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PUBLIC SUBMISSION
As of: 4/28/16 11:21 AM
Received: April 15, 2016
Status: Posted
Posted: April 22, 2016
Tracking No. 1k0-8p36-ulyi
Comments Due: May 02, 2016
Submission Type: Web
Docket: ATSDR-2016-0002
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill 0923-16PJ
Comment On: ATSDR-2016-0002-0003
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill ATSDR-2016-0002
Document: ATSDR-2016-0002-0023
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill 0923-16PJ Comment on
FR Doc # 2016-03305
Submitter Information
Name: Vincent McDermott
Address: 06410
Email: vmcdermott@mminc.com
General Comment
I participated in the 4/14/16 webinar and came away feeling hopeful since the design of the
study will put many of the concerns to rest. As part of your literature search, I refer you to
"Evaluation of the Environmental Effects of Synthetic Turf Fields", Milone & MacBroom, Inc.
December 2008. This was an early study that our firm undertook at our own expense to better
understand the issues. You may find it helpful to your research.
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4/28/2016
Page 1 of 1
PUBLIC SUBMISSION
As of: 4/28/16 11:39 AM
Received: April 27, 2016
Status: Posted
Posted: April 28, 2016
Tracking No. 1k0-8pbd-i7rh
Comments Due: May 02, 2016
Submission Type: Web
Docket: ATSDR-2016-0002
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill 0923-16PJ
Comment On: ATSDR-2016-0002-0003
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill ATSDR-2016-0002
Document: ATSDR-2016-0002-0041
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill 0923-16PJ Comment on
FR Doc # 2016-03305
Submitter Information
Name: Aaron Crowell
General Comment
Given the numerous chemicals that have been found in crumb rubber derived from scrap tires,
the study should examine relevant knowledge gaps regarding the potential for synergistic
effects in chemical mixtures, even in small doses. One reference that should be consulted is
Goodson et al. (2015), "Assessing the carcinogenic potential of low-dose exposures to chemical
mixtures in the environment: the challenge ahead", available at:
http://carcin.oxfordjournals.org/content/36/Suppl_1/S254.full?sid=db47f5ec-47a2-4879-bf306da9c076003d
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Page 1 of 3
PUBLIC SUBMISSION
As of: 4/28/16 11:40 AM
Received: April 27, 2016
Status: Posted
Posted: April 28, 2016
Tracking No. 1k0-8pbf-ipjs
Comments Due: May 02, 2016
Submission Type: Web
Docket: ATSDR-2016-0002
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill 0923-16PJ
Comment On: ATSDR-2016-0002-0003
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill ATSDR-2016-0002
Document: ATSDR-2016-0002-0042
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill 0923-16PJ Comment on
FR Doc # 2016-03305
Submitter Information
Name: Michael Dorsey
Address: 45255
Email: dorseym@wyomingcityschools.org
General Comment
I am the corresponding author of the paper, Mutagenic Potential of Artificial Athletic Field
Crumb Rubber at Increased Temperatures (Dorsey et. al. 2015. OHIO J. SCI. 115(2) 32-39.
Available at: https://library.osu.edu/ojs/index.php/OJS/article/view/4857).
We were interested in identifying any realistic conditions that might lead to exposure of
mutagenic compounds to athletes using crumb rubber fields. We heated crumb rubber from
athletic fields to different temperatures for 30 minutes in water. These "leachates" were tested
for the ability to cause mutations in bacteria using Ames fluctuation assays. Because substances
that cause mutations are often, but not always, carcinogenic, the Ames assay is a classic first
step in determining if a substance may be carcinogenic. We demonstrated that a compound, or
compounds, with mutagenic potential is released from crumb rubber taken off of athletic fields
when heated briefly in water to temperatures that these fields are known to reach, including 60
degrees C. In our study, crumb rubber heated in water to lower temperatures (40 degrees C.),
did not result in the same effect. A separate 2015 paper has suggested that crumb rubber at 60
degrees C. releases significant amounts of PAHs including some known or suspected human
carcinogens (Release of Polycyclic Aromatic Hydrocarbons and Heavy Metals from Rubber
Crumb in Synthetic Turf Fields: Preliminary Hazard Assessment for Athletes. Marsili et al.
2015. J Environ Anal Toxicol 5: 265). Also, the results posted in these public comment pages
by J. Klabin (ID: ATSDR-2016-0002-0017) concerning the analysis of painted playground
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Page 2 of 3
rubber heated in water at different temperatures (different compounds were identified at
different temperatures) are consistent with our results on crumb rubber. We have since tested
unpainted playground rubber with results similar to what we saw with crumb rubber
(unpublished data).
It would be difficult to ignore mutagenicity data when evaluating a potential environmental
cancer risk. Your study should explain why the results in our paper either are or are not relevant
to your studies and conclusions. Otherwise, whether or not these fields pose a health risk will
remain an open question. There could be legitimate reasons why the mutagenicity detected in
our studies would not be of concern to human health, but those reasons will need to be
articulated and justified.
I would point out that in our published study the crumb rubber was taken directly off of athletic
fields, and therefore the possibility remains that it is something else environmental, and not the
crumb rubber per se, that is the source of the mutagenicity we detect. To date, we have tested
five different fields and one source of playground rubber, all showing a consistent pattern, but
all five fields and the playground are within thirty miles of each other.
Next, the success of evaluating "potential cancer and non-cancer toxicity of key tire crumb
constituents based on existing databases of information" (from Federal Research Action Plan on
Recycled Tire Crumb Used on Playing Fields and Playgrounds) will hinge on certain
assumptions:
1. That all of the "key" constituents are identified under all appropriate conditions (for example,
water versus organic solvents, lower versus higher temperatures, and new versus old crumb
rubber).
2. That the databases used are complete and accurate.
3. That there is no synergistic effect of individual components.
If after evaluating the crumb rubber toxicity no cancer causing agents can be found, the
question will remain as to whether the results of our mutagenicity studies may be due to an
unidentified constituent or to some other environmental source. For this reason I suggest, as part
of your studies, starting with leachates similar to what we have made, testing whether they have
biological activity (i.e., mutagenicity), and, if so, using those to identify the source of the
activity.
The CalEPA/OEHHA has requested that the National Institute of Environmental Health
Sciences and National Toxicology Program perform a short-term toxicology study. I feel that
this type of study, in eukaryotic cells, is part of what must be done in order to address the
particular concerns outlined above.
During your analysis of crumb rubber, you may identify compounds that are currently listed by
the USGS as a concern for the environment. The finding of any such compounds should justify
an environmental risk analysis.
I urge you to be completely transparent in releasing or publishing all results.
I hope athletic fields with crumb rubber infill are convincingly shown by the proposed study to
be safe in all respects.
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Page 3 of 3
Thank you for addressing it.
Michael J. Dorsey, Ph.D.
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PUBLIC SUBMISSION
As of: 5/3/16 6:18 PM
Received: April 29, 2016
Status: Posted
Posted: April 29, 2016
Tracking No. 1k0-8pcg-82s1
Comments Due: May 02, 2016
Submission Type: Web
Docket: ATSDR-2016-0002
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill 0923-16PJ
Comment On: ATSDR-2016-0002-0003
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill ATSDR-2016-0002
Document: ATSDR-2016-0002-0045
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill 0923-16PJ Comment on
FR Doc # 2016-03305
Submitter Information
Name: Maya van Rossum
Address: 19007
Email: keepermaya@delawareriverkeeper.org
General Comment
The Delaware Riverkeeper Network submits the attached comment for your consideration.
In addition to the attached comment we would like to request that Maya van Rossum, the
Delaware Riverkeeper, on behalf of the Delaware Riverkeeper Network, be identified as a
stakeholder for participation in your process. Ms. van Rossum has engaged in a significant
amount of research and community education and advocacy around the issue of synthetic turf
fields, particularly those with crumb rubber infill, and would bring an important environmental
and community perspective to your deliberations. Ms. van Rossum is the primary author on the
documents we are submitting today.
Ms. van Rossum can be reached at:
keepermaya@delawareriverkeeper.org
or by phone at 215 369 1188 ext 102
Respectfully submitted and requested.
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Page 2 of 2
(p.s. the action alert document submitted previously was submitted in error and need not be
entered for the record.)
Attachments
Comment 4.29.16 ATSDR & EPA re Art Turf study
https://www.fdms.gov/fdms/getcontent?objectId=0900006481f99f37&format=xml&showor... 5/3/2016
April 29, 2016
Leroy A. Richardson, Information Collection Review Office
Centers for Disease Control and Prevention
1600 Clifton Road NE., MS-D74
Atlanta, Georgia 30329.
Federal eRulemaking Portal: Regulation.gov
Re: Docket No. ATSDR-2016-0002
Dear Mr. Richardson,
Conducting additional research into the health and environmental impacts synthetic turf fields with
crumb rubber infill is essential. Crumb Rubber turf fields are proliferating quickly through
communities with schools and municipalities constructing crumb rubber fields to accommodate kids
playing sports of all ages from elementary level on up. In every instance school district and town
officials cite industry funded research as a primary demonstration of safety. Inadequate Government
documents are of little help in countering such assertions or information the decisionmaking process
as, to the degree they exist, they are very limited in scope, they often rely on industry-provided
information, and they often rely on an absence of information as somehow supporting a
demonstration of no harm. A thorough and independent investigation is essential if we are to protect
children, adults and the environment from the harms of crumb rubber artificial turf.
The Delaware Riverkeeper Network would also like to suggest that research into the impacts of other
artificial turf infill materials is important given that they too are the subject of a multitude of claims of
safety backed by little but industry marketing materials and industry funded research.
I believe it will be important to include an organization like the Delaware Riverkeeper Network
among your stakeholders. We have had to engage in significant research into, and advocacy about,
artificial turf, its environmental and health impacts on a number of occasions over the past 8+ years.
As a result we have a significant and healthy understanding of the science and the issues that have
been and need to be evaluated.
I include with this comment a series of fact sheets and informational materials created by my
organization to help inform local debates regarding the construction or expansion of artificial turf
DELAWARE RIVERKEEPER NETWORK
925 Canal Street, Suite 3701
Bristol, PA 19007
Office: (215) 369-1188
fax: (215)369-1181
drn@delawareriverkeeper.org
www.delawareriverkeeper.org
fields. In these materials we cite a number of scientific and government materials that assess the
environmental and health impacts of crumb rubber artificial turf. We would like to submit them for
the record and your consideration.
Synthetic turf is generally made with rubber from waste tires. Recycled rubber varies considerably in
its chemical composition, even when from the same manufacturer.1 Hazardous substances found in
tires may persist in the environment including polycyclic aromatic hydrocarbons (PAHs), phthalates
and certain metals. These substances may be bioaccumulative, carcinogenic, reprotoxic, mutagenic
and/or endocrine disrupting.2
• Most PAHs are persistent, bioaccumulative and carcinogenic.3
• Phthalates are generally used as solvents and plasticisers in plastics. Phthalates are not
chemically bound to the rubber and as a result can leach from the infill material.4
• Phenols likewise are not chemically bound to the rubber and so can leach. Phenols too are
persistent and bioaccumulative and can have long-term effects on the environment.5
• Among the metals found in tires that may be of concern are zinc, lead, copper, chromium and
cadmium. While zinc and copper are essential for living organisms, when absorbed at high
levels they become harmful. Lead can affect reproduction, development of the nervous system
leading to poor cognitive development, and is a particular threat to fetuses and young children.
Chromium is carcinogenic and mutagenic. Cadmium is toxic to humans and if taken in can
contribute to poor liver and kidney function, as well as osteoporosis. 6
Playing on Artificial Turf brings threats of exposure to hazardous substances through a variety
of pathways.
Direct human exposure to the hazardous substances contained in the rubber in-fill of artificial turf is
believed to occur via three pathways: inhalation, skin contact, and/or ingestion including by children
who come into contact with the material.7
A 2012 study focused on the threat of lead ingestion from artificial turf noted that lead, in the “case of
chronic exposure in early childhood, can induce cell necrosis, nerve behavioral abnormalities and
developmental disability, and in the case of long-term exposure it can induce cell necrosis, blood
pressure, cancer, and kidney tumor.”8 In this study researchers considered the impacts for lead
exposure from children who ingest rubber powder resulting from exposure to crumb rubber infill
artificial turf. The research showed elementary school children had a hazard index that exceeded 0.1,
1 T. Kallqvist, Norwegian Institute for Water Research (NIVA), Environmental Risk Assessment of Artificial Turf Systems,
December 2005, p. 7.
2 KEM, Swedish Chemicals Agency, Facts: Synthetic Turf, April 2007.
3 KEM, Swedish Chemicals Agency, Facts: Synthetic Turf, April 2007.
4 KEM, Swedish Chemicals Agency, Facts: Synthetic Turf, April 2007.
5 KEM, Swedish Chemicals Agency, Facts: Synthetic Turf, April 2007.
6 KEM, Swedish Chemicals Agency, Facts: Synthetic Turf, April 2007.
7 Environment & Human Health, Inc., Artificial Turf, Exposures to Ground-Up Rubber Tires, 2007.
8 Kim, S., Yang, J.-Y., Kim, H.-H., Yeo, I.-Y., Shin, D.-C., & Lim, Y.-W. (2012). Health Risk Assessment of Lead Ingestion
Exposure by Particle Sizes in Crumb Rubber on Artificial Turf Considering Bioavailability. Environmental Health and
Toxicology, 27, e2012005. http://doi.org/10.5620/eht.2012.27.e2012005.
Page 2 of 12
a level that is considered a “potential for hazard”. 9 Middle and high school children were also found
to have exposure levels.
In 2011, research conducted for the New Jersey Department of Environmental Protection began
investigation into the potential for players on artificial turf fields to be exposed to lead, chromium,
arsenic and cadmium as a respirable/inhalable aerosol.10 In air samples collected from the turf
during various levels of activity, researchers detected arsenic, cadmium, chromium and lead, all
metals with known human toxicity. 11 “The findings of this study, although limited in scope, raise
some concerns with regard to the potential hazards that may exist for individuals and in particular
children who engage in sports activities on artificial turf fields.” 12 The research demonstrated that
activity by players on the fields could suspend contaminated particulates into the air that could be
inhaled. “The findings show that both inhalable PM [particulate matter], as well as inhalable lead
(when present) are resuspended from even minor physical activity on an artificial surface. These data
therefore indicates that human exposure from lead-containing artificial turf fields is not just limited to
dermal, but also to inhalation route of exposure.” 13 The three potential avenues for lead from
artificial turf are the blades of artificial grass, the pigment used for the field markings and lines, and
the infill material. Even studies that have not found exposure levels to lead high enough to be of
concern in the context of the study conducted are careful to point out: “some health scientists believe
that any Pb [lead] is harmful to children’s neurocognitive development, and that no new Pb should be
added to their surroundings”14 and that “…physicians should be aware of synthetic turf as pone
potential source of exposure for young children. Health officials investigating elevated blood lead in
children should also be aware of synthetic turf as a potential source of lead exposure.”15
Furthermore, a 2008 study that looked at a variety of contaminants associated with artificial turf did
find that the lead present in the rubber granules, while at low levels, was “highly bioaccessible” to
synthetic gastric fluid used in their research. This study also found a “slightly worrisome” level of
chromium in an artificial turf fiber sample and “high bioaccessible fractions of lead in both synthetic
gastric and intestinal fluids.16
9 Kim, S., Yang, J.-Y., Kim, H.-H., Yeo, I.-Y., Shin, D.-C., & Lim, Y.-W. (2012). Health Risk Assessment of Lead Ingestion
Exposure by Particle Sizes in Crumb Rubber on Artificial Turf Considering Bioavailability. Environmental Health and
Toxicology, 27, e2012005. http://doi.org/10.5620/eht.2012.27.e2012005.
10 S.L. Shalat, Sc.D., “An Evaluation of Potential Exposures to Lead and Other Metals as the Result of Aerosolized Particulate
Matter from Artificial Turf Playing Fields, Final Report”, submitted to NJ Department of Environmental Protection, July 14,
2011.
11 S.L. Shalat, Sc.D., “An Evaluation of Potential Exposures to Lead and Other Metals as the Result of Aerosolized Particulate
Matter from Artificial Turf Playing Fields, Final Report”, submitted to NJ Department of Environmental Protection, July 14,
2011.
12 S.L. Shalat, Sc.D., “An Evaluation of Potential Exposures to Lead and Other Metals as the Result of Aerosolized Particulate
Matter from Artificial Turf Playing Fields, Final Report”, submitted to NJ Department of Environmental Protection, July 14,
2011.
13 S.L. Shalat, Sc.D., “An Evaluation of Potential Exposures to Lead and Other Metals as the Result of Aerosolized Particulate
Matter from Artificial Turf Playing Fields, Final Report”, submitted to NJ Department of Environmental Protection, July 14,
2011.
14
J. Zhang, I. Han, L. Zhang, W. Crain, “Hazardous Chemicals in synthetic turf materials and their bioaccessibility in
digestive fluids,” Journal of Exposure Science and Environmental Epidemiology (2008)
15 G. Van Ulirsch et. al, Evaluating and Regulating Lead in Synthetic Turf, Commentary, Environmental Health Perspectives,
Vol 118, No. 10, Oct. 2010.
16
J. Zhang, I. Han, L. Zhang, W. Crain, “Hazardous Chemicals in synthetic turf materials and their bioaccessibility in
digestive fluids,” Journal of Exposure Science and Environmental Epidemiology (2008)
Page 3 of 12
In October 2006 and January 2007, respectively, two sites in New York where synthetic turf has been
used (a large, then 3 year old, Parade Ground in Brooklyn; a relatively small then 5 month old Sara D.
Roosevelt Park in Manhattan) were analyzed. This testing found PAHs at hazardous levels (as per
New York standards) at each of the sites. At both sites dibenzo (a.h)anthracene, a probable human
carcinogen, was found at hazardous levels, with two other PAH forms, both possible human
carcinogens, found at hazardous levels at the Parade Ground site. A 2008 study also found that the
rubber granules found in artificial turf fields had PAH levels above health-based soil standards, that
there was “low” but not “no” bioaccessibility, and that while levels appear to decline over time this
can be altered by the fact that new rubber can be added periodically to compensate for the loss of
infill material.17 Additional research is needed into the pathways by which these substances may be
absorbed into the bodies of children and athletes via skin contact, ingestion or other pathways18 - but
the need for additional research does not displace the concerns raised by these findings.
Analyses conducted at the Environmental and Occupational Health Sciences Institute of Rutgers
University found the crumb rubber from artificial turf to contain high levels of PAHs, as well as zinc
and arsenic.19 PAHs found to be contained in the crumb rubber “were above the concentration levels
that the New York State Department of Environmental Conservation (DEC) considers sufficiently
hazardous to public health to require their removal from contaminated soil sites. It is highly likely
that all six PAHs are carcinogenic to humans.” 20 “The analyses also revealed levels of zinc in both
samples that exceed the DEC's tolerable levels.” 21 The researchers associated with these findings
were careful to state “We want to emphasize that the findings are preliminary. PAHs in rubber might
not act the same way as in soil, and we do not yet have information on the ease with which the PAHs
in these rubber particles might be absorbed by children or adults -- by ingestion, inhalation, or
absorption through the skin. However, the findings are worrisome. Until more is known, it wouldn't
be prudent to install the synthetic turf in any more parks.” 22
J. Zhang, I. Han, L. Zhang, W. Crain, “Hazardous Chemicals in synthetic turf materials and their bioaccessibility in
digestive fluids,” Journal of Exposure Science and Environmental Epidemiology (2008)
18 Rachel’s’ Democracy & Health News #992, Hazardous Chemicals in Synthetic Turf, Follow-up Analyses, April 12, 2007.
19 Junfeng Zhang, professor and acting chair, Department of Environmental and Occupational Health,
the School of Public Health, the University of Medicine and Dentistry of New Jersey and Rutgers University & William
Crain, professor of psychology at The City College of New York, president of Citizens for a Green Riverside Park,
Hazardous Chemicals in Synthetic Turf, 2006, analyses conducted at at the Environmental and Occupational Health
Sciences Institute of Rutgers.
20 Junfeng Zhang, professor and acting chair, Department of Environmental and Occupational Health,
the School of Public Health, the University of Medicine and Dentistry of New Jersey and Rutgers University & William
Crain, professor of psychology at The City College of New York, president of Citizens for a Green Riverside Park,
Hazardous Chemicals in Synthetic Turf, 2006, analyses conducted at at the Environmental and Occupational Health
Sciences Institute of Rutgers.
21 Junfeng Zhang, professor and acting chair, Department of Environmental and Occupational Health,
the School of Public Health, the University of Medicine and Dentistry of New Jersey and Rutgers University & William
Crain, professor of psychology at The City College of New York, president of Citizens for a Green Riverside Park,
Hazardous Chemicals in Synthetic Turf, 2006, analyses conducted at at the Environmental and Occupational Health
Sciences Institute of Rutgers.
22 Junfeng Zhang, professor and acting chair, Department of Environmental and Occupational Health,
the School of Public Health, the University of Medicine and Dentistry of New Jersey and Rutgers University & William
Crain, professor of psychology at The City College of New York, president of Citizens for a Green Riverside Park,
Hazardous Chemicals in Synthetic Turf, 2006, analyses conducted at at the Environmental and Occupational Health
Sciences Institute of Rutgers.
17
Page 4 of 12
A study by the California Office of Environmental Health Hazard Assessment (OEHHA) summarized
46 studies that identified 49 chemicals which are released from tire crumb. Of the 49, “seven of the
chemicals leached from tire shreds were carcinogens. OEHHA calculated a cancer risk of 1.2 in 10
million based on a one-time ingestion of the tire crumb rubber over a lifetime.”23 While there are
limited studies which assert that recycled tire crumb are stable in the gastrointestinal tract and that
therefore this is not a pathway for exposure, there are other studies which contradict these findings.24
Concerns have been raised about the potential implications of recycled tire in-fill for individuals with
latex allergies and that inhalation could result in a systemic response, as opposed to a contact
response.25
Asserted one analysis, while, “the status of the information about human exposures to recycled tire
crumb rubber in-fill … is not sufficient to determine the safety of the use of the product in situations
that involve continuous episodes of human exposure;” 26 “the available information is sufficient and
strong enough to raise plausible questions with respect to acute toxicity for susceptible persons, and
for cancer risks.”27
Chrysene, a PAH and carcinogen, was found to be ingested as the result of hand-to-surface-to-mouth
transfer from playground surfaces made with recycled tires. Assuming playground use for an 11 year
period (from age 1 to 12) there was found to be an increased cancer risk of 2.9 in one million
(2.9 X 10-6). This risk is greater than the general cancer risk gauge of one in one million (1X10-6).28
This research would seem to suggest that repeat exposure over time to the chemicals released from
artificial turf increases the associated increase in cancer risk.
The hot temperatures create additional concern for exposing players to dangerous toxins. As well
explained by a well cited petition to the Consumer Product Safety Commission for rulemaking: “When
tires are shredded and pulverized, their surface area increases exponentially, as does the particulate
and gas yield from the tire material. Since tires are made of very harmful materials, including 24
gases found to be harmful to humans, carbon black, (a carcinogen which makes up 30% of tires), latex,
benzothiazoles, phthalates, lead, mercury, cadmium, zinc and many other known toxins, when the
fields heat up, they become increasingly dynamic. Of primary concern is the interaction of particles
and gases, ‘because when particles adsorb onto the surface of gases, they become 10-20 times more
toxic than the materials themselves.’ The fields yield continuously, but become more dynamic and
more toxic as they heat up.”29
A Case Study conducted by a group of “physicians and public health professionals working with the
U.S. Environmental Protection Agency’s Region Pediatric Environmental Health Specialty Unit” found
23 Environment & Human Health, Inc., Artificial Turf, Exposures to Ground-Up Rubber Tires, 2007 citing California Office of
Environmental Health Hazard Assessment (OEHHA), Evaluation of Health Effects of Recycled Waste Tires in Playground
and Track Products, January, 2007.
24 Environment & Human Health, Inc., Artificial Turf, Exposures to Ground-Up Rubber Tires, 2007.
25 Environment & Human Health, Inc., Artificial Turf, Exposures to Ground-Up Rubber Tires, 2007.
26 Environment & Human Health, Inc., Artificial Turf, Exposures to Ground-Up Rubber Tires, 2007.
27 Environment & Human Health, Inc., Artificial Turf, Exposures to Ground-Up Rubber Tires, 2007.
28 Office of Environmental Health Hazard Assessment, Evaluation of Health Effects of Recycled Waste Tires in Playground
and Track Products, January 2007. Note -- the 1.2 in 10 million cancer risk found in the OEHHA study was considered by
the authors to be an acceptable level of risk as it falls below the general cancer risk gauge of one in one million (1X10-6).
29 Petition for a Rulemaking on Surface Heat from Artificial Turf, Submitted by PEER to Consumer Product Safety
Commission, Sept 6, 2012.
Page 5 of 12
that they could not secure the research and information necessary to establish the safety in use with
children of tire crumb used as playground surface.30 “The use of recycled tire crumb products on
playgrounds has had little health investigation. The major unresolved concern is the potential for
latex allergy with short-term dermal exposure.” 31 “No published information is available specifically
regarding exposure to crumb rubber constituents from use of the product on playgrounds.” 32
Excessive heat is a major health threat for those that play on artificial turf.
Extreme heat is a health concern – high surface temperatures found on artificial turf fields can
contribute to physiological stress and cause “serious heat-related illnesses”.33 Heat stress, heat stroke
and burns are all of concern. In fact, the “New York City Department of Health and Mental Hygiene
recognizes excessive surface temperatures as the most important health concern associated with
infilled synthetic turf.” 34 Studies document that the surface temperature on artificial turf is
dramatically increased as compared to surrounding land uses including asphalt – so much so that it is
a genuine health threat for players.
Concerns regarding the excessive temperatures range from the implications for players who are
already exerting themselves playing in such excessively high temperatures, to the implications for
burns when players or pedestrians come into contact with the hot surfaces, to the implications for
small children who may come into contact with the extremely hot surfaces during non-sporting
events. Research has also concluded that the “heat transfer from the surface to the sole of the
individual’s foot” could contribute to physiological stress of players. 35
In a 2002 study it was found that “the surface temperature of the synthetic turf was 37° F higher than
asphalt and 86.5° F hotter than natural turf.” 36 A study published in the Journal of Health and
Physical Education and Recreation showed “surface temperatures as much as 95 to 140 degrees
Fahrenheit higher on synthetic turf than natural turf grass when exposed to sunlight.” 37 Random
sampling at Brigham Young University identified temperatures ranging from 117.38 to 157 degrees
on artificial turf while neighboring natural grass areas were in the range of 78.19 to 88.5 degrees
Fahrenheit. “Two inches below the synthetic turf surface was 28.5° F hotter than natural turf at the
surface.”38 Another study comparing temperatures on artificial turf temperatures with air
temperature found that artificial turf ranged from 58 to 75 degrees hotter than measured air
temperature.39 And yet another study considering found ranges of 155.3 to 173.4 degrees on the turf
30 M.E. Anderson et al, A Case Study of tire Crumb Use on Playgrounds: Risk Analysis and Communication When Major
Clinical Knowledge Gaps Exist, Environmental Health Perspectives, Vol 114, No. 1, January 2006.
31 M.E. Anderson et al, A Case Study of tire Crumb Use on Playgrounds: Risk Analysis and Communication When Major
Clinical Knowledge Gaps Exist, Environmental Health Perspectives, Vol 114, No. 1, January 2006.
32 M.E. Anderson et al, A Case Study of tire Crumb Use on Playgrounds: Risk Analysis and Communication When Major
Clinical Knowledge Gaps Exist, Environmental Health Perspectives, Vol 114, No. 1, January 2006.
33
T.J. Serensits, A.S. McNitt, D.M. Petrunak; Human health issues on synthetic turf in the USA, Dept of Crop and Soil
Sciences, The Pennsylvania State University, IMechE Vol 225 Part P: J. Sports Engineering & Technology, Jan 6, 2011.
34
T.J. Serensits, A.S. McNitt, D.M. Petrunak; Human health issues on synthetic turf in the USA, Dept of Crop and Soil
Sciences, The Pennsylvania State University, IMechE Vol 225 Part P: J. Sports Engineering & Technology, Jan 6, 2011.
35
T.J. Serensits, A.S. McNitt, D.M. Petrunak; Human health issues on synthetic turf in the USA, Dept of Crop and Soil
Sciences, The Pennsylvania State University, IMechE Vol 225 Part P: J. Sports Engineering & Technology, Jan 6, 2011.
36 Dr. C. Frank Williams and Dr. Gilbert E. Pulley, Synthetic Surface Heat Studies, Brigham Young University.
37 SportsTurf Managers Association, A Guide to Synthetic and natural Turfgrass for Sports Fields, Selection, Construction
and Maintenance Considerations.
38 Dr. C. Frank Williams and Dr. Gilbert E. Pulley, Synthetic Surface Heat Studies, Brigham Young University.
39 T. Sciacca, The Thermal Physics of Artificial Turf, January 2008.
Page 6 of 12
fields when air temperatures were in the 76 degree range; and 104.2 to 159.3 degrees when air
temperatures were in the 77 degree range. 40
Research has not found good solutions for the excessive heat levels of turf. Irrigation of excessively
hot artificial turf surfaces only provides cooling benefits for about 20 minutes. 41 While irrigation
provides cooling for the synthetic turf, in one seminal study lowering the temperature from 174° F to
85° F, after only 5 minutes the temperature quickly rose again to 120°F; after 20 minutes it rose to
164°F.42 In another important body of work by Penn State, it was found again that irrigation is only
successful in reducing temperatures for about 20 minutes, with a rebound to within 10 degrees of the
pre-irrigation temperature within 3 hours. 43 The use of white crumb rubber as the infill does not
resolve the heat issue. 44 In fact, according to Penn State as part of a study which looked at various
color options for infill and temperature, “[w]hile marketing materials may claim lower surface
temperatures, no scientific reports exist that substantiate such claims.”45
Natural grass, by comparison, provides a natural cooling affect and helps to dissipate heat from
neighboring developed areas.46 “The temperature of natural grass rarely rises above 85 degrees
Fahrenheit, regardless of air temperature.” 47
The heat impacts of artificial turf need to be considered in the context of today’s changing climate.
Global climate change is expected to dramatically increase the number of days over 100 degrees in
many communities. Depending on how aggressively global warming gasses are reduced in coming
years, communities nearby Philadelphia will begin to experience in the range of 10 days (in lower
emission scenarios) to 30 days (if higher emission scenarios continue to prevail) over 100 degrees.48
By later in this century seasonable temperatures are projected to rise 6oF to 14oF in summer
(depending again on emission reductions achieved in the future). 49
Concerns for increased head injuries and bacterial infections as the result of playing on turf
are justified.
There is great concern that the increased level of abrasions and burns which result from playing on an
artificial turf field as compared to natural grass increases the pathways by which bacterial infections,
such as MRSA (methicillin-resistant staphylococcus aureus), can enter the body. As explained in a
2011 Penn State study, “It is important to note that synthetic turf is more abrasive than natural turf
grass and, as a result, breaks in the skin are more common, creating a pathway for infection when in
40 Penn State’s Center for Sports Surface Research, Synthetic Turf Heat Evaluation – Progress Report, January 2012.
T.J. Serensits, A.S. McNitt, D.M. Petrunak; Human health issues on synthetic turf in the USA, Dept of Crop and Soil
Sciences, The Pennsylvania State University, IMechE Vol 225 Part P: J. Sports Engineering & Technology, Jan 6, 2011.
42 Dr. C. Frank Williams and Dr. Gilbert E. Pulley, Synthetic Surface Heat Studies, Brigham Young University.
43
T.J. Serensits, A.S. McNitt, D.M. Petrunak; Human health issues on synthetic turf in the USA, Dept of Crop and Soil
Sciences, The Pennsylvania State University, IMechE Vol 225 Part P: J. Sports Engineering & Technology, Jan 6, 2011.
44
T.J. Serensits, A.S. McNitt, D.M. Petrunak; Human health issues on synthetic turf in the USA, Dept of Crop and Soil
Sciences, The Pennsylvania State University, IMechE Vol 225 Part P: J. Sports Engineering & Technology, Jan 6, 2011.
45 Penn State’s Center for Sports Surface Research, Synthetic Turf Heat Evaluation – Progress Report, January 2012.
46 James B. Beard & Robert L. Green, The Role of Turfgrasses in Environmental Protection and Their Benefits to Humans, J.
Environ Qual. 23:452-460 (1994).
47 SportsTurf Managers Association, A Guide to Synthetic and natural Turfgrass for Sports Fields, Selection, Construction
and Maintenance Considerations.
48 Union of Concerned Scientists, Confronting Climate Change in the U.S. Northeast l New Jersey, 2007.
49 Union of Concerned Scientists, Confronting Climate Change in the U.S. Northeast l New Jersey, 2007.
41
Page 7 of 12
contact with an infected surface.” 50 There are studies to indicate that turf burns may be facilitating
infection by acting as a pathway for infection.51 Study has found that turf burns increased the risk of
infection regardless of the type and timing of care provided the burn. 52
Older turf fields have been found to have higher microbial populations, as well as higher levels in the
higher traffic areas such as the sidelines, thereby suggesting to researchers that microbial populations
can accumulate in synthetic turf over time.53
Concussions (formally described as Mild Traumatic Brain Injury or MTBI) resulting from sports has,
according to the US Centers for Disease Control, reached “epidemic proportions.”54 “’Mild’ head
traumas, and especially a series of such minor concussions can have long term, negative effects on
cognitive function.” 55 Study has documented that artificial turf increases the risk of MTBI over
natural turf, approximately doubling that risk, as well as causing a greater degree of trauma.56
According to study, artificial turf presents a 5 times greater risk of the more severe head injury than
natural turf, although it is still unknown the particular characteristics of the two surfaces that cause
the difference in head injury incidence. 57 Only 31% of the playground surfaces made of recycled
tires tested in one research study passed the California State mandated Head Impact Criterion (HIC)
of <1,000. In this same study 100% of the playground surfaces made of wood chips passed the same
standard. 58
Research shows there are adverse environmental impacts resulting from crumb rubber infill
artificial turf; it is also clear that additional study for water and other natural resources is
needed.
While it seems well recognized that there is a limited level of assessment and investigation into the
environmental impacts associated with artificial turf, a growing body of scientific analysis is
T.J. Serensits, A.S. McNitt, D.M. Petrunak; Human health issues on synthetic turf in the USA, Dept of Crop and Soil
Sciences, The Pennsylvania State University, IMechE Vol 225 Part P: J. Sports Engineering & Technology, Jan 6, 2011.
51 A High Morbidity Outbreak of Methicillin-Resistant Staphylococcus aureus among Players on a College Football Team,
Facilitated by Cosmetic Body Shaving and Turf Burns, study conducted 2004 for Connecticut Dept of Public Health,
Student Health Services of Sacred Heart Univ, Centers for Disease Control and Prevention, Minnesota Dept of Public
Health, Los Angeles County Dept of Health Svces; Dr. S.V. Kazakova et.al., A Clone of Methicillin-Resistant Staphylococcus
aureus among Professional Football Players, The New England Journal of Medicine, Vol 352:468-475 No. 5, Feb. 3, 2005.
52 A High Morbidity Outbreak of Methicillin-Resistant Staphylococcus aureus among Players on a College Football Team,
Facilitated by Cosmetic Body Shaving and Turf Burns, study conducted 2004 for Connecticut Dept of Public Health,
Student Health Services of Sacred Heart Univ, Centers for Disease Control and Prevention, Minnesota Dept of Public
Health, Los Angeles County Dept of Health Svces.
53 J.J. Bass, D.W. Hintze, (2013) “Determination of Microbial Populations in a Synthetic Turf System,” Skyline – The Big Sky
Undergraduate Journal, Vol. 1, Iss. 1, Art. 1.
54 Dr. M. Shorten, J.A. Himmelsbach, BioiMechanica, Sports Surfaces and the Risk of Traumatic Brain Injury citing the US
Centers for Disease Control.
55 Dr. M. Shorten, J.A. Himmelsbach, BioiMechanica, Sports Surfaces and the Risk of Traumatic Brain Injury.
56 Dr. M. Shorten, J.A. Himmelsbach, BioiMechanica, Sports Surfaces and the Risk of Traumatic Brain Injury.
57 Dr. M. Shorten, J.A. Himmelsbach, BioiMechanica, Sports Surfaces and the Risk of Traumatic Brain Injury. See also K.M.
Guskiewica, N.L. Weaver, D.A. Padua, W.E. Garrett Jr., Epidemiology of Concussion in Collegiate and High School Football
Players, Sep-Oct 2000 & Does the Use of Artificial Turf Contribute to Head Injuries, The Journal of Trauma-Injury, Infection
and Critical Care, Oct 2002 for the finding that artificial turf increases the level of injury in comparison to natural grass
fields.
58 Office of Environmental Health Hazard Assessment, Evaluation of Health Effects of Recycled Waste Tires in Playground
and Track Products, January 2007. Please note that in this study 32 recycled tire playground surfaces were tested as
compared to only 5 wood chip playground surfaces.
50
Page 8 of 12
documenting a concerning level of environmental threat and harm and is further demonstrating the
need for more research regarding artificial turf and its ramifications for the environment.
The Connecticut Agricultural Experiment Station conclusively found four compounds which outgassed and leached into water from synthetic turf rubber crumb under ambient temperatures:
Ø Benzothiazole (a skin and eye irritant),
Ø Butylated hydroxyanisole (a “recognized carcinogen, suspected endocrine toxicant,
gastrointestinal toxicant, immune toxicant, neurotoxicant, skin and sense-organ toxicant”),
Ø n-hexadecane (a severe irritant) &
Ø 4-(t-octyl) phenol (“corrosive and destructive to mucous membranes”).59
As rubber degrades it can leach toxic substances which can contaminate soil, plants and aquatic
ecosystems.60 Study has concluded that the use of tires in artificial turf has the potential to pollute
our environment with PAHs, phenols and zinc61 and that runoff from an artificial turf field draining to
a local creek can pose “a positive risk of toxic effects on biota in the water phase and in the
sediment.”62 Other metal contaminants found to leach from tire crumb rubber include zinc, selenium,
lead and cadmium.63 Zinc has also been shown to leach from the artificial turf fibers.64 Extreme
temperatures or solvents are not needed to release these metals, volatile organic compounds or semivolatile organic compounds from the rubber in-fill of artificial turf into the air or water – release takes
place in ambient air and water temperatures.65
“Runoff with high Zn [zinc] from synthetic turf fields may produce adverse effects to plants and
aquatic life. This is of particular concern given that the leaching rate of Zn [zinc] from rubber
granules can be up to 20 times greater than the leaching rate of Zn from agricultural applications of
manure and pesticides.”66 Leaching of substances as the result of surface water runoff from
precipitation has, by some researchers, been predicted to be the greatest risk for the environment
from artificial turf. 67 Study shows there is a risk of local effects for aquatic and sediment dwelling
59 The Connecticut Agricultural Experiment Station, Examination of Crumb Rubber Produced from Recycled Tires, August
2007; Environment & Human Health, Inc., Artificial Turf, Exposures to Ground-Up Rubber Tires, 2007.
60 Quoting Dr. Linda Chalker-Scott, Washington State University -- Turfgrass Resource Center, Facts About Artificial Turf
and Natural Grass; T. Kallqvist, Norwegian Institute for Water Research(NIVA), Environmental Risk Assessment of
Artificial Turf Systems, December 2005, p. 17.; Connecticut Agricultural Experiment Station, Examination of Crumb
Rubber Produced from Recycled Tires.
61 T. Kallqvist, Norwegian Institute for Water Research(NIVA), Environmental Risk Assessment of Artificial Turf Systems,
December 2005, p. 5; T. Edeskar, Lulea University of Technology, Technical and Environmental Properties of Tyre Shreds
Focusing on Ground Engineer Application, 2004 as cited in KEM, Swedish Chemicals Agency, Facts: Synthetic Turf, April
2007.
62 T. Kallqvist, Norwegian Institute for Water Research (NIVA), Environmental Risk Assessment of Artificial Turf Systems,
December 2005, p. 6.
63Environment & Human Health, Inc., Artificial Turf, Exposures to Ground-Up Rubber Tires, 2007.
64 T. Kallqvist, Norwegian Institute for Water Research (NIVA), Environmental Risk Assessment of Artificial Turf Systems,
December 2005, p. 17.
65 Environment & Human Health, Inc., Artificial Turf, Exposures to Ground-Up Rubber Tires, 2007.
66 J. Zhang, I. Han, L. Zhang, W. Crain, “Hazardous Chemicals in synthetic turf materials and their bioaccessibility in
digestive fluids,” Journal of Exposure Science and Environmental Epidemiology (2008)
67 T. Kallqvist, Norwegian Institute for Water Research (NIVA), Environmental Risk Assessment of Artificial Turf Systems,
December 2005, p. 5; NIVA (The Norwegian Institute for Water Research), Evaluation of the Environmental Risks of
Synthetic Turf, 2005; KEM, Swedish Chemicals Agency, Facts: Synthetic Turf, April 2007.
Page 9 of 12
organisms in impacted water courses. 68 Recycled rubber, and associated leachate, has been found to
contain a variety of metals (including lead, cadmium, copper, mercury and zinc), as well as organic
pollutants such as PAHs, phthalates, 4-t-octylphenol and iso-nonyphenol. 69 The leaching of zinc has
been determined to be of major environmental concern.70 The leaching of zinc increases as the
rubber infill weathers over time,71 it is likely this is the same for other contaminants. While Zinc
contributes the most risk, phenols (specifically octylphenol) and PAHs are also of concern. 72 Of the
organic compounds at issue, Octylphenol represents the greatest risk, and possibly could occur at
levels where hormone disrupting effects are a concern. 73 The varying content of tires makes this
threat a moving target.
The Norwegian Institute for Water Research has determined that it is “appropriate to perform a risk
assessment which covers water and sediments in watercourses which receive run-off from artificial
turf pitches.”74
While recycled rubber is a greater source of pollution, newly manufactured rubber also contains
levels of hazardous substances; in the case of zinc and chromium the levels of recycled and newly
manufactured rubber are comparable.75
It is predicted that chemicals leaching from synthetic turf materials occurs slowly, and as a result the
environmental harms may take place over many years.76
Leaching may not be the only source of water contamination from artificial turf. As the artificial turf
is used there is a level of “erosion” that takes place and can result in fine particles that could be
carried to local waterways. This source of contamination needs study.77
The synthetic grass fibers can also be a significant source of pollution, particularly zinc, albeit
significantly lesser amounts leach from the synthetic grass than the rubber infill.78
68 T. Kallqvist, Norwegian Institute for Water Research(NIVA), Environmental Risk Assessment of Artificial Turf Systems,
December 2005, p. 5; NIVA (The Norwegian Institute for Water Research), Evaluation of the Environmental Risks of
Synthetic Turf, 2005, as cited by KEM, Swedish Chemicals Agency, Facts: Synthetic Turf, April 2007; KEM, Swedish
Chemicals Agency, Facts: Synthetic Turf, April 2007
69 T. Kallqvist, Norwegian Institute for Water Research (NIVA), Environmental Risk Assessment of Artificial Turf Systems,
December 2005, p. 7.
70 INTRON, Environmental and Health Risks of Rubber Infill, rubber crumb from car tyres as infill on artificial turf,
February 9, 2007.
71 INTRON, Environmental and Health Risks of Rubber Infill, rubber crumb from car tyres as infill on artificial turf,
February 9, 2007.
72 NIVA (The Norwegian Institute for Water Research), Evaluation of the Environmental Risks of Synthetic Turf, 2005, as
cited by KEM, Swedish Chemicals Agency, Facts: Synthetic Turf, April 2007.
73 T. Kallqvist, Norwegian Institute for Water Research (NIVA), Environmental Risk Assessment of Artificial Turf Systems,
December 2005, p. 17.
74 T. Kallqvist, Norwegian Institute for Water Research (NIVA), Environmental Risk Assessment of Artificial Turf Systems,
December 2005, p. 8.
75 Byggforsk, SINTEF Building and Infrastructure, Potential Health and Environmental Effects Associated with Synthetic
Turn Systems, 2004, as referenced in KEM, Swedish Chemicals Agency, Facts: Synthetic Turf, April 2007.
76 T. Kallqvist, Norwegian Institute for Water Research(NIVA), Environmental Risk Assessment of Artificial Turf Systems,
December 2005, p. 5; NIVA (The Norwegian Institute for Water Research), Evaluation of the Environmental Risks of
Synthetic Turf, 2005, as cited by KEM, Swedish Chemicals Agency, Facts: Synthetic Turf, April 2007.
77 T. Kallqvist, Norwegian Institute for Water Research (NIVA), Environmental Risk Assessment of Artificial Turf Systems,
December 2005, p. 18.
Page 10 of 12
When talking about the use of ground rubber as a supplement to planting soils the North Carolina
Department of Agriculture and Consumer Services sent out a notice identifying the risk that zinc
leaching from the rubber causes a decline in plant growth “directly attributable to zinc toxicity.”79
One Norwegian assessment/presentation reported that “recycled rubber was the major source of
potentially hazardous substances. An exposure scenario where the runoff from a football field is
drained to a small creek showed a positive risk of toxic effects on biota in the water phase and in the
sediment. The risk was mainly attributed to zinc, but also for octylphenol the predicted
environmental concentrations exceeded the no environmental effect concentration.” 80 The
hazardous leaching could result in local environmental effect.81
Conclusion
Given all of the science on the record that demonstrates artificial turf is a threat to health and the
environment, the precautionary principle dictates that artificial turf with crumb rubber infill be
recognized as a threat to public health and safety and the environment and that the ongoing
expansion and construction of crumb rubber turf fields should be prohibited and those fields that
have already been installed should be removed and properly disposed of.
When a community installs a crumb rubber artificial turf field it is forcing children who want to
participate in sports to be forced to expose themselves to its hazards. It is simply neither right nor
fair for communities, with the support or false sense of security given by an acquiescing government
agency, to be making investments that take from parents and kids the ability to decide for themselves
what health hazards they are willing to be exposed to if they want to participate in sports. Advancing
in anyway the construction and expansion of crumb rubber artificial turf fields is forcing an unfair
choice on kids and parents: play sports or protect your health, but you are not allowed to have both.
Respectfully,
Maya K. van Rossum
the Delaware Riverkeeper
P.S. I note, that as a result of my work on this issue, as a parent I have had to pull my son from the
township lacrosse team because they started playing on artificial turf this past year. The health
impacts of artificial turf are too significant and concerning for me, as a parent, to allow my 10 year old
son to play on crumb rubber artificial turf.
78 Byggforsk, SINTEF Building and Infrastructure, Potential Health and Environmental Effects Associated with Synthetic
Turn Systems, 2004, as referenced in KEM, Swedish Chemicals Agency, Facts: Synthetic Turf, April 2007.
79 M. Ray Tucker, Agronomist, Ground Rubber: Potential Toxicity to Plants, Media Notes for North Carolina Growers, North
Carolina Dept of Agriculture & Consumer Services, April 1997.
80 Dr. Christine Bjorge, Norwegian Institute of Public Health, Artificial turf Pitches – an assessment of the health risks for
football players and the environment, Presentation at the ISSS Technical meeting 2006, Dresden.
81 Dr. Christine Bjorge, Norwegian Institute of Public Health, Artificial turf Pitches – an assessment of the health risks for
football players and the environment, Presentation at the ISSS Technical meeting 2006, Dresden.
Page 11 of 12
Attachments:
Submitted as part of this comment are fact sheets and an annotated bibliography that discuss the
research detailed above as well as additional research speaking about the environmental and public
health threats posed by crumb rubber infill artificial turf.
Page 12 of 12
Summary of Research
Assessing the Impacts of Artificial Turf
Updated 4/29/2016
Heat: Research has documented that the surface temperature on artificial turf is dramatically higher than the
surrounding land uses including asphalt. Concerns regarding the excessive temperatures range from the implications
for players who are already exerting themselves to the implications for burns when players or pedestrians come into
contact with the hot surfaces.
1. Petrass, L. A., et al. (2014). Comparison of surface temperatures of different synthetic turf systems and
natural grass: Have advances in synthetic turf technology made a difference. Proceedings of the Institution
of Mechanical Engineers, Part P: Journal of Sports Engineering and Technology.
a. A comparison of surface temperatures of third-generation synthetic turf with a cool climate product
that claims to reduce surface temperatures to surface temperatures of natural grass.
b. Although surface temperatures were lower for the cool climate field compared to other synthetic
turf, both types of artificial turf fields were considerably hotter than natural grass with temperatures
that were between 12° C (53° F) and 22° C (72° F) hotter.
2. Reasor, E. H. (2014). Synthetic Turf Surface Temperature Reduction and Performance Characteristics as
Affected by Calcined Clay Modified Infill. Master’s Thesis, University of Tennessee. Available at:
http://trace.tennessee.edu/utk_gradthes/2750
a. Surface temperatures of artificial turf were between 31° C (88° F) and 57° C (135° F).
b. Although irrigation reduced surface temperatures of artificial turf, increases of 74 to 102% of the
pre-irrigation temperature were observed within 30 minutes after irrigation.
c. Surface temperatures returned to pre-irrigation temperature on all of the treatments between 60
and 120 minutes after irrigation. Therefore, the cooling effect of irrigation will not last the entire
length of an athletic competition.
3. Thoms, A. W. et al. (2014). Models for Predicting Surface Temperatures on Synthetic Turf Playing Surfaces.
Procedia Engineering, 72, 895-900. Available at:
http://www.sciencedirect.com/science/article/pii/S1877705814006699
a. Artificial turf surface temperatures ranged from -9.8 to 86.4° C (14 to 188° F) to when ambient air
temperatures ranged from -0.4 to 37.1° C (31 to 99° F).
b. Absorption of solar radiation results in increased temperatures on artificial turf surfaces, and high
rates of solar radiation are absorbed with minimal light reflectance. Therefore, air temperature in
conjunction with solar radiation explained most of the variation in artificial turf surface
temperatures.
4. Penn State’s Center for Sports Surface Research (2012). Synthetic Turf Heat Evaluation- Progress Report.
January 2012. Available at: http://plantscience.psu.edu/research/centers/ssrc/documents/heat-progressreport.pdf
DELAWARE RIVERKEEPER NETWORK
925 Canal Street, Suite 3701
Bristol, PA 19007
Office: (215) 369-1188
fax: (215)369-1181
drn@delawareriverkeeper.org
www.delawareriverkeeper.org
5.
6.
7.
8.
9.
a. This study measured surface temperatures of artificial turf fields between 140.2 and 173.4° F when
air temperatures were between 73 and 79° F.
b. Looking at various color options for infill and temperature, no product significantly reduced surface
temperatures. Small reductions in temperature are insignificant when surface temperatures still
exceed 150° F. This study concluded that “[w]hile marketing materials may claim lower surface
temperatures, no scientific reports exist that substantiate such claims.”
c. Research has not found a good solution for excessive heat levels of turf.
Serensits, T. J. et al. (2011). Human health issues on synthetic turf in the USA. Proceedings of the Institution
of Mechanical Engineers, Part P: Journal of Sports Engineering and Technology, 225(3), 139-146.
a. High surface temperatures found on artificial turf fields can contribute to physiological stress and
cause “serious heat-related illnesses” including heat stress, heat stroke, and burns.
b. The “New York City Department of Health and Mental Hygiene recognizes excessive surface
temperatures as the most important health concern associated with infilled synthetic turf.”
c. Irrigation of excessively hot artificial turf surfaces only provides cooling benefits for about 20
minutes, with a rebound to within 10 degrees of the pre-irrigation temperature within 3 hours.
d. The use of white crumb rubber as the infill does not resolve the heat issue.
Sciacca, T (2008). The Thermal Physics of Artificial Turf. SynTurf.org. Available at:
http://www.synturf.org/sciaccaheatstudy.html
a. A study comparing temperatures on artificial turf temperatures with air temperature found that
artificial turf ranged from 58 to 75° hotter than measured air temperature.
SportsTurf Managers Association (STMA) (2008). A Guide to Synthetic and Natural Turfgrass for Sports
Fields: Selection, Construction and Maintenance Considerations. 2nd edition. Available at:
http://www.stma.org/sites/stma/files/STMA_Synthetic_Guide_2nd_Edition.pdf
a. Artificial turf gets dramatically hotter than surrounding land uses including asphalt with surface
temperatures as much as 95 to 140° F hotter than natural grass fields whereas the temperature of
natural grass rarely rises above 85° F, regardless of air temperature
Williams, C. F., & Pulley, G. E. (2002). Synthetic surface heat studies. Brigham Young University. Available at:
www.wellesleyma.gov/pages/WellesleyMA_SpragueResources/Synthetic%20Surfaces%20Heat%20Study.do
c
a. Temperature measurements were taken at the surface, above the surface, and below the surface of
artificial turf, natural turf, bare soil, asphalt, and concrete.
b. Surface temperatures of synthetic turf were 37° F higher than asphalt and 86.5° F hotter than
natural turf.
c. Two inches below the surface, synthetic turf was 28.5° F hotter than natural turf.
d. Although irrigation of synthetic turf resulted in a reduction of close to 90°F, temperatures rose 35°
within five minutes and returned to the starting temperature within 20 minutes.
e. “The hottest surface temperature recorded was 200º F on a 98º F day. Even in October the surface
temperature reached 112.4º F.”
f. Brigham Young University has set a surface temperature guideline which restricts play on synthetic
turf fields when surface temperatures are potentially hazardous to athletes. This reduces the
playing season and eliminates any continuous play benefit that is typically mentioned in favor of
artificial turf.
