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HEALTH CONSULTATION

Residential Area Shop Emissions

SOUTH PHILADELPHIA
PHILADELPHIA, PENNSYLVANIA


STATEMENT OF PURPOSE

In August 1991, U.S. Congressman Thomas Foglietta petitioned the Agency for Toxic Substances and Disease Registry (ATSDR) to conduct a health assessment or evaluation of a neighborhood in South Philadelphia [1]. A local community group had contacted the Congressman's office with health concerns regarding the air emissions from an estimated 53 auto body and auto repair shops within a six square block area (Figure 1).

Since receiving this petition, in an attempt to gather pertinent information, ATSDR Region III staff visited the area of concern on several occasions, frequently corresponded with members of the local community group, attended meetings with local health department officials, and corresponded with community residents, officials from state and federal health and environmental agencies, and two local physicians. In October 1993, ATSDR's Petition Screening Committee determined that preparation of a health consultation was an appropriate response to the petition [2].

The purpose of this health consultation was to determine, by a review of the existing information on air emissions and reported health problems in the area, whether the auto body shops are causing an increase in respiratory and other health problems in the community. ATSDR reviewed the air sampling data collected within and outside of one shop and concluded that the emissions likely would not result in concentrations of pollutants in outside air high enough to cause health problems. The air sampling data, however, are limited both in scope and in geographic area covered and ATSDR recommends further air sampling or air emissions modeling to more definitively rule out any community health hazard. ATSDR does not recommend a health study because of the low concentrations of the pollutants detected, the non-specific nature of several of the health symptoms reported, the lack of a known or suspected association between exposure to the air pollutants and several of the diseases or symptoms reported, and the small number of people reporting health problems.

ATSDR concludes that there is an indeterminant public health hazard associated with auto body shop emissions in the petition area. Based on general knowledge of shop operations and review of the existing AMS, EPA, and PADEP air screening and sampling information collected to date, it appears unlikely that the air emissions would cause adverse respiratory symptoms and other health problems in persons living nearby. The air sampling data, however, are limited and does not include data on polyisocyanates.

Figures are provided in Appendix A. Appendix B provides abbreviations for terms used throughout this document. A version of this health consultation was issued for public comment in January, 1995. A response to comments received during the public comment period appears in Appendix C. This health consultation has also been updated and revised as appropriate since the public comment version.


BACKGROUND AND STATEMENT OF ISSUES

A. Description of Petition Area

The petition area is located approximately 1.5 miles south of the central business district of Philadelphia (Figure 1). The area is primarily row house residential (homes built circa early 1900s) but contains numerous commercial establishments interspersed between homes or located on street corners or along the larger streets within the area. The commercial establishments are those typical of inner-city residential areas in large U.S. East Coast cities (e.g. gas stations, grocery stores, sandwich shops, dry cleaners, small retail shops, auto body/repair shops). A few light industrial operations lie within the petition area along the northern border. Philadelphia's large oil refineries are located roughly 1.5 miles to the southwest.

The petition cites the existence of "no less than 53 auto body or repair shops in a six square block area." Although a complete shop-by-shop inspection had not been performed by the community group or regulatory or public health personnel at the time of the petition, a review of the shop names identified by the local community group indicates that 24 of the shops are in the auto repair business, 18 are in the auto painting or body repair business, and 11 are involved in miscellaneous auto-related sales [3]. Several more auto body/repair operations may exist in the area but were not identified (small shops may fail to register with the local licensing agency or decline to advertise for business).

Long-term air monitoring data exist for selected locations in the Philadelphia area only for the National Ambient Air Quality Standard (NAAQS) pollutants: ozone, carbon monoxide, sulfur dioxide, nitrogen dioxide, particulate matter, and lead. Like many urban areas nationwide, the five-county metropolitan area which includes Philadelphia has been routinely classified by the U.S. Environmental Protection Agency (EPA) as a nonattainment area for ozone and, until recently, carbon monoxide. In the last ten years, average carbon monoxide levels for the metropolitan area have declined significantly; average ozone levels do not show a significant trend over this period. To put this information in some perspective, in January of 1998, 59 geographic areas of the United States were classified by EPA as nonattainment areas for ozone, and 29 areas were classified as nonattainment areas for carbon monoxide [4].

B. Community Concerns

Significant community health and nuisance concerns regarding auto body/repair shop emissions first surfaced in June of 1990. The majority of the concerns have been expressed by members of a local community group known as the South Philadelphia Environmental Action Coalition (SPEAC) and have focused on one to three shops near a member's home. However, concerns are not confined to the three shops. Following is a timeline of significant community actions and the concurrent response by regulatory or health officials:

Community Actions Date Agency Actions
Beginning of odor complaints to Philadelphia Air Management Services (AMS) regarding one shop (20+ in a 14 month period) [5][6]. June 1990 AMS begins series of inspections.
Petition submitted to Philadelphia Department of Public Health (PHD) about paint emissions from one shop [7]. September 1990 PHD responds, indicating shop compliance [8].
  December 1990 AMS conducts screening at one shop.
  March 1991 AMS conducts semi-quantitative sampling at one shop.
Petition submitted to city Managing Director about conditions at three shops [9]. April 1991 Several responses are made by the city.
Report from community that children suffered health effects due to emissions form three shops [10]. Pennsylvania Ballet Company reports children suffered health effects from a different shop [11]. July 1991  
Congressman Foglietta submits petition for a public health assessment to ATSDR. August 1991 AMS conducts air quality modeling assessment of one shop.
  October 1991 to September 1992 AMS investigates conditions at 27 shops outside of petition area.
SPEAC begins attending Air Pollution Control Board (APCB) meetings. May 1992 ATSDR staff meet with SPEAC and begin collecting information.
  October 1993 ATSDR decides to conduct health consultation on auto body/repair shops.
    AMS accelerates inspection of shops and coordination with Philadelphia Department of Licenses & Inspections (L&I).
    APCB establishes auto body shop subcommittee.
  June 1994 EPA decides to conduct health/environmental characterization study of South and Southwest Philadelphia; the petition area is included.
  July 1994 PHD holds public meeting on shops; ATSDR participates.
  January 1995 ATSDR issues draft health consultation for public comment.
  May 1995 The National Institute for Occupational Safety and Health (NIOSH) tours several auto body/repair shops in the South Philadelphia area.
  September 1995 EPA Region III commences an Auto Body/Repair Shop Compliance Assistance Program.
  February 1996 AMS enacts an amendment to Air Management Regulation V, Control of Emissions of Organic Substances from Stationary Sources. The amendment adds Section XIV, pertaining to Automobile Refinishing Operations.
  April and May 1996 EPA Region III collects air samples from six sampling stations in the South and Southwest Philadelphia area.
    The Pennsylvania Department of Environmental Protection (PADEP) performs air sampling from three auto body shops in the petitioned area.
  July 1997 EPA conducts multi-media compliance assistance surveys at auto body/repair shops in Philadelphia as part of a Pollution Prevention Initiative.
    EPA publishes the Pilot Multi-Media Environmental Health Characterization Study of South and Southwest Philadelphia, which includes the petition area.
  August 1997 The AMS amendment to Air Management Regulation V becomes effective.
  1998 AMS continues with efforts to bring auto body shops in to compliance; EPA continues with pollution prevention activities.

