you can see on the right, there's

10 a different scale. What it shows is that the model does

11 predict a more gradual reduction in blood lead following a

12 period of extended high exposure.

13 This is another figure that we've added to

14 Chapter 4. We expanded discussion of uncertainty in the

15 air-to-blood slopes as well as implications of particular

16 slope on predictions blood lead. This figure is actually

17 a modified version of the set of figures that were

18 provided in the CASAC comments on the second draft.

19 And we chose these three slopes because

20 they were used in evaluating their related IQ loss of

21 children in the 2008 final rule for the lead NAAQS. And

22 it shows the air -- the impact of these air-to-blood

23 slopes on the estimated change in air-related blood as a

24 function of change in the air lead.

25 And we also included a new table, it's
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1 Table 4-14, to demonstrate the effect of a child's age on

2 air-to-blood slopes. And we used a perspective study in

3 Mexico, Schnaas, et al., to create that table.

4 Moving on to Chapter 5. We've expanded the

5 critical assessment of the individual studies. For

6 epidemiology, this meant focusing on study design and

7 methods, potential confounding as well as reverse

8 causation. We've added details to the text and the table.

9 That should be evident in the redline version. And we

10 have strengthened the critique of the study design and

11 outcome ascertainment for ADHD in particular.

12 We have added discussion of potential

13 confounding by nutritional status and for hematological

14 and developmental effects, and we talk more about

15 potential for the reverse causation in both the renal and

16 the immune effects chapters.

17 For toxicology, we have made sure that it's

18 evident that we're focusing on the oral routes of exposure

19 and concentrations within one order of magnitude of human

20 blood lead levels, and the one order of magnitude is

21 described in more detail on Page 2-3 of the document.

22 And we talk about the animal toxicology

23 studies there, and the majority are below about 25 to 30.

24 We're not using that cut point of 10. These factors were

25 also evaluated and sort of drawn on more specifically as
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1 we documented our conclusions in the tables of causal

2 determinations.

3 We've also improved -- or implemented

4 comments to improve integration and synthesis in the

5 health chapter. We've incorporated advice from experts in

6 neuropsychology and neurotoxicology that appeared on the

7 third slide. We've asked for their help on categorizing

8 the nervous system endpoints and drawing parallels in

9 behavioral constructs in humans and animals.

10 And we've also integrated more closely by

11 outcome the request of epidemiology and the toxicology

12 studies. And there's some examples here that appear in

13 the redline version, Executive Function and Inattention

14 and Impulsivity.

15 This slide shows -- is a comparison of the

16 conclusions that we drew in the second draft, comparing

17 them to the way made our conclusions in the third draft to

18 the ISA. Again, we've made conclusions about specific

19 endpoint groupings. And this table compares the two

20 drafts.

21 In the second draft we concluded there was

22 a causal relationship between nervous system effects

23 generally in lead exposure, but we pointed to cognitive

24 function and inattention in children as the endpoints that

25 were driving the causal determination. And this is --
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1 even though we have ten endpoints, the conclusions around

2 that are -- remain pretty much the same.

3 For cardiovascular effects, we're making

4 causal determinations for four groups of related

5 endpoints. In the previous draft we highlighted blood

6 pressure and hypertension. And now we also include

7 coronary heart disease, which is largely based on the

8 strong evidence from cardiovascular mortality studies.

9 And throughout these slides, the text

10 that's in red is there to note a change from the second

11 draft.

12 The endpoints and causal determinations for

13 other health defects are listed here. After reconsidering

14 the evidence for renal effects, we conclude likely causal

15 rather than causal in the third draft. Largely based on

16 uncertain things related to reverse causality.

17 For immune effects, in the second draft we

18 made our determination based on the strong evidence of the

19 Th2. In the third draft, we considered the evidence in

20 light of the endpoints listed here; atopic and

21 inflammatory conditions, decreases in host resistance and

22 autoimmunity.

23 The other outcomes are relatively

24 straightforward, and there's good parallel between the

25 second and the third drafts.
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1 For reproductive and developmental effects,

2 the sperm effects are in male reproductive function and

3 delayed puberty onset is within development.

4 To enhance transparency on the causal

5 determinations we included tables like this. This is an

6 entry for attention related behavioral problems, and it's

7 actually less detailed than some. We described here very

8 specifically evidence that went into our causal

9 determination.

10 And the column on the left will make the

11 evidence to the preamble where the framework for causal

12 determination is described. We left the key supporting

13 evidence in the second column, and in the third column we

14 note the key studies and the levels at which the effects

15 are observed on the far right.

16 We've received some comments about keeping

17 the text in these tables consistency -- consistent with

18 what's in Chapter 2 and also bringing in some of the

19 limitations of the blood lead levels to tables in Chapter

20 2, and that seems very reasonable to do. And I think the

21 level here that we left is the correct one for this

22 endpoint.

23 We have also incorporated a classification

24 system for at-risk populations, and that is based on what

25 was done for ozone documents. The summary of the factors
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1 that we've evaluated -- the summary table are listed here.

2 And we wanted to acknowledge one of the

3 comments that we received on the second draft of the

4 document, and that was to address the relative magnitude

5 or importance of the risk factors. Each of these risk

6 factors was evaluated to see if there were adequate

7 numbers of studies within each endpoint category.

8 And generally what we found is there were

9 not enough studies to actually look across the studies and

10 make any observations about the relative magnitude of the

11 effects.

12 We -- in the public health significant

13 section we highlight several studies, race and ethnicity,

14 genetic factors, and make sure in Chapter 6 that we

15 actually put the quantitative estimates.

16 But the problem that we're running into is

17 that for some of those studies, when you look across this

18 data -- for example, race and ethnicity, you see different

19 point estimates, but they're very overlapping. So we had

20 trouble relating observations quantitatively about what

21 the relative importance was. So we're looking for

22 feedback. It was our intention to respond to that

23 comment, and we're looking to -- for feedback in case we

24 have missed something. If you can recommend a different

25 approach, then we'll want you to do so.
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1 Moving on to Chapter 7, Ecological Effects.

2 The major revisions are listed here. In the first bullet

3 on as what's recommended, we're focusing on survival,

4 growth and reproduction and the sub-organismal responses

5 are secondary. We added the summary tables, and those are

6 for survival growth and reproduction and endpoints.

7 We've included the media-based exposure

8 concentrations and the modifying factors in those tables.

9 We've also increased synthesis and technical evaluation

10 and clarified language in the causal determinations

11 linking back to those enhanced technical evaluations. And

12 all the units should be standardized in the chapter.

13 Another important change in Chapter 7 was,

14 again, in response to CASAC comments. In the second draft

15 we had a causal determination of aquatic effects

16 generally. We broke out the freshwater and the saltwater.

17 And, again, the causal determinations that are in red are

18 the ones that have changed. And you can see under

19 saltwater there are a lot of inadequates, a few

20 suggesteds.

21 And the reason -- and the freshwater

22 effects were the effects that were driving the causal

23 determinations for aquatic effects. So a few of those are

24 highlighted in red.

25 So those are the major revisions that we
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1 wanted to call your attention to. And we'll hand it back

2 over.

3 DR. FREY: Okay. Well -- yeah, Dr. Kirrane

4 and Dr. Vandenberg, thank you very much. This is a very

5 nice presentation, and I like especially that you're kind

6 of walking us through what's changed and showing us some

7 of these tables and examples of the details and also

8 bringing up comments that you want to respond to but are

9 having challenges in responding to. And I think that

10 helps us focus on where we can help you the most. I

11 appreciate this presentation. It's very nice.

12 At this point, we're at the part of the

13 agenda where we begin to discuss the individual charge

14 questions since we don't have public comments at this

15 point. And as mentioned earlier, if there are -- there is

16 an opportunity for clarifying comments from the public

17 later this morning on the integrated science assessment.

18 If anyone is -- from the public would like to make

19 comments, they should contact Mr. Aaron Yeow, the

20 designated federal officer.

21 With that, let's move directly into the

22 discussion of the charge questions. First, we will

23 discuss the preamble, the legislative and historical

24 background, the executive summary, which is Chapter 1, and

25 the integrative summary, which is Chapter 2. And the lead
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1 discussant on this is Dr. Michael Kosnett, and the other

2 designated discussants are Dr. Michael Rabinowitz and

3 Dr. Ian von Lindern. But there will be an opportunity, if

4 other members have comments, we'll -- we will have that

5 opportunity as well.

6 And just as a reminder, I would recommend

7 -- highly recommend and encourage that the lead

8 discussants plan on doing some homework tonight to try to

9 draft a first version of the response to charge questions.

10 So if you have written material that supports your public

11 oral comments during the discussion, please e-mail that to

12 the lead discussant.

13 And just recall some of the rules for

14 communication with panel members. Since we're a federal

15 advisory committee, we can't have deliberations that are

16 not in public. But it is okay to send information to a

17 limited number of other panel members as long as you copy

18 the designated federal officer, Aaron Yeow. And I would

19 appreciate also if you would copy me as well.

20 So with that, I'd like to turn the floor

21 over to Dr. Kosnett.

22 DR. KOSNETT: Thank you.

23 DR. FREY: And by the way, you have 20

24 minutes.

25 DR. KOSNETT: Yeah. Well, this was a real
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1 easy chapter to review, Chris. It only covered 2,000

2 pages in summary, so...

3 You know, I'll say some things here, and

4 then some of my comments, I guess, came up -- or should be

5 brought up in more detail on Chapter 5 because that's an

6 area that I am particularly interested in.

7 I do think that it was a very positive

8 finding that this document, as Dr. Frey pointed out, you

9 broke out various specific endpoints. And that is really

10 helpful. And I also thought, although you don't do it so

11 much in Chapter 2, but in Chapter 5, Table 5-17, you lay

12 out your assessment for how you went about -- you know,

13 this is the evidence and this is the consequential

14 evidence. So that -- I think that was very, it was very

15 helpful.

16 I think a larger issue that I'll mention

17 that I -- and I wanted to ask my colleagues on the panel

18 how they feel about this. It relates to the causality

19 assessments. One is a more general approach, one is --

20 has to do with a particular influence.

21 The general approach is, you know, you have

22 -- it's clear -- it's pretty clear that when we say

23 there's a causal relationship -- and this is spelled out

24 in Chapter 1. I may have seen it in the preamble. You

25 have to have multiple high-quality studies that hang
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1 together, and you have to have positive toxicological

2 support.

3 I think we're all in agreement, okay, we're

4 close. But then we -- to me it becomes a little bit more

5 unclear how you determine something is likely causal

6 versus suggestive. And I was going through some of these

7 endpoints. Like for example, this document concludes that

8 the hematological effects of lead likely cause. And if

9 you look at hematological effects, it's like ATP and ALAD.

10 Now, I can only speak for myself and maybe

11 others around the room. I have a lot of experience with

12 lead. You know, asthma and ATP and hematologic issues are

13 not really something that has -- that comes to attention

14 in lead-exposed children and adults, at least in my

15 experience. And I'll leave -- you know, maybe

16 Dr. Weitzman and Susan here may say something here on

17 that. But, you know, we don't -- we don't -- it doesn't

18 normally come to the floor.

19 And, in fact, I'm on the CDC committee, and

20 Debbie is too. And our whole document we recently put out

21 about, you know, the whole issue of level concern. We

22 don't mention hematological effects at all.

23 But this document says that the

24 hematological effects are likely causal. So if you look

25 into it, it's all based on animal toxicology. It's not
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1 based on human epidemiology for the most part. There are

2 one -- I should take that back. There's one particular

3 study -- epidemiological study that has found a link

4 between asthma and lead. And I believe there's questions

5 about controlling social and economic status and such.

6 But then I realize under the framework for

7 causality right here, that's sufficient. You can just

8 have good animal studies, and the epidemiology doesn't

9 have to be very good and we can say likely causal.

10 And I don't know if -- you know, another

11 thing I wanted -- that comes up is the cancer assessment.

12 The cancer assessment here, it says, lead is likely

13 causal. It causes cancer, in humans. Well, I -- I think

14 people would take that away, that it could cause it. And,

15 you know, that's mainly -- the epidemiology -- the human

16 epidemiology is very inconsistent. There are some animal

17 studies that indicate that lead causes cancer in a certain

18 animal systems, but that's enough in this document to say

19 likely causal.

20 Now, I went back and thought, Well, what

21 does IARC say? How does IARC put it together? And IARC

22 looked at the same evidence that EPA has, and they said

23 their -- they come down to it produces limited evidence of

24 causing cancer. And they say limited evidence of causing

25 this. There's a positive association that has been
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1 observed between exposure of the agent, mixture or

2 exposure circumstance in cancer for which a causal

3 interpretation is considered by the working group to be

4 credible, but chance, bias or confounding could be -- not

5 be ruled out with a reasonable conscious.

6 And if you look at the evidence for --

7 under likely causal, and I'd like to keep that for my

8 colleagues here at EPA, we look at that. It's not clear

9 to me that if we felt that bias or confounding could rule

10 something out, at least in the human studies, are you just

11 saying that it's still likely causal because the animal

12 studies are positive?

13 MS. ROSS: So it is true that the animal

14 studies -- and this preamble is reflecting that to us.

15 These assessments could also -- the kind of considerations

16 we do in other toxic pollutants where we often don't have

17 (unintelligible). So I think one of the things we

18 recognize here, and it's true in ours too, is that animal

19 data can provide important support for a determination.

20 Without a live human data, we have to look at them

21 together.

22 So if there's strong animal support, but

23 just limited data available for human studies, that can --

24 that can inform determination. It's not required that we

25 have any one type of data. We try to look at them --
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1 whatever we've got to get some --

2 DR. VANDENBERG: I might add just a little

3 bit. And that is that as we develop that framework, we

4 looked at the Institute of Medicine and we looked at other

5 frameworks, including the EPA's cancer guidelines. And

6 this is consistent with the cancer guidelines that EPA has

7 created in 2005.

8 DR. KOSNETT: Okay.

9 DR. VANDENBERG: So, again, the language

10 that you see is not identical across the frameworks.

11 DR. KOSNETT: Right.

12 DR. VANDENBERG: So --

13 DR. KOSNETT: So I guess my recommendation

14 -- and I'll be interested in hearing what other people

15 have to say -- is that particularly in that likely causal

16 suggestion, that the human data is really not driving it

17 all and it's being given by the animal data. In the

18 executive summary and in the integrated summary in Chapter

19 2, which a lot of the policy readers will read, make that

20 a point. You know, make that explicit.

21 I mean, you can hunt -- you can go to Table

22 5-17 and sort it out, but it's good -- it's best to be

23 clear on that, I think.

24 DR. VANDENBERG: Can you tell -- exactly be

25 clear about what? Let me just make sure I understand.
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1 DR. KOSNETT: Well, where do you make the

2 decisions on likely causal based on the animal data being

3 the reason for that, even though the human epidemiology is

4 inconsistent. I think that should be emphasized,

5 particularly with lead. I'll tell you why, because with

6 lead, more than most substances, we have a lot of human

7 data.

8 MS. ROSS: Yes, we agree.

9 DR. KIRRANE: Yeah. I think we can bring

10 that forward, and it needs to be consistent. I think that

11 was another point in your comments.

12 DR. KOSNETT: And then the other point,

13 specifically, have to deal with -- about this causality

14 issue. It had to deal with two particular influences.

15 One is the renal and one is the behavioral aspect.

16 Focusing first on the renal, I notice that they changed

17 the assessment from causal to likely causal, which is the

18 downgrade. And you recognize and have a discussion in

19 Chapter 5 on reverse causality.

20 I think -- you know, I appreciate the fact

21 that those changes were made, and I had argued last time,

22 you know, for that. I -- but, again, if you wanted to

23 parse out the evidence in terms of whether it should be

24 suggested for likely causal at low levels of exposure, you

25 know, the human epidemiology, I felt, was inconsistent.
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1 There are some studies that show a

2 relationship of low levels, and there are some that do

3 not. There are some occupational studies that actually

4 show an increase in creatinine clearance with elevated

5 lead. Now, that has been tried to be explained through

6 equal positive hyperfiltration. But that, that's a

7 post-doc explanation. It's not clear that the blood

8 causes hyperfiltration.

9 DR. KIRRANE: Can I just ask a -- you said

10 low levels. Can you specify what you mean?

11 DR. KOSNETT: I'm not talking -- I mean,

12 I'm not -- I'm talking about the environmental exposure

13 that has occurred in, let's say, the United States in the

14 past 30 years, which -- 20 or 30. Okay. I'm not -- I'm

15 not talking about lead and nephropathy in high dose. I

16 mean, I know -- I'm very clear that lead causes

17 nephropathy in humans in high doses.

18 I'm talking about there is some literature,

19 which maybe you probably know, that suggests that blood

20 lead concentrations of 5 micrograms are associated with

21 decreased renal function. I say associated because that's

22 just with an epidemiological association.

23 Now, the human data is inconsistent in

24 terms of the epidemiology. There's some studies that show

25 that and some studies that don't. The animal data clearly
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1 shows that at elevated levels there's nephropexy toxicity.

2 There are no animal studies that have shown effects of

3 blood lead levels below ten, I don't believe.

4 DR. KIRRANE: It's 25 to 30, though, right?

5 That's on page -- we talk about looking at the informative

6 toxicology studies that are below 25 to 30.

7 DR. KOSNETT: Okay.

8 DR. KIRRANE: We can -- we need to clarify,

9 and there are studies in that range.

10 DR. KOSNETT: In that range. There's none

11 below ten?

12 DR. KIRRANE: Correct. Yeah. But it's 25

13 to 30 that we're setting up our approach.

14 DR. KOSNETT: Related to the animals?

15 DR. KIRRANE: Yes.

16 DR. KOSNETT: Okay. Okay. And there's no

17 human -- there's no pathological mechanism that's been

18 identified in terms of like biomarkers of renal toxicity

19 or pathology at these very low levels. And so some people

20 have said, Well, you know, inconsistent epidemiology, no

21 pathological evidence. What about the issue of reverse

22 causation?

23 And you addressed that in that chapter, but

24 the issue -- I must say -- and I know we don't have time

25 for me to go through all the details about reverse
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1 causation, but when you -- the arguments that are set

2 forth all have counter-arguments. And I think it's an

3 improvement that the discussion is in there, but I think

4 that the discussion still says it's unlikely that -- the

5 gist of that discussion says it's unlikely reverse

6 causation. It exists, so, well, there's a possibility.

7 So I was -- I was thinking in light of all

8 that, why -- why are we saying it's likely causal and not

9 suggestive. If we have the epidemiology, it's -- it's

10 what it is. It's inconsistent. There's no toxicological

11 mechanism at low doses, so like less than ten. And

12 there's an acute concern about reverse causation. Maybe

13 it should be suggested.

14 And then, finally, the point about

15 behavior. I mentioned attention issues. I think that --

16 if you notice in Chapter 2, when it makes these

17 assessments about behavior, it doesn't say anything

18 specifically in the chapter about dose, about blood lead

19 levels. And there seems to be two different groupings of

20 studies about behavior. In fact, you have -- can you put

21 up that slide you had on transparency, please. That was

22 table -- it was --

23 MR. MCNAMARA: I've got it. Just give me

24 one moment.

25 DR. VANDENBERG: It's Slide 16.
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1 DR. KOSNETT: The interesting thing I saw

2 there was that -- if you notice, the studies that -- the

3 consistent epidemiology is -- a lot of it comes from the

4 work that's been done on -- generally on populations that

5 have blood lead levels above ten in the studies that were

6 done in the early '90s.

7 The studies that were done with children

8 with blood lead levels below ten, the epidemiological

9 studies have not been -- well, there are two types.

10 There's the study that Gail did and the study that Rich

11 did, the two people that are here. And the evidence --

12 you notice that the -- in the middle there, you see where

13 it says Wasserman, et al., and Canfield, et al. And they

14 say, Association with inattention ratings inconsistent in

15 prospective studies examining children with lower blood

16 lead levels.

17 So that -- those studies are inconsistent

18 at a lower dose. The studies at a higher dose, above, you

19 notice those are studies from the '90s, for the most part.

20 And they look at -- they've looked at higher lead levels.

21 And then you have the more recent and cross-sectional

22 studies, which are mainly of the ADHD type. But then the

23 question there is -- a lot of it has been the problems

24 with not measuring confounding by parental

25 psychopathology, which is a big issue in the lead-related
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1 behavior effects at this time or the other.

2 So my sense is, and this is maybe -- this

3 is parsing it out, and I'll say this and I'll stop. My

4 sense is that shouldn't the document subdivide the causal

5 assessment for behavior in saying that levels above ten,

6 it's likely causal. Like, at lower levels, the evidence

7 is still just in the suggestive range because the

8 epidemiology is not as established. There's no toxicology

9 in animals below ten. Debbie, right? I mean...

10 DR. CORY-SLECHTA: Yeah, there is.

11 DR. KOSNETT: Okay. Below ten?

12 DR. CORY-SLECHTA: Yeah, attention-related

13 behavior.

14 DR. KOSNETT: In attention? Okay. All

15 right. Well, that's why I asked you because I know you're

16 familiar with that. But I just think that maybe the

17 issues -- I mean, I guess the bigger point is, is that you

18 don't -- the document doesn't break down in Chapter 2, in

19 the summaries, about the -- where -- at what level of

20 concentrations we're seeing these causal relationships.

21 And for the neurocognitive effects, it's

22 very clear that we're seeing them in temporary levels, in

23 the levels around where the standard has an impact. I

24 don't know that the behavioral evidence is on the same

25 par, or the attention level is on the same par and whether
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1 we should point that out. And I'd like to hear feedback

2 from my colleagues now.

3 DR. KORRICK: I just have one comment. So

4 Rich and Gail can comment on this, but in terms of

5 concurrent blood lead levels, the study -- the Canfield

6 and Wasserman studies are similar in their concurrent

7 levels with the standards in the '90s, correct? They're

8 the 6's. These are not super -- Gail's and Rich's were

9 super loads with kids, right?

10 DR. KOSNETT: Well, less than ten.

11 DR. KORRICK: Right. But they're

12 concurrent levels in the '90s reference. So if you look

13 at the summary, the transparency summary --

14 DR. KOSNETT: It's Bellinger's model.

15 (WHEREIN, unintelligible due to multiple

16 people speaking at once.)

17 DR. CANFIELD: The children had higher lead

18 levels.

19 DR. KOSNETT: Yeah. But the concurrent

20 lists were not all that different. So I think we should

21 probably stem with her meaning, something that's specific.

22 But I think that it's a little bit of an

23 oversimplification to say it's all adults and children.

24 I mean, I think one of the other things

25 that's different about Wasserman and Canfield is you guys
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1 looked at younger kids. You looked at four to five year

2 olds, which are very different ages to assess these things

3 than older school-age kids, which is what most of the

4 earlier studies did. So I think the comparisons are more

5 complicated than just saying it's a function of lower dose

6 versus higher dose. And I think that would be in the rest

7 of the literature. I don't think it's that simple.

8 But that's -- you know, I just want to put

9 that -- I think, you know, it's a complicated for all of

10 us to try to figure out what were those other

11 contributions of all of those issues. Age assessment is

12 as important as well as the exposure. I mean, I think

13 it's not just a simple statement. But others should

14 comment here.

15 DR. CANFIELD: Yeah. And so I would agree

16 with those comments. And also there's a difference in

17 your attention measures for your -- a variety of the

18 attention measures and variability simply in the quality

19 of the measures. And I've used some measures that were

20 more experimental in their use, and maybe not as accepted

21 as other measures.

22 They're certainly not on the same par as an

23 IQ. So to try and put all the attention that isn't

24 related to it in categories is quite problematic because

25 some are more pure attention tests and some are more pure
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1 behavioral subregulation or externalized or something to

2 that effect.

3 So -- I mean, I didn't make a submission to

4 the category, but I do think that it's variability among

5 the attention measures as well as age, as well as those

6 all involved. So it -- I think it's great we're having

7 this discussion, by the way. The fact that we get into

8 this point about, you know, really what's the quality of

9 the evidence is where we want it to be. So I think that's

10 really good.

11 My question for the whole panel is, Is

12 there a place that we say this is about as good as we can

13 do given what evidence is out there because we don't have

14 all the studies from all the cells to give us a

15 perspective on how much is age, how much is the particular

16 measure, how much is the dose. Gail, any comments?

17 DR. WASSERMAN: Well, I would agree. I

18 think we've come a very long way in terms of being able to

19 parse out or to describe the complexity of the outcome

20 measure attention versus componsitionality versus

21 diagnosis. And there isn't the same consistency as there

22 is in measuring IQ. You know, we'll have pretty

23 consistent measures. So there's a lot of causes for that

24 variability. I think they're accurately presented in

25 Chapter 5. So the issue is how much integration we need
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1 to pull together here.

2 DR. WEITZMAN: I concur about the quality

3 of what it is that we're trying to do. But as we try to

4 be consistent, there are multiple other pristine groups of

5 experts that weigh in on these things. How important is

6 it that we acknowledge that there are similarities or

7 differences in conclusions that bridge or as compared to

8 other important public groups.

9 As a clinician, I can tell you that the

10 American Academy of Pediatrics will write a policy

11 statement. And if there's inconsistency within the CDC

12 statement, what does that do in terms cognitive issues? I

13 believe that's important to other clinicians.

14 DR. CORY-SLECHTA: I don't think that the

15 new CDC recommendations are very specific with respect to

16 eliminating the phrase level of concern because we're

17 finding effects at the lowest blood lead levels that we

18 can reliably measure. And we describe some of the

19 evidence. That document was not intended to be a

20 comprehensive review, so we don't hang our hat, if you

21 will, on which of those effects. And then we set a

22 reference level from that. But I don't think it would be

23 inconsistent with what was suggested here.

24 DR. WEITZMAN: But I think that's important

25 having authored the previous CDC statement. I believe the
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1 first author -- we did try to be as careful as we could in

2 trying to come up with levels of evidence. And so going

3 forward, is this something that we want to do? I'm not

4 talking about something that's extreme, but simply a

5 couple of sentences, perhaps, to say what Debbie just said

6 in this particular document. I may be off.

7 DR. VANDENBERG: Can I comment to that

8 question?

9 DR. FREY: Yeah. Sure. Go ahead.

10 DR. VANDENBERG: So this review is for --

11 you know, for this purpose, as you see in the framing of

12 it, how we constructed the framework for evaluation, the

13 nature of the way that it's in the literature. It is not

14 identical to what we did, for example. It is just

15 limited. CDC is sort of for their own purposes. Any

16 cross-comparison, it's not so likely here as it may be at

17 subsequent other considerations. So I don't know that I

18 would suggest to find ourselves constrained in this

19 document by what other bodies have done, whether it's IARC

20 or CDC or any of the others.

21 This is the document that's getting

22 reviewed here. I would look at the way we have framed it

23 and the way we've applied the evidence to that framework.

24 It's really the structure for this particular discussion.

25 DR. FREY: Yeah, go ahead.
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1 DR. CANFIELD: Yeah. I think there's one

2 other angle to this, which is it would be -- I think it

3 would be useful to look at the other current documents as

4 providing some help and just another perspective on issues

5 like the ones that Dr. Kosnett was bringing up in terms of

6 likely versus causal versus suggestive.

7 Because those are judgment calls, and there

8 are so many different dimensions to this literature that

9 if you're focusing on these three or four dimensions and

10 not remembering, you know, Dimension 8, you might come up

11 with a different perspective than if you really are

12 thinking about, you know, 8, 6 and 5 -- or something like

13 that.

14 And so other people might be focusing a

15 little bit more on other aspects of the data and providing

16 just a check to say, Oh, yeah, I see what they're

17 thinking, or I more agree with what I did. This is a very

18 sophisticated document, and you've done a great job. And

19 I think the one level -- and this relates also to

20 Dr. Kosnett's remarks.

21 One aspect of the causal determination, I

22 think might be causing some confusion or a sense of

23 inconsistency, is -- there doesn't seem to be a specific

24 way to incorporate information about inconsistencies, say,

25 within a study.
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1 For example, in large studies we may find

2 an effect on one measure, but not another. And you can

3 take that as evidence for, you know, this effect is

4 powerful and yet all the statistics we need and very

5 controlled, but why didn't we find it somewhere else.

6 And I think one reason for this that isn't

7 stated in the document in general is typically small

8 sample sizes. That's causing a huge problem throughout

9 this in -- I think in terms of consistency. It makes it

10 impossible for you to do your job when there's so much

11 noise in the data due to small sample sizes.

12 But the notion of what counts as

13 consistence or inconsistence is not explicit here. And, I

14 mean, it's a -- well, it's a huge amount of work to go

15 into every study -- even in a more detailed way than you

16 already have. It's just like impressive.

17 DR. FREY: Okay. I guess one thing I'm --

18 and I'm not -- I don't have the domain expertise that the

19 discussants on this have, so I -- but one thing I'm trying

20 to figure out from the discussions, what are we going to

21 write for the answer to the charge question.

22 And so I'm -- something I'm -- just to kind

23 of reflect back what I think I've heard is -- one thing is

24 that a causality determination is context dependent, and

25 it matters -- it is affected by things like dose, age,
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1 what metrics are used and so on to Dimension 8, where

2 others -- and that for EPA's purpose they actually could

3 legitimately reach a different causality determination for

4 their context than another agency might reach for another

5 context. I think I've heard that.

6 And if that's true, then maybe that could

7 be discussed in the document just to make that clear that

8 if anyone wants to compare this to IARC or others, they

9 should do so very carefully because they're not really

10 comparable. They're not answering the same question.

11 And so maybe part of the advice is just to

12 be very clear about that. Is that an accurate -- and then

13 I think there were issues about the specific

14 interpretations Dr. Kosnett pointed out, whether something

15 should be likely causal or suggestive. And then some of

16 those decisions need to be reconsidered or at least more

17 clearly justified.

18 DR. KOSNETT: Yeah. Does anyone -- I mean,

19 do -- are people comfortable with calling renal likely

20 causal, or do you think it should be suggestive? The same

21 thing with behavior. I don't think there's a question

22 that the higher doses would give you. I'm just wondering

23 if the lower doses would be an issue confound and has not

24 been as clear. But I -- I don't want to say that if other

25 people aren't comfortable with it. That's why I want to
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1 get feedback on it.

2 DR. FREY: Yeah, and it could be that on

3 that issue -- I don't know that we were kind of -- I guess

4 if no one's objecting, I don't know if that means consent

5 by not objecting. But I guess if anyone takes issue with

6 whether there is uncertainty regarding that -- those two

7 choices of classification that it might be useful to

8 discuss that, but...

9 So in terms of the comment that we could

10 convey to EPA, it could either be just to raise that as an

11 issue that needs more attention, or if the panel feels

12 like the panel wants to advise on what the decision should

13 be on that as opposed to giving the EPA the latitude to

14 revisit that, I think that -- that's a decision we need to

15 make and convey our advice.

16 But what I would suggest -- we're kind of

17 behind schedule, but I suspect we're really not behind

18 schedule because as you pointed out at the beginning,

19 Michael, that some of this touches on Chapter 5. And I

20 think it was a very good discussion. So I'm optimistic

21 we'll still finish by lunch.

22 But I do want to give the other two

23 assigned discussants their opportunity on this charge

24 question. So let me offer the floor to Dr. Rabinowitz.

25 DR. RABINOWITZ: Thank you very much. And
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1 I have a feeling, to some extent, that the horse is kind

2 of out of the barn. No matter what we say, things are

3 going to kind of go along the fence. Despite that, I have

4 some minor comments to make. Maybe I'll just bring one of

5 them to the floor.

6 Of course, when we talk about -- we can

7 press the charge questions. If I could just bring your

8 attention (unintelligible). And that's regarding -- well,

9 it seems like we're wrestling here a bit with causation

10 and confidence and how we can express that in a document.

11 And the epidemiologists, of course, have

12 dealt with this a long time. The legal profession also

13 deals with confidence in making judgments. And I'm not a

14 lawyer, maybe there's no lawyers in the house. But I can

15 -- maybe? Is there a lawyer in the house? That's okay.

16 I -- well, it's always good to have one. So I stand ready

17 to be corrected by what I say.

18 It seems like the legal profession deals

19 with this by coming up with concepts of things are more

20 likely -- more likely guilty than not. Things are more

21 likely true than not. You don't have to be 100 percent

22 sure, but in civil cases you just have to be 51 percent

23 sure.

24 Maybe we can incorporate that kind of

25 thinking into how we address all things here. Well,
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1 things are more likely -- lead is more likely to cause

2 this effect than not. And then you go on to a more higher

3 level of confidence where beyond a reasonable doubt lead

4 causes it. Maybe that way of thinking about how to

5 express more uncertainties might be useful in this

6 context.

7 Having said that, did I -- could I ask you

8 to turn briefly to Page 114 on Line 3. And it's just

9 something here, and it may be just a typo. It just kind

10 of caught my attention. Where it talks about the larger

11 effects -- where lead has a larger effect at lower doses.

12 And I think we all believe that more lead equals more bad,

13 generally, regardless of the -- of what you're looking at,

14 whatever the outcomes are.

15 But here it says that the effect is greater

16 at the low dose, and I think there's some confusion here.

17 You may want to say that the rate of change in the outcome

18 is greater at these low doses of lead. The line is

19 steeper at these low doses. But this occurs from time to

20 time in documents. And I think what we need to say is

21 that maybe lead causes a greater incremental effect rather

22 than lead causes a greater effect. I think that's what

23 needs to be corrected there.

24 Later on we'll get together and talk about

25 what to give you later for the charge questions. As a
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1 general comment, though, I think you can say better and

2 better, how good does it have to be to say it's good

3 enough. I think it's almost good enough.

4 So in my other comments -- even though it's

5 not listed -- for instance, there's some diagrams in that

6 -- I believe it's in Chapter -- in the summary. There's

7 all these possible sources of lead, and they're all

8 equally large in the diagram. We all know in real life

9 some are bigger than others. I know this must be just a

10 schematic diagram. If there's any way to make the

11 extended exposure show up graphically, it just might help

12 the less informative. Those are my comments. Thank you.

13 DR. FREY: Okay. Yeah. I think I would

14 comment that, you know, operationally I think we as a

15 panel serve -- naturally fall into the notion that we need

16 to include ISA, and is it good enough and so on. That's

17 not a particular mandate of CASAC. We can provide

18 comments, and I think we -- we iterate and we want to see

19 the comments addressed. It's kind of like a journal

20 paper, I suppose. It's something we -- you know, do we --

21 do we just offer comments, or do we make a decision on

22 acceptance or rejection. There's a distinction between

23 those two things, I think.

24 I just mention that just because I think we

25 don't necessarily have to bless or say we approve what
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1 they might say, but we do provide our feedback. And I

2 think there is a burden on the EPA to either respond to

3 the comments by changing it or explain why they didn't.

4 But, yeah, at some point maybe we can reach

5 that threshold where we're willing to let it slide. Yeah.

6 DR. VANDENBERG: I'd like to make a comment

7 about that. In many of the previous reviews, sort of the

8 final letter that the CASAC writes to the administrator

9 regarding whatever that final draft is, it's often been --

10 a sentence has often been included by the chair which is

11 that the CASAC finds the document to be adequate for its

12 intended purpose.

13 DR. FREY: Right.

14 DR. VANDENBERG: But it's along those

15 lines.

16 DR. FREY: Yeah.

17 DR. VANDENBERG: It's not a yes, no. It's

18 just is it adequate for its intended purpose. And, again,

19 that speaks back to the idea that in the context in which

20 we were working with, this document has a certain purpose

21 to support ultimately the rulemaking. So that might be

22 something for you to consider as the chair.

23 DR. FREY: Yeah. Yeah. That's a good

24 point. Dr. von Lindern.

25 DR. VON LINDERN: Thank you. I'd like to
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1 say I concur with my colleagues' earlier comments, but I

2 concur with Dr. Rabinowitz. But I have to defer to

3 Dr. Kosnett on that discussion because it's beyond my

4 expertise. And I do want to commend the staff for a great

5 document. I think it helps create a success story in the

6 country wealth. They brought together a tremendous amount

7 of declamation, synthesized that well and done a good job

8 for the purpose of the document.

9 But, as you know, my problem is with the

10 scope and that it's narrow. I think as opposed to the

11 earlier process, the history and summary is a great

12 addition. That helps offset that somewhat, but I'll give

13 a little personal example.

14 This is my fourth time going through this

15 process. And because I'm an engineer and there's not very

16 many engineers on this panel, I always get assigned to the

17 sources category.

18 And the first thing we used to do in the

19 sources category was assess production, use, consumption,

20 disposal and role of lead in society. And we prepared

21 that information, and that was available in the document

22 for the policy reviewers to assess. In the 2006 process I

23 complained that that information was too sparse and it

24 needed to be developed. And the truth of the matter is,

25 is you won't find that information in the peer reviewed
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1 literature. You'll find that information in trade

2 literature, and you'll find it in the regulatory programs.

3 EPA used to pursue that. It used to

4 collect that data, and it used to analyze it. And

5 frankly, you could bet that was the industry. The

6 industry would back that information because they had an

7 interest in it, and they were on these panels.

8 And we, in the document -- the agency then

9 provided the policymakers a view of that aspect of the

10 problem. Well, what -- what the agency has done now is

11 totally eliminated. There's not a single word in this

12 document about production, use, consumption, disposal of

13 lead in the United States. There's lots of suggestive

14 evidence that the United States uses more right now than

15 it did during gasoline additive days, but we seem to

16 totally ignore data.

17 Now, the history does portray a huge public

18 health success, but history does not portray that that

19 production, that use, that consumption, that disposal has

20 gone on at greater levels than it did when we began this

21 process four years ago.

22 And there are more children in the world

23 today that suffer lead poisoning directly or indirectly as

24 a result of this policy. And we have totally ignored

25 that. It's not in this document, and the information is
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1 not available for the policymakers when they review and

2 make a decision.

3 Those are really policy issues, so I'll

4 quit there and take this up again at the next round.

5 Thanks.

6 DR. VANDENBERG: Can I say something?

7 DR. FREY: Yeah, John.

8 DR. VANDENBERG: Yeah, one of the things --

9 we did hear your comments before about this and have added

10 some additional figures that Ellen pointed in 3.6 which

11 does deal with mining primary and secondary production,

12 imports and exports. So I think we've heard your

13 concerns. Perhaps, not globally, but we've added what

14 information we could bring in to try to speak to some of

15 your concerns. I don't want you to feel as though we've

16 ignored your comments.

17 DR. VON LINDERN: No. And I want to,

18 again, stress that I think the staff has done a great job.

19 I just think the agency and, frankly, our federal

20 government have ignored this issue. This forum used to

21 provide a great deal of information for that, but you did

22 not have the opportunity to develop this time around the

23 federal changes of decisions.

24 DR. FREY: Okay. Other comments on this

25 first set of charge questions?
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1 (No response.)

2 DR. FREY: Okay. So Michael, do you feel

3 like you have a roadmap for drafting the initial response

4 to the consensus view on the charge questions? Is there

5 any other input you need from the panel?

6 DR. KOSNETT: Does anyone want to say

7 anything about the renal?

8 DR. CANFIELD: I could give my perspective

9 on -- I think your issue is that -- I think the current

10 classification, the causal classification is acceptable

11 and defensible. I think other judgments could also be

12 defensible.

13 But I think what's most important is that

14 the framework is explicit, and the evidence that they're

15 using to support their judgment is explicit. And there's

16 no mystery here except one person sees the glass half

17 empty and the other sees it half full. I kind of see it

18 boiling down to that.

19 So even if I would not feel comfortable

20 with likely causal, I know what the judgment is based on

21 and I see that it fits their criteria. And maybe I would

22 go back and say, Well, you could prove the causal

23 determination criteria, but I don't think this is the

24 place to do that. So that's my perspective.

25 DR. FREY: Okay. Anybody else?
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1 DR. KOSNETT: So we can say that we

2 compliment, certainly, and be appreciative of the fact

3 that it's more transparent. That would be recognized that

4 they are judgment calls on certain cases that say it was

5 likely or suggested. But the important point is we agree

6 to pinpoint, and that might not be resolvable. But we

7 appreciate the fact that there's more transparency.

8 DR. WEITZMAN: Well, could it be any less

9 than transparent? We've put together an explicit

10 criteria, but that explicit criteria is dependent upon

11 consensus, right? It's not quantitative. It looks like

12 it's clear cut how one reaches a determination about cause

13 and likely. If people are saying -- you disagree?

14 DR. KOSNETT: I don't know that -- if

15 there's -- if you look at the difference between

16 suggestive and likely -- suggestive evidence of causality

17 and likely in the preamble, it's not very clear to me --

18 DR. WEITZMAN: Yeah, I think that's what I

19 said.

20 DR. CANFIELD: I'm just thinking that we're

21 sort of litigating the philosophy of science rather than

22 this particular application of a consensus of how to talk

23 about causality because there's no -- we're not going to

24 get actual approved causality. We're not getting there,

25 but we're going to have various schemes. And, of course,
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1 they have to be things that we agree on.

2 And if it's a consensus that this is a

3 reasonable scheme -- not that there couldn't be other

4 schemes or maybe another group might come up with another

5 scheme or apply it slightly differently. I just feel like

6 we're probably at -- I mean, I have suggestions for things

7 that make me uncomfortable, but I guess I'll propose that

8 this is probably as good as we're likely to find for this

9 kind of an application.

10 And I don't know these kinds of reviews

11 because this is the first time I've served on. I think

12 that this is pretty impressive and it goes a long way, and

13 there are a lot of people in the world that are going to

14 learn a lot about lead if they take a look at this. That

15 doesn't mean that, you know, whether it was -- you know,

16 whether it should have controlled for common knowledge --

17 you know, when I did that analysis -- or not.

18 You know, I can't decide whether I really

19 should have done that or not, you know. So -- but I got

20 consensus of my co-authors.

21 DR. FREY: Okay. So I think I'm hearing

22 two levels of discussion. One is more about the -- I

23 guess the aspects and criteria for causality, which I

24 suspect we're not really wanting to open that as an active

25 area for further changes. And then another is
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1 interpreting that in the context of our particular case,

2 and I think Rich offered a way forward in commenting on

3 that.

4 And I think when you're kind of near the

5 boundary of one category versus another -- I don't know if

6 it's a lack of transparency if you don't have total

7 consensus. It's just -- it's almost like you sort of have

8 essential tendency in the range of opinion, and you're

9 kind of blurry between two categories. I think in a way

10 that could be transparent and still be ambiguous.

11 But, again, I don't know if we want to get

12 into a long, philosophical discussion on that.

13 DR. WEITZMAN: What I don't see is where

14 the evidence says --

15 DR. FREY: Oh, absolutely. Yeah.

16 DR. WEITZMAN: -- that. This is a

17 remarkable, advanced --

18 DR. FREY: Yeah.

19 (WHEREIN, unintelligible due to multiple

20 people speaking at once.)

21 DR. WEITZMAN: So simply saying -- because

22 for somebody who's not as (unintelligible) as most of the

23 people on this panel, the transparency statement, the

24 level of detail, suggests that we have nailed which

25 category it is. So one or two sentences, to me, would
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1 make us that much more obvious.

2 Plus, I don't interact with industry much,

3 but inconsistencies between one synthesis literature and

4 another opens the door to say that we're -- we don't know

5 if we hit it. To me, the one sentence.

6 DR. FREY: Yeah. Oh, absolutely.

7 Absolutely. So I think we're -- I think we've come close

8 enough on this question that I would like to move on,

9 unless anyone has a burning issue.

10 So I'm going to just take the prerogative

11 of a chair, and let's go through one more charge question

12 before our break. We had a scheduled break right around

13 now, but we're actually -- maybe a while ago. But let's

14 move forward and see if my hypothesis that this was the

15 time consuming charge question and the others will be real

16 quick. Let's see how that works out.

17 So we're next going to talk about Chapter

18 3, and this is on Source to Concentration. And the

19 contributing discussants are Drs. Davidson, Hopke and

20 Mr. Poirot. And the lead discussant is Mr. George Allen.

21 So I'll start with George. Oh, hold on one second. Aaron

22 wants to say something.

23 MR. YEOW: Sorry. This is just a reminder

24 for those on the phone to mute your lines. Thanks.

25 MR. ALLEN: Thank you very much. First of
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1 all, I'd like to acknowledge the agency's acceptance of

2 the revision of Chapter 3. It is a clear improvement over

3 the second draft. And I think with some minor changes

4 that we're talking about today that it will be good to go.

5 So I think that's great.

6 The chapter -- changes to the chapter were

7 very responsive to the panel's comments on the second

8 draft. The -- there's a large addition in Section 3.4.1.1

9 on sample collection. It's a good group of description of

10 the state of the science, a measure of altered coarse

11 particles, as I guess they were calling them, greater than

12 ten microns. It fairly illustrated the challenges, the

13 difficulty of trying o measure those larger particles

14 without the biases of the existing high-level FRM that

15 we've all known to -- to have mixed opinions on.

16 And it is understood that the agency will

17 not complete any work on the new, better FRM during the

18 cycle of the lead NAAQS. But I certainly encourage the

19 agency to continue this work as realistically as time

20 allowed. It is a major undertaking, but something that is

21 worth it in the long run.

22 Overall, it seems the readings for

23 non-airport near-source sites, the amount of lead greater

24 than 10 microns is not a lot, 10 to 30 percent, perhaps.

25 A lot of that, you know, being the -- below 15 microns.
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1 It's -- in the context of the NAAQS, .15, .21. I'm not

2 quite sure how we ended up ended up with .15 at the old

3 one.

4 These kinds of differences don't have a lot

5 of meaning, certainly in terms of our uncertainty of a

6 link between measure to air -- measure of lead in the air

7 and those to the body. So I don't think -- personally, I

8 don't think we need to worry about the modesty of this.

9 And the effort to validate a sampler of getting EPA sets

10 somewhere up 10 to 20 -- 15 to 20 microns.

11 Anything over 15 gets extremely difficult

12 extremely fast. And I would urge the agency to maybe --

13 given the limited resources that are currently out there

14 for this thing to work, not to reach too high literally.

15 Maybe try to -- if this panel could support a cut of 15

16 microns -- and I'm not sure we've every really discussed

17 that in this panel from the point of health exposure

18 issues, that I would urge the agency to go with that size

19 cut that is much more practical to achieve both in the

20 wind tunnel testing process and field evaluations.

21 And there is some different -- there's

22 places where different size ranges are mentioned.

23 Sometimes 15 to 20 is mentioned. Sometimes 15 is

24 mentioned throughout the document. So that might be worth

25 the -- pulling those together so that they're more
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1 consistent.

2 The 3.7.3, the section concludes with a

3 sentence that doesn't seem to be fully supported by the

4 chapter in the Section 3.4.1.1, where it says the existing

5 samplers reasonably capture the airborne fraction of

6 ambient lead that is available for human exposure.

7 That is not necessarily the conclusion I

8 got from reading the Section 3.4.1.1. So there might be

9 some opportunity to clarify that there. I would love to

10 see some of the early general aviation airport lead data.

11 I know a lot of it's out there, but probably a lot of it

12 is not. And I understand that technically the agency has

13 to stick to data that are in AQS and certified. I can

14 fully understand that.

15 But I also know that state and locals out

16 there have a lot of data in the pipeline that are, you

17 know, available if you call them up. And since this is a

18 major issue -- a major undertaking of these 15 general

19 aviation airport that's the pilot. Some of them started

20 late, as this document notes. But a lot of them have

21 collected a fair amount data.

22 So in terms of the goals of that project

23 and that program, it would be nice if maybe the final

24 draft -- or the final version, I should say -- I'm hoping

25 this is the final draft of the ISA that somehow some of
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1 those data -- and even if they're preliminary, will be

2 included. That would inform this in terms of -- to an

3 extent these -- not -- you know, these half-ton to one-ton

4 airports could be contributed to elevated lead.

5 Finally, just as a sidebar, in the February

6 issue of Environmental Health Perspectives, there's an

7 interesting article. They call it Sunset for Leaded

8 Av-Gas. It's not a peer reviewed journal article. It's

9 really a news piece. But it does a -- the second half

10 does a very, very good summary of what's currently going

11 on. The process to -- as it says, a push to get the lead

12 out. That's actually in process right now.

13 The time frame, unfortunately, if you leave

14 it to the agencies involved, is more than a decade out.

15 But there's a lot of discussion about how that could be

16 done sooner. So this is something that people in this

17 panel might find interesting. It goes beyond what we're

18 doing right now, but it does give you the good -- the

19 bigger picture of the av-gas lead issue and EPA's efforts

20 to get in the nature of finding, which would move this

21 whole process along and speed it up.

22 And there's a letter from a representative

23 to the FAA saying, you know, let's get the -- get the lead

24 out of your pants and let's move on this one. So that's

25 just a sidebar, but it's the February issue of the EHP as
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1 a news feature if anyone's interested. That's it.

2 DR. FREY: Okay. George, yeah, I want to

3 make a comment before we continue with more discussants.

4 So I think this is a good example of something that -- in

5 some sense, it's actually within our charter to discuss,

6 which would be, for example, the energy implications of

7 implementation of a lead NAAQS. It's actually within our

8 charter to discuss that or provide advice to the

9 administrator.

10 I don't think we're particularly

11 well-positioned to do that in this review cycle. And I

12 think this is an example of something that, as CASAC, we

13 need to establish in cooperation with EPA how to better --

14 fulfill our charter.

15 But just for example, just as a discussion,

16 you know, to the extent that air quality standard might

17 begin to give binding constraint on lead emissions from

18 the airports such to the extent that there is work

19 underway to look for alternative technical solutions that

20 would not substantially reduce the availability of fuel

21 for general aviation, that would potentially be something

22 that we could discuss.

23 I'm not proposing that we do that now, but

24 I just want to point out that this is an example where --

25 in some ways I think we could be doing more with regard to
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1 our charter. And so, you know, I -- I actually supported

2 George in bringing this up. It's -- you know, I think we

3 understand it's probably not something that is actionable

4 in terms of the policy assessment. Maybe it's something

5 that could be mentioned in the ISA, but it is still

6 something that potentially is within our charter. So just

7 an observation.

8 I guess with that I would like to ask

9 Dr. Davidson to offer his comments.

10 DR. DAVIDSON: Thanks a lot, Chris. I just

11 want to echo George's feelings that I think that the EPA

12 has done a great job on improving Chapter 3. I've just

13 got a couple of points that I wanted to make. On Page 366

14 there is a brief discussion comparing the efficiency of

15 different samplers for sampling particles in general.

16 And normally one would expect that if

17 you're going to be comparing two samplers that you would

18 get the best agreement for the smaller particle sizes.

19 And when you go up to the larger particle sizes, you would

20 have a tendency to get a poorer agreement because clearly

21 the efficiency of sampling large particles is more

22 sensitive to the geometry of the -- things like the

23 geometry of the units and the geometry internal to the

24 sampler.

25 But, in fact, there is a comparison there
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1 between the Texas A&M sampler and the Andersen Impactor

2 where the statement says that for PM 4, you have a major

3 disagreement between the two. But for PM 10, you get

4 reasonable agreement. That's very curious. I'm not sure

5 how that can be the case. So I just want to bring that

6 up.

7 I also want -- I just want to make a point

8 that when we're talking about sampling small particles

9 versus sampling large particles, that in fact one of the

10 -- one of the challenges here is that a lot of human

11 exposure to airborne lead is through the ingestion of

12 deposited airborne lead. For, you know, particularly

13 urban gardens, where people are growing vegetables and so

14 forth.

15 And, therefore, this is a major

16 uncertainty. It's -- I agree completely with George.

17 It's really difficult to sample these large particles, and

18 yet those are the ones that are going to be depositing the

19 quickest onto, say, vegetables that people are growing

20 close to sources.

21 So that is a uncertainty. It's problem,

22 and we really haven't solved that one yet. But those are

23 my two comments.

