NIOSH Comments on the CDC Drywall Webpages
Based on comments from NIOSH subject matter experts, NIOSH requests additional information and
cIarificaons before cross-clearance. We also are puzzled that the web pages under review are already
posted for public access on the CDC website. Please cancel public access to the web pages until cross-
clearance issues are resolved.
Response: This document was cleared through NCEH/ATSDR via documentum. The document was
requested by FL and LA health departments and deals with residential exposures only (not occupational).
The reviewers asked why hydrogen sulfide and strontium sulfide were not mentioned in the CDC
summary (fact sheet – http://www.cdc.gov/nceh/drywall/docs/Dryvall_for_Healthcare_Providers.pdf) given
that the Information apparently was extracted from the Florida 00H – Unified Engineering Inc analysis
report (http://www.doh.state.fl.us/environment/community/indoor-air/fldrywallfirstreport.zIp) and linked on
the Florida DOH page (http://www.doh.state.fl.us/environment/community/indoor-air/drywall.html). The
reviewers also were somewhat surprised that no sulfuric acid was detected.
Response: Sulfuric acid was not tested for in this reference. We are currently awaiting EPA test results.
Strontium sulfide was not mentioned as this gas was not found in VOC analytical results. This test
involved placing a sample of drywall kept in a container under high humidity conditions with no air
exchange—quite different than indoor air testing. Because exposure levels of sulfur compounds have not
been characterized, we cannot discuss levels of health concern. It does the public a disservice to
We did not use the analysis of corroded copper or drywall metal results to make any public health
The reviewers also questioned why the signs and symptoms and physical properties mentioned in the
fact sheet do not replicate those found in the sources below. There seems to be a mix and match
technique in order to generalize the health problems and the corrosion results. it Is not clear whether the
authors chose to limit the signs and symptoms to match the potential lower exposures (1-30 ppb) or
whether this is a summary of health problems gleaned as a result of actual exposures to imported drywall.
6orne signs and symptoms are common, but there are inconsistencies when comparing all of the suspected compounds.
OlivIa—they are suggesting the info that follows be placed on the NCEH and ATSDR web page
links for lnfo…not the health care provider fact sheet. For the NCEH Webpage, NIOSH requests
changing the “Protecting workers” section text to the following:
CDC’s National Institute for Occupational Safety and Health is Interested in evaluating potential worker
exposures associated with the removal of imported drywall. To request a NIOSH health hazard evaluation
visit the health hazard evaluation program. For general information on demolition hazards visit the
Occupational Safety and Health Administration’s Demolition Standards Webpage.
To the NCEH “Additional Resources” section, please add a link to the NatIonal Institute for Occupational
Safty and Health Health Hazard Evaluation Program. NIOSH requests adding the same link to the
“Additional Resources” section of the ATSDR Webpage.
Olivia— I’m not sure what to do with this paragraph other than to Indicate that this was developed
for residential exposures—not occupational ones. In other comments, the reviewers noted that
exposure to “sulfur gases” may be an issue in confined spaces (e.g., between the walls) where water
pipes, electrical lines, or other mechanical installations may be located. However, the ranges cited above
(1 to 30 ppb) do not seem to be significant for worker exposure. The only exception might be In
remediation or storage (in non-ventilated spaces) of this drywall where worker exposure could be higher.
The unified Engineering Inc report cited the following ranges of volatile sulfur compounds (to which NIOSH has added RELs, IDLH or AEGLs and signs and symptoms):
Hydrogen sulfide – range 0.08 to 0.6 ppm REL C 10 ppm (15 mg/m3)[10-mlnute] IDLH 1oo ppm
AEGL-1 (8 hr) = 0.33 ppm
Colorless gas with a strong odor of rotten eggs. [Note: Sense of smell becomes rapidly fatigued & can
NOT be relied upon to warn of the continuous presence of H2S.J
Symptoms: Irritation eyes, respiratory system; apnea, coma, convulsions; conjunctivitis, eye pain,
lacrimation (discharge of tears), photophobia (abnormal visual intolerance to light), corneal vesiculation;
dizziness, headache, lassitude (weakness, exhaustion), Irritability, insomnia; gastrointestinal disturbance;
liquid: frostbite (NPG) http://www.cdc.gov/nìosh/npg/npgd0337.html
Attacks many metals and some plastics. IPCS Card http://www.cdc.gov/niosh/ìpcsneng/neng0165.htrnl
Carbonyl sulfide – range 0.32 to 0.87 ppm no REL or IDLH; no TLV; no IPCS card
AEGL-2 (30 mm) = 69 ppm – roughly equivalent to IDLH
Carbonyl sulfide causes neurotoxicity and respiratory paralysis. The warning properties of carbonyl
sulfide are not as prominent as those of hydrogen sulfide (No odor warning properties.) Source: AEGL
TSD http://www.epa.gov/oppt/aegl/pubs/carbonyl_sulfide_interim.pdf According to the TSD there are no
other extant standards or guidelines and no AEGL-1 values due to lack of data – Note that the AEGL
documentation recognizes that because of the poor warning properties; it may cause serious effects or
lethality at concentrations causing no signs or symptoms. Note: this may be the chemical of most concern
given its relative toxicity compared to the other two and its measured ranges In the Chinese drywall.
Carbon disulfide – range 0.02 to 0.18 ppm REL TWA I ppm (3 mg/rn3) ST lo ppm (30 mg/rn3) [skin]
IDLH s 500 ppm AEGL-1 (8 hr) = 6.7 ppm
Strong oxidizers; chemically-active metals such as sodium, potassium & zinc; azides; rust; halogens;
amines [Note: Vapors may be ignited by contact with ordinary light bulb.]
Symptoms: Dizziness, headache, poor sleep, lassitude (weakness, exhaustion), anxiety, anorexia, weight
103$; psychosis; polyneuropathy; Parkinson-like 3yndrorne; ocular changes; coronary heart disease;
gastritis; kidney, liver ìnjury; eye, skin burns; dermatitis; reproductive effects (NPG)
Attacks some forms of plastic, rubber and coating. IPCS Card
Response: The information provided is useful for levels approaching occupational guidelines. It
is not applicable for the users of this document.
All levels detected inside residences to date (we do not have access to the consultant’s protocols
or lab analysis) that have been reported in the media are in the low ppb range.
Once we receive EPA’s test results, we will make modifications as appropriate.
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