Until approximately late 1995, ATSDR Region III staff and a spokesperson for SPEAC frequently discussed health concerns. Much of the information regarding health symptoms experienced by members of the community was provided to ATSDR Region III by this individual and another family member. Reported symptoms included difficulties in breathing, itching or burning eyes, headaches, excessive mucus buildup, nose bleeds, body rashes and lack of muscle control. Odors were mentioned as a recurring problem. A concern also has been expressed about a perceived elevated incidence of brain cancer.

The spokesperson for SPEAC believes that an appropriate health agency should conduct a formal health study or health survey to determine whether or not the prevalence of respiratory ailments within the community is unusually high [10]. The spokesperson believes that this action is necessary even if the auto body/repair shop emissions are ultimately determined not to be the cause of this perceived problem.

In late 1994, in an attempt to gauge the extent of health concerns by other community residents, ATSDR Region III asked SPEAC to have residents who had previously expressed health concerns to city officials, the news media, and SPEAC to contact ATSDR Region III by phone. Following this request, ATSDR Region III was contacted by three residents living near the shop initially identified as having an emissions problem. These residents reported similar but fewer health symptoms than those already reported. (It was suggested to ATSDR that several residents with health concerns did not contact ATSDR Region III staff for various reasons, including lack of faith in government response to public concerns and anxiety about providing names and phone numbers on a telephone answering system.) Several community residents have also expressed their health concerns to a local newspaper and television and radio media [12] [13].

C. Regulatory Responses

Philadelphia Department of Air Management Services/Philadelphia Planning Commission

Historically, because of the low volume of paints and solvent used, emissions from auto body repair/paint shops were not directly the subject of regulation by local, state, or federal regulatory agencies. The Philadelphia Fire Code, however, requires that motor vehicles be spray painted only within a spray paint booth built to Code specifications and that each booth be equipped with an approved exhaust system. Construction of a paint spray booth requires a building permit from L&I, an operating license from AMS, and an AMS permit for the use of air pollution control equipment. Approval for placement of a shop within the city limits is obtained from the City Planning Commission and/or the Zoning Board of Adjustments.

In 1992, AMS investigated 27 auto body shops within the city limits as part of a grant agreement with the EPA to evaluate small source emissions of volatile organic compounds (VOCs). AMS chose to investigate auto body shops partially as a result of the concerns being raised by the South Philadelphia community group. However, none of the shops inspected were within the petitioner's area of concern.

AMS evaluated each shop's spray painting operations, emissions (including any potential impact on the immediate neighborhood), and paint spray booth and filter system. AMS also collected qualitative and quantitative information on paint use to determine compliance with applicable regulations. No outside ambient air monitoring was conducted. AMS concluded that the shops did not pose a health threat or nuisance to the surrounding communities, although, in a few cases, VOC emissions from spray paint were found to exceed allowable regulatory limits and required corrective action [15].

In October 1993, AMS acknowledged that a considerable number of the auto body/repair shops in the petitioner's area of concern had not received proper licensing or permitting from either L&I or AMS. AMS identified over 300 auto body shops citywide that were without air pollution licenses and approximately 60 auto body shops with AMS licenses. Beginning in the winter of 1993, AMS initiated a more active approach to the inspection and licensing of these shops and began a closer coordination effort with L&I [14]. At the request of AMS, the APCB established a subcommittee to further address the auto body/repair shops emissions situation. By October 1994, AMS had inspected 41 of an estimated 78 auto body shops in South and Southwest Philadelphia. Of the 78 shops, AMS determined that 14 were licensed for air pollution, 17 needed licenses, 16 did not require a license, and information was lacking on 28 shops [48].

Through the work of the APCB, an amendment to Air Management Regulation V was made effective in February 1996 after a public hearing and public comment period [43]. The amendment regulates operating standards and practices, recordkeeping requirements, and equipment standards for auto refinishing operations. The amendment states that emissions of toxic air contaminants must comply with Air Management Regulation VI, "Control of Emissions of Toxic Air Contaminants," and that no visible emissions or odor is permitted from facilities performing auto refinishing. All paint spraying must be performed in a paint spray booth operated according to design and specifications of the manufacturer, and AMS may require air emissions modeling on a case-by-case basis. All auto body shops in the city were required to comply with this amended regulation by August 1997.

In light of the new amended regulation and ongoing enforcement efforts, AMS has issued approximately 123 licenses to auto body shops citywide, and 52 license applications are pending. AMS has also issued 72 violations for an estimated 131 auto body shops in the city that are operating without air pollution licenses. All of these 131 shops are scheduled to be inspected [49]. The agency has also been an active participant in EPA's pollution prevention activities geared toward auto body/repair shops.

Since March of 1995 three new auto body shops have received Philadelphia Planning Commission approval to locate in the petition area [50].

Occupational Safety and Health Administration/National Institute for Occupational Safety and Health

To determine if the Occupational Safety and Health Administration (OSHA) has received complaints from auto body/repair shop workers or has conducted an investigation of any of the listed shops, ATSDR Region III contacted the OSHA regional office [16]. This request was made since auto body/repair shop workers would be expected to experience the greatest exposure to shop emissions. A shop with poor industrial hygiene practices might also present a public health threat. OSHA's response stated that "a thorough file review indicates that no investigation has been conducted" [17].

In May 1995, at the request of the ATSDR Region III office and through the assistance of AMS, NIOSH toured eight auto body/repair shops in South Philadelphia. After its visit, NIOSH recommended that all spray painting operations involving polyisocyanates (isocyanates) be conducted in a spray painting booth in order to protect worker health and the health of the surrounding community [44]. NIOSH noted during its tour that all but one of the shops had a spray paint booth. The one shop without a booth reportedly had most of its painting jobs performed by other shops.

NIOSH noted that emission stacks from the spray painting booths appeared to be 4-5 feet higher than the adjacent buildings. These short stacks could, under certain conditions, allow emissions containing polyisocyanates to migrate toward neighboring houses [44]. NIOSH recommended that air pollution dispersion modeling be considered to evaluate whether these emissions might cause excessive exposure to community members. NIOSH noted that air sampling for polyisocyanates in the neighborhood would prove difficult as a result of varying atmospheric and other conditions and might not provide an accurate representation of exposure levels [44].

Environmental Protection Agency

In June of 1994, EPA Region III announced plans to conduct a health and environmental characterization study of South and Southwest Philadelphia. The purpose of the study was "to assess the environmental conditions of these geographic areas and determine the extent of the impact of the environment on the health of the residents." The geographic area addressed by this health consultation is included within the confines of the larger EPA study. ATSDR agreed to assist EPA Region III by providing recommendations for the health characterization component of the study.

EPA's Pilot Multi-Media Environmental Health Characterization Study of South and Southwest Philadelphia (Characterization Study of South and Southwest Philadelphia) was published in July 1997 [45]. The study concluded that the likelihood of community health effects from exposure to individual auto repair shops is probably low, but that the effects of cumulative exposure to many shops are uncertain.