Beard, J. B., & Green, R. L. (1994). The role of turf grasses in environmental protection and their benefits to
humans. Journal of Environmental Quality, 23(3), 452-460. Available at:
https://www.landcarenetwork.org/legislative/TheRoleofTurfgrassesinEnvironmentalProtection.pdf
a. Synthetic surfaces can be up to 39° C (102° F) hotter than natural turf. Natural turf grass provides a
natural cooling affect and helps to dissipate heat from neighboring developed areas.
Page 2 of 10
Health: The impacts of inhalation or ingestion of chemicals continues to be a concern for those playing on artificial
turf. Direct human exposure to the hazardous substances contained in the rubber in-fill of artificial turf is believed
to occur via inhalation, skin contact, and/or ingestion. Furthermore, there are concerns for increased injuries and
bacterial infections when playing on artificial turf.
1. Kim, S., Yang, J.-Y., Kim, H.-H., Yeo, I.-Y., Shin, D.-C., & Lim, Y.-W. (2012). Health Risk Assessment of Lead
Ingestion Exposure by Particle Sizes in Crumb Rubber on Artificial Turf Considering Bioavailability.
Environmental Health and Toxicology, 27, e2012005. http://doi.org/10.5620/eht.2012.27.e2012005.
a. Researchers considered the risks for lead exposure from children ingesting rubber powder resulting
from exposure to crumb rubber infill artificial turf and found that elementary school students had a
hazard index that exceeded 0.1, a level that is considered a “potential for hazard”, with middle and
high school students also suffering exposure levels.
2. Balazs, G. C., et al. (2014). Risk of Anterior Cruciate Ligament Injury in Athletes on Synthetic Playing Surfaces
A Systematic Review. The American journal of sports medicine, 0363546514545864.
a. A systematic review of available literature on the risk of ACL rupture on natural grass versus artificial
turf found that there is an increased rate of ACL injury on synthetic playing surfaces for football
players.
3. Celeiro, M., Lamas, J. P., Garcia-Jares, C., Dagnac, T., Ramos, L., & Llompart, M. (2014). Investigation of PAH
and other hazardous contaminant occurrence in recycled tyre rubber surfaces. Case-study: restaurant
playground in an indoor shopping centre. International Journal of Environmental Analytical Chemistry,
94(12), 1264-1271.
a. The presence of a large number of hazardous substances were found in both the runoff and vapor
phase of recycled tire playground surfaces.
b. Nine polycyclic aromatic hydrocarbons (PAHs) were detected in the runoff/ cleaning water with total
PAH concentrations in the ppm (parts per million) range.
c. The most toxic PAH, benzo[a]pyrene was detected in extracts from playground surfaces.
d. “The presence and the high concentration of these chemical compounds in playground should be a
matter of concern owing to their high toxicity.”
4. Laible, C., & Sherman, O. H. (2014). Risk Factors and Prevention Strategies of Non-Contact Anterior Cruciate
Ligament Injuries. Bulletin of the Hospital for Joint Diseases, 72(1), 70-5. Available at:
http://www.nyuhjdbulletin.org/mod/bulletin/v72n1/docs/v72n1_7.pdf
a. Since shoe-surface interaction is important for injury prevention, “the optimal surface to prevent
injury is outdoors on natural grass.”
b. Artificial turf has a higher friction coefficient and greater ground reaction force, both conditions that
increase the risk for injury.
c. Furthermore, as temperature increases the shoe-surface friction interaction increases and exposes
athletes to greater risk of injury.
5. Bass, J. J., & Hintze, D. W. (2013). Determination of Microbial Populations in a Synthetic Turf System.
Skyline-The Big Sky Undergraduate Journal, 1(1), 1. Available at:
http://skyline.bigskyconf.com/cgi/viewcontent.cgi?article=1000&context=journal
a. Abrasions, even insignificant ones, from artificial turf can create an entry site for pathogens.
b. The higher abrasion rate for synthetic turf increases the risk of infection, and the microbial
populations found within synthetic turf are a source of pathogens when abrasions occur.
c. Older turf fields have higher microbial populations, as well as higher levels in the higher traffic areas
such as the sidelines. These results indicate that artificial turf poses a greater risk for the spread of
pathogens and infections among student athletes.
6. Llompart, M., Sanchez-Prado, L., Lamas, J. P., Garcia-Jares, C., Roca, E., & Dagnac, T. (2013). Hazardous
organic chemicals in rubber recycled tire playgrounds and pavers. Chemosphere, 90(2), 423-431. Available
at: http://www.elcorreodelsol.com/sites/default/files/chemosphere_maria_llompart.pdf
Page 3 of 10
7.
8.
9.
10.
11.
a. An analysis of surfaces containing recycled rubber tires confirmed the presence of hazardous
substances including PAHs, phthalates, antioxidants (e.g. BHT, phenols), benzothiazole, derivatives,
and other chemicals.
b. The vapor phase above the samples confirmed volatilization of many organic compounds
demonstrating that these chemicals can enter the human body through inhalation.
c. The use of recycled rubber tires for play areas, especially facilities for children, should be restricted
or prohibited.
Serensits, T. J., McNitt, A. S., & Petrunak, D. M. (2011). Human health issues on synthetic turf in the USA.
Proceedings of the Institution of Mechanical Engineers, Part P: Journal of Sports Engineering and Technology,
225(3), 139-146.
a. Synthetic turf is more abrasive than natural turf grass, therefore, “breaks in the skin are more
common, creating a pathway for infection when in contact with an infected surface.”
Shalat, S.L. (2011). An Evaluation of Potential Exposures to Lead and Other Metals as the Result of
Aerosolized Particulate Matter from Artificial Turf Playing Fields, Final Report. Submitted to NJ Department
of Environmental Protection, July 14, 2011. Available at: http://www.nj.gov/dep/dsr/publications/artificialturf-report.pdf
a. In air samples collected from artificial turf during various levels of activity, researchers detected
arsenic, cadmium, chromium and lead, all metals with known human toxicity.
b. This research demonstrates that activity by players on the fields could suspend contaminated
particulates into the air that could be inhaled and therefore, human exposure from artificial turf
fields is not limited to dermal.
c. These results “raise some concerns with regard to the potential hazards that may exist for
individuals and in particular children who engage in sports activities on artificial turf fields.”
Van Ulirsch, G. et al. (2010). Evaluating and regulating lead in synthetic turf. Environmental health
perspectives, 118(10), 1345. Available at: http://www.ncbi.nlm.nih.gov/pmc/articles/PMC2957910/pdf/ehp118-1345.pdf
a. Artificial turf can degrade to form lead containing dust at levels that pose a health risk to children.
b. Due to the lack of research, “…physicians should be aware of synthetic turf as one potential source
of exposure for young children…” and “Health officials investigating elevated blood lead in children
should also be aware of synthetic turf as a potential source of lead exposure.”
Center for Disease Control and Prevention. (2008). CDC Health Advisory. Potential exposures to lead
inartificial turf: Public health issues, actions, and recommendations. June 18, 2008. Available at:
http://www.dhhr.wv.gov/oeps/disease/Documents/Advisory_00275.pdf
a. Artificial turf made of nylon or nylon/ polyethylene blend fibers contain lead and pose a potential
public health concern.
b. The risk for lead exposure is higher for artificial fields that are old, frequently used, exposed to the
weather, or demonstrate signs of abraded, faded, or broken fibers. As turf ages, lead is released in
dust that could then be ingested or inhaled.
c. CDC does not know how much lead the body will absorb. However, lead can cause neurological
development symptoms and behavioral problems. Children less than 6 years old are more affected
by lead than adults and absorb lead more easily.
d. CDC does not understand the potential risks associated with lead exposure from artificial turf but
recommends precautions including aggressive hand and body washing after playing on fields,
washing clothes immediately to avoid tracking contaminated dust to other places, and discouraging
eating and drinking while on turf products.
Han, I. K., Zhang, L., & Crain, W. (2008). Hazardous chemicals in synthetic turf materials and their
bioaccessibility in digestive fluids. Journal of Exposure Science and Environmental Epidemiology, 18(6), 600607. Available at: http://www.nature.com/jes/journal/v18/n6/pdf/jes200855a.pdf
Page 4 of 10
a. Samples from rubber granules and from artificial grass fibers were taken at fields of different ages
and analyzed for polycyclic aromatic hydrocarbons (PAHs), zinc, chromium, arsenic, cadmium, and
lead. These samples were then analyzed to determine their bioaccessibility in synthetic digestive
fluids.
b. The rubber granules found in artificial turf fields had PAH levels above health-based soil standards.
Although levels appear to decline over time, this trend can be altered by the fact that new rubber
can be added periodically to compensate for the loss of infill material.
c. There was a “slightly worrisome” level of chromium found in artificial turf fiber samples.
d. Lead in artificial fields can come from the blades of artificial grass, the pigment used for the field
markings and lines, and the infill material. Although there were relatively low concentrations of lead
measured, the researchers were careful to point out: “some health scientists believe that any Pb
[lead] is harmful to children’s neurocognitive development, and that no new Pb should be added to
their surroundings.” Furthermore, the lead present in the rubber granules, while at low levels, was
“highly bioaccessible” to synthetic gastric fluid.
12. Brown, D.R. (2007). Artificial Turf: Exposures to Ground-up Rubber Tires. Environment & Human Health, Inc.
(EHHI). Available at: http://www.ehhi.org/reports/turf/turf_report07.pdf
a. Direct human exposure to the hazardous substances contained in artificial turf occurs via three
pathways: inhalation as chemicals off gas from the turf, skin contact, or ingestion including by
children or infants who come into contact with the material. In the case of allergies (i.e. latex
allergies), inhalation could result in a systemic response, as opposed to a contact response.
b. Extreme temperatures or solvents are not needed to release metals (including zinc, selenium, lead
and cadmium), volatile organic compounds, or semi-volatile organic compounds from the rubber infill of artificial turf into the air or water – release takes place in ambient air and water temperatures.
c. While, “the status of the information about human exposures to recycled tire crumb rubber in-fill …
is not sufficient to determine the safety of the use of the product in situations that involve
continuous episodes of human exposure;” “the available information is sufficient and strong
enough to raise plausible questions with respect to acute toxicity for susceptible persons, and for
cancer risks.”
13. California Office of Environmental Health Hazard Assessment (OEHHA) (2007). Evaluation of Health Effects
of Recycled Waste Tires in Playground and Track Products. Report prepared for the Integrated Waste
Management Board. Available at:
http://www.calrecycle.ca.gov/publications/Documents/Tires%5C62206013.pdf
a. Based on a review of 46 studies, 49 chemicals that are released from tire crumb were identified.
b. Of the 49 chemicals identified, “seven of the chemicals leached from tire shreds were carcinogens.”
c. OEHHA calculated a cancer risk of 1.2 in 10 million based on a one-time ingestion of the tire crumb
rubber over a lifetime.
d. Chrysene, a PAH and carcinogen, was found to be ingested as the result of hand-to-surface-tomouth transfer from playground surfaces made with recycled tires. Assuming playground use for an
11 year period (from age 1 to 12) there was found to be an increased cancer risk of 2.9 in one million
from the general cancer risk gauge of one in one million
e. Only 31% of the playground surfaces made of recycled tires tested passed the California State
mandated Head Impact Criterion (HIC) of <1,000. In this same study 100% of the playground
surfaces made of wood chips passed the same standard.
14. Crain, W. and Zhang, J. (2007). Rachel’s Democracy and Health News #992: Hazardous Chemicals in
Synthetic Turf, Follow-up Analyses, April 12, 2007. Available at:
http://www.precaution.org/lib/07/prn_synthetic_turf.070405.htm
Page 5 of 10
15.
16.
17.
18.
19.
a. Testing on two sites in New York where synthetic turf has been used (the large, 3 year old, Parade
Ground in Brooklyn; the relatively small 5 month old Sara D. Roosevelt Park in Manhattan) found
PAHs at hazardous levels (as per New York standards). Dibenzo (a.h)anthracene, a probable human
carcinogen, was also found at hazardous levels, with two other PAH forms, both possible human
carcinogens, found at hazardous levels at the Parade Ground site.
b. Research into the pathways by which these substances may be absorbed into the bodies of children
and athletes via skin contact, ingestion or other pathways, is very limited with additional research
needed.
Epstein, V. (2007). Texas Football Succumbs to Virulent Staph Infection from Turf. Bloomberg Press,
December 21, 2007. Available at:
http://www.bloomberg.com/apps/news?pid=newsarchive&sid=alxhrJDn.cdc
a. Artificial turf is linked with serious and potentially life threatening staph infections including MRSA
(methicillin-resistant staphylococcus aureus). MRSA can exploit minor skin injuries such as turf
burn, and therefore, MRSA infection rate among players is 16 times higher than the national
average.
KEMI, Swedish Chemicals Agency (2007). Facts: Synthetic Turf. April 2007. Available:
http://www2.kemi.se/upload/trycksaker/pdf/faktablad/fbsyntheticturf.pdf.
a. Tires contain up to 60 different substances which may be bioaccumulative, carcinogenic, reprotoxic,
mutagenic and/or endocrine disrupting.
b. Most PAHs are persistent, bioaccumulative and carcinogenic.
c. Among the metals found in tires that may be of concern are zinc, lead, copper, chromium and
cadmium. Zinc and copper are harmful when absorbed at high levels. Lead can affect reproduction
and development of the nervous system leading to poor cognitive development. Chromium is
carcinogenic and mutagenic. Cadmium is toxic to humans and can contribute to poor liver and
kidney function, as well as osteoporosis.
Mattina, M. I., Isleyen, M., Berger, W., & Ozdemir, S. (2007). Examination of crumb rubber produced from
recycled tires. The Connecticut Agricultural Experiment Station, New Haven, CT. Available at:
http://www.ct.gov/caes/lib/caes/documents/publications/fact_sheets/examinationofcrumbrubberac005.pd
f
a. Multiple compounds out-gas and leached into water from synthetic turf rubber crumb under
ambient temperatures including benzothiazole (a skin and eye irritant), butylated hydroxyanisole (a
“recognized carcinogen, suspected endocrine toxicant, gastrointestinal toxicant, immune toxicant,
neurotoxicant, skin and sense-organ toxicant”), n-hexadecane (a severe irritant), and 4-(t-octyl)
phenol (“corrosive and destructive to mucous membranes”).
Anderson, M. E. et al. (2006). A case study of tire crumb use on playgrounds: risk analysis and
communication when major clinical knowledge gaps exist. Environmental health perspectives, 114(1), 1.
Available at: http://www.ncbi.nlm.nih.gov/pmc/articles/PMC1332647/pdf/ehp0114-000001.pdf
a. A Case Study conducted by a group of physicians and public health professionals working with the
U.S. Environmental Protection Agency’s Region Pediatric Environmental Health Specialty Unit found
that the research and information necessary is not available to establish “the safety in use with
children” of tire crumb used as playground surfaces.
b. “The use of recycled tire crumb products on playgrounds has had little health investigation. The
major unresolved concern is the potential for latex allergy with short-term dermal exposure.”
Crain, W. and Zhang, J. (2006). Rachel’s Democracy and Health News #871: Hazard Chemicals in Synthetic
Turf. September 7, 2006. Available at:
http://www.precaution.org/lib/06/prn_toxins_in_synthetic_turf.060831.htm
Page 6 of 10
20.
21.
22.
23.
24.
a. Analyses conducted at the Environmental and Occupational Health Sciences Institute of Rutgers
University found the crumb rubber from artificial turf to contain high levels of PAHs, as well as zinc
and arsenic.
b. PAHs found to be contained in the crumb rubber “were above the concentration levels that the New
York State Department of Environmental Conservation (DEC) considers sufficiently hazardous to
public health to require their removal from contaminated soil sites. It is highly likely that all six PAHs
are carcinogenic to humans.”
c. “The analyses also revealed levels of zinc in both samples that exceed the DEC's tolerable levels.”
d. The researchers associated with these findings were careful to state “We want to emphasize that
the findings are preliminary. PAHs in rubber might not act the same way as in soil, and we do not yet
have information on the ease with which the PAHs in these rubber particles might be absorbed by
children or adults -- by ingestion, inhalation, or absorption through the skin. However, the findings
are worrisome. Until more is known, it wouldn't be prudent to install the synthetic turf in any more
parks.”
Kazakova, S. V. et al. (2005). A clone of methicillin-resistant Staphylococcus aureus among professional
football players. New England Journal of Medicine, 352(5), 468-475. Available at:
http://www.nejm.org/doi/pdf/10.1056/NEJMoa042859
a. In a study of professional football players from the St. Louis Rams team, all MRSA infections
developed at sites of turf burns.
b. Players reported a higher frequency of abrasions when playing on artificial turf compared to natural
grass.
Begier, E. M. et al. (2004). A high-morbidity outbreak of methicillin-resistant Staphylococcus aureus among
players on a college football team, facilitated by cosmetic body shaving and turf burns. Clinical infectious
diseases, 39(10), 1446-1453. (a study conducted for the Connecticut Department of Public Health, Student
Health Services of Sacred Heart Univ, Centers for Disease Control and Prevention, Minnesota Department of
Public Health, and the Los Angeles County Department of Health Services).
a. In a study of MRSA outbreaks involving college football players, infection was associated with turf
burns from artificial grass. Turf burns increased the risk of infection regardless of the type and
timing of care provided the burn. Turf burns may be facilitating infection by acting as a pathway for
infection.
Shorten, M. R., & Himmelsbach, J. A. (2003). Sports surfaces and the risk of traumatic brain injury. Sports
surfaces. University of Calgary, Calgary, 49-69. Available at:
http://biomechanica.com/docs/publications/docs/Shorten%20-%20Head%20Injury%20Risk.pdf
a. There is double the risk of head traumas such as concussions associated with artificial turf compared
to natural turf, and artificial turf presents a 5 times greater risk of more severe head injury.
b. Concussions (formally described as Mild Traumatic Brain Injury or MTBI) resulting from sports has,
according to the US Centers for Disease Control, reached “epidemic proportions,” and these ’mild’
head traumas, especially a series of concussions, can have long term, negative effects on cognitive
function.
Naunheim, R., et al. (2002). Does the use of artificial turf contribute to head injuries?. Journal of TraumaInjury, Infection, and Critical Care, 53(4), 691-694.
a. The impact-attenuating properties of two artificial fields were compared to a grass outdoor practice
field. Both artificial surfaces were harder compared to the outdoor grass field. It was concluded
that the low impact attenuation of the artificial turf may be contributing to the high incidence of
concussion.
Guskiewicz, K. M., et al. (2000). Epidemiology of concussion in collegiate and high school football players.
The American Journal of Sports Medicine, 28(5), 643-650.
Page 7 of 10
a. In a survey of both high school and collegiate certified athletic trainers representing over 17,000
football players, contact with artificial turf was associated with more serious concussion than
contact with natural grass.
Environment: The pollutant substances found in artificial turf contribute to contamination of soil, plants and aquatic
ecosystems and pose a risk of toxic effects for aquatic and sediment dwelling organisms. The resulting
environmental harm is on-going and long-term, happening over many years. The varying content of tires used for
infill of turf systems makes this threat a moving target. A growing body of scientific analysis is documenting a
concerning level of environmental threat and harm and is further demonstrating the need for more research
regarding artificial turf and its ramifications for the environment.
1. Public Employees for Environmental Responsibility (PEER) (2012). Petition for a Rulemaking on Surface Heat
from Artificial Turf, Submitted by PEER to Consumer Product Safety Commission, Sept 6, 2012. Available at:
http://www.peer.org/assets/docs/doc/9_6_12_PEER_Petition_heat_rulemaking.pdf
a. As well explained by an oft cited petition to the Consumer Product Safety Commission for
rulemaking: “When tires are shredded and pulverized, their surface area increases exponentially, as
does the particulate and gas yield from the tire material. Since tires are made of very harmful
materials, including 24 gases found to be harmful to humans, carbon black, (a carcinogen which
makes up 30% of tires), latex, benzothiazoles, phthalates, lead, mercury, cadmium, zinc and many
other known toxins, when the fields heat up, they become increasingly dynamic. Of primary
concern is the interaction of particles and gases, ‘because when particles adsorb onto the surface of
gases, they become 10-20 times more toxic than the materials themselves.’”
b. Furthermore, artificial turf becomes more toxic as it heats up.
2. Sadiktsis, I., et al. (2012). Automobile Tires A Potential Source of Highly Carcinogenic Dibenzopyrenes to
the Environment. Environmental science & technology, 46(6), 3326-3334. Available at:
http://www.locchiodiromolo.it/blog/wp-content/uploads/2012/03/Sadiktsis-et-al-Automobile-TiresPotential-Source-of-Highly-Carcinogenic-2012.pdf
a. The variability in PAH concentrations between different tires is large.
b. Due to “leaching of PAHs from recycled tire rubber material, tires are a source of environmental
pollution of PAHs through their entire lifecycle.”
3. Connecticut Department of Environmental Protection (2010). Artificial Turf Study: Leachate and Stormwater
Characteristics, Final Report. Available at:
http://www.ct.gov/deep/lib/deep/artificialturf/dep_artificial_turf_report.pdf
a. Stormwater runoff from artificial turf contained zinc, manganese, and chromium at levels toxic to
aquatic organisms.
b. Therefore, there is a potential risk to surface waters from the installation of artificial turf. Zinc levels
could cause exceedance of acute aquatic toxicity criteria. This risk is especially high for smaller
watercourses.
c. Best management practices and treatment (i.e. wetlands, wet ponds, infiltration structures,
compost filter, sand filters, or biofiltration structures) should be used for stormwater runoff from
artificial turf fields that discharge to surface waters.
4. Yaghoobian, N., et al. (2010). Modeling the thermal effects of artificial turf on the urban environment.
Journal of Applied Meteorology and Climatology, 49(3), 332-345.
a. An urban temperature model showed an increase in local atmospheric temperatures of up to 4° C
(39° F) in areas where natural grass cover had been replaced with artificial turf.
5. Han, I. K., et al. (2008). Hazardous chemicals in synthetic turf materials and their bioaccessibility in digestive
fluids. Journal of Exposure Science and Environmental Epidemiology, 18(6), 600-607. Available at:
http://www.nature.com/jes/journal/v18/n6/pdf/jes200855a.pdf
Page 8 of 10
6.
7.
8.
9.
a. Zinc was found to exceed soil limits and the leaching rate from rubber granules was up to 20 times
more than the leaching rate from agricultural applications of manure and pesticides. “Runoff with
high Zn [zinc] from synthetic turf fields may produce adverse effects to plants and aquatic life.”
KEMI, Swedish Chemicals Agency (2007). Facts: Synthetic Turf. April 2007. Available:
http://www2.kemi.se/upload/trycksaker/pdf/faktablad/fbsyntheticturf.pdf.
a. Hazardous substances found in tires may persist in the environment including polycyclic aromatic
hydrocarbons (PAHs), phthalates, phenols, and certain metals.
b. Most PAHs are persistent, bioaccumulative and carcinogenic.
c. Phthalates and phenols are not chemically bound to the rubber and as a result can leach from the
infill material. These chemicals are persistent and bioaccumulative and can have long-term effects
on the environment.
Meil, J., & Bushi, L. (2006). Estimating the Required Global Warming Offsets to Achieve a Carbon Neutral
Synthetic Field Turf System Installation. Athena Institute. Ontario Canada. Available at:
http://sfrecpark.org/wp-content/uploads/AthenaICarbonOffsets.pdf
a. Artificial turf systems have a carbon footprint due to the greenhouse gases emitted during the life
cycle of synthetic turf systems compared to natural grass surfaces.
b. To achieve a 10-year carbon neutral synthetic turf installation, 1861 trees would need to be planted
to offset the field’s carbon footprint.
Källqvist, T. (2005). Environmental risk assessment of artificial turf systems. Norwegian Institute for Water
Research, 19.
a. Recycled rubber varies considerably in its chemical composition, even when from the same
manufacturer.
b. Leaching of contaminants from artificial turf as the result of surface water runoff from precipitation
is a great risk for the environment. It is predicted that chemicals leaching from synthetic turf
materials occurs slowly, and as a result the environmental harms may take place over many years.
There is also a level of “erosion” that takes place and can result in fine particles that could be carried
to local waterways. Chemicals have even been shown to leach from the artificial turf fibers.
c. The leachate from artificial turf can contain a variety of metals (including lead, cadmium, copper,
mercury and zinc) and organic pollutants (including PAHs, phthalates, 4-t-octylphenol and isononyphenol).
d. The runoff from an artificial turf field poses “a positive risk of toxic effects on biota in the water
phase and in the sediment.”
e. Of the organic compounds at issue, octylphenol represents the greatest risk, and possibly could
occur at levels where hormone disrupting effects are a concern.
f. The Norwegian Institute for Water Research has determined that it is “appropriate to perform a risk
assessment which covers water and sediments in watercourses which receive run-off from artificial
turf pitches.”
Thale, S.W. et al. (2004) Potential Health and Environmental Effects Associated with Synthetic Turf Systems-
final report. Byggforsk, Norwegian Building Research Institute. Available at: http://www.issssportsurfacescience.org/downloads/documents/vskyslv2qq_nbiengelsk.pdf
a. While recycled rubber is a greater source of pollution, newly manufactured rubber also contains
levels of hazardous substances; in the case of zinc and chromium the levels of recycled and newly
manufactured rubber are comparable.
b. The synthetic grass fibers can also be a significant source of pollution, albeit significantly lesser
amounts leach from the synthetic grass than the rubber infill
Page 9 of 10
10. Tucker, M.R. (1997). Ground Rubber: Potential Toxicity to Plants. Media Notes for North Carolina Growers,
North Carolina Dept. of Agriculture & Consumer Services, April 1997. Available at:
http://www.ncagr.gov/agronomi/pdffiles/rubber.pdf
a. When talking about the use of ground rubber as a supplement to planting soils, the North Carolina
Department of Agriculture and Consumer Services sent out a notice identifying the risk that zinc
leaching from the rubber causes a decline in plant growth “directly attributable to zinc toxicity.”
11. Quoting Dr. Linda Chalker-Scott, Washington State University - Turfgrass Resource Center, Facts About
Artificial Turf and Natural Grass. (n.d.) Available at: http://plasticfieldsfornever.org/ArtificialTurfBooklet.pdf
a. “There is no question that toxic substances leach from rubber as it degrades, contaminating the soil,
flora, and fauna and aquatic systems.”
12. Turfgrass Resource Center (n.d.) Facts About Artificial Turf and Natural Grass. Available at:
http://plasticfieldsfornever.org/ArtificialTurfBooklet.pdf
a. Part of artificial turf maintenance is the regular replenishment of the infill. Some of the infill is
merely settling, but some of it is washing away or literally “walking away” with players after use.
The effects of this “runaway” infill are unknown and more research is needed to draw conclusions–
where is it going and what impacts is it having?
b. Maintenance of artificial turf can include application of algaecides or disinfectants to keep the
surface clean and application of fabric softener to mask the odor of the artificial turf. What is the
final destination of these chemicals and their implications for the environment and those coming
into contact with them while playing on the fields?
c. There is no indication that artificial turf drains more effectively for purposes of a stormwater
infiltration system than natural grass. In addition, infiltration systems are designed to work with
whatever surface coating they receive from natural grass to porous paving. Although there is no
assumed benefit from an infiltration perspective of natural turf or artificial turf, in many cases the
complex systems designed for artificial turf fields have experience problems, work incorrectly, or
inefficiently.
Page 10 of 10
Fact Sheet
Artificial/Synthetic Turf
While professional sports are turning away from artificial turf, it is gaining ground and
use at the local level at schools and community fields. Producers of artificial turf
make claims of environment, health and safety benefits associated with artificial turf –
when they make these blanket claims they are not giving the full picture.
In terms of environment, health and safety, the jury is still very far out
on artificial turf. There continues to be information documenting harm in
each of these arenas. Most of all, there is a widespread demonstration
and recognition that in terms of environmental, health and safety threats
from artificial turf, much more study, analysis and consideration is
needed. And whatever the final outcome of the research, manufacturers neglect the
reality that as much as they try to mimic natural grass, artificial turf is not grass, and
cannot provide the same natural feel, natural look, natural smell and environmental
benefits that natural grass provides.
Artificial Turf is generally comprised of plastic fibers (generally made of polyethylene,
polypropylene or nylon) attached to a polypropylene or polyester plastic webbing. A
combination of sand and rubber, or sometimes rubber alone, fills between the fibers.
The source for the rubber infill is generally recycled tires. Sometimes newly
manufactured rubber granulate is used but the cost is so much greater than the
recycled tire form that it is generally not the substance used. New developments in
artificial turf technology seem continually in the works.
Water Quality:
While it seems well recognized that there is a limited level of assessment and
investigation into the environmental impacts associated with artificial turf, a growing
body of scientific analysis is documenting a concerning level of environmental threat
and harm and is further demonstrating the need for more research regarding artificial
turf and its ramifications for the environment.
Synthetic turf is generally made with rubber from waste tires. Recycled rubber varies
considerably in its chemical composition, even when from the same manufacturer.1
Hazardous substances found in tires may persist in the environment including
polycyclic aromatic hydrocarbons (PAHs), phthalates and certain metals. These
substances may be bioaccumulative, carcinogenic, reprotoxic, mutagenic and/or
endocrine disrupting.2 The chemicals in waste tires are of such concern that a report
published by the Swedish Chemicals Inspectorate recommends: “waste tyres should
not be used for synthetic turf surfaces.” 3
• Most PAHs are persistent, bioaccumulative and carcinogenic.4
• Phthalates are generally used as solvents and plasticisers in plastics. Phthalates
are not chemically bound to the rubber and as a result can leach from the infill
material.5
• Phenols likewise are not chemically bound to the rubber and so can leach.
Phenols too are persistent and bioaccumulative and can have long-term effects
on the environment.6
• Among the metals found in tires that may be of concern are zinc, lead, copper,
chromium and cadmium. While zinc and copper are essential for living
organisms, when absorbed at high levels they become harmful. Lead can affect
reproduction, development of the nervous system leading to poor cognitive
development, and is a particular threat to fetuses and young children.
Chromium is carcinogenic and mutagenic. Cadmium is toxic to humans and if
taken in can contribute to poor liver and kidney function, as well as
osteoporosis. 7
The Connecticut Agricultural Experiment Station conclusively found four compounds
which out-gassed and leached into water from synthetic turf rubber crumb under
ambient temperatures:
Ø Benzothiazole (a skin and eye irritant),
T. Kallqvist, Norwegian Institute for Water Research (NIVA), Environmental Risk Assessment of
Artificial Turf Systems, December 2005, p. 7.
2
KEM, Swedish Chemicals Agency, Facts: Synthetic Turf, April 2007.
3
KEM, Swedish Chemicals Agency, Facts: Synthetic Turf, April 2007.
4
KEM, Swedish Chemicals Agency, Facts: Synthetic Turf, April 2007.
5
KEM, Swedish Chemicals Agency, Facts: Synthetic Turf, April 2007.
6
KEM, Swedish Chemicals Agency, Facts: Synthetic Turf, April 2007.
7
KEM, Swedish Chemicals Agency, Facts: Synthetic Turf, April 2007.
1
Page 2 of 13
Artificial Turf Fact Sheet, 9/9/07
Ø Butylated hydroxyanisole (a “recognized carcinogen, suspected endocrine
toxicant, gastrointestinal toxicant, immune toxicant, neurotoxicant, skin and
sense-organ toxicant”),
Ø n-hexadecane (a severe irritant) &
Ø 4-(t-octyl) phenol (“corrosive and destructive to mucous membranes”).8
As rubber degrades it can leach toxic substances which can contaminate soil, plants
and aquatic ecosystems.9 Study has concluded that the use of tires in artificial turf
has the potential to pollute our environment with PAHs, phenols and zinc10 and that
runoff from an artificial turf field draining to a local creek can pose “a positive risk of
toxic effects on biota in the water phase and in the sediment.”11 Other metal
contaminants found to leach from tire crumb rubber include zinc, selenium, lead and
cadmium.12 Zinc has also been shown to leach from the artificial turf fibers.13
Extreme temperatures or solvents are not needed to release these metals, volatile
organic compounds or semi-volatile organic compounds from the rubber in-fill of
artificial turf into the air or water – release takes place in ambient air and water
temperatures.14
Leaching of substances as the result of surface water runoff from precipitation has,
by some researchers, been predicted to be the greatest risk for the environment from
artificial turf. 15 Study shows there is a risk of local effects for aquatic and sediment
dwelling organisms in impacted water courses. 16 Recycled rubber, and associated
The Connecticut Agricultural Experiment Station, Examination of Crumb Rubber Produced from
Recycled Tires, August 2007; Environment & Human Health, Inc., Artificial Turf, Exposures to GroundUp Rubber Tires, 2007.
9
Quoting Dr. Linda Chalker-Scott, Washington State University -- Turfgrass Resource Center, Facts
About Artificial Turf and Natural Grass; T. Kallqvist, Norwegian Institute for Water Research(NIVA),
Environmental Risk Assessment of Artificial Turf Systems, December 2005, p. 17.; Connecticut
Agricultural Experiment Station, Examination of Crumb Rubber Produced from Recycled Tires.
10
T. Kallqvist, Norwegian Institute for Water Research(NIVA), Environmental Risk Assessment of
Artificial Turf Systems, December 2005, p. 5; T. Edeskar, Lulea University of Technology, Technical and
Environmental Properties of Tyre Shreds Focusing on Ground Engineer Application, 2004 as cited in
KEM, Swedish Chemicals Agency, Facts: Synthetic Turf, April 2007.
11
T. Kallqvist, Norwegian Institute for Water Research (NIVA), Environmental Risk Assessment of
Artificial Turf Systems, December 2005, p. 6.
12
Environment & Human Health, Inc., Artificial Turf, Exposures to Ground-Up Rubber Tires, 2007.
13
T. Kallqvist, Norwegian Institute for Water Research (NIVA), Environmental Risk Assessment of
Artificial Turf Systems, December 2005, p. 17.
14
Environment & Human Health, Inc., Artificial Turf, Exposures to Ground-Up Rubber Tires, 2007.
15
T. Kallqvist, Norwegian Institute for Water Research (NIVA), Environmental Risk Assessment of
Artificial Turf Systems, December 2005, p. 5; NIVA (The Norwegian Institute for Water Research),
Evaluation of the Environmental Risks of Synthetic Turf, 2005; KEM, Swedish Chemicals Agency, Facts:
Synthetic Turf, April 2007.
16
T. Kallqvist, Norwegian Institute for Water Research(NIVA), Environmental Risk Assessment of
Artificial Turf Systems, December 2005, p. 5; NIVA (The Norwegian Institute for Water Research),
Evaluation of the Environmental Risks of Synthetic Turf, 2005, as cited by KEM, Swedish Chemicals
8
Page 3 of 13
Artificial Turf Fact Sheet, 9/9/07
leachate, has been found to contain a variety of metals (including lead, cadmium,
copper, mercury and zinc), as well as organic pollutants such as PAHs, phthalates, 4-toctylphenol and iso-nonyphenol. 17 The leaching of zinc has been determined to be of
major environmental concern.18 The leaching of zinc increases as the rubber infill
weathers over time,19 it is likely this is the same for other contaminants. While Zinc
contributes the most risk, phenols (specifically octylphenol) and PAHs are also of
concern. 20 Of the organic compounds at issue, Octylphenol represents the greatest
risk, and possibly could occur at levels where hormone disrupting effects are a
concern. 21 The varying content of tires makes this threat a moving target.
The Norwegian Institute for Water Research has determined that it is “appropriate to
perform a risk assessment which covers water and sediments in watercourses which
receive run-off from artificial turf pitches.”22
While recycled rubber is a greater source of pollution, newly manufactured rubber also
contains level of hazardous substances; in the case of zinc and chromium the levels of
recycled and newly manufactured rubber are comparable.23
It is predicted that chemicals leaching from synthetic turf materials occurs slowly, and
as a result the environmental harms may take place over many years.24
Leaching may not be the only source of water contamination from artificial turf. As
the artificial turf is used there is a level of “erosion” that takes place and can result in
Agency, Facts: Synthetic Turf, April 2007; KEM, Swedish Chemicals Agency, Facts: Synthetic Turf, April
2007
17
T. Kallqvist, Norwegian Institute for Water Research (NIVA), Environmental Risk Assessment of
Artificial Turf Systems, December 2005, p. 7.
18
INTRON, Environmental and Health Risks of Rubber Infill, rubber crumb from car tyres as infill on
artificial turf, February 9, 2007.
19
INTRON, Environmental and Health Risks of Rubber Infill, rubber crumb from car tyres as infill on
artificial turf, February 9, 2007.
20
NIVA (The Norwegian Institute for Water Research), Evaluation of the Environmental Risks of
Synthetic Turf, 2005, as cited by KEM, Swedish Chemicals Agency, Facts: Synthetic Turf, April 2007.
21
T. Kallqvist, Norwegian Institute for Water Research (NIVA), Environmental Risk Assessment of
Artificial Turf Systems, December 2005, p. 17.
22
T. Kallqvist, Norwegian Institute for Water Research (NIVA), Environmental Risk Assessment of
Artificial Turf Systems, December 2005, p. 8.
23
Byggforsk, SINTEF Building and Infrastructure, Potential Health and Environmental Effects Associated
with Synthetic Turn Systems, 2004, as referenced in KEM, Swedish Chemicals Agency, Facts: Synthetic
Turf, April 2007.
24
T. Kallqvist, Norwegian Institute for Water Research(NIVA), Environmental Risk Assessment of
Artificial Turf Systems, December 2005, p. 5; NIVA (The Norwegian Institute for Water Research),
Evaluation of the Environmental Risks of Synthetic Turf, 2005, as cited by KEM, Swedish Chemicals
Agency, Facts: Synthetic Turf, April 2007.
Page 4 of 13
Artificial Turf Fact Sheet, 9/9/07
fine particles that could be carried to local waterways. This source of contamination
needs study.25
The synthetic grass fibers can also be a significant source of pollution, particularly
zinc, albeit significantly lesser amounts leach from the synthetic grass than the rubber
infill.26
Concerns about the environmental and health effects of synthetic turf in European
countries is so great that standards and/or guidelines have been set or are under
consideration. For example: Germany has set standards for the use of synthetic turf
including a maximum allowable level of pollution or contamination of water and soil,
with a requirement of regular sampling to ensure these standards are not exceeded.
Allowable pollution levels include: lead 0.04 mg/l, cadmium 0.005 mg/l; chromium
0.05 mg/l, mercury 0.001 mg/l and zinc 3.0 mg/l or 0.5 mg/l depending on the
testing method used. 27 Holland has also suggested appropriate language for a
standard applicable to use of synthetic turf including a ban on the use of carcinogens,
mutagenic, reprotoxic, persistent, bioaccumulative and toxic, or very persistent and
very bioaccumulative substances in the surface layer of the turf and a limitation on
the level of substances in the rubber infill that may cause cancer, may cause heritable
genetic damage, may cause cancer by inhalation, are toxic or harmful to aquatic
organisms or may cause long term affects on the aquatic environment, that may
impair fertility or cause harm to unborn children. Sweden has set guidelines and
limiting values for some of the substances that are present in synthetic turf,
specifically as it relates to air pollution, soil contamination and water pollution. 28 And
because vehicle tires contain levels of several substances of “very high concern”, the
recycling and use of tires in synthetic turf is apparently in conflict with the Swedish
environmental objective of A Non Toxic Environment.29
Part of artificial turf maintenance is the regular replenishment of the infill. There is a
need for research into the loss of existing infill – where is it going and what impacts is
it having?30
Maintenance of artificial turf can include application of algaecides or disinfectants to
keep the surface clean. 31 Maintenance could also include application of fabric
T. Kallqvist, Norwegian Institute for Water Research (NIVA), Environmental Risk Assessment of
Artificial Turf Systems, December 2005, p. 18.
26
Byggforsk, SINTEF Building and Infrastructure, Potential Health and Environmental Effects Associated
with Synthetic Turn Systems, 2004, as referenced in KEM, Swedish Chemicals Agency, Facts: Synthetic
Turf, April 2007.
27
KEM, Swedish Chemicals Agency, Facts: Synthetic Turf, April 2007.
28
KEM, Swedish Chemicals Agency, Facts: Synthetic Turf, April 2007.
29
KEM, Swedish Chemicals Agency, Facts: Synthetic Turf, April 2007.
30
Turfgrass Resource Center, Facts About Artificial Turf and Natural Grass.
25
Page 5 of 13
Artificial Turf Fact Sheet, 9/9/07
softener to mask the odor of the artificial turf. 32 What is the final destination of
these chemicals and their implications for the environment and those coming into
contact with them while playing on the fields? More information is needed on this
subject as well.
Stormwater:
There is no indication that artificial turf drains more effectively for purposes of a
stormwater infiltration system than natural grass. In addition, infiltration systems are
designed to work with whatever surface coating they receive from natural grass to
porous paving. It should be noted that while generally there can be no assumed
benefit from an infiltration perspective of natural turf or artificial turf, there are
instances where schools have experienced problems with the drainage of their artificial
turf fields. 33
Natural grass provides a level of evapotranspiration, pulling water out of the soil and
subsurface and releasing it to the air, providing benefits in reducing the volume of
runoff that results from a site and/or needs to be addressed by other stormwater
management strategies. Artificial turf has no evapotranspiration capabilities.
Grass does provide a level of pollution filtering and therefore water quality protection
for nearby waterways. While this filtering may be limited in the case of turf grass;
such filtering is nonexistent with artificial turf.
Heat Island Effect – for Human Health and Surrounding communities:
Extreme heat is a health concern. Studies document that the surface temperature on
artificial turf is dramatically increased as compared to surrounding land uses including
asphalt.
In a 2002 study it was found that “the surface temperature of the synthetic turf was
37° F higher than asphalt and 86.5° F hotter than natural turf.” 34 A study published
in the Journal of Health and Physical Education and Recreation showed “surface
temperatures as much as 95 to 140 degrees Fahrenheit higher on synthetic turf than
natural turfgrass when exposed to sunlight.” 35 Random sampling at Brigham Young
University identified temperatures ranging from 117.38 to 157 degrees on artificial
turf while neighboring natural grass areas were in the range of 78.19 to 88.5 degrees
Fahrenheit. “Two inches below the synthetic turf surface was 28.5° F hotter than
Turfgrass Resource Center, Facts About Artificial Turf and Natural Grass.
Turfgrass Resource Center, Facts About Artificial Turf and Natural Grass.
33
Turfgrass Resource Center, Facts About Artificial Turf and Natural Grass.
34
Dr. C. Frank Williams and Dr. Gilbert E. Pulley, Synthetic Surface Heat Studies, Brigham Young
University.
35
SportsTurf Managers Association, A Guide to Synthetic and natural Turfgrass for Sports Fields,
Selection, Construction and Maintenance Considerations.
31
32
Page 6 of 13
Artificial Turf Fact Sheet, 9/9/07
natural turf at the surface.”36 And still another study comparing temperatures on
artificial turf temperatures with air temperature found that artificial turf ranged from
58 to 75 degrees hotter than measured air temperature.37 While irrigation provided
significant cooling for the synthetic turf (lowering the temperature from 174° F to
85° F) after only 5 minutes the temperature quickly rose again to 120°F; after 20
minutes it rose to 164°F.38
Concerns regarding the excessive temperatures range from the implications for
players who are already exerting themselves playing in such excessively high
temperatures, to the implications for burns when players or pedestrians come into
contact with the hot surfaces, to the implications for small children who may come
into contact with the extremely hot surfaces during non-sporting events. Particularly
when installed in already built up areas, what affect does the extreme heat associated
with artificial turf have on the surrounding community in terms of temperature?
Natural grass, by comparison, provides a natural cooling affect and helps to dissipate
heat from neighboring developed areas.39 “The temperature of natural grass rarely
rises above 85 degrees Fahrenheit, regardless of air temperature.” 40
The heat impacts of artificial turf need to be considered in the context of today’s
changing climate. Global climate change is expected to dramatically increase the
number of days over 100 degrees communities in our region experience. Depending
on how aggressively global warming gasses are reduced in coming years, communities
nearby Philadelphia will begin to experience in the range of 10 days (in lower emission
scenarios) to 30 days (if higher emission scenarios continue to prevail) over 100o.41
By later in this century seasonable temperatures are projected to rise 6oF to 14oF in
summer (depending again on emission reductions achieved in the future). 42
Educators and decisionmakers selecting artificial turf based on its long-term
viability and community impacts should consider the affect of global climate
change to magnify the heat impacts of artificial turf.
Dr. C. Frank Williams and Dr. Gilbert E. Pulley, Synthetic Surface Heat Studies, Brigham Young
University.
37
T. Sciacca, The Thermal Physics of Artificial Turf, January 2008.
38
Dr. C. Frank Williams and Dr. Gilbert E. Pulley, Synthetic Surface Heat Studies, Brigham Young
University.
39
James B. Beard & Robert L. Green, The Role of Turfgrasses in Environmental Protection and Their
Benefits to Humans, J. Environ Qual. 23:452-460 (1994).
40
SportsTurf Managers Association, A Guide to Synthetic and natural Turfgrass for Sports Fields,
Selection, Construction and Maintenance Considerations.
41
Union of Concerned Scientists, Confronting Climate Change in the U.S. Northeast l New Jersey,
2007.
42
Union of Concerned Scientists, Confronting Climate Change in the U.S. Northeast l New Jersey,
2007.
36
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Artificial Turf Fact Sheet, 9/9/07
Health Issues:
Direct human exposure to the hazardous substances contained in the rubber in-fill of
artificial turf is believed to occur via three pathways: inhalation, skin contact, or
ingestion including by children or infants who come into contact with the material.43
In October 2006 and January 2007, respectively, two sites in New York where
synthetic turf has been used (the large, 3 year old, Parade Ground in Brooklyn; the
relatively small 5 month old Sara D. Roosevelt Park in Manhattan) were analyzed. This
testing found PAHs at hazardous levels (as per New York standards) at each of the
sites. At both sites dibenzo (a.h)anthracene, a probable human carcinogen, was found
at hazardous levels, with two other PAH forms, both possible human carcinogens,
found at hazardous levels at the Parade Ground site. Research into the pathways by
which these substances may be absorbed into the bodies of children and athletes via
skin contact, ingestion or other pathways, is very limited with additional research
needed.44
A study by the California Office of Environmental Health Hazard Assessment (OEHHA)
summarized 46 studies that identified 49 chemicals which are released from tire
crumb. Of the 49, “seven of the chemicals leached from tire shreds were carcinogens.
OEHHA calculated a cancer risk of 1.2 in 10 million based on a one-time ingestion of
the tire crumb rubber over a lifetime.”45 While there are limited studies which assert
that recycled tire crumb are stable in the gastrointestinal tract and that therefore this
is not a pathway for exposure, there are other studies which contradict these
findings.46
Concerns have been raised about the potential implications of recycled tire in-fill for
individuals with latex allergies and that inhalation could result in a systemic response,
as opposed to a contact response.47
While, “the status of the information about human exposures to recycled tire crumb
rubber in-fill … is not sufficient to determine the safety of the use of the product in
situations that involve continuous episodes of human exposure;” 48 “the available
Environment & Human Health, Inc., Artificial Turf, Exposures to Ground-Up Rubber Tires, 2007.
Rachel’s’ Democracy & Health News #992, Hazardous Chemicals in Synthetic Turf, Follow-up
Analyses, April 12, 2007.
45
Environment & Human Health, Inc., Artificial Turf, Exposures to Ground-Up Rubber Tires, 2007 citing
California Office of Environmental Health Hazard Assessment (OEHHA), Evaluation of Health Effects of
Recycled Waste Tires in Playground and Track Products, January, 2007.
46
Environment & Human Health, Inc., Artificial Turf, Exposures to Ground-Up Rubber Tires, 2007.
47
Environment & Human Health, Inc., Artificial Turf, Exposures to Ground-Up Rubber Tires, 2007.
48
Environment & Human Health, Inc., Artificial Turf, Exposures to Ground-Up Rubber Tires, 2007.
43
44
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Artificial Turf Fact Sheet, 9/9/07
information is sufficient and strong enough to raise plausible questions with respect to
acute toxicity for susceptible persons, and for cancer risks.”49
There is great debate about whether artificial turf can increase exposure to, and
infection from, MRSA (methicillin-resistant staphylococcus aureus). Reports including
a December 21, 2007 article in the Bloomberg Press reporting the affliction of an 18
year old football player from MRSA as the result (according to the boy’s doctor) of an
abrasion he received from playing on artificial turf, and citing other findings linking
MRSA infections with artificial turf,50 are a great concern for parents and sports
players alike. Defenders of artificial turf often refer to studies like that of the Penn
State Department of Crop and Soil Sciences which finds that Staphylococcus aureus is
commonplace in the human environment, including on both artificial turf and natural
grass fields.51 But even this study acknowledges that there is no conclusive evidence
currently available that the source of bacteria causing the infections of sports players
is not artificial turf. In addition, the study does not consider the link between burns
sustained while playing on artificial turf and available bacteria as a pathway for
infection. New studies are emerging that demonstrate that turf burns may be
facilitating infection by acting as a pathway for infection.52 Study has found that turf
burns increased the risk of infection regardless of the type and timing of care
provided the burn. 53
Concussions (formally described as Mild Traumatic Brain Injury or MTBI) resulting from
sports has, according to the US Centers for Disease Control, reached “epidemic
proportions.”54 “’Mild’ head traumas, and especially a series of such minor
concussions can have long term, negative effects on cognitive function.” 55 Study has
documented that artificial turf increases the risk of MTBI over natural turf,
Environment & Human Health, Inc., Artificial Turf, Exposures to Ground-Up Rubber Tires, 2007.
Texas Football Succumbs to Virulent Staph Infection from Turf, December 21, 2007, Bloomberg
Press.
51
Penn State Department of Crop and Soil Sciences, A Survey of Microbial Populations in Infilled
Synthetic Turf Fields.
52
A High Morbidity Outbreak of Methicillin-Resistant Staphylococcus aureus among Players on a College
Football Team, Facilitated by Cosmetic Body Shaving and Turf Burns, study conducted 2004 for
Connecticut Dept of Public Health, Student Health Services of Sacred Heart Univ, Centers for Disease
Control and Prevention, Minnesota Dept of Public Health, Los Angeles County Dept of Health Svces; Dr.
S.V. Kazakova et.al., A Clone of Methicillin-Resistant Staphylococcus aureus among Professional Football
Players, The New England Journal of Medicine, Vol 352:468-475 No. 5, Feb. 3, 2005.
53
A High Morbidity Outbreak of Methicillin-Resistant Staphylococcus aureus among Players on a College
Football Team, Facilitated by Cosmetic Body Shaving and Turf Burns, study conducted 2004 for
Connecticut Dept of Public Health, Student Health Services of Sacred Heart Univ, Centers for Disease
Control and Prevention, Minnesota Dept of Public Health, Los Angeles County Dept of Health Svces.
54
Dr. M. Shorten, J.A. Himmelsbach, BioiMechanica, Sports Surfaces and the Risk of Traumatic Brain
Injury citing the US Centers for Disease Control.
55
Dr. M. Shorten, J.A. Himmelsbach, BioiMechanica, Sports Surfaces and the Risk of Traumatic Brain
Injury.
49
50
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Artificial Turf Fact Sheet, 9/9/07
approximately doubling that risk, as well as causing a greater degree of trauma.56
According to study, artificial turf presents a 5 times greater risk of the more severe
head injury than natural turf, although it is still unknown the particular characteristics
of the two surfaces that cause the difference in head injury incidence. 57
Costs:
It is generally agreed that artificial turf costs more to install than natural grass, while
natural grass costs more to maintain. Installation and maintenance costs for each
must be assessed on a case by case basis depending on site specific conditions. But
generally speaking, when the installation and maintenance costs of artificial turf are
assessed for the life span of the turf, particularly when the cost of disposal is added,
the cost of installing and maintaining natural grass is far less. The guaranteed life
and/or lifespan of artificial turf is 8 to 10 years.58 Some attempt to claim a longer life
in order to assert a lower annual cost.59 Comparative cost figures for artificial turf
and natural grass include:
Artificial Turf
Source: San Francisco
Rec and Parks 60
Installation
Annual Maintenance
Cost of Disposal
Average annual cost for
guaranteed life of 8 years.
Average annual cost for life
of 10 years
Average annual cost for life
of 15 years (maximum life
span seen asserted in the
Natural Grass
$800,000
$260,000
$6,000
Unknown but significant as a
hazardous waste
$106,000
$42,000
$0
$86,000
$68,000
$59,333
$59,333
$74,500
Dr. M. Shorten, J.A. Himmelsbach, BioiMechanica, Sports Surfaces and the Risk of Traumatic Brain
Injury.
