2016 Asphalt and Asphalt Emissions CIC Prioritization · PDF fileOctober 21, 2016 Ms. Michelle...

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October 21, 2016 Ms. Michelle Ramirez Office of Environmental Health Hazard Assessment P.O. Box 4010, MS-12B Sacramento, CA 95812-4010 Subject: 2016 CIC Prioritization of Asphalt Emissions Associated with Road Paving Dear Ms. Ramirez: On behalf of the asphalt road paving industry — represented by the National Asphalt Pavement Association (NAPA), Asphalt Institute (AI), and the California Asphalt Pavement Association (CalAPA) — we appreciate the opportunity to comment on the Office of Environmental Health Hazard Assessment’s (OEHHA) August 2016 Prioritization Notice on Chemicals for Consultation by the Carcinogen Identification Committee. In that notice, both Asphalt and Asphalt Emissions Associated with Road Paving and Asphalt and Asphalt Emissions Associated with Roofing are on the agenda for possible prioritization and preparation of hazard identification materials. As requested, our comments will focus on the scientific evidence presented in the Prioritization Notice on Asphalt and Asphalt Emissions Associated with Road Paving, henceforth identified as “Paving Asphalt Emissions;” we do not specifically comment on Asphalt and Asphalt Emissions Associated with Roofing. In summary, based on the scientific epidemiological and toxicological evidence reviewed below, Paving Asphalt Emissions should be evaluated separately from roofing asphalt emissions due to qualitative and quantitative differences in the composition of paving and roofing asphalt emissions; and Paving Asphalt Emissions should not be recommended for priority listing, but if a listing is required, it should be considered as low-priority due to the lack of human and animal carcinogenicity evidence as well as the current industry Consent Judgement that already requires Proposition 65 warnings for asphalt paving operations. Our comments review the International Agency for Research on Cancer’s (IARC) 2013 Monograph evaluation and additional information identified by OEHHA post IARC’s 2013

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Page 1: 2016 Asphalt and Asphalt Emissions CIC Prioritization · PDF fileOctober 21, 2016 Ms. Michelle Ramirez Office of Environmental Health Hazard Assessment P.O. Box 4010, MS-12B Sacramento,

October 21, 2016

Ms. Michelle Ramirez

Office of Environmental Health Hazard Assessment

P.O. Box 4010, MS-12B

Sacramento, CA 95812-4010

Subject: 2016 CIC Prioritization of Asphalt Emissions Associated with Road Paving

Dear Ms. Ramirez:

On behalf of the asphalt road paving industry — represented by the National Asphalt Pavement

Association (NAPA), Asphalt Institute (AI), and the California Asphalt Pavement Association

(CalAPA) — we appreciate the opportunity to comment on the Office of Environmental Health

Hazard Assessment’s (OEHHA) August 2016 Prioritization Notice on Chemicals for

Consultation by the Carcinogen Identification Committee. In that notice, both Asphalt and

Asphalt Emissions Associated with Road Paving and Asphalt and Asphalt Emissions Associated

with Roofing are on the agenda for possible prioritization and preparation of hazard

identification materials. As requested, our comments will focus on the scientific evidence

presented in the Prioritization Notice on Asphalt and Asphalt Emissions Associated with Road

Paving, henceforth identified as “Paving Asphalt Emissions;” we do not specifically comment on

Asphalt and Asphalt Emissions Associated with Roofing.

In summary, based on the scientific epidemiological and toxicological evidence reviewed below,

Paving Asphalt Emissions should be evaluated separately from roofing asphalt

emissions due to qualitative and quantitative differences in the composition of paving

and roofing asphalt emissions; and

Paving Asphalt Emissions should not be recommended for priority listing, but if a

listing is required, it should be considered as low-priority due to the lack of human

and animal carcinogenicity evidence as well as the current industry Consent Judgement

that already requires Proposition 65 warnings for asphalt paving operations.