Partly as a result of citizen concerns regarding auto body shop emissions, EPA Region III and EPA headquarters initiated a pollution prevention and compliance assistance program in Philadelphia focused on ways to minimize the generation of waste and reduce worker exposure to hazardous substances in auto body shops. Activities in this program commenced in 1995 and continue presently.

In 1997, as part of the pollution prevention/compliance effort, EPA conducted multi-media compliance assistance surveys at selected auto body shops throughout Philadelphia (including 15 in South and Southwest Philadelphia) to evaluate trends in shop owner/manager's environmental compliance knowledge [46]. EPA determined that most of the shop owners/managers have some understanding of environmental compliance requirements and that many hire contractors to remove used oil, solvents, batteries, antifreeze, tires, and rags. EPA observed that hazardous wastes were not always labeled properly. In addition, many of the shop owners clean up minor spills with rags or dry sweep, which EPA reports is preferable to washing the waste into a floor drain. Managers of facilities with oil/grease traps and/or baffle systems reported being aware that they needed to clean out the traps once an "oily" sludge Exiting ATSDR Website has built up inside.

Pennsylvania Department of Environmental Protection

No statewide regulations currently exist for auto refinishing [47]. A proposed rule by the Environmental Quality Board will be available for public comment in several months, and a series of public hearings regarding this rule will begin in late September or October 1998. This rule would establish work practices and permitting requirements for auto refinishing facilities. It would also require that finishes used by the auto refinishing industry in Pennsylvania comply with federal requirements. New federal guidelines for VOC content in automobile finishes were established in September 1998.


DATA REVIEW

As a result of the community concerns and complaints received by AMS (reported in the background section), AMS conducted sampling events in December 1990 and March 1991. Both sampling events were at the one shop initially cited as posing an emissions problem.

As part of EPA's Characterization Study of South and Southwest Philadelphia, a short term air monitoring effort was conducted by EPA in 1996 at six monitoring stations in South and Southwest Philadelphia. The Pennsylvania Department of Environmental Protection (PADEP) also conducted sampling with its mobile analytical unit (MAU) in the South and Southwest Philadelphia area during two sampling events in April and May 1996.

A. Air Sampling

1990 AMS Sampling

In December 1990, AMS used a portable flame ionization detector (FID) to detect total organic vapors within and near the shop initially cited as posing an emission problem. Readings were taken during the spray painting of one vehicle located in a spray booth in the shop garage. Recorded readings were 20 parts per million (ppm) total organic vapors in the shop garage and 20 ppm in the shop emissions roof stack. A level of 6 ppm was recorded in the shop office and 2 to 3 ppm along the street and alley adjacent to the shop. Based on the inspector's experience, the street level readings were considered to be "background," or comparable to the FID readings one would expect in most locations throughout inner-city Philadelphia [18].

1991 AMS Sampling

A more extensive survey was conducted by AMS on March 22, 1991. In addition to use of a portable FID, sorbent tubes were used to collect samples from the headspace vapors above paint materials used at the shop, from spray booth stack emissions, and from outside air upwind and downwind of the shop. Sorbent tube samples also were collected in front of the residence of a local community group member located across from the shop. The sorbent tubes were later desorbed of collected organics, and qualitative analysis was performed via Gas Chromatograph/Mass Spectrometer (GC/MS) laboratory analyses. (The portable FID was used to identify total organic vapor concentrations and semi-quantify specific organic chemical concentrations in conjunction with the qualitative results from the spectrometer analyses.) Samples were taken to coincide with spray painting operations. The sampling event was curtailed due to the onset of heavy rainfall at midday [19].

Several points about the strengths and limitations of the AMS sampling strategy should be made before the findings of this sampling event are presented. The portable FID is a general survey or screening instrument which provides an immediate estimated total concentration of all organic compounds in the monitored air. It cannot differentiate between specific organic compounds. The FID responds to almost all organic compounds, but the sensitivity of its response depends on the chemical structure of the compounds. It is usually calibrated with the organic gas methane, meaning that the FID can accurately indicate the concentration of methane in the air if it is the only organic substance present. If other organic compounds are present (as is the case in most urban areas such as South Philadelphia due to the presence of pollutants from many emission sources) and their identity is known, there are ways to grossly estimate their highest possible concentrations through the use of "response factors" provided by the FID manufacturer for different organic compounds in comparison to methane. In essence, AMS determined the presence and identity of several organics other than methane in the air by conducting laboratory analysis of the air samples collected on the sorbent tubes. AMS then grossly estimated a maximum, worst-case concentration of a small subset of these other organics (specifically, acetone and methyl ethyl ketone [MEK, or 2-butanone]) by using the FID response factor approach. Because this was a screening effort, AMS did not use the laboratory analyses to more definitively quantify the concentrations of these other organics.

Sorbent tube sampling followed by laboratory analyses revealed the presence of the following compounds in front of the residence and in the shop stack emissions (in at least one of the stack samples): acetone, MEK, benzene, 2,2-dimethylpropane (neopentane), toluene, perchloroethylene (PCE), ethylbenzene, xylenes, (1-methylethyl) benzene (cumene), and two unidentified petroleum hydrocarbons. Other compounds found in front of the residence but not at the shop included 2-methylpropane (isobutane), chloroform, 1-ethyl-4-methylbenzene (p-ethyl toluene), 1-ethyl-2-methylbenzene (o-ethyl toluene), and naphthalene. Several compounds were found at the shop and upwind or downwind of the residence, but not in front of the residence, including methyl phenyl ketone, methyl benzoate, and benzoic acid. Other compounds were found either in stack emissions or in paint material vapors but were not detected in outside air [19].

The highest portable FID reading recorded in front of the residence was 0.3 ppm. Using the response factor approach, AMS calculated a reading of 0.42 ppm (420 parts per billion [ppb]) for acetone and 1.92 ppm (1,920 ppb) for MEK. It appears, from data provided, that AMS estimated concentrations for only these two compounds since they were the compounds believed to be present at the highest levels based on laboratory analysis. Subject to the limitations of the sampling methodology, these values are believed to represent the worst-case instantaneous concentrations possible for either compound because 1) the portable FID response factor approach assumes that the content of the vapors measured is all acetone or all MEK (although it is clear that many other compounds were present in the ambient air near the residence) and 2) portable FID readings were taken during painting periods. Shop personnel indicated that spray painting generally occurs only two hours per working day and that four cars are spray painted on an average day.

1991 AMS Modeling Assessment

In August 1991, AMS performed an air quality modeling assessment of the paint spray booth emissions from the shop. EPA's "SCREEN" Model was used to estimate worst case solvent concentrations in the neighborhood near the shop. The parameters used in the model were quite conservative and considerably overestimated the actual volume and amount of individual solvents used at the shop. Based on model results, AMS concluded that very sensitive individuals might occasionally detect odors of a few of the solvents used at the shop. (These solvents can be detected by smell at very low concentrations.) Assuming proper operation and maintenance of shop ventilation systems, this scenario would only be expected to occur when emissions were high and dispersion was poor [20].

