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OSHA has no exposure limit for asphalt fumes. Coal tar pitch volatiles, a different material that still turns up when old roofs come off, have one: 0.2 mg/m3 over 8 hours. HazComFast read every asphalt fume, coal tar pitch and benzo(a)pyrene result OSHA's laboratory has published since 1984, and every HazCom citation issued to a roofing contractor from FY2020 to FY2026. The laboratory's last asphalt fume sample from a roofing job dates from 2016. Of the 150 coal tar samples from roofs, 49 prove on their own an exposure above the limit.
Samples reported through August 25, 2026 · citations extracted October 13, 2026 · by HazComFast · method and limits below
The written program is the HazCom paragraph roofers get cited for most. Build yours for the products on your roof, free.
Asphalt and coal tar look alike on a roof. OSHA treats them as two materials, under different rules.
| Material | Federal OSHA | NIOSH and California | IARC |
|---|---|---|---|
| Asphalt (petroleum) fumes | No PEL. 5 mg/m3 proposed in 1992, not adopted | NIOSH: ceiling 5 mg/m3 over 15 minutes, potential carcinogen. California: 5 mg/m3 over 8 hours, as OSHA's chemical database reports it | Roofing with oxidized bitumens: Group 2A. Mastic asphalt and road paving: Group 2B |
| Coal tar pitch volatiles (benzene soluble fraction) | 0.2 mg/m3 over 8 hours, 1910.1000 Table Z-1 and 1926.55 | Asphalt is left out of this entry by 1910.1002 | Evaluated separately from bitumens |
"There is no OSHA standard or permissible exposure level of asphalt fumes, although a 5 mg/m3 permissible exposure limit (PEL) was proposed in 1992." OSHA, Asphalt Fumes: Standards
"Asphalt (CAS 8052-42-4, and CAS 64742-93-4) is not covered under the "coal tar pitch volatiles" standard." 29 CFR 1910.1002
OSHA's page adds that its own risk assessment found a significant lung cancer risk at levels as low as 0.2 mg/m3. That figure is an estimate, not a limit. NIOSH's 5 mg/m3 is a ceiling over 15 minutes, where California's 5 mg/m3 is an 8-hour time-weighted average: same number, different test. The NIOSH figure also carries its "Ca" mark, potential occupational carcinogen.
OSHA's laboratory publishes every result it analyzes once the inspection is closed. A personal sample is one sampler worn by one worker for a number of minutes, and OSHA warns that a sampler is often one of several worn during a shift. For coal tar pitch volatiles, this study asks what each sample proves on its own: concentration times minutes, over 480, every minute without a sample counted as zero. Asphalt fume results are shown as reported, with no limit to compare them with.
| Substance and scope | Samples | Inspections | Median | Highest | Years | Prove 8 h above 0.2 mg/m3 |
|---|---|---|---|---|---|---|
| Asphalt fumes, all industries | 301 | 115 | 0.14 mg/m3 | 25.08 mg/m3 | 1984 to 2026 | no OSHA limit |
| Asphalt fumes, roofing contractors | 51 | 18 | 0.25 mg/m3 | 3.6 mg/m3 | 1986 to 2016 | no OSHA limit |
| Coal tar pitch volatiles, all industries | 1,926 | 592 | 0.13 mg/m3 | 124 mg/m3 | 1984 to 2025 | 437 |
| Coal tar pitch volatiles, roofing contractors | 150 | 38 | 0.29 mg/m3 | 124 mg/m3 | 1984 to 2014 | 49 |
| Coal tar pitch volatiles, roofing since 2000 | 12 | 7 | 0.23 mg/m3 | 0.92 mg/m3 | 2002 to 2014 | 6 |
| Benzo(a)pyrene, roofing contractors | 115 | 32 | 0 mg/m3 | 0.04 mg/m3 | 1984 to 2013 | no OSHA limit |
Across every industry, OSHA's laboratory has published 301 personal asphalt fume results since 1984. Roofing contractors account for 51, from 18 inspections, the last in 2016. The median roofing sample ran 288 minutes, close to a full shift. The file does not say which fraction each result measured, total particulate or the benzene soluble part, so this page does not hold them against the NIOSH ceiling or the California limit.