Our comments review the International Agency for Research on Cancer’s (IARC) 2013

Monograph evaluation and additional information identified by OEHHA post IARC’s 2013

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evaluation. We include two attachments at the end of this document: an executive summary of

our comments, and a brief description of the industry and innovative technologies that reduce

emissions during asphalt paving operations.

IARC and NIOSH Differentiated Industrial Sector,

Asphalt Type, And Impact of Application Temperature

In 2013, IARC re-evaluated various occupational exposures to bitumen and bitumen emissions

(a.k.a. asphalt in the United States), which included road paving, roofing, and mastic

applications. IARC also separately evaluated different types of asphalt used in different

industries: straight-run bitumen (paving), oxidized bitumen (roofing), and hard bitumen (mastic).

IARC recognized in its evaluation the significant impact of temperature on bitumen emissions; in

particular, that as the temperature of the asphalt increases, changes in the composition and

amount of emissions occur.

“The variable physicochemical properties of the individual constituents of

bitumen mean that the composition and physical form of the emissions from

heated bitumens are dependent on the temperature to which the bitumen is

heated.” (IARC, 2013, pp. 35–36)

There are two well-established Chemical Abstract Service (CAS) numbers for asphalt: oxidized

bitumen is identified under CAS No. 64742-93-4, and straight-run or paving-type asphalts are

identified under CAS No. 8052-42-4. Oxidized asphalt is used almost exclusively in the roofing

sector. Paving Asphalt Emissions should be identified with CAS No. 8052-42-4. The use of

different CAS numbers for different types of asphalt, typically used in different industrial sectors

and heated to different temperatures, underscores the differences in the emissions potential of

asphalt at different temperatures.

Similarly, in 2000, the National Institute of Occupational Safety and Health (NIOSH) recognized

that:

“An analysis of the chemical data indicates that paving and roofing asphalts are

qualitatively and quantitatively different; therefore, the vapors and fumes from

these asphalt products also may be different. The chemical composition of vapors

and fumes from asphalt products is variable and depends on . . . type of asphalt,

[and] temperature . . .” (NIOSH, 2000, p. 89)

Both IARC’s and NIOSH’s statements on differentiating roofing and paving asphalt based on

application temperature are supported by the Cavallari et al. (2012) study, “Temperature-

Dependent Emission Concentrations of Polycyclic Aromatic Hydrocarbons in Paving and Built-

Up Roofing Asphalts,” conducted by Harvard University and others. Results from this study

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clearly differentiated polycyclic aromatic hydrocarbon (PAH) emissions associated with paving

or roofing grades of asphalts at varying temperatures.

Cavallari et al. (2012) observed that, in a laboratory headspace analysis, there were only a few

detections of one individual 4-ring PAH in paving asphalt emissions at typical paving

temperatures (≈300°F). This was not the case for roofing asphalt emissions at typical roofing

application temperatures (≈400°F). As many independent studies corroborate these findings,

emissions of 4-ring or greater PAHs from paving asphalt are practically non-existent at typical

paving application temperatures and are quite different compared to emissions from roofing

asphalt at the typically higher roofing application temperatures.

We therefore request that Paving Asphalt Emissions are evaluated separately from roofing

asphalt emissions for prioritization.

Epidemiological and Toxicological Evaluation

of Paving Asphalt Emissions

In OEHHA’s August 2016 Prioritization Review, the agency provides a summary table regarding

evidence of carcinogenicity for mixed types of asphalt. We reviewed the summary table for

applicability to Paving Asphalt Emissions. If OEHHA identified a positive association (checked

box) for one of the categorized endpoints, we identify whether or not that endpoint is applicable

to Paving Asphalt Emissions.

Exposure: Limited/Occupational

We agree with OEHHA’s assessment that Paving Asphalt Emissions do not pose a widespread

exposure potential. IARC identified that:

“[h]uman exposure to bitumens and their emissions comes almost exclusively

from occupational exposure during manufacture and use of the products.”