1996 EPA and PADEP Sampling

In 1996, EPA Region III collected air samples from six sampling stations in the South and Southwest Philadelphia area. Although this sampling effort was part of the broader Characterization Study of South and Southwest Philadelphia and was not specifically focused on auto body shop emissions, several of the VOCs analyzed were associated with auto body paints. One station was located at the intersection of 10th and Reed Streets in South Philadelphia, near the area occupied by the shop investigated by AMS in 1990 and 1991. Samples were collected in "summa" canisters at this station over a 24-hour period on five different days in April and May 1996. The canister samples were analyzed for 36 different organic compounds. In addition, filter samples were collected at this station on three different days and analyzed for 35 individual metals [51].

The PADEP also performed air sampling in April and May of 1996 as part of a special study in support of the Characterization Study of South and Southwest Philadelphia. The PADEP used the analytical instrumentation in the MAU to identify or fingerprint specific organic compounds associated with various emission sources in South and Southwest Philadelphia. Air samples were collected in tedlar bags from three auto body shops in the petitioner's area of concern, and the compounds considered by PADEP to be most representative of the sampled air were targeted for future neighborhood ambient air sampling. For eight hours on one day (April 28, 1996) the MAU was stationed at Moyamensing and Washington Streets in an attempt to detect the presence of four compounds (benzene, toluene, ethylbenzene and xylene) identified as fingerprint compounds for the auto body shops [52].

The 1996 air sampling data collected by EPA at 10th and Reed Streets and by PADEP at the intersection of Washington and Moyamensing Streets provide further evidence that the auto body shops are not releasing emissions at concentrations that would cause adverse health effects to surrounding residents. The results of both investigations indicate that none of the compounds analyzed were present at levels of public health concern. It is acknowledged, however, that the sampling data are limited.

B. Health Outcome Evaluation

In December 1992, the PHD made formal requests to state and federal health agencies to evaluate the possibility of approaching this issue from an epidemiological perspective [21, 22]. In January 1993, the PHD concluded that an environmental epidemiology study was not warranted due to an apparent lack of significant exposures associated with the shop emissions [23]. Shop monitoring and environmental testing were recommended. The National Center for Environmental Health of the Centers for Disease Control and Prevention also recommended additional air monitoring before considering further involvement [24].

In September 1993, at the request of the local community group, ATSDR Region III staff wrote to two general practitioners within the area of concern to determine if the physicians had perceived or documented an apparent increase in respiratory illnesses over the previous three years [25]. One physician responded, reporting that he had not observed a pattern or increase in respiratory complaints or eye, nose, or throat irritation. This medical doctor has practiced in the area for more than six years [26].

EPA's Characterization Study of South and Southwest Philadelphia examined death certificate data (including cancer mortality) and cancer incidence data for South and Southwest Philadelphia, which includes the petition area addressed in this health consultation [45]. The Characterization Study of South and Southwest Philadelphia also provided mortality and cancer incidence data for each individual neighborhood in South and Southwest Philadelphia (the petition area is located within the Southwark-Bella Vista neighborhood identified in the Characterization Study of South and Southwest Philadelphia) and compared the data from the various neighborhoods.

Based on the brief description above, it might seem that a detailed discussion of the Characterization Study of South and Southwest Philadelphia would be pertinent. However, it must be emphasized that the study was not designed to investigate the relationship between specific environmental sources and disease in the community. In addition, many of the health problems of concern to the petition area residents (e.g. respiratory problems, brain cancer, and other symptoms) were not or could not be addressed in adequate detail in the Characterization Study of South and Southwest Philadelphia. The reader is encouraged to review either the complete Characterization Study of South and Southwest Philadelphia or the executive summary for a better understanding of the intent and focus of this report as well as to obtain useful information on the environmental health status of South and Southwest Philadelphia.


DISCUSSION

A. Shop Emissions

People who work in auto body shops can be exposed to hazardous particulates or vapors from grinding, cutting, welding, car preparation, and spray painting [27]. Spray painting, however, is the process which has received the most attention in the occupational health literature [28-30], and it appears to be the most probable source for emissions to escape from the shop to outside air. For this reason, our discussion will focus on the presence of auto body shops in the community rather than auto repair shops, where no spray painting takes place. Unfortunately, few reports exist on how auto body shop emissions might impact the quality of the air around the shops or the health of people living near these shops. A literature search conducted in 1994 identified only one published study assessing the potential for auto body shop emissions to effect adjacent or nearby residents.

VOCs/other organics: Auto body shop operations use a variety of materials which result in the release of numerous organic compounds. Most of the compounds released are considered VOCs (VOCs are organic compounds which produce vapors readily; many VOCs are considered hazardous substances by EPA). One study identified up to 100 different organic compounds during indoor air sampling analyses at an auto painting facility [28]. Acetone, xylenes, toluene, MEK, methyl isobutyl ketone, and n-hexane comprised 90 percent of these compounds. Other common VOCs released during shop activities, dependent on the paints and materials used, include ethyl acrylates, ethylbenzene, benzene, PCE, cumene, various acetates, isocyanates, glycols, and ethers [29]. Many of these compounds were detected by AMS during the March 1991 sampling event.

Non-organic particulates (e.g. lead, zinc, and chromium) also can be dispersed into the shop air if pigments in the sprayed paint contain such substances. However, this discussion focuses on the emission of VOCs because they often have the greatest potential for escaping to outside air, AMS sampling was directed toward organic compound analysis, and the pigment systems of individual paints used by the shops are unknown.

Polyisocyanates, or isocyanates, are an important group of organic compounds due to their toxic properties. Generally, these compounds are contained in the spray paint layer used in auto body shops termed the "clear coats" and/or "topcoats." These compounds are of concern because they affect the upper and lower respiratory tract, are powerful irritants, and can cause sensitization reactions leading to asthma and other health effects. A special NIOSH bulletin was issued in March 1996 warning of the health effects of diisocyanate exposure in the workplace [53].

The VOC content of auto body paints ranges between 2.5 to 6.4 pounds of VOC per gallon of coating, as sprayed, depending on the paint type used. Generally speaking, a typical small auto body shop (less than five employees and an average of six paint jobs per week) is estimated to use five to six gallons of paint per week and release about 10.2 pounds of VOCs per day. The majority of the jobs in small shops consists of spot and panel painting and may involve the spraying of only one pint of paint. Medium-sized shops (more than five employees and an average of fourteen paint jobs per week) are estimated to use sixteen to seventeen gallons of paint per week and release approximately 29 pounds of VOCs per day [31]. Most shops in the petition area are small and employ only a few persons.

Petition Area Shops: ATSDR's 1994 review of AMS file data indicated that the three shops in the petition area inspected in 1993 each emitted less than 3 pounds of VOCs per day [32]. This level of VOC emission is quite low and appears to be comparable to the majority of the shops in the area of concern. Some shops, however, may emit at higher rates. These emission rates should also be placed into the context of the larger industrial sources of VOC emissions in Philadelphia. In Philadelphia, emission levels are estimated to range from 54 to 17,000 pounds of VOCs per day per large industrial facility (the pounds per day per facility range is calculated from AMS data on total pounds of VOCs reported to be emitted per facility per year) [33]. These sources, however, generally emit at higher altitudes further away from residences.