Benzo(a)pyrene is one of the compounds Table Z-1 names in the coal tar pitch volatiles entry. Of 115 roofing samples, 60 found none, and the highest was 0.04 mg/m3. A sample with no benzo(a)pyrene does not clear a roof of coal tar: the limit is set on the benzene soluble fraction.
Many older built-up roofs were laid with coal tar pitch. The roofing samples follow that history: 150 coal tar results, 138 of them before 2000. The later ones come from work on roofs already in place. Twelve samples since 2000, and six of them prove an 8-hour exposure above 0.2 mg/m3 on their own.
| Category | roofing samples |
|---|---|
| 1980s | 68 |
| 1990s | 70 |
| 2000s | 6 |
| 2010s | 6 |
The roof you tear off came with no safety data sheet. HazCom still reaches it:
"This section applies to any chemical which is known to be present in the workplace in such a manner that employees may be exposed under normal conditions of use or in a foreseeable emergency." 29 CFR 1910.1200(b)(2)
An older built-up roof can hold coal tar under the gravel. If a core sample or the owner's records say so, the tear-off goes into the hazard communication program and the 0.2 mg/m3 limit applies to the crew.
From FY2020 to FY2026, OSHA and the State Plans opened 42,211 inspections of roofing contractors. Of those, 710 ended with a HazCom citation, 1.7%, where 6.5% of all inspections did. Falls dominate everything else. The table shows every standard cited at roofing inspections in FY2025 and FY2026, the years for which the full citation table was downloaded.
| Standard | What it covers | Citation items | Inspections |
|---|---|---|---|
| 1926.501 | Duty to have fall protection | 7,076 | 6,891 |
| 1926.1053 | Ladders | 3,299 | 2,891 |
| 1926.503 | Fall protection training | 3,149 | 2,796 |
| 1926.102 | Eye and face protection | 1,734 | 1,730 |
| 1926.502 | Fall protection systems and practices | 1,163 | 797 |
| 1926.20 | General safety and health provisions | 1,064 | 858 |
| 1926.100 | Head protection | 904 | 904 |
| 1903.19 | Abatement verification | 740 | 604 |
| 1910.1200 | Hazard communication | 651 | 252 |
| 1926.451 | Scaffolds | 434 | 247 |
| 1926.1060 | Stairway and ladder training | 313 | 313 |
State Plans that key their own rule numbers, such as Oregon and Washington, are in the download and left out of this table. OSHA keys construction HazCom citations under 1910.1200, which 1926.59 applies to construction.
| Category | HazCom items |
|---|---|
| FY2020 | 184 |
| FY2021 | 161 |
| FY2022 | 182 |
| FY2023 | 246 |
| FY2024 | 318 |
| FY2025 | 415 |
| FY2026 | 255 |
(e)(1) is the written program, (h)(1) training, (g)(1) a safety data sheet for each product, (g)(8) access to the sheets during the shift.
43% of the HazCom items at roofers were serious. For the same counts across every industry, read our study of seven years of HazCom citations.
IARC put roofing with oxidized bitumens in Group 2A, probably carcinogenic, on human, animal and mechanistic evidence taken together. The studies of roofers themselves are harder to read, because many of the workers studied also worked with coal tar.
A group in the IARC scale describes how strong the evidence of a hazard is. It does not give a worker's odds. For the crew on the roof, the practical reading is the same either way: keep the fume down, keep it off the skin, and know whether the old roof holds coal tar.
Before a tear-off on a built-up roof from the 1970s or earlier, ask the owner for records or have a core sample analyzed. Coal tar pitch and asphalt look alike in the field. Only the first carries an OSHA limit, 0.2 mg/m3 over 8 hours.
1926.55, paragraph by paragraphThe written program of 1910.1200(e)(1) is the paragraph OSHA cites most at roofing contractors. It lists the products on that job: the asphalt, the primer, the adhesives, the propane for the kettle.
In HazComFast
The chemical list in your program is built from each jobsite's inventory, under the product name on its SDS. Remove a product and the program tells you the list is out of date, with a button to rebuild it.
