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Information Quality Act Requests for Correction (RfC) Filed by PCTC

RfC #1: There is No Scientific Basis for the USGS to Claim that RTS is a Major Source of PAHs in Sediments

RfC #2: The USGS is Using Inaccurate & Misleading Photographs as a Scare Tactic

RfC #3: USGS claims of health risks are based on a "risk assessment" that exaggerates exposure, omits data without explanation, fails to consider the many other sources of PAHs, does not use best-available toxicity estimates, and many other flaws of both omission and commission. Following its procedure, the USGS post contains the entire RfC in a single file. Individual attachments are available on this site as Exhibit A - the risk assessment peer review - and Exhibit C - the dust study review. Both Exhibits are also posted on the Research page of this web site.

RfC #4: EPA’s Reliance On Outdated Studies Results in Challenge of Two Publications Regarding Refined Coal Tar-Based Sealants

RFC #5: The USGS' application of the CMB model has now been recreated (as the result of materials obtained via a Freedom of Information Act -FOIA- request), clearly revealing USGS misuse of the model. The USGS paper on its CMB model results must be retracted both because it is scientifically indefensible and because publication gives the appearance that use of the flawed model is approved by the USGS. In addition to the USGS web site, the RfC is also available here, and supporting Exhibits A through C here.

Comments Filed by in Response to Federal Register Requests for Comment

Comments submitted to EPA's Office of the Science Advisory Board (SAB) on the List of Candidates for the SAB's Draft Benzo(a)Pyrene IRIS Assessment Review Panel.

Comment submitted on selective use of citations in US EPA's Draft Benzo(a)Pyrene Integrated Risk Information System (IRIS) Assessment (Nov. 2013).

Comments on the hazard characterization and toxicological summary in US EPA's Draft Benzo(a)Pyrene IRIS Assessment submitted jointly with six other organizations (Nov. 2013).

Comments on Draft Guidance Document on Relative Potency Factors for the PAHs developed by the US EPA's IRIS program submitted jointly with five other organizations (April 2010).

Comments Submitted to EPA Region 5 and State Agencies Involved in the Great Lakes Coal Tar Sealcoat PAH Reduction Project

The Minnesota Pollution Control Agency and the other Collaborators in the "Sealcoat PAH Reduction Project" received an EPA grant to run the program. They are not being paid to determine whether coal tar sealants should be replaced with asphalt sealants. Apparently, that determination has already made by someone or a group of people at EPA Region 5 whose identities are unknown. What those people at the EPA relied upon in arriving at their determination is also unknown. What is known is that neither the PCTC nor any other trade organization or stakeholder representing the RTS industry had an opportunity to present its position to the EPA. There was no hearing, no solicitation of comments, and no draft proposal. Just a determination that coal tar sealants should be replaced and a group of willing Project Collaborators who have agreed to accept tax dollars to pursue this agenda. With the usual avenues for comment and interaction with government agencies thus closed, PCTC submits comments to the Project organizers and the public at large. Read details in the cover letter that summarizes the comments and the full comment document.

Food & Drug Administration (FDA)

The U.S. FDA recognizes coal tar as "generally recognized as safe and effective" (GRASE) for use as an over-the-counter topical medication for skin conditions such as dandruff, seborrheic dermatitis, or psoriasis. This is the link to the relevant section of the U.S. Code of Federal Regulations: 21CFR358.

More information about coal tar pharmaceuticals is located on the Science & Health page of this web site.

Benefits of Pavement Maintenance Treatments

Energy Usage and Greenhouse Gas Emissions of Pavement Preservation Processes for Asphalt Concrete Pavements

Information about Coal Tar & Refined Tar-Based Sealcoat

The Truth About Coal Tar

PCTC Columns in Pavement Maintenance & Reconstruction Magazine

March 2014: How Laws are Made in Minnesota: Part 1

February 2014: Pavement Contractors Need to Pay Attention to Storm Water Ordinances

January 2014: Looking Both Ways: 2013 in Review

October 2013: White Hat Bias

August 2013: How Sealcoats Protect Asphalt

June 2013: Good Practices for Sealcoating

April 2013: The Benefits of Preventive Maintenance Pavement Sealers

March 2013: Webinar Follow up: Who Participated, Some Questions Answered

February 2013: Don't Miss Free Sealcoating Webinar

December 2012: Refined Tar-based Sealer Status Update

October 2012: Working for Sealcoaters

Articles in the Trade Press

Pavement Maintenance & Reconstruction Magazine

February 2014: Understanding Sealer Basics by Anne LeHuray

February 2014: Why Viscosity is Important to your Sealcoating Business by Randy Tattershall

February 2014: What's the Future of Pavement Maintenance? by Colby Humphrey On Feb 24, 2014

October 2013: Earns Support of Scientists – and Us by Allan Heydorn

April 2013: 21 Sealcoating Questions and Answers by Allan Heydorn

January 2013: PCTC Makes Progress in 2012 by Allan Heydorn

December 2010: New studies defend use of refined tar-base sealers by Anne LeHuray

December 2010: PCTC Steps up for Contractors by Allan Heydorn

March 2010: Proactive PCTC Acts for Industry by Allan Heydorn

A Contractor’s Letter to Customers Regarding Refined Coal Tar Sealers by Brett Neal / Gerry Signs

10 Important Items A Sealcoater Should Never Leave Without by Tim Parrish

How to Get Started in the Sealcoating Business by Girish Dubey

GemSeal Sealcoating Quick Tips by Harry Carter

Basic Concepts of Refined Coal Tar Based Sealcoatings, Pt 1 by Girish Dubey

Basic Concepts of Refined Coal Tar Based Sealcoatings, Pt 2 by Girish Dubey

Basic Concepts of Refined Coal Tar Based Sealcoatings, Pt 3 by Girish Dubey

Additives for Sealcoatings and Mix Designs by Girish Dubey

Altering Sealer Mix Designs to Suit Cure Conditions by Girish Dubey

Best Sealcoating Practices: Eliminating Bonding Problems
by Girish Dubey

Sealcoating Performance and the Importance of Proper Cure Conditions
by Girish Dubey

Sand or Aggregate in Sealcoatings - Their Value and Selection by Girish Dubey

The Facts about Refined Tar Sealers (RTS) & PAHs
by Girish Dubey

Stormwater Magazine

A Review of PAHs: Polycyclic aromatic hydrocarbons in stormwater and urban sediments by Jaana Pietari, Kirk O'Reilly and Paul Boehm

Useful Information

The Rise of Mommy Fearmongering: Be Afraid… Of Everything! - See more at the Independent Women's Forum website, here.

Get the facts about how chemistry and chemicals have improved our lives at

A Position Statement of The American Council on Science and Health: Scared to Death: How Chemophobia Threatens Public Health

A quick guide to understanding low concentrations of chemicals: Putting terms such as "ppm," "ppb" and "ppt" into perspective