Although a complete shop-by-shop inspection has not been conducted, it appears that most shops in the petition area are operating in compliance with regulatory requirements. Since the release of the draft health consultation in 1995, it is probable AMS has performed inspections at many shops in the petition area, but ATSDR was unable to obtain a compilation of inspection events and results since that time. The new amendment to Air Management Regulation V and EPA's pollution prevention and compliance assistance efforts should act to increase regulatory compliance by the shops.

Past records indicate that some shops operated without a spray booth and/or emission stacks designed to reduce emission levels and ventilate emissions above the pedestrian breathing height [34]. Spray painting operations at some shops reportedly were conducted sporadically throughout any given time period on any day of the week. Due to the limited garage space at many of the shops, cars occasionally protruded onto the pedestrian walkway during painting work for small sections of cars or while the paint dried [10]. Chemical odors were occasionally perceived by ATSDR Region III staff during visits to the area in 1994 and 1995.

If a small shop operates outside of regulatory compliance, any VOCs released from the shops to outside air are expected to be present in low concentrations for only a short period of time. This condition is expected as a result of the small volume of paint used at most of the shops, the sporadic nature of the painting operations, and the dilution effects of ambient air. In addition, the geographical spacing of the existing shops does not appear so dense as to cause a significant deterioration of neighborhood air quality. However, it is important to note that this evaluation is based on professional judgment and that only quantitative sampling of the residential air around the shops (or possibly air emissions modeling) can confirm this. The air sampling by AMS, EPA, and PADEP, although limited in scope, suggests that the shop emissions are not presenting a health problem to residents.

Auto body shops are not the only source of air pollution in the petition area. Many of the compounds associated with auto body shop emissions are also components of numerous additional emissions that exist within this urban environment (from motor vehicles, dry cleaning shops, sandwich or "steak" shops, nearby oil refineries, and other industries). Compounds associated with the auto body shops have been found in ambient air at low concentrations at various permanent air monitoring locations throughout Philadelphia [35]. Further, low levels of several of the compounds (e.g. benzene, xylene, ethylbenzene, trichloroethylene, PCE) are routinely found in the indoor air of private residences as a result of the use of common household products [36]. As a result, a sampling strategy to pinpoint the contribution of the auto body shop emissions to residential air quality would be difficult and might require sophisticated sampling techniques.

A more commonplace sampling strategy would be simply to determine the actual concentrations of shop-related compounds in the air in the neighborhood. These values can then be compared against "background" concentrations of the compounds in a similar area of the city without auto body shops. These results can also be evaluated for toxicological significance. The EPA and PADEP sampling in 1996 accomplished this to some extent.

On a national scale, as a result of the 1990 Amendments to the Federal Clean Air Act concerning efforts to reduce ozone levels, EPA recently issued national VOC emission standards for automobile refinish coatings. This final rule, effective September 11, 1998, is designed to reduce the VOC content of paints and other products manufactured for the automotive refinishing industry [54]. EPA estimates that the rule will reduce VOC emissions by 31,900 tons per year. It is possible that this rule could result in equipment changes becoming necessary at many auto body shops [37].

B. Community Health Concerns

Based on general toxicological data on the substances discovered in neighborhood air by AMS in March 1991, and general knowledge of shop operations and the area's physical setting, ATSDR can provide an opinion about the reported health concerns of the community. However, without reliable data on the actual air concentrations of the pollutants, it is difficult to provide any definite conclusions about the toxicological implications of exposure. Nonetheless, for the two compounds for which worst-case air concentrations were estimated near the one investigated shop (acetone and MEK), the levels reported were more than 300 times (300x) below levels shown to cause upper respiratory tract irritation [38].

It is plausible that residents living adjacent to a shop with periodic, uncontrolled vapor emissions could, under worst-case conditions, experience some of the health symptoms mentioned by community members, including headaches, dizziness, or upper respiratory irritation. Such conditions should be short-lived, however, ceasing soon after exposure ends. If shop emissions are of high enough concentration and discharged directly to the breathing space of an individual (e.g. through a vent adjacent to a homeowner's window or walking space), that individual might experience these conditions. Individuals generally considered to be more sensitive to chemical exposures, such as children or the elderly, might be at greater risk to experience symptoms. Based on information obtained from AMS and ATSDR's visits to the area, however, it does not appear that undiluted, concentrated air emissions from the shops are emitted where residents can breathe them directly.

Specific Health Concerns

Central Nervous System: At concentrations much higher than would be expected in the air near the shops, many of the compounds detected by AMS are known to cause central nervous system depression (resulting in such symptoms as dizziness, headaches, fatigue and nausea) and upper respiratory tract irritation [39]. These adverse effects have been observed in humans after exposure to concentrations in the tens to hundreds ppm dependent on the specific chemical studied. Concentrations at such levels are much higher than what would be expected in the air near the shops.Many of these chemicals, however, can be detected by smell at much lower concentrations. Unfortunately, how odors may affect health is not well understood. Research has shown a relationship between odors and health problems but debate exists as to whether the health conditions are physiologic in origin [40].

Respiratory Problems: According to individual chemical toxicological literature on VOCs, concentrations significantly higher than those estimated by AMS and detected by EPA and PADEP would be required to cause adverse respiratory conditions. For those individuals who are unusually sensitive to chemical exposure or who have preexisting respiratory conditions, it might be possible that a mixture of low-level VOCs could cause an adverse respiratory reaction. The body of scientific literature, however, is currently inadequate to support this conclusion. Only further long-term research on the effects of low level chemical exposures can address this possibility. This issue is beyond the scope of this health consultation.

Polyisocyanates, or isocyanates, are of particular concern regarding respiratory irritation in auto body shops, and such irritation reactions can occur at relatively low concentrations. Isocyanate compounds can also sensitize certain individuals such that repeat exposures at even lower levels can cause respiratory problems [54]. Although ATSDR has no sampling or modeling data on isocyanate emissions from auto body shops, professional judgment suggests that it is unlikely that isocyanates would consistently present a health problem to neighboring residents if proper controls are in place [44].

Nose Bleeds: One resident expressed concern that nose bleeds experienced by children during an outdoor event may have been caused by shop emissions. The toxicological literature reviewed does not specifically identify nose bleeds as a symptom associated with exposure to these compounds.

Brain Cancer: It does not seem plausible that there is a link between the auto body shop emissions and brain cancer based on the environmental data. None of the compounds detected by AMS during the March 1991 sampling event are suspected of being human brain carcinogens. Of the compounds detected, only benzene and PCE are known or suspected human carcinogens but they are not associated with cancer of the brain. It is important to note that little is known about the causes of brain cancer.

Need for a Health Study/Survey: ATSDR has been unable to identify sufficient cause or obtain substantiating information to support the performance of a health study or health survey. Because such activities are quite resource intensive, they are generally not recommended unless adequate data exist to suggest a possible association between the health effect and exposure scenario at issue. In addition, the nonspecific nature and common occurrence of many of the reported symptoms (e.g. headaches, itching eyes, excessive mucus buildup) would make it quite difficult to design an effective health study or survey.

In specific situations, requests by citizens for a health study or survey to determine the incidence of disease in a geographic area can often be addressed by a review of existing, pertinent health outcome data reportable to State Departments of Health. Unfortunately, as in most states, a registry for the incidence of adverse respiratory health conditions among Pennsylvania residents does not exist. The multitude of types of adverse respiratory conditions would make planning such a registry even more difficult. Some information is available regarding mortality due to some specific respiratory diseases (see the Characterization Study of South and Southwest Philadelphia).