(IARC, 2013, p.36)

As noted, emissions during asphalt paving are only encountered in an occupational setting and

for a very short duration during the initial phase of the application process. After the pavement is

compacted, less than 30 minutes after application, there are no further emissions and traffic is

often allowed back on the new pavement within a few hours.

In addition, over the past decade the paving industry has seen dramatic reductions in

occupational emissions of paving asphalt through both paving machine ventilation controls and

technologies like warm-mix asphalt (WMA), which reduces the paving asphalt application

temperature. Furthermore, adherence to both the American Conference of Governmental

Industrial Hygienists (ACGIH) TLV® and California’s Division of Occupational Safety and

Health’s (Cal/OSHA) Permissible Exposure Limit (PEL) for asphalt fume ensures appropriate

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occupational protection; paving asphalt emissions are well below these occupational exposure

limits.

Human Data: Analytical

OEHHA’s assessment indicates there are a number of analytical epidemiological studies that

have investigated the impact of asphalt emissions on human cancers. IARC’s 2013 evaluation

clearly identifies that Paving Asphalt Emissions do not pose a human carcinogenic hazard,

finding:

“there is inadequate evidence in humans for the carcinogenicity of occupational

exposures to bitumens and bitumen emissions during road paving.” (IARC, 2013,

p. 203)

OEHHA also identifies three epidemiological studies published since the 2013 IARC

Monograph evaluation. However, these studies are either not applicable to paving asphalt, were

previously reviewed by IARC (underlying studies), or show excessive confounding as identified

below.

Zanardi et al. (2013) studied workers in an asphalt roofing-roll factory, pre- and post-

asbestos usage. Roofing asphalt is typically an oxidized asphalt product processed at

temperatures much higher than that of paving applications. The process description,

provided by the study authors in their external background information, indicates the

processing of and subsequent exposure to roofing asphalt emissions are not relevant to

Paving Asphalt Emissions.

Rota et al. (2014) conducted a meta-analysis of industrial exposures to PAHs associated

with a variety of industries, including two studies that focused on asphalt workers

(Behrens et al., 2009; Zanardi et al., 2013). However, the Behrens et al. (2009) study was

previously evaluated by IARC and confounding factors were identified; the other study

(Zanardi et al., 2013) is reviewed above.

o Regarding Behrens et al. (2009), IARC previously identified this study as part of

its multicenter epidemiological study, which included mixed-industrial exposures

to asphalt: paving, roofing, and mastic. IARC reviewed Behrens et al.’s results

and concluded the study: “. . . showed an excess of deaths from alcoholism, non-

malignant respiratory diseases and liver cirrhosis, indicating that both alcohol

and tobacco habits were in excess . . .” (IARC, 2013, p.100). As a result of this

type and level of confounding, as well as the non-specific industry allocation to

exposure, results from Behrens et al. (2009), and its findings associated with the

Rota et al. (2014) meta-analysis, are not causative nor applicable regarding

Paving Asphalt Emissions.

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o Zanardi et al. (2013) was identified above as relevant to roofing asphalt exposure

and therefore not applicable to Paving Asphalt Emissions.

Wagner et al. (2015) conducted a meta-analysis of PAH-exposed workers and the risk of

larynx cancer. The only asphalt study analyzed by Wagner et al. (2015) was a 2003

European asphalt worker epidemiological study by Boffetta et al. As noted by Wagner et

al. (2015, Box 1), “road construction with coal tar-based binding material” was an

occupation associated with high PAH exposure. What is not noted by Wagner et al.