24 DR. FREY: Okay. I'm just curious -- you

25 know, George raised the issue about the cut size for
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1 samplers, and I think he -- if I understood correctly --

2 is offering that, in his opinion, 15 microns is a suitable

3 target. I guess to the extent that's something that would

4 get conveyed into a charge question, I think that would

5 merit some discussion from this group of discussants as to

6 whether that is, in fact, something to which the several

7 of you agree and also whether that's something as a panel

8 we would want to support.

9 I don't know -- Cliff, if you have any

10 thoughts on that?

11 DR. DAVIDSON: Well, I think the idea here

12 is, is we have to look at the intended purpose of the

13 sampling, the intended purpose of monitoring. And

14 certainly, George is correct when he says that you get

15 bigger than 15 microns and you start running into

16 inefficiencies in sampling very quickly.

17 I think, though, that it would be -- it's

18 important to be able to understand the exposure of people

19 who are eating vegetables that they're growing near

20 sources and that maybe receiving the brunt of deposition

21 of large particles.

22 And I don't think we have a solution to

23 that problem, you know, short of doing something

24 completely different like having a lead deposition

25 standard or something like that which opens up all kinds
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1 of other problems -- other Pandora's boxes, I guess you

2 could say.

3 But I think the sampling problem does get

4 severe above 15 microns. It's true.

5 DR. FREY: Okay. Let's see, next is

6 Dr. Hopke.

7 DR. HOPKE: Okay. Well, let me -- I mean,

8 I think they've done a real good job of fixing up this

9 chapter. In terms of the sample cut size, I get concerned

10 on focusing on the smaller particles because we do have

11 nasal deposition. We have kids running around where

12 they're going to go into oral breathing. And so there's

13 going to be more inhalability than we normally think

14 about. And particularly the stuff in nasal deposition

15 where it then moves back into the GI tract with the

16 transfer of mucus.

17 So that, you know, having spent the last

18 several years working a lot on Chrome 6 sampling, where we

19 have the same basic issue, I'm worried about the transfer

20 through the GI tract. Unless we can come up with some

21 cleaner, better relationships between large particle

22 distributions and, you know, this -- the shape of coarse

23 mode so that we know that IP 15 really represents X

24 fraction of the coarse mode, I think it's problematic in a

25 broader CS mode to some of these low-volume TXP heads,
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1 like the one McKinney came up with or something like that

2 where we have a reasonable -- you know, we no longer at

3 least have the wind speed and direction issues. We still

4 have, you know, a cut point that's obviously cutting the

5 whole portion of where we cut.

6 Again, keep in mind that we measure PM 10

7 and PM 2.5 mass reproducibly wrong by regulatory processes

8 so that, you know, we need to, to work at something which

9 gives us a useful measure of a sufficient fracture of the

10 exposure that we really get a good estimate of what's

11 going on.

12 I mean, the big particles are going to be

13 largely still around the point sources and are not going

14 to be transferred probably very far. So, you know, one of

15 the big questions still is, are we adequately using

16 Section 109 kinds of controls that are in those point

17 sources and not treating -- and maybe we should be

18 treating these much more as hazardous air pollutants than

19 criteria air pollutants, but that's another discussion.

20 But there are, you know, multiple tools

21 that the EPA has to try to reduce that exposure in those

22 areas. And there probably needs to be a more deep code of

23 attack. I mean, in terms of the general exposure, you

24 know, you'll see the big targets have the av-gas. I mean,

25 if we can do that, then we can reduce substantially the
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1 general population exposure. And other than that -- you

2 know, odds and ends (unintelligible).

3 DR. FREY: Okay. All right. Well, let's

4 see, let's go to Rich and see if we can just synthesize

5 what our message is.

6 DR. POIROT: So I agree with the previous

7 comments. I think some of George's points were right on.

8 You know, the agency was really responsive to our comments

9 last time. It reminds me to be careful what to ask for

10 because they really did everything, I think, that we asked

11 other than this chapter, particularly.

12 But I thought one of the most important

13 additions that reflects on that last discussion that was

14 starting up was, in addition to the section on alternative

15 sampling methods by collecting larger particle sizes,

16 there was a couple of really important, I thought,

17 including statements on various -- Page 368, specifically

18 that the relevant particle size distribution from ambient

19 sampling is smaller than the size distribution for sampled

20 dust, particles selected have been about -- 20 microns are

21 considered too large to be transported by more than a few

22 seconds under typical conditions.

23 To me that's a really important distinction

24 to make; that granted the ingestion of lead includes a lot

25 of larger particles incorporated in dust and taken up by
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1 hand to the mouth and so on and so forth. That absolutely

2 doesn't necessarily mean that that's how we decide what

3 size -- particle size distribution is appropriate for

4 sampling lead concentrations in the ambient air.

5 To me that's a really important addition

6 and concept to carry forward. And it seems to me this

7 idea that particles larger than about 20 really don't have

8 much of an atmospheric lifeline. You know, they are part

9 of this so-called photo suspended particle thing, but only

10 for a few seconds.

11 A representative, either in space or in

12 time, is a sample that's collecting particles that are

13 under microns in diameter, depending on the speed and the

14 direction of the wind and so on and so forth. So to me

15 that's a big deal, and it suggests that there's this

16 convergence between what's feasible, a collection of

17 particles up to a certain size point, and what's

18 desirable. And that's, I thought, dependent on what

19 points directly (unintelligible).

20 It leads me also to make another

21 observation. I -- you know, here and there in this

22 chapter, and I know it comes up in other chapters where

23 the methods are more thoroughly understood, but this

24 concept of dust and loading, which I assume has units of

25 micrograms per square meter and loading rates of
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1 (unintelligible) and so on of dust. Well, okay, so how is

2 the dust measured?

3 You know, I know we see a late sample on a

4 hard surface, but then they're talking about dust loading

5 rates at urban streets and to sidewalks. How do you

6 sample that to loading and determine that loading? How do

7 you measure it? And what are its particle size

8 characteristics?

9 Because almost certainly there's this

10 transferal over the time from the emission of lots of

11 small particle lead that's incorporated into larger

12 particles, either in the atmosphere or shortly following

13 deposition, and then gets incorporated into this dust

14 which is available for ingestion in which falls especially

15 on -- regarding plants and that sort of thing.

16 Is it necessarily the same ambient air lead

17 that we're talking about. So a little more information on

18 dust, how it's sampled and what is the particle size

19 characteristics involved would be useful.

20 Just a few other minor points. I -- you

21 know, maybe this is picky, but the term "TSP," you know,

22 we all use it to mean, I think, whatever we want it to

23 mean. It's become so imprecise that it means on one hand

24 orbital suspended particles. A hypothetical concept it's

25 impossible to measure, but it -- as it's used for lead
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1 sampling, what we really mean is TSP -- whatever the

2 high-volume sample it collects, that's what we're defining

3 as TSP in that sense. When we talk about TSP lead, what

4 we mean is lead likely by the hi-vol.

5 But we also use TSP in the same chapter

6 where a number of other samplers have been called by their

7 inventors TSP samplers. But what they collect is not the

8 same as what the hi-vol collects or what any other

9 so-called TSP sampling collects. And we also talk about

10 the future alternative yet to be developed TSP sampler.

11 Those are four different uses of the same term.

12 How are we ever going to get precise in our

13 measurements if we can't be more precise in our language.

14 So just -- and maybe it's minor. Maybe we've been doing

15 this for so long that we're comfortable with it. Yet it

16 just hit me that, Let's be a little more precise if we

17 can.

18 Again, if you're talking about so-called

19 TSP, meaning something different from what's hi-vol to us

20 and not in quotes -- what was the term I was thinking of,

21 you know, particles larger than ten is what we really

22 mean, PLT. Something bigger than ten, we don't know what

23 it is. We don't know how much. That's what we mean.

24 Let's call it that rather than pretending that we're

25 talking about the same thing.
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1 The last maybe minor comment I have was I

2 just happened to notice there was this nice bigger 325 on

3 Page 3-107 that's the correlation of lead with all of the

4 other line particles species measured in the CSM network.

5 And it just shows -- it ranks them from best correlated to

6 recent and so forth. And I just noticed that it's

7 different from the same exact figure presented in the

8 previous bracket. The things are in different orders.

9 The elements are in different orders.

10 And I'm just curious as to how that came

11 about. One of the reasons being that on the previous

12 version, potassium had had the second highest correlation

13 with lead of any other -- of any other species behind

14 zinc. And now the passing was bumped down three or four

15 notches, something like that. I think it's in eighth

16 place.

17 And then I noticed in the appendix you've

18 got the seasonal correlation, the same pictures are done

19 by spring, winter, summer, fall. And potassium comes in

20 second, third, fourth and second. And yet it comes in

21 eighth place in the annual -- and, you know, it has the

22 implication we've now have available from all this

23 receptive modeling work. Potassium is a great wood smoke

24 indicator, but it could also be fireworks.

25 There's an interesting thing, I just came
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1 across it last night, I'll put it in my advice comments.

2 But paper -- a card research study that showed extremely

3 elevated lead during a fireworks event. And not only

4 that, but the lead had an Asian -- a Chinese

5 (unintelligible) signature and so forth.

6 Anyway, it's just a minor point. That's

7 all I have to say.

8 DR. FREY: Okay. Well, I think both you

9 and Phil kind of allude to that -- this is my

10 interpretation -- it was about the particle measurement

11 techniques. They're really operational definitions of

12 what is a particle and what is a component of a particle.

13 So it's not a philosophical definition. It's a definition

14 of what can be measured.

15 And even a PLT that you propose -- it's

16 probably particles less than ten, but it's actually some

17 fractional cut point that it -- some could be bigger, and

18 so it's -- it's an operational definition. But I guess

19 that's the reality that we have to live with. But John

20 Vandenberg, if you want to clarify.

21 DR. VANDENBERG: Well, just to --

22 specifically that question -- and I don't know, Jennifer,

23 do you want to just share with -- why that would be the

24 change? And while she comes up, I might note that when I

25 was at the commission meeting last week, there was a lot
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1 of discussion on wood smoke and markers in the atmosphere.

2 Particularly in Greece, where evidently --

3 because of the extreme poverty there, they're burning

4 furniture. They're burning their furniture because they

5 have no other source of heat. So they're getting a wood

6 smoke mixed with metals.

7 MS. RICHMOND-BRYANT: Just quickly, the

8 reason for that change in particular was, as we've

9 responded to the comments from the last time about using

10 this Pearson versus Spearman coefficients, it changed some

11 co-relations. And that was when that switched gears. And

12 we're hoping that the consistency in seasonal loads was

13 because it may have convinced me to present all of the

14 Spearman coefficients that would be amongst those data.

15 So that was the reason why.

16 DR. FREY: All right. So I guess to

17 summarize, it seems like it's fair to say that the three

18 or maybe all four of the discussants on this topic are

19 kind of converging toward the practicality of something

20 with like a 15 micron cut point; that that -- as Rich

21 pointed out, that particles larger than 20 don't transport

22 very far. And maybe even the 15 to 20 range they don't

23 transport very far.

24 So in terms of like an area-wide ambient

25 indicator, you know, something up to 15-ish is probably
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1 not too bad. But on the other hand, there is a source

2 unit total particle signal, which I think as Phil alluded

3 to, either might be represented with a different kind of

4 TSP sampler. And as Cliff pointed out, we probably don't

5 want to move into a deposition-base method.

6 Is that a fair summary?

7 DR. HOPKE: I think we're underestimating

8 the transport here. I mean, a 15 micron particle has a

9 deposition velocity of 7 and a half, 7 meters per second.

10 And, you know, at some wind speeds (unintelligible) and

11 carry it. I mean, you know, 20 to 30 micron particles,

12 they're going to have lifetimes of the ordinary of a few

13 hours. That's certainly enough to cover much of the urban

14 area.

15 And a 10 micron particle has a lifetime of

16 about 24 hours.

17 DR. FREY: So what's the --

18 DR. HOPKE: I think we have to be careful

19 here of not -- of recognizing the transport if -- you

20 know, these aren't baseballs that we've got.

21 DR. FREY: Right. So do you see a role,

22 then, for a combination of a -- well, sort of a coarse of

23 an endpoint --

24 DR. HOPKE: There's a good understanding of

25 the fraction of the coarse mode that's PM and a high be
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1 15. But, you know, it's pretty variable depending on what

2 the sources are. And, you know, again, a few big

3 particles carry a lot of mass. It would probably be a

4 good particle size. And so I just worry about whether

5 they're estimating the exposure in areas where there could

6 be large particles in a way that then would give us a

7 problem in producing more exposure than we think there is.

8 And this is an area -- you know, we'd really like to solve

9 this problem once and for all.

10 MR. ALLEN: Well, are you suggesting that

11 we goes as high as we can and take the time and effort to

12 suggest to the agency to push it as much as they can,

13 which will still be well under 20 microns?

14 DR. HOPKE: Right. And the point is, there

15 are other things out there in the NAAQS network that also

16 come into this play in the same similar way. So, you

17 know, I have to think there could be multiple benefits

18 beyond the lead issue if we had a sampler that would agree

19 on this more reliable, in terms of providing that

20 information -- a more inhalable -- not ingestible, but

21 inhalable that would include things that, you know --

22 again, not -- wouldn't get into the respiratory tract, but

23 it would get into, you know, nasal deposition and into the

24 GI tract.

25 DR. FREY: Okay. So --
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1 DR. DAVIDSON: Chris, I was just going to

2 give input on that. To build on what Phil just said, that

3 I think there's one -- there's an important message here,

4 which is that the exposure to population is not entirely

5 small particles, even though those are the easiest ones to

6 measure. And so I think that the document needs to make a

7 point that there can be exposure to larger particles, but

8 that right now they can't be measured very well and that

9 this is a weakness that we have.

10 DR. FREY: Right. Yeah, exactly. Rich.

11 DR. POIROT: Well, I just wanted to maybe

12 point out the obvious that all of these sampling designs

13 using size selective inlets and filtration techniques, you

14 know, can be characterized in a number of ways. And we

15 tend to think of a 50 percent cut point. You know, we'll

16 let in half the particles of this size as being sort of

17 definitive. But at the same time, they're letting in 40

18 percent of the particles that are a little bigger than

19 that and 20 percent and so on.

20 So they all have these slopes to the cut

21 size, which may actually be at very realistic in terms of

22 the overall exposure regime and the importance of smaller

23 versus larger particles, I think, in that sense as well.

24 So it -- you know, and a counterpoint to

25 that is that from the discussion that we heard last time
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1 from Bob Vanderpool, that -- you know, that there's a

2 potential that a sampler with a somewhat higher cut size

3 in the range of 15 could actually collect more lead than a

4 TSP sampler does under certain conditions because it's

5 imperfect and its collection efficiency of all of these

6 particles in different size ranges as well. So it may

7 very well be -- especially if the lead tends to be in the

8 less than 20 micron size range, that kind of an approach

9 may actually collect more lead than the hi-vol TSP's

10 and --

11 MR. ALLEN: I think we've started

12 struggling with facts versus ideal solutions to this

13 problem. And as Rich implied, whatever EPA comes up with,

14 we'll probably have a rather sloppy size cut, which is

15 actually okay. Typically for a PM 2.5 we want to be as

16 sharp as we can. For the TSP, we don't care if it's at a

17 rather broad cut as long as it's reproducible in terms of

18 a measurement that it does.

19 We're not going to get a sharp cut, I know

20 that much for sure right now. And that's okay. You know,

21 I'm trying to just kind of ground things in reality as to

22 what is possible within the reasonable amount of effort.

23 We know we're never going to be able to render near

24 sources. Well, if you want to measure near source,

25 everything you do puts out a dust bucket. But we don't
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1 want to go there, I don't think, certainly not as a

2 (unintelligible).

3 DR. FREY: Okay. I think we've probably

4 reached closure on this. And so, George, your homework is

5 to draft a draft response to the charge question with

6 input from your fellow discussants. Are there any other

7 members of the panel that would like to weigh in on this?

8 Okay. Yes, Herb.

9 DR. ALLEN: Just one comment. Every time I

10 hear things and read things in here, I note that there are

11 issues brought up in one chapter that have great

12 application to another chapter. And there often not

13 indicated within the document itself. One that is in

14 Chapter 7, it is seemingly interesting is the honeybees

15 collected near an airport had the highest concentration of

16 lead out of the study. So that sort of says something

17 about aviation.

18 DR. FREY: Okay.

19 DR. ALLEN: So to add to the samplers.

20 Now --

21 DR. FREY: Yes. Yes.

22 UNIDENTIFIED SPEAKER: Mosquitoes too.

23 DR. FREY: Oh, yeah. They just need to

24 come up with an acronym for that. Yes.

25 DR. RABINOWITZ: Let me just quickly ask --
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1 maybe I'll learn something. The question of particle size

2 collectors, is this area more developed than the studies

3 for occupational exposure?

4 MR. ALLEN: No. It's the same problem.

5 DR. RABINOWITZ: The same problem there.

6 Okay. Thank you.

7 MR. ALLEN: Most occupational exposures,

8 the cuts and its use -- that's just what they've done --

9 deemed important from an occupation perspective, which is

10 different than the larger steel immediate exposure, of

11 course.

12 DR. FREY: Okay. I think we need a break.

13 So during the break, you know, get psyched for quickly

14 responding to charge questions. We'll go ahead and break

15 until 11:05, and we will start promptly at 11:05.

16 (WHEREIN, a brief recess was taken from

17 10:52 a.m. to 11:05 a.m.)

18 DR. FREY: Okay. Our next item of

19 discussion is on the ISA charge question related to

20 Chapter 4, which is on Exposure, Toxicokinetics and

21 Biomarkers. And the discussants are Drs. Pounds and

22 von Lindern, and the lead discussant is Dr. Hays. So I'm

23 looking for Dr. Hays. There he is. Okay. So the floor

24 is yours.

25 DR. HAYS: Thank you. I'd like to commend
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1 the EPA on a good job on Chapter 4. The section on lead

2 in consumer products is not such a great addition. It's

3 extremely helpful, but of course wasn't very helpful.

4 However, the discussion of the importance

5 of the lead in consumer products is extremely sparse and

6 seems to have (unintelligible). I don't know how many

7 studies have been done to show how lead in consumer

8 products can impact what that does. Maybe there are none

9 and that's why it's based on that category. Because given

10 some of those levels, it seems like some of the consumer

11 products that are out there could have significant impact

12 to (unintelligible).

13 Obviously, the -- the assessment for the

14 NAAQS is based on relationship between lead and air

15 ambient levels. And I thought the discussion of those

16 studies that are available in the current relationships

17 and the historical perspectives around the declines in the

18 use of lead in gasoline and related decreases in blood

19 lead in the U.S. and other countries is helpful,

20 especially for establishing the context around setting a

21 lead NAAQS.

22 However, the description of the empirical

23 models and the strengths and weaknesses that are available

24 was good, but what you find is that -- I'm looking through

25 the studies that have been done in the associated smelter
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1 or mining communities, which are very different than the

2 scenarios than what's going on with the general population

3 and setting a NAAQS.

4 Furthermore, it's a challenge about how our

5 blood in relationship is (unintelligible) and excluded at

6 the blood lead levels. Most of the studies have blood

7 lead levels that exceed ten. Some, you know, are as low

8 as two, but that was the minimum in that study. Some of

9 the areas in the -- none of the studies that we have

10 available for the air lead have captured what's really

11 going on in the environment today in the U.S. for air

12 concentrations and very low blood lead levels.

13 It's a very challenging perspective. It's

14 not clear the NAAQS below .15 will have any impact on that

15 method.

16 MR. MCNAMARA: I'm sorry. Move closer to

17 the mic, please.

18 DR. HAYS: Okay. Sorry. Having a

19 statement like that is sometimes conclusive like that in

20 the ISA and may be helpful as well. That sentiment was

21 not captured in the ISA, but I think it was captured in

22 the policy assessment.

23 The relationship between blood and air in

24 Figures 4-22 and 4-24 seems to implies that the blood lead

25 level declines at 0.0 there at lead levels. That's not
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1 the case, it doesn't seem. And I don't think they realize

2 that it's important to have a range there. So consider

3 complicating the figures of this levels that are supported

4 by the ambient is (unintelligible).

5 I'm not sure that the data that they've

6 attached suggests that we take the air lead levels to

7 zero. What I would love to see is something like a pie

8 chart that shows me how we could collect the lead from

9 various sources. That's a function that would work very

10 well. That really has not been captured in this

11 discussion. I mean, I don't think it's just generally the

12 community in relation about air, the relationship about

13 air.

14 So I think, you know, this integrated

15 science assessment is good, but it's really not -- to be

16 honest with you (unintelligible). Do you want to comment

17 on that?

18 DR. VANDENBERG: Just that we appreciate

19 and consider your comments. And we couldn't find the data

20 to do that and didn't feel like we should recycle that

21 whole section. I appreciate that.

22 MR. BROWN: I would just say that it would

23 be very situation specific.

24 DR. HAYS: Absolutely. I totally agree.

25 Yeah. And maybe some communities where it doesn't point
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1 to sources of lead that they would have a higher level.

2 We need other communities where you've got normal

3 exposures, you have some high blood lead levels associated

4 (unintelligible). That kind of discussion would be

5 helpful. And I agree, we probably won't be able to visit

6 that. To me it would be useful to have that stipulation,

7 but...

8 Now, beyond that, I have some specific

9 editorial comments, which I won't go into at this time.

10 DR. FREY: Thanks, Sean. Dr. Pounds.

11 DR. POUNDS: I really like clarity of this

12 chapter. I'm particularly pleased by the lucid

13 description of the topic strengths and limitations

14 introductory found in many of the introductory and

15 concluding sections.

16 I kind of made just, you know, three

17 comments to kind of give my colleagues a chance to reply.

18 Not necessarily in particular order, I agree. Table 4.9,

19 that describes the XRF measurements to population studies.

20 There's part of the text that's already notes some of the

21 issues relating to the measurements and interpretation of

22 this data, but the table doesn't indicate how they

23 censored the data.

24 In order for the panel to draw conclusions

25 about the distribution of all lead in the separate studied
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1 populations, we really need to do that. You can't get

2 there just as a standard deviation. It lets you know how

3 the authors handled missing data. Sometimes it's not a

4 problem if the data is expressed in subtitles. Mostly

5 it's just (unintelligible). I think you can get that out

6 of the literature for most of the studies.

7 Secondly, it's a suggestion. So maybe if

8 the plots that were done with the later model that show

9 timed appendix decreases the blood lead levels, especially

10 after sensation of lead inputs in the models, our --

11 especially because they compress and could be different

12 many years, even a lifetime (unintelligible).

13 And that time compression supports the

14 conclusion for it to decrease blood lead levels is very

15 graphic, which is at odds to what epidemiologist and

16 occupation health physicians expect when they are

17 typically following blood lead levels over periods of a

18 few months or a couple years.

19 So I suggest that this potential confusion

20 could be alleviated by just spinning on that curve after

21 removal of lead from all two and three terms. Some of

22 that is (unintelligible) in calculating the half-times of

23 those three compartments.

24 And then, again, I should note that those

25 calculated half-times would be consistent with the kinds
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1 of data that the reported literature, at least from

2 occupation, cites. You could alternatively show an

3 additional plot that would show us just that timeframe

4 expanded to show the plot.

5 One other comment. Chris is suggesting

6 that it's okay to suggest recently, you might consider

7 speculating, because I'm not aware of it directly, the

8 potential role of a human microbiome in modulating lead

9 bioassessibility of lead. There are many reports of

10 literature optimizing or reducing reverse

11 (unintelligible).

12 And so, you know, I'm plausible that

13 depending on the (unintelligible), which is the kind

14 that's on age, gender, diet and so forth, that there could

15 be a contribution to these dissolution, changing of

16 access, if you will, to different level of minerals that

17 could be said to be sound to be incorporated.

18 That's the big -- I think that's just a

19 research and not something -- I think it's something to

20 do. I think all the other comments are self-explanatory.

21 DR. FREY: Okay. Thank you.

22 Dr. von Lindern.

23 DR. VON LINDERN: Thanks. This time I can

24 concur with my colleagues. They have great comments.

25 They've took most of mine. Especially with regard to
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1 Sean's, and I think it relates to Michael's earlier

2 comment as we're headed into much lower blood lead levels

3 and much lower exposure. The slope and relationship, it's

4 probably changing remarkably and it's going to be hard to

5 keep up. But practically we probably know what we need to

6 move forward.

7 There is a wealth of blood lead level

8 information, and health information that continues to

9 accumulate. Relative to the past, there's a lot less

10 exposure information available across the country right

11 now. And this is, perhaps, one time that I won't chastise

12 the agency for not providing that data. Instead, I

13 really, you know, question myself as to how critical that

14 is in terms of the other places where resources could be

15 expended on, on health issues.

16 So maybe that's a point in which we're good

17 enough for a while. I think in terms of presenting this

18 information that you did an excellent job. And this

19 chapter has improved remarkably through the drafts, I

20 think. And it does a good job now discussing the

21 uncertainties while reaching the important conclusions

22 that are necessary to support the use of the document down

23 the line. So that's my comments on this.

24 DR. FREY: Do other members of the panel

25 have comments?
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1 DR. KOSNETT: I was pleased that -- related

2 to other editions, I like the particular -- the fact that

3 on the modeling you included the rate of change to the

4 higher exposure and the sort of effect. And you didn't --

5 you know, the first document had a sentence that said,

6 Well, after chronic exposure, when you reach some exposure

7 of blood lead levels to where they were before. And then

8 you gave a scenario (unintelligible).

9 So now you illustrate that when you have

10 higher levels of exposure, you build bone up. I think

11 it's a nice -- thank you for doing that.

12 The other thing I briefly wanted to say,

13 you know, the -- one of the key things that comes out of

14 this chapter is the relationship between air lead to blood

15 lead level relationships, right? Because, ultimately,

16 when you set a standard, you must apply air lead to blood

17 lead and blood lead to IQ when you make a decision.

18 So they have -- you know, I don't -- the

19 table, 4-12, that summarizes the study. They have a

20 paragraph on Page 4-144 that talks about, well, the slopes

21 are ranging (unintelligible).

22 But it doesn't really -- in this document,

23 it doesn't really make a final analysis about which ones

24 are the best for this assessment. To the extent, for

25 example, that a policy assessment looks at it and says,
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1 Well, we're going to take a median of 1 point -- a set

2 (unintelligible).

3 Did you want to not really weigh in on what

4 you think is the best for this document and kind of let

5 the folks who did the policy assessment and make that

6 call?

7 DR. VANDENBERG: We typically lay out the

8 evidence here, the judgments that listed -- included in

9 the list of descriptions. That's typically how title

10 that. And I know that some of the comments on other

11 ISA's, including this one, has been an encouragement for

12 us to move more into, given the range of data, what would

13 be the preferred approach. You know, we found that to a

14 greater or lesser extent.

15 DR. KOSNETT: Okay. I -- and I -- that's

16 fine. I understand. I'm just saying some people will not

17 find the policy assessment -- this is a bible of the

18 future. And so people are going to be turning to this

19 and, you know, it might be nice -- because this is such an

20 incredible document -- to include more of that discussion.

21 But you do kind of give an average change in the tables

22 and at least in the slopes.

23 This is kind of -- you know, like kind of

24 pointing people to this agency language. But it -- no big

25 deal, but I'm just -- they haven't really -- they laid it
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1 all out on the table, but they don't always say

2 (unintelligible). That's done in the policy assessment.

3 If you felt compelled -- if you felt inclined to maybe

4 reiterate what you said in the policy assessment, then you

5 could -- but you don't have to.

6 DR. FREY: I think I just want to see if

7 Phil Goodrum is on the phone. And if so, if he wanted to

8 offer comments. Phil?

9 (No response.)

10 DR. FREY: No. Okay. Any other panelist

11 want to weigh in on Chapter 4? Sean, do you feel like you

12 have what you need for drafting your charge question?

13 MR. HAYS: (Nodded head.)

14 DR. FREY: Okay. Thank you. Okay.

15 Excellent. Well, in that case, let's move on to Chapter

16 5, which it will only take a few minutes, right. And the

17 lead discussant on this is Susan Korrick, and the other

18 discussants are Richard Canfield and Michael Kosnett. So,

19 Susan, the floor is yours.

20 DR. KORRICK: Okay. Thank you. First, I

21 have to commend the agency for doing an incredible job of

22 trying to address a lot of very complicated issues. I

23 think that this draft is a big improvement over the

24 previous ones.

25 In particular, I think the most fundamental
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1 concern we had previously was that the causal assessments

2 were not as transparent as they should be. And

3 particularly that the data measured would be in the

4 literature that was carefully acknowledging the issues and

5 strengths was not as explicit as it should have been. And

6 I think that this version addresses those issues, for the

7 most part, quite nicely.

8 Which takes me to some of my specific

9 comments. Which I think that the piece that's still

10 potentially debatable, I think, is that we're finding it's

11 not critical. And that is the kinds of issues that came

12 up and we talked about, the preamble and in Chapters 1 and

13 2, where -- in cases where the strength or evidence is not

14 clearly causal between lead and some particular health

15 outcome, distinguishing between likely causal and

16 suggested is a very subtle nuance distinction.

17 And it's hard to tell from the document how

18 those -- how decisions are being made, distinguishing

19 between those two categories. I'm not sure that that's

20 critical. I think the point is that we could all put

21 differences of opinion in that gray zone. And as long as

22 the criteria and the information that's being looked at

23 for each particular category and how that is very

24 explicitly defined. The ultimate choice in that gray zone

25 is probably not as critical.
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1 And so I think that you guys did a very

2 good job of that. So I think there's going to be debate

3 among all of us as to whether or not something falls

4 within that gray zone, but that's not the key piece. The

5 key piece is providing the information that got put into

6 the gray zone to begin with.

7 So I think that another area that we talked

8 a lot about last time was the notion of trying to divide

9 -- or identify health outcomes in more specific groups

10 that have some functional formalities as well as allowing

11 the risk of the system, but the causality system to be

12 more focused.

13 And I think you did a really good job of

14 that, for the most part. I think what -- again, it's sort

15 of reached a point in my mind that the -- some of the

16 issues with the document are more subtleties about how

17 those groupings remain, and there may be some debate about

18 whether they were all -- what everyone would agree with.

19 I know Dr. Canfield had some comments around that that

20 I'll let him add.

21 And I think that -- you know, in some cases

22 the choice of groupings was not what I would have chosen

23 and some groups of studies were not necessarily organized

24 in a way that I would have chosen, but I don't think

25 that's at issue.
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1 And I have some specific comments around

2 that. For example, you know, under school achievement,

3 the WRAML verbal learning task was listed and that has

4 nothing to do with school achievement. So there's some

5 organizational issues that are not quite accurate, but I

6 think those are really not important into the big picture.

7 Let me just see here. Another sort of

8 larger issue, and I'd be interested to hear what other

9 folks think, is that -- especially for the nervous system

10 studies which is by far the most extensive portion of

11 Chapter 5, the text indicates that some of these are

12 organized according to strength of study design.

13 So there's a clear distinction between

14 prospective and cross-sectional studies. But then within

15 those groupings, it's actually hard to know what the

16 specific design issues that were used to prioritize were.

17 And it's not immediate point, but it sort of gives out

18 this issue of how you think about ray zones. Like if you

19 -- depending on what component, I'll say design is

20 important to me (unintelligible) way of particular

21 findings. And it's a little hard to tell from the text or

22 the description how that was done.

23 You know, for example, on the adult

24 cognition studies, the Baltimore Memory Study is very

25 prominently featured as a prospective population based
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1 study, and it's a good study. But there's some other

2 analysis that weren't ingested or compounded by smoking

3 and alcohol which I think is a potentially important

4 weakness, and it's not really discussed.

5 And maybe the rationale is that it's

6 sensitive to the over-adjustment, but some acknowledgement

7 of the complexities was missing. And I'm not necessarily

8 advocating that the document do that because I think it's

9 already several hundred pages, this particular topic, and

10 you could spend the rest of your lives with this. But

11 there are some subtle issues that are kind of hard to

12 piece out.

13 I think the other subtle issue I just -- I

14 think is worth mentioning is that there's a lot of

15 emphasis in the document in assessing study quality on

16 what's called representiveness. And I assume by that they

17 all mean generalizability. And I think that in a lot of

18 cases it's all misplaced emphasis. I feel as if some

19 studies are downgraded -- for example, the Cleveland

20 cohort in kids were effects of lead on -- only two were

21 not consistently seen.

22 It's, I think, downgraded. And it's

23 important, in part, because the population was felt to be

24 not representative of the generally most population

25 because of the high problems of alcohol and substance
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1 abuse during pregnancy.

2 And I think that -- there's two issues, I

3 guess. One is more of a -- I don't know if policy is the

4 right word, but obviously you want one or two that's

5 applicable to the generally most population because that's

6 the group that's of interest in terms of the policy that

7 will result from the science.

8 But I think the other issue is whether

9 representativeness or generalizability affects validity.

10 And they're not, in my mind, is not the -- they're not the

11 same. If something's not generalized, it doesn't

12 necessarily undermine. It's the written data.

13 So the fact that there was a high

14 prevalence of alcohol use during pregnancy and that cohort

15 doesn't necessarily mean that their findings are not

16 valid. And if it turned out that the effect of lead in

17 the context of prenatal alcohol exposure is different,

18 then in the context where prenatal alcohol exposure has

19 not occurred. That would affect the validity in some

20 study and how we really looked at the specific event. But

21 that's not how it's presented in the document.

22 So I think some things are -- the role of

23 representativeness, to me, is a little overemphasized and

24 is sometimes -- I think -- I'm sure it could be used to

25 undervalue studies that don't always find what the
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1 majority of the studies find. And I think that -- that's

2 just a caveat to keep in mind in sort of summarizing the

3 literature.

4 And then I -- again, this is a fairly

5 specific comment. But I think in an effort to provide

6 very specific health outcome categories, that was

7 generally done extremely well and was very helpful in all

8 senses. Both in terms of the robustness of the literature

9 summary, but also robustness of the causal assessments.

10 But sometimes the document reversed back to

11 more generalized statements, and we'll talk about

12 conclusions around, say, sensory effects of lead. Where I

13 think the sensory effects are quite different and we will

14 be hearing your decision. And the nice review that

15 depicts those different sensory components and listed

16 consecutively gets lost since the summary ends up combined

17 at the end.

18 So I would just urge you not to lose track

19 of the hearing advice and the more (unintelligible) that

20 you take and we'll make summary statements where you don't

21 list the benefit of that more specific analysis.

22 I guess the other thing -- one of the other

23 charge items is the extent to which the nervous system

24 outcomes have been grouped into appropriate constructs and

25 the appropriate parallels were drawn between endpoints of
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1 humans and animals. And I think that this also has the

2 proof, I think, that paring the text to the toxicology

3 summaries that deal more directly with a particular health

4 outcome that's been analyzed in epidemiology, that paring

5 them together so that they come in sequence is helpful

6 just in terms of being able to integrate those two

7 literature streams.

8 So I think I'll stop there because I'm sure

9 my other people have a lot to add. But, again, I think

10 it's much improved. And I think that this gray zone on

11 causality is going to be an area that we're going to have

12 to agree to disagree on in some cases.

13 DR. FREY: Okay. Thank you, Dr. Korrick.

14 Dr. Canfield.

15 DR. CANFIELD: Yes. Thank you for that

16 nice overview. So I would start with what I think is the

17 main issue that I have, and I'm going to say a couple of

18 words and I'm going to throw it to Gail and see if she

19 just wants to do my work for me.

20 And that is this grouping of -- we've got

21 these internalizing behaviors in a few places, but you

22 don't really take advantage of the grouping and the

23 effects of internalizing. And you're lumping attention

24 and attention-related behavior problems. And, again, what

25 we're asking you to do is clean nature at its joints in a
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1 way that probably not everyone agrees, but where the

2 joints are. So I'll give you that, and this may be good

3 enough.

4 But maybe, Gail, are you -- would you be

5 interested in talking about the internalized and

6 externalizing? I would say one possibility to consider is

7 to take internalizing, externalizing and attention. And

8 -- but Gail is more qualified. Is that something you

9 could help us with?

10 DR. WASSERMAN: Do you want me to talk now?

11 DR. CANFIELD: Yes. If you're -- if you're

12 -- if you would like, please.

13 DR. WASSERMAN: In terms of children

14 behavior problems, you do have two big clusters. You've

15 got internalizing problems and externalizing problems.

16 Mind you, they are highly correlated. And that -- that's

17 one concern I have in this section. And that doesn't --

18 we're not really talking about necessarily independent

19 outcomes. It's almost as though they give you an IQ, and

20 so are performance and durable aspects or executive

21 function and IQ. It's not like this is iterated.

22 It may be all the same problems we're

23 talking about, like having different outcomes from the

24 core. So that should be mentioned. But if you take the

25 big chunks in internalizing or externalizing, that would
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1 probably be the most (unintelligible) way to begin. And

2 that would put the extension problems in with the

3 externalizing where there's disagreement about that.

4 But simplest cutting of the wire,

5 internalizing on the line in and externalizing on the

6 other end. So within that issue, internalizing problems

7 would be things like anxiety. It would be things like

8 learning problems.

9 Mind you, there's another whole layer that

10 has to go on top of this, which is that there's a

11 difference between problems or symptoms or items on a

12 checklist which are generally looked at continuously and

13 more categorical diagnostic features.

14 So there's like two big things that are

15 like overlaying each other. But within the internalized,

16 if you could look at, you internalize and take your

17 problems and each construct has its how to part in the

18 diagnostic makeup as well as an incentive makeup.

19 And there are probably -- I agree. I got a

20 little confused with the conduct problems and

21 externalizing them separately because I would put the

22 conduct in the externalizing. As a subcategory I would

23 put the attention problems in with the externalizing as a

24 subcategory. And that might make things go a little bit

25 more smoothly. But they are intercorrelated probably on
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1 any attempt we you make.

2 DR. CANFIELD: So, I mean, what I was

3 struggling with is whether I could justify asking them to

4 seriously consider using externalizing and internalizing,

5 whether that would make life easier and this more readable

6 and we'd have a sudden exit of personnel from EPA.

7 DR. WASSERMAN: I think the text -- you

8 know, have a big group for internalizing. And within that

9 have all of the things, the diagnostic and the symptom

10 things as separate subcategories. And then that would

11 move the conduct problems as a subcategory of the

12 externalizing.

13 DR. CANFIELD: I included in my comments a

14 group reg. So at this point, maybe we can talk over lunch

15 or something about -- or at some point of what you think

16 of that, of you can give some feedback now. I don't know

17 if that's a --

18 DR. FREY: Well, yeah, procedurally we have

19 to deliberate in public on any advice that we would put in

20 the charge question or the letter, so -- and we can

21 provide advice whether or not EPA wants the advice.

22 That's another dimension.

23 DR. CANFIELD: Okay. Well, that's my call

24 then. Okay.

25 DR. FREY: But I guess to the extent if
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1 Dr. Vandenberg or others want to give us a little

2 perspective on how they receive this, we can do that now.

3 DR. VANDENBERG: Sure, if I might. So, you

4 know, this area is -- earlier we brought in some outside

5 folks that helped us and had a number of discussions. As

6 I think you're pointing out, there's a lot of ways of

7 framing this issues. And how you organize it at some

8 levels is very important, and at other levels is it not

9 that important. You know, as we're laying out the

10 evidence, we can -- I don't want to say tell a story, but

11 you're kind of bringing it together rigid information to

12 work with that doesn't really make sense.

13 I think we use the term "internalizing"

14 versus the "externalizing." I think what your framework

15 here presents is a way that structure is -- types of

16 outcomes to certain -- again, it's a structural way of

17 organizing.

18 I think what we could certainly do is look

19 very closely at this. Perhaps, if nothing else, bridge

20 this by bringing some reference into this context. And

21 there's a variety of ways to work on this. Because

22 otherwise it may have this fairly significant ripple

23 effect.

24 DR. CANFIELD: I think you can have

25 psychologist read this and say, I think, why don't they
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1 just talk about externalizing behaviors. So if you're

2 going to use the construct of internalizing, it usually

3 goes with externalizing, but -- and I -- so I guess I -- I

4 appreciate that you thought about it carefully.

5 DR. KIRRANE: Yeah. My only comment is

6 that it would be helpful for us if you made your comments

7 as specific as possible, and you have -- and then we will

8 very seriously consider that implementation. But like

9 John said, the extent that it kind of ripples throughout

10 the documents -- I don't think it's relevant in this case,

11 but please make very specific comments and we will

12 consider them seriously.

13 DR. WASSERMAN: I'm not sure we can do that

14 without, you know, moving -- flopping and moving text.

15 So, I mean, I think the issue is organization and

16 subcategories.

17 DR. KIRRANE: I think we (unintelligible)

18 received our -- you know, along the lines of that.

19 DR. WASSERMAN: Okay. Good.

20 DR. CANFIELD: Yeah. I just couldn't tell

21 whether putting externalizing out there, if you could just

22 kind of lay that out and say, Here's what we're needing

23 and let everything else then kind of flow. But that's up

24 -- you know the document at the writing level, so...

25 DR. VANDENBERG: Yeah. What you're saying
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1 here is -- we've made a big effort to do some

2 reorganization. And I think that the way you've laid this

3 out in your comments is very helpful. We've kind of

4 provided that context. So I think it's clear that this is

5 something that we should very carefully look into. We

6 haven't really done that just yet. But, you know,

7 certainly appreciate the comments.

8 DR. WASSERMAN: It's so much better. It's

9 much better.

10 DR. FREY: If I understand what you're

11 meaning, it sounds like you're talking about a text --

12 DR. WASSERMAN: Yes.

13 DR. FREY: -- category or something like

14 that. And that there may not be an unique one, and that

15 there may be a slightly better one or a significantly

16 better one than what's in there now. But in any case,

17 there's not one, right? And maybe another aspect of it is

18 that just acknowledging that there's more than one way to

19 categorize things, and here's what was chosen and some

20 rationale for that and maybe referencing that there are

21 other ways might also help some of the readers.

22 DR. WASSERMAN: I think there is --

23 (WHEREIN, unintelligible due to multiple

24 people speaking at once.)

25 DR. FREY: Okay.
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1 DR. WASSERMAN: Internalizing and

2 externalizing.

3 DR. FREY: Okay.

4 DR. WASSERMAN: And then with the impact, I

5 think you would have -- you could look at behavior as

6 continuous symptoms towards our diagnosis.

7 DR. FREY: Okay.

8 DR. VANDENBERG: Yeah, if you could -- I

9 don't know if you could pull this up, but on Slide 14 of

10 our presentation -- or maybe you have it in front of you

11 there. What you see is a chart for -- again, it's on Page

12 14. What we're talking about is we've got internalized

13 and we've got attention-related behavior problems. This

14 is some reorganization related to that. You know, in some

15 fashion, it's pretty straightforward.

16 DR. WEITZMAN: I think it's pretty simple.

17 DR. VANDENBERG: Yeah.

18 DR. WEITZMAN: The related table, 5-17, all

19 you need to do is put in external.

20 DR. VANDENBERG: Again, that's very helpful

21 as a way to kind of bridge this effective line. So thank

22 you.

23 DR. KORRICK: Yeah. I think it is simple

24 to it operationally, but I think it's kind of how -- and

25 this is specific to his comment. It's not going to impact
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1 (unintelligible). But I think this was an area where we

2 had some debate about causality and determinations; that

3 it's particularly important.

4 So right now attention to separating it out

5 from conduct and other externalizing behavior -- and you

6 have different degrees of causal assessment for those two

7 outcomes. So when you bind them, essentially, you know,

8 you're going to have to say you had internalizing

9 behaviors -- there's differences in robustness of

10 association for lead in one particular behavior.

11 DR. WASSERMAN: Within a subcategory.

12 DR. KORRICK: Within subcategories. So

13 there's going to be some full effect there. Again, the

14 issue of causality around attention and attention-related

15 behaviors was one that we have (unintelligible)

16 previously. And organizing it this way will help it be

17 clear to everybody, I think.

18 DR. CANFIELD: So one of the problems that

19 you'll encounter is that, when you're talking about

20 attention from a behavior problem standpoint, you're not

21 necessarily talking about the same phenomenon as

22 attention. You're talking about it as a neurocognitive or

23 information processing concept.

24 So I don't envy dealing with the problem or

25 -- but I -- that's what I see. It's some sort of
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1 attention that's separated out. And then you have the

2 attention-related -- you know, behavior problems as a ADHD

3 kind of world and clinical world, and that's different.

4 And I don't know whether that's something that you are

5 clear about in your own minds.

6 DR. FREY: Okay.

7 DR. CANFIELD: Why don't we move on to

8 Dr. Kosnett, if you want to take over and let me gather my

9 thoughts here for a second.

10 DR. KOSNETT: Sure. I wanted to add

11 comments to -- about the reversibility and persistency of

12 neurotoxic effects, as they discussed in the document.

13 There's a section on --

14 DR. FREY: Pull the mic closer to you.

15 DR. KOSNETT: Sure. There's a section in

16 the document, 5-3-12, that talks about lifestyle -- oh,

17 it's not lifestyle, lifestage of exposure. And there's

18 another section, 2.9.5 on Page 2-71 which summarizes some

19 of that. And my comment is this, Section 2.9.5 says it's

20 generally accepted that the effects of lead are not

21 reversible.

22 There's a mention in there of some evidence

23 that there may be some compensation or improvement in the

24 studies. There's more regularity to the discussion in

25 Chapter 5. There's studies in 2009 that show that
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1 children who had earlier high levels around age two, and

2 then by the time that they got to be about age seven, the

3 blood lead levels had gone down; that they performed

4 better than children do have high blood lead levels at age

5 two and stayed high. So if the blood lead levels come

6 down, they seem to do better.

7 So I think -- is it fair to say -- and I

8 want to get feedback from my colleagues. Is it fair to

9 say that there is -- that the issue of reversibility or

10 compensation, which is hard at times to sort out one from

11 the other, the extent of which it occurs is subject to

12 some uncertainty. And at least in some evidence it

13 suggests that the effects might be partially reversible.

14 Although, more studies -- I just wondered if a slight

15 modification of that is needed. What do you think?

16 Debbie?

17 DR. CORY-SLECHTA: Well, I would also

18 assume in that study that the reason that the blood lead

19 levels came down was because there was some kind of an

20 intervention to actively make sure that happened. I get a

21 little bit concerned because interventions by themselves

22 -- maybe that's like a huge placebo thing. So -- and this

23 is why we know very little about -- right now about

24 academic or other kinds of interventions that are able to

25 reverse the effects of lead. So I'm not convinced on the
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1 basis of that; that that would tell us necessarily -- it

2 tells -- it tells me a different story; that -- you know,

3 about the intervention, per se, more than reversibility.

4 And I guess I'm a little concerned about

5 the term "reversibility."

6 DR. KOSNETT: That's right. You're right.

7 Maybe it's compensation.

8 DR. CORY-SLECHTA: Right. Or, you know,

9 it's a proactive intervention. Not, gee, if we just leave

10 them alone -- or just terminate lead exposure that somehow

11 going to go away. We suspect it will go away. And that's

12 coupled with the toxicokinetic issue; that once we

13 terminate lead exposure, we're going to get lead moving

14 back out of the bones. So, you know, that's a dynamic

15 system which means that the whole issue of what's going on

16 toxicokinetically is confounded with that.

17 So I think it's much more difficult. And I

18 guess on the basis of that one study, I'm not willing to

19 say that, you know, reverse -- I wouldn't use the term

20 "reversibility." I think we know nothing about what

21 interventions are actually affected in non-exposed

22 populations from a cognitive standpoint.

23 DR. KOSNETT: Well, then there's a whole

24 section, 2.9.5, and it's entitled reversibility. So it's

25 -- you know, it doesn't mention Dr. Harmon's (phonetic)
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1 study. I don't know. You know, I think it's very

2 difficult to say. Rich, do you want to say something?

3 DR. CANFIELD: No.

4 DR. WASSERMAN: They're all sort of

5 stitched in between reversibility and stalling additional

6 incremental loss. I mean, we looked at exposure that had

7 different trajectories over time. And clearly there was a

8 loss to -- for kids who had worse prenatal and

9 (unintelligible). The kids who had prenatal exposure was

10 associated with a loss. And, however, so is postnatal.

11 So that the issue is not necessarily that you go back

12 that's at the time of that. So it's not really

13 reversible. But maybe you don't continue to take away

14 over time when the trajectory exposure. That's not

15 reversibility.

16 DR. KOSNETT: Well, the -- this is what was

17 interesting is that -- and I think this is true in the

18 Bellinger study, that if you had a high blood lead level

19 at two and your blood lead level came down when you were

20 seven, you performed as well as the kids at age seven that

21 never had a high blood lead level.

22 DR. KIRRANE: I mean, our study wasn't --

23 DR. KOSNETT: That wasn't -- see -- all

24 right. So that wasn't --

25 DR. CANFIELD: That's the exact conclusion
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1 from the Bellinger study. I could be wrong, but I just --

2 I didn't remember it as --

3 DR. KOSNETT: Well, I --

4 DR. CANFIELD: It was statistically

5 different. There may have been --

6 DR. CORY-SLECHTA: I just want to follow-up

7 again. So there's another sort of confound of those on

8 here that I try to keep reminding people of. If you're

9 not doing real well in first and second grade, you're not

10 going to be the valedictorian of your high school class.

11 So even if you stopped lead exposure, the fact that you're

12 behind in reading and behind in math, behind in -- you'll

13 probably lose your trajectory isn't going to be as good

14 anyway without some really proactive intervention.

15 So unsorting that from all these -- in

16 these studies that have gone on in terms of, you know,

17 which blood lead concentrations are the worst or best is

18 very difficult. Nobody has really attempted to do that as

19 far as I know. So, again, I -- you know, I just have

20 reservations about what we would say about reversibility

21 at this point.

22 DR. KORRICK: I think the other issue --

23 the distinction between reversibility, whatever we can or

24 can't say about it, and compensation is not clearly also.

25 So that if there's compensatory mechanisms because of the
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1 developmental (unintelligible) that allow kids to perform

2 better than you might expect at some point, I think that's

3 going to be highly variable in class populations. And

4 it's going to be sort of individual susceptibility issue,

5 and I don't think interpreting the literature based on the

6 promise of individual resistance is necessarily the best

7 thing to do.

8 I think it's just going to be too variable

9 by population and by individual characteristics. Those

10 variability causals are complicated. And it's not only a

11 function of environmental enrichment, but also individual

12 characteristics. I don't know. I think it's a -- it's

13 hard to say for a variety of reasons that lead effects are

14 reversible. And this is just one of the many reasons why

15 experts say that.

16 DR. FREY: I don't want to cut off

17 discussion, but I do want to point out that we are running

18 short on time. So with that I kind of want to circle back

19 to the charge question. I mean, so what we're trying to

20 aim for is what are we going to say to EPA in the charge

21 question. So to the extent they're discussion items, we

22 need to kind of move in that direction. And, Michael, did

23 you want to say something, and then Gail.

24 DR. RABINOWITZ: I've kind of tried to

25 address this way back in Chapter 2. This brings in some
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1 of the problem here about whether or not permanent --

2 whether or not it's really about permanence of an effect

3 or reversibility effect. I don't know if it helps clarify

4 things to talk about it in terms of permanence or

5 reversibility.

6 I did want to see in the context of

7 neurotoxicity of lead that there are a number of effects

8 of lead on obvious sections and (unintelligible), where

9 the effects really are reversible.

10 Also, I thought the document, in discussing

11 whether or not lead effects are reversible -- they kind of

12 rely on -- too much, I thought, on that the chelation did

13 not result in acute or non-acute. And it may not be --

14 this is because chelation not only results in

15 (unintelligible), but also redistributes lead in the body.

16 You may have more lead go in the sacral nervous system.

17 So any good chelation they do in terms of expelling lead

18 kind of complicates by being more within the brain.

19 So relying on chelation not to make the

20 child perform better doesn't mean lead itself. It's an

21 effect of chelation rather than lead, per se. Go ahead.