To summarize community health concern issues, it is unlikely that the general population will experience the health problems expressed by community members as a result of air emissions from auto body shops if the emissions are ventilated out of the shops via roof stacks and ultimately dispersed (resulting in very low concentrations in ambient air). As discussed in the SHOP EMISSIONS section, even ventilation through open garage doors, although certainly not recommended, would be expected to result only in fleeting odors and low concentrations outside the shop before dispersion occurs.

The ambient air of large urban areas similar to Philadelphia has been reported to contain numerous hazardous substances in low concentrations. This condition is the result of the numerous emission sources within a relatively confined space. Many research-oriented epidemiological studies have been conducted over the last thirty to forty years suggesting a correlation between respiratory health problems or increased mortality and the inhalation of "city air." These health outcomes are considered primarily to result from exposure to air particulates (as opposed to vapors or gases) [41, 42]. Philadelphia has been the subject of several of these studies. How this broad and complex issue may relate to the respiratory health status of residents in the petition area is well beyond the scope of this consultation.


CONCLUSIONS

Based on the data and information reviewed, ATSDR concludes that:

  • Based on general knowledge of shop operations and review of the existing AMS, EPA, and PADEP air screening and sampling information collected to date, it appears unlikely that the air emissions would cause adverse respiratory symptoms and other health problems in persons living nearby. The air sampling data, however, are limited and do not include data on polyisocyanates. ATSDR concludes that there is an indeterminant public health hazard associated with auto body shop emissions in the petition area.

  • Based on the low concentrations of the pollutants detected in outside air, the nonspecificity and common occurrence of several of the health symptoms reported, the lack of a known or suspected association between exposure to the air pollutants and several of the diseases or symptoms reported, and the small number of people reporting health problems, insufficient information exists to initiate a health study or health survey of the community living near the auto body shops.

RECOMMENDATIONS

Based on the data and information reviewed, ATSDR recommends the following:

  • Consider investigating, either by air sampling or modeling, if polyisocyanates can be emitted from auto body shops at levels of potential health concern to the surrounding community. Based on past work investigating isocyanate emissions at a facility in North Carolina, ATSDR can assist with this effort.

  • That AMS and L&I continue in their efforts to issue appropriate permits to existing auto body shops and to coordinate regulatory activities. ATSDR also recommends that these departments work with the Philadelphia Planning Commission or Zoning Board of Adjustments to devise an approach to address community concerns regarding any new auto body/repair shops seeking to locate within the area.

  • That AMS and L&I continue to inspect the auto body shops in the area of concern to ensure that appropriate emissions controls are in place, emissions are properly ventilated away from residential breathing space and ventilation systems are located an acceptable distance away from residences.

A copy of this consultation will be provided to all parties who provided information for preparation of this consultation.


PREPARER OF THE REPORT

Jack Kelly, M.S.
Region III Representative


Reviewers:

William T. Going III, M.P.H.
John Steward, M.P.H.
Lynn Wilder, M.S., CIH
Allan Susten, Ph.D., D.A.B.T.


REFERENCES

  1. Letter to Robert Williams, ATSDR DHAC, from U.S. Congressman Thomas Foglietta, July 30, 1991.

  2. Memorandum to Robert Williams, ATSDR DHAC, from John Steward, ATSDR DHAC, September 13, 1993.

  3. List of auto body/repair shops provided to Jack Kelly, ATSDR Region III, from South Philadelphia Environmental Action Committee, May 15, 1992.

  4. National Air Quality and Emissions Trends Report, 1996, Environmental Protection Agency, Office of Air Quality Planning and Standards, EPA 454/R-97-013.

  5. Chronology of AMS Activities provided to Jack Kelly by Robert Ostrowski, Air Management Services, May 19, 1992.

  6. Memorandum to Dr. Maurice Clifford, Philadelphia Health Commissioner from Ronald Cuie, Managing Director's Office, May 28, 1991.

  7. Letter to Dr. Maurice Clifford, Philadelphia Health Commissioner, from community residents, September 14, 1990.

  8. Letter to Gloria Inverso, community resident, from Maurice Clifford, Philadelphia Health Commissioner, October 25, 1990.

  9. Letter to David Pingree, Philadelphia Managing Director, from Concerned Neighbors of Tenth and Reed Streets, April 5, 1991.

  10. Personal communication with SPEAC spokesperson.

  11. Letter to Dr. Conrad Weiler, Philadelphia Zoning Board of Adjustments, from Debra Barrat, Pennsylvania Ballet.

  12. Various newspaper articles/editorial letters, The South Philadelphia Review, October-November 1992.

  13. Interview on local Public Broadcasting Service (PBS) radio show "Earth Talk." July 17, 1992/local television news coverage (Channel 6), date unknown.

  14. Letter to Frank Antico, Philadelphia Dept of Licenses & Inspections, from Greg Tiernan, Philadelphia AMS, October 13, 1993.

  15. Letter to Jerome Balter, PILCOP from Norm Glazer, Philadelphia AMS, November 25, 1992.

  16. Letter to Domenick Salvatore, U.S. Occupational Safety and Health Administration (OSHA) Region III, from Jack Kelly, ATSDR Region III, September 8, 1993.

  17. Letter to Jack Kelly, ATSDR Region III, from Phyllis Kyner, OSHA Region III, November 22, 1993.

  18. Memorandum to Norm Glazer, AMS from Abbas Gholami, AMS, February 13, 1991.

  19. Memorandum to Edward Chasz, AMS Laboratory, May 8, 1991, from Dennis Sosna, Air Toxics Unit, AMS, May 8, 1991.

  20. Memorandum to Robert Ostrowski, AMS from Robert Scott, and Abbas Gholami, AMS, August 9, 1991.

  21. Letter to Dr. Allan Noonan, Pennsylvania Secretary of Health, from Dr. Robert Ross, Philadelphia Health Commissioner, December 18, 1992.

  22. Letter to Dr. Ruth Etzel, CDC NCEH, from Dr. Robert Ross, Philadelphia Health Commissioner, July 7, 1992.

  23. Letter to Dr. Robert Ross, Philadelphia Health Commissioner, from Dr. Allan Noonan, Pennsylvania Secretary of Health, January 11, 1993.

  24. Letter to Dr. Robert Ross, Philadelphia Health Commissioner, from Dr. David Mannino, CDC NCEH, July 16, 1992.

  25. Letter to Dr. Philip Khoury and Dr. Julius Mingroni, private practice physicians, from Jack Kelly, ATSDR Region III, September 7, 1993.

  26. Letter to Jack Kelly, ATSDR Region III, from Dr. Philip Khoury, November 1, 1993.

  27. Health Hazards in a Small Automotive Body Repair Shop, M.A. Jayjock and L. Levin, Ann. Occup. Hygiene, Vol. 28, No. 1, pp.19-24, 1984.

  28. The Contributions to Solvent Uptake by Skin and Inhalation Exposure, W. Daniell et. al., Am. Ind. Hyg. Assoc. J. 53(2): 124-129 (1992).

