Chinese Floor Underlayment Paper with Coal Tar Presents Clear Health Hazard

Long term, low-level exposure to coal tar has been demonstrated to be a health hazard. The most recent entry of flooring paper manufactured in China that contains coal tar in the US market poses a serious health concern. One manufacturer, Lixian Qingshan, sells this product under the various labels and distributes through various channels. Exposure through inhalation and skin contact — both of which can occur while installing the flooring underlayment and handling rolls of product — should be avoided. All efforts should be made to protect workers in the building construction trade from exposure.


In January 2010, Fortifiber contracted an independent testing firm to perform a chemical analysis and determine whether coal tar was present in samples of building paper from Lixian Qingshan. The report confirmed the presence of coal tar in the Lixian Qingshan black asphalt kraft sample. In addition, polycyclic aromatic hydrocarbons (PAHs), chemicals known to be present in coal tar, were found in the sample and quantified in the report. Among the six PAH compounds detected in this sample, Chrysene was measured at 560 mg/kg.

This is the second attempt by Lixian Qingshan to enter the US market with a product containing hazardous coal tar. The first attempt was confirmed in May 2006 in the building paper market on the West Coast. The difference this time is that Lixian Qingshan added a roll label with Fortifiber’s well-respected HWD-15® trademark. The Fortifiber product can be distinguished by presence of the HWD-15® trademark on the face of the material. The genuine HWD-15® also has the Fortifiber® trademark on the roll label.

Health Risks

The International Agency for Research on Cancer lists coal tar as a “Group One Carcinogen.” “Group One” is the classification for substances known to cause cancer in humans, and includes asbestos and gamma radiation. In a U.S. Department of Health and Human Services report issued in August 1995 titled; “Toxicological Profile for Polycyclic Aromatic Hydrocarbons,” they found that:

  1. Individuals exposed by breathing or skin contact for long periods to mixtures that contain PAHs and other compounds can develop cancer.
  2. Adverse non-cancer respiratory effects, including bloody vomit, breathing problems, chest pains, chest and throat irritation, and abnormalities in chest X-rays have been reported in humans exposed to PAHs.
  3. The skin is susceptible to PAH-induced toxicity in both humans and animals.
  4. Workers exposed to substances that contain PAHs (e.g., coal tar) experienced chronic dermatitis and hyperkeratosis (EPA 1988a).
  5. The PAH benzo(a)pyrene has been shown to markedly inhibit the immune system, especially T-cell dependent antibody production by lymphocytes.
  6. There is potential for adverse reproductive effects to occur in humans exposed to benzo(a)pyrene in the workplace or at hazardous waste sites.

The National Toxicology Program, an interagency governmental program for evaluating public health concerns, has published a substance profile on “Coal Tars and Coal Tar Pitches.” This profile states that occupational exposure to coal tar is associated not only with skin and scrotal cancer but “…also has been associated with cancer at other tissue sites, including the lung, bladder, kidney, and digestive tract.”

Coal Tar and Asphalt are Not the Same

In 1983, OSHA removed asphalt from coverage under the Coal Tar Pitch Violates Standard, citing qualitative and quantitative differences between the volatile materials that arise from coal tar and asphalt. A study that compared the skin carcinogenicity of “roofing asphalt” and “coal tar pitch” reported that asphalt fume material contains less than 1% PAHs, while coal tar pitch fume contains more than 90% PAHs. (Niemeier et al., 1982) The lower levels of PAH compounds in asphalt can be explained because the crude oil from which it is processed contains much lower levels.

Coal Tar Coatings Are Hazardous in Any Form

A 1982 memorandum, from Patrick Tyson, OSHA Federal Compliance and State Programs Director, asserts that coal tar is hazardous in any form. The memo states that, “The constituents of coal tar pitch are chemical substances that are collected as they volatilize during the destructive distillation of coal to produce coke, which is the distillation residue of coal. This fact places the constituents under the coal tar pitch volatiles standard. It is irrelevant whether the constituents are in solid, liquid or gaseous form.” This means that black flooring paper impregnated with coal tar presents the same risks as any other form of coal tar.

Coal Tar Exposure Limits

OSHA limits permissible workplace exposure to airborne coal tar pitch violates to 0.2mg/m3 averaged over an 8-hour work shift. The NIOSH recommended limit is 0.1mg/m3 averaged over a 10-hour shift. Precautions to reduce employee exposure include establishing regulated, marked areas, enclosing operations and using local exhaust ventilation or tight fitting respirators, full protective clothing and gloves, thorough washing of clothing and persons immediately following exposure, and not eating, drinking or smoking during exposure or prior to washing.

Trust in Fortifiber’s HWD-15®

The HWD-15® product has been used to protect residential and commercial floors, and has been serving the market as the industry’s most popular vapor retarder for over a decade. The product is made from asphalt, and has no coal tar in its construction. It is made in the U.S.A. utilizing 100% domestic content materials. HWD-15® is only distributed by a select group of hardwood flooring professionals. The HWD-15® trademark is on the face of the product itself, not just the roll label. This assures you are looking at the genuine HWD-15® Hardwood Floor Underlayment.

Coal Tar in the News

California Requires Cancer Warning Label
California’s Proposition 65 requires warning labels on products that contain carcinogens. The State requires some products containing coal tar to carry the warning, “This product contains chemicals known to the State of California to cause cancer.” In February 2001, the FDA acknowledged that coal tar is a human carcinogen but has not imposed universal labeling requirements to that effect. The Lixian Qingshan sample contains measurable levels of four different chemicals listed by the State of California EPA as known carcinogens under Proposition 65 (Benzo[a]anthracene, Benzo[b] fluoranthene, Benzo[a]pyrene and Chrysene). The product being distributed in the United States currently does not carry any warning of the possible health effects these chemicals can pose.

Coal Tar Sealants Banned in Austin

Due to extremely high PAH levels found in sediment samples from local waterways in Austin, Texas, the Austin Watershed Protection and Development Review Department undertook a joint study with the US Geological Survey, and documented high levels of PAH chemicals in runoff water from coal tar sealed parking lots. Concentrations were 65 times higher than unsealed lots. When presented with the evidence, the Austin City Council unanimously passed an ordinance in November 2005 to ban the use of coal tar based sealants on parking lots and driveways within the city limits. Based on the action taken in Austin, the city of Madison, Wisconsin is also considering a ban. The US Congress has been briefed and is currently looking at the long term public health effects and a possible national ban.

Additional Resources

For more information on the health risks associated with coal tar, please visit the following resources:

International Agency for Research on Cancer

US Department of Health & Human Services: Agency for Toxic Substance and Disease Registry

US Department of Health & Human Services: National Toxicology Program

US Department of Labor: Occupational Safety & Health Administration (OSHA)

Centers for Disease Control & Prevention: The National Institute for Occupational Safety and Health (NIOSH)

Office of Environmental Health Hazard Assessment (OEHHA)