22 Thank you.

23 DR. WASSERMAN: It's good to know the

24 strength or limitations of the evidence. We talk about

25 child parental psychopathology as a contributor, as
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1 something that needs to be adjusted or -- consistently

2 through this chapter in several places, it uses almost the

3 same language that the relationship between parental

4 psychopathology and the original behavior or additive

5 behavior is unclear, so we dismiss it.

6 That's not the reason those studies are

7 compelling from parental psychopathology. It typically

8 could be part of the reason, but most forms of behavioral

9 disorder -- behavior problems are highly inheritable,

10 including all of conduct problems, all internalizing

11 problems. And the reason you would want to have that in

12 there is to pull that up.

13 So it's not -- it's a narrative, which I

14 agree mushy at best. It is in there in and of itself, and

15 important in and of itself.

16 DR. KOSNETT: I saw that point and I agree

17 with you.

18 DR. KORRICK: Yeah, I mean -- well, that

19 does come up a lot, and it's repeated throughout.

20 DR. WASSERMAN: The same language.

21 DR. KORRICK: But I think the issue is the

22 -- the issue is it will improve your estimate of lead

23 effects if you adjust for that because it's an important

24 determiner between the documents. But if it is not

25 confound or if it's not related to parental quality
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1 parenting.

2 So I think one argument to be made is

3 there's no good evidence it's related to quality

4 parenting. Failure to adjust for it may diminish the

5 precision of your lead effect estimate, but it should not

6 confound it. It should not bias it. So that's a

7 distinction that's important in the issue of, you know,

8 causal -- the strength of it would turn causality. And I

9 don't know if that was the intent -- was intended by that

10 language in the document or not.

11 (WHEREIN, unintelligible due to multiple

12 people speaking at once.)

13 DR. WASSERMAN: If a parent has a

14 behavioral disorder and is -- has antisocial personality

15 disorder or something and rears, one of the components of

16 that is neglectful parenting.

17 DR. KORRICK: Right.

18 DR. WASSERMAN: So you might not clean your

19 house, or you might not watch your kid when he's chewing

20 on the windowsill.

21 DR. KORRICK: But, no. I think it's a

22 legitimate concern as a confounder. But I think that if

23 there is uncertainty about whether parental

24 psychopathology affects those behaviors -- and, in fact,

25 in some cases it doesn't. Then it's not confounded.
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1 So I guess the question is -- I mean, this

2 is sort of a minor point, but if there's uncertainty about

3 the relationship between parental psychopathology and

4 those behaviors, then -- then you can't set it forward as

5 confounded.

6 DR. WASSERMAN: But lack of parenting is a

7 symptom.

8 DR. KORRICK: Right.

9 DR. WASSERMAN: It's a criteria for --

10 (WHEREIN, unintelligible due to multiple

11 people speaking at once.)

12 DR. KORRICK: Right. So maybe that

13 statement that's being used, if that's well-established --

14 which I don't know that were their term -- the statement

15 that it's uncertain what the relationship is to parenting

16 is the incorrect statement and needs to be corrected. I

17 don't know. I mean, that comes up a lot in the documents,

18 though. If you feel that's incorrect, that's actually an

19 important point just because it's a consistent theme.

20 DR. FREY: Okay. Other comments on Chapter

21 5? Susan -- or Rich, do you have something?

22 DR. CANFIELD: (No response.)

23 DR. FREY: Oh, well, I was going to wrap

24 up. And so if you have something, you know --

25 DR. CANFIELD: Well, I did want to make
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1 sure that I had the -- on the record that I think with

2 respect to the reversibility that we -- the interpretation

3 of the animal enriched environment study, if we could look

4 back at that and see if it -- you might think about it as

5 a deprivation versus experiential exposure to

6 complexities. Isn't that the group that was not given

7 enriched environment is actually in a impoverished

8 environment, and that is achieved (unintelligible)

9 evidence for reversibility in that setting.

10 Okay. I have some other things in mind,

11 comments, but I think most of them are pretty

12 straightforward. So, thank you.

13 DR. FREY: Susan, do you have feel that you

14 have the input that you need? Is there anything you need

15 from the panel that would help clarify what -- get them

16 right?

17 DR. KORRICK: Yeah. I think I'm okay.

18 DR. FREY: Okay. All right. Good. All

19 right. Well, I propose let's continue to Chapter 6. And,

20 you know, if there's some burning issue that comes up, we

21 can circle back if needed. But just in the interest of

22 time. So Chapter 6 is Potentially At-Risk Populations.

23 And the lead discussant is Deborah Cory-Slechta and then

24 Gail Wasserman and Michael Weitzman. So Deborah, you have

25 the floor.
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1 DR. CORY-SLECHTA: Okay. So I -- in my

2 estimation, the chapter was much, much improved over last

3 time. It's reorganized. There's better delineation of

4 what I would consider some of the sources of the risks and

5 the -- I thought the discussion of at-risk vulnerability

6 and susceptibility was very, very helpful. And the

7 chapter does a better job of summarizing the strength of

8 the evidence.

9 Now, what I saw is missing, and you guys

10 brought it up this morning, is any discussion of the

11 relative magnitude of these interactions of these risk

12 modifiers. And what you stated was that it's very

13 difficult to come up with some kind of estimation.

14 But, you know, the fact of the matter is

15 that I -- when I read it now, I can't tell which, if any,

16 of these factors are more or less important. And from a

17 policy point of view, I think that really matters because

18 EPA is committed/required to addressing vulnerability.

19 But right now if I have resources or

20 limited resources -- I don't know which one of these were

21 which, you know, of the set of these should I be more

22 concerned about.

23 And I think what you brought up today was

24 well, how would we go about doing that? Maybe if you

25 could in at least a range of effects, you know, there's
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1 overlapping effects. But give us some idea of the range.

2 Are we talking about 1 percent changes or 20 percent

3 changes with respect to, you know, a (unintelligible) or a

4 diet, whatever. Just give us some idea of the range.

5 At the end of the day, I fully understand

6 that, you know, the -- in a way we're trying to determine

7 whether the safety factors that we've been slapping on to

8 these reviews relate to what we know from the literature.

9 And you can't really pull it out, but at least give us

10 some idea of where these things fall on a scale of

11 magnitude. You know, one fold increase, something like

12 that.

13 And that was really my primary comment on

14 Chapter 6.

15 DR. FREY: Okay. Thank you. Let's see,

16 Dr. Wasserman.

17 DR. WASSERMAN: I think it's greatly

18 improved, but the section -- and then maybe this is just

19 stylistic. The sections on risk I thought -- sometimes

20 now, rightfully so, include multiple endpoints and

21 different associations for different subgroups. And you

22 have to read through the whole paragraph or section to

23 come up with an integrating perspective. I don't know

24 whether it would be helpful to give the reader that at the

25 beginning of the paragraph because I kept reading it
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1 thinking, Oh, that's appropriate; oh, no, it isn't. Or,

2 Oh, there were two girls; no, that doesn't work for boys.

3 And it was hard to pull it all together.

4 Whereas, if you had told me what I should

5 be looking for first, then I would have been able to

6 follow it. So I'm of the school that you say what you're

7 going to say, say it, and then say what you said. But

8 that's a lot of nothing.

9 And then occasionally the sections that

10 considers both human and non-human studies, without

11 clarifying exactly which it is -- and I think that is a

12 vital -- a very important distinction so that it would be

13 useful if each sentence sort of or each discussion of a

14 study brought us back to what the population of species

15 that were studied. And that's it.

16 DR. FREY: Okay. Michael.

17 DR. WEITZMAN: Thank you. I thought that

18 the chapter read much better in treating how each time I

19 view it I see things that I missed before, but I think are

20 still missing. So the lesion is as much with me as with

21 anybody else.

22 Having said that, I have a number of

23 comments that I don't think we need to discuss at large.

24 But there are a couple that we've touched upon, where

25 we've intubated but not dealt with in this particular
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1 section.

2 So for example, when we're speaking about

3 reversibility or exposure, I think that there needs, in

4 this section, to be some acknowledgement. But we don't

5 know how critical it is of exposure or whether it's

6 cumulative exposure or peaked at a particular age. So

7 that's not especially a large issue.

8 I do think that one of the things -- and

9 I'd love to hear feedback from other people. One of the

10 things that we've not talked about is that there are, from

11 a public health perspective, a very large number of

12 children with preexisting conditions that one could

13 hypothesize would place at an increased risk, given the

14 same lead exposure. So I'm talking about premature

15 babies, with those that have birth asphyxia, head trauma

16 or any host of things; prenatal exposure to alcohol,

17 cocaine or heroin, tobacco.

18 You mention at one point where the -- or

19 the chapter mentions that there's one study on prenatal

20 tobacco exposure and increased risks of ADHD, but you have

21 over 30 percent of our children living in households with

22 smokers. So (unintelligible) running in the second-hand

23 smoke exposure. They have deleterious effects that may be

24 additive, or they may preclude the lead effects or

25 diminish them. If, in fact, the same neurotransmitters
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1 (unintelligible) functions are effective.

2 There is one significant group of kids that

3 we haven't mentioned at all, and it's just a pretty easy

4 thing. And that's kids with sickle cell anemia tend to

5 get a peripheral neuropathies. And that was noted in my

6 previous discussions of this.

7 And then the only other thing that I have

8 for you is that the section on socioeconomic status and

9 race/ethnicity. It needs to be updated. We use data from

10 the 2000 census, and the population of children in the

11 United States in the past ten years is changing more in

12 terms of demography than it has any prior -- to any other

13 period in the United States.

14 And so many of those children's families

15 are largely coming from Asia and the Middle East, and so

16 they'll probably have multiple different avenues of

17 exposure. I don't know if there's any reason to assume

18 that given the same exposures they'd have different

19 outcomes. So I hope that's helpful.

20 DR. FREY: Gail.

21 DR. WASSERMAN: Smoking is, indeed --

22 prenatal smoking is one of the strongest risk factors for

23 ADHD, so it definitely should be in there and an active

24 point. And enough said it's just for smoking status,

25 looking at behavior problems. And some of the studies did
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1 have it, but it should be something to expand on.

2 DR. VANDENBERG: You know, just to clarify.

3 So, you know, some instances where we've got some specific

4 evidence and then others, as you were just citing, might

5 be more hypothetical. And so I think what we're trying to

6 do is portray the data that is available and not being

7 irrespective, even though it seems very reasonable. So --

8 did you have a comment?

9 DR. KIRRANE: Yeah. I had kind of a

10 specific question. So if you look at the slide, the 18th

11 slide. So for example, you had said you can't look at the

12 factors that were evaluated and just get a sense of what's

13 the most important one. So obviously I think everyone

14 would agree that childhood is a very important, you know,

15 in terms of lead exposure. But the evidence comes from

16 longitudinal studies, studies that don't have comparison

17 groups. So if we put a range of effects on asking myself,

18 Okay, so children versus adults or -- it doesn't make

19 sense in that -- so that's the kind of -- when we try to

20 do this, we try to do it, you know, methodically across

21 all the factors. And that's the kind of problem I'm

22 anticipating.

23 DR. VANDENBERG: So we have suggestions and

24 considerable outcomes on how do we do that. One thing we

25 did try to portray, for example -- and I think -- I
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1 mentioned about Raytheon (phonetic) -- Raison (phonetic),

2 I think is his name. Where we have some differences of

3 (unintelligible) groups. They aren't -- they are

4 statistically significant.

5 That was one way of portraying that.

6 Doctor, I'm not sure if that's what you were referring to,

7 but any suggestions about how we might bring more

8 information forward to give that sense of, These are the

9 big ones; these are not such big factors, we certainly

10 welcome.

11 DR. CORY-SLECHTA: Well, I think it may be

12 relevant -- it may be that you have to use different

13 mechanisms for different comparisons. Okay. So, you

14 know, what's happened in the case childhood versus adults

15 in the past. You know, we've seen these lines of blood

16 lead in neo-children. The effects are down here and the

17 adults start up there. So maybe something like that.

18 I'm also interested, though, if you have a

19 genetic polymorphism. You know, there's a lot of text

20 about, you know, well, they have this oleo or that. But

21 it's the outcome difference of 1 percent difference. You

22 know, so maybe different kinds of metrics, depending on

23 which comparisons we're talking about kind of thing.

24 You know, just off the top of my head, it's

25 one that I'm sort of thinking about. It may not be that
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1 you could be consistent. But if I'm a policy person at

2 EPA and I have limited resources, I want to know where I

3 can invest my money. I mean, I already know that

4 childhood is one thing. But should I be more worried

5 about X, Y and Z in childhood. You've got -- you know, so

6 sort of how can I package these in terms of where I might

7 go with my resources.

8 DR. FREY: Yeah.

9 DR. CANFIELD: Maybe I'm not remembering

10 something. I was thinking that this table included both

11 risk factors with respect exposure and also one with

12 (unintelligible), which means then it got more things

13 going on here. I can't see a way to put a single

14 statement on it.

15 DR. VANDENBERG: We have previously --

16 we've gone through a number of iterations about

17 susceptibility and vulnerability, behavior versus

18 (unintelligible). And this is, this is an ongoing

19 discussion as to how to best frame that.

20 DR. CANFIELD: I like the discussion, you

21 know.

22 DR. VANDENBERG: Yeah, it's a continued

23 thing to try to refine addressable in the nature of a --

24 of what, and so we certainly welcome your comments on

25 that.
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1 DR. CORY-SLECHTA: Well, you know, the risk

2 group -- the risk one that is working on this might see

3 what they think is elaborate. But they're certainly

4 looking to be able to pull these into the risk assessment

5 more directly instead of a safety-net approach. So maybe

6 they have something. But, you know, again, I'm not

7 convinced when I sort of try to think about what

8 comparisons I looked -- to me, I think we're going to have

9 a one size fits all. I just don't think we can.

10 DR. FREY: Okay. Are there other comments

11 on Chapter 6?

12 (No response.)

13 DR. FREY: Deborah, do you feel like you

14 have the input you need? Do you have any questions for

15 the panel?

16 DR. CORY-SLECHTA: No. I'm okay.

17 DR. FREY: All right. Let's move on to

18 Chapter 7. And the discussants of Chapter 7 can take as

19 much time as they'd like. The only thing between us and

20 lunch is Chapter 7, so -- so Dr. Allen is the lead

21 discussant, and Drs. Johnson and Lanno also are designated

22 to discuss this. So Dr. Allen.

23 DR. ALLEN: Draft 3 is fantastically

24 improved over the earlier versions. You really have done

25 an excellent job. It's well-written. It's lengthy, but
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1 it's reasonably easy to follow. And that -- we'll come

2 back again. It is long. You've done a really good job on

3 summarizing and integrating a huge amount of information.

4 By now reporting all of the concentrations -- or I should

5 say almost all the concentrations in mass units; that is

6 either milligrams/kilograms or milligrams per liter rather

7 than some in mass and others in molar units, it's much

8 easier for everybody to make comparisons among those

9 studies.

10 However, going along with improving it and

11 making it easier to read, makes it easier to find where

12 some improvements can be. And so it's -- I'd like to say

13 these are not as a real criticism, but as something to

14 follow on your improvements. All right.

15 First, it struck me, reading through here,

16 was it's now really clear that the concentrations

17 producing effects vary by many orders of magnitude. You

18 have ranges and effects attributed to them in your

19 Synthesis of New Evidence chapter -- or section, sorry.

20 They summarize this really well. And a Causal

21 Determination sections that follow that. But it isn't

22 easy to see where everything comes from. All right.

23 There is a lot of information in the tables

24 at the end, which is also very good. But what I would

25 like to suggest is the following. All right. Add a
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1 graphic for terrestrial and add a graphic for aquatic

2 effects that relates the various effects on the abscissa

3 to concentration on the ordinate. All right. You know,

4 go X's or bars that show ranges of things.

5 This is helpful in framing where you are,

6 what things are important and relative -- within relative

7 importance of one effect relative to another effect. And

8 now there's just so much material that a summary like this

9 would really help. All right.

10 The effects -- some of the effects that we

11 -- that you cite in there are real, no question about

12 that. They obviously see these. But they --

13 applicability of these to environmental situations is

14 either unproven or probably not there at all. All right.

15 And that doesn't come through. These are presented one

16 after another or with equal weight in terms of writing for

17 all of them.

18 And I went back to take a look at this.

19 The ISA has concentrations that vary by eight orders of

20 magnitude. Eight orders of magnitude. That's far more

21 than what the environmental range is, by many orders of

22 magnitude. The environmental range is only two or three

23 orders of magnitude, which we consider to be big. Eight

24 orders of magnitude is just -- I don't know what to do

25 with it. All right.
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1 So that is where I think that graphic would

2 come in there because if you were on blood lead levels

3 scale, you could see -- and put in there what the

4 environmental range is and what the environmental range,

5 then everybody can see, well, these are effects that

6 people saw, but they're way above the environmental range.

7 That's Point 1.

8 Point 2: A primary factor that controls

9 bioavailability in both aquatic and terrestrial systems is

10 the solubility of the tested material. If you put in --

11 you know, I can add in lots of lead to my fish aquarium by

12 throwing stones in. All right. You know, unless I hit

13 the fish on the head, I'm not going to really worry about

14 what the effect on the (unintelligible) would be. All

15 right.

16 So solubility really has to be dealt with.

17 Lead typically is added as a chloride or the nitrate

18 salts. Both dissociate completely to release lead ions.

19 Lead ions can react with ligands in the solution to form

20 soluble complexes and insoluble precipitates. All right.

21 For solutions that are near neutral pH, the

22 solubility of lead is fairly low. And many of the

23 concentrations reported in the literature likely exceed

24 the solubility of lead hydroxide, cerrusite or

25 hydrocerrusite. Incidentally, hydrocerrusite is the least
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1 soluble, and it is not mentioned anywhere.

2 You need to, I think, have a paragraph that

3 discusses solubility and the importance of solubility in

4 terms of exposure. And how you calculate this -- our --

5 and EPA has a wonderful computer program, that's this

6 MINTEQ.

7 To finish this. An example, all right, of

8 this is there is a discussion of foliar proline

9 concentrations in a macrophyte were reported to increase

10 in concentration-dependent manner as the lead

11 concentration increased from 20,720 to 1,036,000 of

12 micrograms of lead per liter. The upper concentration is

13 over 1 gram per liter. 1 gram of lead per liter is

14 soluble and the pH is too. It just wasn't the solution.

15 So what to make of the study, I don't know.

16 The relevance of the study -- the relevance of a gram per

17 liter of lead -- if I'm an industrial discharger, I'm --

18 first of all, the state's going to fine the hell out of

19 me, you know, if I'm discharging anything near that. But

20 now I'm wasting material. These are recoverable ranges.

21 So, you know, again, what's the relevance

22 of some of these things. And that's, I guess, all I need

23 to say.

24 DR. FREY: Okay. Thank you. Dr. Johnson.

25 DR. JOHNSON: I agree that the quality of
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1 this chapter of the document has improved tremendously

2 over the three drafts.

3 A couple of -- just a couple of minor

4 comments. One is sort of a literary one. It's that you

5 added a section called Fate and Transport of lead in

6 Ecosystems, presumably in response to concerns that this

7 should be an add.

8 But -- so it's there. It's nice enough.

9 It's assigned. But none of the material in that is ever

10 really brought back later in the, in the chapter. I note

11 in particular there's a section that talks about

12 half-lives and the time to reach steady state and all

13 that. And none of those values are, you know, ever

14 brought back later. You know, it just makes you wonder

15 why this -- it's necessary to have that stuff if it's not

16 used later.

17 The table in the appendices -- the tables

18 in the appendices are fantastic. I -- you know, they're

19 -- it's so good to be able to, you know, go through those

20 and see the different key studies and threshold levels.

21 It's like that -- really, really well-done. I really like

22 that.

23 I guess the only real major substantive

24 comment I have is just -- and it's something we've talked

25 about before, which is that the -- in trying to understand
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1 ecosystem effects for the air-quality standard means that

2 at somewhat we have to relate air concentrations to

3 concentrations in soils, terrestrial systems, water for

4 aquatic systems.

5 And there's a real -- you know, there's a

6 real disconnect, a real inability to make meaningful

7 relationships for those. And -- and so, therefore, to try

8 to understand -- to try model effects and come up with

9 relationships that can be used to set a standard becomes

10 really difficult.

11 This will come up again in the PA

12 discussion tomorrow. But, you know, I think it's a -- you

13 can hope that maybe there will be sufficient data in the

14 future to close the gap, but I think it's also appealed

15 to, you know, movements -- we're going relationally

16 forward in this regard to a critical load-type approach

17 for looking at ecological effects of lead because -- you

18 know, trying to do it with large CL data analysis is

19 probably -- given the amount of work that is going on or

20 not going on in the United States, it's hard to imagine

21 that we're ever going to get to the point where there's

22 enough field data to do it without some kind of critical

23 loads approach.

24 And I guess just to close that discussion,

25 I noted in reading through Chapter 3 it talked about
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1 precipitation lead. And the first sentence of this

2 section, it says, there's currently no precipitation

3 monitoring for lead in the United States.

4 I can't believe that. I mean, this --

5 there's no regular monitoring of precipitation of lead in

6 the United States. So in terms of us, you know,

7 suggesting for research -- or not research even, just

8 monitoring it.

9 It seems to me that you would pick lead as

10 sort of an -- even if we're in sort of a sunset period for

11 lead and, you know, lead as a concern as an ecological

12 pollutant, it seems to me we ought to do -- note the --

13 monitoring elements that are falling onto our ecosystem

14 and moving though them, so -- and that's it.

15 DR. FREY: Okay. Thank you. Dr. Lanno.

16 DR. LANNO: Thanks, Chris. First, I'd like

17 to reiterate what Drs. Allen and Johnson said, is that

18 this is a great improvement of the previous drafts. And I

19 really approve of the tables at the end. And as Dr. Allen

20 said, one of the pitfalls is reorganizing the data in a

21 very equal fashion as to answer the questions.

22 It was nice to see a breakout of the

23 freshwater and saltwater data so you can make heads or

24 tails of that and justify that based on bioavailability.

25 So in looking at the tables, one of the problems that I
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1 have -- or one of the problems that I kind of come up with

2 was -- as Dr. Allen suggested, that we get a figure

3 together that would summarize terrestrial and aquatic

4 exposures and the background concentrations or violently

5 levels you'd expect to see.

6 And where these effects occurred was we had

7 this issue about expressing concentrations in chemicals in

8 either mass volume or mass -- mass basis. And so we moved

9 to draw the Chestfield data. You've got many situations

10 where you have no (unintelligible) with lead in the

11 studies, and that's fine.

12 But what do you do with hydroponic data.

13 So you have a mass volume perspective from milligrams to

14 liter exposure to -- micrograms and milligrams to liter of

15 lead exposure in hydroponic systems, but I don't know how

16 you put that all together in one figure using those old

17 expressions of data and such.

18 So you may have to just justify that.

19 Maybe not including the hydroponic data, maybe not

20 including (unintelligible) or something like that.

21 So relevance of those two actual

22 environmental scenarios maybe should be clarified a bit.

23 And to follow along with that, many of the studies have

24 nominal concentrations. For the life of me, I'm not sure

25 what (unintelligible). That just adds some confusion to
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1 what the actual exposure dose is of lead in the system.

2 So if you were to include the nominal

3 values on the figure, it might be indicated as a different

4 color or a different symbol than the actual measured

5 values. And before a figure, I would suggest that maybe

6 you go to the U.S. EPA (unintelligible) document and see

7 how they set up their different concentrations and

8 different responses to -- lethal responses to the survival

9 than they have whole organisms -- sublethal responses,

10 like growth and reproduction. They have the subordinates

11 and biomarker types.

12 But that would be a good place to take a

13 look at a figure to start summarizing data. I have

14 further comments, but we can just talk about that later.

15 DR. FREY: Okay. Great. Other members of

16 the panel, comments on Chapter 7? Oh, I'm sorry. Go

17 ahead.

18 DR. RABINOWITZ: Quick question. Does EPA

19 monitor precipitation for anything, or they monitor it for

20 lead?

21 DR. CANFIELD: Yeah, there's the

22 atmospheric that's the ascitic deposition that someone

23 spoke about (unintelligible).

24 DR. FREY: Yeah.

25 DR. KOSNETT: I had a question of my
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1 colleagues who were focusing on the logical impacts that

2 were discussed a lot in Chapter 7, but there's a section

3 in Chapter 2, 2.9.7, which is clearer in this document

4 than compared to the last document. It's called

5 Ecological Effects and Corresponding lead Concentrations.

6 And it has a sentence in there, it says:

7 There is limited evidence to relate ambient lead

8 concentrate -- ambient air concentrations of lead to

9 levels of deposition onto terrestrial and aquatic

10 ecosystems and to subsequent movement of

11 atmospherically-deposited lead through environmental

12 compartments (e.g., soil, sediment, water, biota).

13 And I read that and I said, There's limited

14 evidence that relate to air concentrations of lead to the

15 ecosystems. And I'm wondering if you agree with that

16 because we -- from a unity epidemiology perspective and

17 clinical perspective, we found that when there's elevated

18 levels of lead being emitted into the air, there's -- I

19 wouldn't call the evidence limited to say that you don't

20 think it's healthy in children. And there's a lot of

21 Superfund studies and everything that show that there's a

22 relationship. It may not be the current air lead.

23 DR. ALLEN: You're looking at the a

24 suspended (unintelligible). To get to ecological

25 receptor, those have to be positive, be soluble and
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1 transported and then be wrapped. There's a lot more

2 stages in not monitoring -- and that's the -- that's the

3 critical loads information that we were discussing. And

4 we don't have good critical loads models. We don't have

5 models, really, that allow us to do how emission of lead

6 from, say, a stationary source that then effects the

7 ecosystem or all its transports.

8 DR. KOSNETT: So we know more about the

9 human ecosystem than the --

10 DR. ALLEN: Yes. Yes. It's a much simpler

11 system.

12 DR. KOSNETT: We know much more about urban

13 settings than --

14 DR. ALLEN: Yes. Yes. Yes.

15 DR. HOPKE: I forget you've got solid

16 surfaces (unintelligible) depositing in the soil that --

17 which is soluble. There was a lot of that -- there was

18 some of that worked on in the settings (unintelligible),

19 but that was a high level. You know, we have different

20 sources now to be used in the composition particles, and

21 their chemistry in the environment is not going to be the

22 same.

23 (WHEREIN, unintelligible due to multiple

24 people speaking at once.)

25 DR. ALLEN: Michael, there's another large
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1 difference that I see between the ecological system, and

2 that is that we see effects much lower in dosages than

3 what we see here. And overall, when I look at a number of

4 this (unintelligible), I find when I look at the logical

5 ones, the most sensitive endpoints are depth. And that

6 makes no sense at all biologically. And that means that I

7 don't -- I think what that means is that we really don't

8 understand the ecological system well. We sure as heck

9 don't understand biomarkers in ecological systems.

10 DR. JOHNSON: The connection between air

11 concentrations and deposition is sort of -- this section

12 starts with looking at the long and hard studies going

13 back through the period of use of lead gasoline, for some

14 sites there is good, sufficient basis to relaying

15 emissions to deposition. But in many of these studies,

16 and the ones I know of, they emitted air concentrations.

17 If you can kind of get the air concentrations, you can

18 kind of back into that way. But, again, that's -- that's

19 characterizing the whole argument of that lead gasoline

20 created. Whether those relationships would hold now,

21 they're very much different. It's unclear.

22 DR. FREY: Okay.

23 DR. KOSNETT: Can I say one other thing?

24 DR. FREY: Sure.

25 DR. KOSNETT: I wanted to -- I asked you
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1 something earlier about Dr. Bellinger's study, on that

2 reversibility. And I think I mischaracterized that. It

3 was prenatal effects that -- in Dr. Bellinger's studies

4 that assumed to dissipate or --

5 DR. CANFIELD: That was Bayley effects that

6 considered -- that found the (unintelligible). It's not

7 clear whether it was a change in instrument or a change in

8 -- a measurement change.

9 DR. KOSNETT: He stills shows that during

10 the fact of two -- that two years of age --

11 (WHEREIN, unintelligible due to multiple

12 people speaking at once.)

13 DR. KOSNETT: No. On later, on later life

14 effects, in his perspective study. There was another

15 study by Dr. Cheng and Ken Dietrich (phonetic) that looked

16 at their cohort and looked at the TOC setting. And they

17 felt that at age -- that the children that came down by

18 age five, compared to the levels of two, improved.

19 DR. CANFIELD: In that one study?

20 DR. KOSNETT: Yeah. Right.

21 (WHEREIN, unintelligible due to multiple

22 people speaking at once.)

23 DR. KOSNETT: But, anyway, I

24 mischaracterized it. It was the prenatal effect. And

25 that was in this publication that I -- in the PHP in 1990.
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1 I just wanted to clear that up for the record.

2 DR. FREY: Okay. Thanks. Anything else on

3 Chapter 7?

4 (No response.)

5 DR. FREY: Okay. I think, actually, some

6 of Dr. Kosnett's comments prompted me to -- it would be a

7 good idea for the discussants on each of the Chapters 3

8 through 7 to also give some thought as to whether there's

9 implications for -- I guess especially Chapter 2, in the

10 summary if there are any, you know, issues that, you know,

11 are not clearly communicated or if there's a mismatch or

12 something missing or so on, for Chapter 2, if you could

13 make sure to let Michael know that since he's the

14 coordinator of the comments on Chapter 2.

15 So please give that some thought. So I

16 guess I'll specifically mention the lead discussants of

17 Chapters 3 through 7 are George, Sean, Susan, Deborah and

18 Herb. But really I think it's a kind of panel-shared

19 responsibility.

20 DR. WASSERMAN: Will the comments in

21 Chapter 2 change as we justify the changes?

22 DR. FREY: Yeah. We certainly can do that.

23 I mean, so we --

24 (WHEREIN, unintelligible due to multiple

25 people speaking at once.)
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1 DR. FREY: But to the extent -- you know,

2 and I guess, also, there may be things that in the

3 chapter, are important to fix in that chapter that may not

4 have implications for Chapter 2. All I'm saying is just

5 be mindful of it. If you see a link, it helps to call

6 that out.

7 We'll definitely consider that in our

8 review of -- our later review of our responsive charge

9 questions, which we are planning -- again, as I mentioned

10 earlier, we'll have a teleconference on April 1st to go

11 over a hopefully close to final draft of the response to

12 charge questions, and we can definitely come back to this

13 issue of concordance among the charge question responses.

14 I know we have at least one clarifying

15 comment, which Aaron now will communicate. I think as far

16 as other issues here, I think we've covered everything we

17 need to cover. So I'll let Aaron communicate any

18 clarifying comments and also I think if there are any

19 housekeeping announcements, and then I'll just make a

20 couple of quick remarks.

21 MR. YEOW: Okay. So we have one request

22 for a public comment. But she was not able to be on the

23 line, but she asked me to read something. And I will not

24 try a female voice impersonation. Okay. So these are

25 public comments from Anita Meyer, Department of Defense
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1 Chemical and Material Risk Management Program. Well, I

2 should also note that these have been e-mailed out to you,

3 and they're available on our website was well.

4 The Department of Defense Chemical and

5 Material Risk Management program would like to call the

6 Panel's attention to a recent (Dec 2012) National Academy

7 of Science study funded by DoD titled "Potential Health

8 Risks to DOD firing Range personnel from Recurrent Lead

9 Exposure".

10 The recent findings in this report would be

11 useful for inclusion in Section 4.1.3.4; for example one

12 of the major findings is that "...the OSHA standard

13 provides inadequate protection for DOD firing-range

14 personnel and for any other worker populations covered by

15 the general industry standard. Specifically, the premise

16 that maintaining blood lead levels under 40 μg/dL for a

17 working lifetime will protect workers adequately is not

18 valid." As a result of this report's findings, the DoD is

19 reviewing its guidelines and practices for its firing

20 range personnel."

21 So that's it for that comment there. And

22 then -- so in terms of housekeeping items, lunch is not

23 provided and the hotel does not have lunch. So we're

24 going to have to -- and Leslie has a list of restaurants

25 out front here.
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1 And the hotel might provide a shuttle, I

2 think, but it only can take like six at a time or

3 something like that. So, you know, I walked it last

4 night. There's a shopping center about ten minutes away,

5 and it has a lot of stuff in there. It's not a bad walk,

6 it's like ten minutes. And, you know, we did eat a little

7 bit in the lunchtime, but we still have a good hour and a

8 half for lunch. So it should be sufficient time for that.

9 But if you need a list of restaurants or whatever, you can

10 check with Leslie out front here. And then I'll just turn

11 it back over to Chris.

12 DR. FREY: Okay. Well, just a reminder to

13 -- on the homework assignment to -- I think while it's

14 fresh is a good time write the draft responses to the

15 charge questions. And if you can e-mail those to both me

16 and Aaron anytime this evening, that would be great so we

17 can get a sense of where things are.

18 I would like to thank the EPA, the National

19 Center for Environmental Assessment and all of their

20 hardworking staff there. And, John, if you would like to

21 say something?

22 DR. VANDENBERG: I would just like to

23 extend our appreciation. I think it's been a very helpful

24 discussion this morning. The written comments are very,

25 very helpful. So, again, thank you for your sustained
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1 support. We very much appreciate it.

2 DR. FREY: And at what time did we want to

3 ask and see for the fourth draft? No. I think we will

4 find -- I think it's fair to say we'll find that the --

5 with our comments that the ISA is adequate for its

6 intended purpose. They're bringing the endorsement that

7 you're looking for.

8 (WHEREIN, unintelligible due to multiple

9 people speaking at once.)

10 DR. FREY: But we're not -- as a panel,

11 we're not asking for a fourth draft. No. Okay. All

12 right. Well, with that, have a good lunch.

13 (WHEREIN, a lunch recess was taken from

14 12:44 p.m. to 2:17 p.m.)

15 DR. FREY: Okay. Let's please get started.

16 Welcome back from lunch. Our agenda this afternoon is --

17 we'll start with a presentation from EPA on the draft

18 policy assessment. We have a couple of comment sessions

19 scheduled, but we don't have any public commenters. So

20 we'll move then into the panel discussion. And today

21 we're scheduled to try to cover Chapters 1, 2 and 3 on the

22 policy assessment before we break. And then tomorrow

23 morning we'll cover Chapters 4, 5 and 6.

24 And as mentioned earlier, if there are any

25 public comments -- there is an opportunity for clarifying
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1 comments from the public at the end of tomorrow morning's

2 session. Are there any panel members on the phone?

3 (No response.)

4 DR. FREY: Okay. All right. Well, with

5 that I would like to turn the floor over to the EPA's

6 Office of Air Quality Planning and Standards.

7 MS. WEGMAN: Thank you, Chris. Good

8 afternoon everybody. My name is Lydia Wegman. I am the

9 director of the Health and Environmental Impacts Division

10 in the Office of Air Quality Planning and Standards. And

11 it's my division that has done the work on the risk and

12 exposure assessment and the policy assessment as well as

13 the work that's been done by our sister division, The Air

14 Quality Assessment Division.

15 And I'll just quickly introduce the folks

16 that are here. Dr. Deirdre Murphy, Ms. Ginger Tennant,

17 Dr. Karen Martin, Mr. Kevin Cavender. Where's Zach? I

18 can't see him. Dr. Zach Pekar and Mr. Lewis Weinstock,

19 he's in the back there. And all of us are here and

20 available to answer questions as discussion proceeds.

21 Okay. I think many of you are familiar

22 with this slide, but I just want to remind folks what the

23 process is that we go through in setting National Ambient

24 Air Quality Standards. And then the next page I'll go

25 through the schedule for this particular review.
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1 But overall we start with a kickoff

2 workshop. We have -- if you go to the middle of this

3 slide, you start with an integrated review plan, which we

4 have done. We have the integrated science assessment.

5 And you, of course, have been reviewing the third draft of

6 that ISA today. We'll also be -- you have also reviewed

7 the risk and exposure assessment, in this case the only

8 draft we have planned for that -- yeah, just the planning

9 documents on that one. And then you have reviewed the

10 draft of policy assessments.

11 And as you can see on the far right, you

12 review all of these documents and we also take public

13 comment. The next step after we complete this process is

14 to develop a proposed rule. And this is on the -- toward

15 the bottom on the left. And we propose a decision --

16 well, we draft the proposed rule. And that goes to the

17 interagency group, which is a group managed by the Office

18 of Management and Budget.

19 And we issue the proposal, and we have

20 public hearings and we take comment. And then we have the

21 draft final notice, which again is reviewed by the Office

22 of Management and Budget and other interested federal

23 agencies. And then we get to the final decision on the

24 standard.

25 So you can see why this process can take a
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1 minimum of five years. Was there a question?

2 (No response.)

3 MS. WEGMAN: No. Okay.

4 DR. WEITZMAN: When do you start again?

5 MS. WEGMAN: When do we start again? Well,

6 we are in the middle right now, as you know, of the lead

7 review having completed the last one in 2008. So we will

8 move forward. And as you will see from the next slide,

9 we're not going to make our five-year schedule. But we're

10 going to be darn close.

11 So where are we in this review. The red --

12 the highlights in red are where we are today at the

13 meeting with you. And, of course, this afternoon we'll be

14 talking about the draft policy assessment.

15 We plan to issue the final policy

16 assessment this summer with the plan -- the goal of having

17 a proposed rule out in January of next year, and the final

18 rule in October of 2014.

19 I want to note, as you are aware, that we

20 are not planning to do a second draft of the policy

21 assessment. As we noted in the cover letter that we sent

22 you, the cover memo, at this point we don't have any

23 substantive information that we would add that would

24 provide a basis to developing a second draft of the policy

25 assessment.
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1 And so this is the one draft that we're

2 planning, and we very much look forward to hearing your

3 comments on it today. And we appreciate the comments that

4 we've received so far and all the work that you've put in

5 to reviewing it. I will note that when issued the final

6 policy assessment, you are welcome to offer comments to us

7 on that if you wish. We won't be soliciting comments on

8 it. But if the CASAC panel has additional comments that

9 it wish to offer, we would certainly take those into

10 account as we move forward in the rulemaking.

11 And I'll also note that there have been

12 occasions where CASAC panels have provided comments to us

13 on our proposed rules. So I want to note that we're not

14 going to be soliciting comments in that way. But to the

15 extent the panel wish to provide additional comments,

16 there will be a couple of opportunities for that even

17 though we're not going to be providing a second draft of

18 the policy assessment to you.

19 So unless there are any questions, I'd like

20 to briefly -- yes?

21 DR. RABINOWITZ: Somebody asked me to ask

22 what was the budget for this?

23 MS. WEGMAN: I can't tell you right now

24 what the budget is for it, but we provided the resources

25 that we felt were needed for this review. And our prime
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1 resource here are the people who have done the work at --

2 you know, a standard team working on it. So I can't --

3 DR. WASSERMAN: Great job.

4 MS. WEGMAN: That's what I think. I think

5 they've done a great job. Thank you. Any other

6 questions?

7 (No response.)

8 MS. WEGMAN: Okay. I'm then going to turn

9 it over to Dr. Murphy. And I think we've already -- I

10 guess the next slide --

11 DR. MURPHY: Yeah. In addition to the

12 people Lydia mentioned, there's also Dr. Halil Cakir in

13 the back as well, which is some of the air quality

14 analysis. If there's questions on that, he can answer

15 them.

16 So moving to the next slide. Who has

17 control of this?

18 MS. WEGMAN: You do.

19 DR. MURPHY: Oh. Sorry. Okay. This

20 morning there was mention to me that someone like to be

21 told what they were going to be told, so this slide is

22 giving you a heads up of what we will briefly cover in the

23 remaining slides. Just touching on the purpose and

24 description for the policy assessment, noting the history

25 and multimedia aspects associated to lead NAAQS and
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1 summarizing the key considerations for the primary

2 standard. And Ginger Tennant will go through those for

3 the secondary standard and then just briefly touch on the

4 overview of the charge.

5 With regard to the policy assessment, the

6 policy assessment presents a staff evaluation and

7 conclusion on the policy implications of key scientific

8 and technical information. The draft policy assessment,

9 which you-all are reviewing, presents the preliminary

10 staff conclusions.

11 Importantly, the policy assessment helps to

12 bridge the gap between the scientific and technical

13 assessments presented in the ISA and REAs that are

14 considered in the review and the judgments that are

15 required by the EPA administrator in determining whether

16 it's appropriate to retain or revise the National Ambient

17 Air Quality Standards.

18 Development of the draft policy assessment

19 is also intended to facilitate CASAC advice to the agency

20 and recommendations to the administrator as provided for

21 in the Clean Air Act, and also to facilitate public input

22 and comment in the early phases of reading.

23 So just briefly, the National Ambient Air

24 Quality Standards for lead were initially set in 1978.

25 Most recently our review of the 1978 standard was
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1 completed in October of 2008. As a result of that review,

2 EPA concluded that the large body of evidence that had

3 been accumulated over that three-decade period called into

4 question the adequacy of the primary and secondary

5 standards.

6 With regard to the primary standard, EPA

7 concluded that it was not requisite to protect public

8 health with an adequate margin of safety as required by

9 the act. And we substantially revised the standard,

10 including the lowering of the level of by an order of

11 magnitude from 1.5 to 0.15 micrograms per deciliter.

12 With regard to the secondary standard, we

13 concluded that it needed substantial revision. However,

14 the relevant data were lacking to provide a basis for

15 setting a secondary standard independent -- of an

16 independent basis than that for the primary. And so it

17 was revised to be identical in all respects to the

18 primary.

19 The review of as a lead National Ambient

20 Air Quality Standards involves complexities that different

21 and unlike any of the other National Ambient Air Quality

22 Standards. The persistence of lead contributes to its

23 multimedia distributions throughout the environment and

24 throughout human exposure microenvironments.

25 Also, the persistence contributes to a
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1 tempo-complexity that in that lead that is emitted during

2 the time -- or has been emitted during the time prior to

3 regulation or during the time of more relaxed

4 recommendation has contributed to concentrations in the

5 environment and in human populations. That remains today

6 in the older generation of human populations.

7 And this complicates our consideration in

8 this review with regard to the adequacy of the now current

9 standard. And these figures was used in the policy

10 assessment to try to illustrate some of them.

11 When we go into the review, the originating

12 question that we begin with is: Does the currently

13 available scientific evidence and exposure risk-based

14 information support or call into question the adequacy of

15 the protection afforded by the current lead standard? And

16 we ask that, first, with regard to primary and then

17 secondary.

18 Traditionally, we turn, first, to

19 considerations of the evidence and then move on to

20 considerations of the exposure risk-based information in

21 thinking about that question.

22 In this review, the evidence available

23 since the last review continues to indicate neurocognitive

24 effects in young children as the most sensitive endpoint;

25 that blood lead is the most appropriate lead exposure/dose
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1 indicator for health effects characterization; that air

2 lead contributes to lead in blood; and that air-to-blood

3 ratio -- estimates of air-to-blood ratio that have been

4 published or made available since the last review fall

5 within the ranges that were available at the time of the

6 previous review.

7 The risk factors that are recognized to

8 increase exposure or susceptibility to lead have been

9 recognized to include early childhood (including prenatal

10 life state), nutritional status, proximity to sources

11 (including residential factors) such as lead in housing

12 and some racial and ethnic backgrounds.

13 And then lastly, as in the last review, a

14 key role was played by epidemiological studies of blood

15 lead and also by studies that relate air concentrations to

16 lead in children's blood. And those will provide for

17 conclusions with regard to health effects of ambient air

18 lead.

19 Additionally, the limited newly available

20 evidence in this review on inputs to the evidence-based,

21 air-related IQ loss framework that was developed in the

22 last review are generally consistent with what was

23 available at that time.

24 The framework integrates two types of

25 relationships, relationships between air -- lead and air
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1 and lead in children's blood and relationships between

2 lead in children's blood and their cognitive impact, their

3 IQ. And this framework was used in the last review to

4 consider the evidence, particularly with regard to the

5 subset of children that are most exposed to lead in the

6 air.

7 Previously identified uncertainties still

8 remain in this review. Those include those with regard to

9 the shape of the dose-response curve for neurocognitive

10 decrements or IQ of air-related lead in young children,

11 uncertainties with regard to air-to-blood ratios that

12 related lead and air to lead in children's blood,

13 particularly with regard to the steps that transfer lead

14 from air through the exposure pathways to lead in

15 children's blood under today's circumstances for exposure.

16 And there's also uncertainty with regard to

17 the role of current air lead exposures in contributing to

18 other health effects in other populations.

19 And moving on to risk-based considerations.

20 We draw the common results of the risk assessment that was

21 developed in the last review. This was completed in

22 November of 2007. So we'll refer to it as the 2007 REA in

23 the document.

24 And for considering risk associated with

25 the now current standard, we focused on results from that
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1 review from two different case studies, one which is

2 referred to as the generalized local urban case study.

3 And for that one we've performed an interpolation of

4 results that were initially -- of analyses that were

5 initially conducted for two air quality scenarios which

6 bracket those associated with the current standard. And,

7 also, there's a location specific urban case study for

8 which the conditions are comparable to the current

9 standards.

10 We concluded that the air-related risk

11 estimates from those two case studies are roughly

12 consistent with and generally supportive of the estimates

13 that are derived from the evidence-based framework.

14 The estimates are approximate. We

15 recognize them to be approximate and characterized by two

16 bounds, and upper bound and a lower bound. And we have

17 limitations in the ability to quantify air-related

18 exposure and risks.

19 This effect on the upper bound contributes

20 to the overestimation of that bound, particularly at lower

21 air concentrations. And that's a function of the methods

22 and data limitations in the risk assessment.

23 Uncertainties that were previously

24 identified with regard to the risk assessment still

25 remain, and including the uncertainty -- included that the
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1 uncertainty in air-related risk is greater in air quality

2 scenarios under lower air concentrations.

3 With regard to the preliminary staff

4 conclusions, we conclude that the current body of

5 evidence, in combination with the exposure/risk

6 information, supports the primary standard as protective

7 as the current standard.

8 Further, we've preliminarily concluded it

9 is appropriate to consider retaining the current standard,

10 including all its elements, without revision based on

11 consideration of the health effects evidence, including

12 particular emphasis on the evidence-based air-related IQ

13 loss framework. And the key aspects of this framework are

14 consistent with the evidence in the last review.

15 Also based on consideration of the exposure

16 risk information drawn from the 2007 REA, as supporting

17 information, along with its associated complexities and

18 limitations. And we consider reasonable judgments on

19 uncertainties in the evidence and exposure/risk, including

20 increased uncertainty at lower air levels, judgments on

21 public health implications of estimated air-related blood

22 lead and risk levels under the current standard and

23 judgments on the appreciable uncertainty as to whether

24 there would be reductions in the public health risk from

25 alternative lower standards.
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1 And with that, I'll turn it over to Ginger

2 for the secondary.

3 MS. TENNANT: Thank you. Okay. So this is

4 the question we're considering with regard to the

5 secondary standard in the policy assessment. And it's

6 essentially the same kind of question that you were asked

7 for the primary. Does the currently available scientific

8 evidence and exposure/risk-based information, as reflected

9 in the ISA and REA, support or call into question the

10 adequacy of the protection afforded by the current

11 secondary lead standard?

12 Okay. And so, again, similar to the

13 primary standard, we'll walk through the evidence-based

14 considerations, the risk-based considerations and then

15 into the preliminary staff conclusions.

16 Again, we have the evidence-based

17 conclusions. And this is just an overview of the main

18 evidence-based considerations that were presented in the

19 draft policy assessment that you're reviewing today.

20 The evidence available since the last

21 review continues to indicate that lead deposition to soils

22 has decreased since the phase-out of leaded on-road

23 gasoline; that bioavailable lead is a better predictor of

24 effect on organisms than the overall amount of lead in the

25 system; that lead has effects on growth, reproduction and
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1 survival, and that these effects can be adverse to

2 organisms and ecosystems.

3 There continues to be limited evidence to

4 link, as we were discussing this morning, the current

5 ambient air lead emissions and deposition to environmental

6 media and then to ecological effects.

7 And the connection between the air

8 concentration and ecosystem exposure and associated

9 potential for welfare effects continues to be poorly

10 characterized and is more so for the conditions associated

11 with the current lower standards than had been the case

12 for the prior standard.

13 Okay. And so this is for the risk-based

14 considerations. So given the evaluation of the newly

15 available evidence, we concluded with case studies that

16 the available evidence didn't provide the basis for

17 developing new ecological risk and exposure assessments.

18 So what we've done is to characterize the

19 case studies presented in here, the 2006 pilot risk

20 assessment, which was the first draft of the REA. There

21 was later drafts that looked at the primary standard, but

22 this is the one that looked at the ecological standard.

23 So that's the difference between the 2006 and the 2007

24 that Deirdre was talking about.

25 And so what we've done here is look at
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1 that. And to the extent to which those case studies were

2 part of the commissions that are associated within our now

3 current standard.

4 And so as you can see, the case study

5 results vary. The primary and secondary lead smelter case

6 studies are located in counties which exceed the current

7 standard. It's unknown whether the current air

8 concentrations at the near roadway case study sites exceed

9 the current standard, although the soil concentrations

10 include deposition that would be associated with higher

11 past concentrations, including usage of leaded gasoline.

12 In the Hubbard Brook Case Study, the

13 ambient air concentrations likely do not directly impact

14 the stream lead levels under air quality conditions

15 associated with meeting the current standard. And that

16 was the semi-conclusion that was reached in the last

17 review.

18 The extent to which the past (vs current)

19 air emissions of lead have contributed to surface water or

20 sediment concentrations at the locations identified in the

21 Nationwide Screen continues to remain unclear.

22 And so when considered with regard to

23 air-related ecosystem exposures likely to occur with air

24 lead levels that just meet the current standard, the risk

25 information does not provide evidence that the current
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1 standard is inadequate.

2 And so these are the preliminary staff

3 conclusions with regards to secondary standard. Currently

4 available evidence does not include evidence of

5 significant effects at lower concentrations or evidence of

6 higher level ecosystem effects beyond those reported in

7 the last review.

8 There are significant difficulties in

9 interpreting effects evidence from laboratory studies to

10 the natural environment and then linking those effects to

11 ambient air lead concentrations. No new critical loads

12 information is available that would inform our

13 interpretation of the public welfare significance of the

14 effects of lead in various ecosystems.

15 Therefore, the risk evidence does not call

16 into question the adequacy of the current standard, and

17 there is no new evidence to inform the consideration of a

18 distinct secondary standard.

19 Therefore, preliminary staff conclusion was

20 it's appropriate to consider retaining the current

21 standard without revision.

22 And now I'm going to hand it back to you.

23 DR. MURPHY: And I'll just touch briefly on

24 the areas of charge questions that's on the table contents

25 of the document as well. The first charge question is
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1 with regard to introductory and background material which

2 are described in Chapter 1, and we're asking this

3 regarding to our characterization of the context and

4 background provided on past reviews and the scope for the

5 current review.

6 Then in Chapter 2 we ask the panel to

7 consider characterization of the most relevant information

8 -- whether or not we characterized the most relevant

9 information on emissions, air quality, lead concentrations

10 and other media and ambient lead monitoring information.

11 With regard to the primary standard, we

12 have two chapters, Chapter 3 and Chapter 4. Chapter 3

13 focuses on the health effects and exposure/risk

14 information. And we've asked this very charge questions

15 for comment on our characterization of key aspects of the

16 health effects evidence, including differences from the

17 last review and the characterization of quantitative

18 exposure/risk estimates, and associated limitations and

19 uncertainties, in a context of the current review.

20 And then lastly, with regard to the primary

21 in Chapter 4, the charge questions speak to the question

22 of our presentation of considerations informing the

23 preliminary conclusions, including focus on the

24 air-related, evidence-based, IQ loss framework. And we're

25 interested in hearing the panel views on the adequacy of
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1 the current standard, including all of these elements.

2 And with regard to the staff conclusion, that the current

3 standard is adequate without revision.

4 With regard to the secondary standard, we

5 have two chapters, Chapter 5 and Chapter 6. The focus is

6 on the welfare effects and exposure of risk information.