  29. Exposure to Organic Solvents, S. Eloffson et.al. Scand J Work Environ Health 6 (1980) 239-273.

  30. Occupational Exposure to 1,6-Hexamethylene Diisocyanate-Based Polyisocyanates in the State of Oregon, 1980-1990, M. Janko, Am. Ind. Hyg. Assoc. J. 53(5):331-338 (1992).

  31. Reduction of Volatile Organic Compound Emissions from Automobile Refinishing, EPA 450/3-88-009, US EPA, October 1989.

  32. Personal review of AMS file data, October 21, 1993.

  33. Philadelphia Toxic Release Inventory Data 1991, AMS.

  34. Various AMS auto body shop inspection reports, 1989-1991.

  35. Final Report of the Philadelphia Integrated Environmental Management Project, US EPA, December 1986.

  36. The Influence of Personal Activities on Exposure to Volatile Organic Compounds, L. A. Wallace et. al., Environmental Research 50, 37-55 (1989).

  37. Adapting to Low VOC Products, AutoInc., October 1993, 12-14.

  38. Toxicological Profile for Acetone, ATSDR, May 1994 and Toxicological Profile for 2-Butanone, ATSDR, July 1992.

  39. Handbook of Toxic and Hazardous Chemicals and Carcinogens, 2nd edition, M. Sittig, 1985.

  40. Illness from Chemical "Odors": Is the Health Significance Understood?, L. Davidoff, in Archives of Environmental Health, Vol 47, Number 1, Jan/Feb 1992.

  41. Air Pollution and Daily Mortality in Birmingham, Alabama, J. Schwartz, in American Journal of Epidemiology, Volume 137, Number 10, 1993.

  42. Air Pollution and Community Health: A Critical Review and Data Sourcebook, F.W. Lipfert, Von Nostrand Reinhold, New York, 1994.

  43. Amendment to Air Management Regulation V: Control of Emission of Organic Substances from Stationary Sources (Adding new definitions and a new Section XIV pertaining to Automobile Refinishing Operations). City of Philadelphia Department of Public Health, Air Pollution Control Board. Effective: February 26, 1996.

  44. Letter to Jack Kelly, ATSDR Region III, from William A. Heitbrink, Ph.D., National Institute for Occupational Safety and Health, May 17, 1995.

  45. Pilot Multi-Media Environmental Health Characterization Study of South and Southwest Philadelphia: Final Executive Summary. Submitted to EPA Region III. Johns Hopkins University, School of Hygiene and Public Health, July 10, 1997.

  46. Memorandum to file from Paige Dillon re: Trip Report for Auto Repair Facility Inspections, July 17, 1997.

  47. Personal communication between Terry Black, Pennsylvania Department of Environmental Protection, and Eastern Research Group, August 21, 1998.

  48. Memorandum from Norm Glazer, AMS to Greg Tiernan, AMS, August 12, 1994.

  49. Personal communication between Greg Tiernan, AMS and Jack Kelly, ATSDR Region III, August 31 and September 21, 1998.

  50. Personal Communication between Philadelphia Planning Commission and Eastern Research Group, September,1998.

  51. South and Southwest Philadelphia Special Air Monitoring Study Results, EPA Region III, August 28, 1996.

  52. Memorandum from Robert Conrad, PADEP Bureau of Laboratories to Mohammed Mazid, PADEP Bureau of Waste Management re: MAU Air Monitoring Report Concerning Odors in South and Southwest Philadelphia, June 26, 1996.

  53. NIOSH Alert: Request for Assistance in Preventing Asthma and Death from Diisocyanate Exposure, National Institute for Occupational Safety and Health, March 1996.

  54. Final Rule: National Volatile Organic Compound Emission Standards for Automobile Refinish Coatings, Federal Register 40 CFR Parts 9 and 59, pages 48806-48819, September 11, 1998.

APPENDIX A: FIGURES

Appendix A was not available in electronic format for conversion to HTML at the time of preparation of this document. To obtain a hard copy of the document, please contact:

Agency for Toxic Substances and Disease Registry
Division of Health Assessment and Consultation
Attn: Chief, Program Evaluation, Records, and Information Services Branch E-56
1600 Clifton Road NE, Atlanta, Georgia 30333


APPENDIX B: ABBREVIATIONS

AMS
Philadelphia Air Management Services
APCB Air Pollution Control Board
ATSDR Agency for Toxic Substances and Disease Registry
EPA Environmental Protection Agency
FID flame ionization detector
GC/MS gas chromatograph/mass spectrometer
L&I Philadelphia Licensing and Inspection
MAU mobile analytical unit
MEK methyl ethyl ketone
NAAQS National Ambient Air Quality Standard
NIOSH National Institute of Occupational Safety and Health
OSHA Occupational Safety and Health Administration
PADEP Pennsylvania Department of Environmental Protection
PCE perchloroethylene
PHD Philadelphia Department of Public Health
ppb parts per billion
ppm parts per million
SPEAC South Philadelphia Environmental Action Coalition
VOCs volatile organic compounds

APPENDIX C: RESPONSE TO COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD

The health consultation for South Philadelphia Residential Area Shop Emissions, Philadelphia, Pennsylvania, was available for public review and comment from December 1994 to April 12, 1995. The Public Comment Period was announced in a press release dated January 11, 1995. Copies of the health consultation were made available for review at a local branch of the Philadelphia Free Library and were available from the Agency for Toxic Substances and Disease Registry (ATSDR) Regional Office by request. The health consultation was also sent directly to numerous local, state and federal agencies and interested members of the general public. Two public availability sessions were held on March 28, 1995, at the South Philadelphia Older Adult Center. The availability sessions were advertised in the South Philadelphia Review and the Philadelphia Welcome Mat.

ATSDR received the following comments/questions for the South Philadelphia Residential Area Shop Emissions health consultation. The specific comments that were received either identified new information, questioned specific sentences or paragraphs in the text, or suggested additions or corrections to improve the clarity, completeness, or accuracy of a specific sentence or paragraph. Those specific comments were not repeated by other respondents and are listed separately. This list of specific comments does not include editorial comments concerning word spelling, sentence syntax, format, etc. If the accuracy of a statement was questioned, this statement was verified and corrected. Comments which requested information be added to the document without providing documented sources of that information were not addressed here.

  1. Comment: Two community members reiterated their concerns regarding odors. One community member notices odors when opening the doors to his home. A second community member reported to ATSDR that they "occasionally smell emissions coming into their house." Comments emphasized that the community also must deal with odors and the nuisance of the fumes long after the daily hours of shop operations.
  2. Response: ATSDR acknowledges community members' concerns regarding odors. ATSDR also recognizes that certain odors can be offensive and affect an individual's general well-being. It is important to understand, however, that individual perceptions of odor can vary considerably, it is often extremely difficult to track and quantify nonpersistent odors, and we routinely detect odors at chemical concentrations well below levels expected to cause adverse health effects. ATSDR can only suggest that residents continue to contact AMS if unacceptable odors believed to be associated with auto body shops continue. Given the city's enforcement efforts since the time of the public comment period, ATSDR assumes that auto body shop odor releases have been reduced or abated in the petition area.

