Federal Regulations for New Source Performance Standards

Section 111 of the Clean Air Act Amendments of 1970 authorizes the U.S. Environmental Protection Agency (EPA) to impose emission standards (NSPS) on those stationary sources that are determined to be significant contributors to air pollution and that consequently endanger the public health or welfare. In five years EPA promulgated 19 final and 1 proposed NSPS for stationary sources. Section 112 of the Act authorizes EPA to promulgate national emission standards for hazardous air pollutants (NESHAPS). EPA promulgated three final and 1 proposed regulation under Section 112. In addition, EPA promulgated NSPS for three "designated" pollutants from specific sources under Section Hid. EPA’s use of Section 111 and 112 authority provides for a quick response emission control program compared to the relatively slow process of establishing additional ambient air quality standards and having the states adopt implementation plans (Section 109). Three court cases, argued in the U.S. Court of Appeals for the District of Columbia, established basic guidelines for future promulgation of NSPS although certain legal actions are still pending. Proposed amendments to the Clean Air Act would further broaden and strengthen EPA’s direct regulatory authority.     

Impact of three interactive Texas state regulatory programs to decrease ambient air toxic levels

The Federal Clean Air Act (FCAA) framework envisions a federal-state partnership whereby the development of regulations may be at the federal level or state level with federal oversight. The U.S. Environmental Protection Agency (EPA) establishes National Ambient Air Quality Standards to describe “safe” ambient levels of criteria pollutants. For air toxics, the EPA establishes control technology standards for the 187 listed hazardous air pollutants (HAPs) but does not establish ambient standards for HAPs or other air toxics. Thus, states must ensure that ambient concentrations are not at harmful levels. The Texas Clean Air Act authorizes the Texas Commission on Environmental Quality (TCEQ), the Texas state environmental agency, to control air pollution and protect public health and welfare. The TCEQ employs three interactive programs to ensure that concentrations of air toxics do not exceed levels of potential health concern (LOCs): air permitting, ambient air monitoring, and the Air Pollutant Watch List (APWL). Comprehensive air permit reviews involve the application of best available control technology for new and modified equipment and ensure that permits protect public health and welfare. Protectiveness may be demonstrated by a number of means, including a demonstration that the predicted ground-level concentrations for the permitted emissions, evaluated on a case-by-case and chemical-by-chemical basis, do not cause or contribute to a LOC. The TCEQ's ambient air monitoring program is extensive and provides data to help assess the potential for adverse effects from all operational equipment in an area. If air toxics are persistently monitored at a LOC, an APWL area is established. The purpose of the APWL is to reduce ambient air toxic concentrations below LOCs by focusing TCEQ resources and heightening awareness. This paper will discuss examples of decreases in air toxic levels in Houston and Corpus Christi, Texas, resulting from the interactive nature of these programs.

Implications: Texas recognized through the collection of ambient monitoring data that additional measures beyond federal regulations must be taken to ensure that public health is protected. Texas integrates comprehensive air permitting, extensive ambient air monitoring, and the Air Pollutant Watch List (APWL) to protect the public from hazardous air toxics. Texas issues air permits that are protective of public health and also assesses ambient air to verify that concentrations remain below levels of concern in heavily industrialized areas. Texas developed the APWL to improve air quality in those areas where monitoring indicates a potential concern. This paper illustrates how Texas engaged its three interactive programs to successfully address elevated air toxic levels in Houston and Corpus Christi.     

Contemporary threats and air pollution

It is now well understood that air pollution produces significant adverse health effects in the general public and over the past 60 years, there have been on-going efforts to reduce the emitted pollutants and their resulting health effects. There are now shifting patterns of industrialization with many heavily polluting industries moving from developed countries with increasingly stringent air quality standards to the developing world. However, even in decreasing concentrations of pollutants, health effects remain important possibly as a result of changes in the nature of the pollutants as new chemicals are produced and as other causes of mortality and morbidity are reduced. In addition, there is now the potential for deliberate introduction of toxic air pollutants by local armed conflicts and terrorists. Thus, there are new challenges to understand the role of the atmospheric environment on public health in this time of changing economic and demographic conditions overlaid with the willingness to indirectly attack governments and other established entities through direct attacks on the general public.     