(2015) is that the use of coal tar-based pavements was common in some European

countries more than four decades ago. In the United States, however, coal tar-based

pavements have not been used except for in some experimental pavements constructed in

the 1980s (as part alternative binder testing in response to the energy crises of the 1970s

and early 1980s). Results from Boffetta et al. (2003) and similar studies that do not

distinguish between asphalt paving and coal tar-based paving prompted IARC to re-

evaluate Asphalt Paving Emissions with a focus on isolating the impact of coal tar and

other confounding factors. IARC re-evaluated Boffetta et al.’s 2003 study in 2010 and

concluded:

“We found no consistent evidence of an association between indicators of

either inhalation or dermal exposure to bitumen and lung cancer risk. A

sizable proportion of the excess mortality from lung cancer relative to the

general population observed in the earlier cohort phase is likely

attributable to high tobacco consumption and possibly to coal tar

exposure, whereas other occupational agents do not appear to play an

important role.” (Olsson et al., 2010, p. 1418)

Therefore, the conclusions of Wagner et al. (2015) have no relevance to past or current

U.S.-based asphalt paving operations and is not applicable to Paving Asphalt Emissions.

Animal Data: Two or More Studies; Tumor Initiation/Promotion or Co-carcinogenicity Studies

While OEHHA’s assessment indicates that a number of animal carcinogenicity studies have been

conducted on asphalt and asphalt fractions, none of the studies identified show a positive

association between Paving Asphalt Emissions and animal carcinogenicity. Each study identified

by OEHHA as relevant to Paving Asphalt Emissions was previously reviewed by IARC and

found to be either not appropriate, confounded, or non-causative.

Therefore, we respectfully urge OEHHA to rely on IARC’s findings relative to the review of the

entire body of scientific animal carcinogenicity studies. IARC stated:

“there is inadequate evidence in experimental animals for the carcinogenicity of

straight-run bitumens [and fume condensates].” (IARC, 2013, p. 203)

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Other Relevant Data: Genotoxicity; Carcinogenic Metabolites; Other

OEHHA’s assessment identifies a number of other data types, all of which were previously

reviewed by IARC (2013). Unfortunately, because referenced citation information is not

provided in OEHHA’s document, it is difficult to address potential discrepancies associated with

any of the study findings identified. For example, in many of OEHHA’s listed study

descriptions, it is uncertain whether mechanistic findings were associated with roofing, paving,

or other types of asphaltic material. Case in point are studies that identify impacts associated

with fume condensates at temperatures up to 316oC, well above both paving and roofing

application temperatures. Similarly, some of the studies listed by OEHHA identified mechanistic

impacts of asphaltic materials like asphalt painting, which is not considered similar to paving

asphalt. Regarding some of the genotoxicity findings reported by OEHHA in road pavers, it is

unknown whether the influence of smoking was controlled in these studies; the original source

reference would need to be reviewed to see whether indeed there were genotoxic impacts that

could be attributed to Paving Asphalt Emissions.

Current Industry Consent Agreement Already Requires

Proposition 65 Warnings Associated With Paving Asphalt Operations

In 2005, the asphalt paving sector entered into a Consent Judgment (California v. Blue’s Roofing

Co. Inc., 2005) with the State of California to provide appropriate warnings under Proposition 65

for “asphalt, sand, diesel engine exhaust, and other materials . . .” (see California v. Blue’s

Roofing Co. Inc., 2005, Exhibit C). At the time, IARC’s 1985 Monograph (IARC, 1985) had

concluded that only certain extracts of asphalt posed a carcinogenic hazard, specifically:

“Extracts of steam-refined and air-refined bitumens are possibly carcinogenic to humans (Group

2B).” IARC’s findings were (and continue to be) designated as a Proposition 65 chemical by

OEHHA as “Bitumens, extracts of steam-refined and air-refined.” Other findings in the 1985

IARC Monograph regarding asphalt conclude that “Bitumens are not classifiable as to their

carcinogenicity to humans (Group 3).”

The U.S. asphalt paving industry does not use steam- or air-refined bitumens nor extracts of

those materials during asphalt paving applications and are already required to warn for exposure

to asphalt under Proposition 65.

Paving Asphalt Emissions Should Not Be Prioritized

Over the past three decades of scientific and regulatory agency review, there has been no

indication of a human or animal carcinogenic effect from exposure to Paving Asphalt Emissions.