  3. Comment: A community member reported to ATSDR that area residents are opposed to having auto body/repair shops being located in their neighborhood.
  4. Response: ATSDR notes this comment, but the issue is one which must be addressed by the local planning agency and is beyond the scope of this health consultation.

  5. Comment: Complaints from neighbors of auto body shops, which are not confined to South Philadelphia, and other sources of solvent emissions indicate that problems do exist, even if an analysis of emissions and ambient concentrations suggests the contrary. In a situation where solvent emissions for a fabric coating operation at a factory were causing malodors at an adjacent school, the Philadelphia Air Management Services (AMS) performed continuous air monitoring outside the school to measure ambient concentrations of toluene and methyl ethyl ketone (MEK). While the results did not indicate the potential for a significant problem, a problem did exist at the school. Teachers and pupils at the school complained about odors, nausea, headaches, dizziness, and drowsiness. No air samples were taken inside the school during malodor incidents. It is possible that the outdoor samples are not indicative of indoor levels, and that solvent fumes were accumulating in the enclosed area; or that occasional exposure to relatively low concentrations is irritating in ways that differ from frequent exposure to higher concentrations. AMS measured toluene in work areas of the factory; levels were higher than the outdoor samples but did not exceed the Occupational Safety and Health Administration (OSHA) limits.
  6. Response: ATSDR fully understands the commenter's concerns. Even when existing toxicological data indicate that individual chemicals are present at concentrations below those believed to be needed for adverse health effects, individuals may experience health effects which they firmly believe are caused by those chemicals, ATSDR can only make its health determination based on existing scientific data. As more research is conducted on the health effects of low exposure levels, multiple low level chemical exposure, the potential health effects of odors, individual sensitivities, and psychophysiological issues, perhaps better informed and acceptable answers can be provided in the future. ATSDR is involved in research in all of these areas.

  7. Comment: One commenter notes that ATSDR's health consultation was "inconclusive by its very design." The auto body/repair shops in the six-block study area pose a threat to the health of people living in the neighborhood through inhalation and ingestion. Another individual noted disbelief that so many small sources of toxics do not have a negative impact on the neighbors.
  8. Response: ATSDR's conclusions are based on a relatively limited data set and, therefore, ATSDR recommended additional sampling or modeling. Without more extensive ambient air data, ATSDR cannot fully evaluate the potential cumulative effect of the multiple shops. Based on ATSDR's review of the limited data, detected contaminant concentrations are not expected to be associated with adverse health effects. See previous responses for clarification on ATSDR's conclusions.

  9. Comment: One commenter noted that the Pennsylvania Department of Environmental Protection (PADEP) is developing regulations for auto body/repair shop emissions.
  10. Response: ATSDR contacted PADEP and added discussion of the statewide rule to text. The reader is referred to the BACKGROUND, Regulatory Responses, Pennsylvania Department of Environmental Protection section.

  11. Comment: One commenter commented on EPA's multi-media inspections of auto body/repair shops in South Philadelphia.
  12. Response: ATSDR received a copy of the Trip Report for the Automotive Repair/Body Shop Compliance Assistance Surveys. ATSDR added these survey activities to the timeline of significant community actions presented in the health consultation. In addition, a description of the findings of this report are presented in the BACKGROUND, Regulatory Responses, Environmental Protection Agency section. For more information on this, EPA Region III should be contacted.

  13. Comment: One commenter expressed concern that the Air Pollution Control Board (APCB) and the Department of Licensing and Inspection (L&I) have been negligent in performing their duties under Title 3 of the Air Management Code. Furthermore, evidence of discriminatory regulation of air pollution sources reportedly exists. The commenter stressed that a moratorium on the issuance of air pollution permits should be imposed until the City of Philadelphia can perform its duty properly.
  14. Another commenter expressed concern that the health consultation reported that the auto body shop industry is underregulated and that a considerable number of auto body/repair shops in the study area have never received proper licensing or permitting. The unregulated auto body/repair shops are likely to pose a significant health threat.

    Response: ATSDR has no place in critiquing the past work practices of local public health or regulatory agencies. Hopefully, current and future practices of the involved city agencies will be acceptable to the commenter.

    It is ATSDR's understanding that, beginning in 1993, the AMS initiated a more active approach to inspection and licensing of these shops and began a closer coordination effort with L&I. In addition, an amendment to the Air Management Regulation V became effective. The reader is referred to BACKGROUND, Regulatory Response, Philadelphia Department of Air Management Services/Philadelphia Planning Commission. The recent final rule enacted by EPA for limiting the VOC content of auto body paints and current regulatory efforts underway by the PADEP should also help address the commenter's concerns.

    ATSDR acknowledges the work that the commenter and others have done to initiate greater attention to the auto body shop emissions issue.

  15. Comment: One community member expressed the following concern regarding a committee looking at environmental equity issues: At a June 14, 1994 meeting of the APCB, an ad hoc committee was appointed to look at environmental equity issues. At the August 9, 1994 APCB meeting, there was no report from the ad hoc committee. The commenter states that the chairman at the meeting suggested that auto body shops possibly should not have been allowed to cluster. At the October 11, 1994 APCB meeting, there was no report from the ad hoc committee. The committee was reportedly dissolved.
  16. Response: ATSDR can only suggest that the commenter contact the APCB. ATSDR has no role in local planning policy and local organizational decisions.

  17. Comment: The AMS air quality data used by ATSDR to decide whether a full health study is appropriate were far from perfect. The data came from a neighborhood that was not in the area studied by ATSDR. Sampling techniques were also problematic. The conclusion that there is not a health risk is based on poor scientific knowledge; we know very little about how toxics affect human health.
  18. Response: Sampling/screening by AMS was performed at the shop initially identified by community members as having emission problems. Information on air quality data not collected from the petition area of concern was merely provided for background and comparison purposes. The limitations of the techniques and equipment used by AMS to take and analyze air samples are presented in the DATA REVIEW section of the health consultation. Since receipt of this comment, additional sampling was performed by EPA and PADEP. Both sampling efforts included stations in the neighborhood of concern and are discussed in the DATA REVIEW section.

    The comment concerning the general lack of knowledge of how toxics affect human health is really too broad to discuss in this document. ATSDR is willing to recommend reference texts and journal articles to address this very general comment.

  19. Comment: The report suggests that because 91 other cities are also in nonattainment areas, the health problem in Philadelphia cannot be too bad. The commenter notes that this is an absurd conclusion. The report does not mention that Philadelphia has the ninth worst air quality in the country.
  20. Response: In the draft health consultation, ATSDR stated that Philadelphia was one of 91 nonattainment areas for ozone, but did not state that health problems do not occur in nonattainment areas. As in the response to comment #9 above, the statement was only made for comparison and background purposes. The air quality status of the Philadelphia area could have been provided but this, too, would only serve as background data. If the commenter's point is that the auto body shop emissions contribute to the deterioration of overall air quality, ATSDR acknowledges this (most chemical emissions sources do, including residential sources). However, ATSDR cannot quantify how much the auto body shop emissions contribute to the general deterioration of air quality but can only comment on whether or not the concentrations of contaminants detected might lead to health problems.


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