# Members of EPA’s Office of Resource Conservati on and Recovery met with members of the Asphalt

Roofing Manufacturers Association (ARMA) on July 15 to hear their concerns about stigma associated

with roofing products made with coal combustion boile r slag if the Agency decides to finalize a Subtitle C

rule. ARMA made the following points:



# • In 2009, ARMA used over 1 million tons of boiler slag for roofing shingles.



# • Based on their history of being on the wrong end of negative advertising regarding health effects of

asphalt (a NIOSH study conducted in 2000, the findings of which were apparently taken out of context

by a competitor), asphalt roofing manufacturers are certain the same will happen if CCRs are

regulated as a hazardous waste.



# • They don't see any distinction betw een listing as a special waste and listing as a hazardous waste.



# • Even if beneficial use is excluded from regulation, regulation as a hazardous waste will lead to a

hazardous waste stigma.



# • The Stigma effect associated with a C-rule would compel them to switch from boiler slag to silica

sand, a material associated with occupational heal th risk from silicosis, or crushed rock, which

involves a larger expenditure of energy, carbon dioxide emissions, and virgin material.



# • How will spills of CCRs during the manufacturin g process and during trans portation be classified?



# • What is the status of slag that has not entered the manufacturing process (i.e., purchased but never

used) and of off-spec material?1ARMA/EPA Discussion of ProposedClassification of Slag as HazardousWaste and the Effects on theAsphalt Roofing IndustryJuly 15, 20102ConsequencesDuring 2009, the roofing industry used morethan 1 million tons of slag. If classifiedhazardous, the roofing industry cannotcontinue using slag.3Reasons for using slag1. Adds strength to shingle.2. Protects asphalt from photodegradation.3. Prevents shingles from sticking together inthe bundle.6Stigma“Asphalt Shingles Put HazardousWasteon Top of Your Home”7Toxic Tort Liability“The hazardous waste in the asphaltroofing you manufactured and soldme harmed my...”910February 15, 2002 DHS wrote a letter toCompany stating:Î“DHS and NIOSH are concerned about themisleading nature of your ads.”Î“You are misrepresenting the conclusions and resultsof the NIOSH study entitledHealth Effects ofOccupational Exposure to Asphalt”.Based on “rumor” of Subtitle Cclassification ARMA members areactively seeking more expensivereplacements:Silica sand– employee exposure issues.– quarried, crushed, washed, etc.Quarried/crushed rock– mined, crushed, washed, etc.– employee exposure issues.13In addition to the Stigma, issues facingthe Asphalt Roofing Industry includethe status of:ÎCCR processing for roofing – increased cost.ÎTransportation spills during truck or RR unloading.ÎManufacturing spills on production line.ÎCooling water that contacts product duringmanufacturing.ÎOff-spec manufacturing scrap.1415Shingle prices to go upsignificantly and make asphaltshingles less competitive due toadditional costs associated withslag replacements.16ConsequencesDuring 2009, the roofing industry used morethan 1 million tons of slag. If classifiedhazardous, the roofing industry cannotcontinue using slag.