Quantification of ozone levels in indoor environments generated by ionization and ozonolysis air purifiers

Indoor air purifiers are advertised as safe household products for health-conscious individuals, especially for those suffering from allergies and asthma. However, certain air purifiers produce ozone (O3) during operation, either intentionally or as a byproduct of air ionization. This is a serious concern, because O3 is a criteria air pollutant regulated by health-related federal and state standards. Several types of air purifiers were tested for their ability to produce ozone in various indoor environments at 40-50% relative humidity, including office rooms, bathrooms, bedrooms, and cars. O3 levels generated by personal wearable air purifiers were also tested. In many cases, O3 concentrations were well in excess of public and/or industrial safety levels established by U.S. Environmental Protection Agency, California Air Resources Board, and Occupational Safety and Health Administration. Simple kinetic equations were obtained that can predict the steady-state level of O3 in a room from the O3 emission rate of the air purifier and the first-order decay rate of O3 in the room. The additivity of O3 levels generated by independent O3 generators was experimentally demonstrated.     

Development and implementation of surface water quality standards for protection of human health in Korea

Current water quality standards for the protection of human health in Korea include 17 substances found in rivers and streams. Due to increasing concern over the release of hazardous chemicals into the aquatic environment, there has been a demand for additional water quality standards. Therefore, the Korean Ministry of the Environment plans to gradually increase the number of water quality standards to 30 substances, including 22 substances for protection of human health and 8 substances for protection of aquatic ecosystems by 2015. In this study, new water quality standards for protection of human health were established for 1,4-dioxane, formaldehyde, and hexachlorobenzene. We selected candidate hazardous chemicals, conducted a human health risk assessment to determine priority chemicals, established water quality standards based on technical analyses and comparison with domestic and developed countries’ water quality standards, and conducted an expert review. Water quality standards for protection of aquatic ecosystems will be derived in the near future. This study describes how the water quality standards for protection of human health were developed and implemented. Current status, recent expansion, and future plans for water quality standards in Korea are also covered.     

Analysis of primary fine particle national ambient air quality standard metrics

In accordance with the Clean Air Act, the U.S. Environmental Protection Agency (EPA) is currently reviewing its National Ambient Air Quality Standards for particulate matter, which are required to provide an adequate margin of safety to populations, including susceptible subgroups. Based on the latest scientific, health, and technical information about particle pollution, EPA staff recommends establishing more protective health-based fine particle standards. Since the last standards review, epidemiologic studies have continued to find associations between short-term and long-term exposure to particulate matter and cardiopulmonary morbidity and mortality at current pollution levels. This study analyzed the spatial and temporal variability of fine particulate (PM2.5) monitoring data for the Northeast and the continental United States to assess the protectiveness of various levels, forms, and combinations of 24-hr and annual health-based standards currently recommended by EPA staff and the Clean Air Scientific Advisory Committee. Recommended standards have the potential for modest or substantial increases in protection in the Northeast, ranging from an additional 13-83% of the population of the region who are living in areas not likely to meet new standards and thereby benefiting from compliance with more protective air pollution controls. Within recommended standard ranges, an optimal 24-hr (98th percentile)/annual standard suite occurs at 30/12 microg/m3, providing short- and long-term health protection for a substantial percentage of both Northeast (84%) and U.S. (78%) populations. In addition, the Northeast region will not benefit as widely as the nation as a whole if less stringent standards are selected. Should the 24-hr (98th percentile) standard be set at 35 microg/m3, Northeast and U.S. populations will receive 16-48% and 7-17% less protection than a 30 microg/m3 standard, respectively, depending on the level of the annual standard. A 30/12 microg/m3 standard suite also provides nearly equivalent 24-hr and annual control of PM2.5 distributions across the United States, thereby ensuring a more uniform and consistent level of protection than unmatched or "controlling" and "backstop" standards. This could occur even within EPA staff's recommended range of standard suites, where 22-43% of the monitors in the country could meet a controlling standard but fail to meet the combined backstop standard, resulting in inconsistent short- and long-term protection across the country. An equivalent standards combination of 30/12 microg/m3 would minimize the wide variation of protectiveness of 24-hr and annual PM2.5 concentrations. Furthermore, given recent associations of subdaily exposures and acute adverse health effects, in the absence of a subdaily averaging metric, a stringent 24-hr standard will more effectively control maximum hourly and multihourly peak concentrations than a weaker standard.     

