Comments on: Chari, R.; Burke, T.A.; White, R.H.; Fox, M.A. Integrating Susceptibility into Environmental Policy: An Analysis of the National Ambient Air Quality Standard for Lead. Int. J. Environ. Res. Public Health 2012, 9, 1077-1096

Abstract: In their recent article [1], Chari et al. call attention to the important subject of setting National Ambient Air Quality Standards (NAAQS) to provide requisite protection for public health, including the health of sensitive groups, as specified under the Clean Air Act (73 FR 66965) [2]. The authors focus on consideration of susceptibility to inform policy choices, using lead (Pb)-related neurocognitive effects and children from low socioeconomic status (SES) families in the context of alternative Pb standard levels. Our comments focus on the authors’ analysis of the scientific evidence and not on policy. We agree with the authors that the health effects evidence for Pb indicates a role (or roles) for SES-related factors in influencing childhood Pb exposure and associated health effects. We disagree, however, with the authors’ interpretation of the literature on SES influence on the shape of the concentration-response (C-R) relationship between children’s blood Pb and IQ (e.g., steepness of the slope). We further address aspects of the scientific evidence that are important to the consideration of sensitive populations in the context of the Pb NAAQS, and how the U.S. Environmental Protection Agency (EPA) considered this evidence in setting the Pb NAAQS in 2008.