Coal tar pavement sealants have long been the mainstay of the Federal Aviation Administration (FAA) for airport pavement maintenance, but that appears to be changing. Just last month, the FAA published proposed changes to their standard recommendations for pavement maintenance.
The specifications are more accurately called an "Advisory Circular" because they are intended to advise design engineers versus being prescriptive. The Circular, 150/5370-10G, is currently in draft form. Comments were sought from industry through October 31st.
The new sections include: emulsified asphalt seal coat, and fuel resistant asphalt. The emergence of fuel resistant asphalt has been covered here before in a republication of an Airport Improvement Magazine article.
One of the interesting elements of the revised standards is found in the revisions to a coal tar emulsion standards or more precisely Thermoplastic Coal Tar Emulsion Surface Treatments. No other product requires more disclaimers (and there are none for asphalt emulsion) and regulatory legalese than this one that include well-known agencies and laws like OSHA, EPA, the Clean Water Act, SARA, Superfund, EPCRA, and CERCLA. Yet we continue to let this product to be used on playgrounds and residential properties!
(1) U.S. Department of Labor, Occupational Safety and Health Administration (OSHA), Regulations (Standards – 29 CFR), 1910.1200 establishes the requirement and minimum information for the MSDS for hazardous materials. The CAS registry numbers for the components identified in the rejuvenation product are the basis for compliance with Title 40 of the CFR – Protection of the Environment limitations.
(2) Title 40 of the CFR – Protection of Environment, Chapter 1, Environmental Protection Agency, Subchapter C – Air Programs, Part 59, National Volatile Organic Compound Emission Standards for Consumer and Commercial Products, includes a rejuvenation product as a bituminous coating and mastic. The limit in the CFR for bituminous coatings and mastics is 500 grams VOC per liter (4.2 pounds VOC per gallon (500 grams VOC per liter)). The airport may have more restrictive limits than listed in the CFR.
(3) Title 40 of the CFR – Protection of Environment, Chapter 1, Environmental Protection Agency, Subchapter D – Water Programs, Part 116, Designation of Hazardous Substances, lists the elements and compounds that are designated as hazardous substances under the Clean Water Act. This designation includes any isomers and hydrates, as well as any solutions and mixtures containing these substances. The CAS registry numbers are listed for cross-reference with the MSDS.
(4) Title 40 of the CFR – Protection of Environment, Chapter 1, Environmental Protection Agency, Subchapter J – Superfund, Emergency Planning, and Community Right-To-Know Programs, Part 302, Designation, Reportable Quantities, and Notification, identifies reportable quantities for hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act and the Clean Water Act, and sets forth the notification requirements for releases of these substances. The CAS registry numbers are listed for cross-reference with the MSDS.
(5) Environmental Protection Agency, EPA 550-B-01-003. Lists of Lists, Consolidated List of Chemicals Subject to the Emergency Planning and Community Right-To-Know Act (EPCRA) and Section 112(r) of the Clean Air Act, October 2001, provides information and includes chemicals subject to reporting requirements under the Emergency Planning and Community Right-to-Know Act (EPCRA), also known as Title III of the Superfund Amendments and Reauthorization Act of 1986 (SARA)1, and chemicals listed under section 112(r) of the Clean Air Act (CAA). The CAS registry numbers are listed for cross-reference
with the MSDS.