Accurate Chemical Analysis of MTBE in Environmental Media

The new millennium ushers in changes for refiners of automobile gasoline in the United States, as well as for the state and federal regulators who establish guidelines for gasoline formulation and environmental regulation governing the fate of gasoline-related chemicals in the nation's air, soil and groundwater. One current issue in the gasoline formulation debate centers on the comparison of the proven benefits of the addition of chemical oxygenates—especially methyltert -butyl ether (MTBE)—to gasoline (to improve tailpipe emission quality) against the presumed environmental problems caused by the presence of oxygenates in ground- and surface waters due to fugitive releases of gasoline. Credible debate on this subject presumes that current and past environmental monitoring data for MTBE in environmental samples is accurate and precise. Experience suggests that this assumption is not correct, in part because certain analytical methodologies—particularly older methods supported by the U.S. Environmental Protection Agency—can fall short of reasonable data quality goals for measurement of MTBE. This Technical Note summarizes the standard EPA methods available to site investigators who need to measure MTBE in environmental media, the limitations and advantages of these measurement techniques, and recommendations for improving these standard EPA methods to yield the highest quality MTBE environmental residue data.     

The Nationwide Program for Maintenance of Air Quality

The initial state implementation plans concentrated on attainment of the ambient air quality standards in the relatively polluted areas of the country. Many of these plans must now be modified to ensure that the ambient standards will be maintained for the foreseeable future, and to ensure that significant deterioration of air quality in clean areas of the country is prevented.

The existing implementation plans currently contain many measures which are applicable to the maintenance and deterioration efforts, but additional measures must also be developed. Many of these additional measures will involve future planning activities—most common of which will be land use planning activities.

The point is made that, after existing sources have reduced their emissions to the lowest practical level, further air pollution control can only be accomplished by implementing rational planning procedures for management of any new sources of air pollution. This will require extensive cooperation among the air pollution control community; regional, state, and local planning agencies; state and local governments; and the general public in order to ensure that future land use plans include appropriate air quality considerations.     

Review of Singapore's air quality and greenhouse gas emissions: current situation and opportunities

Singapore has many environmental accomplishments to its credit. Accessible data on air quality indicates that all criteria pollutants satisfy both U.S. Environmental Protection Agency (EPA) and World Health Organization (WHO) air quality standards and guidelines, respectively. The exception is PM2.5 (particles with an aerodynamic diameter < or = 2.5 microm), which is not currently considered a criteria pollutant in Singapore but may potentially be the major local air pollution problem and cause for health concern. Levels of other airborne pollutants as well as their physical and chemical processes associated with local formation, transformation, dispersion, and deposition are not known. According to available emission inventories, Singapore contribution to the total atmospheric pollution and carbon budget at the regional and global scales is small. Emissions per unit gross domestic product (GDP) are low compared with other countries, although Singapore's per-capita GDP and per-capita emissions are among the highest in the world. Some information is available on health effects, but the impacts on the ecosystem and the complex interactions of air pollution and climate change at a regional level are also unknown. This article reviews existing available information on atmospheric pollution and greenhouse gas emissions and proposes a multipollutant approach to greenhouse gas mitigation and local air quality. Singapore, by reducing its per-capita emissions, increasing the availability of information (e.g., through regularly publishing hourly and/or daily PM2.5 concentrations) and developing a research agenda in this area, would likely be seen to be a model of a high-density, livable, and sustainable city in Southeast Asia and other tropical regions worldwide.     

California Experience with Air Quality Standards

Air quality standards have existed in California for almost six years. They have become an important part of the State’s air pollution control program.

The two principal uses of the standards have been to establish the goals for controlling motor vehicle emissions and to provide a basis for evaluating air quality throughout the State. The standards have also proved to be valuable as a means of communicating on air pollution problems with legislators, administrators, the press, the public, and dischargers of pollutants.

Lack of adequate data on the effects of varying concentrations of contaminants of concern in air pollution is a serious limitation in any effort to establish air quality standards.It is important that this data be obtained.

The concept of employing air quality standards as administrative goals is not unique to the air pollution field but is part of a broad trend to utilize standards for insuring a satisfactory environment. Those engaged in the air pollution field can expect to see increasing emphasis on such standards.

Air quality standards do not provide a magic formula for eliminating air pollution; they are but one element in a comprehensive program. They have limitations and are no better than the data upon which they are based. The standards, however, can play an important role in preserving satisfactory air quality and protecting man’s health.