56
Dr. M. Shorten, J.A. Himmelsbach, BioiMechanica, Sports Surfaces and the Risk of Traumatic Brain
Injury. See also K.M. Guskiewica, N.L. Weaver, D.A. Padua, W.E. Garrett Jr., Epidemiology of Concussion
in Collegiate and High School Football Players, Sep-Oct 2000 & Does the Use of Artificial Turf
Contribute to Head Injuries, The Journal of Trauma-Injury, Infection and Critical Care, Oct 2002 for the
finding that artificial turf increases the level of injury in comparison to natural grass fields.
58
Turfgrass Resource Center, Facts About Artificial Turf and Natural Grass.
59
San Francisco Recreation & Parks, Natural and Synthetic Turf: A Comparative Analysis, December 20,
2005.
60
San Francisco Recreation & Parks, Natural and Synthetic Turf: A Comparative Analysis, December 20,
2005.
57
Page 10 of 13
Artificial Turf Fact Sheet, 9/9/07
literature)
Source: Facts About
Artificial Turf and
Natural Grass 61
Cost of construction and
maintenance per sq. ft.
Cost of disposal per sq. ft.
Springfield College case
study installation and
maintenance average annual
cost during 8 year
guaranteed life of artificial
turf – no disposal costs
included
Source: A Guide to
Synthetic and Natural
Turfgrass for Sports
Fields. 62
Cost of installation per
square foot
Annual Maintenance
Disposal per square foot –
note this cost does not
include the cost of
transportation or landfill
$7.80 – $10.75
$1.75 - $2.25
$105,000
($800,000 install & annual
maintenance of $5,000)
For a 10 year life the figure
is $85,000;
for 15 years it is $58,377
$7.80 to $10.75
$5,000 to $25,000
$1.75 to $2.25
With high quality soil
amendments
$6.50 – $7.95
With native soils
$2.50 – $5.25
$0
$78,000
($400,000 install &
$28,000 annual
maintenance)
For a 10 year life the figure
is $68,000;
for 15 years it is $54,666
$2.50 to $5.25 if done with
native soils
$3.50 to $5.25 if done with
combination of native soils
and sand.
$6.50 to $7.95 if done with
sand and drainage
$4,000 to $11,000 as per
the case studies provided
$0
Turfgrass Resource Center, Facts About Artificial Turf and Natural Grass.
SportsTurf Managers Association, A Guide to Synthetic and natural Turfgrass for Sports Fields,
Selection, Construction and Maintenance Considerations. While the cost figures in this document focus
on the southeast, the figures provide a sound comparative for the relative cost figures provided.
61
62
Page 11 of 13
Artificial Turf Fact Sheet, 9/9/07
surcharges for
environmentally controlled
products
Artificial turf made from rubber contains a number of hazardous substances. As a
result disposal is neither easy nor cheap. It is important to identify and consider the
cost of disposal when considering an investment in artificial turf. The life expectancy
of artificial turf generally ranges from 8 to 10 years63 – therefore disposal of artificial
turf should be amortized over this time frame.
Miscellaneous:
Artificial Turf is available for use immediately upon installation. Natural Turf generally
requires 2 growing seasons before it should be heavily used.64
One of the biggest supporting assertions for artificial turf is the increased level of
playing time it provides. While natural grass may not equal artificial turf in playing
time, natural soil and grass science has progressed significantly, greatly increasing its
durability for sports. Modern natural grass sports fields include sand in their soil
profile to resist compaction and a combination of grass varieties. Natural grass is
becoming the preferred surface for a number of professional sports teams.
Natural grass fields require regular maintenance including, mowing and watering, and
may also result in the use of fertilizers and potentially herbicides. But there are less
environmentally harmful alternatives available for maintenance including electric
mowing equipment and environmentally sensitive lawn care strategies that do not rely
on environmentally harmful chemicals. A number of schools, including Radnor
Township, Delaware County, PA, have successful policies that prevent the use of
dangerous chemicals on school grounds.
Artificial turf also requires regular maintenance. Artificial turf maintenance includes
sweeping, dragging and watering to provide a clean and uniform appearance.65 In
addition, as the result of wear, the infill may need periodic replenishment. 66
Management of an artificial turf field requires special knowledge inseam repair and
snow removal. 67 Special solvents and cleansers are needed to remove tough debris. 68
Turfgrass Resource Center, Facts About Artificial Turf and Natural Grass.
Communication with Nancy Bosold, Extension Educator, Turfgrass Management, Penn Stat
Cooperative Extension, Berks County, Aug 15, 2007.
65
SportsTurf Managers Association, A Guide to Synthetic and natural Turfgrass for Sports Fields,
Selection, Construction and Maintenance Considerations.
66
SportsTurf Managers Association, A Guide to Synthetic and natural Turfgrass for Sports Fields,
Selection, Construction and Maintenance Considerations.
67
SportsTurf Managers Association, A Guide to Synthetic and natural Turfgrass for Sports Fields,
Selection, Construction and Maintenance Considerations.
63
64
Page 12 of 13
Artificial Turf Fact Sheet, 9/9/07
Artificial turf is at risk of damage from plastic bottles, cigarettes and/or gum as well
as general trash thrown on the field. When damaged special repairs may be needed.
Artificial turf also becomes a recipient of a variety of bodily fluids which cannot be
cleansed by natural action as is the case with natural grass. Maintenance can include
application of algaecides and fabric softener to mask the odor of the artificial turf. 69
Artificial turf systems that claim chemical treatment is not required do not seem to
provide a mechanism for handling the germs associated with the bodily fluids on the
turf when there is an absence of rain or when it is captured and reused in newly
emerging artificial turf cooling systems.
It is important to note that the environmental, health and safety impacts
of artificial turf are in need of further study by independent experts.
Until such time as there are conclusive findings regarding the
environmental, health and safety impacts of artificial turf the
Precautionary Principle would direct decisionmakers away from artificial
turf and towards the traditional use of natural grass for sports and public
play fields.
Updated: February 25, 2008
Dated: September 9, 2007
SportsTurf Managers Association, A Guide to Synthetic and natural Turfgrass for Sports Fields,
Selection, Construction and Maintenance Considerations.
69
Turfgrass Resource Center, Facts About Artificial Turf and Natural Grass.
68
Page 13 of 13
Artificial Turf Fact Sheet, 9/9/07
Artificial
Turf
Fact
Sheet
Temporary
Addendum.
Chrysene,
a
PAH
and
carcinogen,
was
found
to
be
ingested
as
the
result
of
hand-‐to-‐surface-‐to-‐mouth
transfer
from
playground
surfaces
made
with
recycled
tires.
Assuming
playground
use
for
an
11
year
period
(from
age
1
to
12)
there
was
found
to
be
an
increased
cancer
risk
of
2.9
in
one
million
(2.9
X
10-‐6).
This
risk
is
greater
than
the
general
cancer
risk
gauge
of
one
in
one
million
(1X10-‐6).1
This
research
would
seem
to
suggest
that
repeat
exposure
over
time
to
the
chemicals
released
from
artificial
turf
increases
the
associated
increase
in
cancer
risk.
Only
31%
of
the
playground
surfaces
made
of
recycled
tires
tested
in
one
research
study
passed
the
California
State
mandated
Head
Impact
Criterion
(HIC)
of
<1,000.
In
this
same
study
100%
of
the
playground
surfaces
made
of
wood
chips
passed
the
same
standard.
2
When
talking
about
the
use
of
ground
rubber
as
a
supplement
to
planting
soils
the
North
Carolina
Department
of
Agriculture
and
Consumer
Services
sent
out
a
notice
identifying
the
risk
that
zinc
leaching
from
the
rubber
causes
a
decline
in
plant
growth
“directly
attributable
to
zinc
toxicity.”3
A
Case
Study
conducted
by
a
group
of
“physicians
and
public
health
professionals
working
with
the
U.S.
Environmental
Protection
Agency’s
Region
Pediatric
Environmental
Health
Specialty
Unit”
found
that
they
could
not
secure
the
research
and
information
necessary
to
establish
the
safety
in
use
with
Office of Environmental Health Hazard Assessment, Evaluation of Health Effects of Recycled Waste
Tires in Playground and Track Products, January 2007.
Note
-‐-‐
the
1.2
in
10
million
cancer
risk
found
in
the
OEHHA
study
was
considered
by
the
authors
to
be
an
acceptable
level
of
risk
as
it
falls
below
the
general
cancer
risk
gauge
-‐6
of
one
in
one
million
(1X10 ).
2
Office of Environmental Health Hazard Assessment, Evaluation of Health Effects of Recycled Waste
Tires in Playground and Track Products, January 2007. Please note that in this study 32 recycled tire
playground surfaces were tested as compared to only 5 wood chip playground surfaces.
3
M. Ray Tucker, Agronomist, Ground Rubber: Potential Toxicity to Plants, Media Notes for North
Carolina Growers, North Carolina Dept of Agriculture & Consumer Services, April 1997.
1
children
of
tire
crumb
used
as
playground
surface.4
“The
use
of
recycled
tire
crumb
products
on
playgrounds
has
had
little
health
investigation.
The
major
unresolved
concern
is
the
potential
for
latex
allergy
with
short-‐term
dermal
exposure.”
5
“No
published
information
is
available
specifically
regarding
exposure
to
crumb
rubber
constituents
from
use
of
the
product
on
playgrounds.”
6
Analyses
conducted
at
the
Environmental
and
Occupational
Health
Sciences
Institute
of
Rutgers
University
found
the
crumb
rubber
from
artificial
turf
to
contain
high
levels
of
PAHs,
as
well
as
zinc
and
arsenic.7
PAHs
found
to
be
contained
in
the
crumb
rubber
“were
above
the
concentration
levels
that
the
New
York
State
Department
of
Environmental
Conservation
(DEC)
considers
sufficiently
hazardous
to
public
health
to
require
their
removal
from
contaminated
soil
sites.
It
is
highly
likely
that
all
six
PAHs
are
carcinogenic
to
humans.”
8
“The
analyses
also
revealed
levels
of
zinc
in
both
samples
that
exceed
the
DEC's
tolerable
levels.”
9
The
researchers
associated
with
these
findings
were
careful
to
state
“We
want
to
emphasize
that
the
findings
are
preliminary.
PAHs
in
rubber
might
not
act
the
same
way
as
in
soil,
and
we
do
not
yet
have
information
on
the
ease
with
which
the
PAHs
in
these
rubber
particles
might
be
absorbed
by
children
or
adults
-‐-‐
by
ingestion,
inhalation,
or
absorption
through
the
skin.
However,
the
findings
are
worrisome.
Until
more
is
known,
it
wouldn't
be
prudent
to
install
the
synthetic
turf
in
any
more
parks.”
10
M.E. Anderson et al, A Case Study of tire Crumb Use on Playgrounds: Risk Analysis and
Communication When Major Clinical Knowledge Gaps Exist, Environmental Health Perspectives, Vol 114,
No. 1, January 2006.
5
M.E. Anderson et al, A Case Study of tire Crumb Use on Playgrounds: Risk Analysis and
Communication When Major Clinical Knowledge Gaps Exist, Environmental Health Perspectives, Vol 114,
No. 1, January 2006.
6
M.E. Anderson et al, A Case Study of tire Crumb Use on Playgrounds: Risk Analysis and
Communication When Major Clinical Knowledge Gaps Exist, Environmental Health Perspectives, Vol 114,
No. 1, January 2006.
7
Junfeng Zhang, professor and acting chair, Department of Environmental and Occupational Health,
the School of Public Health, the University of Medicine and Dentistry of New Jersey and Rutgers
University & William Crain, professor of psychology at The City College of New York, president of
Citizens for a Green Riverside Park, Hazardous Chemicals in Synthetic Turf, 2006, analyses conducted
at at the Environmental and Occupational Health Sciences Institute of Rutgers.
8
Junfeng Zhang, professor and acting chair, Department of Environmental and Occupational Health,
the School of Public Health, the University of Medicine and Dentistry of New Jersey and Rutgers
University & William Crain, professor of psychology at The City College of New York, president of
Citizens for a Green Riverside Park, Hazardous Chemicals in Synthetic Turf, 2006, analyses conducted
at at the Environmental and Occupational Health Sciences Institute of Rutgers.
9
Junfeng Zhang, professor and acting chair, Department of Environmental and Occupational Health,
the School of Public Health, the University of Medicine and Dentistry of New Jersey and Rutgers
University & William Crain, professor of psychology at The City College of New York, president of
Citizens for a Green Riverside Park, Hazardous Chemicals in Synthetic Turf, 2006, analyses conducted
at at the Environmental and Occupational Health Sciences Institute of Rutgers.
10
Junfeng Zhang, professor and acting chair, Department of Environmental and Occupational Health,
the School of Public Health, the University of Medicine and Dentistry of New Jersey and Rutgers
University & William Crain, professor of psychology at The City College of New York, president of
Citizens for a Green Riverside Park, Hazardous Chemicals in Synthetic Turf, 2006, analyses conducted
at at the Environmental and Occupational Health Sciences Institute of Rutgers.
4
Connecticut
is
currently
considering
legislation
to
provide
$250,000
of
funding
for
a
study
into
the
toxicity
of
artificial
turf
athletic
fields.11
One
Norwegian
assessment/presentationconcluded
that
while
indoor
artificial
turf
fields
were
not
generally
an
elevated
health
risk,
studies
to
date
could
not
eliminate
the
concerns
associated
with
development
of
airway
allergies
and
made
a
point
of
noting
“a
link
between
exposure
to
phthalates
and
the
development
of
asthma/allergies”.
12
Phthalates
is
one
of
the
contaminants
of
concern
found
in
artificial
turf
crumb
rubber.
13
The
Norwegian
assessment/presentation
also
reported
that
“recycled
rubber
was
the
major
source
of
potentially
hazardous
substances.
An
exposure
scenario
where
the
runoff
from
a
football
field
is
drained
to
a
small
creek
showed
a
positive
risk
of
toxic
effects
on
biota
in
the
water
phase
and
in
the
sediment.
The
risk
was
mainly
attributed
to
zinc,
but
also
for
octylphenol
the
predicted
environmental
concentrations
exceeded
the
no
environmental
effect
concentration.”
14
The
hazardous
leaching
could
result
in
local
environmental
effect.15
Of
interest
–
William
Carin,
OpEd,
NY
Times,
Turf
Wars,
September
16,
2007.
An Act Concerning a Study of the Toxicity of Artificial Turf Athletic Fields, Raised Bill No. 361,
February Session 2008.
12
Dr. Christine Bjorge, Norwegian Institute of Public Health, Artificial turf Pitches – an assessment of
the health risks for football players and the environment, Presentation at the ISSS Technical meeting
2006, Dresden.
13
KEM, Swedish Chemicals Agency, Facts: Synthetic Turf, April 2007.
14
Dr. Christine Bjorge, Norwegian Institute of Public Health, Artificial turf Pitches – an assessment of
the health risks for football players and the environment, Presentation at the ISSS Technical meeting
2006, Dresden.
15
Dr. Christine Bjorge, Norwegian Institute of Public Health, Artificial turf Pitches – an assessment of
the health risks for football players and the environment, Presentation at the ISSS Technical meeting
2006, Dresden.
11
Page 1 of 2
PUBLIC SUBMISSION
As of: 5/3/16 6:20 PM
Received: May 02, 2016
Status: Posted
Posted: May 02, 2016
Tracking No. 1k0-8pe9-yfcg
Comments Due: May 02, 2016
Submission Type: Web
Docket: ATSDR-2016-0002
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill 0923-16PJ
Comment On: ATSDR-2016-0002-0003
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill ATSDR-2016-0002
Document: ATSDR-2016-0002-0047
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill 0923-16PJ Comment on
FR Doc # 2016-03305
Submitter Information
Name: Nicholas Baker
Address: 91411
Email: nicholasbaker@alum.calarts.edu
General Comment
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill
Docket # ATSDR-2016-0002
Thank you. I appreciate the ability to comment. For more than a decade our government has
permitted tire waste, a material that is considered to be so toxic that it'
not allowed in landfills, to be shredded and placed on athletic fields, kids play areas, gardens,
driveways and other
recreational areas.
We know from numerous credible studies, that tires contain carbon black, benzene, arsenic,
mercury, hydrocarbons,
and heavy metals, that have been linked to cancer. We know when people are playing sports on
these fields, it's common
for these materials to be swallowed, caught in ears, nose, clothing, hair, under skin, and in floor
or seats of cars, showers,
tubs, etc.
Tire crumb and it's by products are harmful to our environment, water. soil, and our eco-system.
Anecdotal evidence of
https://www.fdms.gov/fdms/getcontent?objectId=0900006481f9db69&format=xml&showor... 5/3/2016
Page 2 of 2
hundreds of individuals who have played on fields using this material, who have died or
become seriously ill should be enough
to stop the use of these materials once and for all. If your studies will move this toxic material
out of areas where harm
can occur, then please let's move forward quickly. In the meantime, stopping any further fields
from using this material should
be mandated .
Sincerely,
Nicholas Baker
https://www.fdms.gov/fdms/getcontent?objectId=0900006481f9db69&format=xml&showor... 5/3/2016
Page 1 of 1
PUBLIC SUBMISSION
As of: 5/3/16 6:28 PM
Received: May 02, 2016
Status: Posted
Posted: May 03, 2016
Tracking No. 1k0-8pef-4vnd
Comments Due: May 02, 2016
Submission Type: Web
Docket: ATSDR-2016-0002
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill 0923-16PJ
Comment On: ATSDR-2016-0002-0003
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill ATSDR-2016-0002
Document: ATSDR-2016-0002-0059
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill 0923-16PJ Comment on
FR Doc # 2016-03305
Submitter Information
Name: Jeff Ruch
Address: 20910
Email: jruch@peer.org
Organization: PEER
General Comment
See attached
Attachments
5-2-16_PEER Comments _Federal Artificial Turf Research Action Plan
https://www.fdms.gov/fdms/getcontent?objectId=0900006481f9ff86&format=xml&showori... 5/3/2016
Comments on
Federal Research Action Plan on Recycled Tire Crumbs Used on
Playing Fields and Playgrounds
Submitted by
Public Employees for Environmental Responsibility (PEER)
May 2, 2016
Introduction
Many parents have remarked on their children looking like “coal-miners” after playing in tire
crumb on playgrounds or fields, , and that their white soccer balls quickly turn dark gray to
black as they roll on these artificial surfaces, in contrast to the green chlorophyll stains from
playing on grass.
Yet, there is poor official understanding of what exactly is in the tacky fine tire-derived material
coming off the tire crumb playgrounds and fields sticking to objects and children alike and the
possible short and long term impacts on human health.
There can be no disagreement, and indeed government and independent experts and the industry
concede, that there are a litany of substances in tire crumb and plastics, many of which are
known to be harmful to various body systems (e.g. as carcinogens, hormone disruptors,
neurotoxins, inflammatory irritants etc)and most of the rest have not been tested. There remains
an array of unknowns about the effects on children being in direct contact – some for hours a day
and in a variety of conditions – with shredded tire pellets containing known toxic substances
such as but not limited to lead, arsenic, cadmium, chromium, mercury, carbon black,
benzothiazoles and a number of dangerous hydrocarbons.
Public Employees for Environmental Responsibility (PEER) is submitting the following
comments on the proposed multi-agency federal study into the human health and eco-impacts of
widespread use of shredded tires in playgrounds and sports fields:
I. Research Action Plan Is Poorly Designed and Will Raise More Questions than It
Answers
Announced in February to address to growing public concerns “about the safety of recycled tire
crumb used in playing fields and playgrounds in the United States,” the Obama administration
directed the U.S. Environmental Protection Agency (EPA), the Centers for Disease Control and
Prevention/Agency for Toxic Substances and Disease Registry, and the Consumer Product
Safety Commission (CPSC) to undertake a “coordinated Federal Research Action Plan.” That
plan, however, will not produce definitive guidance as it is geared to diagnose the array of “data
and knowledge gaps” including what precise mix of chemicals is in “recycled tire crumb” and
the potential pathways for human exposure.
The very preliminary nature of this initiative, however, may delay rather than hasten public
health safeguards, especially for very young children spending hours a day on turf playgrounds
and sports fields:
There will be no moratorium on building new tire crumb fields while the research
continues. Nor will parents be given warnings about the potential risks already identified;
Even for the chemical exposures identified previously or through these studies, there are
no longitudinal studies proposed to learn the effects of long-term exposure, especially to
children. Instead, toxicity reviews will be confined to “existing databases” which are few
and seriously incomplete at best. As a result, the key question of what level of childhood
exposure should be of concern will be left largely unexamined; and
Some of the plan’s elements are an utter waste of resources, such as CPSC being tasked
with “exploring conducting a survey of parents to get first hand perspectives on potential
exposures from playground surface materials.” The Consumer Product Safety
Commission does not need a survey to know that children come into intimate contact
with playground surfaces and play with any loose shredded or granular surface by
building with it, pouring it over each other, burying each other in it and sometimes
ingesting it in the process.
II. There Should Be a Focus on Lead
The scattered design of this effort threatens to deflect attention away from several already
identified toxic substances. One of the most obvious of immediate concern is lead – one of the
most harmful neurotoxic substances for children often but irregularly and unpredictably found in
both tire crumb and plastic components of synthetic turf systems.
As CDC’s National Center for Environmental Health warns:
“Reducing children’s exposure to lead is one of the greatest environmental health
accomplishments in the past 20 years. However, there is no safe level of lead, and
children are still being exposed to lead and other environmental hazards.” 1
Moreover, there is no identified safe blood lead level in children. Lead exposure can affect
nearly every system in the body. The effects are especially insidious because lead exposure often
occurs with no obvious symptoms, it frequently goes unrecognized.2
1
Healthy Homes/Lead Poisoning Prevention Program CDC 24/7: Saving Lives. Protecting People from Health
Threats http://www.cdc.gov/nceh/information/healthy_homes_lead.htm
2
http://www.cdc.gov/nceh/lead/ and http://www.cdc.gov/nceh/information/healthy_homes_lead.htm
Lead has been identified in synthetic turf fields as early as 2008 but was not addressed in any
systemic way due to lack of standards or required testing (although the CPSC could have
required the testing mandated for children's products since 2008 under the Children’s Product
Safety Improvement Act (CPSIA).
In fact, the CPSC tested synthetic turf carpets and found lead at varying levels depending on
sample age, but then, astoundingly, concluded the whole synthetic turf system was always and
everywhere safe for children, based on inappropriate modelling rooted in two incorrect
presuppositions: 1) that there is a safe level of blood lead for children; and 2) ingestion is the
only mode of exposure, which it is not since inhalation and dermal exposure are obvious routes
as well.3
To this day the synthetic turf industry cites the still CPSC-posted “OK to Install, OK to Play On”
press release4 which has been disavowed, in front of Congress, by CPSC Commissioner Kaye.5
A 2012 study on artificial turf done for the New Jersey Department of Environmental Protection
found artificial fields made of tire crumb can contain highly elevated levels of lead much greater
than the allowed levels for children, noting “concerns with regard to potential hazards that may
exist for individuals and in particular children who engage in sports activities on artificial fields”;
and that “Inhalable lead present in artificial turf fields can be resuspended by even minimal
activity on the playing surface.”6
Scientists from Rutgers recently participated in a study which found lead and other toxins in the
both the plastic rug (supplied by the industry) and tire crumb infill. Lead was also was found in
simulated body fluids meaning there is little or no protection of any kind against the lead getting
out of the material into the body:
“Since it is possible that children may be exposed to potentially high concentrations of
lead while using artificial turf fields we recommend, at a minimum, all infill and fibers
should be certified for low or no lead content prior to purchase and installation.”7
The study also found lead and chromium in both the tire crumb and the plastic rug and simulated
body fluids at sometimes extremely high levels even in new field carpets:
“Lead was detected in almost all field samples for digestive, sweat, and total extraction
fluids with digestive fluid extract of one field sample as high as 260 mg/kg. Metal
concentrations were not markedly different across the three different sample types (new
infill, new turf fiber, tire crumb field sample). However, one of the ‘new’ turf fiber
3
http://www.peer.org/assets/docs/epa/3_21_13_CPSC_Complaint.pdf
http://www.cpsc.gov/en/Newsroom/News-Releases/2008/CPSC-Staff-Finds-Synthetic-Turf-Fields-OK-to-InstallOK-to-Play-On
5
https://www.youtube.com/watch?v=7crcxR8aYjo
6
http://www.nj.gov/dep/dsr/publications/artificial-turf-report.pdf
7
“Bio-accessibility and Risk of Exposure to Metals and SVOCs in Artificial Turf Field Fill Materials and Fibers”
2014 Brian T. Pavilonis1,Clifford P. Weisel1, Brian Buckley1, and Paul J. Lioy
http://www.ncbi.nlm.nih.gov/pmc/articles/PMC4038666/pdf/nihms565643.pdf
4
samples contained relatively large concentrations of chromium (820 mg/kg) and lead
(4400 mg/kg) compared to the other samples tested… [The] variability of lead contained
in the infill material is large and can span more than two orders of magnitude. One field
[tire crumb] sample did contain a high lead level (260 mg/kg) which was on the same
order of magnitude as the NJ DEP cleanup value (400 mg/kg).”
In evaluating and regulating lead in synthetic turf, the Division of Health Assessment and
Consultation of the Agency for Toxic Substances and Disease Registry concluded that:
“Synthetic turf can deteriorate to form dust containing lead at levels that may pose a risk
to children. Given elevated lead levels in turf and dust on recreational fields and in child
care settings, it is imperative that a consistent, nationwide approach for sampling,
assessment, and action be developed. In the absence of a standardized approach, we offer
an interim approach to assess potential lead hazards when evaluating synthetic turf.”8
But no such approach has ever been instituted. Indeed, as reported in USA Today in 2015:
“The CDC in 2008 said communities should test recreational areas with turf fibers made
from nylon, and they should bar children younger than 6 from the areas if the lead level
exceeded the federal limit for lead in soil in children's play areas. But some communities
have refused to test their fields, fearing that a high lead level would generate lawsuits or
force them to replace and remove a field, which costs about $1 million, according to a
2011 New Jersey state report. Forty-five of 50 New Jersey schools and towns contacted
in 2009 by epidemiologist Stuart Shalat would not let him test their turf-and-rubber
fields, Shalat's report states. The EPA also found, in 2009, that ‘it was difficult to obtain
access and permission to sample at playgrounds and synthetic turf fields.’”9
Industry also admits that its products contain lead. In testimony before the Maryland State
House, a representative of the company FieldTurf when asked point-blank by one delegate:
“Is there lead in your products?” The company executive answered,
“There’s lead in a lot of things in this world…Yes, there’s lead in our products.”10
Both old and new fields keep showing up with lead in them when tested. But the distribution is
not homogeneous and is unpredictable with demonstrated high level content hotspots which
could evade representative sampling. Some tested fields have little or no lead, while some have
high levels and some fields have both high and low levels within the same field (both carpet and
tire crumb infill). There is no way of knowing if any of the components of a given field contain
lead, and how much, without stringent and thorough testing of each field. Unfortunately for the
children, fields with high lead remain in use. However, no one is monitoring, let alone
regulating, artificial turf for lead or other toxins in either old or new fields.
8
Van Ulirsch et al (Environmental Health Perspectives. 2010 Oct;118(10):13459 http://www.ncbi.nlm.nih.gov/pubmed/20884393
9
http://www.usatoday.com/story/news/2015/03/15/artificial-turf-health-safety-studies/24727111/
10
http://wtop.com/montgomery-county/2016/03/md-lawmakers-seem-information-artificial-turf-schools/
In short, the priority for any federal efforts should be to ensure that all playing surfaces for
children are lead-free. The CDC has repeatedly stressed that every effort should be made to
eliminate all unnecessary sources of lead in the environment, especially a child's environment.
Lead in artificial turf is not only totally unnecessary but dangerous to health at any level.
III. Federal Action Plan Should Be Tied to Some Action
No matter how hazardous, artificial turf is essentially unregulated. Under a revised rule of the
Resource Conservation and Recovery Act (RCRA), recycling of hazardous waste may be
considered “legitimate” and therefore exempt from RCRA requirements, even if the end product
it creates is more toxic than other similar products on the market. This applies even where the
end-product is used by children. According to EPA:
“If a hazardous secondary material has been reclaimed and made into a product that will
be used by children, and that product contains hazardous constituents that are not in
analogous products, that product will likely need to be closely scrutinized.”11
Therefore, the EPA does not prohibit the unnecessary incorporation of hazardous constituents
into these products, or even guarantee close scrutiny of this recycling even when children are
involved. Thus, manufacturers that use hazardous wastes to make products for children are no
longer subject to RCRA safety requirements.
To fill this void in public health safeguards, PEER makes three recommendations:
1. The three participating agencies should issue a joint public statement urging that tirecrumb not be installed as play surfaces for children under age 13 until a thorough risk
assessment and analysis of toxic pathways has been completed.
2. The CPSC should declare playgrounds and sports fields in elementary schools to be a
children’s product.
Spurred by outrage over importation of toxic Chinese-made toys, in 2008 Congress mandated
safeguards for children’s products by imposing a lead content limit of 100 parts per million and
third-party testing to ensure compliance. Playgrounds made with shredded tires, however,
generally exceed this lead limit. In fact, the only test the CPSC ever conducted found nearly half
of the fields that it sampled contained lead in amounts more than three times this legal limit (and
they did not test tire crumb infill but only carpets).
In 2012, the Commission declined to classify crumb rubber playgrounds and elementary school
sports fields as a children’s product in response to a PEER request saying that it needed evidence
of promotion and marketing directed at children. In 2013, PEER submitted evidence of
companies like TotTurf and KidWise Outdoor Products marketing products under names such as
PlaySafer and Play Tuff Tiles using sales slogans declaring “softer on little knees” and “keep
kids safe.”12
11
12
http://www.epa.gov/oecaerth/cleanup/rcra/index.html
http://www.peer.org/news/news-releases/move-to-make-synthetic-playgrounds-lead-free.html
In response to this submission, on September 27, 2013 the CPSC informed PEER that it had
tasked its Office of Compliance and Field Operations with a “review and determination of
whether any enforcement action is appropriate.”13 A year later PEER inquired and ultimately
submitted a formal request under the Freedom of Information Act to find out the outcome of this
review. The Commission declined to reply and PEER filed a lawsuit in federal district court to
compel the answer.
That lawsuit ultimately produced documents that that the CPSC had decided not to enforce toxic
lead limits required by law for children’s products in artificial turf playgrounds. On July 20,
2015, CPSC sent a letter to U.S. Senator Elizabeth Warren (D-MA) which contained the
following statement:
“Upon further exploration, Compliance staff concluded, at that time, specific product
enforcement was unlikely to be the best option, based upon the need for individual health
assessments, among other factors. To my knowledge, this information has also been
communicated to PEER.”14
This statement is curious in several respects, beyond that this decision was never shared with
PEER:
The children’s product enforcement route does not require a health assessment. It only
requires a test for lead content – a test which is supposed to be done by the manufacturer;
In response to the PEER Freedom of Information Act lawsuit and a subsequent FOIA
about the basis for the letter to Senator Warren, the CPSC has not been able to locate any
paper trail documenting this decision. A request for clarification received no written
answer. Another email suggests the decision was never reduced to writing; and
If enforcement was not “the best option,” CPSC cannot identify what other options it
examined.
In short, this federal research action plan is proposed solely because the CPSC has abdicated its
legal duty to protect children on playgrounds from chemical exposure.
3. Standardize and monitor ingredients used in artificial fields.
There should be stringent testing of all the colors and of the backing of the carpet for total lead
content (chromium and cadmium should also be tested for) as well as testing of many samples of
the infill.
These products contain an ever-changing “witches brew” of chemicals with wide variations even
in the same field.- so undetectable, low and very high levels can all be found in the same field.
Since there is not standardization, monitoring or regulation of the source material, there is no
way that any study or combination of studies, including the ones proposed, can identify with
certainty just what people are being exposed to on these fields from one field to another or even
13
14
http://www.peer.org/assets/docs/cpsc/11_12_13_CPSC_child_product_referral.pdf
http://www.peer.org/news/news-releases/cpsc-drops-artificial-turf-playground-safety-review.html
within a given field. Certainly any assurance of health safety can never be made given the
knowledge of definite toxins present and the sheer magnitude of the unknowns.
At the same time, there is a lack of Material Safety Data Sheets (MSDS) for the source material
i.e., the tires themselves.
A single company MSDS is an anomaly and indeed its partial list of ingredients raises many red
flags. Most tire companies have asserted they do not need to file MSDS, stating:
“Tires meet the definition of article as defined by the OSHA Hazard Communication
Standard (29 CFR 190.1200) and are exempt from MSDS requirements.”
This ingredient labeling is even more important since pulverizing of the material makes all the
ingredients exponentially more available to interact with and affect living things including
people the smaller the pieces get.
In summary, the federal research action plan is inadequate and must be tied to some actions,
including immediate actions available to CPSC, if it is to do any good.
###
Page 1 of 1
PUBLIC SUBMISSION
As of: 5/3/16 6:32 PM
Received: May 02, 2016
Status: Posted
Posted: May 03, 2016
Tracking No. 1k0-8pej-7832
Comments Due: May 02, 2016
Submission Type: Web
Docket: ATSDR-2016-0002
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill 0923-16PJ
Comment On: ATSDR-2016-0002-0003
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill ATSDR-2016-0002
Document: ATSDR-2016-0002-0064
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill 0923-16PJ Comment on
FR Doc # 2016-03305
Submitter Information
Name: Elliot Belilos
Organization: SFA, RRC, ISRI and STC
General Comment
Comments of (1) The Safe Fields Alliance, (2) The Recycled Rubber Council, (3) The Synthetic
Turf Council, and
(4) The Institute of Scrap Recycling Industries, Inc.
Attachments
STC-SFA-RRC-ISRI Final Comments on FRAP 5-2-16
https://www.fdms.gov/fdms/getcontent?objectId=0900006481fa103f&format=xml&showor... 5/3/2016
May 2, 2016
Mr. Leroy A. Richardson
Information Collection Review Office
Centers for Disease Control and Prevention
1600 Clifton Road, N.E., MS-D74
Atlanta, Georgia 30329
Re:
Information Collection Related to Synthetic Turf Fields with Crumb Rubber Infill – Agency for
Toxic Substances and Disease Registry – ATSDR-2016-0002
The undersigned organizations provide these comments in response to the notice requesting public
comment on “Collections Related to Synthetic Turf Fields with Crumb Rubber Infill.” Specifically, the
notice seeks input on proposed and/or continued information collections that will assist the Agency for
Toxic Substances and Disease Registry (“ATSDR”) within the Centers for Disease Control and
Prevention (“CDC”) and the Environmental Protection Agency (“EPA”) to “conduct two studies to
investigate the chemical composition and use of crumb rubber infill in synthetic turf and the potential for
exposure to environmental constituents that may result from contact with crumb rubber infill.” Although
the information collection request does not specifically reference the Federal Research Action Plan on
Recycled Tire Crumb Used on Playing Fields (“FRAP”), the notice does request information intended to
implement the plan, specifically including comments on the necessity of the proposed collection and ways
to enhance the quality, utility and clarity of the collected information. The FRAP provides an overview of
the research to be conducted by ATSDR, the EPA and the U.S. Consumer Product Safety Commission
(“CPSC”).
We support the research efforts to the extent they are based on sound science and produce
meaningful results upon which users of playing fields and playgrounds with recycled rubber can properly
assess the risks relative to natural grass fields. To that end, we urge that the FRAP (1) carefully consider
current research related to the safety of crumb rubber (properly weighing the value of both peer-reviewed
and non-peer-reviewed research); (2) account for ambient sources of any identified chemicals, by
including control samples of air and natural grass/dirt fields near each synthetic turf field and playground
sampled; (3) report any chemicals identified only in proper context with relation to health-based
guidelines.
The Undersigned Commenters
The Synthetic Turf Council (STC) is an industry association formed in 2003 and made up of 212
members that range from large textile manufacturers, to builders and installers, to independent
professionals such as architects and engineers. The Safe Fields Alliance (SFA) is composed of three of
the largest synthetic sports field businesses in America: FieldTurf, Astroturf, and Sprinturf. The Recycled
Rubber Council (RRC) is made up of companies directly involved in recycling rubber, including that used
in making the infill for synthetic turf fields. The Institute of Scrap Recycling Industries, Inc. (ISRI) is a
1
trade association representing more than 1,600 companies operating at more than 3,500 facilities in the
United States and 34 countries worldwide.
The FRAP Must Carefully Consider Available Research and Ongoing Research.
There are more than 90 studies and reports over the past two decades conducted by independent
bodies, including academic institutions and government agencies over multiple continents. These studies
and reports cover more than 125 fields with different life spans. They investigate toxicity, bioavailability,
and multiple exposure pathways, and include consideration of potential chronic health effects.
Many of these studies have been peer reviewed. All studies that used accepted methodologies to
evaluate exposure or risk indicated no elevated risk of health effects compared with natural grass fields.
While we are aware of one or two published studies (and a few unpublished reports sponsored by
advocacy groups) that allege significant health risks associated with recycled rubber, those studies are
generally chemical composition studies utilizing total extraction methods and provide no information
related to actual chemical exposure or risk. The FRAP must not allow such reports to marginalize the
significant body of published credible scientific data.
In addition to the existing published research, we urge the FRAP to consider ongoing independent
research like that which is currently underway at Brown University. The in-vitro toxicology studies being
conducted at Brown University are attempting to determine whether exposure to crumb rubber can
transform human cells and thus be a precursor to cancer. In fact, this research specifically addresses the
concerns that California OEHHA both has recognized and requested that the National Toxicology
Program (“NTP”) consider conducting.1
The FRAP Must Include Adequate Scientific Controls in its Sampling Methodology.
Any sampling of recycled rubber from playing fields and playgrounds must be accompanied with
parallel sampling from nearby soil from grass fields as well to provide proper scientific controls. In
addition, air sampling must be conducted with appropriate upwind and downwind controls. However, it
is our understanding that appropriate natural soil control samples are not being contemplated by the
FRAP. Sampling controls are important for three reasons.
First, sampling controls would allow the Agencies to identify potential outside sources of
chemicals found in the test results. For example, if a chemical of concern were found in both the recycled
rubber and the surrounding soil, it could potentially be from sources such as a nearby parking lot or other
potential outside exposure points. Failure to utilize sampling controls will compromise the reliability and
relevance of uncontrolled findings.
A second reason to apply scientific controls in the sampling is to provide a reference point. Users
of synthetic turf sports fields and playgrounds need to be provided the information in context. For
example, if a chemical of concern is one that is naturally occurring and is present in soil or grass fields at
comparable or higher levels than is found in synthetic turf fields, consumers need to have that useful
1
The letter can be found here: http://oehha.ca.gov/risk/SyntheticTurfStudies/pdf/OEHHA_NTP110915.pdf
2
information. Failing to provide the information in proper context would be a disservice to the owners and
users of the playing fields and playgrounds. While the stated mission of the FRAP is limited to
identifying potential health risks associated with recycled rubber infill, that mission cannot be fulfilled in
a meaningful way without providing the public information upon which they can determine the risks and
the benefits of both natural fields and synthetic fields.
Finally, failing to utilize adequate sampling controls will call into question the validity of the
results of the federal research. We note that California OEHHA staff had initially not included control
soil sampling in its research, but is reconsidering that position based on comments at a recent Public
Meeting of its Synthetic Turf Scientific Advisory Panel (Feb. 8, 2016). See
http://oehha.ca.gov/SyntheticTurf01122016.mp4.
3:18:35. Comments of Nick Lapas, Californians Against Waste (asking the OEHHA panel to
reconsider the initial decision not to use control samples – i.e., natural turf and air – in their study)
3:28:00. Comments of Michael Peterson, Gradient Consulting, and a consultant to the RRC
(Urging the panel to include natural turf samples as a control)
3:35:12. The Scientific Advisory Panel discussion after comments from the observers, with
several panel members expressing the need for sampling controls.
Sampling controls are a critical component of any scientific sampling plan. If the FRAP fails to include
such controls in the research – particularly if California OEHHA is including sampling controls – this will
call into question the validity and relevance of the Federal research.
The Presence of Chemicals Must Be Reported Only in Context With Regard to Health-based
Guidelines.
Finally, the identification of chemical compounds in recycled rubber must include context, i.e., a
baseline below which the presence of those constituents has been determined to present no significant
health hazards (e.g., health-based standards for toys). Simply reporting the presence of chemical
compounds without regard to whether the levels create any cause for concern, including the
bioavailability of those chemicals, ignores sound science and would needlessly create fear and concern for
the users of the facilities. Sound science recognizes that both natural and synthetic chemicals are harmful
only if they are actually absorbed in actually harmful amounts. At the very least, if the presence of
chemicals found at low levels is reported, the Agencies must provide context to that report by noting (if
so) that the chemical compounds are present only at levels below which there is any significant risk. And,
the Agencies should note whether such chemicals are also present in natural grass and dirt fields,
especially those in urban and suburban settings, where contributions from pollutants deposited from
vehicular exhaust, paint chips, and other dusts and debris are common.
Currently, the synthetic turf and crumb rubber industry uses the following strict, health-based guidelines:
1. For heavy metals, crumb rubber is benchmarked against the heavy metal standards used by the
very stringent EN71-3 European Union toy standards. Crumb rubber is also certified to comply
with the lead standard set by CPSC for children’s toys and the lead standard set by the EPA for
urban/rural soils.
3
2. Human health risk assessment models to estimate additional cancer risk from exposure to PAH’s
via the dermal and ingestion exposure pathways are benchmarked against exposure to background
level of PAH’s and arsenic in urban and rural soils. Additional, theoretical, lifetime cancer riskestimates from exposure during recreational uses are found to be smaller than a de minimis risk
level of one in one million (a standard well below EPA’s level of risk)
Reporting on crumb rubber without comparing data to allowable levels in toys or urban/rural soils would
provide inconclusive and potentially misleading results.
The FRAP Must Consider Benefits and Risks vis-à-vis Alternatives to Recycled Rubber.
The 12,000 synthetic turf sports fields in use today have a significant positive health impact on
communities. Availability during or after rain events increases field play time by a factor of five.
Moreover, turf fields offer a lower maintenance and offer other positive environmental benefits, including
reductions in water usage, pesticides, herbicides, and fertilizer.
In evaluating the relative risks and benefits of recycled rubber, the environmental benefits of
recycled rubber should also be considered. A typical synthetic turf sports field uses recycled rubber from
25,000 tires which may otherwise end up in landfills.
Conclusion
We urge that the Federal Research Action Plan apply sound science, including analyzing all
available peer-reviewed research, applying sampling controls from nearby grass fields and air, and
providing proper context to the low level presence of chemical compounds, if any, in recycled rubber.
Finally, the environmental and health benefits of recycled rubber vis-à-vis alternatives must be
considered. The undersigned organizations represent multiple industries in various parts of the supply
chain: we have spent over a decade studying this issue and are able, willing, and ready to assist the
Federal effort in any way possible. Only with sound scientific methodologies can the FRAP achieve
results upon which users of recycled rubber surfaces can reasonably rely and make informed decisions as
to the relative risks of those surfaces vis-à-vis alternatives.
Respectfully,
The Safe Fields Alliance
The Recycled Rubber Council
The Synthetic Turf Council
The Institute of Scrap Recycling Industries, Inc.
4
Page 1 of 1
PUBLIC SUBMISSION
As of: 5/3/16 6:33 PM
Received: May 02, 2016
Status: Posted
Posted: May 03, 2016
Tracking No. 1k0-8pek-unms
Comments Due: May 02, 2016
Submission Type: Web
Docket: ATSDR-2016-0002
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill 0923-16PJ
Comment On: ATSDR-2016-0002-0003
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill ATSDR-2016-0002
Document: ATSDR-2016-0002-0066
Comment on FR Doc # 2016-03305
Submitter Information
Name: Rockwood Turf
Email: rockwoodturf@gmail.com
General Comment
Studies with Conflicts of Interest and Other Recommendations for Studies and Data.
Attached please find comments regarding studies with conflicts of interest in addition to
recommendations for other studies pertaining to crumb rubber used on playgrounds and
synthetic turf fields, and synthetic turf fields in general.
Comments reference EPA's own "Tire Crumb and Synthetic Turf Field Literature and Report
List as of Nov. 2015" located at https://www.epa.gov/chemical-research/tire-crumb-andsynthetic-turf-field-literature-and-report-list-nov-2015 to be used as part of the new February
2016 federal study: Federal Research Action Plan on Recycled Tire Crumb Used on Playing
Fields and Playgrounds.
Thank you for your consideration of this important matter. Our children thank you!
Attachments
Conflicts-of-Interest-and-Recs-for-EPA-CR-Lit-Report-List-20160502
https://www.fdms.gov/fdms/getcontent?objectId=0900006481fa199c&format=xml&showor... 5/3/2016
Comments: “Tire Crumb and Synthetic Turf Field Literature and Report List as of Nov. 2015”
Please see table below referencing EPA’s “Tire Crumb and Synthetic Turf Field Literature and Report List as of Nov. 2015” posted at https://www.epa.gov/chemical-research/tire-crumband-synthetic-turf-field-literature-and-report-list-nov-2015. Conflicts of interest are identified in the studies conducted on shredded waste tires in crumb rubber infill and playground
rubber mulch. Because conflicts of interest affect a study’s conclusions, determining them is important. EPA should be aware of studies funded or conducted by industry, if the group/company
makes a profit from the product, or if the mission of the group interferes with safety, such as promoting use of recycled tires. This explains why time has been taken to study this issue. Provided
comments are not a review of whether the studies have data gaps or are well done, although a few notes have been given in this regard.
Comments presented here include:
Identification of conflicts of interest – EPA’s “Tire Crumb and Synthetic Turf Field Literature and Report List as of Nov. 2015” (pp. 1-28)
Recommendations for studies to be added (pp. 29-43)
Other data for consideration (pp. 44-56)
Identification of Conflicts of Interest – EPA’s “Tire Crumb and Synthetic Turf Field Literature and Report List as of Nov. 2015”
Study
1. Leaching of DOC, DN
and Inorganic
Constituents from Scrap
Tires
Author(s)
Selbes M., Yilmaz O.,
Khan A.A., Karanfil T.
(2015). Chemosphere.
139:617-23.
(Selbes M1, Yilmaz O1,
Khan AA2, Karanfil T3.)
Group(s)
Conflict of
Interest?
Department of
Environmental Engineering
and Earth Sciences,
Clemson University,
Anderson, South Carolina.
2
Department of Civil
Engineering, Clemson
University, Clemson, South
Carolina.
3
Department of
Environmental Engineering
and Earth Sciences,
Clemson University,
Anderson, South Carolina.
tkaranf@clemson.edu
N
1
Reason for
Conflict of Interest
Notes
N/A
Page | 1
Identification of Conflicts of Interest – EPA’s “Tire Crumb and Synthetic Turf Field Literature and Report List as of Nov. 2015”
Study
Author(s)
Group(s)
Conflict of
Interest?
Reason for
Conflict of Interest
Notes
2. Environmental and
Health Impacts of
Artificial Turf: A Review
Cheng H.1, Hu Y.,
Reinhard M.
(2014). Environ Sci
Technol. 48(4):2114-29.
1
State Key Laboratory of
Organic Geochemistry
Guangzhou Institute of
Geochemistry, Chinese
Academy of Sciences
Guangzhou 510640, China.
N
N/A
Not a study; a literature review only.
3. Environmental Sanitary
Risk Analysis Procedure
Applied to Artificial Turf
Sports Fields
Ruffino et al.
(2013). Environ Sci
Pollut Res Int.
1
Y
Promotes recycling
used tires (see notes).
“Management of the huge quantity of end‐of‐life tires (ELTs)
collected every year leads to several options among which
the preferable ones seem to be recycling and reuse, that
allow the high quality of component materials to be fully
exploited…”
(Ruffino B1, Fiore S,
Zanetti MC.)
DIATI-Department of
Environment, Land and
Infrastructure Engineering,
Politecnico di Torino, Corso
Duca degli Abruzzi, 24
10129 Torino, Italy.
barbara.ruffino@polito.it
http://www.ucprc.ucdavis.edu/PLCA2014/media/pdf/Papers/LCA14_Crumb%20Rubber%20P
avements.pdf
“Management of end-of-life tyres (ELTs) has become a
critical problem worldwide… Since landfill disposal has been
banned in most Countries, alternative final destinations have
been sought, with a major effort being placed in trying to
exploit in the most efficient manner the high energy
potential of ELTs. Nevertheless, due to the fact that rubber
employed in tyre fabrication is the result of specialized
materials’ selection, recycling and reuse seem to be
preferable options for such a high-quality waste material
(Santagata and Zanetti, 2012).”
http://opensample.info/order/ad6145a12f3aa43693b0e51d
ee50a107761f3af0
Page | 2
Identification of Conflicts of Interest – EPA’s “Tire Crumb and Synthetic Turf Field Literature and Report List as of Nov. 2015”
Study
Author(s)
Group(s)
Conflict of
Interest?
Reason for
Conflict of Interest
Notes
4. New Approach to the
Ecotoxicological Risk
Assessment of Artificial
Outdoor Sporting
Grounds
Krüger O.1, Kalbe U.,
Richter E., Egeler P.,
Römbke J., Berger W.
(2013). Environ Pollut.
175:69-74.
1
BAM Federal Institute for
Materials Research and
Testing, Division 4.4
Thermochemical Residues
Treatment and Resource
Recovery, Unter den Eichen
87, 12205 Berlin, Germany.
oliver.krueger@bam.de
N
N/A
5. Artificial Turf Football
Fields: Environmental
and Mutagenicity
Assessment
Schilirò T.1, Traversi D.,
Degan R., Pignata C.,
Alessandria L., Scozia D.,
Bono R., Gilli G. (2013).
Arch Environ Contam
Toxicol. 64(1):1-11.
1
Department of Public
Health and Microbiology,
University of Torino, Via
Santena, 5bis, 10126,
Torino, Italy.
tiziana.schiliro@unito.it
N
N/A
This study was financed by the Department of Sport and
Recreation of the city of Torino, Italy.
6. Bioaccessibility and Risk
Exposure to Metals and
SVOCs in Artificial Turf
Field Fill Materials and
Fibers
Pavilonis B.T.1, Weisel
C.P., Buckley B., Lioy P.J.
(2013). Risk Anal.
Environmental and
Occupational Health
Sciences Institute, Robert
Wood Johnson Medical
School.
Y
Promotes recycling
used tires (see note).
The study was supported by contract #SHW10-004 from the
NJ Department of Environmental Protection, Recycling
Program and Planning.
This study found lead and other toxins in both the plastic rug
and tire crumb infill. Lead was also was found in simulated
body fluids meaning there is little or no protection of any
kind against the lead getting out of the material into the
body.
"Since it is possible that children may be exposed to
potentially high concentrations of lead while using artificial
turf fields we recommend, at a minimum, all infill and fibers
should be certified for low or no lead content prior to
purchase and installation."
Page | 3
Identification of Conflicts of Interest – EPA’s “Tire Crumb and Synthetic Turf Field Literature and Report List as of Nov. 2015”
Study
Author(s)
Group(s)
Conflict of
Interest?
Reason for
Conflict of Interest
Notes
The main outcomes of concern:
The finding of lead and chromium in both the tire
crumb and the plastic rug and body fluids at
sometimes extremely high levels EVEN IN NEW
FIELD CARPETS.
Benzothiazole derivatives and 4-(tert-octyl) phenol
were also found. Both are probable carcinogens.
“Lead was detected in almost all field samples for digestive,
sweat, and total extraction fluids with digestive fluid extract
of one field sample as high as 260 mg/kg. Metal
concentrations were not markedly different across the three
different sample types (new infill, new turf fiber, tire crumb
field sample). However, one of the new turf fiber samples
contained relatively large concentrations of chromium (820
mg/kg) and lead (4,400 mg/kg) compared to the other
samples tested…the variability of lead contained in the infill
material is large and can span more than two orders of
magnitude. One field [tire crumb] sample did contain a high
lead level (260 mg/kg) which was on the same order of
magnitude as the NJ DEP cleanup value (400 mg/kg).”
Lead-free is the only acceptable level for child products (and
indeed for people in general.). There is NO safe level of lead
for children. And yet many of our children are playing often,
if not daily, on fields that may contain lead and certainly do
contain many other toxic substances. Finding ANY lead in
any play area for children of any age is unacceptable. Every
effort should be made to eliminate ALL unnecessary sources
of lead in the environment, especially a child's environment.
Lead in artificial turf is not only totally unnecessary but
dangerous to health.
Page | 4
Identification of Conflicts of Interest – EPA’s “Tire Crumb and Synthetic Turf Field Literature and Report List as of Nov. 2015”
Study
Author(s)
Group(s)
Conflict of
Interest?
Reason for
Conflict of Interest
Notes
The levels of bioaccessibility would have been greatly
underestimated; this study did not use biologically relevant
crumb rubber particle sizes or incubation times when
determining the bioaccessibility of SVOCs and metals in
simulated lung fluids. Tire crumbs do not float in the air.
Athletes are inhaling particulate matter often only a few
microns in diameter. Further, the particulate matter may
stay lodged in the lungs for months, not 24 hours. Surface
area is a key factor in determining bioavailability. The
toxicants in dust are far more bioavailable than those in
crumbs, which in turn are more bioavailable than those in
whole tires.
