Document jmmzkezrRG0LezyDkmvOamzNQ

FROM; Ext. 366-3951 RON SNEE Engineering Department Uuviers 3170 I j TEH 0470170 % PUBLISHED BY THE AMERICAN CHEMICAL SOCIETY Russell P. Christman, Editor Environmental Science & Technology 1155 SIXTEENTH STREET, N.W. WASHINGTON, D.C. 20036 Phone (202) 872-4544 March 10, 1981 Mss. No. ESO-242 Dr. Ronald D. Snee Engineering Department E. I. du Pont de Nemours & Co. Wilmington, Delaware 19898 Dear Dr. Snee: Your manuscript entitled DEVELOPMENT OF AN AIR QUALITY STANDARD FOR LEAD FROM COMMUNITY STUDIES has been examined carefully by the Editor and has been referred to reviewers for comment. On the basis of this study, the Editor has decided that the paper is not acceptable in its present form and requires major revision before it can be considered further. Reviewer comments and editorial recommendations are attached. Please con sider carefully all suggestions, and either make appropriate changes in the manuscript or provide suitable replies. If comments call for clarifying Statements, these should be included in the manuscript. Further consideration is contingent upon revision and/or rebuttal that will overcome the reviewers' criticisms. Additional review and revision may be necessary before a final decision can be made. The next review of the paper will be expedited if you will send us three copies of the revised version, an itemized list of changes made in the manuscript, and your answers to the criticisms. Very truly yours, MC/tp end. Monica M. Creamer Editorial Assistant TEH 0470171 DUP050082990 N42430.Q1 ENVIRONMENTAL SCIENCE AND TECHNOLOGY X PLEASE RETURN ORIGINAL AND ONE ANONYMOUS CARBON MS NO. ESO-242 AUTHOR Ronald D. Snee ,, ,, g m * TITLE DEVELOPMENT OF AN AIR QUALITY ^STANDARD FOR LEAD FROM COMMUNITY STUDIES .. <* 1 ACCEPT Q COMMENTS - -- 4 ACCEPT AFTER REVISION Q * REJECT K M \ * Z>; ri~"r ...." ________.________ . ..................... w- Hie paper Is "neither'a review nor a report of original research. Whilst it has some merits as a discussion of the bases available for standard setting, it is not appropriate for publication in Environmental Science and Technology. There are some scientific weaknesses: 1. Page 4, section 3. The Azar study has been criticised by Hammond in the OSHA Preamble (Federal Register 43^ (225) p 54403). In that study, variations in the contribution of lead from sources other than air were so great that the confidence limits for the regression were broad. Hence the value of B In equation (1) will be variable and both this and the coefficients in the equation will be subject to considerable uncertainty. The variability of B would seem to invalidate equation (4). * 2. Page 5, Section 3. The author cites Chamberlain et al. as the source of a blood lead-air lead slope of 1. More recent studies by Chamberlain et al_. (Investigations into Lead froto , Motor Vehicles, U.K. Atomic Energy Authority Report AERE-9198 (1978)) suggest a ratio of ca. 2. The study of Rabinowitz et al. (J. Lab- Clin. Med., 90, 238-48 (1977)) suggests a ( ratio of 3.5 and indeed most studies imply a ratio of >1. The value of this ratio is fundamental to all standard setting and it is unreasonable of Snee to select a value suiting his own case. ^ ,--- 3. Page 5, section 4. The author uses corrected data to derive the blood lead distributions from the Azar data. The validity of the derived distribution will depend upon the validity A* of the model used to correct the data. It is. not 'possible, to judge .this without seeing . reference 7, which Is not yet available. !" - 4. Page 6, section 4. (.and elsewhere) The author concludes that the Pearson model provides the best fit to the data. He does not, however, provide any evidence to support this assertion. He also does not provide a formula for the best fit Pearson model, whereas he does provide formulae for the other more common models. . 5. Page 13, section 8. The author dismisses the log-normal distribution for blood leads on the basis of Table 6. This does not seem to provide strong evidence for its rejection. Indeed, on most occasions it seems to be perfectly valid. This sort of ezercise would have -to be carried out on far more data to be able to reject the fairly simple log-normal model. The author also states "it is important to note that in several instances the skewness is in the negative direction". He uses this to explain away the lower air quality standards derived in Tables 4 and 5, Yet the data in Table 6 show positive skewness to occur as often as negative, so why is only the negative skewness important? 6, Page 15, Discussion* The author directly compares an air quality standard derived frcfa ' ` his "data"with' that of the EPA. Yet the two are riot directly ccaiparable, as the author himself admits Immediately below. Such a comparison is misleading and should not be made. The implication is that the EPA standard is too low and this seems to emphasise the political nature of the paper. 0470172 DUP050082991 N42430.02 ENVIRONMENTAL SCIENCE AND TECHNOLOGY PLEASE RETURN ORIGINAL AND ONE ANONYMOUS CARBON MS NO. KSO-242 AUTHOR Ronald D. Sb m TITLE DEVEU5PHI3NT OP AN AIR QUALITY STANDARD FOR LEAD FROM COHHONITI STUDIES ACCEPT ACCEPT AFTER REVISION^ , REJECT f~| COMMENTS 1% baa bean several years since .1 have been involved .with environmental stadias of load. I would recsqwraend .further .review by people actively involved in such stadias. I do have some general ceraaants* ,, , *. . The objective of this work is .dissociate air .lead .from background lead in relation to blood lead levels, in .order to -establish a quality standard toe acceptable air lead levels. JEbis .leads at .once to several problems*. 1* Is the IQS to be established by stadias involving the .entire population, or a selected population such.as children? . 2... .Has it beta demonstrotedthat children can stand the sane lead levels as adults or are they more susceptible, for example beaavise they have^a more active calcium metabolism?. .3. . Blood lead levels represent an indeat of recent .exposure, while the 24-hour .samples represent average exposure. Jfs .the ."time constant*; .for blood lead long in relation to 24 hours? If not,, one has to deal .with peaks of air lead during high traffic periods and whether sjjefa peaks .represent a hazard or not. ... Perhaps questions like this could .at .least be mentioned to point out the cccplexity of establishing AQ&. . It .does appear -that '.if .the basic assumptions are aodented, the authors have JMde a .case for less restrictive AQS, .and it is only fair to point these out- , .. .... ... -------- ... --... 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