In using air quality standards, one should keep in mind the comments of H. W. Streeter⁵ on water quality standards—“Let us devise them, try them, revise them, and apply them, but also remember that they are but ’feeble instruments of the human will’ and like all other such tools are made to be discarded for better ones when they become worn out.“     

A Comparative Analysis of Modeled and Monitored Ambient Hazardous Air Pollutants in Texas: A Novel Approach Using Concordance Correlation

Abstract

Often, in studies evaluating the health effects of hazardous air pollutants (HAPs), researchers rely on ambient air levels to estimate exposure. Two potential data sources are modeled estimates from the U.S. Environmental Protection Agency (EPA) Assessment System for Population Exposure Nationwide (ASPEN) and ambient air pollutant measurements from monitoring networks. The goal was to conduct comparisons of modeled and monitored estimates of HAP levels in the state of Texas using traditional approaches and a previously unexploited method, concordance correlation analysis, to better inform decisions regarding agreement. Census tract-level ASPEN estimates and monitoring data for all HAPs throughout Texas, available from the EPA Air Quality System, were obtained for 1990, 1996, and 1999. Monitoring sites were mapped to census tracts using U.S. Census data. Exclusions were applied to restrict the monitored data to measurements collected using a common sampling strategy with minimal missing values over time. Comparisons were made for 28 HAPs in 38 census tracts located primarily in urban areas throughout Texas. For each pollutant and by year of assessment, modeled and monitored air pollutant annual levels were compared using standard methods (i.e., ratios of model-to-monitor annual levels). Concordance correlation analysis was also used, which assesses linearity and agreement while providing a formal method of statistical inference. Forty-eight percent of the median model-to-monitor values fell between 0.5 and 2, whereas only 17% of concordance correlation coefficients were significant and greater than 0.5. On the basis of concordance correlation analysis, the findings indicate there is poorer agreement when compared with the previously applied ad hoc methods to assess comparability between modeled and monitored levels of ambient HAPs.     

use of 1970 census of population data for air pollution research

Today, many more communities in the United States are in a better position to undertake the study of the possible health effects of the air pollution in their environment than has been possible before. Further, such study may furnish baseline data for evaluating the efficacy of air pollution control activity in those cities.

Assessment by city and county control officials can be accomplished by examining the relationship between the demographic characteristics of the area as reported in the 1970 Census of Population, the aerometric measurements now being made routinely in many areas, and mortality in the population as reported to the state office of vital statistics. From the census, detailed demographic or population data will be available by census tract in urban areas. These areas include virtually every U. S. city with a population of 50,000 or more.

The procedures used in the Buffalo and Nashville Air Pollution Studies are discussed with a view toward possible replication by other geographic areas. The need to take account of differences in socio-economic status is emphasized, as is the desirability of obtaining smoking histories. Another major type of air pollution research which is again made possible by the 1970 Census is the comparison of mortality experience, on an agespecific and an age-adjusted basis centered around 1970, for the more than 200 Standard Metropolitan Statistical Areas in the United States.     

Indicators for Chemicals: Sources,impacts and policy performance (5 pp)

Background Different types of indicators have been developed to describe the impact of chemicals on society and environment. Due to the high number of substances and their different types of use, most of these indicators are directed to specific areas of interest – regarding workplace safety, environmental health or consumer health. They address a specific subset of chemicals and can be used for monitoring enterprise-specific, national or international management measures. Main Features A survey of existing indicators for chemicals has shown that indicators already exist for a remarkable number of problem fields. As soon as the release and the environmental fate of chemicals are taken into account, the complexity of the approaches increases considerably. The distinction between indicators for drivers, pressures, state, impacts and responses, as proposed by the European Environmental Agency, supports the identification of proper indicators for a specific type of problem. Discussion and Conclusions. No single indicator exists which is able to cover the whole range of chemicals and their applications. Several indicator approaches cover at least a subset of the most relevant substances. If they are intended to be used for European monitoring, robust data must be provided by EU Member States. Chemicals in enterprises (ancillary inputs as well as process chemicals) are an important element of in-plant material flow management – in terms of occupational safety and health as well as environmental protection. Existing indicators for hazardous chemicals can be a valuable tool for process and product refinement regarding hazardous chemicals, especially for enterprises. Outlook Indicators for production and impact of chemicals, as well as policy performance indicators, are essential elements in order to monitor the management of chemicals. They have to be established for the national and for the EU level.     