7 We're asking the panel's reviews with regard to our

8 characterization of key aspects of the welfare effects

9 evidence, including differences from the last review. And

10 with regard to our characterization of the quantitative

11 screening-level risk assessment and the associated

12 limitations and uncertainties now in context of the

13 current review.

14 And then Chapter 6, we have presented our

15 review of the secondary standard. And we're asking for

16 the panel's views on the presentation of considerations

17 which inform our preliminary conclusions and the panel

18 views on our conclusions with regard to adequacy of the

19 current secondary standard.

20 DR. FREY: Okay. Thank you. Are there

21 questions for clarification from members of the panel for

22 the Office of Air Quality and Standard?

23 (No response.)

24 DR. FREY: Okay. All right. Okay. Well,

25 thank you for the presentation. And I'm assuming you'll
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1 be here if we have some questions from the discussions.

2 The next item on the agenda is public comment, which we

3 don't have any at this time. So then we proceed to the

4 subsequent agenda item, which would be panel discussion.

5 And we'll begin -- we'll go in order of the

6 chapters. We'll begin with Chapter 1. The lead

7 discussant is Dr. Davidson, and the other discussants are

8 Dr. Rabinowitz and Dr. von Lindern. So I'd like to give

9 the floor to Dr. Davidson.

10 DR. DAVIDSON: Okay. Thanks very much,

11 Chris. I want to say that I think this is a very, very --

12 you did a very nice job on this policy assessment. And I

13 feel overall that that Chapter 1, there's a reasonably

14 good job in laying out the floor for the rest of the, the

15 rest of the document.

16 However, I have a couple of minor issues

17 that I don't need to go into here. They're written up.

18 But there's one major issue that I felt we want to bring

19 up. And that is the fact that lead really is unique in a

20 number of ways. It's unique in that of all the various

21 pollutants, we have disturbed the natural cycling of lead

22 to a greater extent than virtually any other pollutant.

23 And I think that was a point that should be made.

24 But in addition -- it's unique in that this

25 is really one of the biggest environmental success stories
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1 that exists for any pollutant. If you look at globally

2 what has happened with lead emissions and lead

3 concentrations, certainly the removal of lead from, from

4 gasoline in the United States was the beginning of the

5 removal of lead from gasoline in many other countries

6 around the world.

7 And so this really has had a tremendous

8 global impact. And I think it would be very difficult to

9 think of another pollutant that has had -- where people

10 have made a decision that has reduced the emissions to the

11 extent that we've done with lead for any other pollutant.

12 Probably the only, the only thing that really comes to

13 mind on a global stance is something like chloroformic

14 carbenes.

15 And, in fact, chloroformic carbenes -- I

16 mean, they are now new pollutants, to begin with. But, in

17 fact, eventually the reduction of chloroformic carbenes

18 will (unintelligible) what's happened to lead.

19 But for right now, lead is really a unique

20 success story. I think that's one thing we could all put

21 some credit into. Okay. But there's another unique, and

22 that's that as a result of a very large emissions lead

23 that occurred over such a long period of time in the U.S.

24 and around the world, lead also has the biggest legacy

25 problem of any pollutant. And it is that point that I
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1 think is most important.

2 So the problem with lead that we face now

3 is not so much the reduction of current emissions as much

4 as it is understanding what happened to the millions of

5 tons -- and we are talking about loads of tons of lead

6 that were emitted in this country. And, in fact, we do

7 not have a good handle on where that lead went and what

8 the exposures are of that lead.

9 So I guess the bottom line point that I

10 would like to make is that I really think putting lead

11 into the proper context needs some statements about the

12 uniqueness of lead, these various points of affecting the

13 natural cycling. An enormous success story, but also a

14 very major legacy problem. And the fact is we don't know

15 today what happened to those millions of tons of lead, and

16 we don't know -- we don't have information on human

17 exposure to those millions of tons of lead. So that's --

18 I would like to see that brought up in the introduction.

19 So that's all I wanted to say.

20 DR. FREY: Okay. Thank you. This will

21 open up a big discussion, but I guess is there a further

22 context in the legacy of lead in terms of re-entrainment

23 and (unintelligible) exposures in the (unintelligible)

24 that's worth discussion along with what you're commenting

25 on?
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1 DR. DAVIDSON: Well, I think that's an open

2 question. As you know, there have been papers and

3 literature about the importance of these cited lead, and

4 there is some disagreement about that importance. I think

5 that's part of the uncertainty.

6 DR. FREY: Okay. All right. Well, thank

7 you, Dr. Davidson. And let's see, next on the agenda is

8 Dr. Rabinowitz. Oh, I'm sorry. Did you have a comment on

9 this issue?

10 DR. WEITZMAN: I thought that was very

11 eloquent. I just wanted to voice my own concern in

12 tempering our enthusiasm about this as a success.

13 Catalytic converters played an enormous role in limiting

14 lead emissions. It wasn't necessarily -- lead being

15 removed from gasoline wasn't necessarily (unintelligible)

16 to protect the nation's children.

17 This is a multimedia exposure problem, and

18 we're here talking about ambient air. But the FDA and the

19 Consumer Products Safety Commission, part of the EPA, as

20 well as the medical community played a profoundly

21 important role in litigation, in eliminating paint -- lead

22 in paint. So I don't in any way mean to trivialize what I

23 have witnessed over the course of decades.

24 But it's taken partnering, and it's taken a

25 real vision about the ozone lap between environmental
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1 health and (unintelligible) agencies. Would you agree

2 with that?

3 DR. DAVIDSON: I would entirely. I think

4 your points are very well taken.

5 DR. FREY: Okay. Dr. Rabinowitz.

6 DR. RABINOWITZ: I agree with everything

7 said so far. What would I say about the documents

8 themselves? I must say I agree -- I like the overall

9 approach. I like the systematic approach. I recognize

10 the nature of it. The opinions suffer from frontal

11 phobia. I don't know if Chris's remarks about how nifty

12 lead is. (Unintelligible.) Further, if you just compare

13 the annual reduction rate of lead in tons, million tons,

14 and just divide it up by the average cost of the pints.

15 If you have any element, iron or copper, zinc, having any

16 element, lead stands way out.

17 If you do that with a simple division, you

18 get the average ton production is divided by the average

19 cost of the proposition. Lead is frighteningly different.

20 I happen to love lead because other (unintelligible)

21 elements in that there's a natural variation of a

22 composition of lead.

23 About this document, I have a few comments.

24 I think that -- just in general, I think that it does

25 adequately provide the reader a clear, stand-alone basis
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1 to make a decision about whether to obtain a revised

2 understanding. I think you could read this without having

3 to go back to the earlier documents.

4 I think it adequately provides the reader a

5 clear basis, and I happen to -- maybe it's through the

6 emission. I happen to agree with you about maintaining

7 the current standards. Basically, if you -- even if you

8 lower the air lead standard to zero, you effectively

9 change blood lead level distribution. So you're not

10 getting the edge protection that we find in here, the

11 airport standard (unintelligible).

12 There are a few little points we could

13 change about it. Chapter 2, Line 28, you talk about the

14 values in the environment. And I think that somehow you

15 should say that these current values in the environment

16 are expected to decrease it for -- to be left on their

17 own. And the rest of my comments are in the written form.

18 Thank you.

19 DR. FREY: Thank you. Okay.

20 Dr. von Lindern.

21 DR. VON LINDERN: Well, I agree with most

22 of the comments that I have heard. I have a couple of

23 caveats. The first one would be I don't love lead. I

24 like lead and I respect lead, and I like it more than I

25 like gold. But that's about as far as I'll go on that.
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1 And I agree with Dr. Davidson, with one

2 caveat on that. As I go through this, generally I think

3 it's a good policy document. And I have to admit it

4 probably adequately addresses the question that's before

5 the agency. So most of my comments, again, are about what

6 the agency doesn't do as opposed to what it does do well.

7 But in the discussion, I do does overdo

8 that the conclusion that no information justifying

9 reconsideration of the NAAQS has come forward. I think

10 that's all I agree with that conclusion. I think there

11 should be caveats to convey the level of uncertainty and

12 lack of information that's involved in that decision. And

13 I don't think that gets conveyed in the policymakers, and

14 I don't think it also gets conveyed in this document how

15 limited the scope, its volume, the ISA is.

16 And that's limited because of the scope.

17 It was limited both in terms of the database that it

18 examined. It's limited in terms of the question that it

19 addresses. And the most important to me, it's limited in

20 terms of the geography that can be considered in

21 evaluating the policy.

22 I think there's also another aspect of this

23 new procedure that bothers me as well, and this looking

24 only at information that has accumulated in the last five

25 years without conveying how limited the previous
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1 information was -- and that the fact that some of that

2 information we're relying on, in particular the areas that

3 I've complained about, are severely outdated.

4 And I hate to see a process come here that

5 every five years we can say, No new information has come

6 forward. We'll stick with what we've got when the basis

7 of that decision is deteriorating because information is

8 no longer applicable.

9 One example of that, I think, is the risk

10 assessment of 2006. I think we all recognized that the

11 word "risk assessment" was weak because they weren't

12 monitoring data. There weren't emissions data to really

13 update the risk assessment based on observation. It was

14 based on modeling. And the inputs of those models at that

15 time were 5, 10, 15, 20 years old. Now, we're still

16 relying on that same document this time around. I don't

17 see that conveyed to the policy readers.

18 I think all too often it says, No new

19 information has come forward, when sometimes it should

20 say, We didn't look for any new information, in some

21 areas. And there simply wasn't enough information before.

22 So the fact that there's not any now doesn't make it more

23 comforting.

24 That doesn't mean that the decision is

25 going to change, but I think it still should be conveyed
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1 to the policy folks that what level of uncertainty goes

2 with -- with these various conclusions that are passed on

3 to them. One of the greatest areas of uncertainty, of

4 course, is in the production use and disposition of lead.

5 And I think Dr. Davidson did a good

6 presentation about the uniqueness of lead. There is

7 multimedia. The agency does a good job of recognizing

8 that. In fact, you've spent (unintelligible) analysis

9 over the last few decades and does do this multimedia

10 analysis. But it also -- its effects go beyond the

11 purview of the Clean Air Act or NAAQS.

12 So I've heard Dr. Frey say that we could

13 give recommendations regarding the effect this may have on

14 energy policy. I wonder if we can give a recommendation

15 on the effects it may have on places that are outside the

16 purview the National Ambient Air Quality Standard.

17 And one example I'd like to make is

18 Dr. Davidson does correctly, I think, point out that the

19 removal of gas in the additives in the U.S. have very

20 positive impacts globally. And United States is a leader

21 there. There was less lead emitted on this plant

22 (unintelligible) as a result of that.

23 But with respect to the production,

24 recycling the solo lead, we didn't curtail that globally.

25 We moved it out of the United States. So those emissions
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1 are still happening. They're having less control, and

2 they're damaging more children.

3 So it is a great success story, but as with

4 every other environmental success story there are

5 unintended consequences. And I think it's appropriate

6 that that should be considered in advance as part of the

7 policy.

8 If you can't look at it in terms of the way

9 you define the document -- the ISA document, it seems to

10 me certainly if you look at it in terms of how it might

11 affect the policy that this agency is putting forward.

12 Thank you.

13 DR. FREY: Okay. Great. Yes, Dr. Murphy.

14 DR. MURPHY: Sorry. I just wanted to

15 clarify. Dr. von Lindern, regarding your mention about

16 REA that it's -- the REA that's the human health risk

17 assessment was not based on decades old information. I

18 mean, there were both modeling and monitoring based case

19 studies. And the monitoring based ones were based on

20 fairly recent information.

21 I cannot remember the exact year, something

22 like 2003 to 2005, I think at that point. It was whatever

23 is most recently available. And the modeling was based on

24 the information we had on emissions at those two point

25 sources that were included. So just as a clarification.
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1 DR. VON LINDERN: Yeah. I wouldn't

2 disagree with that, but most of those emission trackers go

3 back to the 1970s that were used. The monitoring network

4 was severely curtailed in the 1990s, and there was very

5 little -- relatively very little information available to

6 relay at that time. And I think that's why we all see it

7 as a modeling effort. I mean, you-all did a great job of

8 that, but it would have been better to have based that on

9 monitoring and evaluation of real exposure as opposed to

10 modeling exposure. And it's just a little bit

11 (unintelligible) now -- that was outdated at that time,

12 and now it's five years older. The next time we're here

13 it's going to be ten years older. And there's not

14 information being collected to update that. So...

15 DR. FREY: Well, I guess your comments

16 touch on a couple of things -- and, obviously, you alluded

17 to. And I have reviewed the charter of CASAC at the

18 beginning of the meeting. And I think there's at least

19 two things that are relevant.

20 One is, you know, what is the research

21 effort necessary to provide the required information. So

22 that's definitely something we can advise the

23 administrator on. So if there's something that the panel

24 wants to say about the need to collect data to support

25 exposure and risk assessments going forward, we certainly
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1 can say that.

2 And secondly, as I mentioned, part of our

3 charter is to advise the administrator on adverse public

4 health, welfare, social economic or energy effects which

5 may result from various strategies for attainment and

6 maintenance of standards.

7 It doesn't say -- this language here

8 doesn't say public health effects (unintelligible). Maybe

9 that's an intent, but it doesn't actually say that. So I

10 think if the panel wanted to make a statement to the

11 administrator to raise awareness of, you know, the

12 potential -- as you say, either unintended consequences

13 or, you the -- you know, sort of -- well, we solved the

14 problem here (unintelligible).

15 I think we -- initially in our charter, and

16 my interpretation that we could do that.

17 DR. VON LINDERN: Okay. Good. And I, and

18 I agree that we can -- I think it's worth mentioning.

19 DR. FREY: Okay.

20 DR. KOSNETT: I agree. And it is worth

21 mentioning. One of the consequences of the air pollution

22 control technology that's been worked there on the COB

23 issues of lead in the United States, which is

24 (unintelligible). It is resulting in the -- in a lot more

25 of that recycling and getting exported to Mexico.
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1 DR. FREY: Yeah. And the one thing I think

2 we have to, I guess, be mindful of is a lot of our advice

3 is based on a fairly detailed review of evidence -- you

4 know, for example, the size, you know, prompted ISA at

5 times. So I think any statements we make -- I guess there

6 should be, you know, some evidence that we're comfortable

7 with to support that so that there are citations or -- and

8 this will probably come into, you know, written document

9 of these public comments, but I would encourage that as

10 well. I know George and then Rich.

11 MR. ALLEN: Just kind of a quick update.

12 Actually, we are fairly data rich in terms of lead

13 monitoring now. At one point (unintelligible), but I just

14 wanted both source monitoring and population monitoring --

15 lead monitoring is a substantial network, multiple

16 networks. A pretty good, pretty rich data set to let us

17 know what's out there. So in light of that, early 2000's

18 we were in much better shape.

19 DR. VON LINDERN: And I agree. That's a

20 pretty good picture. And as I think I said this morning,

21 it's really a question on my three sources. In terms of

22 other things you can spend money on, and it's probably

23 appropriate where it's at.

24 I probably didn't do a good job in -- also

25 supporting one of Dr. Davidson's points in that lead is
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1 unique and that is multimedia, and there is a real legacy

2 problem there in terms of the zincs. But that's not just

3 a historical problem. That's an ongoing problem. There

4 is still just as much lead being used in the U.S. right

5 now that's ending up in the sub city. And I don't think

6 we know where those cities are, and I think it's incumbent

7 on -- somewhere in the agency probably to do that.

8 And then Dr. Weitzman also did a very

9 excellent job in giving many others credit for this --

10 resolving this problems in the U.S. Many other agencies

11 were involved and many other players and actors and

12 factors. And then you have a little historical note on

13 that, and I agree. And my historical observation would be

14 that there -- there seems to be less collaboration among

15 the different regulators now than there were earlier in

16 the lead times. We used to have other agencies here, and

17 they were all working in a lead regulation world.

18 But we seem now to be almost limited to the

19 indicator or averaging foreman level of NAAQS. I don't

20 know that that focusing on emission to that point from

21 what was doing 30 years ago is in the best interest

22 (unintelligible) of the country.

23 DR. FREY: Okay. Thank you. Rich?

24 DR. CANFIELD: Two questions. One is --

25 you spoke about the need or the desirability for having
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1 evidence for issues like distribution of lead and other

2 offshore and recycling. I would think it would be okay

3 for us to express concern about the general lack of

4 information, and I don't -- I don't -- I mean, other

5 people may know better than, but that includes you and it

6 does exist. So I don't want us to put a standard that we

7 can't meet for something that can be very important.

8 DR. FREY: Yeah. And if could, I think you

9 raise an excellent point. And what I might want to say --

10 I think if we're going to say that NAAQS is going from

11 U.S. to Mexico -- if we're going to make an assertion, we

12 probably need to back that up. But if we're going to just

13 comment on, you know, here's important information that we

14 think should be obtained, then this is sort of like almost

15 a research need or a need for a future setting. And, of

16 course, then the burden's not on us to provide the

17 evidence.

18 DR. KOSNETT: Yeah. It doesn't have to be

19 a huge --

20 DR. FREY: Yeah. No, no.

21 DR. KOSNETT: But for example, there have

22 been usage meetings between the United States and NAAQS

23 where they're always talking about, you know, you travel

24 with lead in the United States. So there's some

25 importance.
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1 DR. FREY: Sure. Yeah.

2 DR. KOSNETT: I think he explained his --

3 you know, certainly, there's a lot of lead. And lead is

4 more recycling lead. So we're using a lot of lead in

5 recycling.

6 DR. CANFIELD: There are a couple of others

7 that are high.

8 DR. KOSNETT: What?

9 DR. CANFIELD: There are a couple of others

10 that are very high.

11 (WHEREIN, unintelligible due to multiple

12 people speaking at once.)

13 DR. CANFIELD: Again, this is outside of my

14 area of expertise. On one hand we have people presenting

15 information about the air monitoring technique and the

16 idea that the data is close to useless. The monitors

17 aren't parallel. They don't get anything; they're not in

18 the right places, et cetera.

19 But then at other times it's characterized

20 as quite good. So I understand one of my main concerns is

21 to have a really good sense of (unintelligible). Really

22 the quality of that air monitoring data, how good is it

23 now. Or do we -- don't -- do we need better air

24 monitoring? Is that really important. And is it worth

25 monitoring with the equipment that we have.
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1 DR. FREY: Yeah. Well, that's a great set

2 of questions. And, obviously, you're more informed to

3 answer it than I am, but I guess I'll kind of summarize.

4 So I think -- you know, almost with any

5 area, if you know more about it, you know more about the

6 skeletons in the closet and the limitations. And you know

7 a little bit more about monitoring of lead with a

8 (unintelligible) sampler.

9 And we had a presentation on this in the

10 last meeting about what's sensitive to things like wind

11 speed and wind direction, so that's probably not the best

12 method. And then we had some discussion earlier about

13 particle size and how that relates to exposure. So I

14 think one way of looking at this -- there's certainly many

15 opportunities to improve the techniques applied for

16 monitoring and to deploy better monitoring methods.

17 But there's almost a flipside to that too,

18 which is that, Well, operationally those will give us a

19 new definition of what it is that we're going to use as an

20 indicator, assuming that maybe some future standard would

21 be based on an improved -- you know, higher particle size

22 cut off or a different kind of TSP monitor.

23 And so then there's -- also I think the

24 question, the consistency in the time series of data that

25 we wouldn't actually be able to compare very well the time
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1 sequence of data from this new monitoring technology with

2 the old monitoring technology because they're

3 operationally different. So there are all these nuances

4 to do it.

5 But I think in terms of, you know, is the

6 current information completely useless, you know,

7 Dr. Hopke used the phrase earlier "reproducibly wrong."

8 And I don't know, maybe I should let you comment on is it

9 completely useless.

10 DR. HOPKE: That's what makes me nervous.

11 DR. FREY: Yeah.

12 DR. HOPKE: Not completely useless, but --

13 you know, again, the technology has moved on. So the

14 question is, you know, at this stage where we ask for good

15 control, is it good enough for this purpose, or is this a

16 scenario where we have relatively limited resources to

17 develop monitoring tools.

18 Is this the place that is important enough

19 to focus that kind of attention? Probably not at this

20 stage, as we -- as we control things better and better,

21 particularly if we can get access to these last major

22 sources, is -- you know, is -- you know, is it good enough

23 for government work?

24 You know, we've got a pretty good idea of

25 the, of the response exposures with the exposures that we
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1 have. We have that and used that to move things in the

2 right direction, seeing less clinical examples of lead

3 poisoning and problems like that. So, you know, at this

4 stage, is this the place where we're going to focus enough

5 attention to divert significant resources. I would say

6 probably not.

7 DR. CANFIELD: I guess that agrees with the

8 (unintelligible). What don't we know that we don't know.

9 You know, that's, I guess, the basis of my -- if we

10 listen, all this lead is coming in. We don't know where

11 it's going and we can't measure it.

12 (WHEREIN, unintelligible due to multiple

13 people speaking at once.)

14 DR. FREY: Yeah. Another phrase of today

15 is -- you know, is it adequate for its intended purpose.

16 DR. CANFIELD: Sure.

17 DR. FREY: I mean, maybe one could argue

18 that the high volume TSP samplers are, in some way,

19 adequate for the intended purpose. But I think, you know,

20 things could be improved. But then if you step back to an

21 even bigger picture (unintelligible), it's less of a

22 priority than something else.

23 I do want to comment on the good enough for

24 government work comment because when I -- my first job out

25 of high school I worked as a lab assistant at the Naval
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1 Research Lab. And there were two post-docs in my lab.

2 And my father was -- worked for the government also. And

3 I used that phrase with the post-docs, and they repeated

4 it to the section chief. And he chewed them out for it,

5 so...

6 (WHEREIN, unintelligible due to multiple

7 people speaking at once.)

8 MR. YEOW: Technically, you guys are

9 special government employees.

10 MR. ALLEN: (Unintelligible.)

11 DR. FREY: Yeah. Yeah. We certainly

12 wouldn't start today with a high-volume sampler that's in

13 use now.

14 DR. HOPKE: And, again, it may be in the

15 context that would go under NAAQS kind of problem that you

16 develop a sampler that could do a better job for lead, but

17 also for (unintelligible) you're interested in monitoring

18 that have problems through both inculcation and deposition

19 and the passage within the GI. And now it may be worth

20 the investment because you're going to use it for more

21 purposes.

22 DR. FREY: All right. Lydia, do you want

23 to add something?

24 MS. WEGMAN: Well, I just wanted to note

25 that we do have two of our monitoring experts here, Kevin
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1 Cavender and Lou Weinstock. And to the extent that it

2 would be useful to the committee to hear from the experts

3 as to where we are in lead monitoring, we'd be happy to

4 have them speak to it.

5 DR. FREY: Okay. Okay. Well, let's see if

6 maybe that -- I don't know that we need that right now,

7 but if that comes up -- yeah. Dr. von Lindern.

8 DR. VON LINDERN: I think maybe I started

9 this, so I'm going to have to bring it back. My primary

10 point was -- and now I'm not sure I know the answer. We

11 didn't do it in the REA -- did we not do it because there

12 were no new data? Or did we examine some data that told

13 us that the situation was still the same? I think it's

14 because -- at least when I agreed that we shouldn't do it

15 was because I thought it defeats the purpose because there

16 wasn't new information accumulated at that time.

17 DR. FREY: Well, yeah, I think -- yeah,

18 that's a -- I think that's a good point. And I think in

19 some of the written comments this comes through. And I'm

20 assuming this will come through in our discussion today

21 is, yeah, there's a question. Is it because nothing's

22 changed or has there been some accumulation of evidence

23 that increases the confidence in previous decision. And

24 those are slightly different. But, yeah, Dr. Murphy.

25 DR. MURPHY: I was just going to clarify.
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1 With regard to the decision on the risk assessment, when

2 we develop an REA planning document, what we did was go

3 through the evidence that had accumulated and ask the

4 question: Was there additional evidence which would have

5 modified how we conducted the risk assessment such that

6 that new evidence warranted us to redo a risk assessment

7 with new information.

8 When we talked about information and

9 evidence, we weren't focused on monitoring information,

10 per se. And I don't think we considered much about the

11 availability of monitoring information other than I will

12 recall with regard to do we have more detailed monitoring

13 information in terms of gradients, because the issue of

14 spatial gradients was something we didn't understand in

15 the last review.

16 So -- but when we evaluated the information

17 available and made a decision that it did not warrant the

18 comment of a new assessment, it was because we would be

19 using the same models. We would be feeding them with

20 similar input. We would not be using substantially

21 different approaches which would give us a substantially

22 different answer. It wasn't focused on monitoring data,

23 per se.

24 DR. FREY: Okay. Other comments on Chapter

25 1?
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1 (No response.)

2 DR. FREY: Cliff, as the lead discussant

3 for Chapter 1, do you have any other requests or input

4 from the panel?

5 DR. DAVIDSON: No. I think I have it.

6 DR. FREY: Okay. Very good. Okay. Let's,

7 let's go to Chapter 2. Chapter 2 is Ambient Air Lead.

8 George Allen and Phil Hopke are discussants, and Rich

9 Poirot is the lead discussant. So I will leave the floor

10 to Rich Poirot.

11 MR. POIROT: Thanks, Chris. So I guess the

12 two -- Chapter 2 charge questions: To what extent does

13 the panel agree that the most relevant information on

14 emissions, air quality and lead concentrations in other

15 media is presented, and to what extent is the information

16 presented appropriately characterized and clearly

17 communicated?

18 In my opinion, yes, to all of the above

19 with just some minor suggested tweaks or suggestions.

20 Regarding the information on emissions, I think you've

21 done a really nice job -- and this is, by the way, a huge

22 improvement over the confusion over emissions that I

23 recall from the last lead cycle where it really wasn't

24 clear, you know, who was in first and who was in second

25 and that sort of thing.
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1 So I note -- you know, up through the 2008

2 NEI inventory data. So just a one general suggestion,

3 there's -- in describing it, since we're now in 2013, why

4 not just past tense, especially since you comment on a

5 number of occasions that there are a number of programs

6 that have already taken place or they're well on their

7 way. They're pushing emissions down or along those lines.

8 There's a very nice appendix that's added

9 that lists all the various regulatory programs. They're

10 already in the works. They're further pushing emissions

11 down. So I'm just thinking -- I don't know if it's

12 possible, but with a future version, the next draft of

13 this final version, any opportunity to get all

14 quantitative about some of those programs in place would

15 be very interesting information.

16 Or even, to me, a general characterization

17 of the kinds of emissions reductions we expect to see. Is

18 it likely to resolve them -- a reduced concentration away

19 from specific kinds of relatively few point sources.

20 That's one kind of reduction. Or if, for example, we

21 really were to get the lead out of av-gas or some other

22 largely dispersed forms of lead, would it be likely to

23 bring down the general population exposures everywhere.

24 And that would be another kind of concern. If that were

25 possible, it might be useful information to include.
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1 Along similar lines, the information that

2 you present under concentrations up through 2011, again,

3 it's very clearly presented. And I think you've done a

4 good job of that. However, as Rich pointed out, you know,

5 we've got a bunch of new source specific, including

6 airport specific monitors that have gone out at various

7 dates in the past from which some data is coming in. And

8 certainly if the airport would relay the sampling, it

9 would be hugely useful to inform not only this process,

10 but of course the parallel Section 231 process.

11 So, you know, with lead, since it's a not

12 to be exceeded standard -- and you can really know if you

13 have a violation with as few as three months of data. And

14 even if you don't have a violation, that kind of

15 information would be informative even if you don't have

16 three years of data that you use to calculate the design

17 data.

18 So maybe in the next version of this policy

19 assessment document -- or even as a -- something in

20 attachment to it, if you could bring any of that new data

21 forward and display it, I think it would inform the

22 decision.

23 By the way, somewhat of an aside, but this

24 parallel Section 231, the process on av-gas is kind of an

25 interesting thing. I got to wondering what happens if the
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1 data comes in -- and maybe you can help us with this. If

2 the data comes in and we have exceeded this near airports,

3 will it be possible for the agency to find that, no, it

4 doesn't pose a significant risk to health?

5 DR. KOSNETT: Can you give a -- just say a

6 word about what is the section -- what is 231?

7 MR. POIROT: Well, maybe --

8 UNIDENTIFIED SPEAKER: Marion back there

9 would probably be the best to speak.

10 DR. HOYER: 231 --

11 DR. FREY: Could you use a microphone?

12 UNIDENTIFIED SPEAKER: Marion, why don't

13 you come up here.

14 DR. MURPHY: This is Dr. Marion Hoyer from

15 our Office of Transportation and Air Quality, and she's in

16 the middle of that process.

17 DR. HOYER: Section 231 is the part of the

18 Clean Air Act that gives us authority to evaluate

19 emissions from aircraft engines that cause or contribute

20 to air pollution. It could be reasonably anticipated to

21 endanger public health and welfare, and it gives us the

22 authority to set additional standards for pollutants that

23 we have test. But just to be clear, EPA does not have the

24 authority to set fuel standards for aircraft.

25 MR. POIROT: So -- and it's described in
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1 the document as sort of this parallel separate unknown

2 process. But what struck me is sort of interesting as

3 having these two balls in the air at the same time. And

4 wouldn't it be interesting if there were exceedances of

5 the standard measured near airports, exceedances of NAAQS

6 -- it would be very difficult -- it would take a really

7 good lawyer to say, No, this doesn't constitute a

8 significant risk to human health.

9 Or maybe the other part of that that could

10 be really interesting is, Okay, what if the measurements

11 come down below the level of the NAAQS, could the agency

12 still then conclude, Yes, this does (unintelligible) lower

13 than the NAAQS. Just the relationship of those things, I

14 just wanted to comment was interesting to me.

15 I guess the information -- I thought the

16 information on -- well, as I said, if it were possible to

17 bring some of the new monitoring data forward, even if

18 it's not a full three years, if might be informative -- if

19 it's possible to do in the next version of this.

20 Then the last part of the charge question

21 related to the, the information on lead in other media.

22 And I guess my -- I had made this comment earlier, but I

23 thought a little bit more information on the

24 characteristics of lead in dust and what we mean by dust.

25 I'm especially interested in knowing
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1 particle size characteristics of this dust that becomes

2 ingested. Because to me that's really where the energy

3 occurs between how do we -- how should we measure -- or do

4 we measure lead in the air, or should it be measured in

5 terms of the particle size characteristics versus what I

6 think of as the different particle size characteristics in

7 the dust that gets deposited on things that gets ingested.

8 Two are not the same in understanding the

9 similarities and overlapping differences would be an

10 important subject. So that was my, my -- those are my

11 general comments on the first question.

12 And then the second charge question,

13 information on ambient lead monitoring, I sort of answered

14 part of that. Oh, this is on monitoring methods more, I

15 think, the second charge question. That's right.

16 And I just noticed, for example, that the

17 agency expects to have a new improved sampler available

18 for consideration in a future review. So my goal would be

19 to get that A changed to B in the next review, rather than

20 just saying, Yeah, we're interested in this, kicking it

21 down the road, kind of like we did last time EPA was

22 interested in an improved and alternative sampler. So I

23 know it's a hard thing to make a commitment, but that

24 would be kind of a direction I would like to encourage you

25 to move in rather than having this maybe (unintelligible).
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1 You know, although it still points out,

2 there's other things to do with money. It's just not the

3 best use. I kind of think it's something better than the

4 hi-vol is within our very near-term grasp. Although,

5 Chris, I thought, made one of the best points is, Man,

6 (unintelligible) historical record that's part of that

7 long-term success story. So certainly if the long-term

8 KSD sites, you don't want to switch to something

9 (unintelligible) for historical purposes. We'll keep a

10 few of these old records around.

11 So, again, towards that goal of moving

12 forward. I thought that was good language in the ISA that

13 made a clear and marketable distinction between the

14 desired characteristics for the sampling in the ambient

15 air versus the particle sizes and other factors pertaining

16 to dust deposited and ingested by non-breathing

17 techniques. So bringing a little bit more of that

18 information forward, I thought would be useful.

19 I'll restate my point about imprecise

20 language. We use TSP to mean whatever is convenient. You

21 know, tell me I'm wrong. I'll say, Oh, I didn't meant

22 that. You know, by the way, while others express concerns

23 about the monitoring and so forth. Look back in the ISA.

24 There's a graphic that shows the particle cut size

25 characteristics of the hi-vol sampler.
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1 And if you look at what's 50 percent

2 particle cut size, and this happened to be at 5 meters

3 (unintelligible). The particle cut size for the TSP

4 hi-vol, based in that chart in the ISA, ranged from about

5 12 to 18 microns. 12 -- and the difference between 12 and

6 18 was which way did you have the chip roof slanted in

7 respect to the wind.

8 So we're talking about 15 to 20 -- 15,

9 George mentioned, would be close to the upper limit of

10 what's theoretically possible. Keep in mind, what we've

11 already got is 12 to 18. You don't know which. You know,

12 maybe we should -- if we're going to continue to use TSP

13 sampling, why not specify the direction that you want the

14 wood slanted, the roof slanted in relationship to the

15 source. Because if you don't, you can deem the thing

16 about the difference between a cut size of 12 and 18. So,

17 anyway, that's all I had to say about specifically the

18 charge questions.

19 Maybe one other kind of minor -- I

20 questioned -- really, more of a question was -- on Page

21 228. And some of the associated graphics, you talk about

22 a category previously historical methods. But monitoring,

23 so I didn't quite know exactly what that was. And I was

24 guessing. Is this site where it used to be an active

25 source, the source is now shut down.
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1 And that category comes out to be kind of

2 the second highest category among all of your categories,

3 which is sort of interesting to me because, okay, the

4 source is shut down. Where is the lead coming from?

5 Presumably it's some sort of fugitive resuspension kind of

6 a thing. I don't know what else to infer there. So

7 that's kind of interesting.

8 And, you know, some of those sites seem to

9 be approaching, you know, closer levels to NAAQS.

10 MR. CAVENDER: With my experience in

11 secondary lead smelting, I would say just because the

12 source stops operating, doesn't mean that they uncover

13 their storage piles or do anything else. There still can

14 be quite a bit of -- due to the dust coming off of these

15 old industrial sites. We've got -- for the most part,

16 that's what we're seeing. There's a couple of sites that

17 we're seeing. We've got years of data, and we can see it

18 trails off at the top. But, yeah, we specifically want to

19 look at those to see if there's some other areas that we

20 should be looking at.

21 MR. POIROT: So, anyway, those were my just

22 general comments. I overall thought that this is really

23 well done. It doesn't need much -- just a tweak in the

24 directions in which I included in my written panel notes.

25 DR. FREY: Okay. Thank you, Rich. George.
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1 MR. ALLEN: Well, I concur with Rich. Just

2 a word (unintelligible). 98 percent of it is good enough.

3 It's only when you're close to large point sources where

4 you might establish that in a meaningful way. At the same

5 time, our mentions of lead are being used precise of any

6 of the NAAQS. We worry about 7 percent. Okay.

7 (Unintelligible.) I understand that. It's important, I'm

8 sure. But I want to put this whole process in perspective

9 to the NAAQS. I know it's important.

10 Overall, Chapter 2, it's a very good

11 summary. It's a well-organized summary. I had one

12 question on Section 2.2.2. The boxplots needed to have

13 the whisker defined. I didn't know whether the whisker

14 was 95th, but that's a minor point.

15 On the second charge question, Section

16 2.2.1, again, that's a well-written description of the

17 process being taken towards a better FRM sampler. And

18 other than that, my comments are pretty much the same as

19 the ISA. So I won't beat that horse anymore.

20 One slight oddity, which gets back to the

21 form of this thing, Page 2-22, Section 2.2.1.3.3. Is the

22 NAAQS form is unique. The lead NAAQS is unique to any

23 other NAAQS, never to be exceeded. So I have a question.

24 It talks about design values. And so how, how do you

25 calculate a design value for lead. Well, it turns out I
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1 answered my own question. And the answer is it's 38

2 values for each of the purposes at the average of

3 one-month's peak. And you are running sort of average of

4 the highest of those as was the second value.

5 It might be useful to have that in the

6 document. I have no idea how it was done, and I had to

7 ask. I mean, I'm sure it's out there in the documents

8 somewhere. And that's it for me.

9 DR. FREY: Yeah. I think that was in

10 2.2.1.3.1. Thanks, George. Phil.

11 DR. HOPKE: Okay. Again, I agree that this

12 is nicely written. It brings on the Chapter 3 stuff into

13 what -- into the PA. One source that I think that's been

14 potentially neglected is the potential for burning old

15 wood. In a recent study that George and I were involved

16 with, we did see some hints that place wood is being made

17 into pellets. And both treated wood and obviously old

18 painted, lead-painted wood.

19 And given the current amount of waste wood

20 that would be generated in the north of New Jersey where

21 it is considered -- in older houses that very well contain

22 lead paint. One's concerned that a lot of that wood would

23 end up in chips and pellets. You know, again, it's not --

24 it may not -- it may be a very localized source, but it

25 could be important to those locales.
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1 My big quibble here is the lack of any

2 basis for the form of the standard. There is no

3 literature cited for the not to be expected form of the

4 standard. As George indicated, it represents a problem in

5 terms of defining a design value. There -- you know, in

6 the other standards we've all had at least some literature

7 on things like the percentile for lead standard and other

8 kinds of bases for reviews that perform.

9 Here there's absolutely nothing, none --

10 you know, the document is totally silent on where they

11 pulled this out of the hat. Now, it dates back to, you

12 know, primeval times when we were all young. But it would

13 be good to see some of that material (unintelligible). It

14 needs to be reviewed and recognized that we thought about

15 it again because the point of the standard is very

16 important. The combination of the concentration of the

17 form is completely what makes things happen. And

18 recognizing that the real world is units of distributions

19 and not in absolute values is really sort of essential to

20 making things work well.

21 And right now we have this 1970s primitive

22 view of things where we can set this never to be exceeded

23 in that criteria, and I think that it deserves at least a

24 short revisit to bring back what the basis was for setting

25 that in the first place. And there be some justification
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1 for why it's still pertinent today.

2 DR. FREY: Okay. Thank you. Rich.

3 MR. POIROT: I'd like to agree with Phil

4 and George on that point. However, I'd like to ask the

5 chair whether he thinks that that -- our comments on

6 Chapter 2 are the right place in the document to put that

7 in?

8 (WHEREIN, unintelligible due to multiple

9 people speaking at once.)

10 DR. FREY: Well, I think certainly for our

11 discussion, we've discussed it now and also tied it in

12 later. I think Chapter 4 actually deals with the form.

13 So we definitely want to make sure in our written comments

14 to the administrator that we convey information relative

15 to the form. Perhaps, in both places, if it makes sense.

16 Definitely we can combine it into the Chapter 4

17 discussion, if that seems to be the best place for it.

18 But I think at this stage having the discussions and

19 certainly --

20 (WHEREIN, unintelligible due to multiple

21 people speaking at once.)

22 MR. POIROT: Yeah. No. I -- I didn't want

23 to cut it off in the session, is all. It's just that

24 question -- in the one place I could think of, maybe, to

25 put it into this Chapter 2 response is in terms of the
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1 presentation of available data. Let's present it, for the

2 most part, as homeland data where there are at least three

3 years available to calculate this design value, even

4 though it is not to be exceeded. You could get an

5 exceedance with (unintelligible). In reflecting on that,

6 it could -- go ahead and make a comment.

7 DR. FREY: Yeah. So I guess in terms of

8 our procedure, Deborah is the lead discussant on Chapter 4

9 -- do I have that right?

10 DR. CORY-SLECHTA: Yes.

11 DR. FREY: So, perhaps, Rich is the lead

12 discussant on Chapter 2 and Deborah on Chapter 4. You

13 want to make sure that -- well, we don't miss it. You

14 know, think all of the other ones did it and then no one

15 does it. But -- and then if there's some reason to have

16 it in both places, because there's some difference in the

17 context, that's certainly fine, in my opinion.

18 DR. MURPHY: Can I just clarify that the

19 data in three years are not required. It's three months

20 that makes a three-month average. And so there's an

21 appendix that describes the criteria for the air-quality

22 analyses and what the requirements were for the averages

23 of that audit graphed in those figures. So just to

24 clarify that point.

25 DR. FREY: Yeah. So it's a three-month
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1 rolling average.

2 DR. MURPHY: Right. So it's three months.

3 You need three monthly averages to derive a three-month

4 average. So it's not a three-year requirement for data.

5 Now, I think there's some confusion because in order to

6 judge an area to be in attainment with this number, you

7 need to have a clean three years, if you will. But to be

8 judged out of attainment, three months will serve.

9 MR. POIROT: Okay. And it was only data,

10 however, from sites to add three years of data and present

11 it.

12 DR. MURPHY: I'm sorry?

13 MR. POIROT: In the appendix, it summarizes

14 the available lead monitoring data. I believe you only

15 presented data from sites that had three years of data.

16 DR. MURPHY: I'm not positive on that, but

17 I don't believe that's the case.

18 MR. POIROT: Oh.

19 DR. MURPHY: But we can check that and be

20 clear on that point. That's a good comment.

21 DR. FREY: That sounds familiar.

22 MR. POIROT: That's why I inferred if three

23 years were necessary for the design guidance. And maybe I

24 misread it.

25 DR. FREY: Okay. Michael.
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1 DR. WEITZMAN: I don't mean to distract,

2 but I want to go back to something that Mr. Poirot said

3 earlier about dust lead. Given the past ten years

4 accumulated data about some of its serious effects at

5 lower levels of exposure in children, and the new CDC

6 statement. Is there a reason to revisit dust lead

7 standards. Does HUD do that or the EPA? And if it's the

8 EPA, is this the right panel? Did that make sense at all?

9 DR. CAVENDER: It is being looked at by

10 another EPA panel, and EPA is developing -- or relooking

11 at the lead -- resident, both the resident and commercial

12 buildings.

13 (WHEREIN, unintelligible due to multiple

14 people speaking at once.)

15 DR. FREY: Okay. Other discussion on

16 Chapter 2? Michael.

17 DR. KOSNETT: I had a question that relates

18 to both lead and the contribution of ambient air lead to

19 lead in soil. Yeah, lead in soil and lead in die. It's

20 addressed -- you know, there's a section on Page 2-27 --

21 no, 2-36 that talks about lead in soil. And then it says

22 at the top of Page 2-37, Few studies have investigated

23 temporal trends of surface soil lead concentrations in

24 more populated areas in relation to reductions in usage of

25 leaded gasoline and paint.
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1 And I've also considered in relation to the

2 decrease of ambient -- airborne air related emissions.

3 Really, there's -- there's nothing really cited in here

4 that points to that. I know we talked about this when we

5 talked about the REA in 2001, but maybe the other people

6 -- I just wanted to speak to that. Do we really not have

7 any data that says what happens to all the lead in the

8 soil that's been deposited over time?

9 In urban -- you know, in urban areas -- you

10 have a thing in the previous paragraph about lead in

11 forests, and that's going down. You say, Well, maybe

12 because it's moving or something (unintelligible). The

13 question is about lead in soil that's just been -- not

14 contained, but in historical emissions it's just sitting

15 there. Do you know what happens to that? The assumption

16 is in your simulations -- do you keep that level, it's not

17 going to change?

18 DR. MURPHY: So I'm assuming you're asking

19 a couple of questions. I'm sorry. I'm hesitant. I guess

20 I could clarify a couple of things. This paragraph is

21 referring to -- as you know, the prior paragraph talks

22 about there are studies that relate trends in soil lead

23 concentrations in the remote areas and we tie them to

24 reductions in the use of lead gasoline.

25 In more populated areas, there are a few
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1 studies which do that in any way. And this then points to

2 the ISA for analyses that are presented in the ISA that

3 are close to that point but don't really present studies

4 that do that. So that's why the statements -- a few

5 studies have investigated because United States doesn't

6 really identify it as a limited data set.

7 Your second question seems to be having

8 something to do with the risk and exposure assessment,

9 which is a different thing. I mean, this is commenting

10 with regard to over this time period when we've seen such

11 dramatic reductions in air concentrations that have been

12 noted in the discussion earlier this afternoon. Have we

13 also tracked reductions in the soil concentrations in

14 urban areas. And this statement really just says a few

15 studies needed to have done that. And to the extent the

16 panel knows about other studies that should be cited, that

17 is something that would be useful to the ISA or could help

18 us if they were already (unintelligible).

19 DR. KOSNETT: My second question, you know,

20 that -- is when you go on and you develop your scenarios

21 and your -- with like the new lead and the old lead, you

22 basically keep the dust lead and the soil lead compound.

23 You keep the soil lead flat. That's what I'm saying. You

24 don't change that.

25 DR. MURPHY: With regard to the risk
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1 assessment --

2 DR. KOSNETT: Yes.

3 DR. MURPHY: -- we maintain -- we did not

4 try to simulate what the change in air concentration would

5 do in terms of changing soil lead because we had limited

6 data to do that with. And so we held constant, the soil

7 -- the outside soil concentration. We did have a model we

8 looked at (unintelligible) lead in response to air

9 concentrations.

10 But with regard with regard to soil

11 (unintelligible). So, yeah, you're right.

12 DR. KOSNETT: And then building on that.

13 If you'll notice, the contributions of ambient air lead to

14 the various things you talk about indoor house dust,

15 outdoor dust, terrestrial media, biota, aquatic media and

16 sediments. What's missing is food, is the diet. There's

17 nothing -- no section in here of that. The zinc, by far,

18 by far, the overwhelming source of lead to the

19 (unintelligible) of Americans today is in the food. Okay.

20 (WHEREIN, unintelligible due to multiple

21 people speaking at once.)

22 DR. WEITZMAN: To preschool children?

23 DR. KOSNETT: To everybody. And if you

24 look at the Clayton and Benson Table 4-1 in the ISA -- I

25 mean, that -- you know, the food and beverage intake for
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1 an adult is one and three-quarters of lead intake. So the

2 question I have is, do we have -- how much of that is

3 legacy of air lead?

4 And over time, since that's the biggest

5 single component of our exposure, if we change -- you

6 know, to what extent is, is future ambient air emissions

7 going to affect that? And just out of my own curiosity,

8 is that a legacy that is going to last for a long, long

9 time.

10 DR. MURPHY: So I think it's fair to say

11 there's a lot of uncertainty in that area. In the risk

12 assessment, for example, we did -- we did something

13 similar with regard to diet that we did with soil. We

14 didn't try to project what might change in terms of

15 dietary concentrations in response to a changed air

16 standard or air concentrations because we don't have

17 information that allows us to make that projection.

18 It's an area of future uncertainty. I

19 think we recognize there is a pathway there, but

20 connotatively we don't have information that allows to do

21 that.

22 DR. KOSNETT: Deirdre, do you think that of

23 the 10 micrograms a day that the average adult gets in the

24 diet -- or somewhere around there, I should say. Maybe

25 not 10, but say 5 to 15, somewhere in that area. Is that,
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1 is that the legacy of lead in gasoline or the airborne

2 lead emissions that they got into the soil or the water

3 and the food supply. I mean, what do you think?

4 DR. MURPHY: I don't have information to

5 make a statement to that issue. As you note, in addition

6 to those sorts of sources, there are also introduction of

7 lead through a different processing that can happen in

8 other countries as well as in the past. So there's a lot

9 of uncertainty.

10 DR. KOSNETT: Does anyone have an idea on

11 that? Michael?

12 DR. RABINOWITZ: Just backing up a little

13 bit here about lead in soil and resampling. It's trite.

14 And it's easy to go back to agricultures and resample it

15 10, 20, 30 years later, no problem. Urban settings are

16 the areas that's pretty difficult because urban activity,

17 just the landscaping, buildings and roads. It's hard to

18 go back and actually sample the same place again and

19 again. It just doesn't work in rural settings like that.

20 It's hard to go back (unintelligible).

21 Like in St. Louis, you go back and see the

22 (unintelligible). We're going to be doing this. The

23 result of all this we're doing is that lead levels go

24 down. The other big change besides taking lead out of

25 gasoline is taking lead out of cans. And that's just a --
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1 this disappeared about the same time lead gas disappeared.

2 I don't think we should forget that there will be lead in

3 containers. So most of the spots we can go with our

4 criteria base now.

5 DR. FREY: Did you have a comment? I think

6 you wanted to weigh in on this discussion.

7 DR. DAVIDSON: I did actually. I wanted to

8 get to the first point that Dr. Kosnett made. With regard

9 to looking at lead in soil, there are published

10 resuspension rates for different types of soil. And we've

11 done some modeling. You said there's resuspension rates.

12 In particular, modeling for Los Angeles where you'd expect

13 there to be very high concentrations in soil near the

14 freeways, near all roads. And what you find is that the

15 resuspension rates are high enough so that you can easily

16 get the -- you can use that model, and you can easily get

17 airborne concentrations that are equal to the current

18 measured airborne concentrations in Los Angeles, which are

19 -- which are -- they're not very high, but you know,

20 they're on the order of 30 or 40 nanograms per deciliter.

21 So well below the standard of .03, .04.

22 But you can easily get that by using --

23 even underestimating resuspension rates and knowing the

24 lead content in the soils. It's interesting, though, that

25 if you solve the equations -- the coupled equations for
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1 lead in soil and lead in air, what you find is that the

2 lead in the soil does not decrease in concentration with a

3 fast time constant by any stretch of the imagination.

4 In other words, there's a huge reservoir of

5 lead and that lead adds to the airborne lead

6 concentration. Indeed, we believe it may be mostly

7 responsible for the airborne lead concentration. But the

8 soil reservoir is not decreasing in its lead level over a

9 time scale of several years. You actually have to be time

10 scales of many decades before you see, before you see a

11 reduction. Which is one reason there was a lot of concern

12 -- at least I was concerned over, What's the ultimate fate

13 of the millions of tons of lead deposited on urban soils.

14 It's not going to go away by itself. And actually I agree

15 completely with what Dr. Rabinowitz said about moving soil

16 in urban areas. That's the way the soil is removed from

17 urban areas. It's when a developer comes in and actually

18 uses a bulldozer and removes big chunks of soil. That's

19 going to get rid of it, by not allowing the wind to

20 naturally resuspend it.

21 DR. KOSNETT: And what do you think -- do

22 you think that the lead in the diet, which is the biggest

23 source for the average American -- is that, is that

24 enduring legacy of past emission or is that from something

25 else?
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1 DR. DAVIDSON: Okay. So this goes back to

2 the National Academy of Science panel back in 1980, which

3 I was on, where we looked at lead in the diet, lead in

4 water, lead in dust and so forth. And at that time, the

5 typical lead in adult diet was around 7,500 grams per bit,

6 so 10 micrograms per bit. And that was contributed --

7 that 75 was contributed mostly by food.

8 Now, the question is, how much of that lead

9 in food is actually from the air. This is a bit -- it's

10 very difficult to know that because the lead in canning

11 went down. The lead in the air went down, so there's less

12 deposition onto food crops. So, in fact, lead is going

13 down from lots of different sources. So it's not

14 surprising that you have a 10 microgram per day lead

15 intake now from diet. But I suspect that a lot of this is

16 the legacy of gasoline derived lead. Because if you look

17 at the emissions that came from lead, we're talking about

18 millions of tons. Do you agree with that, Michael?

19 DR. RABINOWITZ: I suppose. I mean, I

20 agree that, certainly, lead levels in diet are much lower

21 now.

22 MR. MCNAMARA: Move closer to the mic,

23 please.

24 DR. RABINOWITZ: The question is whether

25 residual sources of lead in the diet. And I guess in the
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1 old days you'd see one or two major sources. But now that

2 the general levels have dropped, there's opportunity for

3 smaller sources to be placed in it and roll. For

4 instance, (unintelligible), which used less and less in

5 factories. It used to be lead dairy animals. So you're

6 now going to -- you've seen it on How It's Made, it shows

7 on TV that it's in food in factories. So there are

8 bearings and little bits of metal wind up in it. It's a

9 microscopic analysis.