7. Review of the Human
Health & Ecological
Safety of Exposure to
Recycled Tire
Rubber Found at
Playgrounds and
Synthetic Turf Fields
Cardno Chem Risk.
(2013).
Prepared for: Rubber
Manufacturers Association,
Washington, DC.
Y
Prepared for Rubber
Manufacturers
Association
8. Health Risk Assessment
of Lead Ingestion
Exposure by Particle
Sizes in Crumb Rubber
on Artificial Turf
Considering
Bioavailability
Kim S.1, Yan J.Y., Kim
H.H., Yeo I.Y., Shin D.C.,
Lim Y.W. (2012). Environ
Health Toxicol.
27:e2012005.
1
N
N/A
Institute for
Environmental Research,
Yonsei University, Seoul,
Korea.
The authors have no conflict of interest to declare on this
study.
Page | 5
Identification of Conflicts of Interest – EPA’s “Tire Crumb and Synthetic Turf Field Literature and Report List as of Nov. 2015”
Study
Author(s)
Group(s)
Conflict of
Interest?
Reason for
Conflict of Interest
9. Zinc Leaching from Tire
Crumb Rubber
Rhodes E.P.1, Ren Z.,
Mays D.C. (2012).
Environ Sci Technol.
46(23):12856-63.
1
Department of Civil
Engineering, University of
Colorado Denver, Campus
Box 113, PO Box 173364,
Denver, Colorado.
N
N/A
10. Comparison of Batch
and Column Tests for
the Elution of Artificial
Turf System
Components
Krüger O.1, Kalbe U.,
Berger W., Nordhauβ K.,
Christoph G., Walzel
H.P. (2012). Environ Sci
Technol. 46(24):1308592
1
BAM Federal Institute for
Materials Research and
Testing , Unter den Eichen
87, 12205 Berlin, Germany.
oliver.krueger@bam.de
N
N/A
11. Design of a New Test
Chamber for Evaluation
of the Toxicity of Rubber
Infill
Gomes JF 1, Mota HI,
Bordado JC, Baião M,
Sarmento GM,
Fernandes J, Pampulim
VM, Custódio ML,
Veloso I. (2011). Toxicol
Mech Methods.
21(8):622-7
1
IBB/Centre for Chemical
and Biological Engineering,
Instituto Superior TécnicoUTL , Lisboa , Portugal.
jgomes@deq.isel.ipl.pt
N
N/A
12. An Evaluation of
Potential Exposure to
Lead and Other Metals
as the Result of
Aerosolized Particulate
Matter from Artificial
Turf Playing Fields
Shalat, S.L. (2011).
Division of Environmental
Health. Submitted to the
New Jersey Department of
Environmental Protection.
N
N/A
Notes
Faulty testing method: sand is routinely used to filter
pollutants out of stormwater. Krueger’s method included
filter sand at the top and bottom of the column to “disperse
the flow.” The filter sand may also have reduced the levels
of leachates that were measured. Addition of extraneous
filtering media into a system does not yield a realistic model.
This study examined the levels of PM 100 and respirable
lead dust measured by a stationary air monitor, a mobile air
monitor on a robot remotely controlled by a computer, and
by a personal breathing space air monitor on a child running
soccer drills. Total inhalable particles and inhalable lead
levels were lowest when measured by the stationary air
monitor.
The study found lead in the field dust in the respirable air
space of a robot and real player; highly variable but
Page | 6
Identification of Conflicts of Interest – EPA’s “Tire Crumb and Synthetic Turf Field Literature and Report List as of Nov. 2015”
Study
Author(s)
Group(s)
Conflict of
Interest?
Reason for
Conflict of Interest
Notes
sometimes very high (note most facilities would NOT allow
testing). The concerns about lead exposure have taken on a
new urgency following the release in June 2012 of a study
completed for the New Jersey DEP which found artificial
fields made of tire crumb can contain highly elevated levels
of lead much greater than the allowed levels for children:
13. Artificial-Turf Playing
Fields: Contents of
Metals, PAHs, PCBs,
PCDDs and PCDFs,
Inhalation Exposure to
PAHs and Related
Preliminary Risk
Assessment
Menichini et al. (2011).
Sci Total Environ.
409(23):4950-7.
(Edoardo Menichinia,
Vittorio Abatea, Leonello
Attiasb, Silvia De Lucaa,
Alessandro di
Domenicoa,
Igor Fochi a, Giovanni
Fortea, Nicola Iacovellaa,
Anna Laura Iamicelia,
Paolo Izzob, Franco
Merlia, Beatrice Boccaa)
a
Department of
Environment and Primary
Prevention, Istituto
Superiore di Sanità, Viale
Regina Elena 299, 00161
Rome, Italy.
N
It reports concerns with regard to potential hazards
that may exist for individuals, and in particular,
children, who engage in sports activities on artificial
fields
Inhalable lead present in artificial turf fields can be
resuspended by even minimal activity on the playing
surface.
N/A
b
National Centre for
Chemical Substances,
Istituto Superiore di Sanità,
Viale Regina Elena 299,
00161 Rome, Italy.
Page | 7
Identification of Conflicts of Interest – EPA’s “Tire Crumb and Synthetic Turf Field Literature and Report List as of Nov. 2015”
Study
14. Human Health Risk
Assessment of Synthetic
Turf Fields Based Upon
Investigation of Five
Fields in Connecticut
Author(s)
Ginsberg1 et al. (2011). J
Toxicol Environ Health
A. 74(17):1150-74.
Group(s)
Conflict of
Interest?
Connecticut Dept of Public
Health, Hartford,
Connecticut.
gary.ginsberg@ct.gov
N
1
Reason for
Conflict of Interest
N/A
Notes
Faulty testing method, faulty risk assessment method. The
authors excluded benzene from the risk assessment based
on results from personal air monitor samples taken from a
grass field approximately 15 months after the original
sampling was taken. It is not plausible to suggest that air
samples taken more than a year later, in a different season,
can serve as an adequate background control. The authors
failed to mention the second round of sampling in this
report although it was discussed in a separate report
generated by this research project. The addition of
implausible post hoc control data and the lack of
transparency in this article violate good scientific practices.
Thirteen compounds were included in the cancer risk
assessment. Cancer unit risks were obtained from standard
toxicology databases for four of those, two of those
included human epidemiologic data. Unit risk estimates for
the other nine carcinogens were estimated, assumed or
obtained from nonstandard sources.
Of the dozens of chemicals known to be contained in crumb
rubber, twenty-seven chemicals of potential concern were
identified by the CT DPH for the risk assessment portion of
the “Connecticut Study.” (A total of five documents
comprise the Connecticut Study.) Thirteen chemicals were
identified as carcinogens and included in the cancer risk
assessment. The study authors were only able to identify
unit risk estimates from standard governmental databases
for four of the thirteen carcinogens in the cancer risk
assessment. Unit risk estimates for the other nine
carcinogens were assumed or obtained from nonstandard
sources. This study demonstrates both the lack of necessary
toxicity information to do a quantitative risk assessment and
the inappropriate risk assessment methodology.
Page | 8
Identification of Conflicts of Interest – EPA’s “Tire Crumb and Synthetic Turf Field Literature and Report List as of Nov. 2015”
Study
Author(s)
Group(s)
Conflict of
Interest?
Reason for
Conflict of Interest
Notes
The Connecticut study used a component-based risk
assessment method in which the risks posed by the
individual chemicals were simply summed, ignoring any
possible interaction effects. However, the Connecticut risk
assessment relied on an inappropriate methodology and
both approaches relied on extremely incomplete toxicity
databases. There are too many possible synergistic or
antagonistic interactions between combinations of
chemicals to predict the overall toxicity of the mixture with
any confidence.
Other issues with study methods:
1. The study inappropriately used component-based
risk assessment methods.
2. The study did not include a legitimate estimate of
the risk from respirable rubber dust and carbon
black. The 2010 study done by the University of
Connecticut Health Center (UCHC) had used
stationary air monitors to measure PM 10 levels on
the turf fields near simulated games using 3-4
players and up wind of turf fields (Simcox, Bracker,
& John, 2010). However, as noted earlier, the
Norwegian study found increased levels of PM 2.5,
not PM 10. PM 2.5 is also considered to be more of
a health threat than PM 10.
Although personal air monitors were used in other parts of
the study, they were not used to measure PM 10, PM 2.5 or
carbon black. As indicated by the Shalat study, this may have
led to a significant underestimation of the levels of
respirable particles that players were exposed to. No good
explanation exists for this oversight.
Page | 9
Identification of Conflicts of Interest – EPA’s “Tire Crumb and Synthetic Turf Field Literature and Report List as of Nov. 2015”
Study
Author(s)
Group(s)
Conflict of
Interest?
Reason for
Conflict of Interest
Notes
Since the UCHC study found no significant difference
between the upwind and the on-field levels of PM 10, the
DPH study authors concluded that particulate matter posed
zero risk for the purposes of their health risk assessment.
3. The study assumed that the levels of VOCs and
SVOCs measured on sunny days when the
temperatures were generally in the low 80’s would
be a suitable average of levels of these chemicals for
the four warmest months of the year, and that no
VOCs or SVOCs would be emitted the other four
months of the year when the fields were used.
However, the rate at which VOCs and SVOCs off gas
increases exponentially as temperatures increase.
Exposures at a 100° F day and a 60° F do not equal
the exposure from two 80 °F days. Further, it cannot
be argued that these exposure levels could be
applied to areas with higher temperatures, such as
Texas, Southern California, or even Eastern
Washington. Eastern Washington had far too many
days last summer with the temperature in the 90’s
for these exposure levels to be relevant.
4. No model of inhalation by soccer goalies and
younger people who spend much time on or close to
the surface has been conducted.
5. Three carcinogens that were identified as
Contaminants of Possible Concern were excluded
from the cancer health risk assessment without
explanation.
a. Ethylbenzene: It is unclear why this
carcinogen was not included in the risk
assessment. Ethylbenzene would have made
a significant contribution to the overall risk.
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Group(s)
Conflict of
Interest?
Reason for
Conflict of Interest
Notes
Ethylbenzene has been considered a
carcinogen by California’s OEHHA since
2004. A cancer unit risk value was
established by OEHHA in 2007.
b. Methyl isobutyl ketone: The risk
assessment also did not include methyl
isobutyl ketone. Methyl isobutyl ketone was
declared to be a carcinogen by OEHHA in
2011, but no unit risk was established.
Given the lengths the authors went to in
order to obtain unit risk estimates for
chemicals that are still not considered to be
carcinogens, it is odd that this chemical was
excluded from the risk analysis with no
discussion or indication as to why.
c. Styrene: In the study, the authors state that
the data on styrene is limited and conflicting
but that styrene has positive mutagenicity
data and that its main metabolite, styrene
oxide, is a known carcinogen. Because they
considered styrene a potential carcinogen,
they added an additional uncertainty factor
to styrene’s RFC when calculating its hazard
index in a separate part of the study.
Nonetheless, styrene was omitted from the
cancer health risk assessment.
California’s OEHHA declared styrene to be a carcinogen in
2010.An updated cancer risk assessment was published by
the Connecticut Department of Public Health in 2011, after
additional measurements were taken in October of 2010.
This risk assessment also did not include styrene (Simcox N.
J., et al., 2011).
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Author(s)
Group(s)
Conflict of
Interest?
Reason for
Conflict of Interest
Notes
OEHHA currently estimates the unit risk for styrene oxide to
be 4.6 x10-5. Had styrene been included in the risk estimate
with this as a conservative estimate of its unit risk, styrene
would have been the largest contributor of risk.
6. The limitations of the toxicity data were not fully
discussed, thus giving readers an overly optimistic
view of the accuracy and precision of the estimates.
Although the authors noted how they obtained their
cancer unit risk, reference concentration, and acute
target level for each chemical in a table, the body of
the report does not indicate that most of the table is
filled in based on assumptions of toxic equivalency
or estimated relative potencies. There was no
discussion of the limitations of drawing conclusions
about human health effects based on animal studies.
A discussion of the chemicals involved in Connecticut’s
study, and the nature of the toxicology data for each
chemical is provided below. The Connecticut study drew
data from the Environmental Protection Agency’s (EPA)
Integrated Risk Information System (IRIS) database,
California’s Office of Environment Health Hazard Assessment
(OEHHA) Toxicity Criteria Database, as well as other
standard government sources. The information below
contains information from the above referenced sources as
well as the International Agency for Research on Cancer
(IARC), and the National Toxicology Program (NTP).
The first four chemicals have sufficient data to have
established cancer unit risks in one or more standard
toxicology databases.
Benzene – Adequate animal studies and human
epidemiological data are available. The OEHHA cancer unit
risk estimate was at least 3.7 times greater than the EPA IRIS
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Author(s)
Group(s)
Conflict of
Interest?
Reason for
Conflict of Interest
Notes
unit risk estimate. The authors of the Connecticut study
decided that neither either estimate was demonstrably
more accurate, so the study authors averaged the two unit
risk estimates to create a new unit risk estimate for use in
their study (Ginsburg & Toal, 2010).
Methylene Chloride – Adequate animal studies and human
epidemiological data are available. The study used the EPA
IRIS cancer unit risk.
Naphthalene – The unit risk was from OEHHA’s database
and was based on studies conducted in rodents. There are a
couple of cancer case series in humans, but the EPA and
IARC consider these to be insufficient evidence of
carcinogenicity in humans.
Benzo(a)pyrene – The unit risk was from OEHHA’s database
and was derived from a few studies on hamsters. While
OEHHA staff felt that the studies on benzo(a)pyrene were
not ideal for calculating a cancer unit risk, the toxicology
data on other PAHs were even less complete (Office of
Environment Health Hazard Assessment, 2011).
Benz(a)anthracene Benzo(b)fluoranthene
Benzo(k)fluoranthene Chrysene
The next four chemicals, benz(a)anthracene,
benzo(b)fluoranthene, benzo(k)fluoranthene, and chrysene
are all polycyclic aromatic hydrocarbons (PAHs).
The U.S. EPA determined that these are probable
carcinogens but lacked information sufficient to allow for
direct estimation of cancer unit risks. However, the EPA did
publish, “EPA Provisional Guidance for Quantitative Risk
Assessment of Polycyclic Aromatic Hydrocarbons.” In this
document, the relative potencies of seven PAHs were
estimated based on the effects of dermal exposures to the
Page | 13
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Author(s)
Group(s)
Conflict of
Interest?
Reason for
Conflict of Interest
Notes
PAHs in mice. These potencies were rounded to a single
order of magnitude. The authors of the Connecticut study
assumed that the relative potencies of the PAHs derived
from dermal exposures in mice were equivalent to the
relative potencies for inhalation exposures in humans, thus
allowing for the derivation of unit risks for these chemicals.
There is uncertainty from using mice to model human
toxicity. Uncertainty from using dermal studies to model
inhalation risk. Uncertainty from computing relative
potencies to estimate unit risks rather than computing unit
risks directly from sufficient data. Rounding error. Uncertainty
from using hamsters to model human toxicity. Uncertainty
from exposing hamsters to inhalation of benzo(a)pyrene in a
particle bound form or dissolved in a medium to estimate
response to exposure to the gas. Uncertainty was multiplied
by uncertainty which was multiplied by rounding error, and
the result was represented as a scientifically supported risk
calculation accurate to two significant digits.
Chloromethane: The study authors stated that the cancer
unit risk for chloromethane (methyl chloride) was obtained
from documentation for California’s Proposition 65.
However, no citation was given and the source was unable
to be identified. Chloromethane is not considered by
California or the EPA to a carcinogen. There is some
evidence from a mouse study that chloromethane may
cause renal tumors, but the relevance of this study to
humans is questionable due to differences in rodent and
human physiology.
1-Methylnaphthalene 2-Methylnaphthalene 2,6
Dimethylnaphthalene
Three chemicals, 1-methylnaphthalene, 2methylnaphthalene, and 2,6 dimethylnaphthalene are not
Page | 14
Identification of Conflicts of Interest – EPA’s “Tire Crumb and Synthetic Turf Field Literature and Report List as of Nov. 2015”
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Author(s)
Group(s)
Conflict of
Interest?
Reason for
Conflict of Interest
Notes
classified by the EPA or California as carcinogens. , 1Methylnaphthalene and 2,6 dimethylnaphthalene do not
even appear in the EPA’s IRIS or OEHHA’s toxicity criteria
database. 2-Methylnaphthalene is listed in IRIS as
unclassifiable as to carcinogenicity due to insufficient data.
The limited animal studies thus far on the
methylnaphthalenes have not yielded clear evidence of
oncogenetic effects for these chemicals (Lin, Wheelock,
Morin, Baldwin, & al, 2009).
Benzothiazole: The risk estimate for benzothiazole must be
considered speculative, at best. It is also not considered to
be a carcinogen in the EPA IRIS or the OEHHA database.
There was not enough information on benzothiazole to
estimate a unit risk directly from studies on the chemical
itself. Rather, a related chemical 2-MBT (2mercaptobenzothiazole) was used. In a study for the
National Toxicology Program, rats and mice were orally
exposed to 2-MBT dissolved in corn oil and the animals
displayed elevated rates of cancers at various sites. A
researcher attempting to assess the risk of 2-MBT in water
calculated cancer unit risks based on the study’s data. The
author’s calculations underestimated the total cancer risk
because the calculations only considered the risk for renal
cancer, even though the rodents developed multiple types
of cancer. The authors of the Connecticut study converted
the unit risk for an oral dose of 2-MBT to a unit risk for
inhalation. Thus, the study authors used an underestimate
the unit risk of orally administered 2-MBT in rodents as an
estimate of the unit risk for inhaled benzothiazole in
humans.
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Identification of Conflicts of Interest – EPA’s “Tire Crumb and Synthetic Turf Field Literature and Report List as of Nov. 2015”
Study
Author(s)
Group(s)
Conflict of
Interest?
15. Synthetic Turf Field
Investigation in
Connecticut
Simcox et al. (2011). J
Toxicol Environ Health
A. 74(17):1133-49.
1
University of Connecticut
Health Center, Farmington,
Connecticut.
simcox@uchc.edu
Y
16. Benzothiazole Toxicity
Assessment in Support
of Synthetic Turf Field
Human Health Risk
Assessment
Ginsberg et al. (2011). J
Toxicol Environ Health
A. 74(17):1175-83.
a
N
(Gary Ginsberga*, Brian
Toala & Tara Kurlandb)
b
Connecticut Dept of Public
Health , Hartford,
Connecticut.
Clark University ,
Worcester, Massachusetts.
Reason for
Conflict of Interest
Promotes recycling
used tires (see note).
Notes
Funding for this project was provided by the Connecticut
Department of Environmental Protection.
The addition of post hoc ‘control’ data from personal air
monitor samples violates generally accepted rules of
scientific methodology. Control and test groups should have
been declared and created at the beginning of the study.
Further, background air pollution levels vary from day to day
and from season to season. Thus it is implausible to suggest
that an air sample gathered over a year later, during a
different season, could serve as a control.
N/A
Not a study; it is a literature review only.
The Connecticut study used a component-based risk
assessment method in which the risks posed by the
individual chemicals were simply summed, ignoring any
possible interaction effects. However, the Connecticut risk
assessment relied on an inappropriate methodology and
both approaches relied on extremely incomplete toxicity
databases. There are too many possible synergistic or
antagonistic interactions between combinations of
chemicals to predict the overall toxicity of the mixture with
any confidence.
This article gives the justification for the toxicity estimates
for benzothiazole (BZT) used in the synthetic turf risk
assessments performed by the Connecticut Department of
Public Health (DPH). BZT was slightly more acutely toxic than
2-mercaptobenzothiazol (2-MBZT) in tests on laboratory
animals, and showed genetic toxicity in one strain of
salmonella while 2-MBZT did not show genetic toxicity in any
strains. Given the chemical structure of BZT, and the positive
Page | 16
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Author(s)
Group(s)
Conflict of
Interest?
Reason for
Conflict of Interest
Notes
genetic toxicity test result, the authors chose to estimate the
cancer risk from BZT based on the chemical 2-MBZT. While
2-MBZT did appear to be slightly less toxic than BZT in
several tests, the authors’ approach seems reasonable, and
is far preferable to leaving the risk from BZT out of the
health risk assessment entirely.
17. Hydroxypyrene in Urine
of Football Players After
Playing on Artificial
Sports Fields with Tire
Crumb Infill
Van Rooij1 and
Jongeneelen. (2010). Int
Arch Occup Environ
Health. 83(1):105-10.
1
IndusTox Consult, PO Box
31070, 6503 CB, Nijmegen,
The Netherlands.
joost.vanrooij@industox.nl
Y
Promotes recycling
used tires (see note).
This study is funded by the following organizations in the
Netherlands: KNVB, NOC*NSF, WG Materialen, VACO, DSM,
RecyBem and Ten Cate.
“Old tires, great agreements
RecyBEM B.V. and the Association Tire and Environment
come together in the execution of the Decision
Management Car Tires.
As a member of the Association Tire and Environment, Yde
van der Veen has been made responsible for processing
used car tires in an environmentally-friendly way by virtue of
the decree. The RecyBEM B.V. was founded as an execution
organization for the Decision Management Car Tires to
ensure that all used car tires on the Dutch market are
collected structurally and are reprocessed in an
environmentally-friendly way.
RecyBEM B.V. exercises supervision on the collection
companies contracted by RecyBEM B.V. You can also
recognize BEM-certified collection companies, such as Yde
van der Veen by the use of the uniform tire recycling receipt
of RecyBEM B.V. and the Association Tire and Environment.”
http://www.ydevanderveen.nl/en/recybem-en
Exposure was only measured for one day, at 2.5 hrs. All
players were age 20 or older; no children were included in
study.
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Identification of Conflicts of Interest – EPA’s “Tire Crumb and Synthetic Turf Field Literature and Report List as of Nov. 2015”
Study
18. Risk Assessment of
Artificial Turf Fields
Author(s)
Group(s)
Conflict of
Interest?
Connecticut Department
of Energy &
Environmental
Protection.
(2010). Connecticut
Departments of Public
Health and
Environmental
Protection and the
Connecticut Agricultural
Research Station.
Connecticut Department of
Energy & Environmental
Protection.
(2010). Connecticut
Departments of Public
Health and Environmental
Protection and the
Connecticut Agricultural
Research Station.
Y
Reason for
Conflict of Interest
This study relies on
data collected by
Synthetic Turf Field
Investigation in
Connecticut by Simcox
et al. (2011). J Toxicol
Environ Health A.
74(17):1133-49, which
also has a conflict of
interest.
Notes
Failure to disclose the use of a post hoc control group. The
Connecticut study used a component-based risk assessment
method in which the risks posed by the individual chemicals
were simply summed, ignoring any possible interaction
effects. However, the Connecticut risk assessment relied on
an inappropriate methodology and both approaches relied
on extremely incomplete toxicity databases. There are too
many possible synergistic or antagonistic interactions
between combinations of chemicals to predict the overall
toxicity of the mixture with any confidence.
---“Their “headline” conclusion, however, reflects none of that
concern: ‘Results indicate cancer risks slightly above de
minimis levels for all scenarios evaluated …’ The conclusion
fails to indicate that such risks are highly improbable,
reflecting a series of systematic overestimates of exposure
and risk, and including a contaminant that is almost certainly
not actually off-gassing from the crumb rubber. The CASE
Peer Review Committee strongly urges DPH to revise its risk
assessment and then present its findings with appropriate
cautions. At the least, the various assumptions underlying
the risk assessment should be compiled and presented in a
manner so that they can be understood by non-scientists
(e.g., parents and journalists) reading the report.”
http://www.ct.gov/deep/lib/deep/artificialturf/case_artificia
l_turf_review_report.pdf
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Conflict of
Interest?
Reason for
Conflict of Interest
19. Toxicological
Assessment of Coated
Versus Uncoated
Rubber Granulates
Obtained from Used
Tires for Use in Sport
Facilities
Gomes et al. (2010). J
Air Waste Manag Assoc.
60(6):741-6.
(Gomes J1, Mota H,
Bordado J, Cadete M,
Sarmento G, Ribeiro A,
Baiao M, Fernandes J,
Pampulim V, Custódio
M, Veloso I.)
1
IBB/Center for Chemical
and Biological Engineering,
Instituto Superior Técnico,
and Chemical Engineering
Department, Instituto
Superior de Engenharia de
Lisboa, Lisboa, Portugal.
jgomes@deq.isel.ipl.pt
N
N/A
20. Characterization of
Substances Released
from Crumb Rubber
Material Used on
Artificial Turf Fields
Li et al.
(2010). Chemosphere.
80(3):279-85.
The Connecticut
Agricultural Experiment
Station.
N
N/A
21. Evaluating and
Regulating Lead in
Synthetic Turf
Gregory Van Ulirsch,
Kevin Gleason, Shawn
Gerstenberger, Daphne
B. Moffett, Glenn
Pulliam, Tariq Ahmed,
Jerald Fagliano. (2010).
Environ Health Perspect.
118(10): 1345–1349.
1
N
N/A
Notes
(Li X1, Berger W,
Musante C, Mattina MI.)
(Gregory Van Ulirsch1,
Kevin Gleason2, Shawn
Gerstenberger3, Daphne
B. Moffett1, Glenn
Pulliam4, Tariq Ahmed4,
Jerald Fagliano4)
Agency for Toxic
Substances and Disease
Registry, Atlanta, Georgia.
Not a study; literature review only.
2
New York State
Department of Health,
Troy, New York.
3
Department of
Environmental and
Occupational Health,
University of Nevada Las
Vegas, Las Vegas, Nevada.
4
New Jersey Department of
Health and Senior Services,
Trenton, New Jersey.
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Identification of Conflicts of Interest – EPA’s “Tire Crumb and Synthetic Turf Field Literature and Report List as of Nov. 2015”
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Group(s)
Conflict of
Interest?
Reason for
Conflict of Interest
Notes
22. Safety Study of Artificial
Turf Containing Crumb
Rubber Infill Made from
Recycled Tires:
Measurements of
Chemicals and
Particulates in the Air,
Bacteria in the Turf, and
Skin Abrasions Caused
by Contact with the
Surface
California Office of
Environmental Health
Hazard Assessment.
(2010). Prepared for the
California Department
of Resources Recycling
and Recovery.
California Office of
Environmental Health
Hazard Assessment.
(2010). Prepared for the
California Department of
Resources Recycling and
Recovery.
Y
Prepared for the
California Department
of Resources Recycling
and Recovery.
CalRecycle, as part of
OEHHA, promotes
recycling used tires.
This study examined the temperature at four artificial turf
fields. It measured the VOCs in the air above the air at the
four fields. Air for the VOC samples was collected from
stationary monitors placed beneath galvanized steel garbage
cans for 45 minutes. PM 2.5 samples were also collected
from three fields, however, the results from two fields were
below the limit of detection. The results from the third field
were inconsistent. The study also looked at MRSA risk.
While artificial turf has not been shown to harbor or
transmit the MRSA virus, its abrasiveness significantly
increases the risk of epidermal injuries that could result in a
MRSA infection.
23. An Assessment of
Chemical Leaching,
Releases to Air and
Temperature at CrumbRubber Infilled Synthetic
Turf Fields
Lim L., Walker R.
(2009).
New York State
Department of
Environmental
Conservation, New York
State Department of
Health.
Y
Promotes recycling
used tires (New York
State Department of
Environmental
Conservation).
This report only involved two artificial turf fields, both of
which were located in downtown New York City, making it
very difficult to separate out signal from noise when
attempting to measure possible off-gassing from the fields.
PM 10 and PM 2.5 were measured, but the measurements
at Thomas Jefferson Field were deemed unreliable due to
the implausible relationship between the PM 2.5 and PM 10
readings. The temperature readings on the fields clearly
demonstrated that once the ambient temperature reached
the 80’s, the fields could become hot enough to significantly
increase the risk of heat-related illness.
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Identification of Conflicts of Interest – EPA’s “Tire Crumb and Synthetic Turf Field Literature and Report List as of Nov. 2015”
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Author(s)
Group(s)
Conflict of
Interest?
Reason for
Conflict of Interest
24. A Scoping-Level Field
Monitoring Study of
Synthetic Turf Fields and
Playgrounds
Highsmith R., Thomas
K.W., Williams R.W.
(2009). EPA/600/R09/135.
National Exposure
Research Laboratory, U.S.
Environmental Protection
Agency.
N
N/A
25. Air Quality Survey of
Synthetic Turf Fields
Containing Crumb
Rubber Infill
Vetrano, K.M., Ritter G.
(2009).
Prepared by TRC for the
New York City Department
of Mental Health and
Hygiene, New York, New
York.
N
N/A
26. New Jersey
Investigation of Artificial
Turf and Human Health
Concerns
New Jersey Department
of Health and Senior
Services. (2008). Fact
Sheet. Consumer and
Environmental Health
Services. Epidemiology,
Environmental and
Occupational Health.
Trenton, New Jersey.
New Jersey Department of
Health and Senior Services.
(2008). Fact Sheet.
Consumer and
Environmental Health
Services. Epidemiology,
Environmental and
Occupational Health.
Trenton, New Jersey.
N
N/A
Notes
“This report was prepared for the U.S. Environmental
Protection Agency (EPA) Tire Crumb Committee, a crossAgency workgroup.”
This study examined airborne PM 10 and VOCs at four
outdoor fields and one outdoor playground. Additionally the
extractable heavy metals from surface wipes, the crumb
rubber and the turf blades from each location were also
measured. Bioaccessibility of the lead in the crumb rubber
was estimated using the protocols for assessing the
bioaccessibility of lead in soil.
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Identification of Conflicts of Interest – EPA’s “Tire Crumb and Synthetic Turf Field Literature and Report List as of Nov. 2015”
Study
27. A Review of the
Potential Health and
Safety Risks from
Synthetic Turf Fields
Containing Crumb
Rubber Infill
Author(s)
Denly E., Rutkowski K.,
Vetrano K.M. (2008).
Group(s)
Conflict of
Interest?
Prepared by TRC for the
New York City Department
of Mental Health and
Hygiene, New York, New
York.
N
Reason for
Conflict of Interest
N/A
Notes
Not a study; it’s a literature review only. This report is a
review of the literature on crumb rubber and artificial turf
safety. It also provides information on the manufacture of
tires and the chemicals contained in tires.
"In a letter dated May 14 of that year [2008], Landrigan and
two other doctors at the center advised the Health
Department to not release the ‘deeply flawed’ report, calling
it ‘superficial and one-sided.’ City Limits obtained the
damning five-page letter through another Freedom of
Information Law request.
The literature review ‘does not present a fair and balanced
assessment of the issues surrounding the potential health
hazards of synthetic turf,’ the letter read. ‘It is not up to the
high standard of work that we have come to expect from the
New York City Department of Health and Mental Hygiene in
this administration.’ The letter went on to identify four
‘proven and potential’ hazards of synthetic turf made from
recycled tires. The first and ‘best established’ was exposure
to ‘excessive heat,’ with such medical consequences as ‘foot
burns, dehydration and heat exhaustion.’ The doctors
warned that watering the fields to cool them down could
actually do more harm than good: ‘That can set the stage for
skin infections,’ because ‘residual water droplets may act as
bacterial incubators.’
This observation led to a more in-depth discussion of the
second risk: MRSA, the antibiotic-resistant staph infection
that can be acquired through turf burns. MRSA clusters from
turf burns had been reported in The New England Journal of
Medicine, the doctors noted, and in the CDC's Morbidity and
Mortality Weekly Report.
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Identification of Conflicts of Interest – EPA’s “Tire Crumb and Synthetic Turf Field Literature and Report List as of Nov. 2015”
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Author(s)
Group(s)
Conflict of
Interest?
Reason for
Conflict of Interest
Notes
Lastly, the letter raised the risk of chemical exposures,
acknowledging that the scientific literature was ‘much less
well developed’ on these hazards than on the dangers from
heat and MRSA. ‘Several credible studies’ had found the
crumb rubber contained ‘known human carcinogens’ and
‘neurotoxic chemicals,’ as well as lead, chromium and
arsenic. The city's literature review relied on reports of
human exposure to toxic chemicals from poured- or hardrubber products, ‘very different from the particulate rubber
infill found in synthetic turf fields’ and therefore ‘only
remotely relevant’ to its topic.
The letter was blunt in its criticism: ‘Overall the draft report
from [TRC Companies] on the health hazards of synthetic
turf is incomplete, it relies on irrelevant data sources, it uses
a deeply flawed approach to risk assessment, it glosses over
glaring gaps in the data, and it far too readily dismisses
proven risks to human health. It does not take into account
the unique exposures and the special vulnerabilities of
young children. It concludes quite inappropriately that
absence of evidence of risk is evidence of no risk.’"
http://citylimits.org/2010/08/24/it-wont-taste-great/
28. Synthetic Turf: Health
Debate Takes Root
Claudio L.
(2008). Environ Health
Perspect 116(3): A116–
A122.
Mount Sinai School of
Medicine, New York, New
York.
N
N/A
Not a study; opinion piece only
29. Artificial Turf: Safe or
Out on Ball Fields
Around the World
Lioy P., Weisel C.
(2008). Editorial. J of
Expos Anal Environ
Epidem. 18:533-534
Exposure Science Division,
Environmental and
Occupational Health
Sciences Institute of Robert
Wood Johnson Medical
School.
N
N/A
Not a study; it is an editorial providing an opinion only.
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Identification of Conflicts of Interest – EPA’s “Tire Crumb and Synthetic Turf Field Literature and Report List as of Nov. 2015”
Study
Author(s)
30. Hazardous Chemicals in
Synthetic Turf Materials
and their Bioaccessibility
in Digestive Fluids
Zhang et al. (2008). J
Expo Sci Environ
Epidemiol. 18(6):600-7.
31. Mapping, Emissions and
Environmental and
Health Assessment of
Chemical Substances in
Artificial Turf
Nilsson N.H., MalmgrenHansen B., Thomsen
U.S. (2008).
(Zhang JJ1, Han IK, Zhang
L, Crain W.)
Group(s)
Conflict of
Interest?
Reason for
Conflict of Interest
1
School of Public Health,
University of Medicine and
Dentistry of New Jersey.
jjzhang@eohsi.rutgers.edu
N
N/A
Danish Ministry of the
Environment,
Environmental Protection
Agency.
Y
Promotes recycling
used tires (see note).
Notes
Study financed by Danish EPA.
“3.2 Tyres (Waste strategy 2005-2008)
Landfilling of used tyres has been banned as of 16 July 2001
according to the Statutory Order No 648 of 29 June 2001 on
the revision of Statutory Order No 619 of 27 June 2000 on
Waste. Collection and recovery of tyres is regulated by the
Statutory Order on a Fee on Tyres and a Recovery Subsidy
No 111 of 5 February 2000.
…An intermediary goal was that at least 80% of all discarded
tyres from private cars, vans, and motorbikes will be
collected and recycled or incinerated before 1997. According
to the agreement, 80% of all discarded tyres must be
recycled or incinerated before 2000. Since 2001, the
collection rate has been close to 100%. Goals for 2008:
90% reuse or recycling of all discarded tyres
On 20 February 1995, the Minister for Environment and
Energy entered into an agreement with the tyre and motor
trade associations, the Association of Danish Recycling
Industries and municipal associations on a take-back scheme
for discarded tyres. Through the agreement it is ensured
that discarded tyres are collected and recycled or
incinerated, thus avoiding landfilling and ensuring resource
utilisation of waste tyres…”
http://scp.eionet.europa.eu/facts/factsheets_waste/2006_e
dition/Denmark
Page | 24
Identification of Conflicts of Interest – EPA’s “Tire Crumb and Synthetic Turf Field Literature and Report List as of Nov. 2015”
Study
Author(s)
Group(s)
Conflict of
Interest?
Reason for
Conflict of Interest
32. Evaluation of Health
Effects of Recycled
Waste Tires in
Playgrounds and Track
Products
California Office of
Environmental Health
Hazard Assessment.
(2007). Prepared for the
California Integrated
Waste Management
Board.
California Office of
Environmental Health
Hazard Assessment.
(2007). Prepared for the
California Integrated Waste
Management Board.
Y
CalRecycle, as part of
COEHHA, promotes
recycling used tires.
33. Examination of Crumb
Rubber Produced from
Recycled Tires
Incorvia Mattina M.J.,
Isleyen M., Berger W.,
Ozdemir S. (2007). The
Connecticut Agricultural
Research Station, New
Haven, CT.
The Connecticut
Agricultural Research
Station, New Haven,
Connecticut.
N
N/A
34. Artificial Turf: Exposures
to Ground-Up Rubber
Tires - Athletic Fields Playgrounds - Gardening
Mulch
Brown, D., Alderman,
N., Addiss, S., Bradley, J.
Environment and Human
Health, Inc. (2007).
N
N/A
35. Environmental and
Health Evaluation of the
Use of Elastomer
Granulates (Virgin and
from Used Tyres) as
Filling in ThirdGeneration Artificial
Turf
Moretto. (2007). France.
ALIAPUR in partnership
with Fieldturf Tarkett and
the ADEME (Environmental
French Agency).
Y
Notes
Not a study; a literature review only. Reviews numerous
related studies on shredded and poured in place recycled
tire products. It also contains an original study of oral
toxicity based on gastric digestion simulation of tire shreds.
Non-profit organization
Study referenced in this source is Examination of Crumb
Rubber Produced from Recycled Tires, Incorvia Mattina M.J.,
Isleyen M., Berger W., Ozdemir S. (2007). The Connecticut
Agricultural Research Station, New Haven, CT.
ALIAPUR in partnership
with Fieldturf Tarkett
Page | 25
Identification of Conflicts of Interest – EPA’s “Tire Crumb and Synthetic Turf Field Literature and Report List as of Nov. 2015”
Study
Author(s)
36. Preliminary Assessment
of the Toxicity from
Exposure to Crumb
Rubber: Its Use in
Playgrounds and
Artificial Turf Playing
Fields
LeDoux T. (2007).
37. A Case Study of Tire
Crumb Use on
Playgrounds: Risk
Analysis and
Communication When
Major Clinical
Knowledge Gaps Exists
Anderson et al.
(2006). Environ Health
Perspect.114(1):1-3.
(Mark E. Anderson,1,2
Katherine H. Kirkland,3
Tee L. Guidotti,4 and
Cecile Rose5)
Group(s)
Conflict of
Interest?
Division of Science,
Research and Technology.
New Jersey Department of
Environmental Protection.
N
N/A
Not a study; literature review only.
N
N/A
Not a study; it’s a commentary only. The authors declare
they have no competing financial interests.
1
Department of Community
Health Services, Denver
Health, Denver, Colorado.
2
Department of Pediatrics,
Univ. of Colorado Health
Science Center, Denver,
Colorado.
3
Association of
Occupational and
Environmental Clinics,
Washington, DC.
4
Department of
Environmental and
Occupational Health, MidAtlantic Center for Child
Health and the Environment,
School of Public Health and
Health Sciences, George
Washington Univ. Medical
Center, Washington, DC.
5
Departments of Medicine/
Preventive Medicine and
Biometrics, National Jewish
Medical and Research
Center, Denver, Colorado.
Reason for
Conflict of Interest
Notes
Page | 26
Identification of Conflicts of Interest – EPA’s “Tire Crumb and Synthetic Turf Field Literature and Report List as of Nov. 2015”
Study
38. A Survey of Microbial
Populations in
Infilled Synthetic Turf
Fields
Author(s)
McNitt A.S., Petrunak
D., Serensits T. (2006).
Group(s)
Penn State University,
College of Agricultural
Sciences, Department of
Plant Science.
Conflict of
Interest?
Reason for
Conflict of Interest
Y
This study was funded
by the Synthetic Turf
Council. In addition,
Penn State has a
partnership with
FieldTurf.
http://www.synthetict
urfcouncil.org/?page=R
esearch
Notes
This study does not address tire crumb. It is a study about
the possible risk of Staph and MRSA infections on ST.
Compare with Weber State study Determination of
Microbial Populations in a Synthetic Turf System
Sample Size of Infill Material Being Tested
Penn State-.075 Grams
Weber State-10 Grams
Collection Time Frame of Samples
Penn State-15 days, June only.
Weber State-Once a week for 14 weeks. Very controlled
samples.
Location of Samples
Penn State-“High Use” and “Low Use” areas.
Weber State-1) Sideline, 2) 50 Yard Line and 3) end of
field. 3 locations and same locations on both new and old
field being sampled.
Time of Study
Penn State-Height of Summer when field temperatures
were at the peak.
Weber State-Height of the Actual Football Season when
the fields were in use.
Technical Issues of reasons why the Penn St study did not
find Pathogens (Staph)
Penn State-Shortened agitation times for the samples
(shortened time means less chance for full discovery of
Pathogens, technical please read study)
Penn State-Failed to Isolate S. Aureus (Staph) on samples
Page | 27
Identification of Conflicts of Interest – EPA’s “Tire Crumb and Synthetic Turf Field Literature and Report List as of Nov. 2015”
Study
Author(s)
Group(s)
Conflict of
Interest?
Reason for
Conflict of Interest
Notes
39. Artificial Turf Pitches: An
Assessment of Health
Risks for Football
Players and the
Environment
Norwegian Institute of
Public Health and the
Radium Hospital. (2006).
Norwegian Institute of
Public Health and the
Radium Hospital, Oslo,
Norway.
Norwegian Institute of
Public Health and the
Radium Hospital. (2006).
Norwegian Institute of
Public Health and the
Radium Hospital, Oslo,
Norway.
N
N/A
Demonstrated elevated Particulate Matter (PM) 2.5 and
carbon black levels in indoor turf arenas that used crumb
rubber infills.
40. Measurement of Air
Pollution in Indoor
Artificial Turf Halls
Dye C., Bjerke A,
Schmidbauer N., Mano
S. (2006).
Norwegian Pollution
Control
Authority/Norwegian
Institute for Air Research,
State Programme for
Pollution Monitoring.
N
N/A
This study clearly demonstrated that crumb rubber infill in
indoor turf halls generated significant amounts of fine
respirable dust in the form of rubber particles and carbon
black. (Crumb rubber in outdoor fields would obviously also
generate significant amounts of fine respirable dust.) As the
American Lung Association article explained, fine respirable
dust in general, and carbon black in particular, are
associated with numerous adverse health outcomes. There
are no studies of fine respirable dust or carbon black
exposure in the breathing space of field users during active
field use conditions on indoor or outdoor fields. There are
also no studies of the potential exposures to people living or
attending class in buildings adjacent to artificial turf fields.
41. Toxicological Evaluation
for the Hazard
Assessment of Tire
Crumb for Use in Public
Playgrounds
Birkholz1 et al. (2003). J
Air Waste Manag,
53:903-07.
1
Y
Promotes recycling
used tires (see note).
“The Tire Recycling Management Association of Alberta
provided funding through the Alberta Centre for Injury
Control and Prevention. Harold Hoffman reviewed the initial
proposal and provided comments.”
http://www.synturf.org/images/birkholz_crumb_safety_pap
er.pdf
Enviro-Test Laboratories,
Edmonton, Alberta,
Canada.
Page | 28
Recommendations for Studies to be Added
Study
Author(s)
Group(s)
Conflict of
Interest?
Reason for
Conflict of Interest
Notes
Crumb Rubber Components
42. News Release: Many
carcinogens found in
Yale analysis of crumb
rubber infill and
playground mulch
surfacing
Benoit, G. (2015)
Yale University for
Environment and Human
Health, Inc.
N
N/A
EHHI is a non-profit organization.
Yale researchers document that no toxicological information
exists for approximately half of the 96 identified chemicals in
crumb rubber; inadequate information is available on many
other chemicals.
http://seas.yale.edu/news-events/news/study-led-gabourybenoit-looks-chemicals-synthetic-playing-surfaces-0
http://www.ehhi.org/turf/findings0815.shtml
http://www.ehhi.org/turf/metal_analysis2016.shtml
43. Pilot study:
characterizes chemical
components of artificial
turf, potential inhalation
and dermal exposure to
these chemicals
Harari, H. (Underway as
of 2015)
Children's Environmental
Health Center at Mount
Sinai Hospital
N
N/A
http://www.slideshare.net/KatherineSouthwick1/cehc2015a
nnualreport
44. Scrap Tire Mulch on
Duluth Public Schools'
Playgrounds
North Shore Analytical
for Duluth Parents for
Healthy Playgrounds
(2015).
North Shore Analytical for
Duluth Parents for Healthy
Playgrounds
N
N/A
Kirsling raised funds through a GoFundMe website
Page | 29
Recommendations for Studies to be Added
Study
45. Identification of
Benzothiazole
Derivatives and
Polycyclic Aromatic
Hydrocarbons as Aryl
Hydrocarbon Receptor
Agonists Present in Tire
Extracts
Author(s)
He G1, Zhao B, Denison
MS. Environ Toxicol
Chem. 2011 August ;
30(8): 1915–1925.
doi:10.1002/etc.581
Group(s)
Conflict of
Interest?
Department of
Environmental Toxicology,
University of California,
Davis, California
N
1
Reason for
Conflict of Interest
N/A
Notes
“Leachate from rubber tire material contains a complex
mixture of chemicals previously shown to produce toxic and
biological effects in aquatic organisms. The ability of these
leachates to induce Ah receptor (AhR)-dependent
cytochrome P4501A1 expression in fish indicated the
presence of AhR active chemicals, but the responsible
chemicals and their direct interaction with the AhR signaling
pathway were not examined. Using a combination of AhRbased bioassays, we have demonstrated the ability of tire
extract to stimulate both AhR DNA binding and AhRdependent gene expression and confirmed that the
responsible chemicals were metabolically labile. The
application of CALUX (chemical-activated luciferase gene
expression) cell bioassay-driven toxicant identification
evaluation not only revealed that tire extract contained a
variety of known AhR-active polycyclic aromatic
hydrocarbons but also identified 2-methylthiobenzothiazole
and 2-mercaptobenzothiazole as AhR agonists. Analysis of a
structurally diverse series of benzothiazoles identified many
that could directly stimulate AhR DNA binding and
transiently activate the AhR signaling pathway and identified
benzothiazoles as a new class of AhR agonists. In addition to
these compounds, the relatively high AhR agonist activity of
a large number of fractions strongly suggests that tire
extract contains a large number of physiochemically diverse
AhR agonists whose identities and toxicological/biological
significances are unknown.”
Page | 30
Recommendations for Studies to be Added
Study
46. Release of Polycyclic
Aromatic Hydrocarbons
and Heavy Metals from
Rubber Crumb in
Synthetic Turf Fields:
Preliminary Hazard
Assessment for Athletes
Author(s)
Marsili L, Coppola D,
Bianchi N, Maltese S,
Bianchi M (2015) J
Environ Anal Toxicol 5:
265. doi:10.4172/21610525.1000265
Group(s)
1
Department of Physical
Sciences, Earth and
Environment, Siena
University, Via Mattioli 4,
53100 Siena, Italy.
2
Department of Political
Science and International,
Siena University, Via Mattioli
10, 53100 Siena, Italy.
Conflict of
Interest?
N
Reason for
Conflict of Interest
N/A
Notes
“Synthetic turf, made with an infill of rubber crumb from
used tyres or virgin rubber, is now common in many sporting
facilities. It is known that it contains compounds such as
polycyclic aromatic hydrocarbons (PAHs) and heavy metals.
We evaluated in nine samples of rubber crumb the total
content of some heavy metals (Zn, Cd, Pb, Cu, Cr, Ni, Fe)
normally found in tyres by microwave mineralization and the
levels of the 14 US EPA priority PAHs by Soxhlet extraction
and HPLC analysis. The results showed high levels of PAHs
and zinc in all rubber crumb samples compared to rubber
granulate limits set by Italian National Amateur League
(LND). Following the precautionary principle, a risk
assessment at 25°C was done, using the Average Daily Dose
(ADD) assumed by athletes, expressed in terms of mass of
contaminant per unit of body weight per day (mg/kg day),
and the Lifetime Average Daily Dose (LADD) and then
evaluating the Hazard Index (HI) and the Cumulative Excess
Cancer Risk (∑ECR). In the different rubber granulates
samples the HI ranges from a minimum of 8.94×10-7 to a
maximum of 1.16×10-6, while the ∑ECR ranges from a
minimum of 4.91×10-9 to a maximum of 1.10×10-8.
Finally, the aim of this study was to estimate the “hazard”
for athletes inhaling PAHs released at the high temperatures
this synthetic turf may reach. Then a sequence of proofs was
carried out at 60°C, a temperature that this rubber crumb
can easily reach in sporting installations, to see whether PAH
release occurs. The toxicity equivalent (TEQ) of evaporates
from rubber crumb is not negligible and represents a major
contribution to the total daily intake of PAHs by different
routes.”
Page | 31
Recommendations for Studies to be Added
Study
47. Hazardous organic
chemicals in rubber
recycled tire
playgrounds and pavers
Author(s)
Llompart, M.a, SanchezPrado, L. a, Lamas, J. P. a,
Garcia-Jares C.a, Roca,
E.b, Dagnac, T.c (2013).
Chemosphere, 423-431.
Group(s)
Conflict of
Interest?
Departamento de Quimica
Analitica, Nutricion y
Bromatologia, Facultad de
Quimica, Universidad de
Santiago de Compostela,
Santiago de Compostela
15782, Spain.
N
a
b
Departamento de
Ingeniería Química, Escuela
de Ingenieria, Universidad
de Santiago de
Compostela, Santiago de
Compostela 15782, Spain.
c
INGACAL (Galician
Institute for Food Quality)–
CIAM (Agrarian and
Agronomic Research
Centre), Laboratory of
Food/Feed Safety and
Organic Contaminants,
Apartado 10, E-15080 A
Coruña, Spain.
Reason for
Conflict of Interest
N/A
Notes
“In this study, the presence of hazardous organic chemicals
in surfaces containing recycled rubber tires is investigated.
Direct material analyses using solvent extraction, as well as
SPME analysis of the vapour phase above the sample, were
carried out. Twenty-one rubber mulch samples were
collected from nine different playgrounds. In addition, seven
commercial samples of recycled rubber pavers were
acquired in a local store of a multinational company. All
samples were extracted by ultrasound energy, followed by
analysis of the extract by GC–MS. The analysis confirmed the
presence of a large number of hazardous substances
including PAHs, phthalates, antioxidants (e.g. BHT, phenols),
benzothiazole and derivatives, among other chemicals. The
study evidences the high content of toxic chemicals in these
recycled materials. The concentration of PAHs in the
commercial pavers was extremely high, reaching values up
to 1%. In addition, SPME studies of the vapour phase above
the samples confirm the volatilisation of many of those
organic compounds. Uses of recycled rubber tires, especially
those targeting play areas and other facilities for children,
should be a matter of regulatory concern.”
*Corresponding author.
Tel.: +34 881814225.
E-mail address:
maria.llompart@usc.es
(M. Llompart)
Page | 32
Recommendations for Studies to be Added
Study
48. Empire State Consumer
Project 2015 Children's
Products Safety Report
Author(s)
Chittenden, C., Muir, E.
(2015). (Artificial Turf
pp. 18-20, Artificial
Mulch pp.21-22,
Attachments pp. 32-33.)
Group(s)
Empire State Consumer
Project, Inc.
Conflict of
Interest?
N
Reason for
Conflict of Interest
N/A
Notes
Non-profit organization
"The attached table (last page of attached) lists results
obtained on materials used in rubber mulch. Rubber mulch
is made of ground recycled tires like those used for making
artificial turf fields. The mulch is advertised as a garden and
playground mulch. Some products are marked “Playground
safety tested.” There are no government standards for
testing the safety of rubber mulch for playground use or for
garden use. The East Rochester, New York school district is
using Nike Grind for the infill on its artificial turf field.
Among other health effects caused by arsenic and cadmium,
both are known to be human carcinogens (cancer
classification NTP). Zinc is known to cause respiratory and
digestive health effects, and pancreatic and kidney damage
http://www.atsdr.cdc.gov/substances/index.asp. Inhalation,
ingestion, and dermal exposure to toxic chemicals are all
concerns where children play. Where foods are grown for
human consumption, toxic chemicals potentially leaching
into plants is also a concern that warrants study.
We have included only chemicals that show levels higher
than current acceptable limits. The ‘limits’ are NYS DEC soil
cleanup guidelines for brownfields. These are minimum
requirements and do not imply safety. Limits must be
adjusted downward when multiple chemicals are found
together. US EPA limits for groundwater and wildlife
exposure have not been included.
Although some chemicals show values below equipment
detection limits, in some cases, detection limits may be
higher than DEC limits; these chemicals warrant further
analysis."
Page | 33
Recommendations for Studies to be Added
Study
Author(s)
Group(s)
Conflict of
Interest?
Reason for
Conflict of Interest
American Lung Association
(2015)
N
N/A
N
N/A
Notes
Particulate Matter (PM)
49. American Lung
Association, non-profit:
State of the Air 2015:
Particle Pollution
American Lung
Association. (2015).
This article explains health risks associated with respirable
dust, or the PM 10 and PM 2.5 and carbon black that you
have been hearing about. (PM size 10 microns, or 2.5
microns and smaller, is abbreviated as PM 10 and PM 2.5.)
Short-term exposure risks include increased severity of
asthma attacks in children; increased hospitalizations for
asthma in children; death from respiratory and
cardiovascular disease, including stroke; and increased
numbers of heart attacks.
Toxicity
50. Carbon nanotubes
introduced into the
abdominal cavity of
mice show asbestos-like
pathogenicity in a pilot
study
Poland Craig A, et al.