A California air standard to protect vegetation from ozone

Evidence shows that the current national primary ambient air quality standard, if attained, would still permit substantial injury to vegetation. Thus, in March 1987, the California Air Resources Board (CARB) began consideration of the evidence for the effects of ozone (O3) on vegetation, and of several possible state ambient air quality standards designed to protect vegetation, especially crops, from O3 injury. In its review, the CARB addressed a number of issues relevant to such a standard. One issue considered by the CARB is the relationship of an ambient air quality standard to natural background levels of O3, which would greatly influence the practicality of attainment. Attainment of a standard close to natural background could entail excessive costs. Another issue considered is the occurrence of oxidants other than O3 that can damage vegetation. Throughout much of California, O3 accounts for over 90% of the oxidant air pollutants, and the CARB considered whether, in keeping with current practice, O3 should be used as a surrogate for total oxidant air pollutants. A major new piece of information presented to the CARB was an assessment of the economic effects of several potential standards. This assessment, produced by University of California scientists at Riverside and Davis, calculated the benefits of the potential standards in comparison to current O3 levels and estimated natural O3 background. This assessment was developed using field chamber response data, local crop data, and local O3 concentration data as inputs to the California Agricultural Resources Model, which accounts for both supply and demand effects. Because of California's varied climate, agricultural production occurs on a year-round basis, with overlapping growing seasons for many crops. Over long periods of time, O3 levels may vary markedly because of the influence of various factors, and a 1-h standard may not be an accurate indicator of growing season O3 exposure. A moving three-month averaging time has been proposed as a way to approximate the growing seasons of California's 200 crops. However, a sufficiently stringent 1-h standard would serve as a surrogate for a growing season standard. The CARB reviewed evidence supporting both long-term and short-term standards. Agriculture dominates the economies of some regions within California but is a minor components of other regional economies. Because the San Joaquin Valley is California's most important agricultural area, the CARB reviewed evidence for a regional standard for this area that would be more stringent than standards for other parts of the state.     

Use of Probabilistic Methods to Understand the Conservatism in California’s Approach to Assessing Health Risks Posed by Air Contaminants

Many state and federal agencies have prepared risk assessment guidelines, which describe methods for quantifying health risks associated with exposure to vapors and particulates emitted from point and area sources (e.g., California Air Pollution Control Officers Association [CAPCOA] under the Air Toxics “Hot Spots” Act [Assembly Bill 2588] and the U.S. Environmental Protection Agency [EPA] under the Clean Air Act). In general, these guidelines recommend or require the use of upper bound “point” estimates for numerous exposure parameters. This methodology yields a single risk estimate, which is intended not to underestimate the true risk and may significantly overstate it. This paper describes a risk assessment of a facility’s airborne emissions using a probabilistic approach, which presents a range and distribution of risk estimates rather than a single point estimate. The health risks to residents living near a food processing facility, as estimated using techniques recommended by California AB2588, are compared to the results of a probabilistic analysis. Polychlorinated dibenzo-p-dioxins (PCDDs) and polychlorinated dibenzofurans (PCDFs) were identified as the emitted chemicals of concern. The point estimate method recommended by CAPCOA resulted in estimates that were greater than the 99.99th percentile risk predicted by the probabilistic analysis. As shown in other assessments of persistent airborne chemicals, secondary or indirect exposure pathways (i.e., ingestion of beef, ingestion of cow’s milk, and ingestion of mother’s milk) rather than inhalation, were the greatest contributors to risk. In this analysis, the probability distributions for the cancer potency factor and ingestion of cow’s milk had the largest impact on the results of the 33 exposure factors considered.     

An analysis of candidates for addition to the Clean Air Act list of hazardous air pollutants

There are 188 air toxics listed as hazardous air pollutants (HAPs) in the Clean Air Act (CAA), based on their potential to adversely impact public health. This paper presents several analyses performed to screen potential candidates for addition to the HAPs list. We analyzed 1086 HAPs and potential HAPs, including chemicals regulated by the state of California or with emissions reported to the Toxics Release Inventory (TRI). HAPs and potential HAPs were ranked by their emissions to air, and by toxicity-weighted (tox-wtd) emissions for cancer and noncancer, using emissions information from the TRI and toxicity information from state and federal agencies. Separate consideration was given for persistent, bioaccumulative toxins (PBTs), reproductive or developmental toxins, and chemicals under evaluation for regulation as toxic air contaminants in California. Forty-four pollutants were identified as candidate HAPs based on three ranking analyses and whether they were a PBT or a reproductive or developmental toxin. Of these, nine qualified in two or three different rankings (ammonia [NH3], copper [Cu], Cu compounds, nitric acid [HNO3], N-methyl-2-pyrrolidone, sulfuric acid [H2SO4], vanadium [V] compounds, zinc [Zn], and Zn compounds). This analysis suggests further evaluation of several pollutants for possible addition to the CAA list of HAPs.     