10 You know, Chris -- you pick up a glass

11 somewhere and it's heavy, there's lead in it. And maybe

12 Dr. Weitzman will have some more recent data, but I'll bet

13 from crystal radiates into the diet. Of course, it's

14 porcelain. It's imported. (Unintelligible.)

15 I don't think it's -- I could be wrong.

16 That's why I come to meetings. You could tell me I'm

17 wrong, and I'd learn something. I may be wrong, but I

18 think residual -- the legacy of lead in gasoline is no

19 longer a source of agriculture, and I don't think it's

20 much of a source in diet and a few of these other little

21 sources.

22 DR. KOSNETT: I don't know.

23 DR. RABINOWITZ: This is my seat of the

24 pants answer.

25 DR. KOSNETT: I don't know, and I don't --
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1 I haven't seen data on it. It's not in the 1,600 pages.

2 Like I said, it's not -- and we don't know, but it's an

3 interesting question. I don't want to waste any more

4 time, but it's an interesting question.

5 DR. WEITZMAN: Well, I just think it's the

6 largest single source, you know, to have, right? There's

7 also lead in water, right?

8 (WHEREIN, unintelligible due to multiple

9 people speaking at once.)

10 DR. FREY: Yes.

11 DR. WEITZMAN: If every, every

12 municipality, every state has a lead program that deals

13 with lead in paint in the houses. And so I'm confused

14 when you say that the majority of lead comes from food.

15 Is that true for children with blood lead above five?

16 DR. KOSNETT: I'm not talking about that,

17 no. No. I'm talking about -- I'm not saying --

18 (WHEREIN, unintelligible due to multiple

19 people speaking at once.)

20 DR. KOSNETT: I'm not saying that. I'm

21 saying for the background -- the background person that's

22 had blood lead of about 1.3. Right? Isn't that the

23 geometric -- you look at what is maintained -- you know,

24 what is the input that we get on a daily basis, the

25 biggest single source that we can trace. Not to the lead
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1 worker, not to the child. Other people. It's lead in the

2 diet. It's not lead in the air. I mean, that's a

3 (unintelligible), right? It's not lead in water

4 necessarily.

5 So we don't breath it, we don't drink it.

6 It's -- because we eat it, you know. And some of it we

7 get from soil. But if you add up all the numbers, the

8 biggest source is diet.

9 DR. FREY: I guess this discussion also

10 prompts me to point out -- and we talked about this

11 earlier that, you know, the one thing we can advise the

12 administrator and the agency on is data needs and research

13 needs. And if this is an area where not a lot is known,

14 you think it's tangent or relevant to informing the next

15 round of review of the standard, this may be something

16 we'll want to mention.

17 And related to that, I do want to -- I

18 guess for all the charge question lead discussants, both

19 of the ISA and Policy Assessment, I would encourage you

20 and your groups to identify if their research or

21 information needs are relevant to your topic areas. And

22 maybe, you know, separately list them and a few bullet

23 items.

24 I guess depending how many we come up with,

25 we may want to call that out as a separate component in
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1 the letter to the administrator. And part -- I don't want

2 to change things by saying we're moving along pretty well.

3 If we have some time tomorrow morning after we complete

4 the charge questions, I think it would be worth a few

5 minutes just to see where we are on wanting to recommend

6 research or information priorities.

7 It also reminds me that -- I wanted to ask,

8 and I don't mean to put anyone on the spot publicly in

9 front of the entire panel, but Dr. von Lindern, would you

10 be willing to volunteer to draft some text related to the

11 unintended consequence or the -- you know, that issue that

12 we talked about earlier of kind of the global displacement

13 of lead as a potential adverse impact that we might want

14 to point out to the administrator. And would you be

15 willing to kind of serve as a lead? I think you're

16 best --

17 DR. VON LINDERN: I guess I asked for that.

18 DR. FREY: Yeah, I think so.

19 DR. VON LINDERN: Yes, I will.

20 DR. FREY: Okay. So if anyone has input on

21 that, I would encourage you to -- okay. So having said

22 those things, any other discussion on Chapter 2? Yes,

23 Rich.

24 DR. CANFIELD: So just going back to the

25 notion of a point source that is being commissioned and
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1 maintains its pollutant ways, does that suddenly become a

2 non-regulated site, or what -- I mean, if --

3 MR. CAVENDER: The actual requirements for

4 lead monitoring, we regulate the states who put the lead

5 monitorings out. We put in a regional administrator

6 authority that can require a monitor anywhere where

7 there's a decision that the lead NAAQS may be exceeded.

8 And then the previous preamble to that of 2010, which was

9 2008, we specified one area in particular they should be

10 using that authority in a recently closed facility. So

11 they don't automatically get out. We're hoping that

12 they'll still be addressed to that approach.

13 DR. RABINOWITZ: Just a quick comment.

14 Perhaps, you can guide us on this. Don't most old,

15 closed-up lead factories become Super Fund sites and,

16 thus, they're monitored?

17 MR. CAVENDER: I don't know, but I would

18 suspect yes. I've heard many have never officially closed

19 to avoid that.

20 DR. FREY: Well, it sounds like we might be

21 at a good point for a break now. Let's take a break until

22 -- let's do a 15-minute break, which would take us to

23 4:20. And then we'll take on Chapter 3.

24 (WHEREIN, a brief recess was taken from

25 4:03 p.m. to 4:20 p.m.)
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1 DR. FREY: All right. The only thing

2 between you and dinner is our discussion of Chapter 3,

3 so...

4 I have a list of people that want to

5 mention something briefly. I'll start with Dr. Murphy and

6 then Dr. Kosnett.

7 DR. MURPHY: I just wanted to mention since

8 there was much discussion previously about research needs

9 that we do -- although we did not include a charge

10 question, but at the end of Chapters 4 and 6, there are

11 sections with regard data gas and areas for future

12 research. And so your consideration of that and focus of

13 your comments in that way might be a (unintelligible) way

14 to go.

15 DR. FREY: Yeah. Thank you. That's a good

16 point. Yeah, I have noticed that those were there, which

17 is great. Michael, you promised a brief comment.

18 DR. KOSNETT: Yeah, just briefly. I mean,

19 we had some discussion during the break about the

20 contribution of dust and lead, and I was -- I revise what

21 I said. For adults diet is the most important part, but

22 for children those actions and analysis suggest that dust

23 is more important.

24 DR. WEITZMAN: I'm glad you revised it

25 because then we were going to have to rewrite --
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1 (WHEREIN, unintelligible due to group

2 laughing.)

3 DR. KOSNETT: Yeah. So it's for adults,

4 not for children. So I just wanted to clarify that on the

5 record.

6 DR. FREY: I know Michael's relieved

7 because we were talking about that during the break also.

8 So thank you for that clarification. All right. Let's go

9 to Chapter 3. And we have an esteem group of five

10 discussants. Rich Canfield is the lead, and then Michael

11 Kosnett, Joel Pounds, Gail Wasserman and Michael Weitzman

12 are also discussants.

13 So I'll yield the floor to Dr. Canfield.

14 DR. CANFIELD: So --

15 DR. FREY: Oh, and I'm sorry to interrupt.

16 Just one thing, the -- I was asked to remind everybody

17 please use your microphone, which you are doing and I want

18 to congratulate you for that. But I want to make sure

19 everyone remembers to use the microphone.

20 DR. CANFIELD: Okay. So Chapter 3. I have

21 sort of the full view of Chapter 3. On one hand I think

22 it reviews the evidence and is fairly complete. But I, on

23 the other hand, think it's extremely difficult to get

24 through. And it's -- I think it's clear that it's a

25 draft.
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1 So it -- I have a lot of comments that are

2 really stylistic, but it -- I think it was to the point.

3 And at least in my reading -- maybe it was too late at

4 night when I was doing it, but I felt like that complexity

5 of the expressions were interfering with my ability to

6 keep the thread and, you know, feel confident about my

7 evaluation.

8 So -- and I recognize this takes just a,

9 you know, herculean amount of condensation to get Chapter

10 5 down to this. So I congratulate you on that. That is

11 not easy in any way. And these accurate sentences have to

12 have parentheticals to refer to, you know, sections in the

13 Chapter 5, and there are other qualifiers, but something

14 -- it just gets out of control. But it's primarily

15 stylistic things, which in this case became partly a

16 problem with clarity, just in general. So I think it was

17 reasonably complete, but not reasonably clear.

18 So with respect to the first charge

19 question, that is that. I think it generally captures the

20 key aspects of the evidence. And my concerns about

21 content are really just related to content in the ISA

22 rather than the translation of it in here. There may well

23 be places where others will find a lack of translation for

24 me to -- it was more the -- the content seemed to be

25 fairly complete.
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1 So in the second charge question, to what

2 extent is the newly available evidence on air-to-blood

3 ratios appropriately characterized and considered in light

4 of information previously available in past reviews.

5 So I think it's -- the context is clear.

6 The history is laid out. It's clear there's no change in

7 the -- recommended at this time, given the data context.

8 And I think especially in this section, 2.1, it was often

9 the case that it's not until the end of the section that

10 you got the message that you wanted at the beginning of

11 the section to help you understand what it's saying

12 essentially. That's distracting. So I'm sure all of that

13 goes together.

14 So, also, what extends to newly available

15 evidence, Charge Question 3, to what extent is newly

16 available evidence on concentration-response functions for

17 IQ decrements in young children appropriately

18 characterized and considered in light of information

19 previously available in past reviews.

20 Now, I take that to be a question about,

21 Did you really capture what you needed to capture from the

22 ISA in this short document. And I think there could be

23 various (unintelligible) because there are a lot of angles

24 to the concentration response, if you will.

25 I think the newly available data is
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1 appropriately characterized and weighted. I think that

2 the importance that you give to it is appropriate. Even

3 though I think parametric information could be extracted

4 from the data in the more current -- the recent studies, I

5 don't think that I would want to see the previous studies

6 weighted by less reliable information. So I think that

7 the weighting is despondent.

8 And I also think, in terms of

9 characterizing this context, that you correctly identify

10 that we really have a lack of information of lead levels

11 to verify range. And we have the problem -- or we just

12 don't know what that -- what the approaching origin means

13 in low-level lead.

14 So on to Charge Question 4. I actually

15 should have said if any of my co-panel members want to

16 jump in, you can. I am getting on to Charge Question 4.

17 So feel free to jump in.

18 So Charge Question 4. With regard to the

19 exposure and risk information, to what extent is the

20 information drawn from the human exposure and health risk

21 assessment in the last review sufficiently characterized

22 and clearly communicated. To what extent is the

23 information appropriately interpreted in light of the

24 currently available information and for the purpose of

25 assessing the adequacy of the now current standard.
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1 So I think the information in the last

2 review was well-characterized and appropriately

3 interpreted, but the clarity of this communication can be

4 improved. And I think it's clear, and I agree that new

5 REA is not warranted at this time. But I would like to

6 know that at the beginning of the sections rather than at

7 the end.

8 So Charge Question 5. Are the limitations

9 and uncertainties in the exposure/risk information

10 appropriately characterized and considered in our

11 interpretation of the information in the context of this

12 current review.

13 They -- the limitations and uncertainties

14 are all characterized. The epidemiological data are

15 inherently limited, and there's a lack of data on the

16 effects of exposures at levels common today. And, thus,

17 their concentration response estimates are uncertain.

18 Primary choices for biokinetic models

19 typically require restricted assumptions, and that's a

20 source clearly identified. And there's no single air

21 quality scenario that covered all basis. So in many ways

22 I felt like the uncertainties and limitations were, were

23 clear.

24 I have a -- just a couple of potential --

25 potentially important wording changes or things to
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1 consider, I should say. One is, there are a number of

2 places where I would appreciate a change -- or appreciate

3 change of business. I think this goes back to a common --

4 this is on other sections, where it would be good to say

5 when the new information reinforces, strengthens or

6 otherwise improves the interpretation of the previous

7 information.

8 And so maybe the notion of whether there's

9 any quality of change would be important or something

10 that's a bigger jump and appreciated. So clearly no --

11 nothing that is qualitatively important as has been put

12 out recently. So, again, this could come up in Chapter 5,

13 but I'm -- the ISA, but it seemed by the time I got to

14 this condensation of all the information, I looked at

15 Table 3-2 on Page 321 -- 3-21. I am wondering whether the

16 24 month Bayley data are sufficiently strong to merit

17 presenting at this level of the review.

18 And I would be interested in my colleagues'

19 views of that, just my -- and for those not in the area,

20 the fact that 24 months is a timely behavior still

21 changing radically in the child's mode of expression, his

22 language and solve problems, that are pointing to -- it's

23 difficult to predict much in later function and later IQ

24 based on those kinds of scores. They go through the

25 (unintelligible).
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1 And so I would kind of put the baby in a

2 different category than all of the IQ data. Again, that

3 could be, I think, justified for -- for the ISA, but I

4 just felt like it was out of place here -- or it could be

5 reasonably considered to be out of place here. And others

6 may provide their perspective on that.

7 I thought that your discussion about -- and

8 this could have gone any way -- the limitations and

9 uncertainty section, but your -- Page 22, Line 17-23, very

10 nice discussion of the problem with unknown earlier

11 exposures. That comes up many times in this chapter, and

12 I think it becomes redundant at times. And -- but there

13 is a need to mention it again and again. It's

14 appropriate, but I think it -- you could expand a little

15 bit on this section on Page 22 and maybe include that as a

16 particular cross-sectional settings and maybe put that

17 earlier so that -- so that that issues is dealt with and

18 find a shorthand way to refer back to it when it becomes

19 relevant later.

20 At this point, most of it is in this place

21 -- or you get little dribs and drabs of the -- of the

22 aspect of this issue that are relevant to the specific

23 context, and then you have to say more than you need to --

24 more than you should need to. And that's fine. So that

25 would reduce the redundancy and just make this issue -- a
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1 very important issue clear throughout the document.

2 So besides wording issues and some

3 clarification questions and things like that, that's my --

4 that's all I have to say.

5 DR. FREY: Okay. Thank you. Dr. Kosnett.

6 DR. KOSNETT: I agreed with the analysis in

7 Chapter 3. I thought that it was well-presented and

8 cognitive. It was appropriate to use the modeling of the

9 slopes to the lead air relationship, blood lead air

10 relationship. I was -- thought it was a nice analysis. I

11 don't really have a substantive critique to offer about

12 that, so I'll be brief.

13 DR. FREY: Okay. Thank you.

14 DR. POUNDS: I thought following Michael I

15 would have a chance to drink my coffee. So with respect

16 Charge Question Number 1, the answer is yes. This chapter

17 maps very well to the relevant -- I can say chapters in

18 each bulleted and bold question, that it's in this

19 chapter. It's very clearly linked to the ISA. It was

20 easy to read that way. The data and conclusions are

21 compared and contrasted clearly and concisely with the

22 evolution of data.

23 With the conclusions of the previous

24 review, there were occasions when I thought that there was

25 too much data. This may be because of spending a lot of
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1 time with the areas over the last couple of years. But I

2 thought that -- I can -- I reread this (unintelligible).

3 As Rich said, when you get to -- you know, what's the

4 bottom line?

5 There was one -- and I guess this is

6 Question 5. (Unintelligible.) And I'll have to say it

7 too, because I think I'll say it a little different. That

8 there's an enormous amount of EPA experience that they've

9 derived in this effort in the last couple of years.

10 Policy assessment too often concludes the review, or the

11 recent literature does not provide any new insight.

12 So as a reader, I have to conclude -- well,

13 can we regulate the lead as low as we have to go, or we're

14 not doing the time and research that we need with the

15 appropriate external designs to support regulation of lead

16 levels that we're going to be facing in five years.

17 I'm suggesting that rather than cutting

18 back on collecting our data, our ideas, that the EPA

19 should systematically address the adequacy of the existing

20 data and identify explicit data caps that are yet to

21 support what we expect to be lead exposure relevance in

22 the -- 2017, '18. (Unintelligible) dealing with models

23 that were published 20 years ago and haven't been

24 adequately updated or reparameterized with modern biology,

25 and I think that's indefensible.
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1 To change the subject, one key aspect

2 that's not incorporated into the policy analysis

3 adequately and that's -- although, I think that they

4 looked at the appropriate model and comprehensively

5 incorporated the key aspects, but Chapter 4 included some

6 nicely articulated limitations of blood lead emission in

7 situations of changing lead exposures there. This concept

8 should be introduced to the policy a little bit more

9 directly.

10 And then one potential confusing part of

11 the task, and that's in Question 2, is the expression of

12 the air-to-lead ratios. Sometimes these ratios are

13 expressed as 1:2 or 1:5, other times they're reduced to a

14 slope. So I have to do this mental arithmetic in my

15 calculating division state to try to contrast and compare

16 -- and contrast air regulations from adjacent paragraphs,

17 for example. Just a consistent use of notation would

18 improve the reading a little. But the chapter did meet

19 the goals that it set out for itself.

20 DR. FREY: Rich.

21 DR. CANFIELD: I just want to clarify.

22 They're coming up with different lead mentions in Chapter

23 4, and --

24 DR. POUNDS: They give you time not to --

25 air regulations?
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1 DR. CANFIELD: No. The -- you're saying

2 different ways of measuring blood lead or --

3 DR. POUNDS: No. The -- more the -- the

4 inability of the given blood lead to inform --

5 (WHEREIN, unintelligible due to multiple

6 people speaking at once.)

7 DR. CANFIELD: Okay. Okay.

8 DR. FREY: Okay. Great. Let's see.

9 Dr. Wasserman.

10 DR. WASSERMAN: I have (unintelligible),

11 except I would --

12 (WHEREIN, unintelligible due to multiple

13 people speaking at once.)

14 DR. CANFIELD: If you take a look at IQ

15 scores --

16 DR. WASSERMAN: At Table 3-2?

17 DR. CANFIELD: Oh, is that the one? I'm

18 sorry. Maybe I'm -- maybe I'm --

19 (WHEREIN, unintelligible due to multiple

20 people speaking at once.)

21 DR. WASSERMAN: Is that the table you're

22 looking at?

23 DR. CANFIELD: I'll check it out, but I

24 agree with you with this. If it's not just IQ plus

25 Bayley, then I would agree with -- I'll leave it at that,
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1 but I think I looked at it differently.

2 DR. FREY: Okay. Thank you. Dr. Weitzman.

3 DR. WEITZMAN: I concur with what my

4 colleagues said before me.

5 DR. FREY: Okay. Other discussion on

6 Chapter 3?

7 DR. CANFIELD: I would like to formally

8 withdraw my comment on Table 3-2. It doesn't -- it is a

9 hot shop, so...

10 DR. FREY: Okay. Other comments,

11 discussion on Chapter 3?

12 (No response.)

13 DR. FREY: Okay. Well, I would propose

14 that -- we're actually a little ahead of time on our

15 agenda, but I think it might be good if we use the time we

16 scheduled and continue through 5:30 if the Chapter 4

17 discussants are willing to do that.

18 And my thought is, we may or may not get

19 through all of Chapter 4 today. But it might be good to

20 go through it this afternoon and then reflect on it this

21 evening, and then we can pick up again with it. I think

22 Chapter 4, in some ways, is kind of the bottom-line key

23 thing, right? This is where the EPA is making a

24 recommendation about that standard, and so what's what

25 this whole process -- at least for the primary standard is
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1 culminated to.

2 So we have three discussants, which is

3 Deborah Cory-Slechta, Sean Hays and Susan Korrick. Would

4 you-all be amenable to proceeding?

5 (WHEREIN, group nods heads.)

6 DR. FREY: Okay. With that then, I would

7 like to turn the floor over to Deborah.

8 DR. CORY-SLECHTA: Okay. I'm going to go

9 through the charge questions, and I'm going to talk about

10 the reality perspective and then sort from an academic

11 perspective with respect to a couple of the charge

12 questions.

13 I did feel that the evidence-based

14 framework from the last review is appropriate. I was on

15 that review, and I felt it was appropriate then. And that

16 the new literature really just provides further support

17 for the health effect conclusions that are presented in

18 the prior review. Fundamentally, we haven't really

19 altered that much of the uncertainties.

20 The second of those questions is, What are

21 the panel's view on staff's interpretation of the

22 exposure/risk information, and on staff's conclusions that

23 the information is generally supportive of the conclusions

24 drawn from the evidence-based framework as to the adequacy

25 of the current standard.
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1 If felt that he exposure-risk information

2 from the prior review does appear appropriate given the

3 absence of significant new information that's really been

4 a fundamentally change in the interpretation.

5 The third question seemed like a little bit

6 of an open question, and here's where I'm going to say

7 something that I said in the last review of CASAC review

8 of lead. That is, What are the panel's views on public

9 health policy judgments that inform staff's preliminary

10 conclusions with regard to the adequacy of the current

11 standards.

12 And I have a couple of statements here.

13 One, the document states repeatedly that no threshold for

14 lead effects on IQ can be identified. But I think this is

15 a bit of an overinterpretation. We're now seeing reports

16 of blood lead levels -- reductions in IQ of blood lead

17 levels as low as 2 micrograms per deciliter. In essence,

18 we're seeing effects being reported at the lowest blood

19 lead levels that are -- can be reliably measured. So

20 we're basically right up against the wall.

21 So where the threshold is going to come in

22 there, I don't really know unless we start doing all the

23 blood lead by ICPMS or AAS, which isn't going to happen in

24 the field. So the idea that there's a threshold, in my

25 view, sort of contradicts the literature that continues to
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1 accumulate.

2 Okay. There's statements that the

3 regulations -- again, this from my different perspective.

4 The regulations do not require that a zero risk be

5 achieved, neither does it prevent it. It doesn't say you

6 cannot go to a zero risk. And so given that and the fact

7 that we have this supra-linear concentration-response

8 curve that had been demonstrated in several studies, it

9 becomes difficult, at least in my mind, to support a

10 standard based on a one to two IQ point loss from a

11 neuroscience/psychology biological perspective.

12 I said this before, I'll say it again. The

13 fact that we're basing the standard on some level of

14 degeneration of function, it's really difficult for me as

15 a neuroscientist and psychologist to really seem

16 appropriate. And from a public health perspective, I

17 don't really want to be the one in the room telling them,

18 Don't worry. It's only a one to three IQ point loss, at

19 least just from -- whatever.

20 So I don't know. Maybe get some wording

21 with respect to this -- especially the threshold level,

22 you might want to think about. And, you know, from a

23 policy perspective, we are making judgments based on

24 what's an acceptable loss of IQ. And that has public

25 health consequences. It has social ramifications. And I
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1 brought it up five years ago, and I still believe that.

2 With respect to the last two, In the panels

3 view, does the discussion in Section 4.3 provide an

4 appropriate and sufficient rationale to support the

5 staff's preliminary conclusion that it is appropriate to

6 consider retaining the current standard.

7 And, you know, I have to answer yes, given

8 the evidence-based framework and the fact that we are now

9 down to lowest blood lead levels that can be reliably

10 measured, at least in the field. So it's not really clear

11 that we would need all these IQs anymore. It's become a

12 bit of a moot point in a way. Well, you can expand that

13 discussion as well.

14 And any recommendations regarding

15 additional interpretations. I would just go back to the

16 repeated statements about the threshold because I just

17 don't see how that fits with where we are in terms of

18 reliability of blood lead measures by almost all the

19 laboratories that are part of the quality control programs

20 doing these and where we're seeing the IQ reductions. So

21 those are my comments.

22 DR. FREY: Okay. Nice mapping to the

23 charge questions. Let's see, our next discussant is

24 Dr. Hays.

25 DR. HAYS: Thank you. It was nice to read
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1 Chapter 4, but it was kind of like, you know, reading what

2 we thought was going to come out when we saw the first

3 draft of the ISA. You pretty much knew what was going to

4 be the conclusion, and they gave it to us.

5 I concur with respect to the answers to the

6 charge questions that Deborah provided. Provided, it sets

7 for the argument for there's no special literature as

8 well. So I'm on that.

9 I think the -- there's some very profound

10 statements in Chapter 4, at least I was -- I followed my

11 chair reading. Page 4-28, Line 2-3, it says: We also

12 recognize increased uncertainty in projecting the

13 magnitude of blood lead response to ambient air

14 concentrations at and below the level of the current

15 standard. As we talked about in the science assessment,

16 they are withstanding the relationship between air and

17 blood at the low levels that we have today. It is

18 uncertain.

19 Now, Page 4-32, Lines 33 through 35: In

20 staff's view, based on current evidence there is

21 appreciable uncertainty associated with drawing

22 conclusions regarding whether there would be reductions in

23 risk to public health from alternative lower levels as

24 compared to the levels of the current standard.

25 Now, having listened to what Deborah said
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1 about the IQ levels going on even at the lowest exposures,

2 perhaps, this sentence should be rewritten to write -- to

3 read something about drawing conclusions regarding whether

4 there would be reductions in blood lead levels from

5 alternative lower levels. That's compared to the level

6 standard.

7 And I think that -- I think that some of

8 the things Michael has said that it occurs that -- Michael

9 was mentioning about diet as a primary level of exposure

10 or dust. The reduction in air levels beyond -- below the

11 NAAQS. There may not be an impact in low blood lead

12 levels. So I guess I would recommend that change. So

13 instead of saying reductions in risk to public health, say

14 reductions in blood lead levels.

15 I agree that the new science does not

16 support lowering the NAAQS any lower than its current

17 level.

18 Deirdre, you did ask about our input on

19 these concluding sections on uncertainties and future

20 research and data collection. I actually liked those a

21 lot. They're very good.

22 One of the statements in there I thought

23 was really profound, but it was really vague the way it

24 was written was, you said: Apportionment of blood lead

25 levels with regard to exposure pathways with a particular
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1 focus on understanding -- the particular distinction

2 pertinent to policy relevant exposures in background

3 sources.

4 Well, I kind of rewrote that and said:

5 Apportionment of blood lead levels with regard to exposure

6 pathways, particular focus on understanding pathways and

7 sources that cause more elevated blood lead levels among

8 children today.

9 Now, I catch what you-all were trying to

10 say there, but I think that was the issue. What is

11 causing the elevated blood lead levels in children today,

12 and what can you do to reduce those exposures. And I

13 think this gets back to, you know, air is not the driving

14 factor anymore. It's the other sources.

15 You know, I reiterate a comment I had given

16 a long time ago, and that is how tough Canada -- and I

17 think Michael was involved in that as well. How the

18 Canada set up their regulation. What they did is similar

19 to what you did in terms of assessing blood level and IQ

20 decrements and coming up with target blood lead level.

21 But then across the agency, then, they

22 said, Okay, we need to get down to this level. Let's say

23 2 micrograms per deciliter. How do we do that? And they

24 said, Okay. Air, you get 20 percent. Soil, you get 40

25 percent. Diet, you get the other -- whatever, I can't do
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1 the math in my head that fast. And then they go, Portion

2 it that way. They said, Okay. Go get it and we'll come

3 to that level.

4 And that makes sense. And I think this

5 gets back to some of Ian's comments earlier about, you

6 know, this -- this blinder's view of air being

7 (unintelligible), and I know that's a mandate through

8 NAAQS. But lead is different than that, and you've got it

9 regulated from a multimedia source. I think that kind of

10 approach will be really useful.

11 Now, how you do that, I don't know. Take

12 it out of the NAAQS and put it in something else.

13 Initially ambient -- multimedia exposure quality standard.

14 I don't know, something like that. But that's how the

15 agency can handle these issues and how we can do so. But

16 the blood lead levels and public health risks in the

17 future don't (unintelligible). So that's it.

18 DR. FREY: Okay. This -- well, thank you.

19 Yeah. So you've got to give a national multimedia

20 standard. This reminds me that for a number of years

21 there's been discussion about multipollutant air quality

22 standards, and -- so I think we could expand that concept

23 in giving kids plenty of food (unintelligible). I'm happy

24 to develop regulations.

25 But I think from a science perspective,
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1 that certainly makes a lot of sense -- from a statutory

2 mandate perspective as a challenge for EPA.

3 Well, let's see. Our next discussant is

4 Dr. Korrick.

5 DR. KORRICK: So I actually don't have much

6 to add. I think the previous -- Deb and Sean summarized

7 things real nicely, except that reiterate -- I think the

8 language is important here. And we talk about a -- it had

9 a reduced risk to the public health in the context of a

10 standard that potentially is associated with a couple

11 points loss of IQ in most exposed children. I think it's

12 a little better.

13 As with what Debbie said, I find that a

14 little difficult as a public health message. And then I

15 think that the uncertainty -- as Sean said, the

16 uncertainty in that issue is whether reducing the standard

17 further than what you have children's blood lead levels,

18 not whether it has an impact on protecting their health

19 because I think the current standard has already

20 demonstrated that it has some limitations in terms of its

21 public health protectiveness. Which is, I realize, a

22 policy decision by a health point of view. It's not

23 optimally protected. So I think that language is actually

24 really important. It's just that our message isn't

25 communicated.
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1 Now, I think I -- sort of on a more generic

2 basis, in the document there's obviously a lot of emphasis

3 on areas of uncertainty. And the importance of

4 uncertainty and categorizing cannot be done at this point

5 in the process. But sometimes I felt as if it was a

6 little bit of a cop out. There's more known, perhaps, in

7 some instances than was explicitly acknowledged.

8 So in terms of the discussion of the

9 standard using three-month averaging, not to be exceeded

10 by the level of form, there's language saying that that's

11 -- there's a lot of uncertainty about the timing and

12 duration of lead exposure that's relevant. And I would

13 say that's true, but that there are some perimeters that

14 we're very aware of that are applicable that could be

15 mentioned in that example.

16 So, for example, we know that the exposure,

17 we kind of see, are adverse in terms of developmental

18 outcomes. And pregnancy has a self-limited time period,

19 and there's even some data to suggest that exposures

20 during some trimesters are at more lead risk. So one of

21 the bounds of that uncertainty is that we know that

22 exposures leads to early childhood, over a period of

23 months, are relevant.

24 And then a lot of the children's IQ data

25 goes out, say, age six or seven. So you know that the
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1 time frame this -- in the scale of months to a handful of

2 years. You're not trying to extrapolate, at least based

3 on the health outcome that's considered most synthesized.

4 You have to kind of extrapolate over an adult lifetime.

5 So to say there's uncertainty about the

6 relevant time period and duration of exposure is an

7 accurate comment, but we do have information about grammar

8 trends a little bit that is relevant to the form standard,

9 and maybe the standard makes sense.

10 And I think being able to acknowledge that

11 means that much. It's more detail than we want to put in

12 this kind of assessment, but I think acknowledging that is

13 actually helpful to the reader because uncertainty and

14 lack of characterizing information are not dissonant. You

15 can have both things going on simultaneously. I think

16 that's the case for a lot of the uncertainties that play

17 into this policy assessment.

18 So I think that's the only, sort of

19 additional, comment that I would make.

20 DR. FREY: Okay. Great. Other comments on

21 Chapter 4?

22 (No response.)

23 DR. FREY: And in particular -- you know,

24 so this is -- as I said earlier, this is kind of the

25 bottom line for the primary standard. Any further
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1 comments regarding indicator or level, the averaging time,

2 the form?

3 (No response.)

4 DR. FREY: Is there any -- I guess in the

5 absence of a comment, does that mean sort of by silent

6 consent that the panel's comfortable with the EPA's

7 proposal to retain the current standard and all of those

8 attributes of the standard or what the indicator of level

9 averaging time form. And if not, speak now. Okay. So

10 Phil, Herb and Deborah.

11 DR. HOPKE: Okay. Well, again, let me

12 bring -- bring up the issue of the form again. I mean,

13 I'm not opposed to the form, but I don't think it's been

14 very well presented. I don't think it's been very well

15 justified. I don't think it necessarily, you know, has

16 the context of the kind of exposure, you know, relative --

17 you know, how does it really relate to the exposure and

18 add protectiveness to the standard?

19 We see in these kinds of discussions, for

20 example, in -- you know, the percentile standard aquatic

21 to PM 2.5. We haven't seen a parallel kind of discussion

22 here. In fact, at this point -- you know, like I said,

23 this is a holdover from the original 1970 whatever and,

24 you know, we've learned just a little bit since then in a

25 variety of fields.
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1 And it might be nice to understand what the

2 thinking was then and why we believe that's still

3 (unintelligible). I'm not suggesting necessarily that it

4 be changed, but I don't think at this point the status quo

5 ranthy (phonetic) is -- has been very well justified.

6 DR. FREY: So is that focused on the not to

7 exceed --

8 DR. HOPKE: Yeah.

9 DR. FREY: -- aspect of the form?

10 DR. HOPKE: Absolutely.

11 DR. FREY: Okay. All right. Well, that

12 may be something -- and, Rich, do you want to address that

13 issue?

14 MR. POIROT: Well, just to follow up on

15 that. You know, in some ways the form has become more

16 stringent with the last review and that it used to be, I

17 think, a fixed calendar three-month quarter. And now it's

18 rolling. And so those two aspects of the form --

19 DR. HOPKE: Right. But they're -- in

20 neither cases there have been analysis of data or anything

21 shown why this is good, bad, different, better.

22 DR. FREY: Okay. Well, let's see, Herb had

23 his hand up.

24 DR. ALLEN: I really like what Sean had to

25 say about basically the multimedia exposure because that's
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1 what it is. And as you lower the amount of exposure from

2 air, it becomes less and less important. And that really,

3 I think, comes across -- so what happens when air no

4 longer is of importance, and what is the form -- what kind

5 of standard do you have for air where you are basically

6 force the habit of their standard because that's the act

7 if air no longer is a factor.

8 DR. FREY: Well, that -- yeah, that's a

9 good question. Yeah, so the NAAQS -- and I'm not a

10 lawyer, so maybe the general counsel of the EPA could

11 answer this better than I can.

12 But I think the -- as I understand the

13 Clean Air Act, it gives the EPA the authority to establish

14 criteria which essentially, as I understand, is basically

15 identifying what pollutants to regulate under the NAAQS.

16 And as I understand it, it is actually --

17 it is possible to add more pollutants to the NAAQS. I

18 don't think that's been done. But then the flipside, is

19 there a process for removing pollutants from the NAAQS?

20 And that's clearly not been done, either.

21 And, yeah, at some point -- you know, as

22 you say, if the air component drops down -- maybe we're

23 not at that point yet, but is there a point in which --

24 this is looking at that question.

25 DR. ALLEN: Yeah. And that's what we were
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1 discussing for an hour or so, on air. If the major -- if

2 food is the major source of lead, what we need to be doing

3 is legacy lead not hurt depositional lead, then do we --

4 doing anything in an air lead standard is not going to

5 affect -- is not going to affect food. So here what the

6 effect (unintelligible). There is probably as much

7 exposure from the water as there is from the air in many

8 cases, and many cases it's not.

9 Those would be dealt with.

10 (Unintelligible) exposure of any importance is food. All

11 right. And that's going to be a legacy issues, and that's

12 going to be around for a long, long time because lead does

13 not move to ground and water.

14 DR. FREY: Okay.

15 DR. CORY-SLECHTA: I want to underscore, I

16 think Sean's point about the fact that it doesn't impact

17 blood lead at the end of the day, it really has become

18 sort of moot issue. We're down to 2 micrograms now,

19 basically. We're at the lowest reliable measurement

20 levels. So I would agree. Maybe it's time for a

21 reconsideration of lead as a NAAQS, but it's important as

22 a multimedia pollutant. And doing it a different way is

23 just -- it's still there. It's critical.

24 DR. RABINOWITZ: It seems like we still

25 need a standard. Even though we've reduced lead in air
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1 throughout the solo -- it doesn't matter so much. We

2 still need a standard to keep it low. I'm not sure how

3 you best do it, and I need an average not to exceed. But

4 you still need some standard so somehow it doesn't creep

5 up again in some other sources. That's regarding lead in

6 the air.

7 And regarding lead in food, I'm not sure

8 how much of it is still a legacy of airborne lead. I

9 think there's other sources of lead going into our mouths

10 from other sources of contamination, not just old airborne

11 lead that's either in the soil and predislocated and maybe

12 splashed onto the food. There are other sources of maybe

13 in factoring the processing of the intention.

14 DR. FREY: Thank you. Phil and then Sean.

15 DR. HOPKE: Yeah. I just want to point

16 out, in terms of keeping NAAQS code, there's and aphorism

17 by Mark Twain. Never do something bad when someone's

18 watching. Okay. And given the network we have and where

19 we're spending resources to actually make composition

20 measurements, it's very easy then -- so the NAAQS gives

21 you a false sense of security. So beware. Having the

22 NAAQS doesn't necessarily mean that somebody isn't

23 producing -- putting lead in the air at some place for

24 which you're not making composition measurements.

25 DR. FREY: Okay. It sounds like a unique
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1 system, kind of, situation.

2 DR. HOPKE: Of course.

3 DR. FREY: Yeah. Sean.

4 DR. HAYS: Within our documentation, it

5 kind of makes it seem like we've succeeded. And maybe we

6 have towards -- with respect to air. But I just came

7 across this quote today. Failure changes for the better,

8 success for the worse. And so we claim success with

9 respect to lead exposures in air. But that maybe creates

10 a false sense of security, like Phil just mentioned. And

11 somehow there needs to be a shown statement about its

12 other sources of lead need to be the focus, and EPA needs

13 to consider how to handle those through the various other

14 tools it has available to itself.

15 DR. FREY: Okay.

16 DR. KORRICK: I'm sorry. Maybe I

17 completely lost you guys. I thought part of the challenge

18 here, it's not that there's not been a huge -- there's not

19 been a huge benefit of lowering air lead levels to public

20 exposure risk and health risk, but I thought that we don't

21 know what proportion of exposure is attributed to air.

22 And we don't know if you have the standard if it would

23 have an impact on lead exposure risk.

24 And it sounds like most people are assuming

25 that we know that the role of their lead is very, very
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1 small. I mean, I know in adults -- Michael has pointed

2 out there that the food is the major source of this

3 exposure. But even if there are lead -- you get a 10 or

4 15 or 20 percent of exposure risk, given that health risk

5 especially in kids, it's so explicitly sensitive below the

6 exposure. So that can still represent a substantial

7 health benefit to eliminate that exposure source.

8 So I'm a little confused. Did I miss

9 something that -- I feel as if there's an expression of

10 more certainty that some of these more fundamental issues

11 than I have been presented.

12 DR. CANFIELD: And just to go along with

13 that is our ability to claim victory over air lead based

14 on our current ability to measure its effects in the most

15 sensitive -- or on children. So we may find -- so I am

16 somewhat convinced by people who say, you know, pretty

17 dusty will be a moot point, but -- 016 micrograms per

18 deciliter or something.

19 DR. FREY: Yeah. Deborah, you have a

20 comment?

21 DR. CORY-SLECHTA: Well, I think Susan's

22 point is well-taken. Of course, we're beyond primary

23 prevention, unfortunately. But in kids the issue has

24 always been dust and not so much food. And if you look at

25 the young teens blood lead distributions by age, they're
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1 always highest of the one or two years of age and some of

2 which can come from air.

3 Having said that, those populations are

4 also largely inner-city populations where there's probably

5 so much incorporation into the soil at this point that

6 short of digging it up or completely rehabbing houses, I

7 think that's considered to be the source of those -- for

8 those age groups. So, you know, there is resuspension of

9 air. We did hear about that, and that has been considered

10 for dust. And I think it's being considered in the

11 dust-lead standard. But really the issue here is dust.

12 And this is just a residual contamination. I don't know,

13 you know, where it's going to go at this point short of a

14 lot of money for each contaminated site.

15 DR. KORRICK: Okay. I mean, I think it's a

16 bit -- we were talking about this a little bit; that --

17 Michael's -- the lead-per-kid study where the data is low

18 leads around houses that had the highest blood lead

19 levels. The impact on health was proportionally very

20 small. So I think the conventional -- what's known is

21 that the dust appears to be the major source of the

22 exposure aspects, but it's not so -- I don't think it's

23 been so clearly apportioned that that's -- maybe I'm

24 wrong.

25 I mean, basically, heavily exposed kids in
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1 inner-city housing who've ingested lead paint are getting

2 exposed from lead paint. But there's a whole lot of kids

3 out there who have a blood lead level of 2 that have not

4 ingested lead paint and that are still along the continuum

5 of children who are going to be adversely affected by

6 lead. And I don't think we necessarily know where the

7 lead is coming from. Is that not correct?

8 DR. HAYS: That's how lead is.

9 DR. KORRICK: Yeah. And so I -- I mean,

10 I'm not saying that keeping the same standard isn't the

11 appropriate thing to do at this time. But I think -- I

12 feel uncomfortable being to (unintelligible) about having

13 finished this story when there's fundamental uncertainties

14 about the role that air lead plays in exposure and the

15 role that changes the standard might claim as exposure.

16 I think that's the area where things are

17 unresolved. And because from a public health point of

18 view, the sensitive outcome -- the outcome is so

19 exquisitely sensitive to small amounts of lead, those

20 uncertainties compound.

21 DR. FREY: Okay. Herb and then Sean and

22 then Phil.

23 DR. ALLEN: I agree with you, Susan. But I

24 think what's needed is a better understanding of what the

25 portions of lead exposure are from various sources to
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1 various populations. And only when you have that can you

2 really understand whether a proposal to have the standard

3 stay as it is move up, move down. It's possible.

4 That's when -- when everybody knew that air

5 lead was -- the lead in air was the source of most of the

6 exposure, but it was very simple to set a standard because

7 if you lowered the amount of lead in the air, you lowered

8 the amount of blood. And, you know, the city had a good

9 response. I don't think that's clear anymore. I mean, we

10 have the same issue going on in the ecological one where

11 what we said is, We don't really know how (unintelligible)

12 the critical loads model, which is the same thing we

13 really need on -- you know, it is the equivalent of a

14 critical load, right, to tie these together. Until you

15 have them all tied together, you can look and see where --

16 where the control is, where the engineering part. And

17 then that becomes the answer to the question.

18 DR. FREY: Sean and then Phil and then

19 Deborah.

20 DR. HAYS: I don't have a comment anymore.

21 DR. FREY: Okay. Phil.

22 DR. HOPKE: Okay. I mean, again, the

23 question is, is lead then -- I mean, I would like to look

24 at a broader context of threats to public health in the

25 air. And is lead really the place where we want to put
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1 the amount of time and effort that we are now relative to

2 mercury or several other things that I can think of.

3 And, you know, isn't it time that we

4 started putting real life into the criteria of pollutants.

5 And it was cleverly designed by congress that they need to

6 be modifiable. We have sat in a very rigid structure for

7 35 years always looking at the same things. And I'm not

8 sure that we're really doing the job we're supposed to do

9 to protect public health with an active margin of safety

10 from broadly distributing multiple sources of air

11 pollutants.

12 And so I would like to see us use this

13 opportunity, not -- probably not this time, but I want to

14 really see av-gas cleaned up and, you know, we'll get it

15 straight. You know, seriously look at the next go-around

16 as the last step and be able to use that as a way of

17 saying, Now, it's time to move on, you know.

18 And I realize that opens a Pandora's box

19 and makes very -- lots of people very uncomfortable

20 because they've made careers out of lead criteria

21 documents -- well, not so much lead criteria documents,

22 only a recent amount out of that. But, you know, isn't it

23 time to think of this as a dynamic system in which we're

24 working to find the most important causes of public health

25 problems. And I don't think our curve approaches that.
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1 DR. FREY: Okay. I have Deborah and then

2 Cliff and then Michael.

3 DR. CORY-SLECHTA: Well, I actually want to

4 go back to Dr. Davidson's question that he raised earlier

5 in relation to what Susan was bringing up. Because I

6 appreciate your point, Susan, but I also remember

7 Dr. Davidson asking, What happened to those million pounds

8 of lead that have been dispersed into the environment

9 before.

10 Well, we know where they are. They're --

11 DR. DAVIDSON: Tons.

12 DR. CORY-SLECHTA: Huh?

13 DR. DAVIDSON: Tons.

14 DR. CORY-SLECHTA: Tons. I'm sorry, a

15 million tons. A lot of them are in the inner-city soils

16 and dust where they're going to remain. So I think sort

17 of following up on what Dr. Hopke said as well, so what is

18 the contribution now with the new standard to that huge

19 burden that's already there in those inner-cities?

20 I mean, is it -- is it enough of a -- what

21 they call in psychophysiology a just noticeable

22 difference; that, in fact, it's contributing? I don't

23 know that it is, and I am hearing a lot of people say that

24 that -- you know, we don't really know what the

25 attributable proportion of that is. But there's a huge
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1 level there already.

2 We now have the standard down to .15. I've

3 heard people say that lowering it further won't change

4 anything. And, you know, at this point -- like I still

5 believe, short of going into these cities and removing old

6 housing and the soil, we're probably not going to

7 influence kid's blood leads. Even changing dietary

8 probably isn't going to change the kid's blood leads.

9 DR. DAVIDSON: Okay. So let me just

10 respond to Susan by saying I think that we do have two

11 separate issues here. One issue is the issue of airborne

12 -- the airborne lead standard at .15 micrograms per cubic

13 meter. And I think we've heard from several people that

14 lowering that standard is not going to do much good at

15 this point. So I think that is one recommendation to

16 count.

17 But I think that the second issue is, are

18 there other things that need to be done to protect --

19 protect the public, particularly the susceptible

20 population like kids from lead exposure. And I think that

21 is very different than regulating the airborne lead

22 concentration.

23 So, namely, it involves the legacy lead

24 which lead in dust and so forth. So I think these are two

25 separate -- two separate issues. And I think we need to
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1 make that clear in our panel response for the policy

2 assessment; that these are really two very separate

3 issues, but they're important -- particularly the second.

4 DR. FREY: Okay. Go ahead. Michael,

5 Susan, Rich.

6 DR. KOSNETT: Yeah, I agree that there's

7 separate -- you know, they're separate issues. I think

8 the thing we need -- you know, why are we here today?

9 We're here because in 2008 they asked -- they lowered the

10 standard, and -- and under the terms of the National

11 Ambient Quality Standards, there's a five-year review. So

12 we're coming back now and we're looking at the collective

13 data and we're saying that the standard should be

14 maintained.

15 But I think that's an important -- I mean,

16 the fact that the standards at .15 has protected a lot of

17 children in this country. And, you know, there are a lot

18 of sources and perhaps -- potential point sources and lead

19 which are not being developed or used in this country

20 because of this. So I think this standard is protecting

21 us. I mean, you know, we like -- we'd like to maintain

22 it.

23 And there are other sources of lead that we

24 certainly need to go after. And there's a lot of lead, as

25 Debbie mentioned, you know, in certain demographic groups
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1 -- depending on where they live and what have you. And we

2 need to address that. But let's -- I don't think anyone

3 is saying that we want to forget about what -- I mean,

4 we've gotten a good standard here. It's made a tremendous

5 difference. I think what we're saying here is that based

6 on the past (unintelligible), let's keep it where it's at.

7 But I don't think we want to measure into telling EPA use

8 another method (unintelligible).

9 We shouldn't even approach the fact of

10 saying that it's no longer -- that the standard is no

11 longer necessary because the standard's been a success.

12 DR. HOPKE: No. The standard has not been

13 (unintelligible). You took the gas -- the lead out of

14 gasoline -- out of the catalytic converters.

15 (WHEREIN, unintelligible due to multiple

16 people speaking at once.)

17 DR. HOPKE: -- because you knew that was

18 poisoning the air. I mean, the lead went before the

19 standards went down, but --

20 DR. KOSNETT: But Phil, the fact that you

21 still have this standard --

22 DR. HOPKE: No. It has nothing to do it.

23 DR. KOSNETT: There might be -- there could

24 be -- there -- if you wanted to recycle the battery -- you

25 want to be a battery smelter in the United States or
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1 whatever, you'd have to have tremendous air pollution

2 control.

3 DR. HOPKE: Right.

4 (WHEREIN, unintelligible due to multiple

5 people speaking at once.)

6 DR. HOPKE: But you can do the same thing

7 under Section 109 as a point source that happens. You do

8 NAAQS and you do residual risks. And if there's any more

9 risk turns out that we know that the money was for, you

10 have to do more than that.

11 DR. MURPHY: I would just clarify you still

12 have to meet the NAAQS. At any --

13 (WHEREIN, unintelligible due to multiple

14 people speaking at once.)

15 DR. MURPHY: Yes. In ambient air, you have

16 to meet the NAAQS. And in the residual risk program, when

17 they do risk assessments --

18 DR. HOPKE: No. You don't have to have the

19 NAAQS. You could eliminate the NAAQS tomorrow. But if

20 you had the scientific basis to do that, and I think we're

21 almost there.

22 (WHEREIN, unintelligible due to multiple

23 people speaking at once.)

24 DR. HOPKE: No. That's the point.

25 DR. KOSNETT: For any --
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1 DR. HOPKE: No. They go on and on and

2 forever.

3 DR. MURPHY: If I could just mention --

4 DR. HOPKE: We're still running with 188

5 hazardous confounds defined in 1970 by congress, and there

6 hasn't been a new hazardous pollutant produced by a

7 general company since -- in 42 years? Give me a break.

8 DR. WEITZMAN: I think carbons, Phil, were

9 eliminated as NAAQS.

10 DR. MURPHY: Yeah.

11 MS. WEGMAN: And you can get a hazard with

12 a high carbons with as NAAQS --

13 (WHEREIN, unintelligible due to multiple

14 people speaking at once.)

15 MS. WEGMAN: I mean, it is possible to do

16 it, if it were appropriate to do so.

17 DR. HOPKE: Well --

18 MS. WEGMAN: And just to be clear, it was a

19 1990 measure specifically eliminating NAAQS.

20 DR. HOPKE: Well, in the '70s -- there's a

21 few changes from '70 to '90, but their basic questions

22 remain consecutively.

23 MS. WEGMAN: But the list in the statute

24 came in, in 1990, the correct codes. But in any event, it

25 doesn't really matter. The only point is, we do have
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1 authority of two above the NAAQS, if that were

2 appropriate.

3 DR. HOPKE: I'm saying not now, but you

4 should be seriously looking at the next go-around if you

5 can get the (unintelligible).

6 MS. WEGMAN: All right. Well, we'll see

7 how that goes.

8 DR. FREY: Let's see, I think -- I almost

9 forgot who the speaker was before. So I know Michael

10 spoke, and then Susan and then Rich were in the queue.

11 DR. KORRICK: Okay. I don't think we're

12 completely in disagreement. Now, I think that if the big

13 picture issue is public health in the future, then

14 figuring out what the most important determinants of lead

15 exposure in kids are and how to best address those would

16 be first on the list. And that sort of incorporates

17 Cliff's first two points.

18 And then I think there's a third issue

19 here, which is that prioritizing components and their

20 relative public health importance is another big picture

21 issue, which I don't -- I don't know. I guess I didn't

22 think about it within the scope of what we're doing, but

23 -- but, no. I mean, if -- you know, if you asked me, it's

24 a professional word that the greatest risk of kid's health

25 today lead in air would never be on the list.
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1 So, I mean, I think -- I mean, I don't know

2 whether the NAAQS have changed with prior criteria

3 pollutants. But ingestion comes up, you know, from a

4 societal point of view. What are the things that most

5 impact the quality of children's lives. This isn't one of

6 them, but that's a huge charge to try to come up with the

7 priorities for research money and for resource allocation

8 if children's health is your first goal.

9 So I mean, that's a third issue, but I

10 think it's kind of beyond what we're doing today.

11 DR. FREY: Okay. Rich.

12 MR. POIROT: I've decided I'm too ignorant

13 about policy issues to ask the questions.

14 DR. FREY: Okay. Well, I think I'll --

15 just to maybe clarify, I don't think the panel was moving

16 in the direction of this review recommending revocation of

17 the lead NAAQS. I mean, maybe one way of looking at it is

18 that the lead NAAQS, in some ways, is at a pretty mature

19 state in this development.