In 2000, the National Institute for Occupational Safety and Health (NIOSH) recognized industry

differences in the use of and exposure to different types of asphalt. In its Hazard Review

(NIOSH, 2000), the agency concluded that:

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“the collective data currently available from studies on paving asphalt provide

insufficient evidence for an association between lung cancer and exposure to

asphalt fumes during paving.” (NIOSH, 2000, p. 95)

IARC’s 2013 evaluation reviewed the state of science associated with asphalt emissions. The

three newer studies OEHHA identified are consistent with those findings. As IARC states:

“there is inadequate evidence in humans for the carcinogenicity of occupational

exposures to bitumens and bitumen emissions during road paving.” (IARC, 2013, p. 203)

Since the paving asphalt industry’s 2005 Consent Judgement, Proposition 65 warnings continue

to be posted and communicated regarding the potential hazard of asphalt and other materials

used during asphalt paving applications. No additional benefit would be gained by listing Paving

Asphalt Emissions.

In addition, the industry’s on-going implementation of both engineering controls and WMA to

reduce emissions, coupled with existing regulatory occupational exposure limits, ensure worker

exposure to Paving Asphalt Emissions remain very low and will continue to be reduced.

In conclusion, based on the totality of scientific epidemiological and toxicological evidence’

which does not identify a cancer hazard; the existing requirement for Proposition 65

warnings during paving asphalt operations; an existing Cal/OSHA PEL for asphalt

emissions to protect workers in an occupational setting; and the IARC- and NIOSH-

acknowledged need to differentiate emissions based on application temperature, Paving

Asphalt Emissions should not be recommended for priority listing by the Carcinogen

Identification Committee; however, if a listing is required, it should be considered as low-

priority.

Sincerely,

Howard Marks, Ph.D., M.P.H.

Vice President – Environmental, Health &

Safety

National Asphalt Pavement Association

Russell W. Snyder, CAE

Executive Director

California Asphalt Pavement Association

Paul Sohi

Director of Health, Safety and Environment

Asphalt Institute

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References:

Behrens T, Schill W, & Ahrens W (2009). Elevated

Cancer Mortality in a German Cohort of Bitumen

Workers: Extended Follow-Up Through 2004. Journal

of Occupational and Environmental Hygiene,

6(9):555–561. doi:10.1080/15459620903077682

Boffetta P, Burstyn I, Partanen T, Kromhout H, Svane

O, Langård S, Järvholm B, Frentzel-Beyme R,

Kauppinen T, Stücker I, Shaham J, Heedrik D, Ahrens

W, Bergdahl, IA, Cenée S, Ferro G, Heikkilä P,

Hooiveld M, Johansen C, Randem BG, & Schill W

(2003). Cancer Mortality Among European Asphalt

Workers: An International Epidemiological Study. I.

Results of the Analysis Based on Job Titles. American

Journal of Industrial Medicine, 43(1):28–39.

doi:10.1002/ajim.10181

California v. Blue’s Roofing Co. Inc. (2005). Corrected

Consent Judgement, Case No. RG 03-082954. Superior

Court of California for the County of Alameda.

http://www.prop65casedocs.com/documents/OrderReg

ardingConsentJudgments.pdf

Cavallari JM, Zwack LM, Lange CR, Herrick RF, &

McClean MD (2012). Temperature-Dependent

Emission Concentration of Polycyclic Aromatic

Hydrocarbons in Paving and Built-Up Roofing

Asphalts. Annals of Occupational Hygiene, 56(2):148–

160. doi:10.1093/annhyg/mer107

IARC (1985). Polynuclear Aromatic Compounds. Part

4, Bitumens, Coal-tars and Derived Products, Shale-

oils and Soots. IARC Monographs on the Evaluation of

the Carcinogenic Risk of Chemicals to Humans,

Volume 35. Lyon, France: International Agency for

Research on Cancer.

