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Information Quality Act Requests for Correction (RfC) Filed by PCTC
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.
Comments Filed by PavmentCouncil.org in Response to Federal Register Requests for Comment
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Comments on Draft Guidance Document on Relative Potency Factors for the PAHs developed by the US EPA's IRIS program submitted jointly with five other organizations (April 2010).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
Information about Coal Tar & Refined Tar-Based Sealcoat
PCTC Columns in Pavement Maintenance & Reconstruction Magazine
Articles in the Trade Press
Pavement Maintenance & Reconstruction Magazine
April 2013: 21 Sealcoating Questions and Answers by Allan Heydorn
January 2013: PCTC Makes Progress in 2012 by Allan Heydorn
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
How to Get Started in the Sealcoating Business by Girish Dubey
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
A Review of PAHs: Polycyclic aromatic hydrocarbons in stormwater and urban sediments by Jaana Pietari, Kirk O'Reilly and Paul Boehm
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 SafeChemicalPolicy.org
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