20 And, I mean, we're kind of -- I guess from

21 the fact that in EPA's recommending not changing the

22 standard, we've gone through a significant process of

23 reviewing the science. And I guess the fact of the

24 evidential basis we're setting the standard hasn't changed

25 in a substantial way.
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1 That's not to say it couldn't change with

2 more focus efforts to collect relevant information. And a

3 number of panelist have pointed out that that seems to not

4 be happening in areas where it maybe could be helpful. So

5 it may not be the case that this is the final word on the

6 lead standard and that 1,000 years from now we'll have the

7 same standard. But I guess that's where we are right now.

8 Mike.

9 DR. RABINOWITZ: Would the chair serve, by

10 a show of hands, on actually bringing -- I just didn't

11 know the procedure, but would the chair be served? Would

12 the chair like to see a show of hands at some point during

13 the meeting whether or not -- how we rate on the question

14 on maintaining or revising the airborne standard for lead?

15 Or do you want them to read the comments?

16 DR. FREY: Yeah. That's a good question,

17 but I don't know that we vote on that, per se.

18 DR. RABINOWITZ: Okay.

19 DR. FREY: But I think it is -- in fact, we

20 knew in the sense that we do try to reach a consensus. So

21 I think the way I prefer to handle it is, if anyone

22 objects to the panel recommending -- to support EPA's

23 recommendations to advise the administrator of retaining

24 current standard, that ought to be brought up.

25 I don't think I -- my interpretation -- and
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1 I haven't actually heard anyone say that. I think we've

2 heard some discussion that kind of is broader and goes

3 beyond that particular question. And if I'm wrong, then

4 speak, by all means.

5 DR. HOPKE: Yeah, that's right.

6 DR. FREY: Yeah. So --

7 DR. HOPKE: I'm saying that we still have a

8 couple of important distributed sources of lead, aviation

9 gas and (unintelligible). Everything else beyond that

10 then -- we're never going to control the soil. And points

11 lessons were contributed through all other leads. So

12 let's start to recognize that and at least have a sensible

13 scientific discussion as to whether we continue on this

14 path forever (unintelligible).

15 DR. FREY: Yeah. And I think the -- yeah,

16 and that's really more of a policy than a science issue in

17 a sense, I think. But the -- I think --

18 DR. HOPKE: You know, under a broad charter

19 the CASAC has --

20 DR. FREY: Yes.

21 DR. HOPKE: -- we're in a position to say

22 to the administrator --

23 DR. FREY: Yeah.

24 DR. HOPKE: -- maybe it's time for you to

25 seriously think about moving on.
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1 DR. FREY: Right. And I think the resource

2 implications for the agency are maybe a factor there, but

3 -- and this is actually something I wanted to not discuss

4 today, but maybe tomorrow. Is there are a few items I

5 thought -- assuming that we don't need the full morning

6 tomorrow on secondary standard -- and if we do, that's

7 perfectly fine -- but I did want to also raise the issue

8 kind of more operationally of the process that we've gone

9 through in this review cycle, given that -- you know, Sean

10 made the comment that we still get surprised that the

11 policy assessment has come out the way it has.

12 And I think if we would have seen the

13 policy assessment a year or two ago, it would also have

14 been no big surprise. What does that say about the value

15 of going through this detailed, you know, third draft ISA

16 and -- and I think -- and, honestly, there is a value to

17 that. I think there is tremendous value, and I think this

18 morning you heard a lot of locutory comments about how the

19 lead ISA is going to be an extremely valuable document to

20 a scientific community.

21 On the other hand, you know, there's a lot

22 of time and effort that goes into that. In some sense,

23 the characteristic time of the change and the information

24 basis for the lead standard is much slower than the

25 five-year review cycle. And I think we're kind of caught
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1 in that. But by statute, we must review this standard

2 every five years. You know, ideally, maybe if we were to

3 review this standard every 10 years or 15 years. I don't

4 think we have that option.

5 But we might have the option of thinking

6 about, Well, what's the process. Because the ISA is not

7 mandated under the Clean Air Act. That's sort of a

8 construct that we use, both agency and us as CASAC. And

9 it works very well, I think, when we are in situations

10 where we need to recommend revisions to the standard. But

11 does it work well in situations where we don't need to

12 recommend revisions to the standard.

13 So I don't propose to have that discussion

14 right now, but maybe tomorrow we can talk a little bit

15 about that. Because I think if we can find some

16 efficiencies, it may be helpful to all involved.

17 MS. WEGMAN: Dr. Frey, if I could just add

18 one thing --

19 DR. FREY: Yeah.

20 MS. WEGMAN: -- for consideration tomorrow.

21 The ISA, per se, is not mandated by the law, but we are --

22 you and we are both a party to review air quality

23 criteria, and that's why we need to have the air quality

24 criteria documented in the ISA.

25 DR. FREY: Right.
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1 MS. WEGMAN: So we are required by law as

2 part of the five-year review to reviewing and considering

3 the air quality criteria. So we would need some

4 version --

5 DR. FREY: Oh, sure. Yeah. Yeah. No.

6 I'm --

7 MS. WEGMAN: I just wanted to clarify that.

8 (WHEREIN, unintelligible due to multiple

9 people speaking at once.)

10 DR. FREY: Yeah. Yeah. I mean, we need

11 something, but -- I think we talked a lot this afternoon

12 about the role for the lead NAAQS, and that was actually

13 something I was going to suggest we talk about and we had

14 covered that. I think looking toward the letter to the

15 administrator going beyond charge questions -- or

16 actually, it is implicit in some of our charge questions,

17 issues of data and research needs. That's something we

18 are, under our charter, tasked to advise the administrator

19 about.

20 And we've kind of touched on that. I would

21 encourage you, as I said earlier, to groups to make a full

22 venue to your group discussions. And we can always pull

23 out those into maybe a separate item in the letter to the

24 administrator on advice on research and data needs.

25 We already discussed a little bit about
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1 adverse consequences that are part of our charter to

2 address, and Dr. von Lindern will be the lead on drafting

3 some input on that. And we've heard some discussion on

4 multimedia issues, which reminded me, you know, as CASAC,

5 we also -- informally, at least -- would like to give some

6 thought to multimedia. And multimedia -- I'm sorry, not

7 multimedia, multipollutant.

8 And multipollutant may make much more sense

9 for things like asset to a knots or knots in ozone. And

10 that's something, as I understand in our agenda for the

11 ozone panel meeting this summer, we may actually have that

12 as an agenda item. I don't know that there's a clear role

13 for lead to be a multipollutant review along with other of

14 the existing criteria pollutants. And it's not obvious at

15 all that that makes sense.

16 But I just mention that as something that

17 the statutory CASAC is always interested in looking at

18 other opportunities to do things synergistically among

19 criteria pollutants. But I think here it's maybe more

20 than multimedia issue, and that then goes beyond the

21 NAAQS, even to other statutory authority besides even the

22 Clean Air Act.

23 So with those kinds of things to think

24 about plus the charge questions -- and I would recommend

25 all the groups do as much as they can while it's still
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1 fresh. Are there any kind of burning issues anyone wants

2 to raise before we break for the evening?

3 (No response.)

4 DR. FREY: Any questions? Clarifications

5 you need to add?

6 (No response.)

7 DR. FREY: Lydia or Deirdre, anything you

8 want to add?

9 MS. WEGMAN: Huh-uh.

10 DR. MURPHY: No. Thank you.

11 MS. WEGMAN: Thank you.

12 DR. FREY: All right. Let's see, let me

13 just review my own notes. So in sense, we've kind of

14 covered Chapter 4. We've had all the lead discussants

15 talk about Chapter 4. If there are any burning issues

16 with Chapter 4 that come up, we can continue tomorrow.

17 But otherwise, our main published agenda would be Chapters

18 5 and 6. And so we'll resume in the morning for that.

19 Any housekeeping issues?

20 MR. YEOW: No.

21 DR. FREY: Okay. So at this point, I think

22 -- officially we're not adjourning. We're just breaking

23 until tomorrow. So we will now recess until tomorrow.

24 (WHEREIN, the meeting was recessed at

25 5:37 p.m.)
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1 C E R T I F I C A T E

2

STATE OF MISSOURI )

3 ) ss.

COUNTY OF JEFFERSON )

4

5 I, Wanda L. Greenlee, a Certified Court Reporter,

6 CCR No. 1188, within and for the State of Missouri, do

7 hereby certify that the tape transcription in the

8 foregoing tape was transcribed to the best of my ability

9 and therefore reduced to typewriting under my direction;

10 that I am neither counsel for, related to, nor employed by

11 any of the parties to the action in which this tape was

12 taken, and further, that I am not a relative or employee

13 of any attorney or counsel employed by the parties

14 thereto, nor financially or otherwise interested in the

15 outcome of the action.

16

17

18 ______________________________

 Wanda L. Greenlee, CCR

19

20

21

22

23

24

25
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A

μg/dL 156:16

A&M 79:1

a.m 2:1 95:17,17

AA's 6:9

Aaron 2:2 4:15 5:3

5:6,18,21,25 11:7

24:16,19 25:21

39:19 40:18 72:21

155:15,17 157:16

AAS 242:23

ability 169:17

230:5 258:13,14

278:8

able 24:25 30:23

54:18 80:18 93:23

99:5 112:6 122:24

134:5 140:4

145:19 155:22

193:25 251:10

262:16

abscissa 142:2

absence 242:3

252:5

absolute 210:19

absolutely 8:12

71:15 72:6,7 84:1

98:24 210:9

253:10

abuse 110:1

academic 122:24

241:10

academics 6:23

Academy 55:10

156:6 222:2

acceptable 68:10

243:24

acceptance 63:22

73:1

accepted 53:20

121:20

access 101:16

194:21

accessible 30:8

accomplish 6:4

account 162:10

accumulate 102:9

243:1

accumulated 165:3

183:24 197:16

198:3 214:4

accumulation

197:22

accurate 59:12

108:5 230:11

251:7

accurately 54:24

achieve 74:19

achieved 131:8

243:5

achievement 108:2

108:4

acknowledge 2:10

37:2 55:6 73:1

251:10

acknowledged

250:7

acknowledgement

109:6 135:4

acknowledging

106:4 118:18

251:12

acquainted 11:15

acronym 94:24

act 2:16 16:14,19

19:9 21:7 164:21

165:9 185:11

202:18 254:6,13

274:7 276:22

acting 4:8,12 6:1

6:11

action 3:22 278:11

278:15

actionable 78:3

actions 228:22

active 70:24 136:23

206:24 262:9

actively 122:20

activity 17:7

219:16

actors 190:11

actual 69:24

148:21 149:1,4

227:3

acute 49:12 127:13

add 45:2 94:19

107:20 112:9

121:10 141:25

142:1 143:11

145:7 161:23

196:23 213:10

225:7 249:6

252:18 254:17

274:17 277:5,8

added 29:5 30:9,11

32:8,13 33:8,12

38:5 67:9,13

143:17 145:5

200:8

addition 27:5 65:12

73:8 83:14 84:5

96:2 163:11

177:24 219:5

additional 17:1

20:25 67:10 101:3

124:5 162:8,15

198:4 202:22

244:15 251:19

Additionally

167:19

additions 83:13

additive 66:15

128:4 135:24

additives 185:19

address 15:17

17:17 18:5,19

37:4 61:25 105:22

126:25 237:19

253:12 266:2

269:15 276:2

addressable 139:23

addressed 48:23

63:19 214:20

227:12

addresses 106:6

183:4,19

addressing 132:18

adds 148:25 221:5

adequacy 17:2

165:4 166:8,14

171:10 174:16

175:25 176:18

232:25 237:19

241:24 242:10

adequate 37:6

64:11,18 158:5

165:8 176:3

195:15,19

adequately 82:15

156:17 181:25

182:4 183:4

237:24 238:3

ADHD 33:11 50:22

121:2 135:20

136:23

adjacent 238:16

adjourning 277:22

adjust 128:23

129:4

adjusted 128:1

administrative

18:24

administrator 2:18

16:21,25 17:5,8

17:22 20:13 21:8

21:14 22:25 23:2

26:13 27:17 64:8

77:9 164:15,20

187:23 188:3,11

211:14 225:12

226:1,14 227:5

271:23 272:22

275:15,18,24

admit 183:3

adult 108:23 218:1

218:23 222:5

251:4

adults 42:14 52:23

137:18 138:14,17

228:21 229:3

258:1

advance 186:6

advanced 2:21

71:17

advantage 112:22

adverse 17:9 18:13

172:1 188:3

226:13 250:17

276:1

adversely 260:5

advice 2:18 4:20

7:10,11 20:9

22:18 34:5 59:11

60:15 77:8 88:1

111:19 115:19,21

115:21 164:19

189:2 275:24

advise 16:25 17:4,8

17:22 18:13 23:1

60:12 187:22

188:3 225:11

271:23 275:18

advising 17:23 18:7

22:25

advisors 7:3

advisory 1:8 2:4,13

2:16 4:4,17 7:17

9:15 16:13 20:6

21:6 40:15

advocate 7:22,25

advocating 109:8

affect 110:19

186:11 218:7

255:5,5

affiliation 13:16

14:1

afforded 166:15

171:10

afternoon 24:13

158:16 159:8

161:13 216:12

240:20 275:11

age 33:1 53:11 54:5

54:15 58:25

101:14 122:1,2,4

124:20 135:6

153:10,17,18

250:25 258:25

259:1,8

agencies 76:14

160:23 181:1

190:10,16

agency 1:7 2:24

4:21 6:5 7:19

8:11,19 9:2 10:1

10:14,16 12:12

14:6 18:17 26:8

59:4 66:8,10

67:19 73:16,19

74:12,18 75:12

83:8 91:12 102:12

104:24 105:21

164:19 183:5,6

185:7 186:11
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190:7 202:3

203:11 204:17

225:12 247:21

248:15 273:2

274:8

agency's 10:7 28:8

73:1

agenda 3:13,14

13:23 20:17,19,20

20:21 21:23 24:1

24:9 39:13 158:16

177:2,4 180:7

240:15 276:10,12

277:17

agent 44:1

ages 53:2

aggressive 20:20

21:23

ago 66:21 72:13

190:21 237:23

244:1 247:16

273:13

agree 46:8 53:15

54:17 57:17 69:5

70:1 79:16 80:7

83:6 91:18 98:24

99:5,18 107:18

112:12 114:19

128:14,16 137:14

144:25 150:15

181:1,6,8 182:6

182:21 183:1,10

188:18,20 189:19

190:13 199:13

209:11 211:3

221:14 222:18,20

233:4 239:24,25

246:15 255:20

260:23 265:6

agreed 20:2 197:14

236:6

agreement 42:3

78:18,20 79:4

agrees 113:1 195:7

agriculture 223:19

agricultures

219:14

ahead 13:24 56:9

56:25 95:14

127:21 149:17

212:6 240:14

265:4

aim 126:20

air 1:8 2:4 14:6

16:14,19,20,21

17:5 18:3 19:9

26:3,9,13 31:2,15

31:21 32:22,24

74:6,6 77:16

82:18,19 84:4

85:16 96:14 97:10

97:11,23 98:6,12

98:13 103:14,16

146:2 150:8,14,18

150:22 152:10,16

152:17 159:6,10

159:13,24 163:13

164:17,21,23

165:20,21 167:1

167:15,17,25,25

168:6,12,14,17

169:5,21 170:1,2

170:20 172:5,7

173:7,13,14,19,23

174:11 175:9

176:22 180:18

182:8 185:11,16

188:21 192:15,22

192:23 199:7,14

202:15,18,20

203:3 204:4

205:15 214:18

215:2 216:11

217:4,8,13 218:3

218:6,15,16 221:1

222:9,11 225:2

233:20 236:9,9

238:16,25 245:13

245:16 246:10

247:13,24 248:6

248:21 254:2,3,5

254:7,13,22 255:1

255:4,7,25 256:6

256:23 257:6,9,19

257:21 258:13

259:2,9 260:14

261:4,5,7,25

262:10 266:18

267:1,15 269:25

274:7,22,23 275:3

276:22

air-quality 146:1

212:21

air-related 31:16

32:23 167:21

168:10 169:10,17

170:1,12,21

173:23 175:24

air-to-blood 31:23

32:15,22 33:2

167:2,3 168:11

231:2

air-to-lead 238:12

airborne 75:5

79:11,12 215:2

219:1 220:17,18

221:5,7 256:8,10

264:11,12,21

271:14

aircraft 202:19,24

airport 75:10,19

94:15 182:11

201:6,8

airports 30:18 76:4

77:18 202:2 203:5

al 33:3 50:13,13

ALAD 42:9

alcohol 109:3,25

110:14,17,18

135:16

Allen 6:19 15:6,6

15:12,12 23:8,9

23:12 72:20,25

91:10 93:11 94:9

94:19 95:4,7

140:20,22,23

147:17,19 148:2

150:23 151:10,14

151:25 189:11

196:10 199:8

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Allenspark 15:11

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allow 126:1 151:5

allowed 73:20

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allows 218:17,20

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alternative 77:19

83:14 86:10

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174:11 175:10

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American 4:21

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amount 25:5 58:14

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analysis 70:17

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analyze 66:4

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Andersen 79:1

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Angeles 220:12,18

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animal 33:22 42:25

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anticipate 27:15

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anticipating 18:25

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antisocial 129:14

anxiety 114:7

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approve 19:14

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approximate

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AQCD 30:22

AQS 75:13

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area 9:24 41:6

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argue 18:11 195:17

argued 46:21

argument 129:2

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arguments 49:1

arithmetic 238:14

article 76:7,8

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ascertainment

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ascitic 149:22

Asia 136:15

Asian 88:4

aside 201:23

asked 5:25 8:2 34:7

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asking 112:25

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aspect 46:15 57:21

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aspects 57:15 70:23

113:20 163:25

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asphyxia 135:15

assertion 191:11

assess 53:2 65:19

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assessing 109:15

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assessment 2:9,9

19:7,8,8 20:13,23

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265:2 273:11,13

assessments 27:8

41:19 44:15 49:17

106:1 111:9

160:10 164:13

172:17 187:25

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asset 276:9

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associated 47:20,21

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assumed 153:4

assuming 176:25

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assumptions

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asthma 42:12 43:4

at-risk 36:24

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atmosphere 85:12

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atmospheric 84:8

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atmospherically-...

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atopic 35:20

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attached 98:6

attachment 201:20

attack 82:23

attainment 17:11

18:14 188:5 213:6

213:8

attempt 115:1

attempted 125:18

attendance 3:25

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attention 5:11 36:6

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114:23 120:4,14

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attention-related

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autoimmunity

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av-gas 76:8,19

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availability 77:20

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available 3:4 31:1

44:23 65:21 67:1

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avoid 227:19

awards 7:24

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babies 135:15

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background 29:5

31:11,11 39:24

148:4 175:1,4

224:21,21 247:2

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backing 219:12

bad 62:12 90:1

157:5 253:21

256:17

balance 9:6 12:6

balanced 9:9,12,16

balls 203:3

Baltimore 108:24

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baseballs 90:20

based 11:5 35:7,15

35:18 36:24 42:25

43:1 46:2 68:20

96:9,14 108:25

126:5 147:24

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184:14 186:17,18

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baseline 32:3

bases 210:8

basic 81:19 268:21

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basing 243:13

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battery 266:24,25

Bayley 153:5

234:16 239:25

bearings 223:8

beat 208:19

began 66:20

beginning 60:18

133:25 178:4

187:18 231:10

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behavior 49:15,17

49:20 51:1,5,13

59:21 112:24

113:14 119:5,13

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128:4,5,9 136:25

139:17 234:20

behavioral 34:9

36:6 46:15 51:24

54:1 128:8 129:14

behaviors 112:21

117:1 120:9,15

129:24 130:4

belabor 21:22

believe 8:12,15

43:4 48:3 55:13

55:25 62:12 63:6

147:4 213:14,17

221:6 244:1 253:2

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Bellinger 124:18

125:1

Bellinger's 52:14

153:1,3

beneficial 10:3

benefit 22:18 26:14

26:20 27:16,23

111:21 257:19

258:7

benefits 91:17

Benson 217:24

Bert 15:12

best 7:7 13:3 45:22

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126:6 128:14

139:19 190:21

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205:3,5 211:17

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bet 66:5 223:12

better 8:23 10:17

63:1,2 73:17

77:13 81:21 118:8

118:9,15,16 122:4

122:6 126:2

127:20 132:3,7

134:18 171:23

187:8 189:18

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208:17 249:12

253:21 254:11

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beverage 217:25

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beyond 12:1 19:18

20:10 62:3 65:3

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270:10 272:3,9

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bias 44:4,9 129:6

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big 23:1 50:25

82:12,15,24 84:15

91:2 101:18

104:24 105:23

108:6 113:14,25

114:14 115:8

118:1 138:9,9

142:23 179:21

210:1 219:24

221:18 269:12,20

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bigger 51:17 63:9

76:19 80:15 86:22

87:2 88:17 92:18

195:21 234:10

biggest 177:25

178:24 218:4

221:22 224:25

225:8

bind 120:7

binding 77:17

bioassessibility

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bioavailability

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bioavailable

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biokinetic 233:18
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Bob 93:1

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boiling 68:18

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bound 169:16,16

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bracket 87:8 169:6

brain 127:18

branch 27:7

breadth 16:8

break 51:18 72:12

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breaking 277:22

breakout 147:22

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brief 13:14 78:14

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briefly 16:12 24:20

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bright 7:1

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61:4,7 67:14 79:5

138:7 177:18

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bringing 36:18

39:8 57:5 78:2

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205:17 263:5

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brings 13:20 14:21

126:25 209:12

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broader 17:14

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broadly 262:10

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Brook 173:12

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41:5 65:6 94:11

116:4 132:10,23

134:14 145:10,14

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BROWN 98:22

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burden's 191:16

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209:14 277:1,15

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busy 12:21 25:6

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Cakir 163:12

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calendar 253:17

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call 7:13 39:1 75:17

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called 20:15 86:6

109:16 145:5

150:4 165:3

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Canada 247:16,18

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Canfield 14:8,8

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53:15 57:1 68:8

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153:5,19 190:24

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canning 222:10

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capture 75:5

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captured 97:10,21

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carbenes 178:14,15

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carbons 268:8,12

card 88:2

cardiovascular

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care 93:16

career 5:5 6:16,18

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careers 262:20

careful 56:1 83:9

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carefully 59:9

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Carolina 1:12 16:6

carry 84:6 90:11

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19:23,25 20:4,7,7

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causality 35:16

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46:19 58:24 59:3

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causals 126:10

causation 33:8,15

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cause 42:8 43:14

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causes 43:13,17

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causing 43:24,24

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caveat 111:2 183:2

caveats 182:23

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Cavender 159:17

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CCR 1:21,22 278:6

278:18

CDC 42:19 55:11

55:15,25 56:15,20

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cell 136:4

cells 54:14

censored 99:23

census 136:10

center 6:12 25:3

157:4,19

cerrusite 143:24

certain 28:25 43:17

64:20 69:4 84:17

93:4 116:16

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certainly 11:18

13:2 17:22 53:22

69:2 73:18 74:5

80:14 85:9 90:13

94:1 116:18 118:7

138:9 139:24

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162:9 178:3

186:10 187:25

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212:17 222:20

249:1 265:24

certainty 258:10

certified 3:23 75:13

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certify 278:7

cetera 192:18

chair 2:12 3:23

4:14 19:23 23:13

26:17 64:10,22

72:11 211:5

245:11 271:9,11

271:12

challenge 97:4

249:2 257:17

challenges 8:19

39:9 73:12 79:10

challenging 97:13

chance 44:4 99:17

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change 23:9 29:19

32:23,24 35:10

38:13 62:17 88:24

89:8 103:3 104:21

153:7,7,8 154:21

182:9,13 184:25

215:17 216:24

217:4 218:5,14

219:24 226:2

231:6 234:2,3,9

238:1 242:4

246:12 264:3,8

271:1 273:23

changed 28:18

38:18 39:6 46:16

89:10 197:22

204:19 218:15

253:4 270:2,24

changes 7:20 28:24

30:1 46:21 67:23

70:25 73:3,6

133:2,3 154:21

233:25 257:7

260:15 268:21

changing 28:19,21

64:3 101:15 102:4

136:11 217:5

234:21 238:7

264:7 270:21

chapter 30:11,14

31:12,13,18,18,25

32:14 33:4 34:5

36:18,19 37:14

38:1,12,13 39:24

39:25 41:1,5,11

41:11,24 45:18

46:19 48:23 49:16

49:18 51:18 54:25

60:19 63:6 72:17

73:2,6,6 75:4

78:12 81:9 83:11

84:22 86:5 94:11

94:12,14 95:20

96:1 99:12 102:19

103:14 105:11,15

108:11 121:25

126:25 128:2

130:20 131:19,22

132:2,7 133:14

134:18 135:19

140:11,18,18,20

141:19 145:1,10

146:25 149:16

150:2,3 154:3,9

154:12,14,21

155:3,3,4 175:2,6

175:12,12,12,21

176:5,5,14 177:6

177:13 182:13

198:24 199:3,7,7

199:12 208:10

209:12 211:6,12

211:16,25 212:8

212:12,12 214:16

226:22 227:23

228:2 229:9,20,21

230:9,13 234:12

235:11 236:7,16

236:19 238:5,18

238:22 240:6,11

240:16,19,22

245:1,10 251:21

277:14,15,16

chapters 29:16

30:1,2,4,5,6,13

33:16 84:22

106:12 154:7,17

158:21,23 175:12

176:5 177:6

228:10 236:17

277:17

characteristic

273:23

characteristics

85:8,19 126:9,12

203:24 204:1,5,6

205:14,25

characterization

167:1 175:3,7,15

175:17 176:8,10

200:16

characterize

172:18

characterized

92:14 169:15

172:10 175:8

192:19 199:16

231:3,18 232:1,21

233:10,14

characterizing

152:19 232:9

251:14

charge 20:12,25

21:3,13,24 22:4

24:6 39:13,22

40:9 58:21 60:23

61:7 62:25 67:25

68:4 72:11,15

80:4 94:5 95:14

95:19 105:12

111:23 115:20

126:19,20 155:8

155:12,13 157:15

164:4 174:24,25

175:14,21 199:12

203:20 204:12,15

206:18 208:15

225:18 226:4

228:9 230:18

231:1,15 232:14

232:16,18 233:8
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244:23 245:6

270:6 275:15,16

276:24

chart 98:8 119:11

206:4

charter 2:12,17

13:20 16:12,16,17

17:17,20 18:7,12

18:20 19:10,15,16

19:19,25 77:5,8

77:14 78:1,6

187:17 188:3,15

272:18 275:18

276:1

chartered 16:14

20:15

chastise 102:11

check 57:16 157:10

213:19 239:23

checklist 114:12

chelation 127:12

127:14,17,19,21

Chemical 15:21

156:1,4

chemicals 148:7

chemistry 151:21

Cheng 153:15

Chestfield 148:9

chewed 196:4

chewing 129:19

chief 6:8 27:7 196:4

child 15:18 127:20

127:25 225:1

child's 33:1 234:21

childhood 137:14

138:14 139:4,5

167:9 250:22

children 32:21

34:24 42:14 50:7

50:15 52:17,23

66:22 113:13

122:1,4 135:12,21

136:10 137:18

150:20 153:17

166:24 168:5,10

180:16 186:2

214:5 217:22

224:15 228:22

229:4 231:17

247:8,11 249:11

258:15 260:5

265:17

children's 136:14

167:16 168:1,2,12

168:15 249:17

250:24 270:5,8

Chinese 88:4

chip 206:6

chips 209:23

chloride 143:17

chloroformic

178:13,15,17

choice 106:24

107:22

choices 60:7 233:18

choose 17:21

chose 32:19

chosen 107:22,24

118:19

Chris 3:14 5:20

14:2 16:4 25:15

25:19 41:1 78:10

92:1 101:5 147:16

157:11 159:7

177:11 199:11

205:5 223:10

Chris's 26:17

181:11

Christopher 2:11

4:8,12,14 5:18,22

Chrome 81:18

chronic 103:6

chunks 113:25

221:18

circle 126:18

131:21

circumstance 44:2

circumstances

168:15

citations 189:7

cite 142:11

cited 180:3 210:3

215:3 216:16

cites 101:2

cities 190:6 264:5

citing 137:4

city 190:5 261:8

civil 12:8 14:3

15:13 16:2,5

61:22

CL 146:18

claim 257:8 258:13

260:15

clarification

176:21 186:25

229:8 236:3

Clarifications

277:4

clarified 31:14

38:10 148:22

clarify 30:15 48:8

75:9 88:20 127:3

131:15 137:2

186:15 197:25

212:18,24 215:20

229:4 238:21

267:11 270:15

275:7

clarifying 3:10,17

24:11 39:16

134:11 155:14,18

158:25

clarity 99:11

230:16 233:3

Clarkson 15:22

class 125:10 126:3

classification 36:23

60:7 68:10,10

Clayton 217:24

clean 1:8 2:4 16:14

16:19 19:9 112:25

129:18 164:21

185:11 202:18

213:7 254:13

274:7 276:22

cleaned 262:14

cleaner 81:21

clear 41:22,22 44:8

45:23,25 47:7,16

51:22 59:7,12,24

69:12,17 73:2

97:14 108:13

118:4 120:17

121:5 141:16

153:7 154:1

181:25 182:5

199:24 202:23

205:13 213:20

229:24 230:17

231:5,6 233:4,23

236:1 244:10

261:9 265:1

268:18 276:12

clearance 47:4

clearer 150:3

clearly 47:25 59:17

78:20 106:14

124:7 125:24

154:11 199:16

201:3 232:22

233:20 234:10

236:19,21 254:20

259:23

Cleveland 109:19

cleverly 262:5

Cliff 16:1 80:9 90:4

199:2 263:2

Cliff's 269:17

clinical 14:14 121:3

150:17 195:2

clinician 55:9

clinicians 55:13

close 42:4 72:7

79:20 146:14,24

155:11 161:10

192:16 206:9

208:3 216:3

closed 227:10,18

closed-up 227:15

closely 6:17 34:10

116:19

closer 97:16 121:14

207:9 222:22

closet 193:6

closure 22:20 94:4

clusters 113:14

co-authors 70:20

co-located 31:6

co-panel 232:15

co-relations 89:11

coaches 7:3

coarse 73:10 81:22

81:24 90:22,25

COB 188:22

cocaine 135:17

code 12:8 82:22

256:16

codes 268:24

coefficients 31:8

89:10,14

coffee 236:15

cognition 108:24

cognitive 34:23

55:12 123:22

168:2 236:8

coherent 29:8

cohort 109:20

110:14 153:16

collaboration

190:14

colleague 29:14

colleagues 26:3

41:17 44:8 52:2

65:1 99:17 101:24

122:8 150:1

234:18 240:4

collect 66:4 86:7

93:3,9 98:8

187:24 271:2

collected 75:21

94:15 187:14

collecting 83:15

84:12 237:18

collection 11:3 73:9

84:16 93:5 246:20

collective 265:12

collectors 95:2

collects 86:2,8,9

color 149:4

Colorado 14:15,17

15:11

Columbia 15:19

column 36:10,13

36:13

combination 90:22

170:5 210:16

combine 211:16

combined 111:16

come 3:18 19:17

42:18 43:23 54:18

56:2 57:10 70:4

72:7 81:20 91:16
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128:19 132:13

133:23 141:1

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184:4,5,19 189:8

197:20 202:13

203:11 223:16

225:24 234:12

242:21 245:2

248:2 259:2 270:6

273:11 277:16

comes 42:13 43:11

50:3 84:22 87:19

87:20 88:24 93:13

103:13 130:17

131:20 137:15

141:22 178:12

197:7,19 202:1,2

207:1 221:17

224:14 235:11

254:3 270:3

comfortable 59:19

59:25 68:19 86:15

189:6 252:6

comforting 184:23

coming 61:19

136:15 195:10

201:7 207:4,14

238:22 247:20

260:7 265:12

commend 65:4

95:25 105:21

comment 11:16

12:5 18:22 20:1

24:4,8,16 37:23

52:3,4 53:14 56:7

60:9 63:1,14 64:6

77:3 87:1 94:9

98:16 101:5 102:2

111:5 117:5

119:25 121:19

133:13 137:8

145:24 155:15,22

156:21 158:18

160:13,20 164:22

175:15 177:2

180:8 191:13

194:8 195:23,24

198:18 200:4

203:14,22 212:6

213:20 220:5

227:13 228:17

240:8 247:15

251:7,19 252:5

258:20 261:20

273:10

commenters 24:5

158:19

commenting 71:2

179:24 216:9

comments 3:8 11:8

11:20,20,21 12:11

13:9 22:1 23:22

24:11,12 25:7

27:14,16,20 28:15

28:22 29:6,22

30:4 32:5,18 34:4

36:16 37:3 38:14

39:8,14,16,19

40:4,11 41:4

46:11 53:16 54:16

61:4 63:4,12,18

63:19,21 64:3

65:1 67:9,16,24

73:7 78:9 79:23

83:7,8 88:1 89:9

98:19 99:9,17

101:20,24 102:23

102:25 104:10

105:8 106:9

107:19 108:1

115:13 117:6,11

118:3,7 121:11

130:20 131:11

134:23 139:24

140:10 145:4

149:14,16 154:6

154:14,20 155:18

155:25 157:24

158:5,25 159:1

162:3,3,6,7,8,12

162:14,15 181:23

182:17,22 183:5

187:15 189:9

197:19 198:24

204:11 207:22

208:18 211:5,13

228:13 230:1

240:10 244:21

248:5 251:20

252:1 271:15

273:18

commercial 214:11

commission 26:6

88:25 180:19

commissioned

226:25

commissions 173:2

commitment 5:12

204:23

committed/requi...

132:18

committee 1:9 2:5

2:13,16 16:13

21:7 23:16 40:15

42:19 197:2

committees 5:12

11:22

common 70:16

168:20 233:16

234:3

communicate

155:15,17

communicated

154:11 199:17

232:22 249:25

communication

40:14 233:3

communities 97:1

98:25 99:2

community 98:12

180:20 273:20

company 268:7

comparable 59:10

169:8

compare 31:5 59:8

181:12 193:25

238:15

compared 55:7

150:4 153:18

236:21 245:24

246:5

compares 34:19

comparing 30:19

34:16 78:14,17

comparison 34:15

78:25 137:16

comparisons 53:4

138:13,23 140:8

141:8

compartments

100:23 150:12

compelled 105:3

compelling 128:7

compensation

121:23 122:10

123:7 125:24

compensatory

125:25

complained 65:23

184:3

complete 73:17

160:13 226:3

229:22 230:17,25

completed 3:24

161:7 165:1

168:21

completely 79:16

80:24 143:18

194:6,9,12 210:17

221:15 257:17

259:6 269:12

complex 19:22

complexes 143:20

complexities 109:7

131:6 165:20

170:17

complexity 54:19

230:4

compliance 4:1

complicated 53:5,9

105:22 126:10

complicates 127:18

166:7

complicating 98:3

compliment 69:2

component 88:12

108:19 218:5

225:25 254:22

components 111:15

129:15 269:19

componsitionality

54:20

composition

151:20 181:22

256:19,24

compound 216:22

260:20

compounded 109:2

comprehensive

29:8 55:20

comprehensively

238:4

compress 100:11

compression

100:13

computer 144:5

concentrate 150:8

concentration

72:18 94:15 142:3

144:11,12 172:8

200:18 210:16

217:4,7 221:2,6,7

231:24 233:17

264:22

concentration-de...

144:10

concentration-re...

231:16 243:7

concentrations

17:6 18:3 31:3

32:3 33:19 38:8

47:20 51:20 84:4

97:12 125:17

141:4,5,16 142:19

143:23 144:9

146:2,3 148:4,7

148:24 149:7

150:5,8,14 152:11

152:16,17 166:4

167:15 169:21

170:2 173:8,9,11

173:13,20 174:5

174:11 175:9

178:3 199:14

201:2 214:23

215:23 216:11,13

217:9 218:15,16

220:13,17,18

245:14

concept 84:6,24

85:24 120:23
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concepts 61:19

concern 42:21

49:12 55:16 106:1

113:17 129:22

147:11 180:11

191:3 200:24

221:11

concerned 81:9

122:21 123:4

132:22 209:22

221:12

concerns 67:13,15

145:6 192:20

205:22 230:20

concisely 236:21

conclude 35:14

170:4 203:12

237:12

concluded 34:21

165:2,7,13 169:10

170:8 172:15

concludes 42:7

75:2 237:10

concluding 99:15

246:19

conclusion 75:7

100:14 124:25

164:7 174:19

176:2 183:8,10

244:5 245:4

conclusions 29:18

34:1,16,17,18

35:1 55:7 99:24

102:21 111:12

164:10 167:17

170:4 171:15,17

174:3 175:23

176:17,18 185:2

236:20,23 241:17

241:22,23 242:10

245:22 246:3

conclusive 97:19

concordance

155:13

concur 55:2 65:1,2

101:24 208:1

240:3 245:5

concurrent 52:5,6

52:12,19

condensation 230:9

234:14

conditions 35:21

83:22 93:4 135:12

169:8 172:10

173:14

conduct 2:8 114:20

114:22 115:11

120:5 128:10

conducted 2:21,24

169:5 198:5

confidence 61:10

61:13 62:3 197:23

confident 230:6

confirm 18:25

conflict 4:3

confound 59:23

125:7 128:25

129:6

confounded 123:16

129:25 130:5

confounder 129:22

confounding 33:7

33:13 44:4,9

50:24

confounds 268:5

confused 114:20

224:13 258:8

confusing 238:10

confusion 57:22

62:16 100:19

148:25 199:22

213:5

congratulate 2:11

229:18 230:10

congress 16:17

262:5 268:5

connection 152:10

172:7

connotatively

218:20

conscious 44:5

consecutively

111:16 268:22

consensus 68:4

69:11,22 70:2,20

71:7 271:20

consent 60:4 252:6

consequence

226:11

consequences

186:5 188:12,21

243:25 276:1

consequential

41:13

consider 6:24

27:19 64:22 98:2

98:19 101:6 113:6

115:4 117:8,12

132:4 142:23

155:7 168:4 170:9

170:18 174:20

175:7 234:1 244:6

257:13

considerable

137:24

consideration

28:14 166:7

170:11,15 174:17

204:18 228:12

274:20

considerations

44:15 56:17 164:1

166:19,20 168:19

171:14,14,18

172:14 175:22

176:16

considered 35:19

44:3 83:21 153:6

164:14 173:22

183:20 186:6

198:10 209:21

215:1 231:3,18

233:10 235:5

251:3 259:7,9,10

considering 29:20

168:24 171:4

275:2

considers 134:10

consistence 58:13

consistency 36:17

54:21 58:9 89:12

193:24

consistent 2:19

6:16 32:6 36:17

45:6 46:10 50:3

54:23 55:4 75:1

100:25 130:19

139:1 167:22

169:12 170:14

238:17

consistently 109:21

128:1

constant 217:6

221:3

constitute 203:7

constrained 56:18

constraint 77:17

construct 114:17

117:2 274:8

constructed 56:12

Construction 16:5

constructs 34:9

111:24

consultations 7:10

10:19

consumer 96:2,5,7

96:10 180:19

consuming 72:15

consumption 65:19

66:12,19

contact 24:16

39:19

contain 209:21

contained 215:14

containers 220:3

contaminated

259:14

contamination

256:10 259:12

content 220:24

230:21,21,24

contents 174:24

context 18:1,6,22

29:10 31:10 58:24

59:4,5 62:6 64:19

71:1 74:1 96:20

110:17,18 116:20

118:4 127:6 175:3

175:19 176:12

179:11,22 196:15

212:17 231:5,7

232:9 233:11

235:23 249:9

252:16 261:24

continue 73:19

77:3 124:13

131:19 206:12

240:16 272:13

277:16

continued 139:22

continues 102:8

166:23 171:21

172:3,9 173:21

242:25

continuous 119:6

continuously

114:12

continuum 260:4

contractors 6:23

contradicts 242:25

contrast 238:15,16

contrasted 236:21

contribute 202:19

contributed 76:4

166:4 173:19

222:6,7 272:11

contributes 165:22

165:25 167:2

169:19

contributing 72:19

168:17 263:22

contribution 17:5

18:3 30:15 31:16

101:15 214:18

228:20 263:18

contributions

53:11 217:13

contributor 127:25

control 163:17

186:1 188:22

194:15,20 230:14

244:19 261:16

267:2 272:10

controlled 58:5

70:16

controlling 43:5

controls 82:16

143:8

convene 2:5

convenes 2:1

convenient 205:20

conventional

259:20
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convergence 84:16

converging 89:19

conversation 19:18

conversations 9:22

converters 180:13

266:14

convey 60:10,15

183:11 211:14

conveyed 13:2 80:4

183:13,14 184:17

184:25

conveying 183:25

convinced 89:13

122:25 140:7

258:16

cooperation 77:13

coordinator 154:14

cop 250:6

copper 181:15

copy 40:17,19

core 113:24

Cornell 14:8

coronary 35:7

correct 36:21 48:12

52:7 80:14 260:7

268:24

corrected 61:17

62:23 130:16

correctly 80:1

185:18 232:9

correlated 87:5

113:16

correlation 31:8

87:3,12,18

Corresponding

150:5

Cory-Slechta 15:8

15:8 51:10,12

55:14 122:17

123:8 125:6

131:23 132:1

138:11 140:1,16

212:10 241:3,8

255:15 258:21

263:3,12,14

cost 181:14,19

council 3:6 5:13

26:4

counsel 254:10

278:10,13

count 264:16

counter-argume...

49:2

counterpoint 92:24

counties 173:6

countries 96:19

178:5 219:8

country 12:3,14

65:6 102:10 179:6

190:22 265:17,19

counts 58:12

COUNTY 278:3

couple 5:6 11:7

23:6 56:5 78:13

83:16 100:18

112:17 134:24

145:3,3 155:20

158:18 162:16

177:16 182:22

187:16 192:6,9

207:16 215:19,20

233:24 237:1,9

241:11 242:12

249:10 272:8

coupled 123:12

220:25

course 3:11 12:20

18:2 25:19,21

61:6,11 69:25

95:11 96:3 160:5

161:13 180:23

185:4 191:16

201:10 223:13

257:2 258:22

Court 1:21 278:5

cover 3:14 30:2

90:13 155:17

158:21,23 161:21

161:22 163:22

covered 41:1

155:16 156:14

233:21 275:14

277:14

create 28:11 33:3

65:5

created 45:7

152:20

creates 257:9

creatinine 47:4

credibility 8:11

credible 44:4

credit 178:21 190:9

creep 256:4

criteria 6:21 12:2

16:18,22 68:21,23

69:10,10 70:23

82:19 106:22

130:9 210:23

212:21 220:4

254:14 262:4,20

262:21 270:2

274:23,24 275:3

276:14,19

critical 29:23 33:5

102:13 106:11,20

106:25 135:5

146:16,22 151:3,4

174:11 255:23

261:12,14

critically 21:3

criticism 141:13

critique 33:10

236:11

crops 222:12

cross-comparison

56:16

cross-references

30:9,12

cross-sectional

50:21 108:14

235:16

crossed 25:12

crystal 223:13

CS 81:25

CSM 87:4

cubic 264:12

culminated 241:1

culmination 23:5

cumulative 135:6

curiosity 218:7

curious 79:4,24

87:10

current 57:3 68:9

96:16 150:22

166:8,15 168:17

168:25 169:6,8

170:4,7,9,22

171:10 172:4,11

173:3,6,7,9,15,18

173:24,25 174:16

174:20 175:5,19

176:1,2,13,19

179:3 182:7,15

194:6 209:19

220:17 232:4,25

233:12 241:25

242:10 244:6

245:14,20,24

246:16 249:19

252:7 258:14

271:24

currently 74:13

76:10 147:2

166:12 171:7

174:3 232:24

curtail 185:24

curtailed 187:4

curve 100:20 168:9

243:8 262:25

cut 33:24 69:12

74:15,19 79:25

81:9 82:4,5 88:17

89:20 92:15,20

93:2,14,17,19

126:16 193:22

205:24 206:2,3,16

211:23

cuts 31:7 95:8

cutting 82:4 114:4

237:17

cycle 22:16 73:18

77:11 199:23

273:9,25

cycling 177:21

179:13

D

daily 224:24

dairy 223:5

damaging 186:2

darn 161:10

data 37:18 44:19

44:20,23,25 45:16

45:17 46:2,7

47:23,25 57:15

58:11 66:4,16

75:10,13,16,21

76:1 89:14 98:5

98:19 99:22,23

100:3,4 101:1

102:12 104:12

106:3 110:12

136:9 137:6

146:13,18,22

147:20,23 148:9

148:12,17,19

149:13 165:14

169:22 184:12,12

187:24 189:12,16

192:16,22 193:24

194:1 197:12,12

198:22 200:2

201:7,13,16,17,20

202:1,2 203:17

207:17 212:1,2,19

213:4,9,10,14,15

213:15 214:4

215:7 216:6 217:6

223:12 224:1

225:12 228:11

231:7,25 232:4

233:14,15 234:16

235:2 236:20,22

236:25 237:18,20

237:20 246:20

250:19,24 253:20

259:17 265:13

275:17,24

database 183:17

dates 201:7 210:11

Davidson 16:1,1

72:19 78:9,10

80:11 92:1 177:7

177:9,10 180:1,7

181:3 183:1 185:5

185:18 199:5

220:7 222:1 263:7

263:11,13 264:9

Davidson's 189:25

263:4

day 6:1 13:22 20:10

20:11 133:5

218:23 222:14

255:17
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223:1

deal 46:13,14 67:11

67:21 84:15

104:25 112:3

dealing 120:24

237:22

deals 61:13,18

211:12 224:12

dealt 61:12 134:25

143:16 235:17

255:9

Deb 249:6

debatable 106:10

debate 107:2,17

120:2

Debbie 42:20 51:9

56:5 122:16

249:13 265:25

Deborah 15:8

131:23,24 140:13

154:17 212:8,12

241:3,7 245:6,25

252:10 258:19

261:19 263:1

Dec 156:6

decade 76:14

decades 29:12

180:23 185:9

186:17 221:10

decide 23:13 70:18

84:2

decided 270:12

deciliter 165:11

220:20 242:17

247:23 258:18

decision 60:12,14

63:21 67:2 103:17

111:14 160:15,23

178:10 182:1

183:12 184:7,24

197:23 198:1,17

201:22 227:7

249:22

decisions 46:2

59:16 67:23

106:18

declamation 65:7

decline 32:2

declines 96:17

97:25

decrease 100:14

182:16 215:2

221:2

decreased 47:21

171:22

decreases 35:21

96:18 100:9

decreasing 221:8

decrements 168:10

231:17 247:20

deem 206:15

deemed 95:9

deep 82:22

defeats 197:15

defects 35:13

Defense 155:25

156:4

defensible 68:11,12

defer 65:2

define 186:9

defined 106:24

208:13 268:5

defining 86:2 210:5

definitely 5:13,15

136:23 155:7,12

187:22 211:13,16

definition 88:13,13

88:18 193:19

definitions 88:11

definitive 92:17

degeneration

243:14

degrees 24:18

120:6

Deirdre 159:16

172:24 218:22

246:18 277:7

Delaware 15:14

delayed 36:3

deleterious 135:23

deliberate 115:19

deliberations 2:14

2:20,23 3:3 40:15

delighted 23:22

delineation 132:3

deliver 24:2

demographic

265:25

demography

136:12

demonstrate 33:1

demonstrated

243:8 249:20

Department 14:2

14:10,11,16 15:1

15:4,13,21 16:2,5

155:25 156:4

Departments 15:24

dependent 58:24

69:10 84:18

depending 84:13

91:1 101:13

108:19 138:22

225:24 266:1

depicts 111:15

deploy 193:16

deposited 79:12

204:7 205:16

215:8 221:13

depositing 79:18

151:16

deposition 80:20

80:24 81:11,14

85:13 90:9 91:23

149:22 150:9

152:11,15 171:21

172:5 173:10

196:18 222:12

deposition-base

90:5

depositional 255:3

deprivation 131:5

depth 16:7 152:5

deputy 4:9,11,16

26:12

derive 213:3

derived 169:13

222:16 237:9

describe 17:3 54:19

55:18

described 33:21

36:7,12 175:2

202:25

describes 99:19

212:21

describing 200:3

description 73:9

96:22 99:13

108:22 163:24

208:16

descriptions 104:9

deserves 210:23

design 33:6,10

108:12,16,19

201:16 208:24,25

210:5 212:3

213:23

designated 2:3

39:20 40:2,18

140:21

designed 262:5

designs 92:12

237:15

desirability 190:25

desirable 84:18

desired 205:14

Despite 61:3

despondent 232:7

detail 5:11 28:17

28:20 31:3 33:21

41:5 71:24 251:11

detailed 22:24 36:7

58:15 189:3

198:12 273:15

details 30:3 33:8

39:7 48:25

deteriorating 184:7

determinants

269:14

determination

34:25 35:18 36:9

36:12 38:15 44:19

44:24 57:21 58:24

59:3 68:23 69:12

141:21

determinations

29:25 34:2 35:4

35:12 36:5 38:10

38:17,23 120:2

determine 42:5

85:6 133:6

determined 4:2

determiner 128:24

determining

164:15

develop 45:3 67:22

160:14 194:17

196:16 198:2

216:20 248:24

developed 65:24

86:10 95:2 167:21

168:21 265:19

developer 221:17

developing 6:20

20:11 161:24

172:17 214:10

development 10:14

26:1,3,9 28:3,5

36:3 164:18

270:19

developmental

33:14 36:1 126:1

250:17

develops 27:7

deviation 100:2

devoted 12:21

DFO 2:3,25

diagnosis 54:21

119:6

diagnostic 114:13

114:18 115:9

diagram 63:8,10

diagrams 63:5

dialogue 9:1

diameter 84:13

die 214:19

diet 101:14 133:4

217:16 218:13,24

221:22 222:3,5,15

222:20,25 223:13

223:20 225:2,8

228:21 246:9

247:25

dietary 218:15

264:7

Dietrich 153:15

difference 8:15

53:16 69:15

114:11 138:21,21

152:1 172:23
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differences 31:14