Nature Nanotechnology
2008. 3: 423-428.
51. Supplementary
Guidance for
Conducting Health Risk
Assessment of Chemical
Mixtures
EPA Risk Assessment
Forum Technical Panel.
(2000). Washington DC.
U.S. Environmental
Protection Agency
Thus far, risk assessments on crumb rubber, a complex
chemical mixture, have not been conducted in a manner
consistent with these guidelines.
The guidelines define a complex mixture thus: “A mixture
containing so many components that any estimation of its
toxicity based on its components’ toxicities contains too much
uncertainty and error to be useful…Risk assessments of
complex mixtures are preferably based on toxicity and
exposure data on the complete mixture...” Appendix B p.2
Page | 34
Recommendations for Studies to be Added
Study
Author(s)
52. Assessing the
carcinogenic potential
of low-dose exposures
to chemical mixtures in
the environment: the
challenge ahead
Goodson, W. H., Lowe,
L., & al, e. (2015).
Carcinogenesis, S254S296.
53. Toxicity and metabolism
of methylnaphthalenes:
Comparison with
naphthalene and 1nitronaphthalene
54. Automobile Tires a
Potential Source of
Highly Carcinogenic
Dibenzopyrenes to the
Environment
Group(s)
(Over 141 affiliations; see
hyperlink.)
Conflict of
Interest?
Reason for
Conflict of Interest
N
N/A
Lin, C. Y., Wheelock, A.
M., Morin, D., Baldwin,
R. M., & al, e. (2009).
Toxicology, 16-27.
N
N/A
Ioannis Sadiktsis, et al.
Environ. Sci. Technol.
Feb 21, 2012, 46,
3326−3334.
N
N/A
Notes
This paper reports that the World Health Organization and
the International Agency for Research on Cancer (IARC)
suggest that the fraction of cancers attributable to toxic
environmental exposures is between 7% and 19% of all
cancers; other sources suggest the proportion of cancers
due to unknown causes may be much higher. Supported by
over 500 references, this paper presents evidence of
physiologic mechanisms that predict/explain how chemicals
that are not carcinogens when acting alone (heavy metals,
endocrine disruptors, and others) can collectively work
through different pathways (such as immune suppression) at
different points in time to ultimately induce cancer. Note:
Other articles in the supplement would also prove relevant.
“…Through the release of PAHs from stockpiled scrap tires,
PAH emissions from pyrolysis of scrap tires or leaching of
PAHs from recycled tire rubber material, tires are a source of
environmental pollution of PAHs throughout their entire
lifecycle.”
Page | 35
Recommendations for Studies to be Added
Study
Author(s)
Group(s)
Conflict of
Interest?
Reason for
Conflict of Interest
Notes
Health Effects
55. Determination of
Microbial Populations in
a Synthetic Turf System
Bass, Jason J. and
Hintze, David W. (2013)
Weber State University
N
N/A
Sample Size of Infill Material Being Tested
Penn State-.075 Grams
Weber State-10 Grams
Collection Time Frame of Samples
Penn State-15 days, June only.
Weber State-Once a week for 14 weeks. Very controlled
samples.
Location of Samples
Penn State-“High Use” and “Low Use” areas.
Weber State-1) Sideline, 2) 50 Yard Line and 3) end of
field. 3 locations and same locations on both new and old
field being sampled.
Time of Study
Penn State-Height of Summer when field temperatures
were at the peak.
Weber State-Height of the Actual Football Season when
the fields were in use.
Technical Issues of reasons why the Penn St study did not
find Pathogens (Staph)
Penn State-Shortened agitation times for the samples
(shortened time means less chance for full discovery of
Pathogens, technical please read study)
Penn State-Failed to Isolate S. Aureus (Staph) on samples
Page | 36
Recommendations for Studies to be Added
Study
Author(s)
Group(s)
Conflict of
Interest?
Infectious Diseases
Division, Hartford
2
Connecticut Active
Bacterial Core Surveillance
Project, Connecticut
Department of Public
Health, Hartford
3
Student Health Services of
Sacred Heart University,
Fairfield, Connecticut
4
Epidemic Intelligence
Service Program, Centers
for Disease Control and
Prevention, Atlanta, Georgia
5
Division of Public Health
Laboratories, Minnesota
Department of Public
Health, Minneapolis,
Minnesota
6
Los Angeles County
Department of Health
Services, Los Angeles,
California
N
N/A
“Potential conflicts of interest. All authors: No conflict.”
“Players who sustained turf burns had a risk of infection that
was 7 times higher than that for players without turf burns…
MRSA was likely spread predominantly during practice play,
with skin breaks facilitating infection. Measures to minimize
skin breaks among athletes should be considered, including
prevention of turf burns and education regarding the risks of
cosmetic body shaving. MRSA-contaminated pool water may
have contributed to infections at covered sites, but small
numbers limit the strength of this conclusion. Nevertheless,
appropriate whirlpool disinfection methods should be
promoted among athletic trainers.”
Y
Penn State has a
partnership with
FieldTurf.
Lowest temp in a test of synthetic fields on an average 76
degree air temp day...154. See pp. 12-14 for outdoor
testing."No product in this test substantially reduced surface
temperature compared to the traditional system of green
fibers filled with black rubber in both the indoor and
outdoor test. Reductions of five or even ten degrees offer
little advantage when temperatures still exceed 150 °F. Until
temperatures can be reduced by at least twenty or thirty
degrees for an extended period of time, surface temperature
will remain a major issue on synthetic turf fields."
1
56. A High-Morbidity
Outbreak of MethicillinResistant
Staphylococcus aureus
among Players on a
College Football Team,
Facilitated by Cosmetic
Body Shaving and Turf
Burns
Elizabeth M. Begier1,4,
Kasia Frenette1, Nancy L.
Barrett1,2, Pat Mshar1,
Susan Petit1,2, Dave J.
Boxrud5, Kellie WatkinsColwell3, Sheila
Wheeler3, Elizabeth A.
Cebelinski5, Anita
Glennen5, Dao
Nguyen4,6, James L.
Hadler1, The
Connecticut
Bioterrorism Field
Epidemiology Response
Teama
57. Synthetic Turf Heat
Evaluation – Progress
Report
Penn State’s Center for
Penn State’s Center for
Sports Surface Research. Sports Research
(January 2012).
Reason for
Conflict of Interest
Notes
Page | 37
Recommendations for Studies to be Added
Study
Author(s)
58. Synthetic Surface Heat
Studies
Williams, C.F., and
Pulley, G.E. (2002)
59. Associations between
health effects and
particulate matter and
black carbon in subjects
with respiratory disease
Group(s)
Brigham Young University
Conflict of
Interest?
Reason for
Conflict of Interest
N
N/A
Jansen Karen L., et al.
Environ Health Perspect.
2005. 113:12: 1741–
1746.
N
N/A
60. Acute respiratory
inflammation in children
and black carbon in
ambient air before and
during the 2008 Beijing
Olympics
Lin W., et al. Environ
Health Perspect. 2011
Oct;119:10:1507-12.
N
N/A
61. Association of black
carbon with cognition
among children in a
prospective British
cohort study
Sugilia S. Franco, et al.
American Journal of
Epidemiology 2007,
167:3:280-286.
N
N/A
62. Does traffic exhaust
contribute to the
development of asthma
and allergic sensitization
in children: findings
from recent cohort
studies
Lennart, B. Bertil, F.
Environmental Health
2009, 8:17.
N
N/A
Notes
Page | 38
Recommendations for Studies to be Added
Study
Author(s)
Group(s)
Conflict of
Interest?
Reason for
Conflict of Interest
63. Occupational Exposure
in the Rubber
Manufacturing Industry
IARC Monographs
Volume 100F,
Supplementary Web
Tables, Section 2,
Cancer in Humans. IARC
Monographs on the
Evaluation of
Carcinogenic Risks to
Humans.
World Health Organization
(WHO), International
Agency for Research on
Cancer (IARC
N
N/A
64. Tire-Derived Flooring
Chemical Emissions
Study and Indoor
Reference Exposure
Levels (iRELs)
Office of Environment
Health Hazard
Assessment's (OEHHA),
CalRecycle, California
Department of Public
Health's (CDPH). 2011.
Office of Environment
Health Hazard
Assessment's (OEHHA),
CalRecycle, California
Department of Public
Health's (CDPH)
Y
CalRecycle, as part of
OEHHA, promotes
recycling used tires.
65. Dermal exposure to
chemicals in the
workplace: just how
important is skin
absorption?
Semple, S. Department
of Environmental &
Occupational Medicine,
University of Aberdeen,
Foresterhill, Aberdeen
AB25 2ZD, UK. Occup
Environ Med
2004;61:376-382
doi:10.1136/oem.2003.
010645.
Department of
Environmental &
Occupational Medicine,
University of Aberdeen
N
N/A
Notes
These web tables formed part of the original submission and
have been peer reviewed. They are posted as supplied by
the Working Group. Readers are requested to report any
errors to: edit-vol100F@iarc.fr.
Page | 39
Recommendations for Studies to be Added
Study
66. Nanotechnology:
Toxicologic Pathology
Author(s)
Ann F. Hubbs,1 Linda M.
Sargent,1 Dale W.
Porter,1 Tina M. Sager,1
Bean T. Chen,1 David G.
Frazer,1 Vincent
Castranova,1 Krishnan
Sriram,1 Timothy R.
Nurkiewicz,2 Steven H.
Reynolds,1 Lori A.
Battelli,1 Diane
Schwegler-Berry,1
Walter McKinney,1 Kara
L. Fluharty,1 and Robert
R. Mercer1
Toxicol Pathol. Author
manuscript; available in
PMC 2015 Dec 1.
Published in final edited
form as:
Toxicol Pathol. 2013
Feb; 41(2): 395–409.
Group(s)
Conflict of
Interest?
Health Effects Laboratory
Division, National Institute
for Occupational Safety and
Health, Morgantown, West
Virginia
N
1
Reason for
Conflict of Interest
Notes
N/A
2
Center for Cardiovascular
and Respiratory Sciences,
West Virginia University
School of Medicine,
Morgantown, West Virginia
Address correspondence
to: Ann F. Hubbs, Health
Effects Laboratory Division,
National Institute for
Occupational Safety and
Health, Centers for Disease
Control and Prevention,
1095 Willowdale Rd,
Morgantown, WV 26505;
Email: vog.cdc@sbbuha
Published online 2013
Feb 6.
doi: 10.1177/01926233
12467403
PMCID: PMC4665093
NIHMSID:
NIHMS723787
Page | 40
Recommendations for Studies to be Added
Study
Author(s)
Group(s)
Conflict of
Interest?
Reason for
Conflict of Interest
67. nanoCOLT - Long-term
effect of modified
carbon black
nanoparticles on
healthy and damaged
lungs
Prof. Dr. Bernd Müller,
Philipps-University of
Marburg, Marburg (DE)
FB 20 Medizin und
Universitätsklinikum - Klinik
für Innere Medizin Pneumologie,
Press Release
Philipps-University of
(16.10.2014, in GERMAN Marburg, Marburg (DE),
only). Biowissenschaftler Institut für Anatomie - AG
erforschen
Barriere-Organe,
Auswirkungen von
University Lübeck, Lübeck
Nanopartikeln (DE), Fraunhofer Institute
for Toxicology and
Marburger
Experimental Medicine
Lungenspezialist leitet
(ITEM), Hannover (DE),
bundesweiten
Forschungsverbund (uni- Engler-Bunte-Institute Division of Combustion
marburg.de)
Technology (EBI vbt),
Karlsruhe Institute of
Technology (KIT), Karlsruhe
(DE), Experimental
Pneumology, Research
Center Borstel - LeibnizCenter for Medicine and
Biosciences, Borstel (DE)
N
N/A
68. Toxicological Profile for
Synthetic Vitreous
Fibers
Syracuse Research
Corporation for U.S.
Department of Health
and Human Services,
Public Health Service,
Agency for Toxic
Substances and Disease
Registry. 2004.
N
N/A
Syracuse Research
Corporation for U.S.
Department of Health and
Human Services, Public
Health Service, Agency for
Toxic Substances and
Disease Registry.
Notes
Page | 41
Recommendations for Studies to be Added
Study
Author(s)
Group(s)
Conflict of
Interest?
69. International Agency for
Research on Cancer
(IARC) - Summaries &
Evaluations: The Rubber
Industry (Group 1)
International Agency for
Research on Cancer
(IARC).
International Agency for
Research on Cancer (IARC).
N
N/A
70. Work Environments and
Exposure to Hazardous
Substances in Korean
Tire Manufacturing
Naroo Lee1 Byung-kyu
Lee,2 Sijeong Jeong,2
Gwang Yong Yi,1 and
Jungah Shin1
Saf Health Work. 2012
Jun; 3(2): 130–139.
Published online 2012
Jun 8.
doi: 10.5491/SHAW.201
2.3.2.130
PMCID: PMC3440462.
1
N
N/A
Occupational Safety and
Health Research Institute,
Incheon, Korea.
2
Korea Occupational Safety
and Health Agency,
Incheon, Korea.
Corresponding author.
Correspondence to: Naroo
LEE. Occupational Safety
and Health Research
Institute, Korea
Occupational Safety and
Health Agency, 478,
Munemi-ro, Bupyeong-gu,
Incheon 403-711, Korea.
Tel: +82-32-510-0802, Fax:
+82-32-518-0864, Email:
ten.ahsok@eelooran
Reason for
Conflict of Interest
Notes
Page | 42
Recommendations for Studies to be Added
Study
Author(s)
Group(s)
Conflict of
Interest?
71. Urban Airborne
Particulate Matter:
Origin, Chemistry, Fate
and Health Impacts
Springer-Verlag Berlin
Heidelberg. Edited by
Fathi Zereini, Clare L. S.
Wiseman. 2010.
Institute for Atmospheric
and Environmental
Sciences. Department of
Environmental Analytical
Chemistry, J.W. GoetheUniversity. Adaptation and
Impacts Research Group.
Institute for Environmental
Studies. University of
Toronto.
N
N/A
72. Effects of Chemical Coexposures at Doses
Relevant for Human
Safety Assessments
European Centre for
Ecotoxicology and
Toxicology of Chemical
(ECETOC). Technical
Report No. 115. ISSN0773-8072-115 (print).
ISSN -2079-1526-115
(online). Brussels, July
2012.
European Centre for
Ecotoxicology and
Toxicology of Chemical
(ECETOC)
N
N/A
73. Leaching of Phenols
from Tire Shreds in a
Noise Barrier
Håøya, A.O.1, Aabøe, R.2,
Edeskär, T.3.
1
N
N/A
RAMBØLL.
Reason for
Conflict of Interest
Notes
2
Norwegian Public Roads
Authorities, (NPRA)
Norway.
3
Luleå University of
Technology, Sweden.
Page | 43
Other Data for Consideration
Title
Author(s)
Group(s)
Conflict of
Interest?
Reason for
Conflict of Interest
Notes
News Reports/Video
74. Field Turf admits lead is
in their [artificial turf]
product but opposes
signs to inform the
public
YouTube posted (April 7,
2016).
SF Parks
N
N/A
Video
75. NBC News - How Safe is
the Artificial Turf on
Your Child's Sports Field
? (cancer)
Gosk, S.
NBC News
N
N/A
Video
76. Is Rubber Mulch a Safe
Surface for Your Child's
Playground?
Rappleye, H., Gosk, S.,
Monahan, K., Alba, M.
NBC News
N
N/A
Video
77. E:60 Sports Matter: Turf
Wars: How Safe Are The
Fields Where We Play?
Foudy, J. (November 24,
2015).
ESPN
N
N/A
Video
“March 11, 2016 testimony by Field Turf Mid-Atlantic Sales
representative to the Ways and Means Committee of the
Maryland General Assembly in a hearing on HB883 seeking
to require informational signs at the entrance to artificial
turf fields regarding precautions recommended by the CDC
to safeguard children from exposures to lead. When asked
by Delegate Mary Washington (D43, Baltimore City) about
the status of a law suit against Field Turf regarding lead
content, and whether Field Turf's artificial turf products
contain lead, the response was ‘Yes, there is lead in our
product.’” Yet Field Turf opposes HB883.”
Page | 44
Other Data for Consideration
Title
Author(s)
Group(s)
Conflict of
Interest?
Reason for
Conflict of Interest
Notes
78. Children and synthetic
turf
Forman, J., Landrigan,
P., Brown, D., Michels,
K., Alderman, N.
Mount Sinai School of
Medicine, Children's
Environmental Health
Center at Mount Sinai
Hospital, Environment and
Human Health, Inc.
N
N/A
Video includes pediatricians, toxicologists and others
discussing plastic turf in addition to other toxins.
79. The Health Hazards of
Artificial Turf Crumb
Rubber Playing Fields
Landrigan, P.
Children's Environmental
Health Center at Mount
Sinai Hospital
N
N/A
Video
80. Are we treating women
athletes like guinea
pigs?
International News
Review
International News Review
N
N/A
Video
81. Playground Hazards: Are
Rubber Chips Toxic?
Enninga, H.
WDIO-TV, LLC
N
N/A
Video
"’He would come home with a black dust on him,’ Kirsling
said. ‘It would be all over his legs. I mean, his legs would be
black if he wore shorts.’
Then one day this May, Kirsling said he realized those
playground drawbacks might be more serious.
‘(Jack) would come home and he would blow his nose, and it
would be gray from the dust,’ Kirsling said. He would say, 'I
have a headache. I have a scratchy throat.'
After Kirsling spoke to other parents who had also noticed
similar symptoms, his initial endearment turned to alarm.
‘It seems very odd that more than one child is coming home
and saying the same things,’ Kirsling said. ‘Something
doesn't seem right here.’"
See: Scrap Tire Mulch on Duluth Public Schools' Playgrounds
Page | 45
Other Data for Consideration
Title
82. Student suffers severe
injuries during
punishment
Author(s)
Smith, M.
Group(s)
ABC 7 KVIA
Conflict of
Interest?
N
Reason for
Conflict of Interest
N/A
Notes
Video
“It took less than 200 yards for Brandon Chacon, 15, to
bruise and blister his hands beyond recognition Tuesday.
Chacon, taking part in a football drill known as "bear crawls,"
is now unable to play football all because of a punishment
administered by an assistant coach…
On Tuesday the temperature was around 96 degrees...
Studies done by Penn State University show that turf, like
the kind on El Dorado's new football field, can see
temperatures 35-55 degrees hotter than normal grass.
Previous studies done by Texas A&M show turf can reach
temperature above 160 degrees in the state of Texas.”
83. Football player burns
hand on hot turf after
coach’s practice
punishment
Newton, J.
News 8 WTNH
N
N/A
Video
“…players at Stratford High, forced to crawl on the artificial
turf with their bare hands during the September heat wave.
Pictures…showing one student-athlete’s hand with a huge
blister covering most of his palm. Apparently caused by the
extreme temperature of the turf, against his bare skin.
‘Ridiculous. That was insane. That can cause an infection,’
said Felicia Murray, who has a daughter at the school.
Our own thermometer showed temperatures of the artificial
grass hovering around 150 degrees.”
Page | 46
Other Data for Consideration
Title
Author(s)
Group(s)
Conflict of
Interest?
Reason for
Conflict of Interest
Notes
Lindstrum, A.
Playground
Underlayment
Committee.
Playground Underlayment
Committee
N
N/A
“The Crumb Rubber underlayment was unacceptable to
many parents for a variety of reasons. It off-gassed heavily
year-round, though it was much stronger in hot weather.
The smell had a strong chemical quality to it, similar to
industrial solvents and tires. A number of adults and children
reacted strongly to the Crumb Rubber after being on the
playground for only minutes. Some had allergic reactions
and had to get medical attention. Others got headaches and
nausea. Enough people reacted strongly enough that the
school had an unusually difficult time scheduling volunteers
for playground duty during recess…”
85. Written Testimony
before the Connecticut
General Assembly on
Children
Wright, R., Evans, S.
(2016).
Children's Environmental
Health Center at Mount
Sinai Hospital
N
N/A
Testimony in Support of Raised Bill 5139, An Act Concerning
the Use of Recycled Tire Rubber at Municipal and Public
School Playgrounds.
“Given the hazards associated with recycled tire rubber, it is
our recommendation that these products never be used as
surfaces where children play.”
86. Dr. Landrigan Answers
Back-to-School
Questions
Landrigan, P.
Children's Environmental
Health Center at Mount
Sinai Hospital
N
N/A
87. Reducing Environmental
Cancer Risk: What We
Can Do Now
President’s Cancer
Panel. (2010). Bethesda:
U.S. Department of
Health and Human
Services.
N
N/A
Other Testimonial
84. Life After Crumb Rubber
Overviews
Page | 47
Other Data for Consideration
Title
Author(s)
88. Substantial contribution
of extrinsic risk factors
to cancer development
Wu, S., Powers, S., Wei,
Z., & Hannun, Y. A.
(2016). Nature, 43-47.
89. Artificial Turf: Exposures
to Ground Up Rubber
Tires on Athletic Fields
and Playgrounds
Environment and
Human Health, Inc.
(EHHI)
90. Overview of the Risks of
Synthetic Turf Fields
91. Fact Sheet: CPSC, EPA &
CDC on Artificial Turf
Safety & Precautions
Group(s)
Conflict of
Interest?
Reason for
Conflict of Interest
Notes
N
N/A
Environment and Human
Health, Inc. (EHHI)
N
N/A
Non-profit organization
Brown, D.
Environment and Human
Health, Inc. (EHHI). (April 4,
2015).
N
N/A
Non-profit organization
Dr. David Brown, among other qualifications, is a former
Deputy Director of The Public Health Practice Group of
ATSDR at the CDC. In this article, he details weaknesses in
scientific studies and holes in the “collective database” to date.
This overview outlines why children are specifically at higher
risk to toxins, and why he and many other epidemiologists,
toxicologists, and public health officials are concerned about
crumb rubber. Instead of conducting research proactively,
prior to health effects, Dr. Brown asserts that “a natural
experiment is being conducted in which thousands of
children are being exposed on playing fields to rubber 1)
known to contain carcinogens and 2) documented to
produce cancer in workers in the tire manufacturing plants.”
Safe Healthy Playing
Fields Coalition. (July,
2015).
Safe Healthy Playing Fields
Coalition
N
N/A
Non-profit organization
The Consumer Product Safety Commission (CPSC) and the
Environmental Protection Agency (EPA) have retracted prior
assurances regarding artificial turf, in acknowledgement of
multiple concerns raised by the scientific community and the
public. The Centers for Disease Control and Prevention (CDC)
identifies artificial turf as one of seven sources of lead
exposure for children.
Page | 48
Other Data for Consideration
Title
92. Crumb Rubber
Author(s)
Gilbert, S.
93. Tire Crumb Synthetic
Turf Study Reference
Materials
Group(s)
Conflict of
Interest?
Reason for
Conflict of Interest
Notes
Toxipedia
N
N/A
Provides thorough overview of crumb rubber.
QWERTY Media Resources
N
N/A
“This resource is being posted and maintained for
educational, journalistic, and reference purposes. The
content continues to be vetted and updated for factual
accuracy.” Provides thorough overview of synthetic turf
including history.
Bloomberg L.P.
N
N/A
Player suffers from MRSA recurrence via turf burn/Texas has
16x higher player MRSA infection rate than national avg.
“’Mom, I can't move my arms or legs.’” Boone, 16, wide
receiver, ‘was suffering from a recurrence of...MRSA, which
his doctor said he got through an abrasion from playing on
artificial turf,’ Baker said. Texas has artificial turf at 18
percent of its high school football stadiums, according to
Web site Texasbob.com. It also has an MRSA infection rate
among players that is 16 times higher than the estimated
national average, according to three studies by the Texas
Department of State Health Services.”
N
N/A
“The JP Moms group’s efforts to get rid of the rubber mulch
were based on fears that regular exposure to volatile organic
compounds in the tires might have long-term negative
health impacts. Some also said that exposure to the tires
caused them to have respiratory issues, and complained that
the light-weight material is easily spread throughout the
park and carried home in children’s’ clothes.”
News Articles
94. Texas Football
Succumbs to Virulent
Staph Infection From
Turf
Epstein, V. Bloomberg.
(December 21, 2007).
95. DCR removes tire mulch
from local playgrounds
Oliveira, R. Jamaica Plain Jamaica Plain Gazette
Gazette. (December 3,
2010).
Page | 49
Other Data for Consideration
Title
Author(s)
Group(s)
Conflict of
Interest?
Reason for
Conflict of Interest
Notes
96. Feds promote artificial
turf as safe despite
health concerns
Frank, T. USA Today.
(March 16, 2015).
USA Today.
N
N/A
The article describes how the Synthetic Turf Council has
mischaracterized the results of some studies on artificial turf
fields and has ignored scientists’ warnings about children
possibly ingesting lead in turf and tire crumbs. The article
describes the differing opinions of different health
departments, and how the EPA ignored internal warnings
from its scientists. It also discusses how the CPSC
pronounced artificial turf, ‘safe to play on,’ whereas the CDC
listed artificial turf as one of the top sources of lead
exposure, along with paint and costume jewelry, for
children.
97. Critics say EPA played
dual role in recycled tire
controversy
Gutierrez, M. San
Francisco Chronicle.
(February 21, 2015).
San Francisco Chronicle.
N
N/A
This article discusses the EPA’s role in promoting the use of
crumb rubber and how it ignored its own scientist’s
concerns about the safety of using crumb rubber in
children’s play areas. It also discusses the apparent link
between crumb rubber and increased lymphoma and
leukemia incidence in soccer players.
98. Combinations of 'safe'
chemicals may increase
cancer risk, study
suggests
Harris-Lovett, S. Los
Angeles Times. (July 1,
2015).
Los Angeles Times
N
N/A
“…it’s plausible that consuming mixtures of these chemicals
is riskier than consuming any one individually.
‘To me, it’s not a surprise,’ said Birnbaum (Director of the
National Institute of Environmental Health Sciences, NIEHS,
of the NIH). Scientists know that small effects from many
chemicals can add up to cause other diseases, she said. For
instance, chemicals known as endocrine disruptors can lead
to neurological, immune system and reproductive problems,
among others.
Considering the safety of individual chemicals is a lot like
looking at the trees, but missing the forest, Birnbaum said.
Page | 50
Other Data for Consideration
Title
Author(s)
Group(s)
Conflict of
Interest?
Reason for
Conflict of Interest
Notes
When doing research to determine chemical safety, ‘we’ve
got to start thinking more about what reality is,’ she said.
This could mean sweeping changes in rules about the levels
of chemicals considered safe in drinking water, food, and air.
‘I’d like to see regulators and policy makers start looking at
the totality of the exposure instead of one chemical at a
time,’” she said.
Other Miscellaneous
99. Bioavailability Study
Models
N/A
N/A
N
N/A
When reading the details of all the bioavailability studies,
shreds and crumbs are used even when modeling
bioavailability in simulated lung fluid. Athletes are not
inhaling crumbs because the crumbs aren't floating in the
air! They are inhaling PM 2.5 and PM 10 which remain in the
lungs for days to months, not 24 hours. Similarly, ingestion is
crumbs and dust via hand to mouth behavior. A half inch
long shred is not a good model.
100.Human Rights Tribunal
of Ontario between
Players on National
Teams Participating in
the FIFA Women’s
World Cup Canada and
Canadian Soccer
Association, Fédération
Internationale de
Football Association
Boies, Schiller & Flexner
LLP
Boies, Schiller & Flexner
LLP
N
N/A
Synthetic turf named "inferior, dangerous and
discriminatory.”
Ryder, Wright, Blair &
Holmes LLP
Ryder, Wright, Blair &
Holmes LLP
Osler, Hoskin &
Harcourt LLP
Osler, Hoskin & Harcourt
LLP
(September 23, 2014).
Suit filed against FIFA January 2015: discrimination for
forcing to play on synthetic turf, World Cup 2015. The
women dropped it, due to FIFA's lack of response, and some
players said FIFA was going to retaliate against them
personally. After what the women experienced this year,
FIFA will NEVER again hold ANY World Cup on synthetic.
"1) by forcing them to compete on a surface that
fundamentally alters the way the game is played, (2) by
Page | 51
Other Data for Consideration
Title
Author(s)
Group(s)
Conflict of
Interest?
Reason for
Conflict of Interest
Notes
subjecting them to unique and serious risks of injury, and (3)
by devaluing their dignity, state of mind and self-respect as a
result of requiring them to play on a second-class surface
before tens of thousands of stadium spectators and a global
broadcast audience."
"No soccer player prefers FieldTurf. It pales in comparison to
a well-manicured grass pitch and takes some getting used
to."
"Turf exposes players to injuries that do not exist on natural
grass, such as skin lesions, abrasions and lacerations."
"In addition, artificial turf is uniquely vulnerable to
degradation upon installation as a result of the effects of
weathering, brushing and painting. CSA's site choice for the
finals is particularly susceptible to such adverse effects as it
is in use more than 200 days a year according to a report
published in 2013. This type of use makes artificial turf an
even more dangerous and difficult surface on which to play."
"force the top female soccer players in the world to play
their preeminent event under inferior, dangerous and
discriminatory conditions."
Also see p. 7 - turf burn, other dangers of synthetic turf.
101.Public Health Statement
for Lead
ATSDR. (August 2007).
CAS# 7439-92-1
ATSDR
N
N/A
Synthetic turf is known to give players horrible turf burns
frequently. It opens them up to more infection and
apparently, more lead exposure.
"More lead can pass through skin that has been damaged
(for example, by scrapes, scratches, and wounds)."
Page | 52
Other Data for Consideration
Title
Author(s)
Group(s)
Conflict of
Interest?
Reason for
Conflict of Interest
102.Surface Temperature of
Synthetic Turf
Penn State Center for
Penn State Center for
Sports Surface Research. Sports Surface Research
The Sportsturf Scoop:
Surface Temperature of
Synthetic Turf
Y
Penn State has a
partnership with
FieldTurf.
103.Miscellaneous Extreme
Temperature
Information
N/A
N
N/A
N/A
Notes
"Children less able to adapt to changes in
temperature...How does high surface temperature affect
field users?...Greater chance of heat-related issues.
Discomfort, dehydration, heat stroke." Some believe that
the crumb rubber infill is to blame for high temperatures.
However, no matter what type of infill is used, "Fibers are a
major contributor to high surface temperatures."
Sample Temperatures 2015 WWC
Air
Synthetic Turf
82 °F
77 °F
150 °F
From 86 °F to over
122 °F within
5 minutes.
131 °F
64 °F
129 °F
77 °F
109 °F
78 °F
120 °F
Sources:
https://en.m.wikipedia.org/wiki/2015_FIFA_Women%27s_World_
Cup
http://news.nationalpost.com/sports/soccer/womens-world-cupoffence-is-hot-and-the-fields-are-hotter-renewing-complaints-overartificial-turf
http://t.thestar.com/#/article/sports/soccer/2015/06/08/womensworld-cup-heats-up-as-pitch-level-mercury-soars.html
Page | 53
Other Data for Consideration
Title
Author(s)
Group(s)
Conflict of
Interest?
Reason for
Conflict of Interest
Notes
Kansas City, Missouri, Stanley-Durwood Soccer
Stadium
o
95 °F air, 159 °F synthetic turf
http://www.sportingnews.com/soccer/story
/2014-08-23/alex-morgan-nwsl-portlandthorns-hot-turf-field-uswnt
On a 98 °F (37 °C) day, MU’s Faurot Field had a
surface temperature of 173 °F (78 °C). The
temperature of the nearby natural grass was only
105 °F (41 °C). Even at head-level, the temperature
over the artificial turf was 138 °F (59 °C).
o
13
Dr. Brad Fresenburg, turfgrass specialist
from the University’s Division of Plant
Sciences, explains the danger of artificial turf
is that the rubber and plastic materials used
absorb more of sunlight’s heat energy than
natural grass, causing extraordinarily high
temperatures.
http://plasticfieldsfornever.org/ArtificialTurf
Booklet.pdf "Synthetic Turf Playing Fields
Present Unique Dangers,” Applied Turfgrass
Science, November 3, 2005.
Columbia, Missouri: Professor says “the fibers in a
synthetic field control the heat.”
According to a news report in the Columbia Missourian (6
September 2013), the Faurot Field at the University of
Missouri’s Memorial Stadium registered a high of 151
degrees during the school’s football season opener on
Page | 54
Other Data for Consideration
Title
Author(s)
Group(s)
Conflict of
Interest?
Reason for
Conflict of Interest
Notes
Saturday 31 August. “A team of turf experts used an infrared
thermometer to measure the heat coming off of the field in
Memorial Stadium.” “The National Weather Service in St.
Louis [had] reported Saturday'’ high temperature in
Columbia as 100 degrees, but that reading was on a natural
grass surface about 6 feet above the ground.” The service’s
hydrologist, Mark Fuchs, said “on an artificial-turf surface,
the temperatures jump.” The Division of Plant Sciences
professor Brad Fresenburg had this to say about the heating
of the artificial turf fields: sunlight plays a vital role in turf
temperature. “If we’ve got the sun in the air and there’s a
clear blue sky, we’re easily going to be in the 150s. It could
even be in the 160s.” “We know that the fibers in a synthetic
field control the heat.” “Artificial fields are made of
petroleum-based fibers that absorb heat as weather
conditions change. Mid- to late afternoon, when direct
sunlight has had its greatest effect on temperature, is
usually when turf fields reach high temperatures. Much like
vinyl in cars, the fibers capture and hold heat until the field
has time to cool. Often, the fields get so hot that the heat
can be felt through the soles of shoes.” “Temperature
readings vary depending on the kind of surface, amount of
cloud cover, humidity, wind speed and thermometer height
during the time of the reading. A slight breeze, for instance,
can change temperatures by 20 or 30 degrees.” “The clarity
of the sky and the time of day — that makes a huge
difference in what reflects off of that field as far as heat. The
sky, if it’s more clear blue, that’s going to allow the field to
absorb more heat.” Source: Beth Castle, “Artificial turf turns
up the heat on Faurot Field,” in the Columbia Missourian, 5
Page | 55
Other Data for Consideration
Title
Author(s)
Group(s)
Conflict of
Interest?
Reason for
Conflict of Interest
Notes
September 2013, at
http://www.columbiamissourian.com/a/165243/artificialturf-turns-up-the-heat-on-faurot-field/ . See pdf here.
Cooling the synthetic field only lasts 5 minutes
Irrigation of the synthetic turf had a significant result cooling
the surface from 174 °F to 85 °F but after five minutes the
temperature rebounded to 120 °F. The temperature rebuilt
to 164 °F after only twenty minutes.
http://plasticfieldsfornever.org/ArtificialTurfBooklet.pdf
Page | 56
Page 1 of 1
PUBLIC SUBMISSION
As of: 5/3/16 6:35 PM
Received: May 02, 2016
Status: Posted
Posted: May 03, 2016
Tracking No. 1k0-8pem-rune
Comments Due: May 02, 2016
Submission Type: Web
Docket: ATSDR-2016-0002
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill 0923-16PJ
Comment On: ATSDR-2016-0002-0003
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill ATSDR-2016-0002
Document: ATSDR-2016-0002-0069
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill 0923-16PJ Comment on
FR Doc # 2016-03305
Submitter Information
Name: Marc Elrich
Address: 20850
Email: councilmember.elrich@montgomerycountymd.gov
General Comment
See attached file(s)
Attachments
ME comment re federal review of AT
https://www.fdms.gov/fdms/getcontent?objectId=0900006481fa18ec&format=xml&showor... 5/3/2016
MONTGOME RY COUNTY CO UNCI L
R O C K V I L L E , M A R Y L AN D
Comment on “Collections Related to Synthetic Turf Fields with Crumb Rubber Infill”
From: Montgomery County, Maryland Councilmember Marc Elrich (At-large)
Date: May 2, 2016
As an elected official, I have been confronted with the issue of whether artificial turf playing
fields are safe and whether public funds should be used to construct and maintain these fields. I
represent the almost one million residents of Montgomery County, Maryland; our county is one
of the wealthiest and best-educated counties in the country. My staff and I have grappled with
questions surrounding artificial turf for years, and the more we have examined the issue, the
more we realize how little is known and how few questions can be adequately answered.
I appreciate the attempt by the federal agencies to tackle this issue, and on behalf of many of my
constituents and based on years of reviewing research and conversations with scientists, parks
managers, school administrators, elected officials, residents and other concerned individuals, I
make the following comments, observations and requests. I have five major points and then
follow them with additional information to support those points.
1. Clarify that the questions and goals outlined in this study will not answer the question of the
true safety/toxicity of AT with tire crumb infill. Characterizing chemical composition and
“exposure potential” are insufficient tools. This study will not satisfactorily answer the
question: are artificial turf fields safe for children to use over the long-term? An
epidemiological study is necessary. Only a long-term controlled epidemiological study could
provide meaningful answers about human safety. University of Washington soccer coach
Amy Griffin continues to collect names of soccer players, other athletes and other frequent
users of artificial turf fields (like marching band participants). This information raises
serious concern, and the federal agencies need to consider how they can collect information
that could analyze actual uses and outcomes.
2. Any and all toxicity studies must address and examine cumulative and combined effects of
toxic chemicals. Artificial turf contains a variety of chemicals that interact with each other
and in the body. Without studying their synergistic effects, the study will exclude some
important considerations. (See below for scientific comment on this issue.)
3. All potential health impacts should be viewed specifically and separately for children.
Studies should examine exposure for children. “Environmental exposure for children is quite
different. They take in much more of everything than adults. Their brains and nervous
systems are developing quite rapidly – referred to as “unique windows of vulnerability.”
(Joel Forman, MD, Mt. Sinai Medical School, Program Director of the Pediatric Residency
Program, Children's Environmental Health Center) Towards that end, I urge you to consult
extensively with Dr. Forman, Dr. Phillip Landrigan and other researchers associated with the
Childrens Environmental Health Center at Mt. Sinai Medical School.
4. For a federal study to be useful to local jurisdictions and residents, it must acknowledge and
address the myriad of issues and concerns that are inextricably intertwined. The chemical
composition of crumb rubber infill is an important issue, but it is not the only issue. The
blades, carpet, carpet backing and the color of the blades are all integral to any meaningful
assessment. Other issues should be examined and acknowledged: the heat impact for the
field users as well as serious environmental concerns, including the “heat island” effect and
impacts on waterways, aquatic life and wildlife.
5. Every step of the way, the involved federal agencies must be mindful of their possible biases.
I would refer you to the EPA website announcing this study: “Limited studies have not
shown an elevated health risk from playing on fields with tire crumb, but the existing studies
do not comprehensively evaluate the concerns about health risks from exposure to tire
crumb.” (https://www.epa.gov/chemical-research/federal-research-action-plan-recycled-tirecrumb-used-playing-fields) Such a statement is misleading and should be deleted. Results
from “limited studies” have been mixed. If “limited studies” refers to EPA’s prior studies, it
should be noted that they were not simply limited but also quite possibly flawed, and
therefore, not an appropriate basis for any general statements.
(http://www.peer.org/news/news-releases/epa-retracts-synthetic-turf-safety-assurances.html)
Additional information and commentary:
Regarding points 1 and 2 above:
How we think about levels of concern of chemicals is changing and evolving.
A recently published scientific paper, “What Can Epidemiological Studies Tell Us about the
Impact of Chemical Mixtures on Human Health?” explains:
“Although there is growing concern that exposure to chemical mixtures during critical
periods of human development could increase the risk of adverse health effects including
allergic diseases, cancer, neurodevelopmental disorders, reproductive disorders, and
respiratory diseases, researchers primarily study chemicals as if exposure occurs
individually. This one-chemical-at-a-time approach has left us with insufficient
knowledge about the human health effects of exposure to chemical mixtures.” [Emphasis
added.] http://ehp.niehs.nih.gov/15-10569/
Another study from 2015 suggests that the combination of “safe” chemicals may increase
cancer risk:
“Our analysis suggests that the cumulative effects of individual (non-carcinogenic)
chemicals acting on different pathways, and a variety of related systems, organs, tissues
and cells could plausibly conspire to produce carcinogenic synergies.” [Emphasis added.]
http://carcin.oxfordjournals.org/content/36/Suppl_1/S254.full?sid=db47f5ec-47a2-4879bf30-6da9c076003d#ref-8
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In commenting on the above study, the director of the National Institute of Environmental Health
Sciences, Linda Birnbaum (who was not involved in the study), said
“….We live in a chemical soup,…Considering the safety of individual chemicals is a lot like
looking at the trees, but missing the forest, Birnbaum said. When doing research to determine
chemical safety, “we’ve got to start thinking more about what reality is,” she said. This could
mean sweeping changes in rules about the levels of chemicals considered safe in drinking water,
food, and air. I’d like to see regulators and policy makers start looking at the totality of the
exposure instead of one chemical at a time,” she said. [Emphasis added.] (“Combinations of
'safe' chemicals may increase cancer risk, study suggests,” Los Angeles Times, by Sasha HarrisLovett, 7/1/15 http://www.latimes.com/science/sciencenow/la-sci-sn-chemical-combinationssafety-cancer-20150626-story.html)
While the 2015 report is important and significant, this general idea and information is not new.
As the President’s Cancer Panel pointed out in its 2008-2009 annual report, federal
environmental laws not only leave many known carcinogens completely unregulated, they also
“fail to address the potential hazards of being exposed to combinations of chemicals”. [Emphasis
added] (Environmental Working Group, http://www.ewg.org/research/rethinkingcarcinogens/executive-summary)
The true impact of chemical exposure could take decades to be measured.
A telling example is a study of 9,300 daughters born to mothers who had been exposed to the
pesticide DDT, which was banned in 1972 because of its effects on the environment, especially
the eggs of the bald eagle. EPA labeled DDT as a probable carcinogen, and multiple studies
linked DDT exposure to breast cancer, but then a 2014 meta-analysis found no significant
association. But then this mother-daughter study showed that the prior studies were looking at
the wrong generation – the daughters of women exposed to DDT - were associated with almost a
fourfold increase in breast cancer, independent of the mother's history of breast cancer. The
study, which covered a span of 54 years, also determined that those with higher levels of
exposure were diagnosed with more advanced breast cancer. The study results are dramatic, but
they took 54 years. (“Startling link between pregnant mother’s exposure to DDT and daughter’s
risk of breast cancer,” by Ariana Eunjung Cha, The Washington Post, 6/17/15
https://www.washingtonpost.com/news/to-your-health/wp/2015/06/16/ddts-breast-cancer-legacypregnant-mothers-exposure-linked-to-four-fold-increase-in-daughters-risk/ and
http://press.endocrine.org/doi/10.1210/jc.2015-1841)
You will not have “safety” answers in 2016 or one or two years later. Please acknowledge this
fact and address epidemiological questions.
Further points to consider:
Federal agencies should not reference “prior studies” without including and acknowledging the
following studies, which raise serious concern about artificial turf. One study raises the
possibility of inhalable lead.
The study states “…if the lead is present to any appreciable extent in the wipes it will likely
be present in the breathing zone of players who are active on these fields, and that
furthermore, these levels potentially exceed ambient EPA standards. (“An Evaluation of
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3
Potential Exposures to Lead and Other Metals as the Result of Aerosolized Particulate
Matter from Artificial Turf Playing Fields Submitted to:Alan Stern, Dr.P.H. New Jersey
Department of Environmental ProtectionSubmitted by: Stuart L. Shalat, Sc.D. (July 14,
2011) http://www.nj.gov/dep/dsr/publications/artificial-turf-report.pdf) Note that many
facilities would not allow testing.
Other studies have raised serious concerns about tire crumb and lead exposure.
A 2014 study found lead and other toxins in the both the plastic rug and tire crumb infill.
Lead was also was found in simulated body fluids meaning there is little or no protection of
any kind against the lead getting out of the material into the body. "Since it is possible that
children may be exposed to potentially high concentrations of lead while using artificial turf
fields we recommend, at a minimum, all infill and fibers should be certified for low or no
lead content prior to purchase and installation."
("Bio-accessibility and Risk of Exposure to Metals and SVOCs in Artificial Turf Field Fill
Materials and Fibers" Brian T. Pavilonis, Clifford P. Weisel, Brian Buckley, and Paul J.
Lioy http://www.ncbi.nlm.nih.gov/pmc/articles/PMC4038666/pdf/nihms565643.pdf 2014)
No two fields are alike because each field contains 30,000 to 40,000 ground up tires, which
come from a multitude of manufacturers.
“Every turf field has to be analyzed in detail to be sure it doesn’t have a problem,’
said Paul Lioy, a professor of environmental and occupational medicine at the Robert
Wood Johnson Medical School in New Jersey.” [Emphasis added.] (“Feds promote
artificial turf as safe despite health concerns,” by Thomas Frank USA Today, 3/16/2015
http://www.usatoday.com/story/news/2015/03/15/artificial-turf-health-safetystudies/24727111/)
"Not surprisingly, the shredded tires contain a veritable witch’s brew of toxic
substances," Gaboury Benoit, Ph.D., Yale Professor of Environmental Chemistry and
Engineering. (“Study: Artificial turf contains carcinogens,” by Tony Spinelli, 7/3/15
http://www.theridgefieldpress.com/48210/study-artificial-turf-containscarcinogens/#ixzz47WNF1FSf)
Additionally, the information required from field managers around the country is time-intensive
as outlined in the Federal Register, and the attempt to reach a maximum of 40 fields nationally is
insufficient. So the time required from the individuals is large and the amount of information
collected will not be much more than anecdotal.
The fields heat is a health hazard. It is hotter than asphalt and much hotter than grass.
At the Women’s World Cup in Edmonton, Canada, in June 2015, the air temperature was 75
degrees, and “the heat from the carpet approaching 120 degrees at kickoff…Research, partly
funded by the city of Las Vegas, found artificial turf above 122 degrees is considered unsafe for
sustained athletic use and that, depending on the air temperature, turf can get as hot as 180
degrees…This was a temperature where if you put your hand down on it, you could only hold it
for five seconds or so before it would burn,” Dale Devitt, director of the Center for Urban Water
Conservation at the University of Nevada Las Vegas told the Vegas Sun. [Emphasis added.]
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4
(“The artificial turf at the Women’s World Cup was reportedly 120 degrees at kick off,” by
Marissa Payne, The Washington Post, 6/6/2015
http://www.washingtonpost.com/news/early-lead/wp/2015/06/06/the-artificial-turf-at-thewomens-world-cup-was-reportedly-120-degrees-at-kick-off/)
Environmental impacts of artificial turf should also be noted.
Artificial turf fields create “heat islands” – an environmental hazard.
The extreme heat “is not only a hazard for users, but also can contribute to the ‘heat island
effect,’ in which cities become hotter than surrounding areas because of heat absorbed by
dark man-made surfaces such as roofs and asphalt.” (“Synthetic Turf: Health Debate Takes
Root” by Luz Claudio, Environmental Health Perspectives 2008 March; 116(3): A116–
A122. http://www.ncbi.nlm.nih.gov/pmc/articles/PMC2265067/
“Columbia University climate researcher Stuart Gaffin analyzed thermal images generated
from NASA satellite maps of New York City. He wanted to figure out how urban trees may
help cool down neighborhoods. When Gaffin noticed a bunch of hot spots on the maps,
he assumed they were rooftops…two turned out to be turf fields" says Gaffin. In
retrospect, he says he should have realized that, because they're a perfect sunlight-absorbing
system.” (“High Temps On Turf Fields Spark Safety Concerns,” by Allison Aubrey,
National Public Radio, 8/7/2008
http://www.npr.org/templates/story/story.php?storyId=93364750)
Artificial turf appears to contribute to elevated levels of zinc in the water.
“There is a potential risk to surface waters and aquatic organisms associated with whole
effluent and zinc toxicity of stormwater runoff from AT fields.” (“Artificial Turf Study,
Leachate and Stormwater Characteristics,” July 2010 Conn. Department of Environmental
Protection
“Crumb rubber derived entirely from truck tires may have an impact on aquatic life due to
the release of zinc. For the other three types of crumb rubber, aquatic toxicity was found to
be unlikely.” Pg. 2
“Zinc concentrations are higher than the surface water standards.” Pg. 29
(“An Assessment of Chemical Leaching, Releases to Air and Temperature at Crumb-rubber
Infilled Synthetic Turf Fields” May 2009 from staff at NY State Department of
Environmental Conservation)
Plastic artificial turf blades will likely disintegrate and degrade with some ending up in bodies of
water and in the food of wildlife either directly or via landfills; plastics of various sizes are
already threatening aquatic life. The impacts of larger sized plastics is more widely known, but
now more is being discovered about the serious effects of microplastics. (“Ingested microscopic
plastic translocates to the circulatory system of the mussel, Mytilus edulis (L).” by Browne
MA1, Dissanayake A, Galloway TS, Lowe DM, Thompson RC, Environmental Science &
Technology, 7/1/2008 http://www.ncbi.nlm.nih.gov/pubmed/18678044) “As plastic breaks into
smaller pieces, it is more likely to infiltrate food webs. In laboratory and field studies, fish,
invertebrates and microorganisms ingest micrometer-sized particles…” (“Classify plastic waste
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5
as hazardous,” by Chelsea M. Rochman, Mark Anthony Browne, Eunha Hoh, Hrissi K.
Karapanagioti, Lorena M. Rios- Mendoza, Hideshige Takada, Swee Teh, Richard C. Thompson.
Nature, 2/14/13.)
Confusion over focus of the undertaking:
While the official federal register announcement does not mention playgrounds, the EPA’s
website explaining this study refers to “this coordinated Federal Research Action Plan on
Recycled Tire Crumb Used on Playing Fields and Playgrounds…”
(https://www.epa.gov/chemical-research/federal-research-recycled-tire-crumbs-used-playingfields) It would be better to included playgrounds, especially since children are particularly
vulnerable to toxic chemicals, but at a minimum the information disseminated should be
consistent between postings.
Conclusion:
As should be apparent from the above information and comments, my staff, constituents and I
have spent numerous hours reviewing these issues. I am deeply concerned that the study as
designed will offer the false hope of absolute answers. We may not know for many years the
true and complete impacts of artificial turf fields. I have concluded that we should adhere to the
precautionary principle and minimize use of artificial turf fields. Instead, we need to focus our
research and energy on improving natural grass fields, which already can be designed to
withstand heavy rains and avoid rain-outs. Increasing knowledge and experience is helping
expand the usage of these fields. The public focus should be on the best practices that give the
greatest use of natural grass fields with the least amount of fertilizers, pesticides and water.
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Page 1 of 1
PUBLIC SUBMISSION
As of: 5/3/16 6:42 PM
Received: May 02, 2016
Status: Posted
Posted: May 03, 2016
Tracking No. 1k0-8per-nvit
Comments Due: May 02, 2016
Submission Type: Web
Docket: ATSDR-2016-0002
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill 0923-16PJ
Comment On: ATSDR-2016-0002-0003
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill ATSDR-2016-0002
Document: ATSDR-2016-0002-0077
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill 0923-16PJ Comment on
FR Doc # 2016-03305
Submitter Information
Name: Christi Davis, Ph.D.
Address: 98036
Email: christidavis2002@hotmail.com
Organization: Washington Alliance for Non-toxic Play and Athletic Fields
General Comment
See attached file(s)
Attachments
Comments on ASTDR 2016-0002
https://www.fdms.gov/fdms/getcontent?objectId=0900006481fa2025&format=xml&showor... 5/3/2016
Comments on ASTDR 2016-0002-0003
Federal Research Action Plan on
Recycled Tire Crumbs Used on Playing Fields and Playgrounds
Submitted to Federal Register May 2, 2016
Washington Alliance for Non-Toxic Play and Athletic Fields
The overarching public health question surrounding crumb rubber is, “Is crumb rubber safe to use on
play fields and playgrounds?” Not only has it been established that the carcinogens and other toxicants
from crumb rubber off-gas into the air, but research has also proven that they leach into water and
simulated body fluids as well (1) (2) (3) (4) (5) (6). Coach Amy Griffin has already compiled a selfreported list of hundreds of athletes whose cancers may be related to crumb rubber exposure (7), and
millions of children and young adults are currently exposed to crumb rubber on a daily basis. Therefore,
a timely, accurate, and reliable estimate of the risks associated with crumb rubber exposure is of utmost
importance.
Given the current state of relevant toxicity data, the planned exposure study is insufficient to provide
reliable, timely estimates of the health risks associated with the use of crumb rubber. In the April 14,
2016 webinar for this study, one of the presenters stated that study researchers intended to combine
exposure data from the federal study with existing toxicology data to predict health risks and make
recommendations. There are no toxicity studies on crumb rubber as a complete mixture. Further, even
if EPA guidelines didn’t clearly state that component-based methods were useless for estimating the
toxicity of complex mixtures, the toxicity information on the components of crumb rubber is too
incomplete to be usable (8). For example, the recent EHHI/Yale study identified 96 chemicals in crumb
rubber, almost half of which had not undergone any government toxicity testing (9). Until there is a
reliable, scientifically defensible estimate of the carcinogenicity of crumb rubber, there can be no
reliable health risk assessment.
It is not even clear that an estimate of the carcinogenicity of crumb rubber is technically feasible
because crumb rubber is not a standardized product. It is a waste product. The chemical composition
of the waste stream used to produce it is highly heterogeneous, may contain chemical hot spots, and
may change at any time in significant and unpredictable ways with no notice, ever.