https://monographs.iarc.fr/ENG/Monographs/vol1-

42/mono35.pdf

IARC (2013). Bitumens and Bitumen Emissions, and

Some N- and S-Heterocyclic Polycyclic Aromatic

Hydrocarbons. IARC Monographs on the Evaluation of

Carcinogenic Risks to Humans, Volume 103. Lyon,

France: International Agency for Research on Cancer.

http://monographs.iarc.fr/ENG/Monographs/vol103/mo

no103.pdf

NIOSH (2000). Hazard Review: Health Effects of

Occupational Exposure to Asphalt. DHHS (NIOSH)

Publication No. 2001–110. Cincinnati, OH: National

Institute for Occupational Safety and Health.

https://www.cdc.gov/niosh/docs/2001-110/pdfs/2001-

110.pdf

OEHHA (2016). Chemicals for CIC Consultation:

Asphalt and Asphalt Emissions Associated with Road

Paving and Asphalt and Asphalt Emissions Associated

with Roofing. Sacramento, CA: Office of

Environmental Health Hazard Assessment.

http://oehha.ca.gov/media/downloads/crnr/090916asph

altemissions.pdf

Olsson A, Kromhout H, Agostini M, Hansen J, Funch

Lassen C, Johansen C, Kjaerheim K, Langard S,

Stucker I, Ahrens W, Behrens T, Lindbohm M-J,

Heikkila P, Heederik D, Portengen L, Shaham J, Ferro

G, de Vocht F, Burstyn I, & Boffetta P (2010). A Case-

Control Study of Lung Cancer Nested in a Cohort of

European Asphalt Workers. Environmental Health

Perspectives, 118(10):1418–1424.

doi:10.1289/ehp.0901800

Rota M, Bosetti C, Boccia S, Boffetta P, & La Vecchia

C (2014). Occupational Exposures to Polycyclic

Aromatic Hydrocarbons and Respiratory and Urinary

Tract Cancers: An Updated Systematic Review and a

Meta-analysis to 2014. Archives of Toxicology,

88(8):1479–1490. doi:10.1007/s00204-014-1296-5

Wagner M, Bolm-Audorff U, Hegewald J, Fishta A,

Schlattmann P, Schmitt J, & Seidler A (2015).

Occupational Polycyclic Aromatic Hydrocarbon

Exposure and Risk of Larynx Cancer: A Systematic

Review and Meta-analysis. Occupational &

Environmental Medicine, 72(3):226–233.

doi:10.1136/oemed-2014-102317

Zanardi F, Salvarani R, Cooke RM, Pirastu R, Baccini

M, Christiani D, Curti S, Risi A, Barbieri A, Barbieri

G, Mattioli S, & Violante FS (2013). Carcinoma of the

Pharynx and Tonsils in an Occupational Cohort of

Asphalt Workers. Epidemiology, 24(1):100–103.

doi:10.1097/EDE.0b013e318276cc95

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Attachment I: Executive Summary

Comments of the

National Asphalt Pavement Association

California Asphalt Pavement Association

Asphalt Institute

Before the

Carcinogen Identification Committee

Office of Environmental Health Hazard Assessment

“Prioritization Notice on Asphalt and Asphalt Emissions Associated with Road Paving”

October 21, 2016

Paving Asphalt Emissions should be evaluated separately from roofing asphalt emissions.

In 2013, IARC concluded, “The variable physicochemical properties of the individual

constituents of bitumen mean that the composition and physical form of the emissions from

heated bitumens are dependent on the temperature to which the bitumen is heated.”

In 2000, NIOSH stated, “An analysis of the chemical data indicates that paving and roofing

asphalts are qualitatively and quantitatively different; therefore, the vapors and fumes from

these asphalt products also may be different. The chemical composition of vapors and fumes

from asphalt products is variable and depends on . . . type of asphalt, [and] temperature . . .