HazCom program generatorParagraph (g)(8) wants the SDS readily accessible during each work shift, in the work area. On a roof, that means a phone, not a binder in the truck.
In HazComFast
The jobsite's SDS load on the phone the first time a worker signs in with signal. Products with no SDS show in red. A form filled in with no signal goes out once when the connection works, even when the trailer Wi-Fi has no internet.
SDS QR code generatorTraining under (h)(1) is the second most cited paragraph at roofers. It covers the kettle, the fume, the burns from hot asphalt and what the label says, before the first job.
In HazComFast
Write the program in English and Spanish. Each section shows whether its translation is current, and the PDF prints both languages from the same revision.
HazCom training record generatorRun the kettle at the lowest temperature the product instructions allow, keep the lid down, and keep the crew upwind of the kettle and the mop. NIOSH's 5 mg/m3 recommendation is a 15-minute ceiling, so the peak at the kettle counts, not just the day.
PPE selectorFall protection under 1926.501 leads the roofing citations by far. In FY2025 and FY2026 it was cited in 6,891 of the 9,386 roofing inspections with a citation.
Fall protection plan builderFree to reuse with a link to this page, under the Creative Commons Attribution 4.0 license.
HazComFast. (2026). Hot asphalt and coal tar on roofs: what OSHA measured, and what it cites roofers for. https://hazcomfast.com/osha-data-research/roofing-asphalt-study. Samples reported through August 25, 2026, citations extracted October 13, 2026.
No. OSHA's own page says there is no OSHA standard or permissible exposure level for asphalt fumes. A 5 mg/m3 PEL was proposed in 1992 and never adopted. NIOSH recommends a 5 mg/m3 ceiling over 15 minutes, and OSHA's chemical database lists a California PEL of 5 mg/m3 over 8 hours.
No, and OSHA's rules keep them apart. Under 29 CFR 1910.1002, coal tar pitch volatiles include those from petroleum "excluding asphalt", and asphalt is not covered by the coal tar pitch volatiles standard. Coal tar pitch volatiles have a limit of 0.2 mg/m3 over 8 hours as the benzene soluble fraction, in 1910.1000 Table Z-1 and in 1926.55 for construction.
IARC classified occupational exposure to oxidized bitumens and their emissions during roofing as probably carcinogenic to humans, Group 2A, in volume 103 of its Monographs. Mastic asphalt work with hard bitumens and road paving with straight-run bitumens are in Group 2B. NIOSH lists asphalt fumes as a potential occupational carcinogen.
Yes. 1926.59 applies 1910.1200 to construction, and paragraph (b)(2) covers any chemical known to be present in the workplace in a way that employees may be exposed. The roofing asphalt, primers, adhesives and kettle fuel belong in the written program, with their safety data sheets available on the job.
Rarely, compared with other inspections. Of the 42,211 roofing inspections opened from FY2020 to FY2026, 710 ended with a HazCom citation, 1.7%. Across all 474,306 inspections opened in those years, the share was 6.5%. Fall protection takes most of the attention on a roof.
(e)(1), the written program, with 566 citation items from FY2020 to FY2026. Training under (h)(1) comes next with 417, then the safety data sheets under (g)(1).
Rarely, if its laboratory file is the measure. OSHA's laboratory has published 51 personal asphalt fume samples from roofing contractors since 1984, the last taken in 2016, and 150 coal tar pitch volatile samples, the last in 2014. Samples from open cases and from State Plan laboratories are not in that file.
From OSHA's published data: the sampling results of OSHA's laboratory since 1984, reported through August 25, 2026, and the Department of Labor's inspection and violation tables, extracted October 13, 2026. HazComFast counted them. No establishment is named.
Yes. The tables are free to download and reuse with a link to this page, under the Creative Commons Attribution 4.0 license (CC BY 4.0).
Written and maintained by HazComFast. Regulatory text quoted from the eCFR and OSHA's pages. Counts built from OSHA's published data.
General information, not legal advice.
OSHA inspections come unannounced, apart from the few exceptions listed in 29 CFR 1903.6. Get the binder in order before the opening conference, not during it.
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