Predicting the health risks posed by crumb rubber is a formidable challenge. However, measuring any
harm already caused should be relatively straightforward.
Prior formal studies on crumb rubber have provided the scientific basis to ascertain not only that crumb
rubber may cause cancer, but also predict what types of cancer it would be likely to cause on the basis
of its chemical components. However, it is the list of athletes who have contracted cancer compiled by
Coach Amy Griffin that gives research on the safety of crumb rubber urgency. Crumb rubber has only
WANPAF Comments on ASTDR 2016-0002-0003
1
been commonly used in playgrounds and playfields for about 15 years, but there is already a selfreported list of hundreds of suspected cancer cases in young people. The list is remarkable not only for
the age of the cancer patients, but also for how quickly cancers related to crumb rubber exposure seem
to be appearing. Cancer is typically slow to develop, often only appearing decades after exposure.
Further, parents have been repeatedly reassured that any carcinogens in crumb rubber are present at
minute doses that pose virtually no risk. If cancers are appearing in unexpectedly large numbers now,
then either exposures are much higher than believed or crumb rubber may be a potent carcinogen and
the long-term cancer risk may be far greater than originally thought.
Amy Griffin’s List
While the list of athletes diagnosed with cancer collected by Coach Amy Griffin does not constitute an
epidemiologic study, what the list reveals is as instructive as it is frightening. The distribution of cancers
by type on the list does not reflect the distribution in the general population for individuals aged 5-29.
There is an excess rate of leukemia, lymphoma, and lung cancer relative to thyroid, brain, and testicular
cancer on the list. Further, the risk may be concentrated in certain areas or with certain teams.
If a self-reported cancer list is just the product of public fears, then the reported cancers should display a
distribution that reflects the distribution of cancer in the underlying population. A failure to display this
pattern either reflects a significant reporting bias or an underlying difference in cancer rates in the
reference population, or both. Standard population cancer incidence rates are easily available from the
SEER dataset as shown in Table 1 below (10).
Table 1. Age-Specific SEER Incidence Rates By Cancer Site, All Ages, All Races, Both Sexes, 2004-2013
Cancer Site
Age at Diagnosis
5-9
4.18
1.50
0.15
3.41
10-14
3.22
2.52
0.65
2.61
15-19
3.08
4.82
2.36
2.20
20-24
2.66
6.89
5.24
2.26
25-29
2.74
7.54
9.25
2.82
Leukemia
Lymphoma
Thyroid
Brain and Other Nervous
System
Lung and Bronchus
-0.05
0.12
0.32
0.60
Testis*
0.04 0.11
1.88
5.13
7.20
Rates are per 100,000 persons. *Rates for testicular cancer are for 100,000 persons assuming 50,000
males.
An age 5-29 age adjusted cancer rate for each of the cancers can be calculated using the standard 2000
US population distribution (not shown) from the SEER database. The age adjusted cancer rates are
shown in Table 2.
At last report, the individuals on Amy’s list range in age from 5 to 29 years and were diagnosed at least
as far back as 2007. The list contains data through March of 2016, so it covers at least 9.25 years (11).
The numbers included in Table 2 only include individuals that self-reported as playing soccer. Sixteen
cases of sarcomas and 9 cases of other rare cancers in soccer players are not included in Table 2.
Sarcomas were not included in the list because the SEER database breaks down cancers by site, not
WANPAF Comments on ASTDR 2016-0002-0003
2
type. Fifty-four individuals that only reported playing sports other than soccer are on Amy’s list but are
not included in Table 2.
While the numbers on Amy Griffin’s list do not represent the cases for a defined population, they could
be assumed to do so for purposes of illustration. Assume the actual cancer cases in Table 2 represent
cases from a defined population of unknown size x. If it is assumed that the rate of thyroid cancer in the
theoretical population is the same as the rate in the U.S. population, then the size of the theoretical
population can be calculated as 12*100,000/(3.37*9.25)= 38,548 individuals. Given a population of
38,548 individuals at risk for 9.25 years, it is possible to calculate the expected number of cases for each
of the other cancers on Amy’s list. Then the ratio of actual to expected cases can be calculated. As can
be seen in Table 2, the number of leukemia, lymphoma and lung cancer cases are elevated relative to
thyroid, brain and testicular cancer.
Table 2. Expected Number of Cancer Cases Versus Actual Number on Amy Griffin’s List
Leukemia
Lymphoma
Thyroid
Brain and Other Nervous
System
Lung and Bronchus
Testis
Age-adjusted
incidence in
5-29 year
olds
3.19
4.55
3.37
2.66
0.21
2.73
Expected
number of
cases
Ratio Actual to
Expected
Cases
11.39
16.21
12
Actual
number of
soccer
players
41
64
12
9.49
0.74
9.73
11
4
9
1.16
5.41
0.92
3.60
3.95
1
The incidence of lymphoma cases in soccer goalkeepers in Washington State was investigated based on
Amy Griffin’s list. Washington was selected because the author and Ms. Griffin live in Washington and a
significant percentage of the names on the list are from Washington. Goalkeepers were examined
because of their elevated exposure and high rates of appearance on the list. Lymphoma was examined
because many of the carcinogens in crumb rubber are believed to cause blood cancers and because of
the number of lymphoma cases on the list as a whole.
Based on private communications with Amy Griffin, her list includes 7 goalkeepers from Washington
State, aged 12-24 who were diagnosed with lymphoma between 2008 and 2015. By estimating the
number of goalkeepers in this age group, it is possible to estimate incidence.
There are approximately 1,552 boys and girls high school soccer teams in Washington State. Per Amy
Griffin, approximately an additional 10% of high school age soccer players play on select teams instead
of high school teams. This yields a total estimate of 1,707 teams of high school age players, and an
estimated 3,414 14-17 year old goalkeepers. Assuming goalkeepers are spread equally over the age
range, this yields 854 goalkeepers per age, or 4,268 goalkeepers per 5 year age spread. Although
athletes may stop playing after graduation from high school, their exposure during their youth can never
be erased. Thus, they remain in the risk pool. Additionally, goalkeeper is such a specialized position
that it is highly unlikely that a player who was not a goalkeeper in high school would become one after
WANPAF Comments on ASTDR 2016-0002-0003
3
high school. Thus, once a cohort completes high school, the number of people in that cohort who are
exposed to crumb rubber while playing goalkeeper should remain stable over time.
Estimating the number of goalkeepers in the 12-13 age range is difficult. There are likely more 12-13
year old children playing soccer, but 12-13 year olds are less likely to be set in the position they play at
that age. Therefore, to provide a conservative estimate, it is assumed that there are twice as many
goalkeepers per age for 12-13 year olds as there are for 14-24 year olds. The estimate of the at-risk
population is a back of the envelope estimate, and there are additional unstated assumptions in play.
However, it provides a useful, reasonably conservative, estimate of the at-risk population.
Based on the estimated numbers of goalkeepers and age-specific rates for lymphoma for individuals
aged 10-14, 15-19, and 20-24 years, there should have been approximately 5.6 lymphomas in
goalkeepers between the ages of 12 and 24 in Washington between 2007 and 2015. There are 8 on
Amy’s list, approximately 43% more than expected. It is a disturbing finding given that Amy’s list is
entirely self-reported and should only represent a fraction of the actual number of cases. This provides
support to the theory that soccer players are at an elevated risk of leukemia, lymphoma, and lung
cancer and the proportions of cancers on Amy’s list are due to elevated risks of certain cancers in soccer
players and not reporting bias.
Amy Griffin testified before the Washington State House Environment Committee on January 26, 2016
that her list contained five different groups of two or more players with cancer from the same team (7).
Thus, at least 5% of the names on Amy Griffin’s list come from mini clusters. Some clustering of cancer
cases will occur by random chance, but the proportion of the cases on Amy’s list that come from
individual teams is clearly excessive. Either players from teams with multiple cases are more likely to
self-report, or something is placing players on certain teams at elevated risk, or both. Given the
concerns about crumb rubber, it is entirely possible that players on teams with high levels of exposure
to crumb rubber, either due to extended seasons, or practicing on indoor fields, are at elevated risk. It is
also possible that certain fields pose much higher risk than other fields.
The data on Amy’s list raise grave concerns. Many of these concerns can be answered by a thorough
epidemiologic study. Fortunately, the necessary data exist, and the CDC has epidemiologists that are
fully capable of doing the type of research that is necessary to protect the health of our children.
Epidemiology
It should be fairly straightforward to design an epidemiologic study that would at least be able to
determine if soccer players, or goalkeepers in particular, are at an elevated risk of developing certain
cancers such as Hodgkin’s lymphoma or lung cancer.
For example, epidemiologists could model the incidence of selected specific cancers for all athletes who
played NCAA soccer between 2000 and 2013.
Cancer registries are already in place. The NCAA should have a list of all college athletes complete with
basic demographic data as well as information on sports and positions played. Hopefully, the NCAA will
be willing to cooperate in the name of public health and athlete health. While there are always
concerns about privacy, the NCAA would not necessarily need to reveal any information that isn’t
WANPAF Comments on ASTDR 2016-0002-0003
4
already publicly available. Further, cooperation in a government study designed to protect athlete
health could be portrayed as positive and proactive. Failure to cooperate could be publicly portrayed as
a sign that the association has something to hide or that it does not put the well-being of its student
athletes first.
If the NCAA is unwilling to cooperate, it is likely that the necessary information will be available from big
data brokers. Failing that, there are always sites such as TopDrawerSoccer.com that display the name,
college, home town, and position of 69,802 college soccer players in the US right now (12). Sites such as
this likely have archives of data from previous years as well.
Without a measure of athlete exposure to crumb rubber, a comparison of cancer incidence rates in
soccer players to rates in the general population can underestimate the risks associated with crumb
rubber. When soccer players are mixed together in the same data set with nothing to indicate exposure
level, the resulting risk estimate is a function of both the risk associated with exposure to crumb rubber
and the average level of exposure. However, the average level of exposure remains unknown, and if it is
assumed that all practices and games are spent on artificial turf, then the risk associated with crumb
rubber will be greatly underestimated.
However, adding proxy measures of exposure could improve estimates of any increased cancer risk
associated with exposure to crumb rubber and provide an estimate of any potential dose response.
NCAA data should include both the location of the athletes’ colleges and their home towns or high
schools. The average high temperatures in the summer and fall months might be one proxy measure of
exposure since the outgassing of toxic chemicals increases exponentially with temperature.
Adding annual US crumb rubber market penetration data to the model would increase the precision of
the model. Obviously, if exposure to crumb rubber causes cancer, then cancer rates should increase as
market penetration increases and as the number of years athletes are exposed to it increases. College
athletes in 2005 were exposed to crumb rubber for a relatively short period of time and a much smaller
percentage were exposed. College athletes in 2013 may have played on it for 13 years, and a relatively
large percentage probably played on it since high school.
Adding annual market penetration to the model for each athlete’s home town/ home state would
increase the precision of the model. Adding in the type of field present at each athlete’s college or
annual market penetration of crumb rubber in each athlete’s college town / state would also increase
the precision of the model.
Although the EPA no longer participates in the Scrap Tire Workgroup, it may have historical market
penetration data. Otherwise, the Synthetic Turf Council, or major turf retailors such as FieldTurf, may
have the data. Since this study has explicitly stated that it will include representatives from the
synthetic turf industry in this research, it is only reasonable to expect basic cooperation from the
stakeholders. If the STC or major retailors choose not to cooperate with an investigation on the safety
of crumb rubber, partial, if not complete, data may be available elsewhere. For example, states that
have given subsidies for the construction of synthetic turf fields and may have market data for their
state. (A failure of the synthetic turf industry to cooperate with the study could be interpreted as a tacit
admission that the industry believes that there are significant health risks associated with crumb rubber
use. This could provide further justification for an immediate moratorium on the use of crumb rubber.)
WANPAF Comments on ASTDR 2016-0002-0003
5
A multivariate regression model with proxy variables and other basic explanatory variables such as age,
gender, and position, as well as all necessary interaction terms could be created. Determination of the
exact type of statistical model to be used should obviously be left up to biostatisticians / epidemiologists
who regularly model cancer epidemiological data. A list of the types of cancer to investigate can be
compiled from the list of cancer cases maintained by Coach Amy Griffin, and by consultation with
toxicologists on the cancers expected from the carcinogens in crumb rubber. In addition, the
Washington State Department of Health is validating the Washington State cancer cases on Amy’s list
and expects to publish some descriptive statistics concerning the list in the summer of 2016 (13). The
DOH plans to determine if the cases represented on Amy’s list represent an excessive rate of cancer
cases among soccer players / goalkeepers in Washington (14). However, there is no plan to
independently identify other cases of cancer in soccer players in Washington.
The main weakness of an epidemiologic study is that it has no ability to predict long-term effects.
Crumb rubber has been widely used for around 15 years. The full effects of a carcinogen on human
health typically take 30-50 years to appear. If the epidemiologic studies do not reveal any current
cancer excesses, animal experimentation could help rule out any long-term risks. However animal
experimentation is expensive, time-consuming, and should be avoided whenever possible for ethical
reasons. If there is a current excess of cancer cases, then crumb rubber is unsafe and should not be
used. Animal studies would not be necessary to determine whether or not to ban it.
Specific Comments on Exposure Study Design
Bioavailability
Any bioavailability studies should mimic real world exposure scenarios, including using realistic particle
sizes and exposure periods as much as possible. Thus, gastric studies should include crumb rubber dust
as well as crumbs. While some children engage in pica, and soccer goalies get crumbs in their mouths
when diving for balls, much of the oral exposure of children is via hand to mouth behavior. Thus,
children are ingesting dust, not tire shreds or crumbs. Toxins on particles 10 to 250 micrometers in
diameter are likely to be much more bioavailable than toxins encased in shreds half an inch in length.
The Kim study examined the effects of particle size on the bioavailability of lead in EPDM based on acid
extraction and simulated digestive fluid extraction (15). The study found that lead was more than five
times more bioavailable in particles less than 250 microns in diameter than it was in larger particles.
The bioavailability of toxins in 1-2 mm diameter crumbs in simulated lung fluid is not biologically
relevant because humans are breathing in airborne particles, not large crumbs (4). Further, the smaller
particles, those just a few microns in diameter, can pass through the lung tissue, into the bloodstream,
and from there into various organs and tissues. At that point, the bioavailability of the toxicants in
blood or tissue becomes relevant. Similarly, the estimated bioavailability of PAHs on PM 2.5 that are
estimated to stay in the lungs for 3 months is very different than the estimated bioavailability of PAHs
on a 1 mm crumb that is estimated to stay in the lungs for 24 hours.
Collection Procedures
WANPAF Comments on ASTDR 2016-0002-0003
6
Samples of crumb rubber should not be washed as washing removes the smaller dust particles.
Samples of new crumb rubber should be taken from the top, middle and the bottom of the bag because
of granular convection, also known as the ‘Brazil-nut effect.” Different sized crumbs will have different
surface areas relative to their mass. Hence the toxicants contained in them will have different levels of
bioaccessibility. Different sizes of crumb rubber particles may also be chemically different. A tire is not
composed of a uniform piece of rubber. Different portions of the tire have different formulations, some
of which may be more likely to crumble than others. Different tire parts have been exposed to different
microenvironments containing different contaminants. This affects how the rubber ages and breaks
down. The outer layer of the tread that was most exposed to roadway contaminants could be the most
brittle and likely to crumble into dust. Conversely, inner layers of rubber that were more protected
from the elements and contaminants may remain as larger crumbs. Washing the dust off of the crumbs
could mean washing away relevant contaminants from the sample.
Similarly, when collecting crumb rubber samples from fields and playgrounds, care must be taken to
collect the dust and respirable particulate matter as well. Care must be taken not to re-suspend
particulate matter that has settled from the air. Sweeping samples into a collector risks loss of dust and
settled particulates. Vacuuming up the crumb may be the best way of capturing all of the crumb rubber
in a given area. It is important to know all of what is actually on the fields, not just what is in the large
crumbs on the fields.
Legislation or administrative action compelling institutions that receive federal funding, such as most
public schools, to participate upon request should be considered. In 2011, Dr. Stuart Shalat noted that
only 5 of the 50 schools and towns he contacted gave him permission to test their fields due to liability
concerns (16). That was before Coach Amy Griffin’s list of athletes who have developed cancer started
raising public concern. Field owners might be much less cooperative today. Given previous difficulties
in obtaining permissions to test fields, collecting 40 samples from fields, stratified by field type, age and
census region may mean contacting hundreds of towns or schools. Alternatively, it might help to
publicize the school districts and cities that refuse to allow their fields to be tested. At the same time, a
policy of not releasing any individual results, unless hazardous levels of a toxicant are identified (such as
lead > 400 ppm in crumbs), could shield participants from unintended negative consequences. Thus,
those who refuse to help look like they have something to hide or like they aren’t concerned about the
health of their field users, while those that participate get to look like they are taking steps to protect
public health.
All air monitoring should include personal air monitoring of VOCs, SVOCs, PM 2.5, and carbon black.
Proper off-field, up wind controls should be taken concurrently. On-field sampling should be done
during actual games, scrimmages or practices. Referees may wear the monitoring equipment if it is not
feasible to have players wear monitors. Stationary monitors on the side of the field do little to reveal
what players on the field are exposed to due to atmospheric mixing and the settling of dusts. Players
actively churn the crumb re-suspending dust and PM 2.5, and opening up pockets of trapped gasses
(16).
Measurements of PM 2.5 and carbon black from personal air monitors would be new information.
Personal air monitors have been used for VOCs and SVOCs but not PM 2.5 (17). Even though carbon
WANPAF Comments on ASTDR 2016-0002-0003
7
black constitutes roughly 30% of crumb rubber, no measurements of ambient carbon black levels at
synthetic turf fields in the U.S. using any type of monitor were located. The estimates of airborne
carbon black from crumb rubber typically come from a study of indoor turf fields conducted in Norway
(18).
Estimating exposures goal keepers receive, especially during practice diving drills may be difficult. It
may not be safe for either the player or the equipment for goal keepers to dive into the turf while
wearing the monitors. It may be more practical to have engineers study films of goalies diving after
balls, and then design ways to mimic the spray of crumbs and dust particles they receive each time they
dive into the turf.
It is encouraging that the CDC, CPSC and EPA are examining the toxic exposures that children and
athletes receive when using playgrounds and athletic fields that use artificial turf. However, given the
number of citizens that are exposed to crumb rubber on a daily basis, and the evidence that crumb
rubber is already responsible for excess cancer cases in the country’s youth, a more aggressive research
program, including a large epidemiological study, is needed.
WANPAF Comments on ASTDR 2016-0002-0003
8
References
1. Characterization of Substances Released from Crumb Rubber Material Used on Artificial Turf Fields. Li,
X, et al. 2010, Chemosphere, pp. 279-285.
2. Hazardous organic chemicals in rubber recycled tire playgrounds and pavers. Llompart, Maria, et al.
2013, Chemosphere, pp. 423-431.
3. Release of Polycyclic Aromatic Hydrocarbons and Heavy Metals from Rubber Crumb in Synthetic Turf
Fields: Preliminary Hazard Assessment for Athletes. Marsili, L., Coppola, D., Bianchi, N., Maltese, S.,
Bianchi, M., & Fossi, M. C. 2016, Environmental & Analytical Toxicology.
4. Bioaccessibility and Risk Exposure to Metals and SVOCs in Artificial Turf Field Fill Materials and Fibers.
Pavilonis, B.T., et al. 2013, Risk Analysis .
5. Simcox, Nancy, Bracker, Anne and John, Meyer. Artificial Turf Field Investigation in Connecticut.
Farmington : University of Connecticut, 2010.
6. Mutagenic Potential of Artificial Athletic Field Crumb Rubber at Increased Temperatures. Dorsey,
Michale J., et al. 2, 2015, The Ohio Journal of Science, Vol. 115, pp. 32-39.
7. TVW. House Environment Committee. [Online] January 26, 2016. [Cited: May 2, 2016.]
http://www.tvw.org/watch/?eventID=2016010305.
8. EPA Risk Assessment Forum Technical Panel. Supplementary Guidance for Conducting Health Risk
Assessment of Chemical Mixtures. Washington DC : U.S. Environmental Protection Agency, 2000.
9. EHHI. New Study – Many carcinogens found in Yale analysis of crumb rubber infill and playground
mulch surfacing. Environment and Human Health, Inc,. [Online] June 11, 2015.
http://www.ehhi.org/turf/new_study_jun2015.shtml.
10. Surveillance, Epidemiology, and End Results (SEER) Program: SEER*Stat Database: Incidence - SEER
18. Age-Specific (Crude) SEER Incidence Rates By Cancer Site All Ages, All Races, Both Sexes 2004-2013.
s.l. : National Cancer Institute, DCCPS, Surveillance Resarch Program, Surveillance Systems Branch, 2016.
11. Alderman, Nancy. personal email. 2016.
12. TopDrawerSoccer.com. College Player Search. [Online] Advanced Sports Media Group. [Cited: May
2, 2016.]
http://www.topdrawersoccer.com/search/?query=&genderId=&classId=&divisionId=All&conferenceId=
All&positionId=0&pageNo=0&area=collegeplayer.
13. Wasserman, Cathy. personal email. 2016.
14. Washington State Department of Health. Synthetic Turf. [Online] [Cited: May 2, 2016.]
http:www.doh.wa.gov/CommunityandEnvironment/Schools/EnvironmentalHealth/syntheticTurf.
15. Kim, Sunduk, et al. Health Risk Assessment of Lead Ingestion Exposure by Particle Sizes in Crumb
Rubber on Artificial Turf Considering Bioavailability. [Online] February 2, 2012. [Cited: May 2, 2016.]
http://e-eht.org/journal/view.php?doi=10.5620/eht.2012.27.e2012005.
WANPAF Comments on ASTDR 2016-0002-0003
9
16. Shalat, Stuart L. An Evaluation of Potential Exposures to Lead and Other Metals as the Result of
Aerosolized Particulate Matter from Artificial Turf Playing Fields. s.l. : New Jersey Department of
Environmental Protection, 2011.
17. Ginsburg, Gary and Toal, Brian. Human Health Risk Assessment of Artificial Turf Fields Based Upon
Results from Five Fields in Connecticut. Hartford : Connecticut Department of Public Health, 2010.
18. Norwegian Institute for Air Pollution. Measurement of Air Pollutions in Indoor Turf Halls. s.l. :
Norwegian Pollution Control Authority, 2005.
19. Assessing the carcinogenic potential of low-dose exposures to chemical mixtures in the environment:
the challenge ahead. Goodson, William H, Lowe, Leroy and al, et. 2015, Carcinogenesis, pp. S254-S296.
20. Substantial contribution of extrinsic risk factors to cancer development. Wu, Song, et al. 2016,
Nature, pp. 43-47.
21. Artificial-Turf Playing Fields: Contents of Metals, PAHs, PCBs, PCDDs and PCDFs, Inhalation Exposure
to PAHs and Related Preliminary Risk Assessment. Menichini, E, et al. 2011, The Science of the Total
Environment, pp. 4950-4957.
22. Highsmith, R., Thomas, K.W. and Williams, R.W. A Scoping-Level Field Monitoring Study of Synthetic
Turf Fields and Playgrounds. s.l. : National Exposure Research Laboratory, U.S. Environmental Protection
Agency, 2009.
23. Synthetic Turf Field Investigation in Connecticut. Simcox, Nancy J., et al. 2011, Journal of Toxicology
and Environmental Health: Part A Current Issues, pp. 1133-1149.
24. Office of Environment Health Hazard Assessment. Appendix B. Chemical-specific summaries of the
information used to derive unit risk and cancer potency values. updated 2011. OEHHA Toxicity Criteria
Database. [Online] 2011. http://www.oehha.ca.gov/tcdb/index.asp.
25. Toxicity and metabolism of methylnaphthalenes: Comparison with naphthalene and 1nitronaphthalene. Lin, Ching Yu, et al. 2009, Toxicology, pp. 16-27.
26. President’s Cancer Panel. Reducing Environmental Cancer Risk: What We Can Do Now. Bethesda :
U.S. Deptartment Health and Human Services, 2010.
WANPAF Comments on ASTDR 2016-0002-0003
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WANPAF Comments on ASTDR 2016-0002-0003
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Page 1 of 3
PUBLIC SUBMISSION
As of: 5/3/16 6:43 PM
Received: May 02, 2016
Status: Posted
Posted: May 03, 2016
Tracking No. 1k0-8per-o6x7
Comments Due: May 02, 2016
Submission Type: Web
Docket: ATSDR-2016-0002
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill 0923-16PJ
Comment On: ATSDR-2016-0002-0003
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill ATSDR-2016-0002
Document: ATSDR-2016-0002-0079
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill 0923-16PJ Comment on
FR Doc # 2016-03305
Submitter Information
Name: Jonathan Damm
Address: 20191
Email: jondamm@yahoo.com
General Comment
Dear Federal Agencies:
I am a concerned parent with a background in environmental law and a lacrosse player and
coach. Because of my education, I understand and appreciate the dangers inherent with repeated
exposure to toxins. Since I am a coach and player, I have also spent many hours on tire crumb
fields. I have witnessed how children are exposed to the fine particulate. After reading all the
available literature, my wife and I concluded the risks far outweigh any benefits of using fields
with tire crumb. Regardless of your final conclusions, it is clear that tire crumb is beyond our
capacity to thoroughly investigate - as I will discuss below. So we will never let our three young
children play on tire crumb. A generation of young Americans relies on you for similar
protection.
Later this year, when the federal government issue its preliminary statement regarding the
safety of tire crumb on synthetic turf fields, the most important messages to communicate to
concerned parents are: 1) Tire Crumb is a "Moving Target" - tire manufacturers frequently
change tire ingredients. So any formal study conclusion only speaks to existing fields. Any field
installed after a study, or any field not studies, may contain chemicals that were not examined in
past studies - including any federal study. So for all the millions of dollars of resources the
federal government is about to spend on this study, any conclusions can only speak to actual
https://www.fdms.gov/fdms/getcontent?objectId=0900006481fa2055&format=xml&showor... 5/3/2016
Page 2 of 3
fields that were studied. A study can only be backwards looking by its very nature since there
can be zero confidence that manufacturers will not change tire ingredients. This must be clearly
communicated. 2) Compound based risk assessment can only be done on chemicals and
compounds that have regulatory risk frameworks. Tire crumb contains numerous chemicals and
compounds with no regulatory risk frameworks. Therefore, any formal study will necessarily
contain significant data gaps. 3) Given that tire crumb contains multiple chemicals and
compounds with no risk frameworks, epidemiological studies and animal studies are the only
available methods of study to overcome this intrinsic problem. If there are no significant
epidemiological studies undertaken or planned, this must be communicated. If there are no
animal studies planned, this must be communicated.
If the three points of focus above were communicated clearly and prominently, it would help
educated field users to truly understand that sometimes, a problem is beyond our ability and
present capacity to accurately make predictions or draw conclusions regarding safely. If the
federal government was realistic in this endeavor, it would recognize this from the very start.
And given what we know about the multiple carcinogens, mutagens and reprotoxins in this
material, the government should conclude from the start that tire crumb is simply too risky to
use in such close proximity to children.
Sweden Concluded that Tires should Not be Used
Such a position would not be novel or unprecedented. The Swedish agency tasked with
reviewing tire crumb on synthetic fields recommended that tires should not be used as material
on synthetic turf fields for exactly these reasons. Sweden wisely concluded that given the
complexity and the inherent unknowns regarding tire crumb use on turf fields, they simply
should not be used.
"Tyres contain substances of very high concern
Tyres contain several substances that are substances of very high concern. These substances
maypersist in the environment, they may be bioaccumulative, carcinogenic, reprotoxic, or
mutagenic. This is true of, for example, polycyclic aromatic hydrocarbons (PAHs), phthalates
and certain metals. These substances should not be released into the environment and thus
waste tyres should not be used for synthetic turf surfaces.
KemI's Recommendations:
Do not select synthetic turf that contains substances of very high concern when laying new
surfaces
Material that contains substances of very high concern should not be used, as specified by the
environmental objectives of the Swedish parliament. This means that granulate formed from
recycled rubber should not be used when laying new surfaces of synthetic turf. The Norwegian
authorities have issued a similar recommendation."
http://www.wellesleyma.gov/pages/WellesleyMA_SpragueResources/Swedish%20Study.doc
In addition to Sweden and Norway, whole countries that have recommended that tires not be
used on turf fields, municipalities like as New York City have has banned tire crumb since 2009
for their schools and parks.
https://www.fdms.gov/fdms/getcontent?objectId=0900006481fa2055&format=xml&showor... 5/3/2016
Page 3 of 3
Similarly in 2009, the L.A. Unified School district has banned tire crumb. The list grows larger
by the week. In early 2015, Montgomery County, Maryland's most populous, banned tire crumb
by a unanimous vote of the council.
Please honor the precautionary principal and recommend a complete ban on the use of tire
crumb on turf fields and playgrounds. See attached for full comments.
Regards,
Jonathan Damm
Attachments
Comments on ASTDR 2016-0002 by Jonathan Damm
https://www.fdms.gov/fdms/getcontent?objectId=0900006481fa2055&format=xml&showor... 5/3/2016
Comments on ASTDR 2016-0002-0003
Federal Research Action Plan on
Recycled Tire Crumbs Used on Playing Fields and Playgrounds
Submitted to Federal Register May 2, 2016
By Jonathan R. Damm
Dear Federal Agencies:
I am a concerned parent with a background in environmental law and a lacrosse player
and coach. Because of my education, I understand and appreciate the dangers inherent
with repeated exposure to toxins. Since I am a coach and player, I have also spent
many hours on tire crumb fields. I have witnessed how children are exposed to the fine
particulate. After reading all the available literature, my wife and I concluded the risks far
outweigh any benefits of using fields with tire crumb. Regardless of your final
conclusions, it is clear that tire crumb is beyond our capacity to thoroughly investigate –
as I will discuss below. So we will never let our three young children play on tire crumb.
A generation of young Americans relies on you for similar protection.
Later this year, when the federal government issue its preliminary statement regarding
the safety of tire crumb on synthetic turf fields, the most important messages to
communicate to concerned parents are: 1) Tire Crumb is a “Moving Target” – tire
manufacturers frequently change tire ingredients. So any formal study conclusion only
speaks to existing fields. Any field installed after a study, or any field not studies, may
contain chemicals that were not examined in past studies – including any federal study.
So for all the millions of dollars of resources the federal government is about to spend
on this study, any conclusions can only speak to actual fields that were studied. A study
can only be backwards looking by its very nature since there can be zero confidence
that manufacturers will not change tire ingredients. This must be clearly communicated.
2) Compound based risk assessment can only be done on chemicals and
compounds that have regulatory risk frameworks. Tire crumb contains numerous
chemicals and compounds with no regulatory risk frameworks. Therefore, any
formal study will necessarily contain significant data gaps. 3) Given that tire crumb
contains multiple chemicals and compounds with no risk frameworks, epidemiological
studies and animal studies are the only available methods of study to overcome this
intrinsic problem. If there are no significant epidemiological studies undertaken or
planned, this must be communicated. If there are no animal studies planned, this
must be communicated.
If the three points of focus above were communicated clearly and prominently, it would
help educated field users to truly understand that sometimes, a problem is beyond our
ability and present capacity to accurately make predictions or draw conclusions
regarding safely. If the federal government was realistic in this endeavor, it would
recognize this from the very start. And given what we know about the multiple
carcinogens, mutagens and reprotoxins in this material, the government should
1
conclude from the start that tire crumb is simply too risky to use in such close proximity
to children. The following links provide examples of chemicals of concern in tire crumb.
http://www.albany.edu/ihe/Synthetic_Turf_Chemicals.php
http://www.ncbi.nlm.nih.gov/m/pubmed/22352997/
http://www.ehhi.org/turf/new_study_jun2015.shtml http://southlakesturf.org/wpcontent/uploads/2015/02/Pg-31.jpg
http://southlakesturf.org/wp-content/uploads/2015/02/Attachment-1-Crumb-RubberChemicals.pdf
Sweden Concluded that Tires should Not be Used
Such a position would not be novel or unprecedented. The Swedish agency tasked with
reviewing tire crumb on synthetic fields recommended that tires should not be used as
material on synthetic turf fields for exactly these reasons. Sweden wisely concluded that
given the complexity and the inherent unknowns regarding tire crumb use on turf fields,
they simply should not be used.
Tyres contain substances of very high concern
Tyres contain several substances that are substances of very high concern.
These substances maypersist in the environment, they may be
bioaccumulative, carcinogenic, reprotoxic, or mutagenic. This is true of, for
example, polycyclic aromatic hydrocarbons (PAHs), phthalates and certain
metals. These substances should not be released into the environment and thus
waste tyres should not be used for synthetic turf surfaces.
KemI’s Recommendations:
Do not select synthetic turf that contains substances of very high concern
when laying new surfaces
Material that contains substances of very high concern should not be used, as
specified by the environmental objectives of the Swedish parliament. This means
that granulate formed from recycled rubber should not be used when laying new
surfaces of synthetic turf. The Norwegian authorities have issued a similar
recommendation.
http://www.wellesleyma.gov/pages/WellesleyMA_SpragueResources/Swedi
sh%20Study.doc
In addition to Sweden and Norway, whole countries that have recommended that tires
not be used on turf fields, municipalities like as New York City have has banned tire
crumb since 2009 for their schools and parks. http://www.nydailynews.com/newyork/city-yields-ground-crumb-rubber-turf-wars-article-1.389543
Similarly in 2009, the L.A. Unified School district has banned tire crumb.
http://usatoday30.usatoday.com/sports/2009-06-10-artificial-turf_N.htm
The list grows larger by the week. In early 2015, Montgomery County, Maryland’s most
populous, banned tire crumb by a unanimous vote of the council.
http://www.mymcmedia.org/councilmember-berliner-applauds-council-turning-the-page2
on-artificial-turf/ Recently, the city of Hartford, CT banned Tire Crumb as well.
http://ctmirror.org/2016/02/12/a-shifting-ground-for-artificial-turf-in-connecticut/
There are many other communities taking similar action. A Google search will provide
you with plenty of evidence. Industry lobbyists and representatives will likely tell you that
these are just reactionary measures because of sensational headlines of anecdotal
news about goalies with cancer. I will discuss the goalies with cancer below. First,
Sweden and Norway took their precautionary measures in 2006, well before the news
about goalies with cancer in 2014. It was enough for them to understand what is in tire
crumb. They didn’t need to conduct a generation long experiment to decide if it is safe.
They erred on the side of caution, which is a reasonable measure given the multiple
chemicals of concern, carcinogens, PAHs, VOCs, phthalates, heavy metals and
endocrine disruptors. All these things are in tire crumb. There is no debate about that.
Over the last ten to twenty years, parents have been increasingly aware that they
should take reasonable steps to protect their kids from having toxins bioaccumlate in
their kids’ bodies. So countries and municipalities that are avoiding tire crumb are not
simply acting because they are scared, they are taking prudent and reasonable
measures to minimize exposure to dangerous toxins. BPA and phthalates are good
examples. These chemicals are not banned by EPA and really not heavily regulated as
far as I understand.
Exposure
But the science is pretty clear at this point that we should protect children from
unnecessary exposure to endocrine disruptors. When developing kids are on a tire
crumb field, they often ingest tire crumb. They either ingest actual particles or they
ingest micro particles that get mixed into their sweat as it runs over their skin and into
their mouth. The attached document from the safe healthy playing fields coalition
illustrates how small particles actually are. The picture below is from the attachment.
But look at how small the dust is. The larger black spot is a highly magnified piece of tire
crumb. The specs are microscopic dust. The picture of the woman illustrates how easily
the dust can be transferred from a field to a sweaty person and into their mouth.
3
They inhale fine tire crumb dust. They inhale VOCs. They absorb chemicals and oils
from tire plasticizers either directly through their skin or in open wounds. It gets in their
noses. It gets in their eyes. There are multiple exposure routes.
Bioavailability
Based on limited study, industry representatives like to assert that the chemicals in tire
crumb are somehow not bioavailable. But there are studies that contradict that. For
example, there is a study from South Korea that concludes that lead in EPDM rubber
particulate is indeed bioavailable. It should not be any different for metals in particulate
and dust like tire crumb. “Conclusions - Results of this study confirm that the
exposure of lead ingestion and risk level increases as the particle size of crumb
rubber gets smaller.” http://www.ncbi.nlm.nih.gov/pmc/articles/PMC3278598/
So it is reasonable for parents to take precautions in their daily lives to protect their
children from toxins. People wash fruit, they off-gas products, they avoid flame
retardants, and they avoid endocrine disruptors and PAHs in their children’s products.
The list goes on. So when municipalities ban tire crumb, they are simply acting in the
same reasonable and cautious way that their populations act every day. Why would
parents want to take reasonable steps to protect their children from harmful
toxins in their daily lives, then turn around and expose their kids to all the same
chemicals of concern and even worse? It does not make sense to take one step
forward and two steps back.
Avoiding tire crumb is not a reactionary measure to sensational news; it is wisdom and
common sense. Using tire crumb where kids play is reckless and out of step with a
growing population of educated American’s approach to toxins around children. It is
truly mind boggling that there are individuals in the federal government that consider
this even remotely as a good idea.
Every day, we learn how toxins bioacumulate in the body. Folks take careful steps to
protect their families. By even pretending that somehow a field full of all the same
chemicals of concern could be tolerable under any circumstance is just plainly behind
the times. The only reason there has not already been a mass revolt is that there has
not been an opportunity to educate the millions of people that need the education. But if
the same people who avoid BPA and phthalates in their childrens’ products actually
learned in detail just how full of toxins their kids’ fields are, they would put it all together.
So please don’t pretend that somehow different rules apply just because kids are
running around an exercising. It is illogical to think that exercising somehow mitigates
the harms and risks. If anything, it makes it worse.
4
Goalies with Cancer – Only 5000 blood Cancers a Year
What about those soccer goalies with cancer? Anything short of a serious statistical
analysis would be too bad. It appears that there are only around 5000 blood cancers a
year under the age of 24. There are now over 100 goalies on Amy Griffin’s list. Most
have blood cancers. Given so few kids with blood cancers in a given year, it seems very
unlikely that one person would be able to put together a list of so many people with two
things in common 1) plays one particular position (goalie), and 2) plays mostly on one
particular kind of field (tire crumb). And there are still not that many tire crumb fields
nationally – around 12,000. So Amy Griffins list should be taken very seriously.
http://www.cancer.gov/research/progress/snapshots/adolescent-young-adult
Carbon Black
Any investigation must also look closely at carbon black. Carbon black makes up about
1/3 of a tire. That means about 1/3 of a tire crumb field is also carbon black. Carbon
black is a known animal carcinogen and a possible human carcinogen. Nanoparticles in
carbon black have been theorized to present asbestos like concerns.
http://www.turfandrec.com/index.php?option=com_content&task=view&id=2986 If this is
not looked at very closely, it would be a monumental oversight. Will the study look
closely at carbon black exposure?
Carbon Nanotubes
“Inhaling carbon nanotubes could be as harmful as breathing in asbestos, and its
use should be regulated lest it lead to the same cancer and breathing problems that
prompted a ban on the use of asbestos as insulation in buildings, according a new study
5
posted online . . . by Nature Nanotechnology.”
http://www.scientificamerican.com/article/carbon-nanotube-danger/
"[Ti]res enhanced with CNT (carbon nanotubes) appear to have improved mechanical
properties, such as tensile strength, tear strength and hardness of the composites, by
almost 600%, 250% and 70% respectively, comparing with those of the pure SBR
composites (styrene‐butadiene rubber)." http://www.iosrjournals.org/iosrjmce/papers/vol11-issue4/Version-1/B011410711.pdf
This concern with carbon nanotubes goes back to the “Moving Target” concern I
discussed in the first page of this document. Tires are waste products that are not
designed for use, ingestion, inhalation and absorption by children. Any slew of
potentially carcinogenic material could make their way into the next generation of tires,
and probably will. This should be unacceptable from the start.
Past studies have been negligent in how they collect data. They underestimate
exposure. The 2008 EPA study set up a particle collector and had kids run by
periodically. The particle collector was surrounded by a small 3 foot fence. That is not
realistic exposure replication. In order to replicate a goalies exposure, you would literally
have to kick the tire crumb fly-out into the collector again and again for hours and hours.
Past studies also use simulated body fluids that do not accurately extract all the
chemicals in tire crumb. The Yale study found 12 carcinogens.
http://www.ehhi.org/turf/findings0815.shtml Industry critics claim that Yale used to harsh
an extraction method. But there is no debate that the carcinogens were present. One
can make an argument that prior extraction methods based on simulated body fluids
were not stringent enough.
I am attaching the written testimony of Dr. Wright from the Mount Sinai Children’s
Environmental Health Center.
https://dl.dropboxusercontent.com/u/101177270/CEHC%20RB%205139%20Testimony
%20Feb%2016%202016.pdf
It says it all. In short:
1. "Given the hazards associated with recycled tire rubber, it is our recommendation that
these products never be used as surfaces where children play."
2. "[W]e found significant gaps in the evidence supporting the safety of recycled rubber
turf products."
3. "Children are uniquely vulnerable to harmful exposures from recycled rubber
surfaces."
4. "In the absence of convincing evidence of safety, we recommend that children not
play on recycled rubber surfaces that contain known carcinogens and neurotoxins and
support a ban on the use of these products."
6
I hope the federal government takes the same reasonable position. Even if you do not,
a large portion of the population will continue to act prudently and will avoid using fields
with tire crumb. You might as well act responsibly and protect those that do not have the
fortune to be as educated on the dangers of bioaccumulated toxic exposure.
Heat - 120 degrees
A few comments on heat - I read that the fields would be tested at two temperatures.
One would be at room temperature or average outdoor temp. The other would be at a
higher temperature to mimic a hot day. I hope you paid attention to the temperatures at
the women’s soccer world cup. The temperatures of the turf were not just hot, they were
astonishingly hot. It was measured at 120 degrees! So please measure it at that
temperature. Anything else would be a sham.
https://www.washingtonpost.com/news/early-lead/wp/2015/06/06/the-artificial-turf-atthe-womens-world-cup-was-reportedly-120-degrees-at-kick-off/
Industry MSDS
The Synthetic Turf Council has a MSDS that makes clear there are certain precautions
that their installer should take. They include washing frequently, wearing a respirator,
and wearing eye protection to name a few (see next page). But importantly, this is the
industries own material. How can they be asserting on the one hand that children are
safe to play on tire crumb and then at the same time, warning their installers to take
very deliberate and thorough measures to protect themselves from tire crumb as they
install it?
It is very puzzling to try to understand how this material is safe for players who get the
same if not more exposure than installers. Kids who roll in tire crumb, eat tire crumb,
drink tire crumb in sweat, inhale tire crumb, absorb tire crumb, and grow up on tire
crumb are getting absolutely no warnings like the installers. It is a terrible injustice and
wildly hypocritical.
7
https://www.dropbox.com/s/yvszy6bgtsis39a/STC%20MSDS.pdf?dl=0
8
Why should kids not receive the same warnings when they get even more exposure
than installers? When parents are educated on this seeming hypocrisy, they see right
through industry assertions that the material is safe. If you conclude that tire crumb is
safe as well, you will have to explain why installers receive special warnings about
wearing respirators and washing.
9
There should be signs on every field that provide the same warnings to parents and
players.
These are just some thoughts that hopefully provide some insight as to why you should
categorically conclude that tire crumb is too risky to use where children play. Please do
the right thing and recommend that there be a moratorium on the use of tire crumb on
synthetic turf fields and playgrounds.
Please consider attachments 1 and 2 as a fully incorporated part of this document and
part of my formal comments as well.
Regards,
Jonathan R. Damm
Reston, VA 20191
jondamm@yahoo.com
Vermont Law School, JD, MSEL ‘99
10
Attachment 1
11
12
13
14
15
Attachment 2
Comments on ASTDR 2016-0002-0003
Federal Research Action Plan on
Recycled Tire Crumbs Used on Playing Fields and Playgrounds
Submitted to Federal Register May 2, 2016
SAFE AND HEALTHY PLAYING FIELDS COALITION www.safehealthyplayingfields.org
A grass roots coalition working for healthier alternatives for children and communities
INTRODUCTION
On behalf of the millions of children, parents and athletes who play field sports in the US at schools,
parks, athletic facilities and playgrounds, thank you for agreeing to study the potential harm caused by
playing on or being near athletic fields with surfaces made waste tires. There are more than 12,000 of
these playfields in place (15,000 according to the website of a large company that installs them), and
they are being installed at a rate we estimate to be about 3000 a year. By our calculations, 12,000 fields
currently present 2,380,000 tons or 4,760,000,000 pounds of loose, unencapsulated tire crumb on their
field surface. (See our Table of Runoff and Material Volumes attached.) Tens of thousands of students
and young athletes play on those fields, many more thousands have direct or indirect contact with the
material. It is a public health issue of substantial importance.
The following lists our comments on the proposed study. We argue that the fields present known
carcinogenic, pathogenic, and mutagenic material in a high surface area, pulverized form that is more
toxic than whole tires, and should never have been allowed near children, or adults, because of risk of
ingestion and inhalation exposure to all the ingredients in tires. On warm, sunny days the surface
temperature routinely reaches over 150F, which presents direct, well-known heat injury risks to
children. The heat increases off-gassing of the tire components, increasing the likelihood of pulmonary
16
exposures, and creates a complex dynamic in the children’s exposure zone immediately above a field
that has not been correctly modeled or studied yet. The material lacks uniformity, or any regulatory or
exposure controls. We assert that it is impossible to assure even a single tire crumb field is free of
inhalation and ingestion risk of dangerous particulate and gases inherent in tires, tire crumb, and add-in
composites; and that dangerous and unwanted exposures from lead, benzothiazoles, 12 carcinogens,
phthalates, carbon black and other materials, can happen with every use. The data gaps are enormous,
and we hope CDC/CPSC/EPA will recognize there is no way the tire crumb industry can protect any
player, on any field, from the potential for dangerous exposures with normal use. We argue that not
enough scrutiny was placed on this material.
NOTE: The Safe and Healthy Playing Fields Coalition is a grass roots group of scientists, public health
professionals, toxicologists, neurobiologist, educators, plastics engineers, medical doctors, waste
management and remediation professionals, coaches, researchers, and parents who donate their own
time and skills towards helping communities and individuals assess risks to their communities from tire
crumb field use. We do not have a lobbying firm, law firm, hired laboratory, consultant, or revenuegenerating source (such as tire crumb), and rely solely on the skill of researchers who donate time to
compile our comments. That said, we have found compelling data that refutes almost all claims of
safety, and when we asked for additional time to compile the information, we were given two weeks,
but denied additional time. Hence, we are working at a disadvantage, and hope that during this study
year, we will have time and opportunity to substantiate our concerns, and share our research with the
study officials. One of our comments below explains our requests for a conference or virtual meeting
that allows more disclosure and discussion.
Our comments are listed in numerically and organized into: 1. General Comments, 2. Characterization
and methodology comments; 3.Summary List of requests, and a number of supporting documents are
also submitted as part of our comments.
PART I: GENERAL COMMENTS:
17
1. CPSC/CDC/EPA should use their existing authority to immediately reclassify tire crumb
athletic fields as a children’s product, since thousands of fields have been installed in schools
that serve hundreds of thousands of children.
2. We have grave concerns about their safety to human health and the environment, since known
carcinogenic and pathogenic components in the field material yield into both air and water pathways,
and provide ample opportunity for both chronic low dose exposures with every use of the field to
lead, chromium, mercury, zinc, PAH, VOC, carbon black, styrenes, benzothiazoles, and plastics; and
more intermittent, but dangerous high dose exposures from “HOTSPOTS” of component material.
(See comments on Characterization). Each of the fields has material that is known to cause cancer,
illnesses, and injury in humans; and leachate from runoff causes several negative impacts on the aquatic
ecosystems. We believe that the potential for human illness (including several cancers) from both low
dose and high dose exposures to the ingredients in tires is staggering. Basic logic favors our position.
Based on the known potential for exposures to children, and the finding of a group of 200 soccer players
with cancer (the group represents the reach of a single charismatic soccer coach), an immediate
moratorium on new construction of the fields should be put in place with the existing authority of
CDC/CPSC/EPA, until the tire crumb fields can be shown to be safe to inhale and ingest.
3. The tire crumb recycling industry, which appears “green” in its efforts to sell millions of used tires
in “repurposed” shredded form, in fact enables a direct transfer of the contamination burden of waste
tires from landfills/collection sites (in the US and abroad) to the play surfaces of 12,000 schools and
sports centers, where tens of thousands of children and adults have direct contact with the toxins in
tire crumb materials on the field surface, and these exposures could happen with every single contact.
4. For the most part, the schools and sports centers do not have resources to conduct toxicity due
diligence; meaning, they do not have access to a toxicologist who reads the industry studies with their
health as the only priority. Purchasers rely on the tire crumb recycling industry statements, industry
studies, and industry funded websites that claim toxicology assessment and public health guidance. The
sales material can be striking, and the studies appear convincing on the surface, but our study groups
have found significantly misleading information about the safety and actual risk of harm from the tire
18
crumb fields to all users, particularly children. They are likely unaware that claims that the fields are
“SAFE TO INSTALL; SAFE TO PLAY” have been repealed.
5. PEER Filings. Public Employees for Environmental Responsibility have filed a number of complaints
and documents that argue for a repeal of endorsements of tire crumb safety from EPA/CPSC, and those
statements were in fact repealed; but most schools and potential purchasers are unaware of the
removal of endorsements and claims of safety. The PEER filings are an excellent source for telling the
toxicity story and regulatory story of this product. We respectfully request that the entire file of
complaints and responses to the complaints, and other supporting material be entered into the record
for ASTDR 2016-0002-0003.
The full list of documents for the ASTDR 2016-002-0003 collection and record can be found here:
http://www.peer.org/campaigns/public-health/artificial-turf/news-releases.html. Please include all
in that list, and all supporting materials.
6. Formal legal requests have been made to classify the tire crumb fields as a children’s product since
children use them, and sales and marketing material are very clear about tire crumb fields are for
children. CDC/CPSC/EPA should use their existing authority to explicitly label the fields as children’s
products. (Please refer to PEER filings for details and supporting arguments:
http://www.peer.org/campaigns/public-health/artificial-turf/news-releases.html)
7. CLASSIC CANCER CLUSTER APPEARANCE: SOCCER PLAYERS
Parents and schools may have trusted the “Safe to Play” statements, but the parents of the 200 young
women and men, who played intense soccer and were stricken with cancer do not trust those claims
anymore.
The case of over 200 young soccer players who used tire crumb fields and contracted cancer, strongly
indicates a classic cancer cluster, though the cases have not undergone the formal validation process,
not yet. That is because a process for the collection of this information, does not exist yet for either
cancer victims, or for other illnesses, head injuries, and heat injuries/illness from the fields.
19
8. We respectfully request that an official study of the soccer player cancer cluster be initiated by CDC
immediately.
Through our activist network, we learned about these cases, which were reported to the NBC news link,
or directly to a single, trusted concerned soccer coach. EHHI reported as follows:
______________________________________
“New Cancer Numbers Among Soccer Players on Synthetic Turf,
April 2016
It is important to remember that the only people counted in the numbers below are those who have
known to call Amy Griffin. There is still no government agency tracking the cancers among the athletes
who have played on synthetic turf. We know the actual numbers of athletes who have played on
synthetic turf and contracted cancer have to be much greater than those who have known to report
their illness to Amy Griffin.
In January of 2016, there were 159 cancers reported among soccer players; now (April 2016) there are
166. Ninety-seven of those in January were goalkeepers; now there are 102. Sixty-one percent of the
soccer players with cancer are goalkeepers. As of this writing, 220 athletes of various sports who have
played on synthetic turf have cancer; 166 soccer players who have played on synthetic turf also have
cancer.
166 Soccer Players who have played on synthetic turf and have cancer
102 are goalkeepers (61% are goalkeepers)
64 soccer players with lymphomas, 39 are goalkeepers (61%––over half are
goalkeepers)
10 soccer players with Non-Hodgkin lymphoma, 7 are goalkeepers (70%––over half)
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54 soccer players with Hodgkin lymphoma, 32 are goalkeepers (60%––over half)
41 total leukemias, 24 are goalkeepers (59%––over half)
16 total sarcomas, 7 are goalkeepers (44%)
12 thyroid, 9 are goalkeepers (75%––over half)
11 brain––5 are goalkeepers (45%)
9 testicular––6 are goalkeepers (67%––over half)
4 lung––3 are goalkeepers (almost all are goalkeepers)
Remaining are OTHER rare cancers.”
Source: Various; Victim parent volunteers, EHHI primary collection; 4/2016 (ongoing)
_____________________________________________________________
All the victims were frequent users of turf fields, spending multiple hours a week in close contact with
the material in the fields. All were in their mid-twenties or younger.
9. The self-reporting to a trusted coach, is also an indication that the actual illness rates are not yet
being properly assessed or managed by any hospital, medical system, or group; there is no “home” for
this information, yet. The 200+ cancer victim count is likely the reach of a single coach with the help of
a link in broadcast media, and a fraction of the actual count of victims of cancer or other serious
illnesses. Better investigation and creating a “safe” place to report serious and intermittent illness will
uncover many more victims, and provide needed perspective on the accuracy of risk assessment for this
product.
