Tagged: DQA

EPA’s Reliance On Outdated Studies Results in Challenge of Two Publications Regarding Refined Coal Tar-Based Sealants

PavementCouncil.org submitted a Request for Correction (RfC) of information to the US Environmental Protection Agency (EPA) under the Data Quality Act (DQA). The RfC challenges the EPA’s reliance on outdated papers that offer theories about the alleged impact of refined coal tar-based sealants (RTS) on the environment. All of the studies cited by the EPA were published years ago by staff affiliated with the US Geological Survey (USGS) or the City of Austin. Most of the conclusions proffered in these publications have been called into question by more recent peer reviewed articles and comments published in well respected scientific journals. Up to now, the more recent literature concerning RTS has been overlooked by the EPA. The RfC is available on EPA’s Information Quality web site.

One EPA publication that specifically has been challenged can be found at the EPA’s CADDIS website. CADDIS is an EPA initiative developed to help scientists and engineers assess the manner in which aquatic systems can be affected by a large number of “stressors,” such as those commonly associated with urbanization. Guidance offered by the EPA at this website emphasizes how important it is to consider all relevant evidence when determining the cause or causes of various environmental impacts. The guidance strongly encourages consultation with industry stakeholders who may have important insights and expertise. However, when it comes to RTS, the EPA thus far has failed to solicit input from PavementCouncil.org or consider industry funded research. This oversight has forced PavementCouncil.org to use the formal RfC process as a way to update the EPA, and the public, about the manner in which the scientific literature has evolved. As pointed out in the RfC, the EPA also has overlooked reports and studies prepared by other government agencies that have failed to support the RTS hypotheses offered by the USGS and the City of Austin in their older studies.

PavementCouncil.org also seeks correction of a document titled Coal-Tar Sealcoat, Polycyclic Aromatic Hydrocarbons, and Stormwater Pollution which purports to define a “Stormwater Best Management Practice.” Again, in generating this document, the EPA has relied on outdated articles published by the USGS and City of Austin team even though those articles have been critiqued in more recent peer reviewed publications. Such selective use of the scientific literature, citing articles only on one side of a scientific debate, is an example of what appears to be White Hat Bias (“bias leading to the distortion of information in the service of what may be perceived to be righteous ends.”). Since evidence documented in many articles and comments on RTS have been omitted from this second EPA document, PavementCoatings.org was forced to address these issues as well in the RfC that has just been filed.

PavementCouncil.org has challenged the USGS studies via three DQA filings since May, 2013, available on the USGS web site. That process is still ongoing.