University of California, San Francisco
c/o California Poison Control System
San Francisco Division, Box 1369
San Francisco, CA 94143-1369
February 19, 2008
To Whom It May Concern:
The multi-year asphalt (hot mop) re-roofing of a community of homes (Antelope, CA) has been brought to my attention as the director of the University of California, Pediatric Environmental Health Specialty Unit prompting this letter. I have reviewed the TASC Asphalt Roofing Tar Summary draft report created for this community and would like to add a few comments from my perspective.
The constituents of the fumes that neighbors are forced to inhale by virtue of living near an ongoing roofing activity include known carcinogens (PAHs), skin and respiratory irritants, and unpleasant strong odors. Children, by virtue of their higher minute ventilation and outdoor play activities, are potentially at risk for greater exposure to these hazards than an adult residing at the same location. Since children are growing and developing they are also susceptible to different and more severe health impacts. Children’s airways are smaller, still growing, and developing, potentially putting them at greater risk for developing or exacerbating underlying asthma. Asthma accounts for a substantial proportion of children’s hospitalizations in California. Any carcinogen exposure early in life may be considered to include a higher risk to those exposed as a result of the rapid proliferation and differentiation of cells during this time as well as the greater life expectancy that allows for more years for a cancer to manifest. These concepts are recognized by the US EPA in their carcinogen guidance for risk assessment.
Exposure to noxious odors is in and of itself a hazard as is noted in the TASC document. There is a very limited literature about non-occupational or childhood exposure to asphalt roofing fumes. This is not surprising as these sorts of health effects studies in children are rare. One would expect that the risk involved in a brief isolated exposure of this kind to be relatively small but in a large community program including work over multiple years the hazard considerations would be appreciably different. Whatever ill health effects one might expect would more than likely be disproportionately shouldered by the children of the community. Since there are established, safer, and cost effective roofing alternatives currently in common use, it seems unwise to continue with large scale asphalt project that exposes the community to a long term exposure to these fumes.
Please let me know if I can be of some further assistance in this matter. I can be reached at (415) 206-4083 or toll free 1-866-827-3478.
Sincerely,
Mark Miller MD, MPH
Director UCSF Pediatric Environmental Health Specialty Unit
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