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204:9

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10:11,13 29:16

30:16 31:6 32:10

37:18,24 49:19

52:20,25 53:2

57:8,11 59:3

74:21,22 78:15

80:24 86:11,19

87:7,8,9 90:3 93:6

95:10 97:1 100:11

101:16 110:17

111:13,15 113:23

120:6 121:3 123:2

124:7 125:5

133:21,21 136:16

136:18 138:12,13

138:22 145:20

149:3,4,7,8

151:19 152:21

165:20 169:1

181:19 190:15

193:22 194:3

197:24 198:21,22

204:6 216:9 219:7

220:10 222:13

235:2 237:7

238:22 239:2

243:3 248:8

253:21 255:22

264:21

differently 70:5

240:1

difficult 7:4 74:11

79:17 123:17

124:2 125:18

132:13 146:10

178:8 203:6

219:16 222:10

229:23 234:23

243:9,14 249:14

difficulties 174:8

difficulty 73:13

digging 259:6

dimension 57:10

59:1 115:22

dimensions 57:8,9

diminish 129:4

135:25

dinner 228:2

direction 82:3

84:14 126:22

193:11 195:2

204:24 206:13

270:16 278:9

directions 207:24

directly 13:2 39:21

66:23 84:19 101:7

112:3 140:5

173:13 238:9

director 4:7,8,9,11

4:13,16 5:6,18 6:2

6:11,11 25:2

159:9

directors 10:11,16

disagree 69:13

112:12 187:2

disagreement 79:3

114:3 180:4

269:12

disappeared 220:1

220:1

discharger 144:17

discharging 144:19

disconnect 146:6

discuss 22:2,4

27:13 39:13,23

60:8 77:5,8,22

134:23 140:22

273:3

discussant 20:25

40:1,12 72:20

95:22 105:17

131:23 140:21

177:7 199:2,9

212:8,12 244:23

249:3

discussants 21:1

40:2,8 58:19

60:23 72:19 77:3

80:5 89:18 94:6

95:21 105:18

140:18 154:7,16

177:7 199:8

225:18 229:10,12

240:17 241:2

277:14

discussed 11:24

21:5,21 59:7

74:16 109:4

121:12 150:2

211:11 275:25

discusses 144:3

discussing 25:10

102:20 127:10

151:3 172:4 255:1

discussion 3:11,12

3:15 13:22 17:14

18:9,18,24 19:3

20:22 21:9 22:21

24:6 29:22 31:1

31:16,19,21 32:14

33:12 39:22 40:11

46:18 49:3,4,5

54:7 56:24 60:20

65:3 70:22 71:12

76:15 77:15 78:14

80:5 82:19 83:13

89:1 92:25 95:19

96:4,15 98:11

99:4 104:20

121:24 126:17,21

132:5,10 134:13

139:19,20 144:8

146:12,24 157:24

158:20 159:20

177:4 179:21,24

183:7 193:12

197:20 211:11,17

214:15 216:12

220:6 225:9

226:22 228:2,8,19

235:7,10 240:5,11

244:3,13 248:21

250:8 252:21

272:2,13 274:13

276:3

discussions 2:22

3:21 12:9 19:20

20:24 24:13 28:7

58:20 116:5 136:6

177:1 211:18

252:19 275:22

disease 35:7

dismiss 128:5

disorder 128:9

129:14,15

dispersed 200:22

263:8

displacement

226:12

display 201:21

disposal 65:20

66:12,19

disposition 185:4

dissipate 153:4

dissociate 143:18

dissolution 101:15

dissonant 251:14

distinct 174:18

distinction 20:3,5

63:22 83:23

106:16 108:13

125:23 129:7

134:12 205:13

247:1

distinguishing

106:15,18

distract 214:1

distracting 231:12

distributed 272:8

distributing 262:10

distribution 83:18

83:19 84:3 99:25

182:9 191:1

distributions 31:14

81:22 165:23

210:18 258:25

disturbed 177:21

divert 195:5

divide 107:8

181:14

divided 181:18

division 14:9,13

25:3 159:9,11,13

159:14 181:17

238:15

Doctor 138:6

document 7:18

12:15 26:2 28:12

28:12,21 29:1,8

29:16,20 30:9

33:21 37:4 41:8

42:7,20,23 43:18

51:4,18 55:19

56:6,19,21 57:18

58:7 59:7 61:10

64:11,20 65:5,8

65:21 66:8,12,25

74:24 75:20 92:6

94:13 102:22

103:5,22 104:4,20

106:17 107:16

109:8,15 110:21

111:10 117:24

121:12,16 127:10

129:10 145:1

149:6 150:3,4

168:23 174:25

177:15 181:23

183:3,14 184:16

186:9,9 189:8

198:2 201:19

203:1 209:6

210:10 211:6

231:22 236:1

242:13 250:2

273:19

documentation

257:4

documented 34:1

274:24

documents 12:1,2

19:14,16,18 21:5

27:23 36:25 57:3

62:20 117:10

128:24 130:17

160:9,12 181:7

182:3 209:7

262:21,21

DoD 156:7,8,13,18

doing 7:5 23:5

26:19 40:8 76:18

77:25 80:23 86:14

103:11 105:21

125:9 132:24

190:21 219:22,23
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237:14 242:22

244:20 255:2,4,22

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domain 58:18

door 72:4

dosages 152:2

dose 47:15 49:18

50:18,18 53:5,6

54:16 58:25 62:16

149:1

dose-response

168:9

doses 47:17 49:11

59:22,23 62:11,18

62:19

doubt 62:3

downgrade 46:18

downgraded

109:19,22

Dr 2:11 4:6,8,12,14

6:19 11:16,18

12:17 13:9,25

14:2,8,10,13,18

14:21,25 15:3,8

15:10,12,15,18,20

15:23 16:1,4 23:8

23:9,11,12,21,25

24:16,20,21,22,24

25:1 29:2,17 39:3

39:3,4 40:1,2,3,21

40:22,23,25 41:8

42:16 45:2,8,9,11

45:12,13,24 46:1

46:9,12 47:9,11

48:4,7,8,10,12,14

48:15,16 49:25

50:1 51:10,11,12

51:14 52:3,10,11

52:14,17,19 53:15

54:17 55:2,14,24

56:7,9,10,25 57:1

57:5,20 58:17

59:14,18 60:2,24

60:25 63:13 64:6

64:13,14,16,17,23

64:24,25 65:2,3

67:6,7,8,17,24

68:2,6,8,25 69:1,8

69:14,18,20 70:21

71:13,15,16,18,21

72:6 77:2 78:9,10

79:24 80:11 81:5

81:6,7 83:3,6 88:8

88:21 89:16 90:7

90:17,18,21,24

91:14,25 92:1,10

92:11 94:3,9,18

94:19,21,23,25

95:5,12,18,22,23

95:25 97:18 98:18

98:24 99:10,10,11

101:21,22,23

102:24 103:1

104:7,15 105:6,10

105:14,20 107:19

112:13,13,14,15

113:10,11,13

115:2,7,13,18,23

115:25 116:1,3,24

117:5,13,17,19,20

117:25 118:8,10

118:12,13,22,25

119:1,3,4,7,8,16

119:17,18,20,23

120:11,12,18

121:6,7,8,10,14

121:15 122:17

123:6,8,23,25

124:3,4,16,22,23

124:25 125:3,4,6

125:22 126:16,24

127:23 128:16,18

128:20,21 129:13

129:17,18,21

130:6,8,9,12,20

130:22,23,25

131:13,17,18

132:1 133:15,16

133:17 134:16,17

136:20,21 137:2,9

137:23 138:11

139:8,9,15,20,22

140:1,10,13,16,17

140:20,22,23

144:24,24,25

147:15,15,16,19

148:2 149:15,18

149:21,24,25

150:23 151:8,10

151:12,14,15,25

152:10,22,23,24

152:25 153:1,3,5

153:9,13,15,19,20

153:23 154:2,5,6

154:20,22 155:1

157:12,22 158:2

158:10,15 159:4

159:16,17,18

161:4 162:21

163:3,9,11,12,19

174:23 176:20,24

177:7,8,8,9,10

179:20 180:1,6,7

180:8,10 181:3,5

181:5,6 182:19,20

182:21 183:1

185:5,12,18

186:13,13,14,15

187:1,15 188:17

188:19,20 189:1

189:19,25 190:8

190:23,24 191:8

191:18,20,21

192:1,2,6,8,9,13

193:1 194:7,10,11

194:12 195:7,14

195:16,17 196:11

196:14,22 197:5,7

197:8,17,24,25

198:24 199:2,5,6

202:5,10,11,14,14

202:17 207:25

209:9,11 211:2,10

212:7,10,11,18,25

213:2,12,16,19,21

213:25 214:1,9,15

214:17 215:18

216:19,25 217:2,3

217:12,22,23

218:10,22 219:4

219:10,12 220:5,7

220:8 221:15,21

222:1,19,24

223:12,22,23,25

224:5,10,11,16,20

225:9 226:9,17,18

226:19,20,24

227:13,20 228:1,5

228:6,7,15,18,24

229:3,6,13,14,15

229:20 236:5,5,6

236:13,14 238:20

238:21,24 239:1,3

239:7,8,9,10,14

239:16,17,21,23

240:2,2,3,5,7,10

240:13 241:6,8

244:22,24,25

248:18 249:4,5

251:20,23 252:4

252:11 253:6,8,9

253:10,11,19,22

253:24 254:8,25

255:14,15,24

256:14,15,25

257:2,3,4,15,16

258:12,19,21

259:15 260:8,9,21

260:23 261:18,20

261:21,22 263:1,3

263:4,7,11,12,13

263:14,17 264:9

265:4,6 266:12,17

266:20,22,23

267:3,6,11,15,18

267:24,25 268:1,3

268:4,8,10,17,20

269:3,8,11 270:11

270:14 271:9,16

271:18,19 272:5,6

272:7,15,18,20,21

272:23,24 273:1

274:17,19,25

275:5,10 276:2

277:4,7,10,12,21

drabs 235:21

draft 2:8,9 20:13

20:22 22:9,11

24:2 27:13 28:15

28:23 29:19 32:18

34:16,17,21 35:5

35:11,15,17,19

37:3 38:14 40:9

64:9 73:3,8 75:24

75:25 94:5,5

105:23 140:23

155:11 157:14

158:3,11,17 160:5

160:8,10,16,21

161:14,20,24

162:1,17 164:8,18

171:19 172:20

200:12 226:10

229:25 245:3

273:15

drafting 68:3

105:12 276:2

drafts 32:1 34:20

35:25 102:19

145:2 147:18

172:21

dramatic 216:11

drank 7:20

draw 99:24 148:9

168:20

drawing 34:8

245:21 246:3

drawn 33:25

111:25 170:16

232:20 241:24

drew 34:16

dribs 235:21

drink 225:5 236:15

driving 34:25

38:22 45:16

247:13

dropped 223:2

drops 254:22

Drs 72:19 95:21

140:21 147:17

due 52:15 58:11

71:19 118:23

129:11 130:10

151:23 153:11,21

154:24 158:8

192:11 195:12

196:6 207:14

211:8,20 214:13

217:20 224:8,18

229:1 239:5,12,19

266:15 267:4,13

267:22 268:13

275:8
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duration 250:12

251:6

dust 31:15 83:20,25

84:24 85:1,2,4,13

85:18 93:25

203:24,24 204:1,7

205:16 207:14

214:3,6 216:22

217:14,15 222:4

228:20,22 246:10

258:24 259:10,11

259:21 263:16

264:24

dust-lead 259:11

dusty 258:17

dynamic 123:14

262:23

E

E 278:1,1

e-mail 3:18 15:17

40:11 157:15

e-mailed 156:2

e.g 150:12

earlier 12:19 29:6

39:15 53:4 65:1

65:11 102:1 116:4

122:1 140:24

153:1 155:10

158:24 182:3

190:15 193:12

194:7 203:22

214:3 216:12

225:11 226:12

235:10,17 248:5

251:24 263:4

275:21

early 6:18 7:21

10:2,17,23 23:14

50:6 75:10 164:22

167:9 189:17

250:22

earned 5:24

easier 115:5 141:8

141:11,11

easiest 92:5

easily 220:15,16,22

East 136:15

easy 41:1 136:3

141:1,22 219:14

230:11 236:20

256:20

eat 157:6 225:6

eating 80:19

echo 12:18,25

78:11

ecological 38:1

146:17 147:11

150:5,24 152:1,8

152:9 172:6,17,22

261:10

Ecology 15:4

economic 17:9 43:5

188:4

ecosystem 146:1

147:13 151:7,9

172:8 173:23

174:6

ecosystems 145:6

150:10,15 172:2

174:14

edge 182:10

editions 103:2

editorial 21:16

99:9

effect 33:1 54:2

58:2,3 62:2,11,15

62:21,22 103:4

110:16 116:23

120:13 127:2,3,21

129:5 142:7,7

143:14 153:24

169:19 171:24

185:13 241:17

255:6

effecting 12:3

effective 7:19 9:4

10:1 11:5 119:21

136:1

effectively 182:8

effectiveness 8:11

effects 17:10 18:13

33:14,16 34:22

35:3,14,17 36:1,2

36:14 37:11 38:1

38:15,22,22,23

42:8,9,22,24 48:2

51:1,21 55:17,21

62:11 109:20

111:12,13 112:23

121:12,20 122:13

122:25 126:13

127:7,9,11 128:23

132:25 133:1

135:23,24 137:17

138:16 141:17,18

142:2,2,10,10

143:5 146:1,8,17

148:6 150:5 151:6

152:2 153:3,5,14

166:24 167:1,17

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79:16,25 80:14

94:4 154:17

189:10 199:8

206:9 207:25

209:10,15 210:4

211:4

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getting 4:20 7:25

8:20 9:19 56:21

69:24 74:9 89:5

182:10 188:25

232:16 260:1

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196:19

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164:2 171:1

girls 134:2

gist 49:5

give 6:3 8:6,25

22:17 28:17,20

49:23 54:14 59:22

60:22 62:25 65:12

68:8 76:18 77:17

91:6 92:2 99:17

104:21 113:2,19

115:16 116:1

133:1,4,9,24

138:8 154:8,15

177:8 185:13,14

193:18 198:21

202:5 232:2

238:24 248:19

268:7 276:5

given 2:22 45:17

54:13 74:13 96:9

104:12 131:6

135:13 136:18

146:19 172:14

209:19 214:3

231:7 239:4 242:2

243:6 244:7

247:15 256:18

258:4 273:9

gives 29:10 82:9

108:17 202:18,21

254:13 256:20

giving 24:18 60:13

163:22 190:9

248:23

glad 25:20 228:24

glass 68:16 223:10

global 178:8,13

226:12

globally 12:3 67:13

178:1 185:20,24

go 5:10 8:6 10:5

12:12 13:15,24,24

19:18 20:17 22:23

28:7 29:14 31:9

45:21 48:25 56:9

56:25 58:14 61:3

62:2 68:22 72:11

73:4 74:18 78:19

81:12 83:4 94:1

95:14 99:9 114:10

114:24 123:11,11

124:11 127:16,21

132:24 139:7

142:4 145:19

149:6,16 155:10

159:23,24 160:2

164:2 166:11

177:5,17 182:3,25

183:2 185:10

187:2 196:15

198:2 199:7 212:6

214:2 216:20

219:14,18,20,21

219:23 220:3

221:14 228:14

229:8 234:24

237:13 240:20

241:8 243:6

244:15 248:1,2

258:12 259:13

263:4 265:4,24

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269:4

goal 161:16 204:18

205:11 270:8

goals 75:22 238:19

goes 21:13 22:7

70:12 76:17 91:11

117:3 160:16

185:1 222:1

231:13 234:3

250:25 269:7

272:2 273:22

276:20

going 5:15 7:7 8:17

8:17,20,21 9:21

11:25 18:19 20:10

24:19 27:1 28:16

42:6 56:2 58:20

61:3 65:14 69:23

69:25 70:13 72:10

72:17 76:10 78:17

79:18 81:12,13

82:11,12,13 86:12

90:12 92:1 93:19

93:23 97:2,11

102:4 104:1,18

107:2 112:11,11

112:17,18 117:2

119:25 120:8,13

123:11,13,15

125:10,13 126:3,4

126:8,20 130:23

134:7 139:13

140:8 141:10

143:13 144:18

146:15,19,20,21

151:21 152:12

156:24 161:9,10

162:14,17 163:8

163:21 174:22

184:25 187:13,25

191:10,10,11,12

193:19 195:4,11

196:20 197:9,25

206:12 215:11,17

218:7,8 219:22
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gold 182:25

good 2:2 7:3 9:19

12:3,17 35:24

43:8,9 45:22

54:10,12 60:20

61:16 63:2,2,3,16

64:23 65:7 70:8

73:4,9 76:10,18

77:4 81:8 82:10

90:24 91:4 96:1

96:24 98:15

102:16,20 107:2

107:13 109:1

113:2 117:19

125:13 127:17,23

129:3 131:18

141:2,24 145:19

149:12 151:4

152:14 154:7

157:7,14 158:12

159:7 177:14

179:7 183:3 185:5

185:7 188:17

189:16,20,24

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195:23 197:18

199:6 201:4 203:7

205:12 208:2,10

210:13 213:20

227:21 228:15

234:4 240:15,19

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254:9 261:8

264:14 266:4

271:16

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government 67:20

194:23 195:24

196:2,9

grade 125:9

gradients 198:13

198:14

gradual 32:11

gram 144:13,13,16

grammar 251:7

grams 222:5

granted 83:24

grants 6:13,14

graphed 212:23

graphic 100:15

142:1,1 143:1

205:24

graphically 63:11

graphics 206:21

grasp 205:4

gray 106:21,24

107:4,6 112:10

great 8:5,5 11:19

26:14 54:6 57:18

65:4,11 67:18,21

73:5 78:12 87:23

94:11 96:2 101:24

147:18 149:15

157:16 163:3,5

186:3,13 187:7

193:1 228:17

239:8 251:20

greater 62:15,18,21

62:22 66:20 73:11

73:23 104:14

170:1 177:22

greatest 185:3

269:24

greatly 133:17

Greece 89:2

Greenlee 1:21

278:5,18

ground 93:21

255:13

group 16:10 21:10

27:7 44:3 70:4

73:9 80:5 110:6

115:8,14 131:6

136:2 140:2

160:17,17 229:1,9

241:5 275:22

grouped 111:24

grouping 112:20

112:22

groupings 29:21

34:19 49:19

107:17,22 108:15

groups 9:21 35:4

55:4,8 107:9,23

137:17 138:3

225:20 259:8

265:25 275:21

276:25

growing 79:13,19

80:19

growth 38:4,6

149:10 171:25

guess 11:6 12:18

17:16 24:18 41:4

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60:3,5 70:7,23

73:11 78:8 80:3

81:1 88:18 89:16

110:3 111:22

115:25 117:3

123:4,18 130:1

144:22 145:23

146:24 154:9,16

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179:9,21 187:15

189:2,5 193:3

195:7,9 199:11

203:15,22 212:7

215:19 222:25

225:9,18,24

226:17 237:5

246:12 252:4

269:21 270:20,23

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guidance 8:1

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guidelines 45:5,6

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habit 254:6

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68:16,17 76:9

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half-lives 145:12

half-times 100:22

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half-ton 76:3

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hand 7:19 21:15

39:1 84:1 85:23

90:1 174:22

192:14 229:21,23

253:23 273:21

handful 8:10 251:1

handle 179:7

248:15 257:13

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handled 100:3

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hang 41:25 55:20

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182:5,6 210:17

219:7 242:23

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122:20 138:14

178:2,18 179:4,15

206:2 263:7

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215:7,15 254:3

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happy 5:16 8:3

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109:11 122:10

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hardworking

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241:3 244:24,25

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hazard 268:11

hazardous 82:18

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head 11:9 105:13

135:15 138:24

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headed 102:2

heads 81:25 147:23

163:22 241:5

health 14:11,12,16

14:17 17:9 29:18

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66:18 74:17 76:6

100:16 102:8,15

106:14 107:9

111:6 112:3

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175:13,16 181:1

186:16 188:4,8

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245:23 246:13

248:16 249:9,14

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258:4,7 259:19

260:17 261:24

262:9,24 269:13

269:20,24 270:8

healthy 150:20

hear 22:3 52:1 67:9

94:10 108:8 135:9

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heart 35:7

heartened 11:20

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heat 89:5

heavily 20:8 259:25

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heck 152:8

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hell 144:18

help 10:16 11:4

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28:25 34:7 39:10

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helpful 23:19 25:8

27:21,22 29:1

41:10,15 96:3,3

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helping 7:19

helps 30:10 39:10

65:5,12 127:3

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hematologic 42:12

hematological

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Herb 6:19 94:8

154:18 252:10

253:22 260:21

herculean 230:9

heroin 135:17

hesitant 215:19

hi-vol 86:4,8,19

93:9 205:4,25

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high 13:3 32:8,12

47:15,17 74:14

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109:25 110:13

122:1,4,5 124:18

124:21 125:10

151:19 192:7,10

195:18,25 220:13

220:15,19 268:12

high-level 73:14

high-quality 41:25

high-volume 86:2

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higher 50:18,20

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62:2 93:2 99:1

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highest 87:12 94:15

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highlight 29:15

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highly 40:7 113:16

126:3 128:9

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historical 29:4,8

39:23 96:17 190:3

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206:22 215:14

history 29:6 65:11

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hold 72:21 152:20

holdover 252:23

homeland 212:2

homework 11:1

40:8 94:4 157:13

honest 98:16

honestly 273:16

honeybees 94:14

honored 27:10

hope 6:4 11:15 22:8

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266:22 267:3,6,18

267:24 268:1,4,17

268:20 269:3

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house 61:14,15

129:19 217:14

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housekeeping

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260:1 264:6

Hoyer 202:10,14

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HUD 214:7

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122:22 141:3

191:19 199:21

221:4 257:18,19

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Huh 263:12

Huh-uh 277:9

human 33:19 43:1

43:15 44:10,20,23

45:16 46:3,6,25

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179:16 186:16

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humans 34:9 43:13

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hundred 109:9

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hydrocerrusite

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148:15,19

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hyperfiltration

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hypertension 35:6

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hypothetical 85:24

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idea 64:19 80:11

84:7 133:1,4,10

154:7 192:16

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166:10

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immediately 27:22

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246:11 249:18

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Impactor 79:1

impacts 150:1

159:9 185:20

impartiality 4:4

imperfect 93:5

impersonation

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implementation

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117:8
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importance 37:5

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improved 34:3

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improvements

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inattention 34:13

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include 19:2 35:6

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included 31:17,25

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includes 3:2 17:23

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175:16,23 176:1,9

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inclusion 156:11

incoming 19:23

inconsistence 58:13

inconsistencies

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inconsistency

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46:4,25 47:23

48:20 49:10 50:14

50:17 55:23

incorporate 57:24

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incorporated 34:5

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incorporates

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incorporation

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incorrect 130:16

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increase 47:4

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135:13,20 144:11

170:20 245:12

increases 197:23

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inculcation 196:18

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independent

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indicated 94:13

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indicator 23:2

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industry 12:6 66:5

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198:11,13,16

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informative 48:5

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informing 175:22

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83:24 85:14 270:3

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initial 68:3

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169:4,5 188:15

248:13

inlets 92:13

INN 1:11

inner-cities 263:19

inner-city 259:4

260:1 263:15

input 68:5 92:2

94:6 131:14

140:14 164:21

198:20 199:3
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insoluble 143:20

instance 63:5 223:4

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instrument 153:7

intake 217:25

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integrate 112:6

integrated 2:8 19:7

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27:7 34:10 39:17

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integrates 167:24

integrating 10:13

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integration 34:4

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integrative 39:25

intended 55:19

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129:9 158:6

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intent 129:9 188:9

intention 37:22

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interactions 2:23

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interagency 160:17

intercorrelated

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interest 4:3 66:7

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interested 24:15

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interesting 6:22

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interfering 230:5

interim 7:23

internal 78:23

internalize 114:16

internalized 113:5

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internalizing

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113:15,25 114:5,6

115:4,8 116:13

117:2 119:1 120:8

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interpolation 169:3

interpretation 44:3

88:10 99:21 131:2

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interpretations

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interpreted 232:23

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intervention

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interventions

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interviews 8:2

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introduced 238:8

introducing 27:5

introduction

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introductions

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introductory 99:14

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intubated 134:25

inventors 86:7

inventory 200:2

invest 139:3

investigated 214:22

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involved 28:5 54:6

76:14 85:19

183:12 190:11

209:15 247:17

274:16

involvement 10:2

involves 165:20

264:23

ions 143:18,19

IP 81:23

IQ 32:20 53:23

54:22 103:17

113:19,21 167:21

168:3,10 170:12

175:24 231:17

234:23 235:2

239:14,24 242:14

242:16 243:10,18

243:24 244:20

246:1 247:19

249:11 250:24

IQs 244:11

iron 181:15

irrespective 137:7

ISA 3:11,15,17

19:7 20:12 21:24

22:9 24:11 28:14

32:2 34:18 63:16

75:25 78:5 95:19

97:20,21 142:19

158:5 160:6

164:13 171:9

183:15 186:9

189:4 205:12,23

206:4 208:19

216:2,2,17 217:24

225:19 230:21

231:22 234:13

235:3 236:19

245:3 273:15,19

274:6,21,24

ISA's 104:11

issue 18:12 19:22

41:16 42:21 46:14

48:21,24 50:25

54:25 59:23 60:3

60:5,11 67:20

68:9 72:9 75:18

76:6,19,25 79:25

81:19 91:18

107:25 108:8,18

109:13 110:8

112:17 114:6

117:15 120:14

122:9 123:12,15

124:11 125:22

126:4 128:21,22

129:7 131:20

135:7 148:7

155:13 160:19

161:15 177:18

180:9 198:13

219:5 226:11

235:22,25 236:1

247:10 249:16

252:12 253:13

255:18 258:23

259:11 261:10

264:11,11,17

269:13,18,21

270:9 272:16

273:7 276:20

issued 162:5

issues 4:3 6:25 7:4

12:13 13:12,20

18:4,5 19:4,17

42:12 49:15 51:17

53:11 55:12 57:4

59:13 67:3 74:18

82:3 94:11 99:21

102:15 105:22

106:4,6,11 107:16

108:5,16 109:11

110:2 116:7

154:10 155:16

177:16 188:23

191:1 235:17

236:2 248:15

255:11 258:10

264:11,25 265:3,7

270:13 275:17

276:4 277:1,15,19

item 95:18 177:2,4

275:23 276:12

items 3:22 24:9

111:23 114:11

126:21 156:22

225:23 273:4

iterate 63:18

iterated 113:21

iterations 139:16

J

Janet 26:12,16

January 161:17

JEFFERSON

278:3

Jennifer 88:22

Jersey 209:20

job 6:15 8:3,4,6,7,9

10:17 11:19 57:18

58:10 65:7 67:18

78:12 81:8 96:1

102:18,20 105:21

107:2,13 132:7

140:25 141:2

163:3,5 177:12,14

185:7 187:7

189:24 190:9

195:24 196:16

199:21 201:4

262:8

Joel 14:25 229:11

John 24:25 25:2

26:16 67:7 88:19

117:9 157:20

Johnson 13:25 14:2

14:2 140:21

144:24,25 147:17

152:10

joining 24:23 25:16

joints 112:25 113:2

journal 63:19 76:8

judge 213:6

judged 213:8

judgment 22:19

57:7 68:15,20

69:4
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justification 210:25

justified 59:17

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253:5

justify 115:3

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154:21

justifying 183:8

K

Karen 159:17

keep 8:16,17 11:4

28:19 44:7 82:6

102:5 111:2 125:8

205:9 206:10

215:16 216:22,23

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keeping 36:16

256:16 260:10

Ken 153:15

kept 8:17 133:25

Kevin 159:17

196:25

key 36:12,14

103:13 107:4,5

145:20 164:1,7

167:14 170:13

175:15 176:8

230:20 238:1,5

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kicking 204:20

kickoff 160:1

kid 129:19

kid's 264:7,8

269:24

kids 52:9 53:1,3

81:11 109:20

124:8,9,20 126:1

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258:5,23 259:25

260:2 264:20

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kind 5:8 8:25 12:12

16:15 19:22,24

23:1 39:5 44:15

58:22 60:3,16

61:1,3,24 62:9

63:19 68:17 70:9

71:4,9 88:9 89:19

90:3 93:8,21 99:4

99:16,17 101:13

104:4,21,23,23

109:11 116:11

117:9,22,23 118:3

119:21,24 121:3

122:19 126:18,22

126:24 127:11,18

132:13 137:9,19

137:21 138:23

146:22 148:1

152:17,18 154:18

171:6 189:11

193:3,22 194:19

196:15 200:20,24

201:14,24 204:21

204:24 205:3

206:19 207:1,5,7

226:12,15 235:1

240:22 245:1

247:4 248:9

250:17 251:4,12

251:24 252:16,21

254:4 257:1,5

270:10,20 272:2

273:8,25 275:20

277:1,13

kinds 70:10 74:4

80:25 82:16

100:25 106:11

122:24 138:22

200:17,19 210:8

234:24 252:19

276:23

Kirrane 27:8 28:15

29:14,17 39:3

46:9 47:9 48:4,8

48:12,15 117:5,17

124:22 137:9

knew 7:7 245:3

261:4 266:17

271:20

knots 276:9,9

know 3:19 4:6 5:1

5:4,7,9,19 7:13

8:3,9,14,24 9:11

10:9 12:8,25

13:16 17:24,25

18:15 21:16 22:23

24:24 27:22 41:3

41:12,21 42:12,15

42:17,21 43:10,10

43:15 45:20 46:20

46:22,25 47:16,19

48:20,24 51:15,24

53:8,9 54:8,22

56:11,17 57:10,12

58:3 60:3,4 63:8,9

63:14,20 65:9

68:20 69:14 70:10

70:15,15,17,18,19

71:5,11 72:4

73:25 75:11,15,17

76:3,23 77:16

78:1,2 79:12,25

80:9,23 81:17,22

81:23 82:2,4,8,14

82:20,24 83:2,8

84:8,21,22 85:3,3

85:21,21 86:21,22

86:23 87:21 88:22

89:25 90:10,11,20

91:1,2,8,17,21,23

92:14,15,24 93:1

93:19,20,23 95:13

96:6 97:7 98:14

99:16 100:2

101:12 102:5,13

103:5,13,18

104:10,13,19,23

107:19,21 108:2

108:15,23 110:3

115:8,16 116:4,9

117:14,18,24

118:6 119:9,14

120:7 121:2,4

122:23 123:2,8,14

123:19,20,25

124:1,1 125:16,19

125:19 126:12

127:3,23 129:7,9

130:14,17,24

131:20 132:14,20

132:21,25 133:3,6

133:8,11,23 135:5

136:17 137:2,3,14

137:20 138:14,15

138:19,20,22,24

139:2,3,5,21

140:1,6 142:3,24

143:11,12 144:15

144:19,21 145:13

145:14,18,19

146:5,12,15,18

147:6,11 148:15

151:8,12,19

152:16 154:10,10

154:13 155:1,14

157:3,6 161:6

163:2 179:14,16

180:2 181:11

187:20 188:11,13

189:4,4,6,8,10,17

190:6,20 191:5,13

191:23 192:3

193:4,5,5,6,21

194:5,6,8,13,14

194:22,22,24

195:3,8,8,9,10,15

195:19 197:6,10

199:24 200:1,11

201:4,11,12

204:23 205:1,21

205:22 206:11,11

206:23 207:6,8,9

208:9,13 209:23

210:5,10,12

212:14 214:20

215:4,9,15,21

216:19 217:25

218:6 220:19

222:10 223:10,22

223:25 224:2,6,23

225:6,11,22

226:11 227:17

229:6 230:6,9,12

232:12 233:6

237:3 242:22

243:20,22 244:7

245:1 247:13,15

248:6,7,11,14

250:16,21,25

251:23 252:15,16

252:17,20,22,24

253:15 254:21

257:21,22,25

258:1,16 259:8,12

259:13 260:6

261:8,11,13 262:3

262:14,15,17,22

263:10,23,24,24

264:4 265:7,8,17

265:21,25 267:9

269:9,21,23 270:1

270:3 271:11,17

272:18 273:9,15

273:21 274:2

276:4,12

knowing 7:8 9:13

203:25 220:23

knowledge 17:1,23

70:16

known 2:16 25:19

73:15 225:13

250:6 259:20

knows 216:16

Kool-Aid 7:21

Korrick 14:10,10

52:3,11 105:17,20

112:13 119:23

120:12 125:22

128:18,21 129:17

129:21 130:8,12

131:17 241:3

249:4,5 257:16

259:15 260:9

269:11

Kosnett 14:13,13

40:1,21,22,25

45:8,11,13 46:1

46:12 47:11 48:7

48:10,14,16 50:1

51:11,14 52:10,14

52:19 57:5 59:14

59:18 65:3 68:6

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Kosnett's 57:20

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KSD 205:8

L

L 1:21 278:5,18

lab 195:25 196:1,1

laboratories

244:19

laboratory 15:2

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lack 4:4 71:6 130:6

183:12 191:3

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251:14

lacking 165:14

laid 104:25 118:2

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landscaping 219:17

language 30:7

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104:24 128:3,20

129:10 188:7

205:12,20 234:22

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Lanno 15:3,3

140:21 147:15,16

lap 180:25

large 28:11 58:1

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79:9,17 80:21

81:21 83:21 91:6

134:23 135:7,11

146:18 151:25

165:2 178:22

208:3

largely 35:7,15

82:13 136:15

200:22 259:4

larger 41:16 62:10

62:11 73:13 78:19

83:15,25 84:7

85:11 86:21 89:21

92:7,23 95:10

108:8

largest 224:6

lastly 167:13

175:20

late 75:20 85:3

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latitude 60:13

laughing 229:2

law 2:17 16:15

274:21 275:1

laws 4:2

lawyer 61:14,15

203:7 254:10

lawyers 61:14

lay 41:11 104:7

117:22

layer 114:9

laying 116:9

177:14

lead 1:9 2:5,9,10

18:1,10 20:24

22:15,25 23:3

27:9 29:11 30:16

31:1,3,6,9,15,17

31:20,21,21 32:1

32:4,6,7,11,16,21

32:24 33:20 34:23

36:19 39:25 40:7

40:12 42:8,12

43:4,12,17 46:5,6

47:5,15,16,20

48:3 49:18 50:5,8

50:16,20 52:5,17

55:17 62:1,3,11

62:12,18,21,22

63:7 65:20 66:13

66:23 70:14 72:20

73:18,23 74:6

75:6,10 76:4,11

76:19,23 77:7,17

79:11,12 80:24

83:24 84:4 85:11

85:16,25 86:3,4

87:3,13 88:3,4

91:18 93:3,7,9

94:16 95:22 96:1

96:5,7,14,18,19

96:21 97:6,7,10

97:12,24,25 98:6

98:8 99:1,3,25

100:9,10,14,17,21

101:8,9 102:2,7

103:7,14,15,16,17

103:17 105:17

106:14 109:20

110:16 111:12

120:10 121:20

122:3,4,5,18,25

123:10,13,13

124:18,19,21

125:11,17 126:13

127:7,8,11,15,16

127:17,20,21

128:22 129:5

131:23 135:14,24

137:15 138:16

140:20 143:2,11

143:17,18,19,22

143:24 144:10,12

144:13,17 145:5

146:17 147:1,3,5

147:9,11,11

148:10,15 149:1

149:20 150:5,7,8

150:11,14,18,22

151:5 152:13,19

154:16 156:8,16

161:6 163:25

164:24 165:19,22

166:1,15,25,25

167:2,2,8,11,15

167:16,18,25

168:1,2,5,10,12

168:12,13,14,17

170:22 171:11,21

171:23,24,25

172:5 173:5,14,19

173:24 174:11,14

175:9,10 177:6,19

177:21 178:2,2,3

178:5,11,18,19,22

178:24 179:2,5,7

179:8,10,12,15,17

179:22 180:3,14

180:14,21 181:12

181:13,16,19,20

181:22 182:8,9,23

182:24,24 185:4,6

185:21,24 188:23

189:12,15,25

190:4,16,17 191:1

191:24 192:3,3,4

192:4 193:7 195:2

195:10 196:16

197:3 199:2,7,9

199:14,23 200:21

200:22 201:11

203:21,24 204:4

204:13 207:4,11

208:5,22,25

209:22 210:7

212:8,11 213:14

214:3,6,11,18,18

214:19,19,19,21

214:23 215:7,10

215:13,22,24

216:21,21,22,22

216:23 217:5,8,13

217:18 218:1,3

219:1,2,7,13,23

219:24,25 220:1,2

220:9,24 221:1,1

221:2,5,5,5,7,8,13

221:22 222:3,3,4

222:5,8,10,11,12

222:14,16,17,20

222:25 223:5,11

223:18 224:7,12

224:13,14,15,22

224:25 225:1,2,3

225:18 226:13,15

227:4,4,7,15

228:20 229:10

232:10,13 236:9,9

237:13,15,21

238:6,7,22 239:2

239:4 242:8,14,16

242:16,19,23

244:9,18 245:13

246:4,11,14,24

247:5,7,11,20

248:8,16 249:17

250:12,20 255:2,3

255:3,4,12,17,21

255:25 256:5,7,8

256:9,11,23 257:9

257:12,19,23,25

258:3,13,25

259:18 260:1,2,3

260:4,6,7,8,14,19

260:25 261:5,5,7

261:23,25 262:20

262:21 263:8

264:12,20,21,23

264:24 265:18,23

265:24 266:13,18

269:14,25 270:17

270:18 271:6,14

272:8 273:19,24

275:12 276:2,13

277:14

lead-exposed 42:14

lead-painted

209:18

lead-per-kid

259:17

lead-related 50:25

leaded 76:7 171:22

173:11 214:25

leader 27:9 185:20

leads 84:20 250:22

259:18 264:7,8

272:11

learn 70:14 95:1

223:17

learned 9:8 252:24

learning 108:3

114:8

leave 42:15 76:13

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legitimate 129:22

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Leslie 156:24

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lessons 272:11

let's 39:21 47:13

72:11,13,16 76:23

76:24 81:5 83:3,4

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131:19 133:15

140:17 158:15

180:7 197:5 199:6

199:7 212:1

227:21,22 229:8

239:8 244:23

247:22 249:3

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level 21:12 23:2

28:17 36:21 42:21

51:19,25 55:16,22

57:19 62:3 71:24

97:25 99:1 101:16

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124:21 151:19

165:10 174:6

182:9 183:11

185:1 190:19

203:11 215:16

221:8 234:17

243:13,21 245:14

246:5,9,17 247:19

247:20,22 248:3

250:10 252:1,8

260:3 264:1

levels 32:4 33:20

36:14,19 46:24

47:2,10 48:1,3,19

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52:18 55:17 56:2

66:20 70:22 96:10

96:15 97:6,7,12

97:25 98:3,6 99:3

100:9,14,17 102:2

103:7,10 116:8,8

122:1,3,4,5,19

143:2 145:20

148:5 150:9,18

153:18 156:16

170:20,22 173:14

173:24 207:9

214:5 219:23

222:20 223:2

232:10 233:16

237:16 242:16,17

242:19 244:9

245:17,23,24

246:1,4,5,10,12

246:14,25 247:5,7

247:11 248:16

249:17 255:20

257:19 259:19

Lewis 159:18

life 7:21 63:8 115:5

148:24 153:13

167:10 262:4

lifeline 84:8

lifestage 121:17

lifestyle 121:16,17

lifetime 90:15

100:12 156:17

251:4

lifetimes 90:12

ligands 143:19

light 29:21 35:20

49:7 189:17 231:3

231:18 232:23

liked 246:20

limit 206:9

limitations 36:19

99:13 127:24

169:17,22 170:18

175:18 176:12

193:6 233:8,13,22

235:8 238:6

249:20

limited 10:24 40:17

43:23,24 44:23

56:15 74:13

132:20 139:2

150:7,13,19

167:19 172:3

183:15,16,17,18

183:19,25 190:18

194:16 216:6

217:5 233:15

limiting 180:13

Lindern 11:16,18

13:9 14:21,22

40:3 64:24,25

67:17 95:22

101:22,23 177:8

182:20,21 186:15

187:1 188:17

189:19 197:7,8

226:9,17,19 276:2

line 23:5 62:8,18

87:4 102:23 114:5

119:21 155:23

179:9 182:13

235:9 237:4

245:11 251:25

lines 64:15 72:24

117:18 138:15

200:7 201:1

245:19

link 43:3 74:6

155:5 172:4

linked 236:19

linking 38:11

174:10

links 31:17

list 24:17 104:9

111:21 156:24

157:9 225:22

228:4 268:23

269:16,25

listed 24:5 35:13,20

37:1 38:2 63:5

104:8 108:3

111:15

listen 195:10

listened 7:10

245:25

lists 52:20 200:9

liter 141:6 144:12

144:13,13,17

148:14,14

literally 74:14

literary 145:4

literature 32:7

47:18 53:7 56:13

57:8 66:1,2 72:3

100:6 101:1,10

106:4 111:3,8

112:7 126:5 133:8

143:23 180:3

210:3,6 237:11

241:16 242:25

245:7

litigating 69:21

litigation 1:22

180:21

little 6:3 13:18

19:21 29:3 30:8

42:4 45:2 52:22

57:15 65:13 85:17

86:16 92:18

108:21 110:23

114:20,24 116:1

122:21,23 123:4

157:6 182:12

187:5,5,10 190:12

193:7 203:23

205:17 219:12

223:8,20 235:14

235:21 237:7

238:8,18 240:14

242:5 249:12,14

250:6 251:8

252:24 258:8

259:16 274:14

275:25

live 44:20 88:19

266:1

lived 7:3

lives 4:18 109:10

270:5

living 135:21

load 261:14

load-type 146:16

loading 84:24,25

85:4,6,6

loads 52:9 89:12

146:23 151:3,4

174:11 179:5

261:12

local 169:2

locales 209:25

localized 209:24

locals 75:15

located 15:11 173:6

location 169:7

locations 173:20

locutory 273:18

logical 150:1 152:4

long 19:19 40:17

54:18 61:12 70:12

71:12 73:21 86:15

93:17 106:21

141:2 152:12

178:23 218:8,8

247:16 255:12,12

long-term 205:7,7

longer 82:2 184:8

223:19 254:4,7

266:10,11

longitudinal

137:16

look 26:24 37:9,17

42:9,24 44:6,8,20

44:25 50:20 52:12

56:22 57:3 69:15

70:14 77:19 80:12

114:16 116:18

118:5 119:5 131:3

137:10,11 142:18

149:13 152:3,4

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224:23 239:14

258:24 261:15,23

262:15

looked 43:22 45:4,4

50:20 53:1,1

106:22 110:20

114:12 124:6

140:8 153:15,16

172:21,22 214:9

217:8 222:3

234:14 238:4

240:1

looking 8:22 20:10

26:23 27:2 37:21

37:23 48:5 62:13

95:23 96:24 134:5

136:25 140:4

146:17 147:25

150:23 152:12

158:7 183:23

193:14 207:20

220:9 239:22

254:24 262:7

265:12 269:4

270:17 275:14

276:17

looks 69:11 103:25

Los 220:12,18

lose 111:18 125:13

loss 32:20 124:6,8

124:10 167:21

170:13 175:24

243:10,18,24

249:11

lost 11:23 111:16

257:17

lot 11:2 12:21 27:1

28:11 30:12 31:3

38:19 42:11 45:19

46:6 50:3,23

54:23 70:13,14

73:24,25 74:4

75:11,11,16,20

76:15 78:10 79:10

81:18 83:24 88:25

91:3 102:9 105:22

107:8 109:14,17

112:9 116:6

128:19 130:17

134:8 138:19

141:23 150:2,20

151:1,17 157:5

188:24 189:2

192:3,4 209:22

218:11 219:8

221:11 222:15

225:13 230:1

231:23 236:25

246:21 249:1

250:2,11,24

251:16 259:14

260:2 263:15,23

265:16,17,24

273:18,21 275:11

lots 66:13 85:10

143:11 222:13

262:19

Lou 197:1

Louis 1:23 219:21

love 75:9 98:7

135:9 181:20

182:23

loved 8:4,7

low 46:24 47:2,10

48:19 49:11 62:16

62:18,19 97:7,12

143:22 237:13

242:17 245:17

246:11 256:2

259:17

low-level 232:13

low-volume 81:25

lower 50:15,18

51:6 53:5 59:23

62:11 102:2,3

152:2 169:16,20

170:2,20,25

172:11 174:5

182:8 203:12

214:5 222:20

245:23 246:5,16

254:1

lowered 261:7,7

265:9

lowering 165:10

246:16 257:19

264:3,14

lowest 55:17

242:18 244:9

246:1 255:19

lucid 99:12

lumping 112:23

lunch 20:21 22:3

60:21 115:14

140:20 156:22,23

157:8 158:12,13

158:16

lunchtime 157:7

Lydia 159:8 163:12

196:22 277:7

M

macrophyte 144:9

magnitude 33:19

33:20 37:4,10

132:11 133:11

141:17 142:20,20

142:22,23,24

165:11 245:13

main 16:24 112:17

171:17 192:20

277:17

maintain 217:3

265:21

maintained 224:23

265:14

maintaining 3:3

156:16 182:6

271:14

maintains 227:1

maintenance 17:11

18:14 188:6

major 24:9 29:15

29:19 38:2,25

73:20 75:18,18

79:2,15 145:23

156:12 177:18

179:14 194:21

223:1 255:1,2

258:2 259:21

majority 33:23

111:1 224:14

makeup 114:18,18

making 3:4 23:14

24:15 35:3 61:13

141:11 210:20

240:23 243:23

256:24

male 36:2

Man 205:5

manage 21:17

managed 160:17

management 10:22

156:1,5 160:18,22

mandate 16:15

63:17 248:7 249:2

mandated 19:9

274:7,21

manner 144:10

mapping 244:22

maps 236:17

margin 165:8

262:9

Marion 202:8,12

202:14

Mark 256:17

markers 89:1

marketable 205:13

Martin 159:17

Mary 27:6

mass 82:7 91:3

141:5,7 148:8,8,8

148:13

massive 10:10

material 40:10

142:8 143:10

144:20 145:9

156:1,5 175:1

210:13

math 125:12 248:1

matter 61:2 65:24

132:14 256:1

268:25

matters 58:25

132:17

mature 270:18

MBL 15:16

McCabe 26:12,16

McKinney 82:1

MCNAMARA

49:23 97:16

222:22

mean 45:21 47:10

47:11,16 51:9,17

52:24 53:12 54:3

58:14 59:18 70:6

70:15 81:7 82:12

82:23,24 84:2

85:22,23 86:1,4

86:22,23 90:8,11

98:11 109:17

110:15 115:2

117:15 124:6,22

126:19 127:20

128:18 130:1,17

139:3 147:4

154:23 178:16

180:22 184:24

186:18 187:7

191:4 195:17

203:24 205:20

207:12 209:7

214:1 216:9

217:25 219:3

222:19 225:2

226:8 227:2

228:18 252:5,12

256:22 258:1

259:15,25 260:9

261:9,22,23

263:20 265:15,21

266:3,18 268:15

269:23 270:1,1,9

270:17,20 275:10

meaning 52:21

74:5 86:19 118:11

meaningful 146:6

208:4

means 60:4 85:23

123:15 139:12

146:1 152:6,7

232:12 251:11

272:4

meant 33:6 205:21

measure 54:16,20

55:18 58:2 73:10

73:13 74:6,6 82:6

82:9 85:7,25 92:6

93:24 195:11

204:3,4 258:14

266:7 268:19
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measured 85:2

87:4 88:14 92:8

106:3 149:4 203:5

204:4 220:18

242:19 244:10

measurement 18:9

88:10 93:18 153:8

255:19

measurements

31:6 86:13 99:19

99:21 203:10

256:20,24

measures 53:17,18

53:19,19,21 54:5

54:23 244:18

measuring 50:24

54:22 239:2

mechanism 48:17

49:11

mechanisms

125:25 138:13

media 172:6

175:10 199:15

203:21 217:15,15

media-based 38:7

median 104:1

medical 15:9

180:20

Medicine 14:15

15:24,25 45:4

meet 2:15 173:24

191:7 238:18

267:12,16

meeting 1:10 2:1,4

2:6,7 3:21 4:10

5:3 17:15 19:1

22:15 23:13,17

25:10 27:13 88:25

161:13 173:15

187:18 193:10

271:13 276:11

277:24

meetings 2:14,15

2:21 3:3,5 191:22

223:16

member 14:15

members 4:4 9:19

12:20 13:15 16:7

19:2 20:7 23:16

26:18 40:4,14,17

94:7 102:24

149:15 159:2

176:21 232:15

memo 161:22

Memory 108:24

mental 238:14

mention 17:12

18:21 19:12 24:22

41:16 42:22 63:24

121:22 123:25

135:18 154:16

163:20 186:15

225:16 228:5,7

235:13 268:3

276:16

mentioned 39:15

49:15 74:22,23,24

78:5 113:24 136:3

138:1 144:1 155:9

158:24 163:12

188:2 206:9

250:15 257:10

265:25

mentioning 109:14

188:18,21 246:9

mentions 135:19

208:5 238:22

mentor 13:2

mercury 262:2

merit 80:5 234:16

message 83:5 92:3

231:10 249:14,24

met 3:1

metal 223:8

metals 89:6

meter 84:25 264:13

meters 90:9 206:2

method 90:5 97:15

193:12 266:8

methodically

137:20

methods 18:9 33:7

83:15 84:23

169:21 193:16

204:14 206:22

metrics 59:1

138:22

Mexico 33:3

188:25 191:11

Meyer 155:25

mic 24:20 97:17

121:14 222:22

Michael 14:13

15:15,23 40:1,2

60:19 68:2 105:18

126:22 131:24

134:16 151:25

154:13 213:25

214:16 219:11

222:18 228:17

229:10,11 236:14

246:8,8 247:17

258:1 263:2 265:4

269:9

Michael's 102:1

229:6 259:17

microbiome 101:8

microenvironme...

165:24

microgram 222:14

micrograms 47:20

84:25 144:12

148:14 165:11

218:23 222:6

242:17 247:23

255:18 258:17

264:12

micron 89:20 90:8

90:11,15 93:8

microns 73:12,24

73:25 74:10,16

80:2,15 81:4

83:20 84:13 91:13

206:5

microphone 14:20

202:11 229:17,19

microphones 14:20

microscopic 223:9

middle 50:12

136:15 160:2

161:6 202:16

Midwest 1:22

Mike 271:8

milligrams 141:6

148:13,14

milligrams/kilog...