“NIOSH recognizes the difference of paving and roofing asphalt based on application

temperature. CAS numbers differentiate asphalt emissions based on temperature.”

Exposure to paving asphalt emissions occurs exclusively during an occupational setting.

In 2013, IARC determined, “[h]uman exposure to bitumens and their emissions comes

almost exclusively from occupational exposure during manufacture and use of the products.”

Neither human nor animal evidence indicates that Paving Asphalt Emissions pose a

carcinogenic hazard.

In 2013, IARC established, “there is inadequate evidence in humans for the carcinogenicity

of occupational exposures to bitumens and bitumen emissions during road paving;” and

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“[T]here is inadequate evidence in experimental animals for the carcinogenicity of straight-

run bitumens [and fume condensates].”

Asphalt Paving Emissions continue to be well-regulated, controlled, and reduced.

Asphalt Paving Emissions are currently regulated through an ACGIH TLV® and Cal/OSHA

Permissible Exposure Limit and are addressed under a Proposition 65 Consent Judgement

(California v. Blue’s Roofing Co. Inc.).

Asphalt Paving Emissions continue to be controlled and reduced in occupational settings

through the use of paver engineering controls and deployment of warm-mix asphalt.

Asphalt and Asphalt Emissions Associated with Road Paving should not be recommended

for Priority Listing by the Carcinogen Identification Committee based on the scientific

evidence.

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Attachment II: Production, Application, and Controlling Asphalt Paving Emissions

Asphalt pavement material or mix is used to construct roadways, airfields, and other hardscapes,

and is typically is composed of about 95 percent mineral aggregate and 5 percent paving asphalt

bitumen (CAS No. 8052-42-4). The bitumen functions as a glue to bind mineral aggregates into a

cohesive mix. The pavement materials are typically mixed at a temperature of approximately

300°F in an industrial facility and trucked to a roadway construction site where it is applied

using specialized machines. An asphalt paving crew typically consists of two or three individuals

associated with a paving machine operation, two or three laborers with rakes and lutes that help

further distribute the pavement material after it exits the paving machine, and two or three

individuals operating individual rolling machines to compact the pavement to its final density.

Over the past two decades, the U.S. paving industry has intensively engaged in reducing bitumen

emissions surrounding paving operations. Beginning in 1996, the asphalt pavement industry

partnered with NIOSH, labor unions, and FHWA to explore opportunities to minimize paving

asphalt emissions through the application of engineering controls. This effort led to a voluntary

agreement with NIOSH to install such control systems on all highway-class paving machines

manufactured in the U.S. after July 1, 1997 (NIOSH, 1997). In 2006, NIOSH conducted a

follow-up study that identified the successfulness of these engineering controls which are now

incorporated on most highway-class pavers in the U.S. (Mickelsen et al., 2006).

As noted in our comments, application temperature is widely recognized as a significant

parameter affecting paving (and other) asphalt emissions. Over the past decade, warm-mix

asphalt (WMA) was developed as an additional innovative method to reduce paving asphalt

emissions at its source. These technologies allow asphalt to be produced and applied at lower

temperatures than conventional asphalt mixes. Most important, WMA has the potential to

virtually eliminate emissions surrounding paving workers. Reductions of up to 50 percent in

asphalt paving emissions have been documented with the use of WMA technology (Mejías-

Santiago & Osborn, 2014). Over the course of five years (from 2009 to 2014), WMA use has

increased more than five-fold and now represents almost one-third of the total asphalt pavement

tonnage placed on U.S. roadways (Hansen & Copeland, 2015).

Through active innovation over the past two decades, Paving Asphalt Emissions continue to be

reduced; in some cases even below detectable levels.

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Attachment II: References

Hansen KR & Copeland A (2015). Asphalt Pavement

Industry Survey on Recycled Materials and Warm-Mix

Asphalt Usage: 2014. Information Series IS 138(5e).

Lanham, MD: National Asphalt Pavement Association.

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