10. The CDC and appropriate agencies should issue a directive asking for adequate screening for
injury and disease. That US hospital and medical systems are not yet set up to collect this data is a
contributing factor; and concurrently, screening for synthetic field use should be part of a responsible
screening protocol. To our utter dismay, we learned from pediatric oncologists in our group that at least
some oncologist are prohibited from screening victims/patients for tire crumb field use; the screening
must be part of the approved protocol, and tire crumb product is not yet included..
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11. In fact, the number of all injuries from tire crumb fields should be collected and analyzed to
include, but not be limited to: head injury and concussion; joint injuries (multiple); heat injury; blood
cancer; lymphomas; testicular cancer; pulmonary illness; neurological impairment; kidney disease;
diabetes; brain disease and cancers. These findings need to be documented, and the children who
suffer from them should be screened for tire crumb field use and proximity. No doctor or oncologist
should be prevented from asking questions, screening for, or questioning the safety of this product or
contact with this product. We believe there are many more heat related illnesses, head injuries, and
endocrine system disruptions directly resulting from exposure to the fields than what is being reported.
12. REQUEST MORE INVESTIGATION INTO EXISTING AND POTENTIAL CANCER CLUSTER: We ask that
the multiagency group takes steps to expedite the process of collecting epidemiological data and
verification of the current soccer player cluster, and other potential clusters, to include field
maintenance workers who rake the fields, field installers who pour the millions of pounds of material
onto field surfaces, school custodians, high contact users of any kind, and school children in buildings
adjacent to the fields. Residences near the fields should be considered in the scope of the study or
subsequent studies. In our own informal assessment, and using SEER database and known levels of
cancer victims, we found the potential for 7-11 cancer clusters. We respectfully ask the CDC experts to
look into this possibility and take the necessary steps to prevent additional injury and cancers.
13. NEED FOR EXPLICIT PROTECTION FROM RETRIBUTION: Sadly, the families, coaches, and school
leaders who have reported illnesses do so with concern for retribution from the tire crumb industry,
school boards, university administrations, and even sports league administrators, and may need
explicit protection and remedy against retribution. Researchers who study the potential for harm tell
us that they do not have protection from retribution from tire crumb field industry proponents. Even in
our own group, public health and medical professionals must make statements of concern anonymously
to protect themselves from retribution––professionally and personally from industry proponents.
Adequate protections need to be established to protect the professionals and parents who speak out.
14. PROTECTION FOR CHILDREN IS NOT A COST-BENEFIT ANALYSIS. Children have a unique
vulnerability to toxic exposures––both intermittent high exposures––and to low dose exposures, and if
we are aware of a carcinogenic presence, then we are responsible for using a precautionary principle,
and removing that exposure risk. With due respect, this is not a cost-benefit analysis that will show a
22
percentage of children will get sick (cost) vs. tournaments played or jobs created (benefit). It is a
decision made by a civil society that upholds protection for children’s health above all other industry
priorities, and a recognition that tens of thousands of children, if not hundreds of thousands, are already
being exposed to material with known carcinogenic, and harmful materials on school turf fields.
15. The CDC/CPSC/EPA should recognize that the fields serve children, acknowledge that there are zero
safety controls on the material and the potential exposures, and immediately acknowledge tire crumb
fields as children’s products, and use your existing authority to regulate them as children’s products.
Therefore, we emphatically REQUEST THAT THE CPSC/EPA/CDC USE EXISTING AUTHORITY TO
IMMEDIATELY CLASSIFY ARTIFICIAL TURF AS A CHILDREN’S PRODUCT, SINCE THOUSANDS OF
CHILDREN ALREADY USE THE FIELDS, IN THOUSANDS OF SCHOOLS.
Since children and adults are already being exposed on tire crumb fields to the materials in tires, we ask
for an immediate moratorium on further construction of tire crumb based or recycled rubber based
artificial turf fields until adequate assurances that tire crumb particulate, off-gassing, and combinations
are safe for children to inhale and safe for children to ingest.
Your three agencies do not need to conduct a study to know with absolute certainty that tires were
not designed to be inhaled by children, and we should protect children, at any length, from chronic or
lose dose carcinogenic exposures.
Even if we cannot model or know (or will we ever know) the exposures to each child, each day (and we
will never know), we do know with certainty that:
1. Carcinogens are in tires.
2. Shredded, pulverized tire crumb contains everything in tires, and more ingredients,
including: carbon black, phthalates, VOCs, PAHs, benzothiazoles, lead, chromium, zinc,
nanoparticle additives, proprietary additives, 12 known carcinogens, 90 materials
known to be harmful to human and environmental health, (EHHI)
3. The material can be inhaled when playing and ingested with contact, or intermittent
adjacent contact.
23
4. Every single direct or indirect use has the potential for exposure to hotspots and low
dose chronic exposures to multiple scenarios of these materials.
5. The exposures could impact children, school buildings, and surrounding areas;
contamination travels to cars, homes, and even children’s bedrooms.
6. It is both within the authority and the responsibility of your three agencies to take
immediate action to protect the public, especially children, from known carcinogenic,
pathogenic exposures.
.
Only a complete moratorium on their use will protect the millions of children, athletes and bystanders
from inhalation and ingestion of the materials that yield from tire crumb synthetic turf fields.
16. It is also evident that tire crumb will never be safe unless ALL tire ingredients, all “recipes”, the
manufacturing of tires, and then preparation of materials for fields are controlled from a toxicity
perspective. This level of voluntary cooperation from the tire manufacturing industry will, of course,
never happen.
17. ONLY UNIFORM MATERIAL SAFE TO INHALE AND INGEST IS APPROPRIATE FOR SCHOOL FIELDS ;
UNTIL THEN, A MORATORIUM. When the play surface material is uniform, consistent, and controlled,
when it is tested by an adequate study with pediatric toxicology assessments to be safe for ingestion
and inhalation, and results are peer reviewed following IRB standards, then we may consider a synthetic
turf field might be safe. Until then, tire crumb should be rejected from any casual or unnecessary
contact with children or adults.
18. RECONSIDERATION: A reconsideration of the moratorium could occur when the industry can
demonstrate a uniform, non-carcinogenic, non-inhalable, non-ingestible alternative that does not
present PAH, VOCs, phthalates, lead, chromium, mercury, 1,3-benzothiazoles, butadiene, styrenes,
carbon black (in particulate, gaseous form, or any form to children); and the product undergoes strict,
peer-reviewed study by independent qualified toxicologists who have a mandate to protect children’s
health and the health of the environment above the interests of industry. The hypothetical product
should be subject to regular reviews and quality control determinations to ensure safety over the life of
the synthetic field. Safety Data Sheets should be provided and accessible for every user. If waste tires
24
are used, the controls requested above will never be possible, since the tire material, by definition, is a
composite of many toxins in unknown quantities and with unknown impacts.
PART TWO: CHARACTERIZATION OF TIRE CRUMB COMMENTS
1. SCALE AND SCOPE: Tire crumb potential to individuals, buildings, surrounding areas and stormwater
for contamination is enormous.
2. PUBLIC HEALTH ISSUE: SCALE AND SCOPE CONCEPTS
The potential for contamination from tire crumb is a growing public health issue, in terms of the relative
size of the product and its mass; the total number of potential fields; and their basic contact with
students, athletes, school personnel, buildings, communities, and streams/storm water.
To give an idea of the existing volumes of material, the field runoff and children affected or who may be
affected, we have developed reference tables, and the summary is attached to this filing These tables
indicate the scope and scale, and demonstrate that these are not isolated fields, nor tiny exposure
potentials. The quantities of material are enormous. The source and reasoning is explained, but the
tables are designed for your model development and quick reference.
3. ENORMOUS QUANTITIES ON EACH FIELD SURFACE .
To give an idea of the scale, a modest soccer field uses 30,000 waste tires. According to a randomly
selected company selling packaged tire crumb infill for original or replacement treatments, 30,000 tires
makes about 396,667 pounds of lbs of material. According to our calculations, the volume for 2” thick
field is about 525 cubic yards, However, a large football field, three times the size of a small soccer
field, could use 1,000,000 pounds of tire crumb material.
4. The tires are shredded, pulverized into crumb of various sizes, and the shredded material is poured on
top of a plastic “grass” carpet. Importantly, the material is loose, unencapsulated and can loft into the
air when struck by a ball or foot, or body. We estimate that, depending on the school, each field has
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regular, daily contact with at least 1000 athletes and students. At sports events, busy tournaments, or
with active use, a field can have contact with many, many more.
5. No fields we found have mandated capture of the leachate or particulate at the field.
6. TOTAL FIELD VOLUMES POTENTIAL:. The universe of potential tire crumb playfields is
approximately 200,000 - 220,000 schools and athletic facilities in the US, based on number of schools.
The potential reach of exposure from use of these fields is in the millions of children, millions of adults,
hundreds of thousands of exposed buildings and adjacent soils, and hundreds of thousands of public
easements and storm water access points (we estimate 1:1 ratio for field to point source drainage).
7. TABLE RUNOFF AND VOLUMES: SUMMARY OF KEY METRICS
For reference, we analysed fields by sport type, by Metropolitan Service Area, and calculated the
volumes for rainfall (by city), and for amount of tire crumb material on a field surface.
Key metrics are the following:
Estimated tire crumb per 85,000 sq feet field and 2” deep tire crumb infill is 525
cubic yards, 396,667 pounds, or 198 tons per field.
The total amount of tire crumb material on surface of 12,000 fields is
estimated to be 6,296,296 cubic yards, or 4,760,000,000 pounds or 2,380,000
tons that are currently in sports centers and schools in April 2016..
Runoff is calculated by city and field size, but the total runoff for fields in the
top 50 MSAs is 15,006,99,787 gallons.
26
Total Runoff for 12,000 fields based on number of fields per MSA, accounting for
rainfall in that MSA, and added together for 2016 is: 23,370,639,827 gallons… for
a single year.
The calculations were made to illustrate the scale and scope of this product, and to characterize the
reach of exposures from the field surface into the airway, and into the water pathway.
8. INGREDIENTS IN TIRE CRUMB: Lack Of Uniformity, High Variation, Multiple Toxins
Tire crumb appears to be a composite material, heterogenous with multiple known carcinogens,
pathogens, and mutagens. The material is not uniform, comes from multiple sources and lots, and can
be mixed with plastics and materials of unknown origin. The material can have anticlumping agents,
flame retardant additives, paint, and strengthening or characteristic enhancing additives. Shredding of
tires can cause small pieces of steel or metals to be included in the material from steel belted tires.
Some tire crumb is from newer depositories from recalled tires, some from landfills, and some have
been subjected to a variety of weather and conditions. Leachate and off gassing could be variable, with
the expectation that newly installed/poured material off-gassing is higher than from an older field, but
we expect those rates would vary with the age of the tires from which the tire crumb was made.
9. HETEROGENEOUS, MULTIPLE TOXINS, UNKNOWN ORIGIN: To say that tire crumb infill comes from
multiple sources, is an understatement: dispensaries, landfills in the US, landfills abroad, collection
centers, factory waste from China, factory waste from the US and abroad. Some of the newer marketed
blends included multi colored sport shoe waste, shoe factory waste, and many unidentified synthetic
materials. Just as tire companies may add anything to their “recipe” for a tire, an infill provider may
offer materials that could have anything added into the blend. Tire plugs, tire polishes, tire coatings, and
materials picked up on the roads should be considered. And even if it is known that there are only tires
in the blend, there is a broad variation in the ingredients based on the use of the tire, and the
manufacturer. Those tires may look the same, but from a toxicity standpoint their variation and the
unknowns in the “recipe” create a margin of uncertainty that makes any claim of known safety for
inhalation or ingestion impossible. If a vendor says he or she knows what is in a lot of tire crumb, and
that is known to be safe, then they ignored the materials in the product. Since we never know what is
27
in any field for sure, and if we know that they have tire crumb, they cannot be demonstrated safe for
children to inhale, ingest, nor play upon.
10. What Is In Tires? SOME GROUPS WENT LOOKING
Since it was difficult from MSDS or any other source to identify the components in tires or tire crumb,
some groups studied them directly.
11. Environment and Human Health Inc, and Yale University Study
EHHI, Inc. in cooperation with Yale University studied samples of rubber mulch, and new tire crumb with
the intent of characterizing their ingredients.
The summary text of their characterization study is found here:
http://www.ehhi.org/turf/metal_analysis2016.shtml
http://www.ehhi.org/turf/findings0815.shtml
The EHHI/Yale Study list of components found is explained this way:
The shredded rubber tire playground mulch samples tested were provided by the manufacturer and
were purchased in new bags of rubber mulch for use in gardens and playgrounds. The rubber tire infill
for synthetic turf fields was obtained as new infill material from installers of synthetic turf fields. There
were 5 samples of infill from 5 different installers of fields and 9 different samples of rubber mulch
taken from 9 different unopened bags of playground mulch.
RESULTS
There were 96 chemicals found in 14 samples analyzed. Half of those chemicals had no
government testing on them - so we have no idea whether they are safe or harmful to health. Of
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those chemicals found that have had some government testing done on them these are the findings
with their health effects.
TWELVE (12) KNOWN CARCINOGENS
2-Mercaptobenzothiazole/ Carcinogen, toxic to aquatic life
9,10-Dimethylanthracene/ Carcinogen, respiratory irritant and can cause asthma
Bis(2-ethylhexyl) phthalate/ Carcinogen, may cause damage to fetuses
Fluoranthene / Carcinogen, Fluoranthene is one of the US EPA's 16 priority pollutant, A PAH.
Heptadecane/ Carcinogen
2-mercaptobenzothiazole / Carcinogen
Phenol, 4-(1,1,3,3-tetramethylbutyl)/Carcinogen
Phenanthrene/ Carcinogen - A PAH
Phthalimide/ Carcinogen, skin, eye and lung irritan. A Fungicide
Pyrene, 1-methyl- /Carcinogen
Tetratriacontane /Carcinogen, eye and skin irritant. Can cause systemic damage to central nervous
system.
Pyrene/ Carcinogen, toxic to liver and Kidneys, a PAH
Carbon Black/ Carcinogen
Carbon Black makes up to 20% to 30 % of every tire. It is used as a
reinforcing filler. Carbon Black is listed as a carcinogen by the International Agency for Research on
Cancer (IARC).
Carbon Black, as such, was not analyzed by the Yale Study because Carbon Black is made up of a
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number of chemicals – some of which were found in the Yale study.
Carbon Black is not one chemical -- it is made up of many chemicals - often of petroleum products.
Furthermore, carbon black has no fixed composition, even of the many compounds it contains. Carbon
black from different sources will have
differing compositions. In our method, carbon black will register as
a series of substances extracted from it. There is no carbon black
molecule, it is a mixture.
TWENTY (20) KNOWN IRRITANTS
1,4-Benzenediamine, N-(1,3-dimethylbutyl)-N'-phenylIrritant - causes skin and eye irritation, toxic to aquatic life
1,4-Benzenediamine, N-(1-methylethyl)-N'-phenylIrritant - causes skin and eye irritation, toxic to aquatic life
2(3H)-Benzothiazolone
Irritant - causes skin and lung irritantation
2-Dodecen-1-yl(-)succinic anhydride
Irritant - causes eyes, skin and lungs irritation
3,5-di-tert-Butyl-4-hydroxybenzaldehyde
Irritant - causes irritation to eyes, skin and lungs.
Anthracene
Irritant - causes skin, eye and respiratory irritation. Breathing it can irritate the nose, throat and lungs
causing coughing and wheezing.
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Benzenamine, 4-octyl-N-(4-octylphenyl)Irritant - causes eye and skin irritation
Benzenesulfonanilide
Considered hazardous, very little testing has been done on it.
Benzothiazole, 2-(methylthio)Irritant - causes Skin and eye irritation.
Dehydroabietic acid
Toxic to aquatic organisms
Docosane
Irritant - causes Skin irritation
Hexadecanoic acid, butyl ester
Irritant - causes eye, skin and lung irritant. Can cause reproductive effects.
Methyl stearate
Irritant - causes eye, skin and lung irritation.
Octadecane
Irritant - causes kin, eye and respiratory irritation
Octadecanoic acid also known as Stearic acid
Irritant - causes skin, eye and respiratory irritation
Oleic Acid
Irritant - causes skin and eye irritation
Phenol, 2,2'-methylenebis[6-(1,1-dimethylethyl)-4-ethylIrritant - causes skin, eye and respiratory irritation
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Tetradecanoic acid
Toxic to aquatic organisms. Skin and eye irritant.
Anthracene, 2-methyl-
Acute aquatic toxicity, Not much data available - what there is shows it to be an eye, skin and lung
irritant
Anthracene, 9-methylAcute aquatic toxicity, serious eye irritant
13. Carbon Black
Carbon black plays an extraordinary role in tires, and in their toxicity and potential for harm from
exposures. Well known from decades of air pollution studies, urban epidemiological studies, carbon
black causes lung cancer, brain cancer, kidney cancer, heart disease, neurological disorders, and
cognitive degenerative disease.
A known carcinogen (WHO), we have found variations in percentages of the amount of carbon black in
a tire, from 30%-68%. (EHHI/Yale Study; NY STUDY, .pdf, pp19-20.) Carbon black breaks down into many
sized particles, including PM10/PM2.5. That size particle was shown to cause several types of cancer,
including brain cancer, kidney cancer, kidney disease, bladder cancer, and neurological disease and
cognitive impairment disorders. (CITE; Harvard Mexico Studies and Urban Cohort Studies) We know for
sure that carbon black is in tires, in part from simple observation of color.
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14. THE NY STUDY CHARACTERIZES TIRE CRUMB THIS WAY:
“The components of Firestone’s and Dow Chemical Company’s rubber are summarized in technical
specification documents. Although they are only two of many different rubber manufacturers, a
similarity between the two vendors is readily apparent, even between three different types of rubber,
solution-SBR, cold polymerized emulsion SBR, and high cis2-4 polybutadiene rubber. In general, the
following similarities were observed between the two manufacturers for the compounds used to
produce the rubber:
• The polymer used to produce solution-SBR contained approximately 18-40% bound styrene.
• The oil content in the polymer ranged from 27.3-32.5% in solution-SBR and cold polymerized emulsion
SBR. Oils used include aromatic oil, high viscosity naphthenic oil, and treated distillate aromatic extract
oil.
• Besides the polymer used, the other components of the rubber were similar between manufacturers
and the relative proportions (parts by weight) of these other components ranged as follows:
o Carbon black: 50.00 – 68.75
o Zinc oxide: 3.00
o Stearic acid: 1.00 – 2.00
o Sulfur: 1.5 – 1.75
o N-tert-butyl benzothiazole sulfonamide (TBBS): 0.9 – 1.50
o Naphthenic or aromatic oil: 5.00 – 15.0
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The components summarized above are the principal components of the major type of rubber (SBR)
used for the manufacturing of crumb rubber and therefore have the potential to have a significant
presence in crumb rubber. As discussed in subsequent sections of this report, some of these
components have been found to be prevalent in crumb rubber, including zinc (from the zinc oxide),
benzothiazole compounds (from TBBS), and PAHs (possibly from the oils used). These compounds may
be attributed to the SBR used in the manufacturing of crumb rubber.”
15. Phthalates are a regulated toxin, and PEER filings covered some of the toxicity and regulatory
discussion. Please refer to http://www.peer.org/campaigns/public-health/artificial-turf/newsreleases.html
16. ZINC
Coastal Marine Resource Center Study, found fatal levels of zinc in leachate from tire crumb fields. This
amount would cause fatal impacts to aquatic ecosystem within 48 hours. This is a notable amount, and
though was assessed in terms of environmental health, indicates presence.
Menichini and Abate Study: “Zn concentrations (1 to 19 g/kg) and BaP concentrations (0.02 to 11 mg/kg)
in granulates largely exceeded the pertinent standards, up to two orders of magnitude”. “Zinc and BaP
concentrations are high in rubber largely exceeding the Italian soil standards”.
17. METALS: MERCURY, CHROMIUM, ARSENIC
The highest median values were found for Zn (10,229 mg/kg), Al (755 mg/kg), Mg (456 mg/kg), Fe
(305 mg/kg), followed by Pb, Ba, Co, Cu and Sr. The other elements were present at few units of mg/kg.
The highest leaching was observed for Zn (2300 μg/l) and Mg (2500 μg/l), followed by Fe, Sr, Al, Mn and
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Ba. Little As, Cd, Co, Cr, Cu, Li, Mo, Ni, Pb, Rb, Sb and V leached, and Be, Hg, Se, Sn, Tl and W were below
quantification limits. Data obtained were compared with the maximum tolerable amounts reported for
similar materials, and only the concentration of Zn (total and leached) exceeded the expected values.
18. LEAD, POLITICS and CHILDREN
The problem is synthetic turf is NOT REGULATED as a children's product by the CPSC thwarting the
ability to apply lead regulations that CPSC could enforce.
Lead was identified in synthetic turf fields as early as 2008 but was not addressed in any systemic way
due to lack of standards or required testing (although the CPSC could have required the testing
mandated for children's products since 2008). The CPSC has chosen not to mandate this children's
product testing for synturf and in fact advised the industry about not having it designated as a children's
product < http://parentscoalitionmc.blogspot.com/2009/03/artificial-turf-tale-of-lead-levels.html> .
This has led to a "buyer beware" situation especially after the CPSC tested synthetic turf carpets, found
lead at varying levels depending on sample age, and astoundingly concluded the whole synthetic turf
system was, always and everywhere, safe not just for adults but for children. The assumptions were
based on inappropriate modelling for blood lead levels from a meager sampling and the troubling
finding presupposes that there is, a safe level of blood lead, which most pediatricians and lead experts
agree there is not safe level.
To this day the synthetic turf industry cites the still CPSC-posted "OK to Install, OK to Play on" press
release which should never have been posted to begin with, has been disavowed, in front of US
Congress, by CPSC commissioner Kaye and is an embarrassment to government science, policy and
public health
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19. By contrast, The Centers for Disease Control (CDC) in contrast warned and continues to warn the "
there is no safe level of lead" to expose children.
http://www.cdc.gov/nceh/lead/>
http://www.cdc.gov/nceh/information/healthy_homes_lead.htm.
“No safe blood lead level in children has been identified. Lead exposure can affect nearly every system
in the body. Because lead exposure often occurs with no obvious symptoms, it frequently goes
unrecognized"
In 2010 Van Ulirsch et al ( Environ Health Perspect. 2010 Oct;118(10):13459
22. And for the past 2 years the company FieldTurf has, with impunity, noted its synturf fields contain
lead during testimony on various bills in the Maryland State House.
The latest admission documented on video:
"....asked point-blank by one delegate, “Is there lead in your products? The executive
answered, “There’s lead in a lot of things in this world.”.... “Yes, there’s lead in our
products." In spite of this admission and the fact that the legislation in question was
meant to post the CDC prescribed warnings about minimizing lead and other toxin
exposures from the synturf and tire waste products, and in spite of the fact that the
legislation had strong and broad input and support, the legislation was not even allowed
to come up for a vote in committee by the committee chair.
23. Public Employees for Environmental Responsibility compiled the literature as of early 2012 on
lead
see: and
specifically: 2012-07-12_lead-limits-needed-on-tire-crumb-playgrounds (NOTE if you go to PEER.ORG
news releases: click on public health and "artificial turf" to find the actual filings with many links}
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Unfortunately for the children, fields with high lead remain. But those responsible for protecting
children are kept in the dark. NO ONE IS MONITORING OR REGULATING ARTIFICIAL TURF FOR LEAD OR
OTHER TOXINS in either old or new fields, including the Consumer Product Safety Commission (CPSC)
(see
For example as reported in that article:
Dr. Shalat's New Jersey State Study (2012) on artificial turf found lead in the field dust in the respirable
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air space of a robot and real player- highly variable but sometimes very high (note most facilities would
NOT LET THEM TEST).
2014
" Bio-accessibility and Risk of Exposure to Metals and SVOCs in Artificial Turf Field Fill Materials and
Fibers" , Brian T. Pavilonis1,Clifford P. Weisel1, Brian Buckley1, and Paul J. Lioy1
QUOTE from Pavilonis et al:."Since it is possible that children may be exposed to potentially high
concentrations of lead while using artificial turf fields we recommend, at a minimum, all infill and
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fibers should be certified for low or no lead content prior to purchase and installation."
*The main out-comes of concern from Pavilonis et al:
a) the finding of lead, and chromium in both the tire crumb and the plastic rug and
simulated body fluids at sometimes extremely high levels *EVEN IN NEW FIELD
CARPETS.*
b) Benzothiazole derivatives and 4-(tert-octyl) phenol were also found in in the
simulated body fluids. Both are probable carcinogens (the subject of another fact sheet).
QUOTE: "Lead was detected in almost all field samples for digestive, sweat, and total
extraction fluids with digestive fluid extract of one field sample as high as 260 mg/kg.
Metal concentrations were not markedly different across the three different sample
types (new infill, new turf fiber, tire crumb field sample). However, one of the *new*
turf fiber samples contained relatively large concentrations of chromium (820 mg/kg)
and lead (4400 mg/kg) compared to the other samples tested…the variability of lead
contained in the infill material is large and can span more than two orders of
magnitude* . One field [tire crumb] sample did contain a high lead level (260 mg/kg)
which was on the same order of magnitude as the NJ DEP cleanup value (400 mg/kg).”
In summary: Lead-free is the only acceptable level for child products (and indeed for
people in general). There is NO safe level of lead for children. And yet many of our
children are playing often, if not daily, on fields that may contain lead and certainly do
contain many other toxic substances. Finding ANY lead in any play area for children of
any age is unacceptable. As the CDC notes: Every effort should be made to eliminate ALL
unnecessary sources of lead in the environment, especially a child's environment. *Lead
in artificial turf is not only totally unnecessary but dangerous to health AT ANY
LEVEL*.
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28. Other sources of information on Lead in tire crumb fields:
www.ehhi.org/turf/
www.safehealthyplayingfields.org
www.synturf.org
[FOOTNOTE SYN TURF]Where on the Synturf page on lead you can find:
No. 36] Mayo Clinics tips to protect children from lead in artificial turf. April 2015.
No. 35] Durham, New Hampshire: Lead scare at UNH, s Memorial Field. November 2012.
No. 34] Beware of lead content in exotic color artificial turf fields! September 2012.
No. 33] Odessa, Texas: Eager fans will not be given pieces of the artificial turf field. September 2012.
No. 32] U.S. Federal panel increases child protection against lead. February 2012.
No. 31] UNLV researcher spreads word about the need to test artificial turf fields. December 2010.
No. 30] Environmental Health Sciences study (2010): Deteriorating synthetic turf dust containing lead
may pose a risk to children. October 2010.
No. 29] Concord, Mass.: Town replaces fake grass fields, officials insist nothing is wrong with the lead
levels! July 2012
28. TWELVE (12) CARCINOGENS found and HOW DO THEY INTERACT:
The Yale Study identified the presence of so many carcinogenic materials in a single material that it
raises many more questions about interaction of PAHs with metals, and combination impacts. The
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interaction of the PAHs and benzothiazoles with other materials in the fields needs to be characterized
and addressed
29. Strengthening Additives: Nanoparticles
We would also ask for information and clarity about tire strengthening additives of any kind that were
built into the material anytime in the past 30 years, these would have been added to tires.
[http://nice.asu.edu/nano/carbon-black-and-amorphous-silica-tires]
Similarly, we request that the tire manufacturing industry explain their use of nanoparticle products, of
any kind, including the type and size, source company and source country, and ask for an explanation
about how:
a. they can be quantified in the product, and
b. how can they be cleaned up if they are released when the tire crumb and or
plastic “grass” carpet degrades?
c. We would also like to understand what material characterization of their
behavior in tires performance,
d. And or their behavior once they are released into the environment.
e. We ask for any epidemiological due diligence that was conducted by any tire
company on nanoparticle use prior to using them in a commercial product.
f. Plans for continued use and safety precautions tire companies will impose upon
themselves
g. Epidemiological studies conducted on these particles in tires
30. Plastics, Microplastic Fibers, Microbeads, and Small Particulate Plastics
Assessment of microfiber particulate and small particulate plastics needs to be assessed in
characterization studies.
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31. Flame Retardants
Flame retardants can be added to a tire in production, or applied post production in a shipping setting or
possibly as tire crumb. Since flame retardants are known carcinogens with health issues of concern, and
will be on the surface of the waste tire crumb, tire infill providers need to know if they are present, and
purchasers need to know that the material contains flame retardants prior to purchase.
32. Tires and Tire Crumb Additives
Myriad products exist to clean, protect, condition, and color tires. We wonder if they are components
of tire crumb?
33. Road Waste Picked Up By Tires
Tires spend their lives on roadways, of course, and can pick up many materials in their travels. Debris,
hydrocarbons, ….
34 CARINOGENIC, PATHOGENIC, and MUTAGENIC ingredients in tires cannot be removed by
shredding tires into tire crumb and must be assumed to be accessible.
35. Tire crumb and repurposed rubber appear to be the same thing, with interchangeable use… but
are they the same? We would like clarification.
We would like clarification about the distinction between the tire crumb, repurposed crumb rubber,
and crumb rubber. Specifically if using the term “repurposed rubber crumb” implies uniformity of
ingredients? Does that term imply tires are not used? If so, what are the ingredients in repurposed
rubber crumb and how do they differ from tire crumb?
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36. We would also like access to all MSDS/SDS of tire crumb manufacturers and tire companies, and
the ability to ask questions about how and where they were made, variations on lots, source and
composite addendums. It is difficult to locate them.
37. EXEMPTION ON LISTING HAZARDOUS MATERIALS: We would like to understand why tire
companies have an exemption on their need to list ingredients under Section 2: Hazardous Materials of
an MSDS/SDS. We were unable to find the source of that exemption, if it has a deadline, and whether
your study group thinks it is an obstacle to understanding and characterizing risk of exposure from tires
and tire crumb.
38. Of those MSDS that we located, several, like this Michelin North America Material Safety Data Sheet
for Michelin, Uniroyal, BF Goodrich, says in “Section 2 HAZARDOUS INGREDIENTS: Note: Tires meet
the definition of article as defined by the OSHA Hazard Communication Standard (29 CFR 1910.1200)
and are exempt from MSDS requirements.”
There was clearly no mention of 1,3 butadiene, carbon black, POHs, VOCs, benzothiazoles, or any
plasticizers, nor metals, styrene, sulphur, known irritants, or well… anything. Since that section also
outlines corrosive, combustible and waste treatment, it is important for more than this issue. We
explicitly ask CDC/CPSC/EPA if they can use their existing authority to require tire crumb companies and
tire companies to provide ingredient information.
39. SOURCE MATERIAL UNKNOWN: MSDS/SDS CANNOT REPRESENT WHOLE FIELD. Tire crumb comes
from many tires, and many sources. Since not a single tire crumb field can accurately list or track which
tires were source materials, or what other mixed in components, and there is no accountability from
tire crumb recycling industry for the shredded product, then MSDS/SDS cannot be accurate for a whole
field due to variability. Therefore, the burden of “proof” of risk lays squarely on the ability of the
purchaser (schools, sports directors, booster clubs) to assess risk… of a very very complex product. So,
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if the exemption stays in place, we will know for sure that we cannot know what is in a tire crumb based
field.
40. TREATMENT TO SHOW NO PARTICULATE OR BREAKDOWN: SHOW US.
As for studies that claim that their product has been treated (such as cryogenic treatment) to not break
down into dangerous particulate, we are deeply skeptical, and would ask for proof. We also ask for
assay testing over a period of at least several summer weeks. We ask for the researchers to simulate the
pounding over 10 years and assess the particulate characteristics and particle size. That testing in fact is
being done right now… in thousands of children across the country. Simple observation on a player
body, on the sideline benches, or under a microscope shows consistent breakdown into particulate.
41. SHREDDED, PULVERIZED, HIGH SURFACE AREA FORM OF TIRES and ADD INS is LIKELY MORE TOXIC
THAN WHOLE TIRES.
Unfortunately, because it is shredded, pulverized, and in loose and unencapsulated form, tire crumb has
exponentially more surface area than whole tires (Thomas, Gupta study; ) and we are concerned the
material is very likely more toxic––possibly many times more toxic––in the school field form than whole
tire form, since the increased surface area provides more opportunity for molecules to escape. We
know for sure that the increased amount of surface area in tire crumb makes the material in tire crumb
more available to the breathing and exposure zones, and to runoff.
42. CRUMB IS SURROUNDED BY DUST PARTICULATE:
Accurate characterization technique must include a study of the particulate that surrounds tire
crumbs, and steps must be taken to make sure that the sampling process does not inadvertently
remove that dust and particles. We found several examples of the samples being washed, some in
unbuffered water, prior to their analyses being done. Of course, that removes the particulate that
concerns us the most. Distribution of the particulate size and type is important. Those particulate
can become aerosolized by numerous gases and we ask that attempts are made to properly model
this dynamic under high heat conditions, primarily.
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46
47
43. VERY COMPLEX PICTURE From TOXICOLOGY PERSPECTIVE: Tire crumb material is complex from a
toxicology perspective, largely due to the chemical complexity presented by multiple known toxic
components and variation. It has been described as a “toxic soup” of ingredients for which we have no
consistent data on proportions or levels. Characterization of ingredients’ margin of error is unknown..
Testing must be done at the field levels using accepted sampling plans that have been statistically
shown to be valid. Not fields have been tested in sufficient detail to determine or rule out any
exposures or risks. A look at testing protocols for lead in urban soil sites illustrate the level of
attention required and show the degree that current testing has fallen short of that needed for
decision making for children’s health.
44. CONTACT PATTERNS, FIELD USE and ADJACENT BUILDING CONTAMINATION
Exposure is likely determined by ingredients in surface, activity, and number of children or users on
field. Each school or community field has high use and high contact patterns, such as hosting contact
sports, like football, lacrosse, soccer, and baseball, athletic camps, workshops and practices. In those
sports, children dive into the field materials. As a child runs or skids or slide tackles, a column of
material rises up, as does the dust and particulate that surround the tire crumbs themselves.
Testing for exposure need to list weather conditions including humidity, wind speed, and
precipitation, temperature on field surface and ambient air temperature. Number of children on
field, and activity level of that play needs to be recorded, video would be most interesting.
Children of all ages use the fields for multiple sports, recreation and school events. Artificial turf tire
crumb fields abound in elementary schools and at indoor and outdoor sports centers where children of
all ages and all stages of development play soccer, lacrosse, football, track, cheerleading, band, and use
the field for general recreational school activities. In the fields with which we are familiar, families with
members of all ages use the fields; and the community holds events, picnics, special fairs, and activities.
Some fields are immediately adjacent to a school building.). That there are many uses, and probably
many levels of contact and exposure is an important part of characterizing exposures, but both low dose
exposures AND high contact exposure scenarios and use need to be examined, with appropriate
epidemiological process.
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45.. SCHOOL BUILDINGS AND SURROUNDING AREAS ARE CONTAMINATED with a great deal of tire
crumbs. The fields appear to lose from 1-30 tons of material over their 8-10 year life, and some of it
goes directly into buildings, cars, and then homes. This impact needs to be studied as an inadvertent
consequence.
46. CANNOT ARGUE NO INHALATION OR INGESTION RISK or SAFETY FOR EVEN A SINGLE FIELD. We
argue that given the unique characteristic of nonuniformity, known carcinogenic materials, breakdown
into particulate/dust, no known source of origin, and no accurate studies on complex interactivity of
those components in the children’s exposure zone, in the tire crumb as it is installed today in 12, 000
fields, not a single field installer, nor material provider can demonstrate that the material is safe from
inhalation and ingestion during normal use, active use, and on hot days.
47. EVERY USE COULD POSE A TOXIC EXPOSURE and it would be irrational to argue otherwise. We
argue that due to the high variability of toxins in the tire crumb substrate (from tires, unknown
additives, and factory waste add-ins), and lack of any control of the material, well-known sampling
techniques will NOT accurately predict risks to human health.
48. CHILDREN CANNOT AVOID THE EXPOSURES: Since school children cannot self-advocate and take
responsibility for staying off a field if directed to be there by coaches or school officials or parents, we
must assume that children cannot avoid the exposures when they play on those fields.
49. CANNOT CLAIM THAT EXPOSURES WILL NOT OCCUR. Absolutely no way to responsibly claim that
ingestion and inhalation of particulate from the material will NOT occur to those children.
50. HOTSPOTS of intermittent dangerous exposures are possible, and should be expected and
searched for in every field.
We must assume that tires have different “recipes” based on their type of use. Therefore, knowing the
type of tire used in tire crumb, and each tire “recipe” would be helpful in assessing characterization of
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ingredients. However, there is no way to ever know what tires, or what material is in any field, and
therefore, an MSDS/SDS cannot be representative of any field, or even any meaningful part of a field.
Alarmingly, the high variability in the ingredients presents worrisome “hotspots” potential, where the
hotspots might be missed in sampling but even a single exposure could have very serious impacts for a
child who has the unfortunate luck to dive into that hotspot. PAH’s may be more prevalent, and
present dangerous levels for installation period of the field, and for some unknown period of time
afterwards, and considered a “hotspot”, then the consistent release of PAHs in the subsequent years
could mean low dose, chronic exposures. Both need to be examined.
51. Lead, chromium, mercury and arsenic could be hotspot sources, based on which tires were used,
and how they were treated prior to being placed in the field.
52. For example, when we asked about the source of lead in tire crumb fields, an infill vendor explained
to us that a) lead could be in any field as an ingredient of the tires, of the treatment of tires, and b) once,
they were aware of a shipment of tires that was treated with an anticlumping material that contained
lead and the whole lot had lead, and c) that some lots had flame retardants added as well. They would
never really know, but “most purchasers never ask”, according to the infill material vendor. If an MSDS
was required, an additional charge was to be imposed, since MSDS were not available from the
materials they acquired from China or other countries. We have collected many more examples of the
worrisome unknown ingredients in our fields and can share with the study teams, if requested. While
this information is anecdotal, that is the point: we have no idea what is in any field, for sure.
53. Another example, but this is not anecdotal: in a primary study field exposures in CT, a researcher
found that the children’s monitors showed benzene. Since there is no safe level of exposure for
benzene, and in fact, tires are not expected to have benzene, the field was sampled more closely, until
that “hotspot” was located. The original source of that benzene was not determined, but it was next to
a busy parking lot where cars’ exhaust may have been a source as they turned the corner, or possibly
the tire crumb material had been previously stored in an area with benzene in surrounding
environment, or perhaps it was picked up from contact on roads. We will never know. That finding
suggests that the carbon black in the tires can adsorb additional toxins present near tires or tire crumb,
and could release that material as the fields are pounded with running feet, or possibly on a hot day.
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The proper characterization of this material needs to account for adsorption characteristics of carbon
black, and other interactions
54. The point is, that it is impossible to locate hotspots for all toxins in every field, and incorrect to
extrapolate the risk for a whole field from a single sample or even multiple samples, since every
sample is unique. So, while hotspots can easily be missed in a field, the unfortunate child that dives
into that particular part of a field has an exposure that can actually be life threatening, but missed in
its entirety in the sampling based risk assessment.
55. In fact, since the tire crumb creates multi sized “dust” particles, and off gases, it is impossible to
prove that even a single field is safe from inhalation or ingestion exposures from tire dust particulate,
off-gassing components, multiple toxins and combinations of toxins, and heat.
56. Importance of the Heat Factor: Source of direct injury and chemical catalyst
HOT HOT HOT HOT EXTREMELY HOT FIELDS
Grass playfields remain close to the temperature of ambient air, and are often much cooler. Asphalt
playgrounds used to have a use limit of 141F and many schools remove children from playgrounds
when temperatures get hot. With tire crumb based turf fields, surface temperatures can soar on even
mild sunny days.
Tire crumb fields “superheat” to levels that are routinely over 150F on a sunny spring day, and in a
recent study conducted on a sunny day Utah, found to be close to boiling point, 190F, according to the
Penn State Field Turf Heat Study. The study found that tire crumb field surfaces are hotter than ambient
air, and increase in heat in a non-linear function with each additional degree Kelvin of heat, hence the
designation “superheating”. To draw an example, on a Labor Day Weekend in DC area, with ambient
temps of 82F, the field surface temperature hit 164F by noon on several fields used in a busy,
tournament for about 1000 children, both boys and girls, ages 8-15. Those levels are known to melt
plastic cleats, require tubs of water on the sidelines to cool down shoes, and create heat-related injury
51
including heat stroke, nausea, heat exhaustion, and dehydration in children and all users. It is not
unusual for children players to vomit, faint, and suffer dehydration from hot conditions on the fields.
57. Marketing and sales for these fields tout their usability in all conditions as a benefit (more practice
and play hours), but in fact, the heat build up on fields makes them very uncomfortable during many
days and conditions. In DC, there are over 100 days of sunshine each year, and most are during the
spring, summer and fall, making the fields uncomfortably hot and possibly dangerously hot for a third of
a year. A calculus should be made on the percentage of safe days to play based on field yield risk, and
heat.
58. Tire crumb fields do not have any protection from heat, and so they are irrigated to be cooled
down, but the effect is temporary.
59. To our knowledge, there has been no well known place for doctors nor parents to report heat
injury, though they are commonplace. (This author specifically remembers a hot, poor air quality day in
August in 2014 in Washington DC when during a single practice, 4 soccer players vomited, another child
was taken to the hospital after passing out, and another sidelined himself against the coach’s wishes,
due to extreme dizziness and nausea.)
60. Reluctance to Report? Yet, it is curiously uncommon for school teachers, coaches and parents to
remove the children from the fields, due to temperature. We cannot explain that in rational terms.
We have also noted another curious effect: as football, soccer and lacrosse increase in popularity and
competition in the US, competition for spots on high performance teams is fierce. There is a perception
from strong sales and marketing of the fields, that the turf fields present a competitive edge for a
school, a club or even a teenager trying to get into college, and are worth the high price paid. As
psychologist Dr. Wendy Miller, explains, “ it is a culture where high performance parents, players and
schools might be willing to overlook these injuries, thinking that to complain would jeopardize their
child’s access to a competitive team. This thinking could easily lead to the silencing of reporting of
injuries.”
52
Heat injury reporting needs to be included in the survey questionnaires, and victims of heat injury and
illnesses need to have a place to report, with impunity.
61. HEAT MAKES THE CHEMICAL DYNAMICS ABOVE A FIELD VERY COMPLEX
In addition to the serious issue of direct injury from hot playfields to young children, or anyone, the
super hot fields present a very challenging chemical situation.
Dr. David Brown, ShD, toxicologist, professor and former Deputy Director of Public Health Practice
Group at ATSDR/ CDC explains that, “the unintended, and largely unstudied chemical consequences of
what comes off such an enormous quantity of high surface area material, in amounts and sequence that
is scientifically accurate is very difficult to predict and model. Since the chemicals in the area above the
field could change instantaneously, the conditions are critically important (number of players,
temperature, time from last rainfall, etc.), as is the sampling methodology. But no one has been able to
come close to modeling the actual yield, we only know the materials by characterization with samples,
and that variation in samples is so broad as to almost be meaningless, since it could be easy to miss
harmful exposures.”
62. Analyzing the field yield on a hot day is very complex, and challenging to even trained toxicologists.
The superheating of the fields makes gases yield at faster rates as temperatures on the tire crumb
surface increases. So, as a day heats up, it is very likely that the yield increases directly with temperature
increase; a hot day creates more gases. Based on well understood scientific laws, we presume that the
gas yield from the field at surface temperature of 50F (a cloudy day in January in DC) would be
considerably less than a field surface temperature of 158F measured last week. If more gases are
escaping the surface, then there are more “opportunities” for particulate to adsorb onto the surface of
the gases, creating very dynamic series of compounds, none of which would be recommended to
inhale.. The changes in the chemical composition over the fields as their temperatures rise is very
difficult to test and model. These changes happen in an instant… as a threshold is reached… and the
exposures can increase sharply. It is a very sophisticated and difficult challenge to model. But what is the
most important is not only that the 24 gases that escape tire crumb (Norway Study) create dangerous
mixtures but those gas/particulate mixtures, (and air) create a vector for deep lung exposures of all the
53
materials in the tire crumb field. So, on poor air quality days, when there are many children on the field
and a lot of stirring up of the material, the fields could present enormous risk.
63. We are concerned about the range of yield levels, but, we are most concerned about the
intermittent risk to children during those hot periods (a hot, poor air quality summer day during
children’s soccer camp week in Washington DC, for example) when the fields are likely yielding more
gas, and therefore particulate has more “carriage” into lungs, respiration rates are higher, skin is
exposed, and perspiration is highest. All these are likely factors in exposure. It is during those days when
exposures are probably highest, and high enough overwhelm a developing immune system.
64. Exposure Study Needs To Focus On Worst Case Conditions
We acknowledge that the level of yield from the fields might vary widely with material variation, and will
also vary with outdoor weather (temperature, wind, humidity and sun) conditions. Taking averages from
fields across the country will be meaningless, and will only help the industry to expand its message of
“found no harm”. An analogy might be to determine the health of a forest taking 4 samples from 40
locations, evenly spaced, but the sampling might easily miss a blazing forest fire. That one day might
destroy living material exponentially, but it could easily be missed. Dangerous exposures can be
unpredictable in this material due to the scope and scale, the toxic character, and the superheating
characteristic.
65. A better approach is to carefully detect high yield days, and look THAT DAY for exposures in a
child’s body during those periods. Since the exposures might attenuate, the work would have to be
done expeditiously. The harmful exposures may or may not be detectable a day or a month later in a
child. Monitor both genders, for patterns that might lead to that awful air quality soccer camp in the
city on a tire crumb field, on days when vomiting and melting shoes are commonplace. A focus on the
impacts from the high end of those yields we believe will present exposures that are clearly, and
unequivocally harmful from both heat injury perspective and toxicity exposure potential. We do not
know for sure if the carcinogenic exposures from low dose regular exposures or from high dose “events”
are more dangerous, but both need to be studied as separate situations, not as an average.
54
66. We urge your team to focus the study resources on primary measurements made in high use
scenarios on hot days, and refrain from the approach used in earlier studies that look at chemical
compositions during winter or rain conditions on limited number of fields.
67. The only reliable way to assess the risk to children from a particular field, or groups of fields, is to
look at their direct exposures, and importantly look at bloodlevels of the known substances.
Cooperation from both high use athletes and those exposed to chronic levels of materials will be
important.
68. The Study Needs To Focus Also On Low Dose Exposure Risks
Trained immunotoxicologists look at the impacts of chronic low dose exposures to metals, PAHs, VOCs
and many other materials in tire crumb. Their input is crucial to understanding risk of exposure in a
developing child.
69. Characterization Mistakes
Studies look convincing, but miss the forest for the trees.
Tire recycling and tire crumb industry reports are quick to point out that when they find harmful
materials in their samples, they are under the known safety limits. There are two interesting fallacies in
that reasoning.
First, since the samples in several studies are few and not uniform, they fail to acknowledge the
statistical significance of finding known regulated toxic material in 2 million pounds of powdered tires…
if one finds the needle, is it luck, or is it because needles are more prevalent than expected?
Proof of presence is meaningful! For example, in the NY Study, PAHs were found, as were metals,
benzothiazoles, and many substances. Their presence indicates a risk.
In a child’s product, since many materials are not known how they affect children, just knowing they are
there is enough to use a precautionary principle and prevent the exposure. Arguing that the materials
55
appear under a limit (especially if that quantity is an average of multiple samples), or there is no
established limit (because it has not been studied), are not as meaningful as the proof of their presence.
Second, though the conclusions of the industry reports may be of no harm found/safety, a close look at
the data itself on PAHs, lead, cobalt, chromium, etc. is useful, since a) it proves presence, and b) at
levels that suggest risk for chronic exposure. Chronic exposure risk is the subject of a great deal of new
cancer research, and we care about all the materials, including those which are potentially toxic.
70. ARGUMENT FOR MORATORIUM BASED ON KNOWN CHARACTERIZATION FOR TIRE CRUMB
Because of the:
a. known loss of 1-30 tons of material from the fields during the 8-10 year “life of the field”
into air and water
b. ingredients list: over 50% of its components are known carcinogens and pathogens, [cite
Yale Study]
c. massive scope and scale of this product, (the amount of material and surface area of
these fields is enormous; scale/millions of pounds in each installation),
d. inability to control the levels of toxic exposure to children, or even properly characterize
them due to immense variation and chemical complexity of what happens on a hot day
over a field, and around children. We cannot suggest mitigation strategies for the
danger, because the material is inconsistent,
e. Even if we did know for sure what was in each field, and suggest mitigation techniques
and protections…. All the tire company has to do is change their recipe, or many recipes,
as they do continually, and the study is worthless. Children are still being exposed to
whatever is in the tire, the lot or that particular field..
71. Moving Target Analogy
56
Even if the study were completely successful, and the tire crumb material categorized properly, the
trouble is, tire manufacturers could change the “recipe” for tires… and in fact they do this regularly…
and the study results will be useless, or at best, diminish in usefulness.
Any attempt to study tire crumb safety on turf fields is analogous to trying to hit a moving target. Tire
crumb is a waste product. Tires are not designed or intended to be used as infill for turf fields.
Ingestion, inhalation and absorption of fine particulate by children is not a consideration of tire
manufacturers as they choose chemicals and compounds for their tires. Nor are they bound to maintain
any safety considerations for such use by children.
So any study of present day tire crumb is a futile endeavor, because such study tells us nothing about a
field that gets installed immediately after the study. Tire manufacturers often change the chemical
composition of tires and will likely do so again.
Even if a field passed safely concerns in a present day study, a new field could easily fail a hypothetical
study conducted the day after the present study. So unless every field was tested using the exact same
methodology after every installation, there is absolutely no way to assure the user that their new field is
safe. Those new fields could easily have an entirely different chemical composition simply because tire
manufacturers changed their tire ingredients.
So the present Federal Study is only a backwards looking study, not forward looking. Any conclusion
must be transparent and clear on that issue - upfront and center. Otherwise the public is being misled
into a false sense of security.
57
72. Sampling: Not Appropriate For Tire Crumb
The core pediatric toxicology problem in industry based safety studies, is that there appears to be an
assumption that tire crumb is a uniform material, and behaves uniformly. It does not. There also
appears to be an assumption that sampling will be an accurate method for studying tire crumb risk to
children, and it is not. Sampling will not be accurate to assess a nonuniform, heterogeneous material
with multiple known toxic ingredients, high direct contact (dermal, hand to mouth, breathing zone)
for pediatric use. Sampling cannot produce a single sample that is representative of the whole field, or
even a part of the field, other than the sample itself.
73. Methodology needs to study PERFECT STORM exposure conditions, and be able to calculate
exposures during those relatively dangerous days.
Nor can sampling in the way it is proposed (samples from 40 fields across the US), illustrate impacts
from a perfect storm of exposure conditions on a particular field, say, during an intense soccer camp in
in summer in Washington, DC with high ambient and field surface temperatures (ie 160F), bad air
quality, no wind, when working athletes are breathing in particulate with high VOC, PAH,
benzothiazoles, and carbon black… and many more compounds, on a particularly high yield day.
Averages cannot be relied upon in sampling for this type of product, since they will further obscure the
risk from exposures to hot spots of high risk material that are on fields. Averaging the results from a
national distribution in various weather conditions simply obscures the acute risks further; it is useless
for risk analysis. In layman’s terms, it is like studying a forest using “x” number samples, but missing the
forest fire that is blazing away at a nearby area of the park. For a child, it means that she plays on a field
that was called “SAFE TO PLAY”, after sampling, but in fact she might easily have been covered with
multiple materials known to cause cancer, and in fact, that might be a regular event. The uncertainty of
exposure frequency makes the risk higher, not less.
74. The core of the methodology used in the 50 studies asserted by the tire recycling industry were
based on simple characterization of a single sample, but not on realistic, combined, nor worst case
(the most important) use scenarios.
58
75. Multiple carcinogen and multiple pathogen combined effects need to be measured. Single
material measurements could be only a fraction of the exposures, since the material exposures are likely
to be from combinations of materials.
76. BIOMONITORING FRONT AND CENTER
Because sampling presents inconclusive results, a methodology that relies on biomontioring will be
more meaningful. We suggest that more sophisticated approach be considered. Personal sampling
monitors attached to children, dermal, urine, breathing analyses, and particularly, blood and tissue
samples from frequent users, players on “Perfect Storm Days” and those expected to have chronic low
dose exposures. We understand that biomonitoring raises more issues, but absent a good model,
empirical data is the most reliable way to accumulate actual evidence of exposures and to be able to
establish a reliable causal link to the cancers and diseases we predict from exposures.
77. IMMUNOTOXICOLOGY SUPPORT: RECRUIT THE BEST PEDIATRIC IMMUNOTOXICOLOGISTS AND
RESEARCHERS. Some researchers and epidemiological professionals are already on the trail of better
ways to identify actual exposures, and can create biomarker groups as indicators of presence of illness
or exposures. These researchers have background in immunological toxicology, and can track subtle
changes in an immune system that might be precursors to serious disease, like cancer, kidney disease,
brain changes, and lung disease. It is possible to create biomarker group to prove tire crumb exposures
in users and we believe that the preliminary proof of concept step could be accomplished in less than 6
months with cooperative athletes, and study volunteers, and modest budget. While we will not list them
here, for protection of their privacy and frankly, for fear of industry retribution, we will nonetheless let
you know that we have found multiple professionals who are capable and willing to work on this task,
provided a protective forum and IRB standards are in place.
