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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- RfC #4: EPA’s Reliance On Outdated Studies Results in Challenge of Two Publications Regarding Refined Coal Tar-Based Sealants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 PavmentCouncil.org 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- Comments on Draft Guidance Document on Relative Potency Factors for the PAHs developed by the US EPA’s IRIS program submitted jointly with five other organizations (April 2010).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.
Environmental Benefits of Pavement Maintenance Treatments
- Energy Usage and Greenhouse Gas Emissions of Pavement Preservation Processes for Asphalt Concrete Pavements
- Life Cycle Analysis: An Economic Input Output and process based LCA comparison between unsealed concrete and sealed asphalt parking lots’ upstream environmental impacts
Information about Coal Tar & Refined Tar-Based Sealcoat
Post Publication Peer Reviews (PPPR) at PubPeer.com
- Crane, J. L. (2014a). Source Apportionment and Distribution of Polycyclic Aromatic Hydrocarbons, Risk Considerations, and Management Implications for Urban Stormwater Pond Sediments in Minnesota, USA. Arch Environ Contam Toxicol, 66, 176-200. doi:10.1007/s00244-013-9963-8
- Mahler, B. J., P. Van Metre, T. J. Bashara, J. T. Wilson, and D. A. Johns, 2005, Parking Lot Sealcoat: An Unrecognized Source of Urban Polycyclic Aromatic Hydrocarbons: Environmental Science & Technology, v. 39, p. 5560 – 5566.
- Mahler, B. J., Van Metre, P., Wilson, J. T., Musgrove, M., Burbank, T. L., Ennis, T. E., & Bashara, T. J. (2010). Coal-tar-based parking lot sealcoat: an unrecognized source of PAH to settled house dust. Environmental Science & Technology, 44, 894 – 900. doi:10.1021/es902533r
- Van Metre, P., Mahler, B., & Wilson, J. (2009). PAHs underfoot: contaminated dust from sealcoated pavements is widespread in the United States. Environ Sci Technol, 43, 20-25.
- Van Metre, P., & Mahler, B. J. (2010). Contribution of PAHs from coal–tar pavement sealcoat and other sources to 40 U.S. lakes. Science of the Total Environment, 409, 334 – 344. doi:10.1016/j.scitotenv.2010.08.014
- Van Metre, P. C., & Mahler, B. J. (2014). PAH Concentrations in Lake Sediment Decline Following Ban on Coal-Tar-Based Pavement Sealants in Austin, Texas. Environmental Science & Technology. doi:10.1021/es405691q
- Watts, A. W., Ballestero, T. P., Roseen, R. M., & Houle, J. P. (2010). Polycyclic Aromatic Hydrocarbons in Stormwater Runoff from Sealcoated Pavements. Environmental Science & Technology, 44, 8849 – 8854. doi: 10.1021/es102059r
- Williams, E. S., Mahler, B. J., & Van Metre, P. (2013). Cancer Risk from Incidental Ingestion Exposures to PAHs Associated with Coal-Tar-Sealed Pavement. Environmental Science & Technology, 47, 1101 – 1109. doi:dx.doi.org/10.1021/es303371t
- Witter, A. E., Nguyen, M. H., Baidar, S., & Sak, P. B. (2014). Coal-tar-based sealcoated pavement: A major PAH source to urban stream sediments. Environmental Pollution, 185(0), 59-68. doi:http://dx.doi.org/10.1016/j.envpol.2013.10.015
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: PavementCouncil.org 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
- 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