141:6

million 181:13

263:7,15

millions 179:4,15

179:17 221:13

222:18

mind 82:6 107:15

110:10 111:2

113:16 114:9

131:10 178:13

206:10 243:9

mindful 21:25

22:22 155:5 189:2

minds 121:5

mine 101:25

minerals 101:16

minimum 97:8

161:1

mining 30:21 67:11

97:1

minor 21:16 61:4

73:3 85:20 86:14

87:1 88:6 130:2

145:3 177:16

199:19 206:19

208:14

MINTEQ 144:6

minute 13:19 16:11

minutes 3:20,23

5:25 6:3 11:7

21:24 40:24

105:16 157:4,6

226:5

mischaracterized

153:2,24

mismatch 154:11

misplaced 109:18

misread 213:24

misrepresenting

22:6

missed 37:24

134:19

missing 100:3

109:7 132:9

134:20 154:12

217:16

Missouri 1:22,23

278:2,6

mix 6:22

mixed 73:15 89:6

mixture 44:1

mode 81:23,24,25

90:25 234:21

model 26:11 32:6

32:10 52:14 100:8

146:8 217:7

220:16 238:4

261:12

modeling 87:23

103:3 184:14

186:18,23 187:7

187:10 220:11,12

236:8

models 96:23

100:10 151:4,5

184:14 198:19

233:18 237:22

modern 237:24

modesty 74:8

modifiable 262:6

modification

122:15

modified 31:5

32:17 198:5

modifiers 132:12

modifying 38:8

modulating 101:8

molar 141:7

moment 5:1,7

49:24

money 8:20 139:3

189:22 205:2

259:14 267:9

270:7

monitor 149:19,19

193:22 227:6

monitored 227:16

monitoring 18:10

30:24 80:13 147:3

147:5,8,13 151:2

175:10 184:12

186:18,19 187:3,9

189:13,14,14,15

192:15,22,24,25

193:7,16,16 194:1

194:2,17 196:17

196:25 197:3
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203:17 204:13,14

205:23 206:22

213:14 227:4

monitorings 227:5

monitors 192:16

201:6

month 7:13 234:16

monthly 213:3

months 27:19

100:18 201:13

212:19 213:2,8

234:20 250:23

251:1

moot 244:12

255:18 258:17

morning 2:2 5:7

12:17 20:21 24:10

39:17 132:10

157:24 158:23

163:20 172:4

189:20 226:3

273:5,18 277:18

morning's 159:1

mortality 35:8

Moscow 14:24

Mosquitoes 94:22

motion 23:14

mouth 84:1

mouths 256:9

move 23:23 26:25

27:4 39:21 72:8

72:14 76:20,24

90:5 97:16 102:6

104:12 105:15

115:11 121:7

126:22 140:17

158:20 161:8

162:10 166:19

195:1 204:25

222:22 255:13

261:3,3 262:17

moved 31:3 148:8

185:25 194:13

movement 150:10

movements 146:15

moves 81:15

moving 27:14,17

31:12 33:4 38:1

117:14,14 123:13

147:14 163:16

168:19 205:11

215:12 221:15

226:2 270:15

272:25

mucus 81:16

multidisciplinary

16:8

multimedia 18:4

163:25 165:23

180:17 185:7,9

190:1 248:9,13,19

253:25 255:22

276:4,6,6,7,20

multiple 41:25

52:15 55:4 71:19

82:20 91:17

118:23 129:11

130:10 133:20

136:16 151:23

153:11,21 154:24

158:8 189:15

192:11 195:12

196:6 211:8,20

214:13 217:20

224:8,18 239:5,12

239:19 262:10

266:15 267:4,13

267:22 268:13

275:8

multipollutant

31:10 248:21

276:7,8,13

municipality

224:12

Murphy 159:16

163:9,11,19

174:23 186:13,14

197:24,25 202:14

212:18 213:2,12

213:16,19 215:18

216:25 217:3

218:10 219:4

228:5,7 267:11,15

268:3,10 277:10

mushy 128:14

mute 72:24

mystery 68:16

N

NAAQS 32:21

73:18 74:1 77:7

91:15 96:14,21

97:3,14 163:25

183:9 185:11

190:19 191:10,22

196:15 203:5,11

203:13 207:9

208:6,9,22,22,23

227:7 246:11,16

248:8,12 254:9,15

254:17,19 255:21

256:16,20,22

267:8,12,16,19,19

268:9,12,19 269:1

270:2,17,18

275:12 276:21

nailed 71:24

name 13:16 14:1

25:2 138:2 159:8

nanograms 220:20

narrative 128:13

narrow 65:10

nasal 81:11,14

91:23

nation 12:23

nation's 180:16

national 6:12 10:11

10:15 15:1 16:19

16:21 17:21 25:3

156:6 157:18

159:23 164:16,23

165:19,21 185:16

222:2 248:19

265:10

Nationwide 173:21

natural 14:6 17:6

18:3 31:11 174:10

177:21 179:13

181:21

naturally 63:15

221:20

nature 56:13 76:20

112:25 139:23

181:10

Naval 195:25

navigate 30:10

near 71:4 80:19

93:23,24 94:15

143:21 144:19

173:8 202:2 203:5

220:13,14

near-source 73:23

near-term 205:4

necessarily 19:15

63:25 75:7 84:2

85:16 99:18

107:23 109:7

110:12,15 113:18

120:21 123:1

124:11 126:6

180:14,15 225:4

252:15 253:3

256:22 260:6

necessary 17:3

102:22 145:15

187:21 213:23

266:11

need 9:17 10:5,7,18

10:23 21:17,22

48:8 54:25 58:4

59:16 60:14 62:20

63:15 68:5 74:8

77:13 82:8 94:23

95:12 99:2 100:1

102:5 105:12

119:19 126:22

131:14,14 134:23

140:14 144:2,22

155:17 157:9

177:17 187:24

190:25 191:12,15

191:15 192:23

197:6 207:23

213:3,7 235:13,23

235:24 237:14

244:11 247:22

255:2,25 256:2,3

256:4 257:12

261:13 262:5

264:18,25 265:8

265:24 266:2

273:5 274:10,11

274:23 275:3,10

277:5

needed 17:23 65:24

122:15 131:21

162:25 165:13

208:12 216:15

231:21 260:24

needing 117:22

needs 21:21 46:10

60:11 62:23 82:22

92:6 128:1 130:16

135:3 136:9

179:11 210:14

225:12,13,21

228:8 257:11,12

275:17,24

neglected 209:14

neglectful 129:16

NEI 200:2

neither 243:5

253:20 278:10

neo-children

138:16

nephropathy 47:15

47:17

nephropexy 48:1

nervous 34:8,22

108:9 111:23

127:16 194:10

NESCAUM 15:6

network 87:4 91:15

187:3 189:15

256:18

networks 189:16

neurocognitive

51:21 120:22

166:23 168:9

neuropathies 136:5

neuropsychology

34:6

neuroscience/psy...

243:11

neuroscientist

243:15

neurotoxic 121:12

neurotoxicity

127:7

neurotoxicology

34:6

neurotransmitters

135:25
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neutral 143:21

never 93:23 124:21

208:23 210:22

227:18 256:17

269:25 272:10

new 2:12 5:18 6:20

8:18 11:15 16:21

17:2,21,23 31:24

32:25 55:15 73:17

141:19 172:17

174:11,17 178:16

183:23 184:5,18

184:20 193:19

194:1 197:12,16

198:6,7,18 201:5

201:20 203:17

204:17 209:20

214:5 216:21

233:4 234:5

237:11 241:16

242:3 246:15

263:18 268:6

newly 167:19

172:14 231:2,14

231:15,25

news 76:9 77:1

nice 11:14 39:5,11

75:23 87:2 103:11

104:19 111:14

112:16 145:8

147:22 177:12

199:21 200:8

235:10 236:10

244:22,25 253:1

nicely 18:5 106:7

209:12 238:6

249:7

nifty 181:11

night 88:1 157:4

230:4

nitrate 143:17

Nodded 11:9

105:13

nods 241:5

noise 58:11

nominal 148:24

149:2

non-acute 127:13

non-airport 73:23

non-breathing

205:16

non-exposed

123:21

non-human 134:10

non-regulated

227:2

non-technical 30:8

noon 3:16

normal 99:2

normally 42:18

78:16 81:13

north 1:12,23 16:6

209:20

Northwest 15:1

notation 238:17

notches 87:15

note 18:15 25:24

35:10 36:14 88:24

94:10 100:24

145:10 147:12

156:2 161:19

162:5,11,13

190:12 196:24

200:1 219:5

noted 136:5 146:25

161:21 216:12

notes 75:20 99:20

207:24 277:13

nothing's 197:21

notice 2:22 46:16

49:16 50:2,12,19

87:2 160:21

217:13

noticeable 263:21

noticed 87:6,17

204:16 228:16

notify 3:18

noting 163:24

notion 58:12 63:15

107:8 226:25

234:8

November 168:22

nuance 106:16

nuances 194:3

number 23:18

27:21 28:19 40:17

86:6 92:14 116:5

127:7 134:22

135:11 139:16

152:3 177:20

200:5,5 213:6

234:1 236:16

248:20 271:3

numbers 37:7

225:7

nutritional 14:9

33:13 167:10

NYU 15:25

O

o 73:13

objecting 60:4,5

objects 271:22

obligation 19:13

observation 78:7

84:21 184:13

190:13

observations 37:10

37:20

observed 36:15

44:1

obtain 182:1

obtained 191:14

obvious 72:1 92:12

127:8 276:14

obviously 11:1

12:22 82:4 96:13

110:4 137:13

142:12 187:16

193:2 209:17

250:2

occasionally 134:9

occasions 162:12

200:5 236:24

occupation 14:16

95:9 100:16 101:2

occupational 47:3

95:3,7

occur 173:23

occurred 47:13

110:19 148:6

178:23

occurs 62:19

122:11 204:3

246:8

October 161:18

165:1

oddity 208:20

odds 83:2 100:15

offer 60:24 63:21

78:9 105:8 162:6

162:9 236:11

offered 71:2

offering 80:2

office 4:2,7,12,13

6:7,9,21,23 10:14

26:2,3,8,9,13 28:4

159:6,10 160:17

160:21 176:22

202:15

officer 2:3 39:20

40:18

officially 227:18

277:22

offset 65:12

offshore 191:2

OGC 26:10

oh 5:23 57:16 71:15

72:6,21 94:23

121:16 130:23

134:1,1,2 149:16

163:19 180:8

204:14 205:21

213:18 229:15

239:17 275:5

Ohio 15:3

okay 11:8 16:4

20:16 23:7,25

24:5,19,25 39:3

40:16 42:3 45:8

47:14 48:7,16,16

51:11,14 58:17

61:15 63:13 67:24

68:2,25 70:21

77:2 79:24 81:5,7

83:3 85:1 88:8

91:25 93:15,20

94:3,8,18 95:6,12

95:18,23 97:18

101:6,21 104:15

105:10,14,14,20

112:13 115:23,24

117:19 118:25

119:3,7 121:6

130:20 131:10,17

131:18 132:1

133:15 134:16

137:18 138:13

140:10,16 144:24

147:15 149:15

152:22 154:2,5

155:21,24 157:12

158:11,15 159:4

159:21 161:3

163:8,19 171:3,12

172:13 176:20,24

176:24 177:10

178:21 179:20

180:6 181:5

182:19 186:13

188:17,19 190:23

191:2 197:5,5

198:24 199:6,6

203:10 207:3,25

208:6 209:11

211:2 213:9,25

214:15 217:19

222:1 226:20,21

229:20 236:5,13

239:7,7,8 240:2,5

240:10,13 241:6,8

243:2 244:22

247:22,24 248:2

248:18 251:20

252:9,11 253:11

253:22 255:14

256:18,25 257:15

259:15 260:21

261:21,22 263:1

264:9 265:4

269:11 270:11,14

271:18 277:21

old 74:2 148:16

184:15 186:17

194:2 205:10

207:15 209:14,17

216:21 223:1

227:14 256:10

264:5

older 53:3 166:6

187:12,13 209:21

olds 53:2

oleo 138:20
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on-road 171:22

once 3:23 52:16

71:20 91:9 118:24

123:12 129:12

130:11 151:24

153:12,22 154:25

158:9 192:12

195:13 196:7

211:9,21 214:14

217:21 224:9,19

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264:19 269:13,20

publication 153:25

publicly 226:8

published 16:18

167:4 220:9

237:23 277:17

pull 55:1 119:9

121:14 128:12

133:9 134:3 140:4

275:22

pulled 210:11

pulling 74:25

pure 53:25,25

purpose 56:11 59:2

64:12,18,20 65:8

80:12,13 158:6

163:23 194:15

195:15,19 197:15

232:24

purposes 14:19

21:2 56:15 196:21

205:9 209:2

pursue 11:4 66:3

purview 185:11,16

push 76:11 91:12

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put 21:4 37:15

42:20 43:21 49:20

53:8,23 69:9 88:1

106:20 107:5

114:2,21,23

115:19 119:19

137:17 139:13

143:3,10 148:16

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191:6 208:8 211:6

211:25 226:8

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235:1,16 248:12

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179:10 186:11

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qualified 113:8

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234:11

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20:15 26:4 53:18

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170:1 173:14

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quantitative 37:15

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58:21 59:10,21

60:24 72:8,11,15

80:4 88:22 94:5

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105:12 115:20

126:19,21 130:1

137:10 142:11

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161:1 165:4

166:12,14,21

171:4,6,9 174:16

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180:2 183:4,18

189:21 193:24

194:14 197:21

198:4 203:20

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206:20 208:12,15

208:23 209:1

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218:2 222:8,24

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questioned 206:20

questions 11:7,11

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22:4 23:8,23

39:14,22 40:9

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quibble 210:1

quick 11:6 72:16

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quickly 80:16 89:7

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quite 10:11 12:23

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R 278:1

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177:8 180:8 181:5

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221:15 222:19,24

223:23 227:13

255:24 271:9,18

race 37:13,18

race/ethnicity

136:9

racial 167:12

radiates 223:13

Radiation 26:9

radically 234:21

raise 60:10 188:11

191:9 273:7 277:2

raised 79:25 263:4

Raison 138:1

RALEIGH-CARY

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ramifications

243:25

range 48:9,10 51:7

71:8 89:22 93:3,8

98:2 104:12

132:25 133:1,4

137:17 142:21,22

143:4,4,6 156:8

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rate 62:17 103:3

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ratings 50:14

ratio 167:3,3

rationale 109:5

118:20 244:4

ratios 168:11 231:3

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re-entrainment

179:22

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197:11 198:2

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reach 59:3,4 64:4

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reached 22:20 94:4

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reaching 102:21

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readings 73:22

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100:1 102:13

103:22,23 104:3

104:25 107:13

108:6 109:4

110:20 112:22

113:18 116:12

118:6 124:12

125:14,18 127:2,9

132:17 133:9,13

140:24 141:2,16

141:20 142:9

143:13,16 145:10

145:21,21,21

146:10 147:19

151:5 152:7

154:18 177:19,25

178:7,12,19

179:10 184:12

189:21 192:21,21

192:24 199:21,23

200:21 201:12

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210:19 215:3,3,6

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230:21 231:21

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242:22 243:14,15

243:17 244:10

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249:24 252:17

253:24 254:2

255:17 259:11

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rears 129:15

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122:18 128:6,8,11

136:17 212:15

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reasonable 36:20

44:5 62:3 70:3

79:4 82:2 93:22

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199:23

receive 3:7 19:11

116:2

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117:18 162:4

receiving 80:20

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227:24 277:23

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recognize 44:18

46:18 169:15

181:9 218:19

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272:12

recognized 69:3

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210:14

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185:7 210:18

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17:21 37:24 40:6

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271:23

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231:7

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270:16,21 271:22

reconsideration

183:9 255:21

reconsidered 59:16

reconsidering

35:13

record 131:1 154:1

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recoverable 144:20

Recurrent 156:8

recycle 98:20

266:24

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188:25 191:2

192:4,5

red 35:10 38:17,24

161:11,12

redistributes

127:15

redline 33:9 34:13

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reduced 178:10

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reduction 32:11

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reductions 170:24

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reference 52:12

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referencing 118:20

referred 169:2

referring 138:6

215:21

refine 139:23

reflect 11:21 30:1

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reflected 171:8

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165:6,12 166:8,16

167:17 168:4,8,11

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170:3 171:4

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175:20 176:2,4,7

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217:10,10 218:13

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245:22 246:3

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registered 3:8

regular 147:5

regularity 121:24

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regulating 264:21

regulation 166:3

190:17 237:15

247:18

regulations 238:16

238:25 243:3,4

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82:7 200:9

rehabbing 259:6

reinforces 234:5

reiterate 105:4

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215:22 252:17

related 32:20 35:4

35:16 36:6 48:14

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102:1 142:2

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relating 31:22

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81:21 96:16

103:15 146:7,9

152:20 167:25,25

168:1

relative 17:5 18:2

30:15 37:4,10,21

102:9 132:11

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relatively 35:23

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relay 187:6 201:8

relaying 152:14

release 143:18

relevance 144:16

144:16,21 148:21

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83:18 117:10

138:12 165:14

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reliable 91:19

232:6 255:19

reliably 55:18

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reluctant 10:22

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184:2,16

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168:8 169:25

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268:22

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remarkable 5:13

71:17

remarkably 102:4

102:19

remarks 3:10,17

13:11 57:20

155:20 181:11

remember 125:2

186:21 263:6

remembering

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remembers 229:19

remind 3:25

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reminded 276:4

reminder 40:6

72:23 157:12

reminding 125:8

reminds 14:18 83:9

226:7 248:20

remote 215:23

removal 100:21

178:3,5 185:19

removed 180:15

221:16

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removing 254:19

264:5

renal 33:15 35:14

46:15,16 47:21

48:18 59:19 68:7

render 93:23

rendered 23:17

reorganization

10:10 118:2

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reorganized 132:3

reorganizing

147:20

reparameterized

237:24

repeated 128:19

196:3 244:16

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report's 156:18

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Reporter 1:21

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reporting 141:4

reports 30:1 101:9

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representative

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representativeness

110:9,23

represented 90:3

representiveness

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represents 81:23

210:4

reproducible 93:17

reproducibly 82:7

194:7

reproduction 38:4

38:6 149:10

171:25

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require 18:16

227:6 233:19

243:4

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44:24 164:15

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212:19 275:1

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213:4

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2:19,25 3:2,22

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research 6:9,12,13

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88:2 101:19 147:7

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225:12,20 226:6

228:8,12 237:14

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reservations

125:20

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reservoir 221:4,8

resident 214:11,11

residential 167:11

residual 222:25

223:18 259:12

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resistance 35:21

126:6

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resolved 17:15

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resource 163:1

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respect 55:15 131:2

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responsibility

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restaurants 156:24

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result 17:10 18:13

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reverse 33:7,15

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48:25 49:5,12

101:10 122:25

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121:11 122:9

123:3,5,20,24

124:5,15 125:20

125:23 127:3,5

131:2,9 135:3

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122:13 124:13

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review 1:9 2:5,8

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18:17,22 19:15,24

20:15,22,22 22:8

22:10,15,16 26:15

28:12,25 29:23

41:1 55:20 56:10

67:1 77:11 111:14

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162:25 164:14,25

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166:22,23 167:4,6

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175:5,17,19 176:9

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225:15 232:21

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reviewed 56:22

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revise 164:16

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revisions 16:22

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29:15 30:3 38:2

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revisit 60:14

210:24 214:6

revocation 270:16

rewrite 228:25

rewritten 246:2

rewrote 247:4

rich 14:5 50:10

52:4 71:2 83:4

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208:1 211:2

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89:7

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52:11 64:13 66:14

69:11 72:12 76:12

76:18 83:3,7

89:16 90:21 91:14

92:8,10 93:20

102:10 103:15

105:16 110:4

118:17 120:4

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140:17 141:14,22

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142:25 143:12,15

143:20 144:7

153:20 158:12

159:4 160:11

161:6 162:23

176:24 178:19

180:6 190:4

192:18 195:2

196:22 197:6

204:15 210:21

211:6 212:9 213:2

214:8 217:11

224:6,7,22 225:3

228:1 229:8

240:23 242:20

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261:14 267:3

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rightfully 133:20

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ripple 116:22

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rise 21:12

risk 19:7 37:5,5

107:11 132:11

133:19 135:13

136:22 139:11

140:1,2,4 156:1,5

159:11 160:7

167:7 168:20,24

169:10,22,24

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174:15 176:6,11

184:9,11,13

186:16 187:25

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203:8 216:8,25

218:11 232:19,20

243:4,6 245:23

246:13 249:9

250:20 257:20,20

257:23 258:4,4

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risk-based 166:13

166:20 168:19

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132:4 135:20

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roadmap 68:3

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110:22 167:14

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roll 223:3

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room 42:11 243:17

Ross 27:6 44:13

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roughly 169:11

round 13:14 67:4

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rule 32:21 44:9

160:14,16 161:17

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SAB 4:2,7,11,13

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saltwater 38:16,19

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sample 58:8,11

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sampled 83:19

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samples 31:1

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78:15,21 79:8,9

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224:21 226:2

231:11 239:1

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214:21 215:7

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scale 32:10 133:10

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148:22 169:5

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schedule 60:17,18

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scheduled 72:12

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112:18 119:11

120:25 124:23

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selfish 8:13

semi-conclusion

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225:7 247:24

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solid 151:15

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solubility 143:10

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start 24:6 72:21

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149:13 158:17

160:1,3 161:4,5

196:12 228:5

242:22 272:12

started 75:19 93:11

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summarized 249:6

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271:22

supported 75:3

78:1 98:3

supporting 36:12

170:16 189:25

supportive 28:8

169:12 241:23

supports 40:10

100:13 170:6

suppose 63:20

222:19

supposed 262:8

supra-linear 243:7

sure 9:15 11:17

14:20 20:1 22:6

23:11 33:17 37:14

45:25 56:9 61:22

61:23 74:2,16

79:4 93:20 98:5

106:19 110:24

112:8 116:3

117:13 121:10,15

122:20 131:1

138:6 148:24

152:8,24 154:13

192:1 195:16

197:10 208:8

209:7 211:13

212:13 229:18

231:12 256:2,7

262:8 275:5

surface 85:4

173:19 214:23

surfaces 151:16

surprise 273:14

surprised 273:10

surprising 222:14

survival 38:3,6

149:8 172:1

Susan 14:10 42:16

105:17,19 130:21

131:13 154:17

241:3 260:23

263:5,6 264:10

265:5 269:10

Susan's 258:21

susceptibility 126:4

132:6 139:17

167:8

susceptible 264:19

suspect 60:17

70:24 123:11

222:15 227:18

suspended 84:9

85:24 150:24

Sustainable 15:21

sustained 25:21

157:25

switch 205:8

switched 89:11

symbol 149:4

symptom 115:9

130:7

symptoms 114:11

119:6

synergistically

276:18

synthesis 34:4 38:9

72:3 141:19

synthesize 83:4

synthesized 65:7

251:3

Syracuse 14:3 16:3

system 34:8,22

36:24 107:11,11

108:9 111:23

123:15 127:16

149:1 151:11

152:1,8 171:25

257:1 262:23

systematic 181:9

systematically

237:19

systems 43:18

143:9 146:3,4

148:15 152:9

T

T 278:1,1

table 8:18 13:15,24

30:25 32:25 33:1

33:3,8 34:19 37:1

41:11 45:21 49:22

99:18,22 103:19

105:1 119:18

139:10 145:17

174:24 217:24

234:15 239:16,21

240:8

tables 31:5 34:1

36:5,17,19 38:5,8

39:7 104:21

141:23 145:17

147:19,25

tails 147:24

take 7:16 13:19

16:11 43:2,14

58:3 67:4 70:14

72:10 91:11 98:6

104:1 105:16

111:20 112:22

113:7,24 114:16

121:8 124:13

140:18 142:18

149:12 157:2

160:12,20,25

162:9 203:6

227:21,22,23

231:20 239:14

248:11

taken 3:21 9:11

83:25 95:16

158:13 180:24,24

181:4 200:6

208:17 227:24

278:12

takes 4:25 27:19

28:11 60:5 106:8

230:8

talk 13:18,19,23

16:11 18:2 30:3

33:14,22 48:5

61:6 62:24 69:22

72:17 86:3,9

111:11 113:10

115:14 117:1

127:4,24 149:14

182:13 206:21

217:14 241:9

249:8 274:14

275:13 277:15

talked 106:12

107:7 135:10

145:24 146:25

198:8 215:4,5

225:10 226:12

245:15 275:11

talking 11:2 47:11

47:12,15,18 56:4

73:4 79:8 85:4,17

86:18,25 113:5,18

113:23 118:11

119:12 120:19,21

120:22 133:2

135:14 138:23

161:14 172:24

179:5 180:18

191:23 206:8

222:17 224:16,17

229:7 259:16

talks 62:10 103:20

121:16 145:11

208:24 214:21

215:21

tangent 225:14

tape 278:7,8,11

target 80:3 247:20

targets 82:24

task 108:3 238:11

tasked 275:18

team 4:24 27:9

28:10,11,13 163:2

teams 10:18

technical 7:25

16:13 38:9,11

77:19 164:8,12

technically 75:12

196:8

technique 192:15

techniques 88:11

92:13 193:15

205:17

technology 188:22

194:1,2,13

teens 258:25

teleconference

155:10

tell 20:8 45:24 46:5

55:9 106:17

108:21 116:10

117:20 123:1

132:15 162:23

205:21 223:16

telling 243:17

266:7

tells 123:2,2

tempering 180:12

tempo-complexity

166:1

temporal 214:23

temporary 51:22

ten 5:5 35:1 48:3

48:11 49:11 50:5

50:8 51:5,9,11

52:10 73:12 86:21

86:22 88:16 97:7

136:11 157:4,6

187:13 214:3

tend 17:13,18

19:19 92:15 136:4

tendency 71:8

78:20

tends 93:7

Tennant 159:16

164:2 171:3
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tense 200:4

term 85:21 86:11

86:20 116:13

123:5,19 130:14

terminate 123:10

123:13

terminated 23:13

terms 12:19 19:6

22:25 25:10 26:25

27:12 28:2,20,21

29:4,11 46:23

47:24 48:18 52:4

54:18 55:12 57:5

58:9 60:9 74:5

75:22 76:2 78:4

81:9 82:23 89:24

91:19 92:21 93:17

100:21 102:14,17

110:6 111:8 112:6

113:13 125:16

127:4,17 136:12

137:15 139:6

142:16 144:4

147:6 156:22

179:22 183:17,18

183:20 186:8,10

189:12,21 190:2

194:5 198:13

204:5 210:5

211:25 212:7

217:5 218:14

232:8 244:17

247:19 249:20

250:8,17 256:16

265:10

TerraGraphics

14:23

terrestrial 142:1

143:9 146:3 148:3

150:9 217:15

test 7:9 202:23

tested 143:10

testing 74:20

tests 53:25

Texas 79:1

text 31:8 33:8 35:9

36:17 99:20

108:11,21 112:2

115:7 117:14

118:11 138:19

226:10

Th2 35:19

thank 4:17,22,24

23:15,19,21 25:1

29:2,17 39:4

40:22 60:25 63:12

64:25 72:25 95:6

95:25 101:21

103:11 105:14,20

112:13,15 119:21

127:22 131:12

133:15 134:17

144:24 147:15

157:18,25 159:7

163:5 171:3

176:20,25 179:20

180:6 182:18,19

186:12 190:23

207:25 211:2

228:15 229:8

236:5,13 240:2

244:25 248:18

256:14 277:10,11

thanking 25:23

thanks 4:15 5:21

12:15 16:6 67:5

72:24 78:10 99:10

101:23 147:16

154:2 177:10

199:11 209:10

theme 130:19

theoretically

206:10

thereto 278:14

they'd 136:18

140:19

thing 6:16 43:11

50:1 58:17,19,23

59:21 65:18 74:14

84:9 85:15 86:25

87:25 103:12

111:22 122:22

126:7 136:4,7

137:24 138:23

139:4,23 140:19

152:23 178:12,20

189:1 199:25

201:25 204:23

206:15 207:6

208:21 215:10

216:9 225:11

228:1 229:16

240:23 260:11

261:12 265:8

267:6 274:18

things 8:22 9:1,7

9:14 10:25 11:3

12:19 21:15 22:23

28:18,19 35:16

41:3 44:17 52:24

53:2 55:5 58:25

61:2,19,20,25

62:1 63:23 67:8

70:1,6 78:22 87:8

91:15,21 93:21

94:10,10 103:13

110:22 114:7,7,14

114:24 115:9,10

118:19 127:4

131:10 133:10

134:19 135:8,10

135:16 139:12

142:4,6 144:22

155:2 157:17

187:16,19 189:22

193:10 194:20

195:1,20 203:13

204:7 205:2 210:7

210:17,20,22

215:20 217:14

226:2,22 230:15

233:25 236:3

246:8 249:7

251:15 260:16

262:2,7 264:18

270:4 276:9,18,23

think 3:13 6:1 8:19

8:21 9:13,17,24

9:25 10:5,15 11:3

11:23 13:1,4,8,11

16:23 17:13,14,18

18:1,5,18 20:24

21:11,19,20,22

22:6 24:5 25:17

29:7 30:9 36:20

39:9 41:7,14,16

42:3 43:13 44:17

45:23 46:4,9,10

46:20 49:2,3,15

51:16 52:20,22,24

53:4,6,7,9,12 54:4

54:6,9,18,24

55:14,22,24 57:1

57:2,19,22 58:6,9

58:23 59:5,13,20

59:21 60:14,20

62:12,16,20,22

63:1,3,13,14,18

63:23,24 64:2

65:5,10 67:12,18

67:19 68:9,9,11

68:13,23 69:18

70:11,21 71:2,4,9

72:7,7 73:3,5 74:7

74:8 77:4,10,12

77:25 78:2,11

80:1,4,11,17,22

81:3,8,13,24 83:7

83:10 85:22 87:15

88:8 90:2,7,18

91:7,17 92:3,6,15

92:23 93:11 94:1

94:3 95:12 97:21

98:1,11,14 100:5

101:18,19,20

102:1,17,20

103:10 104:4

105:6,23,25 106:6

106:9,10,20 107:1

107:2,7,13,14,21

107:24 108:6,9,18

109:3,8,13,14,17

109:22 110:2,8,22

110:24 111:1,5,13

112:1,2,8,9,10,16

115:7,15 116:6,13

116:14,18,24,25

117:10,15,17

118:2,4,22 119:5

119:16,23,24

120:1,17 122:7,15

123:17,20 124:1

124:17 125:22

126:2,5,8,12

128:21 129:2,21

129:22 131:1,4,11

131:17 132:17,23

133:17 134:11,19

134:23 135:3,8

137:5,13,25 138:2

138:11 140:3,7,8

140:9 143:1 144:2

146:12,14 150:20

152:7 153:2 154:5

154:18 155:15,16

155:18 157:2,13

157:23 158:3,4

159:21 163:4,4,9

177:11,23 178:8,9

178:20 179:1,10

180:1,4 181:3,24

181:24 182:2,4,14

183:2,9,10,13,14

183:22 184:9,10

184:18,25 185:5

185:18 186:5,22

187:6,18 188:10

188:15,18 189:1,5

189:20 190:5,6

191:2,8,10,14

192:2 193:4,14,23

194:5 195:19

197:8,13,17,18,18

198:10 199:5,20

201:3,21 204:6,15

205:3 209:9,13

210:23 211:10,12

211:18,24 212:14

213:5 218:10,19

218:22 219:3

220:2,5 221:21,22

223:15,18,19

224:5 225:14

226:4,15,18

229:21,23,24

230:2,16,19 231:5

231:8,22,25 232:1

232:3,5,6,8 233:1

233:4 234:3 235:3

235:12,14 237:7

237:25 238:3

240:1,15,21

242:14 243:22

245:9 246:7,7

247:10,13,17
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254:18 255:16

256:9 258:21

259:7,10,15,20,22

260:6,11,16,24

261:9 262:2,23,25

263:16 264:10,13

264:15,17,20,24

264:25 265:7,15

265:20 266:2,5,7

267:20 268:8

269:8,11,12,18,22

270:1,10,14,15

271:19,21,25

272:1,15,17,17,25

273:1,12,16,17,17

273:25 274:4,9,15

275:11,14 276:19

276:23 277:21

thinking 5:16 9:1

10:23 11:1 25:23

49:7 57:12,17

61:25 62:4 69:20

86:20 134:1

138:25 139:10

166:21 200:11

253:2 274:5

thinks 211:5

third 20:22 27:13

34:7,17 35:15,19

35:25 36:13 87:20

160:5 242:5

269:18 270:9

273:15

Thomas 4:9,11

thoroughly 84:23

thought 6:2 29:1

41:10 43:20 83:12

83:16 84:18 96:15

117:4 127:10,12

132:5 133:19

134:17 154:8,15

180:10 197:15

203:15,23 205:5

205:12,18 207:22

210:14 235:7

236:7,10,14,24

237:2 240:18

245:2 246:22

257:17,20 273:5

276:6

thoughts 80:10

121:9

thread 230:6

threats 261:24

three 32:19 57:9

87:14 89:17 99:16

100:21,23 142:22

145:2 189:21

201:13,16 203:18

212:2,19,19 213:2

213:3,7,8,10,15

213:22 241:2

243:18

three-decade 165:3

three-month

212:20,25 213:3

250:9 253:17

three-quarters

218:1

three-year 213:4

threshold 64:5

145:20 242:13,21

242:24 243:21

244:16

thrill 8:1

thrilled 8:6

throw 112:18

throwing 143:12

tie 215:23 261:14

tied 211:11 261:15

time 4:18 6:22 7:1

12:21 13:8 21:17

22:2 23:3 24:5

25:13,17 46:21

48:24 51:1 61:12

62:19,20 65:14

67:22 70:11 72:15

73:19 76:13 83:9

84:12 85:10 89:9

91:11 92:17,25

94:9 99:9 100:13

101:23 102:11

107:8 122:2 124:7

124:12,14 126:18

131:22 132:3

134:18 140:19

145:12 157:2,8,14

158:2 166:2,2,3

167:5,23 177:3

178:23 184:15,16

187:6,11,12

193:24,25 197:16

203:3 204:21

208:5 215:8

216:10 218:4,9

220:1 221:3,9,9

222:4 224:4 226:3

231:7 233:5

234:13 237:1,14

238:24 240:14,15

247:16 250:18

251:1,6 252:1,9

255:12,20 260:11

262:1,3,13,17,23

272:24 273:22,23

timed 100:9

timeframe 101:3

timeline 27:12,25

28:3

timely 234:20

times 6:8 122:10

189:5 190:16

192:19 210:12

235:11,12 238:13

timing 250:11

title 10:12,15 104:9

titled 156:7

tobacco 135:17,20

TOC 153:16

today 2:7 3:15,25

5:16 6:1 13:7

24:18 27:13 28:2

66:23 73:4 97:11

132:23 158:20

160:6 161:12

162:3 166:5

171:19 179:15

195:14 196:12

197:20 211:1

217:19 233:16

240:19 245:17

247:8,11 257:7

265:8 269:25

270:10 273:4

today's 29:21

168:15

toes 25:11

told 134:4 163:21

163:21 197:12

Tom 4:16 5:21

Tom's 25:20

tomorrow 2:7

24:13 146:12

158:22 159:1

226:3 267:19

273:4,6 274:14,20

277:16,23,23

ton 30:19 181:18

tone 23:9

tonight 40:8

tons 30:21 179:5,5

179:15,17 181:13

181:13 221:13

222:18 263:11,13

263:14,15

tools 82:20 194:17

257:14

top 114:10 138:24

207:18 214:22

topic 17:25 89:18

99:13 109:9

225:21

total 31:17 71:6

90:2

totally 66:11,16,24

98:24 210:10

totals 30:20

touch 13:11 164:3

174:23 187:16

touched 134:24

275:20

touches 60:19

touching 163:23

tough 25:16 247:16

tougher 8:20,21

toughest 6:25

toxic 44:16

toxicity 48:1,18

toxicokinetic

123:12

toxicokinetically

123:16

Toxicokinetics

31:13 95:20

toxicological 42:1

49:10

toxicology 14:14

15:1,10 33:17,22

34:11 42:25 48:6

51:8 112:2

trace 224:25

track 111:18

tracked 216:13

trackers 187:2

tract 81:15,20

91:22,24

trade 66:1

traditionally 13:14

166:18

trails 207:18

trajectories 124:7

trajectory 124:14

125:13

transcribed 278:8

transcription 278:7

transfer 81:16,19

168:13

transferal 85:10

transferred 82:14

translation 230:22

230:23

transparency

29:24 36:4 49:21

52:13 69:7 71:6

71:23

transparent 69:3,9

71:10 106:2

transport 89:21,23

90:8,19 145:5

Transportation

202:15

transported 83:21

151:1

transports 151:7

trauma 135:15

travel 191:23

treated 209:17

treating 82:17,18

134:18
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tremendously

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Triangle 25:3

tried 9:15 47:5

126:24

trimesters 250:20

trite 219:13

trivialize 180:22

trouble 37:20

true 44:13,18 59:6

61:21 81:4 124:17

224:15 250:13

truth 7:17 65:24

try 40:8 44:25

53:10,23 55:3

56:1 67:14 74:15

82:21 125:8

137:19,20,25

139:23 140:7

146:7,8 155:24

158:21 166:10

217:4 218:14

238:15 270:6

271:20

trying 28:20 55:3

56:2 58:19 73:13

93:21 105:22

107:8 126:19

133:6 137:5

145:25 146:18

247:9 251:2

TSP 85:21 86:1,3,3

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90:4 93:4,16

193:22 195:18

205:20 206:3,12

TSP's 93:9

tunnel 74:20

turn 4:10 5:19

24:19 29:13 40:20

62:8 129:8 157:10

159:5 163:8

166:18 171:1

241:7

turned 110:16

turning 104:18

turns 208:25 267:9

TV 223:7

Twain 256:17

tweak 207:23

tweaks 199:19

two 20:7 30:19

34:19 46:14 49:19

50:9,11 60:6,22

63:23 70:22 71:9

71:25 78:17 79:3

79:23 97:8 100:21

106:19 109:20

110:2,4 112:6

113:14 114:14

120:6 122:1,5

124:19 134:2

142:22 148:21

153:10,10,18

167:24 169:1,5,11

169:15 175:12

176:5 186:24

187:19 190:24

196:1,25 199:12

203:3 204:8 223:1

243:10 244:2

253:18 259:1

264:10,24,25

265:2 269:1,17

273:13

TXP 81:25

type 44:25 50:22

types 6:21 50:9

116:15 149:11

167:24 220:10

typewriting 278:9

typical 83:22 222:5

typically 18:15

58:7 93:15 100:17

104:7,9 128:7

143:17 233:19

typo 62:9

typos 21:16

U

U.S 1:7 96:19 97:11

149:6 178:23

185:19 190:4,10

191:11

ultimate 106:24

221:12

ultimately 4:21

64:21 103:15

uncertain 35:16

130:15 233:17

245:18

uncertainties 31:22

62:5 102:21 168:7

168:11 169:23

170:19 175:19

176:12 233:9,13

233:22 241:19

246:19 251:16

260:13,20

uncertainty 32:14

60:6 74:5 79:16

79:21 122:12

129:23 130:2

168:16 169:25

170:1,20,23 180:5

183:11 185:1,3

218:11,18 219:9

235:9 245:12,21

249:15,16 250:3,4

250:11,21 251:5

251:13

unclear 42:5 128:5

152:21 173:21

uncomfortable

70:7 260:12

262:19

uncover 207:12

underestimating

90:7 220:23

undergo 20:14

undermine 110:12

underscore 255:15

understand 45:25

75:12,14 78:3

80:18 104:16

118:10 133:5

145:25 146:8

152:8,9 192:20

198:14 208:7

231:11 253:1

254:12,14,16

261:2 276:10

understanding

90:24 179:4 182:2

204:8 247:1,6

260:24

understood 73:16

80:1 84:23

undertaking 73:20

75:18

undervalue 110:25

underway 77:19

unfortunately

76:13 258:23

UNIDENTIFIED

94:22 202:8,12

unintelligible 44:17

52:15 61:8 71:19

71:22 83:2 84:19

85:1 88:5 90:10

94:2 96:6,12 97:5

98:4,16 99:4

100:5,12,22

101:11,13 103:8

103:21 104:2

105:2 108:20

111:19 114:1

117:17 118:23

120:1,15 124:9

126:1 127:8,15

129:11 130:10

131:8 133:3

135:22 136:1

138:3 139:12,18

143:14 148:10,20

148:25 149:6,23

150:24 151:16,18

151:23 152:4

153:6,11,21

154:24 158:8

178:18 179:23,23

180:15 181:1,12

181:20 182:11

185:8,22 187:11

188:8,14,24

189:13 190:22

192:11,21 193:8

195:8,12,21 196:6

196:10,17 203:12

204:25 205:6,9

206:3 208:2,7

210:13 211:8,20

212:5 214:13

215:12 216:18

217:8,11,19,20

219:20,22 223:4

223:14 224:8,18

225:3 228:13

229:1 231:23

234:25 237:2,6,22

239:5,10,12,19

248:7,17,23 253:3

255:6,10 260:12

261:11 266:6,8,13

266:15 267:4,13

267:22 268:13

269:5 272:9,14

275:8

unintended 186:5

188:12 226:11

Union 26:25

unique 6:22 118:14

177:19,20,24

178:19,21 190:1

208:22,22 256:25

uniqueness 179:12

185:6

unit 90:2

United 26:19 47:13

66:13,14 136:11

136:13 146:20

147:3,6 178:4

185:20,25 188:23

191:22,24 216:5

266:25

units 38:12 78:23

84:24 141:5,7

210:18

unity 150:16

University 14:4,9

14:14 15:4,9,14

15:19,22 16:3

unknown 173:7

203:1 235:10

unproven 142:14

unresolved 260:17

unsorting 125:15

unsuccessful 9:12
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update 30:23

184:13 187:14

189:11

updated 29:25

136:9 237:24

upper 144:12

169:16,19 206:9

urban 79:13 85:5

90:13 151:12

169:2,7 215:9,9

216:14 219:15,16

221:13,16,17

urge 74:12,18

111:18

usage 173:11

191:22 214:24

use 14:20 15:16

19:6,6 25:12

53:20 65:19 66:12

66:19 85:22 86:5

95:8 96:18 102:22

110:14 116:13

117:2 123:19

136:9 138:12

152:13 185:4

193:19 196:13,20

201:16 202:11

205:3,20 206:12

215:24 220:16

229:17,19 236:8

238:17 240:15

262:12,16 266:7

274:8

useful 23:17 57:3

60:7 62:5 82:9

85:19 99:6 134:13

156:11 197:2

200:25 201:9

205:18 209:5

216:17 248:10

useless 192:16

194:6,9,12

uses 66:14 86:11

128:2 221:18

usually 18:17 117:2

V

vague 246:23

valedictorian

125:10

valid 110:16

156:18

validate 74:9

validity 110:9,19

valuable 12:23

273:19

value 7:2 9:13

208:25 209:4

210:5 212:3

273:14,16,17

values 145:13

149:3,5 182:14,15

208:24 209:2

210:19

Vandenberg 24:21

25:1,2 39:4 45:2,9

45:12,24 49:25

56:7,10 64:6,14

64:17 67:6,8

88:20,21 98:18

104:7 116:1,3

117:25 119:8,17

119:20 137:2,23

139:15,22 157:22

Vanderpool 93:1

Vanessa 4:6 5:4,4,8

7:20 8:17 11:19

13:1 25:17,18

variability 53:18

54:4,24 126:10

variable 91:1 126:3

126:8

variation 181:21

variety 6:6 7:5

53:17 116:21

126:13 252:25

various 17:10 41:9

69:25 83:17 98:9

142:2 174:14

177:20 179:12

185:2 188:5 200:9

201:6 217:14

231:23 257:13

260:25 261:1

vary 141:17 142:19

173:5

vegetables 79:13

79:19 80:19

velocity 90:9

venue 275:22

verbal 108:3

verify 232:11

Vermont 14:6

version 22:11,12,13

32:17 33:9 34:13

40:9 75:24 87:12

106:6 200:12,13

201:18 203:19

275:4

versions 31:5

140:24

versus 42:6 53:6

54:20,20 57:6,6

71:5 79:9 89:10

92:23 93:12

116:14 131:5

137:18 138:14

139:17 204:5

205:15

victory 258:13

view 13:4 66:9 68:4

132:17 134:19

210:22 229:21

241:21 242:25

244:3 245:20

248:6 249:22

260:18 270:4

views 175:25

176:16,18 234:19

242:8

violation 201:13,14

violently 148:4

virtually 177:22

vision 180:25

visit 99:5

vital 134:12

Vu 4:6

voice 155:24

180:11

volume 148:8,13

183:15 195:18

volunteer 10:4

226:10

von 11:16,18 13:9

14:21,22 40:3

64:24,25 67:17

95:22 101:22,23

177:8 182:20,21

186:15 187:1

188:17 189:19

197:7,8 226:9,17

226:19 276:2

vote 271:17

vs 173:18

vulnerability 132:5

132:18 139:17

W

walk 157:5 171:13

walked 157:3

walking 39:6

wall 242:20

walls 25:25

Wanda 1:21 278:5

278:18

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8:25 12:18,25

13:19 19:5 23:15

25:12 37:25 39:8

53:8 54:9 56:3

59:24,25 60:22

62:17 63:18 65:4

67:15,17 68:6

71:11 77:2,24

78:11 79:5,7,7

80:8 85:22 88:20

88:23 90:5 93:15

93:24 94:1 98:16

104:3 105:6,11

110:4 113:10

116:1,10 121:8

122:8 124:2 125:6

126:16,17,18,23

127:6 128:11

130:25 139:2

158:2 159:22

161:19 162:13

177:11,18 191:6,9

195:23 196:22

205:8 206:13

207:18 208:8

211:13,22 212:13

214:2 224:3

225:16,17,25

226:1,13 228:4

229:17,18 232:5

232:15 238:21

243:17,22 251:11

253:12 255:15

256:15 261:25

262:13 263:3

266:3,7,25 271:15

273:7 277:8

wanted 8:3 16:11

19:20,24 37:2

39:1 41:17 43:11

46:22 78:13 92:11

103:12 105:7

121:10 152:25

154:1 179:19

180:11 186:14

188:10 189:14

196:24 203:14

215:6 220:6,7

226:7 228:7 229:4

231:10 266:24

273:3 275:7

wanting 70:24

226:5

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72:22 112:19

115:21 187:24

277:1

warrant 198:17

warranted 198:6

233:5

wasn't 7:2 32:6

96:3 124:22,23,24

144:14 180:14,15

184:21 197:16

198:22 199:23

Wasserman 15:18

15:18 50:13 52:6

52:25 54:17

113:10,13 115:7

117:13,19 118:8

118:12,22 119:1,4

120:11 124:4

127:23 128:20

129:13,18 130:6,9

131:24 133:16,17

136:21 154:20

163:3 229:11

239:9,10,16,21
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waste 209:19 224:3

wasting 144:20

watch 129:19

watching 256:18

water 6:7,8,21

146:3 150:12

173:19 219:2

222:4 224:7 225:3

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way 5:9,24 24:9

26:7,25 28:6

34:17 40:23 54:7

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57:24 58:15 62:4

63:10 70:12 71:2

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113:1 114:1

116:15,16 118:2

118:18 119:21

120:16 126:25

133:6 138:5

139:13 143:6

152:18 162:14

180:22 181:16

186:8 193:14

195:18 199:21

200:7 201:23

205:22 206:6

208:4 216:1

221:16 228:13,13

230:11 235:8,18

236:20 244:12

246:23 248:2

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270:17,25 271:21

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ways 12:14 16:23

19:10 29:20 77:25

92:14 116:6,21

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227:1 233:21

239:2 240:22

253:15 270:18

we'll 11:2 13:23

29:20 37:25 39:1

40:4 54:22 60:21

62:24 92:15 93:14

95:14 111:11,20

141:1 155:7,10

158:4,17,20,23

160:6 161:13

168:22 171:13

177:5,5,6 184:6

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227:23 248:2

262:14 269:6

271:6 277:18

we're 3:14 5:15,15

12:23 20:24 21:20

23:21 24:5,17

27:13,23 28:19

30:23 33:18,24

35:3 37:16,21,23

38:3 39:12 40:14

42:3,3 48:13

51:20,22 54:6

55:3,16 60:16,17

61:9 64:5 69:20

69:23,24,25 70:6

70:8,24 72:4,7,13

72:17 73:4 76:17

77:10 79:8 85:17

86:2,15,24 89:12

90:7 93:19,23

102:2,16 104:1

106:10 112:11,25

113:18,22 116:9

117:22 119:12

123:13 126:19

133:6 135:2 137:5

138:23 140:8

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156:23 158:10,11

158:21 161:9,9

162:1,13,17 171:4

175:2,24 176:7,15

180:18 184:2,15

187:12 189:6

191:10,11,12

192:4 193:19

195:4 200:3

204:20 206:8,12

207:16,17 219:22

219:23 222:17

226:2 227:11

237:13,16 240:14

242:15,18,20

243:13 244:20

250:14 254:22

255:18,19 256:19

258:22 262:8,8,23

264:6 265:9,12,12

265:13 266:5

267:20 268:4

269:11,22 270:10

270:20,24 272:10

272:21 273:25

277:22,22

we've 12:19 18:8

18:23 21:19 22:20

23:5 28:23 29:10

29:15,23,25 30:6

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31:19 32:13 33:4

33:8 34:3,5,7,10

34:18 36:16 37:1

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56:23 67:12,13,15

69:9 72:7 73:15

74:16 86:14 87:22

89:8 90:20 93:11

94:3 112:20 118:1

118:3 119:12,13

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135:10 137:3

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211:11 216:10

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255:25 257:5

264:13 266:4

270:22 272:1

273:8 275:20

276:3 277:13,14

weak 184:11

weakness 92:9

109:4

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wealth 65:6 102:7

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163:4,8,18 196:24

268:11,15,18,23

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275:1,7 277:9,11

weigh 55:5 94:7

104:3 105:11

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weighted 232:1,6

weighting 232:7

Weinstock 159:18

197:1

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69:8,18 71:13,16

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131:24 134:17

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welfare 17:9 172:9

174:13 176:6,8

188:4 202:21

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well-characterized

233:2

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well-established

130:13

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77:11

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well-written

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went 36:8 41:12

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226:10,15 240:17

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winter 87:19

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25:6 26:14 50:4

58:14 73:17,19

74:14 77:18 82:8
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87:23 98:9 112:19

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146:19 159:11,13

162:4 163:1

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younger 53:1

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243:4,6

zinc 87:14 181:15

217:17

zincs 190:2

zone 106:21,24

107:4,6 112:10

zones 108:18

0

0.0 97:25

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016 258:17

03 220:21

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1 9:6 30:1,6 39:24

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138:21 143:7

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198:25 199:3

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1,000 271:6

1,036,000 144:11

1,600 224:1

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1:5 238:13

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74:10 79:3 82:6

90:15 184:15

218:23,25 219:15

222:6,14 258:3

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100 61:21

108 16:18

109 82:16 267:7

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114 62:8

1188 1:22 278:6

12 206:5,5,5,11,16

12:44 158:14

14 119:9,12

15 73:25 74:1,2,10

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75:18 80:2,15

81:4,23 89:20,22

90:8 91:1 93:3

97:14 184:15

206:8,8 218:25

258:4 264:2,12

265:16 274:3

15-ish 89:25

15-minute 227:22

16 30:10 49:25

17-23 235:9

18 206:5,6,11,16

237:22

188 268:4

18th 137:10

1970 252:23 268:5

1970s 187:3 210:21

1978 164:24,25

1980 222:2

1986 30:22

1990 153:25 268:19

268:24

1990s 187:4

1st 155:10

2

2 30:1,6 36:18,20

39:25 41:11 45:19

49:16 51:18

106:13 126:25

143:8 150:3 154:9

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155:4 158:21

175:6 182:13

199:7,7,12 208:10

211:6,25 212:12

214:16 226:22

238:11 242:17

247:23 255:18

260:3

2-22 208:21

2-27 214:20

2-3 33:21 245:11

2-36 214:21

2-37 214:22
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2-71 121:18

2,000 41:1

2.1 231:8

2.2.1 208:16

2.2.1.3.1 209:10

2.2.1.3.3 208:21

2.2.2 208:12

2.5 82:7 93:15

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123:24

2.9.7 150:3

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20 21:24 40:23

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83:20 84:7 89:21

89:22 90:11 91:13

92:19 93:8 133:2

184:15 206:8

219:15 237:23

247:24 258:4

20,720 144:11

2000 136:10

2000's 189:17

2001 215:5

2003 186:22

2005 45:7 186:22

2006 65:22 172:19

172:23 184:10

2007 168:22,22

170:16 172:23

2008 32:21 161:7

165:1 200:1 227:9

265:9

2009 121:25

2010 227:8

2011 201:2

2012 156:6

2013 1:14 200:3

2014 161:18

2017 237:22

21 74:1

22 235:9,15

228 206:21

231 201:10,24

202:6,10,17

24 90:16 234:16,20

25 33:23 48:4,6,12

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28 182:13

3

3 6:9 30:11,13

31:18 62:8 72:18

73:2 78:12 140:23

146:25 154:7,17

158:21 175:12,12

209:12 227:23

228:2 229:9,20,21

231:15 236:7

240:6,11

3-107 87:3

3-2 234:15 239:16

240:8

3-21 234:15

3-5 30:17

3.4 30:24

3.4.1.1 73:8 75:4,8

3.5 31:2

3.6 30:20 67:10

3.7.3 75:2

30 6:5 33:23 47:14

47:14 48:4,6,13

73:24 90:11

135:21 190:21

219:15 220:20

30-plus 5:4,5

314 1:24

321 234:15

325 87:2

33 245:19

35 245:19 262:7

366 78:13

368 83:17

38 209:1

4

4 30:14 31:12,18,25

32:14 79:2 95:20

96:1 105:11

158:23 175:12,21

211:12,16 212:8

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232:14,16,18

238:5,23 240:16

240:19,22 245:1

245:10 251:21

277:14,15,16

4-1 217:24

4-11 32:2

4-12 32:9 103:19

4-14 33:1

4-144 103:20

4-22 97:24

4-24 97:24

4-28 245:11

4-32 245:19

4.1 30:13

4.1.3.4 156:11

4.3 244:3

4.9 99:18

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40 11:22 92:17

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42 10:12,15 268:7

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5 1:14 30:2 33:4

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60:19 105:16

108:11 121:25

130:21 158:23

176:5 184:15

206:2 218:25

230:10,13 233:8

234:12 237:6

277:18

5-17 41:11 45:22

119:18

5-3-12 121:16

5:30 240:16

5:37 277:25

50 92:15 206:1

51 61:22

6

6 37:14 57:12 81:18

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7

7 30:2 38:1,13 90:9

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70s 268:20

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75 222:7

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8 6:1 57:10,12 59:1

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9:30 24:7

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90s 50:6,19 52:7,12

95th 208:14

98 208:2