In November 2013, PCTC joined 6 other organizations to review and comment on EPA’s public review draft of the EPA Integrated Risk Information System (IRIS) assessment of the PAH compound Benzo(a)Pyrene. EPA uses B(a)P as the index chemical for all the other PAHs. Those jointly prepared and submitted comments are available here.
PCTC also submitted a separate comment on EPA’s selective use of citations. Of the thousands of possible sources of PAHs in the environment, EPA, in the Preface of the draft assessment, chose to mention only one source: refined coal tar-based pavement sealers (RTS). Of the thousands of scholarly papers that have been published concerning PAH sources, EPA only cited one: Mahler et al. (2005). If you have been following PCTC’s investigations these past 10 years, you know that the analysis discussed in Mahler et al. (2005) has been proven to be unreproducible by several scientists, including Mahler’s fellow government-employed scientists. Further, you are aware that it is now known beyond any doubt that Mahler et al. (2005) is not reproducible because the USGS authors cherry picked the data they used to represent “urban sediment” PAH signatures, using 20 data points selected because they were similar to RTS, not because they were representative. Dr. Mahler’s email to a City of Austin staffer indicating how it was done is available here.
PCTC’s comment on EPA’s selective use of citations can be read here.