Transmissometer Measurement of Participate Emissions from a Jet Engine Test Facility

The body of information presented in this paper is directed toward those individuals involved with handling hazardous materials, whether in actual use of such chemicals, or in monitoring atmospheric emissions. Although specifically relating experience in the design and testing of phosgene emission control equipment, it attempts to establish general guidelines for effectively dealing with emissions of hazardous materials. An approach for handling chemical pollutants having no established air quality emission standards is developed. The paper presents a technique for establishing process emissions at acceptably low levels to insure the health and safety of the general population as well as that of the process workers themselves. Methods, suitable for measuring phosgene at these low levels, have been investigated, and problems associated with such an investigation are discussed. While complete theoretical scrubber design criteria are beyond the scope of this paper, many of the "real world" problems which affected scrubber performance are presented. Finally, the practical aspects of process emissions control are illustrated by actual results from the system test.     

Determination of acute exposure guideline levels in a dispersion model

The U.S. Environmental Protection Agency (EPA) is in the process of establishing acute exposure guideline levels (AEGLs) for a number of toxic chemicals. These guidelines represent predictable human consequences from measured exposures of selected toxic chemicals over time. They are intended for emergency planning and regulatory purposes. This paper presents a method that can be used by atmospheric dispersion models to compute AEGL values and graphically display the regions exposed to each guideline level on area maps. EPA currently defines three levels of AEGLs corresponding to increasingly severe symptoms, ranging from notable discomfort (AEGL-1) to serious adverse health effects (AEGL-2) to life-threatening effects or death (AEGL-3). For each chemical's three AEGL levels, guideline concentrations are defined for five exposure durations: 10 min, 30 min, 1 hr, 4 hr, and 8 hr. Dispersion models can compute a chemical dosage (time-integrated concentration) and a peak concentration throughout the area exposed to the plume. The AEGL then can be computed by finding the effective duration of the plume at each location, computing the AEGL-equivalent dosages for these durations, and comparing the dosage at each point with the AEGL-equivalent dosages. AEGL contours then can be plotted and readily interpreted in terms of expected toxicity levels for each level of health impact.     

Can varying concepts of susceptibility in risk assessment affect particulate matter standards?

The Clean Air Act mandates that sensitive subpopulations be considered in setting standards to protect the public's health. The purposes of this paper are to point out different conceptualizations of susceptibility, examine how it is approached in risk-related processes, and recommend ways it may be more explicitly framed for risk assessment and management purposes. We studied the traditional risk assessment paradigm, the U.S. Environmental Protection Agency (EPA) guidelines and revised PM standard, discussions from recent interdisciplinary meetings, and peer-reviewed literature. Areas of controversy include what factors intrinsic and extrinsic to the host should be incorporated in susceptibility, what health endpoints are of concern, whether susceptibility is deterministic or stochastic, and whether it should be defined on an individual or population scale. Recent discussions about susceptibility applied to PM indicate that it needs to be more clearly defined and evaluated for scientific and policy purposes. We conclude that varying concepts of susceptibility can affect risk-related processes such as PM standard setting. We recommend that susceptibility be clearly defined in the problem statement of risk assessments and be addressed in a specific subsection of risk characterization, integrating all susceptibility findings from the prior three steps in the risk assessment paradigm.     

Can Varying Concepts of Susceptibility in Risk Assessment Affect Particulate Matter Standards?

ABSTRACT

The Clean Air Act mandates that sensitive subpopulations be considered in setting standards to protect the public's health. The purposes of this paper are to point out different conceptualizations of susceptibility, examine how it is approached in risk-related processes, and recommend ways it may be more explicitly framed for risk assessment and management purposes. We studied the traditional risk assessment paradigm, the U.S. Environmental Protection Agency (EPA) guidelines and revised PM standard, discussions from recent interdisciplinary meetings, and peer-reviewed literature. Areas of controversy include what factors intrinsic and extrinsic to the host should be incorporated in susceptibility, what health endpoints are of concern, whether susceptibility is deterministic or stochastic, and whether it should be defined on an individual or population scale. Recent discussions about susceptibility applied to PM indicate that it needs to be more clearly defined and evaluated for scientific and policy purposes. We conclude that varying concepts of susceptibility can affect risk-related processes such as PM standard setting. We recommend that susceptibility be clearly defined in the problem statement of risk assessments and be addressed in a specific subsection of risk characterization, integrating all susceptibility findings from the prior three