78. Immunotoxicology support: look carefully at the ages those immune system markers in all
children who are using these fields, understanding that some metabolic types, and ages may be more
59
vulnerable than others. In fact, there are early indications that certain age groups, such as
prepubescent females (age 8-11), may be more vulnerable to exposures to benzothiazoles, plastics,
phthalates, and endocrine disruptors in general, and therefore might be at higher risk to contract cancer
or disease from low dose particulate exposures from tirecrumb, and the plastic “grass” carpet
particulate. We need to establish the datum from players to study this. We still do not know, but some
indications exist. For that reason, we respectfully request that the study team include toxicologists and
epidemiologists that are trained to keep these concepts front and center.
79. LOW DOSE EXPOSURE CONCEPTS and CONCERNS
Based on what we know now about low dose exposures to VOCs, PAHs, benzothaizoles, styrenes,
carbon black, plastics, plasticizers, and metals, even at low, sub acute exposures, the fields could be very
dangerous. That possibility was not considered in the CPSC study, EPA study, nor in mulitiple industry
studies. These need to be assessed:
Chronic exposure to metals, plastics and plasticizers
Chronic exposure to carbon black mimics air pollution exposures
Immune system reactions
Endocrine disruption exposures from plasticizers and phthalates,
Exposures from multiple low doses and chronic exposures
80. The study should calculate yield of material that leaves the fields, and how it leaves the fields.
How much in the air , water pathways, and with users (in shoes, cars, etc.) Interviews with schools
and vendors need to establish the replacement quantities of these fields, and how often new material
is put into place, since it would affect exposures, and give an indication of gross yields. We estimate
that the fields lose from 1-30 tons (estimated) of material, so exposures and impacts need to be
measured in adjacent buildings, soils, and stormwater systems. With 12,000 existing facilities, this
may need to be the subject of additional studies conducted to also assess if the fields shall be
regulated as point source contamination under Clean Water Act and Clean Air Act. It is a very
important metric, and a perfect opportunity to include it, with little incremental cost, in your study.
60
81. INTEGRITY STANDARDS. To track the history of the emergence of this product is to track effective
lobbying for regulation changes that favored the tire industry, and the tire recycling industry. This
industry took advantage of an enormous quantity of recalled and used tire stockpiles, and heavily sold
and marketed the materials to schools, and sports centers where millions of children play. Central to the
steps that catapulted this industry forward was the removal of the designation of artificial turf fields as
children’s products, based on the rationale that adults played on them, too. Yet the fields continue to be
sold to elementary schools and to sports centers brimming with elementary, middle and high school
players. The sales oriented industry was willing to submit children, schools and communities to the
materials in tires in enormous amounts, and call them safe. As this claim is deeply questioned now, we
also urge you to NOT allow the sampling or data collection to be conducted by an interested party,
including schools, sports centers, athletic group personnel or administrators, field installers or
laboratories or consultants hired by those groups, and establish peer reviewed standards for testing.
82. Any group or individual who does participate in the study, including regulatory staff, needs to sign
an affidavit certifying that she or he, and her/his group has not received compensation or benefits in
any form, including but not limited to sales commissions, direct payment, compensation, bonuses,
grass to artificial turf grant, field financing, water savings rebates (State of California and possibly
others), or physical benefits including but not limited to uniforms, facility enhancements (restrooms,
concession stands, parking lots, storage facilities, etc.), stadium components, or field equipment of
any sort, from the field installers or tire crumb field industry and its assigns, and has no financial
conflict of interest. The document should be filed with an appropriate agency and made public.
83. We ask for full transparency on all parts of the study process for parents, interested parties, and
schools.
OUR REQUESTS TO ASTDR/CDC/CPSC/EPA
Request
1. Regulate tire crumb and rubber mulch as children’s product
61
Background
PEER filed formal request;
12,000 fields x 30,000 tires is the
amount of existing material in
children’s use; see table A for
details on volumes and surface area
sizes, children/schools. Known
carcinogenic material and known
contact.
2. Remove “safe to play, safe to install” or any other references that imply safety from all
EPA, CPSC and CDC websites and public information sources
3. Place all PEER artificial turf filings in Federal Record
PEER Formal Request; agencies
must remove all endorsements of
safety.
http://www.peer.org/campaigns/p
ublic-health/artificial-turf/newsreleases.html
4. Issue a directive to public health agencies to disseminate warnings regarding unknown
risks from lead exposure from AT fields, as well as exposures to carbon black, known
carcinogens, PAH, VOCs into air and water pathways; direct hospital systems and medical
systems to screen for tire crumb field use, and report results
5. Use only independent lab or consultants unassociated with tirecrumb industry, adhering
to high ethics guidelines; transparent process for review; affidavit of no conflict of interest
6. Commission a primary study, conducted by independent, peer reviewed group such as
CDC to examine existing cancers AND illness in tire crumb field users and maintenance
workers of tire crumb fields
7. Mandate Cal Recycle Study corrections to methodology; mandate methodology peer
review; and mandate to impose Prop 65 rule based on OEHHA’s own findings on
carcinogenic exposure
8. Convene a conference for presentation of risks and concerns from parent groups, cancer
survivors to Federal Research Team
9. Convene series of webinars and open comment opportunities
10. Allow public health and environmental advocacy groups in Federal Research Team
with complete transparency
11. Establish a collection point for recording experience of victims and those who may
have suffered injury from use of the fields, including heat injury, concussion or head
trauma, cognitive disorder, illness, and cancer for study and documentation; victim
hotline; for both child and adult contact with fields
12. Funding to identify potential biomarkers of exposure; conclusive marker study in users
13. Conduct blood monitoring and studies on existing cancer survivors.
14. Conduct cancer cluster study on soccer player cluster, and identify additional clusters
such as maintenance workers and installers
15. Provide full transparency with all interested parties
16. Conduct full epidemiological study of tire crumb on playfields existing and predictive
17. Study forms and questionnaires should include data collection on what is released
from fields into air, adjacent areas, water pathways, and quantified. Replacement
quantities for tire crumb fields should be quantified and examined as a metric that
indicates yield.
18. Based on release/yield figures, and other inputs, tire crumb fields should be evaluated
for compliance with Clean Water Act and Clean Air Act, and regulated accordingly.
19. We request that OEHHA study methodology be peer reviewed by your agencies
before it begins, taking into account the comments received in this proceeding.
20. OEHHA Study Process and Methodology Concerns: How will those be considered?
21. Consider explicit protection from retribution steps be put in place to protect
researchers, players, and concerned parents from retribution
62
For parents, schools, athletic groups,
and communities; conduct parent
outreach webinars
Needs participation from
CDC/CPSC/EPA staff so parents
and public can have direct contact
Page 1 of 1
PUBLIC SUBMISSION
As of: 5/3/16 6:48 PM
Received: May 02, 2016
Status: Posted
Posted: May 03, 2016
Tracking No. 1k0-8per-rnvy
Comments Due: May 02, 2016
Submission Type: Web
Docket: ATSDR-2016-0002
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill 0923-16PJ
Comment On: ATSDR-2016-0002-0003
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill ATSDR-2016-0002
Document: ATSDR-2016-0002-0085
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill 0923-16PJ Comment on
FR Doc # 2016-03305
Submitter Information
Name: Tracy Stewart
Address: 02053
Email: tracystewart903@gmail.com
General Comment
Synthetic Turf Fields with Crumb Rubber Infill ATSDR-2016-0002
Submitted by: Tracy Stewart
May 2, 2016
Please accept the following attached letter of inquiry and concern along with supporting
documents as noted.
NOTE: I AM HAVING DIFFICULTY UPLOADING MY DOCUMENT TITLED "Heat" and
"heat 2" and require assistance.
Attachments
COVER LETTER_STEWART_Synthetic Turf Fields with Crumb Rubber Infill ATSDR
ATSDR-2016-0002_STEWART_Medway Athletic Fields Follow-Up
ATSDR-2016-0002_STEWART_Medway Turf Submittal 6-30-14-2
https://www.fdms.gov/fdms/getcontent?objectId=0900006481fa207f&format=xml&showor... 5/3/2016
Synthetic Turf Fields with Crumb Rubber Infill
ATSDR-2016-0002
Submitted by: Tracy Stewart
May 2, 2016
Please accept the following letter of inquiry and concern along with supporting documents as
noted.
Background: I am a mother to a 10 yr old child who participates in sports throughout the year
including soccer. In the town of Medway Massachusetts where we reside there are currently 3
synthetic turf fields constructed with the use of tire-crumb rubber infill. (voted in May 2014 and
opened in April 2015) These fields are located on the grounds of our public High School and are
used during the school day by the physical education classes and various outdoor groups.
During the off hours when school is not in session, sports groups both independent and schoolorganized use the fields.
This spring my husband and I chose to defer our daughter’s soccer practices which were held on
the synthetic turf fields.
I have been an active and vocal resident regarding the concerns of tire-derived materials as
outlined below.
While I oppose the use of any tire-derived material in spaces where athletes or children play;
many “studies” and resources offer no definitive information. It is the desire of parents to
obtain definitive answers through the launch of this investigation known as Synthetic Turf
Fields with Crumb Rubber Infill ATSDR-2016-0002.
Concerns that need to be proven:
• HEAT: The dangers of heat were documented in Medway MA in June of 2015 as found in
attachment ATSDR-2016-0002_HEAT_STEWART
The Thermal Physics of Artificial Turf By Tom Sciacca found in: ATSDR-20160002_HEAT_STEWART2
• OFF-GASSING, see concerns addressed in attachment regarding off-gassing visible in
sunny conditions.
Regulatory issues need to be addressed and action taken:
• Use as a Children’s product: It is commonly known that Children as young as age 4 are
playing youth sports both indoors and outdoors on synthetic turf fields and playgrounds
made with tire-derived crumb rubber and rubber mulch
HEALTH:
Asthma: ?
Inhalation: ?
Cumulative exposure: ?
I strongly believe that the industry has dominated the conversation for many years through paid
consultants and hefty marketing budgets. Our government needs to listen to the parents and
athletes while also gaining first-hand experience from our perspective. The health risk associated
with tire-derived waste products used on sports field and playgrounds is extremely suspect. I
hope the agencies with consider the exposures and causes that may be associated with various
disease and illness from lung irritation through the more serious exposures leading to the
possibility of cancer.
Thank you for your consideration,
Tracy Stewart
Board of Select men
Z!ennis 7' Crowley, Chair
:Jolm :71 Joreslo, Vice-CA air
!J&cf,ad:71 7J '-9nnocenzo, Clerk
.91enn ZJ. 7rindad e
Medwa y Town Hall
155 Village Street
Medway, MA 02053
Phone (508) 533-3264
Fax (508) 321-4988
2J(aryjane WN!e
TOW N OF MED WAY
COMM ONWE ALTH OF MASS ACHU SETTS
Novem ber 3, 2014
Dear Residents:
During the last few weeks , the Board of Selectmen have received conce
rns from a
group of reside nts regard ing the safety of the mater ials being used as
infill at the
athlet ic compl ex at Medw ay High School. Specifically, these conce rns
have arisen
again follow ing a press story on NBC Nightl y News earlie r in Octob er.
That story,
however, broug ht forwa rd conjec ture and specu lation rather than scient
ific eviden ce
that a real hazard or risk is prese nt in these fields. With little in the way
of new
inform ation, the story raised fears that were broug ht forth at the outse
t of our fields
progra m, fears that were appro priate ly addressed and answe red as recent
ly as this
spring . Now, with our projec t nearin g compl etion, we again find ourse
lves as a
comm unity pausin g to be certai n that the path we have chose n for this
projec t is
indeed safe for all. As your Board of Selectmen, that is our respo nsibili
ty and you can
be certain that we take that respo nsibili ty very seriou sly.
Since the outse t of this projec t, one point is very clear: everyo ne, from
volunt eer
comm ittee members, to our electe d and appoin ted Board s, to staff alike,
is in fact
workin g toward a most comm on goal. That goal is the creati on of a new
modern field
system that is not only multi- dimen sional but most impor tantly, one
that is safe for all
those who may use it. This latter point is very clear upon a review of
the projec t
specif ication s, as well as a review of the certifi cation s and attest ations
on our
produ cts used in and on the fields. In fact, our specif ication s direct ly
require that the
turf mater ials used are lead free, and that the infill substa nce is made
with materials
that meet or exceed safety standa rds. Further, the Town has also receiv
ed a holdharml ess statem ent for any claims "relate d to hazar dous mater ials (e.g.
lead, zinc) or
other enviro nmen tal impac ts." These are signifi cant safety and legal
protective
measures that have been built into this projec t right from the beginn
ing, measures
that would not be possib le if our produ ct was anyth ing but safe. And,
since the NBC
story aired, our volunt eers and staff have again sough t to confir m this
data with our
design profes sional s and the agent s representing the manu factur es
of our produ cts.
To that end, this Board has again received assura nces that the produ
cts designed and
specif ied for the Town of Medw ay will result in a safe playin g surfac e.
FIELDS PROJECT SAFETY LEITER - NOVEMBER 3, 2014(PA GE #2)
As noted from design throug h project constru ction, the Town has placed deman
ds
upon the design firm, Gale Associ ates, to produc e docum entatio n to verify that
this
produc t's history is well known from a safety and use perspective. To date, the
inform ation received has been quite positive. In fact, as presented by Gale,
"it should be noted that crumb rubber from recycled tires has been
incorpo rated into recrea tional surface s since the early 1970's where it can be found
in
playgro und and runnin g surface s. Such use has been a recycli ng alterna tive
encour aged by the United States Environmental Protec tion Agenc y (USEPA).
As a
direct result, crumb rubber has been a highly tested and researched material.
While
there are alternative infill produc ts available (EPDM, TPE, Cork, Coconut), they
remain
relatively untested in terms of their performance, long term stabilit y, health, safety
and
environ mental risks."
Again, please be assure d that your Board of Selectmen recognizes the concer
ns that
some have raised relative to the NBC report. However, the sugges ted options
of
switch ing infill materia ls or simply halting the projec t may pose even greate r health,
environ mental and financi al risks to our Comm unity, risks that are at best
unnece ssary and at worst irrespo nsible based upon the conjec ture and innuen
do that
the aired story was based upon. Rather at this time, it is clear that the Town has
indeed taken the approp riate steps to ensure safety for all, and will continu e to
do so
as we move toward final comple tion of the fields comple x. That said, please be
reminded, as stated at the Octobe r 21 Board of Selectmen meeting, if any factual
and
scienti fic data is presen ted to the Town from State or Federal author ities that
contra dicts our curren t unders tanding , then we will respon d to that accord ingly
as
well.
What sets Medway apart from others is the commi tment, the cooperation, and
the
caring of her residen ts. Those qualitie s are again most eviden t here, and those
qualitie s will ensure that we as a Comm unity and in particu lar this Board will make
the
best decisio n today and in the future regard ing the safety of our fields and all
public
places.
Thank you!
Very truly yours,
Your Medway Board of Selectm en
Dennis P. Crowley, Chair
John A. Foresto, Vice-C hair
Richard A. D'lnnoc enzo, Clerk
Glenn D. Trindade
Maryjane White
Gale Associates, Inc.
,.._,,",'>"~"'"'*''"'-"'<1~"'"""="'"m'~~""~'"<"·""'~"'"'"'~~--~"""'~~-=""
'-=~=~·•=••="'"""-"-'
Meets Criteria for:
Certification Details
Chemical Emissions
Heavy Metals
Lead
Certificate Number: 902709
Status: Certified
Period: 5/20 I I - 5/20 I 5
Restrictions: NONE
'""'""""""'~"'""""''"""""==-"""~"""'"""'"~"'"""""''"'"""
~"""~.~~-~=~-~""~~
·-""~"""~'"""""""'"""""""""'"'''""'"""''"'~""""'''"''""'"'"'"'""-"""'-"'""''""~=r""""~~=''"""''~~~"
Reference Standard: GGPS.006 GREENGUAAD Standard for Synthetic Turf Systems and Components
Product Type: Component- infill
Specified IVOCs must produce an air concentration level no greater than 11100 the Thre$hold UmitValue (TLV) industrial workplace standard and no greater
than 112 the CA Chronic
Reference Ex!XJsure level (CREL) following usage definition in GGPS.006 GR.EENGUARD Standard for Synthetic Turf Systems and Components.
Total lead content meets the requirements of 90ppm in surface coatings (per Consumer Product Safety Improvement Act (CPSIA) of 2008).
Heavy metal limits are based on ASTM f963..()8 and the European Standard "Safety of toys," EN 71: Part 3: 199-4, Amendments -AC:. 2000 /AC: 2002.
GREENGUARD Certification affirms that products meet the criteria of the referenced standard and the requirements of the specific certification program.
Certification testing is conduaed according to a consistent. defined protocol.
-
"~,~~"""'-~""'~-=-·-==~~
,,.,
"""""""'""'"-·~~~-_,
,_ _ _.
GGPC.006/I.
\Y'.\.\\
.SyntheticTurfCoundl.\)1 g
Syn the tic Turr··
CO UNC IL
Gui deli nes for
Cru mb Rub ber Infill Use d
in Syn thet ic Tur f Fiel ds
·,v\·.·\\
.SyntheticTurfCouncil in~
Synthetic urr··
COU NCIL
Guidelines for Crumb Rubber Infill Used in Synthetic
Turf Fields
Printed October 2010
Revised October 23,2014
Copyright© 2010 by the Synthetic Turf Council
400 Galleria Parkway, Suite 1500
Atlanta, GA 30339
No part of this document may be reproduced or transmitted in any form or by any means,
electronic or mechanical, including photocopy, recording or any information storage or
retrieval system now known or to be invented, without permission in writing from the
Synthetic Turf Council, except by a reviewer who wishes to quote brief passages in a review written for inclusion in a magazine, newspaper or broadcast. The Synthetic Turf
Council is a non-profit, educational organization and possesses all rights pertaining to this
publication.
\\'\\'\\ SyntheticTurfCouncil (JIg
Synthetic urf'"
COU NCIL
Table of Contents
•
Purpose and Objectives ........................................................................................ .l
•
General Characteristics .........................................................................................2
•
Processing Standards ............................................................................................ 3
•
Certification Compliance.......................................................................................3
•
Packaging and Pallets............................................................................................4
•
Field Quality Testing and Sampling ......................................................................S
•
Standard Format MSD$ .........................................................................................7
•
About the Synthetic Turf Council ..........................................................................l l
\\ \\W
SyntheticTurfCouncil Top: 1 x 4's (measuring%" thick x 3.5" wide); gaps< 3"
=> Structural: 2 x 4's (measuring 1.5" x 3.5"), minimum of 3
=> Bottom: 1 x 4's (measuring%" thick x 3.5" wide), minimum of 3
Field Quality Testing and Sampling
Equipment:
•
Sampling stick
•
Sample splitter
•
Sample tray (width= 12", length= 12", Depth= 3")
•
High precision scale (0.01 gram)
•
Tweezers
Sampling:
•
Randomly select 3 bags (super sacks) per load ofinfill material.
•
Record the bag information such as bag number, lot number, date shipped, bill of lad·
ing number, etc.
•
Place the sampling stick into the bag vertically 3 times in 3 different locations and collect 3 samples.
•
Place the 3 samples into a plastic bag.
•
Repeat above steps until at least 3000 grams of crumb rubber are obtained.
•
Shake the collected sample well.
STC© October 2010, rev. 10/23/2014
5
c:
\\"\\'\' .SyntheticTurfCouncil.l :!,
Cownponent
EENGUARD
Synthetic Turf Certified
Liberty Tire
Turf Infill-Lockport, NY
Meets Criteria for:
Chemical Emissions
Heavy Metals
Lead
Certification Details
Certificate Number: 902708
Status: Certified
Period: S/20 I I - S/20 I S
Restrictions: NONE
Reference Standard: GGPS.006 GREENGUARD Standard for Synthetic Turf Systems and Components
Product Type: Component- in1ill
Specified IVOCs must produce an air concentration level no greater than 1/100 the Threshold Limit Value (TLV) industrial workplace standard and no greater than 112 theCA Chronic
Reference Exposure Level (CREL) following usage definition in GGPS.006 GREENGUARO Standard for Synthetic Turf Systems and Components.
Total lead content meets the requirements of 90ppm in surface coatings {per Consumer Product Safety Improvement Act (CPSIA) of 2008).
Heavy metal limits are based on ASTM F963-08 and the European Standard "Safety of toys," EN 71: Part 3: 1994, Amendments -AC: 2000 /AC: 2002.
GREENGUARD Certification affirms that products meet the criteria of the referenced standard and the requirements of the specific certification program.
Certification testing is conducted according to a consistent. defined protocol.
GGPC.006~\
®
Air Quality Sciences
January 15, 2013
Liberty Tire Recycling, LLC
Mr. David Forrester
14 North Pine Circle
Belleair, FL 33756
Subject:
AQS Project 90270, Profile Study Test Results
Dear David:
Thank you for choosing Air Quality Sciences, Inc. (AQS), an ISO 17025 accredited testing laboratory, for
your analytical needs. Attached to this letter are profile study test results, including predicted room
concentrations.
Predicted Levels Compared to
GREENGUARD IAQ Criteria
Sample Description
TVOC
Formaldehyde
Total Aldehydes
./
./
./
10+20 BM Rubber Crumb, Brantford, ON
,; ·meets erlter!a; / ~ ·meets within
2'6."1~: X~
over by more than 25% of criteria
Predicted Levels Compared to
GREENGUARD Children & Schools Criteria
Sample Description
10+20 BM Rubber Crumb, Branlford, ON
"' ·meets cntena:
meet'£ wtthm 25%:
y
X~
TVOC
Formaldehyde
Total
Aldehydes
CRELITLV
./
./
v'
---
Issues
over by more than 25% of criter1a
AQS appreciates your business. Soon you will be contacted by your GREENGUARD Program Account
Manager, John Testa (678) 444-4082.
Please keep in mind that all information obtained as part of the profile study testing is confidential as per
the signed Testing Agreement. For more technical information about the GREENGUARD program, please
visit, http://greenguard.org/en/technicaiCenter.aspx.
Sincerely,
~;11,j~
Allyson M. McFry
Chemistry Laboratory Director
Attachment:
AQS Report No. 90270-86
2211 Newmarket Parkway
Atlanta, GA 30067
770-933-0638 • Fax 77Q-933-0641
@
CONFIDENTIAL
Air Quality Sciences
Test data and interpretation applicable to
GREENGUARD Certification Program only
SYNTHETIC TURF PROFILE STUDY TEST REPORT
PRELIMINARY ASSESSMENT FOR GREENGUARD CERTIFICATION
Profile study data provides a preliminary estimate of the product's potential to qualify for GREENGUARD Certification
PREPARED FOR: LIBERTY TIRE RECYCLING, LLC
PRODUCT 90270-P0860AA; 1 0+20 BM RUBBER CRUMB, BRANTFORD, ON
ANALYTE
GREENGUARD
MAXIMUM
ALLOWABLE
LIMIT
24HR
EMISSION FACTOR
1Jglm2 •hr
168 HR
ESTIMATED
CONCENTRATION
TVOC
o.Smglnr
1,440
O.D15 mg/m•
Formaldehyde
0.0135ppm
11100TLV&
12.0
< 0.001 ppm
Individual VOCs
Yes (See Tables 1 through 3)
~CREL
BQl denotes below quantifiable level of 0.041Jg based on a standard 18 L a•r coUection volume for TVOC and 1nd1VIdual VOCs and
0.1 pg based on a standard 45 L air collection volume for formaldehyde and total aldehydes.
The predicted concentrations are based on a standard soccer field turf area usage (1 ,505 m2) in a stadium with ASHRAE 62.1-2010
ventilation conditions (94,423 m! in volume and 0.73 ACH) and assumed decay parameters (kT = 0.005; kF = 0.005; ~ = 0.005).
Analyses based on EPA Compendium Method T0·17 and ASTM D 6196 for VOCs by thermal desorption followed by gas
chromatography/mass spectrometry (TDIGC/MS), and EPA Method T0-11A and ASTM D 5197 for selected aldehydes by high
performance liquid chromatography (HPLC).
Heavy Metals
Arsenic
{AS)
Barium
fBal
GREENGUARD
MAXIMUM
ALLOWABLE
LIMIT (mg'lcg)
25
1,000
75
60
60
90
60
500
MEASURED
VALUE
< 2.5
< 100
<7.5
<6.0
<6.0
<9.0
<6.0
<50
Cadmium Fhromium Mercury
{Cdl
{Hill
fCrl
Lead
{Pb)
Antimony Selenium
{Se)
fSbl
(EN71·3. 1994 and Amendments ·A 1.2000/Ac.2002)
Test Method: Soluble heavy metals content analysis was determined by Inductively Coupled Plasma Spectrometry.
CPSIA Lead Content
GREENGUARD
MAXIMUM
ALLOWABLE
LIMIT
MEASURED
VALUE
(mglkg)
PRODUCT
COMPLIANCE
38.0
Yes
(mglkg)
RESULTS
< 90
Total Lead Content in Substrate. Consumer Product Safety Improvement Act (CPSIA) of 2008 reduced to EN requirements.
Per ASTM F963-08, the CPSIA and the European Standard QSafety of toys EN 71: Part 3: 1994
Consumer Product Safety Improvement Act (CPSIA) of 2008
H.
Metal testing completed by a CPSC approved laboratory.
Volatile organic compound (VOC), including aldehyde, testing was completed by AQS, Inc.
This test data is provided for general infonnational purposes only. The data indicate the level of emissions from the designated
product and how they compare to the emission criteria of the GREENGUARD lAO standards. This data does not imply that the
product has been qualified to meet the requirements of the GREENGUARD Certification Program nor does it imply that the product
is or is not certified by the GREENGUARD Certification Program.
2211 Newmarket Parkway
Atlanta, GA 30067
770·933·0638 • Fax 770..933·0641
Page 1 of 7
Released by Air Quality Sciences, Inc.
Date Prepared:
January 15, 2013
AQS Project#:
90270
AQS Report #:
90270·86
©2013 Air Quality Sciences, Inc.
An ISO 17025 Accredited IAQ Firm
This test is accredited and meets the requirements of ISO!IEC 17025 as verified by ANSI·ASQ National Accreditation Board/ACLASS.
Refer to certificate and scope of accreditation AT~1297
CONFIDENTIAL
Test data and interpretation applicable to
GREENGUARD Certification Program only
EMISSIONS TESTING PARAMETERS
Customer:
Liberty Tire Recycling, LLC
AQS Sample Identification:
AQS 90270-P0860AA
Product Description:
SYNTHETIC TURF; 10+20 BM Rubber Crumb, Brantford, ON
(one-sided area= 0.0361 m•)
Product Loading:
0.42
Test Conditions:
1.0 ± 0.05 ACH
50%RH±5% RH
23"C ± 1"C
Test Period:
12/05/12-12/06/12
Test Description:
The product was received by AQS on 12/03/12 as packaged
and shipped by the customer. The package was visually
inspected and stored in a controlled environment
immediately following sample check-in. Just prior to loading,
the product was unpackaged, prepared for the required
loading, and poured into a tray to expose the top surface
only. The sample was placed inside the environmental
chamber, and tested according to the specified protocol.
m•tm•
Environmental chamber test foNowing ASTM 0 5116 in a 0.09 ± 0.007 m~ chamber.
Page 2 of7
Released by Air Quality Sciences, Inc.
Date Prepared:
AQS Project #:
AQS Report#:
©2013AirQuality
January 15, 2013
90270
90270·86
Sciences. Inc.
CONFIDENTIAL
Test data and interpretation applicable to
GREENGUARD Certification Program only
TABLE 1
EMISSION FACTORS OF IDENTIFIED INDIVIDUAL VOLATILE ORGANIC
COMPOUNDS AT 24 ELAPSED EXPOSURE HOURS
PREPARED FOR: LIBERTY TIRE RECYCLING, LLC
PRODUCT 90270-P0860AA; 10+20 BM RUBBER CRUMB, BRANTFORD, ON
CAS
NUMBER
EMISSION
FACTOR
(1Jg/m2 •hr)
COMPOUND IDENTIFIED
107-21-1
1,2-Ethanediol (Ethylene glycol)1
281
95-16-9
Benzothiazolet
226
108-94-1
Cyclohexanone
73.9
108-10-1
2-Pentanone, 4-methyl (Methyl isobutyl ketone, MIBK)1
61.1
1120-21-4
Undecane
60.7
7206-29-3
6-Dodecene, (Z)-*
56.1
Decane1
49.3
124-18-5
17302-32-8
Nonane, 3,7-dimethyl*
45.0
62-53-3
Aniline
37.1
91-57-6
Naphthalene, 2-methyl
35.9
62016-14-2
Octane, 2,5,6-trimethyl*
34.2
934-74-7
Benzene, 1-ethyl-3,5-dimethyl
33.7
98-55-5
3-Cyclohexene-1-methanol, a.,a.,4-trimethyl
Formamide, N-(1, 1-dimethylethyl)-*
28.9
Dodecane
27.9
1758-88-9
Benzene, 2-ethyl-1 ,4-dimethyl*
26.5
17312-55-9
Decane, 3,8-dimethyl*
26.2
95-93-2
Benzene, 1,2,4,5-tetramethyl
26.0
91-17-8
Naphthalene, decahydro-•
25.0
2425-74-3
112-40-3
17312-53-7
28.6
Decane, 3,6-dimethyl*
23.3
123-48-8
3-Heptene, 2,2,4,6,6-pentamethyl-*
21.2
1678-93-9
Cyclohexane, butyl
19.0
Octane, 2,3,6-trimethyl*
17.8
Tridecane
16.8
62016-33-5
629-50-5
Page 3 of 7
Released by Air Quality Sciences, Inc.
Date Prepared:
January 15,2013
AQS Project#:
90270
AQS Report#:
90270-86
©2013 Air Quality Sciences, Inc.
CONFIDENTIAL
Test data and interpretation applicable to
GREENGUARD Certification Program only
CAS
NUMBER
138-86-3
96-48-0
EMISSION
FACTOR
(1Jg/m2 •hr)
COMPOUND IDENTIFIED
Limonene (Dipentene; 1-Methyl-4-(1methylethyl)cyclohexene)
2(3H)-Furanone, dihydro (Butyrolactone)
16.4
16.1
25551-13-7
Trimethylbenzene (AIIIsomers)t
15.9
77376-84-2
Tert. -butylaminoacrylonitryl*
15.4
17302-36-2
5-Ethyldecane*
14.9
91-20-3
Naphthalene t
14.9
106-42-3
Xylene (para and/or meta)t
14.7
874-35-1
1H-lndene, 2,3-dihydro-5-methyl*
14.4
Decane, 3, 7-dimethyl-*
14.4
57-55-6
1,2-Propanediol (Propylene glycol)
14.2
68-12-2
Formamide, N,N-dimethylt
13.7
Nonane, 4,5-dimethyl*
13.7
Phend
13.2
2958-76-1
Naphthalene, decahydro-2-methyl*
13.0
764-96-5
5-Undecene, (Z)*
11.1
1680-51-9
Naphthalene, 1,2,3,4-tetrahydro-6-methyl*
11.1
4292-75-5
Cyclohexane, hexyl*
10.8
475-20-7
Longifolene
10.6
Nonane, 4-methyl
9.9
147-47-7
Quinoline, 1,2-dihydro-2,2,4-trimethyl-*
9.9
629-62-9
Pentadecane
9.6
109-02-4
Morpholine, 4-methyl*
8.9
17312-57-1
Dodecane, 3-methyl*
8.7
622-96-8
Benzene, 1-ethyl-4-methyl (4-Ethyltoluene)
8.4
119-64-2
Naphthalene, 1,2,3,4-tetrahydro
8.4
629-59-4
Tetradecane
8.4
90-12-0
Naphthalene, 1-methyl
7.9
871-83-0
Nonane, 2-methyl
7.7
17312-54-8
17302-23-7
108-95-2
17301-94-9
489-40-7
99-87-6
62016-30-2
1H-Cycloprop[e]azulene, 1a,2,3,4,4a,5,6, 7b-octahydro1,1 ,4,7-tetramethyl-, [1aR-(1 aa,4a,4aj3,7ba)]*
Benzene, 1-methyl-4-(1-methylethyl) (p-Cymene; 4lsopropyltoluene)
Octane, 2,3,3-trimethyl-*
Page 4 of 7
7.5
7.5
7.2
Released by Air Quality Sciences, Inc.
January 15, 2013
Date Prepared:
90270
AOS Project #:
90270·86
AQS Report#:
©2013 Air Quality Sciences, Inc.
CONFIDENTIAL
Test data and interpretation applicable to
GREENGUARD Certification Program only
CAS
NUMBER
EMISSION
FACTOR
(1Jg/m2 •hr)
COMPOUND IDENTIFIED
110-12-3
2-Hexanone, 5-methyl*
6.5
100-52-7
Benzaldehyde
6.5
18321-36-3
Benzene, (1,1-dimethyl-2-propenyl)-*
6.3
1678-92-8
Cyclohexane, propyl
6.3
4904-61-4
1,5,9-Cyclododecatriene•
6.0
41446-63-3
7-Tetradecene, (E)*
6.0
61141-72-8
Dodecane, 4,6-dimethyl*
6.0
53927-61-0
Benzenamine, N-(2 ,2-dimethylpropyi)-N-methyl-•
5.5
581-40-8
Naphthalene, 2,3-dimethyl*
5.5
2051-30-1
Octane, 2,6-dimethyl
5.3
Propanoic acid
5.3
N-tert-Butylacetamide*
4.8
79-09-4
762-84-5
Analysis based on EPA Compendium Method
T0~17
and ASTM D 6196 for VOCs by thermal desorption followed by gas
chromatography/mass spectrometry (TD/GC/MS).
Quantifiable level is 0.04 ~g based on a standard 18 Lair collection volume.
*Indicates NIST/EPAINIH best library match only based on retention time and mass spectral characteristics.
toenotes quantified using multipoint authentic standard curve. Other VOCs quantified relative to toluene.
Page 5 of 7
Released by Air Quality Sciences. Inc.
Date Prepared:
January 15, 2013
AQS Project #:
90270
AQS Report#:
9027Q-86
@2013 Air Quality Sciences, Inc.
CONFIDENTIAL
Test data and interpretation applicable to
GREENGUARD Certification Program only
TABLE2
EMISSION FACTORS OF TARGET LIST ALDEHYDES
AT 24 ELAPSED EXPOSURE HOURS
PREPARED FOR: LIBERTY TIRE RECYCLING, LLC
PRODUCT 90270-POBSOAA; 10+20 BM RUBBER CRUMB, BRANTFORD, ON
.
CAS
NUMBER
4170-30-3
COMPOUND IDENTIFIED
EMISSION
FACTOR
(1Jg/m2 •hr)
2-Butenal
BQL
75-07-0
Acetaldehyde
BQL
100-52-7
Benzaldehyde
4.8
5779-94-2
Benzaldehyde, 2,5-dimethyl
BQL
529-20-4
Benzaldehyde, 2-methyl
BQL
Benzaldehyde, 3- and/or 4-methyl
BQL
123-72-8
Butanal
BQL
590-86-3
Butanal, 3-methyl
BQL
50-00-0
Formaldehyde
12.0
66-25-1
Hexanal
BQL
110-62-3
Pantanal
BQL
123-38-6
Propanal
BQL
620-23-5 /1 04-87-0
Analysis based on EPA Method T0·11A and ASTM D 5197 for selected aldehydes by high performance liquid chromatography
(HPLC).
BQL = Below quantifiable level of 0.1 JJ9 based on a standard 45 Lair collection volume.
Page 6 of7
Released by Air Quality Sciences, Inc.
Date Prepared:
January 15, 2013
AQS Project #:
90270
90270-86
AQS Report#:
©2013 Air Quality Sciences. Inc.
CONFIDENTIAL
Test data and interpretation applicable to
GREENGUARD Certification Program only
TABLE3
REGULATORY LIST
PREPARED FOR: LIBERTY TIRE RECYCLING, LLC
PRODUCT 90270-P0860AA; 10+20 BM RUBBER CRUMB, BRANTFORD, ON
< ()
CAS
NUMBER
107-21-1
96-48-0
110-12-3
106-10-1
62-53-3
108-94-1
50-00-0
68-12-2
91-20-3
90-12-0
91-57-6
108-95-2
79-09-4
25551-13-7
106-42-3
COMPOUND
CAL
PROP. 65
1,2-Ethanediol (Ethylene glycol)
2(3H)-Furanone, dihydro (8utyrolactone)
2-Hexanone, 5-methyl
2-Pentanone7 oz/sy
SECONDARY BACKING
TOTAL CARPET WEIGHT
PERMEABILITY
PERFORATIONS
TUFT BIND
SAND / RUBBER INFILL
ROLL WIDTH
ROLL LENGTH
Supplier/Installer Required Experience
(specification section 32 18 23)
Gridiron PRO ST
42 oz/sy
APT MFPE350DM
Proprietary PE formulation for superior wear
resistance
10,800 denier
Meets Intent of Spec
Yes
Yes
350 microns polyethylene diamond shape
2.5”
Green
1/2"
6.0 oz/sy
13 pic polybac
26 oz/sy urethane
74 oz/sy
24.5 in/hr
Standard
10.5 lbs/force
Ambient Rubber with Silica Sand
3.5 lbs/sf Rubber (53.8%)
3 lbs/sf Sand (46.2%)
6.5 lbs/sf Total Infill Weight
15’
Up to 240’
Submitted
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
The synthetic turf manufacturer must have completed a
minimum of twenty-five (25) synthetic turf installations in
the last 5 years, each in excess of 75,000 square feet.
Submitted
Yes
Turf Installation Crew: Synthetic turf installation crew
shall have installed a minimum of ten (10) outdoor
athletic field systems of similar type measuring 75,000
square feet or greater. The Turf Installation Crew shall
contain at least three (3) members who have installed at
least five (5) similar outdoor turf installations each greater
than 75,000 square feet. The designated crew foreman
shall have installed at least ten (10) similar outdoor turf
installations greater than 75,000 square feet, and shall
be subject to the approval of the Engineer. The crew
foreman shall be on site during all turf installation
procedures, and shall not be replaced without Owner
approval. Installation crew and foreman shall submit a
list of previously installed projects, by type, size, and
location for the Owner’s representative inspection at the
pre-construction conference and prior to start of Work.
Submitted
Yes
15’
Up to 240’
The synthetic turf shall be manufactured and supplied by
a company which has been in business continuously for
a period of a minimum of five (5) years under the same
name and ownership and with at least five (5) years’
experience in the manufacture and supply and of the
type of materials specified herein on projects of
comparable size to this Project.
16-18 oz/sy urethane
63 oz/sy
> 40 in/hr
Finger-Unit Drainage
9 lbs/force
Cryogenic Rubber with Silica Sand
3 lbs/sf Rubber (32.6%)
6.2 lbs/sf Sand (67.4%)
9.2 lbs/sf Total Infill Weight
15’
Up to 240’
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Historically Approved
6/30/2014
1of3
Medway High School
Turf Review Comparison Sheet
Submittal Requirement / Product Data
Submittal Requirements
(specification section 32 18 23)
Performance Specification
The General Contractor shall submit a list of previously
installed projects, to include individual owner contact
information,
by
the
proposed
Synthetic
Turf
Supplier/Installer, along with crew and foreman
qualifications at the pre-construction conference that
demonstrates
compliance
with
the
minimum
requirements of this section, 1.02, Paragraphs 1-3.
Revolution
Gridiron PRO ST
Submitted
Meets Intent of Spec
Yes
Submit a signed statement from the Infilled Synthetic Turf
System Manufacturer that the Drawings and
Specifications have been reviewed by a qualified
representative of the Infilled Synthetic Turf System
Manufacturer and major materials suppliers, and that
they are in agreement that the materials and installation
methods to be used for the Infilled Synthetic Turf System
are proper and adequate for use as a multi-purpose
athletic field in New England.
Submitted
Yes
Submit a recent reference list for the turf system
manufacturer/installer of at least five (5) outdoor high
school or college installations, each in excess of 80,000
S.F. incorporating the monofilament synthetic turf system
proposed for this project in compliance with this
specification. Minor variations in infill design in projects
cited for experience are acceptable.
Submitted
Yes
Submit a recent reference list for the turf system
manufacturer/installer of at least fifteen (15) outdoor
installations, each in excess of 80,000 S.F. incorporating
a tufted polyethylene infilled turf system.
Submitted
Yes
Job resumes of Infilled Synthetic Turf System
Manufacturer’s
Installation
Supervisor
(showing
supervision of at least ten (10) similar infilled turf
installations) and Infilled Synthetic Turf System Installers.
Submitted
Yes
Cut Sheets for all materials required under this Section
(turf, fiber, sand, rubber, etc.) including third party ASTM
certified lab gradation reports.
Submitted
Yes
Provide a sample written 8-year labor and materials
warranty from the Infilled Synthetic Turf System
Manufacturer.
Provide a sample Written Third Party Insured Warranty.
Submitted
Yes
Submitted
Yes
A signed letter on turf manufacturer company letterhead
holding the Owner, Designer and all other project
consultants harmless for any violation of patent rights or
infringements and claims related to hazardous materials
(e.g. lead or zinc) or other environmental impacts.
Submitted
Yes
Historically Approved
6/30/2014
2of3
Medway High School
Turf Review Comparison Sheet
Submittal Requirement / Product Data
Performance Specification
Provide a carpet seaming plan.
Revolution
Gridiron PRO ST
Submitted
Meets Intent of Spec
Yes
Supply shop drawings (including details) at an approved
scale for location, installation, and erection of the
synthetic turf anchoring system
Provide a striping and marking plan for all intended
sports in compliance with NFHS, MIAA, and the
Drawings for approval by the Owner and Designer.
Submitted
Yes
Submitted
Yes
Provide color samples of manufacturer’s standard
monofilament polyethylene fiber for approval.
Submitted
Yes
Provide a minimum of 12” x 12” sample of monofilament
polyethylene carpet. Provide additional carpet samples
for other colors required under this Section.
Submitted
Yes
Provide 12” long sample of seaming tape.
Submitted
Yes
Provide certified sieve analysis of sand and rubber infill
materials for approval.
Submitted
Yes
Provide a 1-quart sample of the infill mix at the
Designer’s approved mix ratio.
Submitted
Yes
Synthetic Turf Supplier/Installer shall provide a written
statement that their product is lead free prior to
installation.
Submitted
Yes
6/30/2014
3of3
Page 1 of 1
PUBLIC SUBMISSION
As of: 5/3/16 6:49 PM
Received: May 02, 2016
Status: Posted
Posted: May 03, 2016
Tracking No. 1k0-8per-e8z3
Comments Due: May 02, 2016
Submission Type: Web
Docket: ATSDR-2016-0002
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill 0923-16PJ
Comment On: ATSDR-2016-0002-0003
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill ATSDR-2016-0002
Document: ATSDR-2016-0002-0086
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill 0923-16PJ Comment on
FR Doc # 2016-03305
Submitter Information
Name: Andrew Markiel
General Comment
Please immediately classify crumb rubber as a children's product. Please see attached document
for justification.
See attached file(s)
Attachments
2016HB-05139-R000216-Sarah Evans, Icahn School of Medicine at Mount Sinai-TMY
https://www.fdms.gov/fdms/getcontent?objectId=0900006481fa2058&format=xml&showor... 5/3/2016
Children's Environmental Health Center
Department of Preventive Medicine
Icahn
School of
Icahn School of Medicine at Mount Sinai
One Gustave L. Levy Place, Box 1217
New York, NY 10029-6574
Medicine at
Mount
Sinai
Written Testimony before the Connecticut General Assembly Committee on Children
February 16, 2016
Testimony in Support of:
Raised Bill 5139, An Act Concerning the Use of Recycled Tire Rubber at Municipal and
Public School Playgrounds.
To Senator Bartolomeo, Representative Urban, and honorable members of the
Committee on Children:
We, the Children's Environmental Health Center of the lcahn School of Medicine at
Mount Sinai, strongly support Raised Bi/15139, An Act Concerning the Use of Recycled
Tire Rubber at Municipal and Public School Playgrounds. Given the hazards associated
with recycled tire rubber, it is our recommendation that these products never be used
as surfaces where children play.
As pediatricians, epidemiologists, and laboratory scientists at the Children's
Environmental Health Center of the lcahn School of Medicine at Mount Sinai, which
hosts one of 10 nationally funded Pediatric Environmental Health Specialty Units, we
have received numerous phone calls from concerned parents and physicians regarding
the wide scale use of recycled rubber surfaces on school grounds and in park properties.
This led us to conduct a review of the risks and benefits of artificial playing surfaces,
during which we found significant gaps in the evidence supporting the safety of
recycled rubber turf products. Our findings are summarized below and discussed in
detail in the attached documents: "Artificial Turf: A Health-Based Consumer Guide" and
"Position Statement on the use of Recycled Tires in Artificial Turf Surfaces".
Children are uniquely vulnerable to harmful exposures from recycled rubber surfaces.
Public playgrounds are typically utilized by children age 6 months to 12 years, a
population exquisitely vulnerable to the health effects of toxic environmental
exposures. This vulnerability is due to a number of factors including, but not limited to,
their unique physiology and behaviors, rapidly developing organ systems, and immature
1
detoxification mechanisms . Additionally, because of their young age, children have
more future years of life and therefore more time to develop chronic diseases.
1
Bearer, CF. Neurotoxicology 21:925-934, 2000.
Children's Environmental Health Center
Department of Preventive Medicine
Icahn School of Medicine at Mount Sinai
One Gustave L. Levy Place, Box 1217
New York, NY 10029-6574
Icahn
School of
Medicine at
Mount
Sinai
We have identified several potential dangers that playing on recycled rubber playing
surfaces pose to children. These include:
1. Extreme heat. On hot summer days, temperatures of over 160 degrees
2
Fahrenheit have been recorded on recycled rubber play surfaces • Vigorous play
in these conditions conveys a very real risk of burns, dehydration, heat stress, or
heat stroke. Children are less able to regulate their body temperature than adults,
making them particularly susceptible to conditions of extreme heat'. In addition,
children have a higher surface area to body mass ratio, produce more body heat
per unit mass, and sweat less than adults, all factors that increase susceptibility to
heat injury'.
2. Inhalation and ingestion of toxic and carcinogenic chemicals. Children are
particularly vulnerable to chemical exposures from playground surfaces due to
their developmentally appropriate hand to mouth behaviors. In addition, their
close proximity to the ground and higher respiratory rates compared with adults
increase the likelihood of inhalational exposures. Thus, there is a potential for
toxins to be inhaled, absorbed through the skin and even swallowed by children
who play on recycled rubber surfaces.
The major chemical components of recycled rubber are styrene and butadiene,
the principal ingredients of the synthetic rubber used for tires in the United
5
States • Styrene is neurotoxic and reasonably anticipated to be a human
6
carcinogen . Butadiene is a proven human carcinogen that has been shown to
2
Devitt, D.A., M.H. Young, M. Baghzouz, and S.M. Bird. 2007. Surface temperature, heat loading and
spectral reflectance of artificial turfgrass. Journal of Turfgrass and Sports Surface Science 83:68-82
3
https://www .a ap .org/ en-us/advocacy-and-policyI aap-hea lth-in itiatives/Ch i ld ren-andDisasters/Pages/Extreme-Temperatures-Heat-and-Cold.aspx
4
Falk 8, Dotan R. Appl Physio/ Nutr Metab. 2008 Apr;33(2):420-7. doi: 10.1139/H07-185.
5
Denly eta/ A Review of the Potential Health and Safety Risks from Synthetic Turf Fields Containing
Crumb Rubber lnfill. May 2008. http://www.nyc.gov/html/doh/downloads/pdf/eode/turf_report_OS08.pdf
6
ATSDR Toxicological Profile for Styrene, November 2010.
http://www. atsd r.cdc.gov/toxprofiles/tp53. pdf.
Children's Environmental Health Center
Department of Preventive Medicine
Icahn
School of
Medicine at
Icahn School of Medicine at Mount Sinai
One Gustave L. Levy Place, Box 1217
New York, NY 10029-6574
Mount
Sinai
cause leukemia and lymphoma 7 • Shredded and crumb rubber also contain lead,
89
cadmium, and other metals known to damage the developing nervous system ' •
Some of these metals are included in tires during manufacture, and others picked
up by tires as they roll down the nation's streets and highways. Children may also
inhale potentially harmful chemicals that have been detected in the air above
rubber turf such as benzathiazole and polycyclic aromatic hydrocarbons (PAHs),
10
both of which are linked to cancer .
It is important to note that risk of harm due to exposures from recycled rubber
turf has been assessed only for single chemicals, yet children are exposed to
numerous harmful chemicals in aggregate during play on these surfaces. It is
widely recognized that carcinogens and other environmental toxins act in an
additive or multiplicative fashion, making risk assessment ofthe chemical
mixtures present in recycled rubber critical for a comprehensive safety
11
assessement . Because tire rubber composition varies by manufacturer, it is
impossible to know the full contents of chemicals contained within a recycled
rubber playing surface. For a more comprehensive description of the harmful
chemicals contained within recycled rubber products, please see the attached
Consumer Guide.
4. Transportation home of rubber pellets. Recycled rubber materials used in play
surfaces break down into smaller pieces over time that may be picked up on
children's shoes, clothing and skin. The rubber is then tracked into children's
homes and cars, and carried into the places where children live, play, eat and
sleep. Thus exposure can continue for many hours beyond the time that a child
spends in the play area.
'International Agency for Research on Cancer, 2008.
http:/I monogra p hs.ia rc. fr/ENG/M o nogra phs/voi100F /m ono100F-26. pdf
8
Timothy Ciesielski eta/. Cadmium Exposure and Neurodevelopmental Outcomes in U.S. Children. Environ
Health Perspect. 2012 May; 120(5): 758-763. 27. doi: 10.1289/ehp.l104152
CDC (2012) Low Level Lead Exposure Harms Children: A Renewed Call for Primary Prevention.
http://www.cdc.gov/nceh/lead/acclpp/final_document_010412.pdf
10
Connecticut Department of Public Health (2010) Human Health Risk Assessment of Artificial Turf Fields
Based Upon Results from Five Fields in Connecticut.
http://www.ct.gov/deep/lib/deep/artificialturf/dph_artificial_tu rf_report.pdf
11
Goodson WHet a/2015. Assessing the carcinogenic potential of low-dose exposures to chemical
mixtures in the environment: the challenge ahead. Carcinogenesis 36(Suppl1):5254-5296.
9
Children's Environmental Health Center
Department of Preventive Medicine
Icahn
School of
Medicine at
Icahn School of Medicine at Mount Sinai
One Gustave L. Levy Place, Box 1217
New York, NY 10029-6574
Mount
Sinai
5. Escape of chemical hazards from rubber surfaces to the environment. A number
of the toxic and chemical components of the recycled rubber that is installed on
playgrounds are soluble in water. When rain and snow fall on synthetic fields,
these materials can leach from the surface to contaminate ground water and
12
soil • In addition, chemicals in turf can be released into the air and inhaled,
particularly on hot days.
Disposal of recycled rubber surfaces. A further unresolved issue is what to do with the
toxic components of recycled rubber play surfaces 10 years from now when they reach
the end of their usable life-span and need to be dismantled. The costly process of
separating, reclaiming, reusing, recycling, or disposing of the various components of a
turf field are often overlooked at the time of installation. What will disposal cost? Who
will pay? Often, these questions have not been factored into the overall cost.
Safe alternatives to recycled rubber playground surfaces exist. Daily outdoor play and
physical activity are essential components of a healthy childhood. Thus safe play areas
are critical to any school environment. While it is important to minimize playground
injuries, the Consumer Product Safety Commission Public Playground Safety Handbook13
contains several additional safe and affordable alternatives such as wood mulch, which
does not carry the same risks of chemical and heat exposure outlined above.
The potential long-term consequences of exposures to synthetic rubber play surfaces
have not been carefully assessed by independent third parties prior to their installation
throughout the country. For this reason, Senator Richard Blumenthal called upon the
federal government to conduct comprehensive studies to verify the safety of recycled
rubber for use in areas where children play- including playgrounds 14• Subsequently, on
February 12, 2016, the United States Environmental Protection Agency announced the
launch of an investigation into the safety of crumb rubber in partnership with the
Centers for Disease Control and Prevention and the Consumer Product Safety
12
Connecticut Department of Environmental Protection (2010) Artificial Turf Study: Leachate and
Stormwater Characteristics.
http://www.ct.gov/deep/lib/deep/artificialturf/dep_artificial_t urf_report.pdf
US Consumer Product Safety Commision. Public Playground Safety Handbook. #365, November 2010.
https:/ /www.cpsc.gov/ /PageFiles/122149/325.pdf
14
http://www .n h register.com/a rticle/N H/20151106/N EWS/15110963 7
13
Children's Environmental Health Center
Department of Preventive Medicine
Icahn
School of
Medicine at
Icahn School of Medicine at Mount Sinai
One Gustave L. Levy Place, Box 1217
New York, NY 10029-6574
Mount
Sinai
Commission, stating "existing studies do not comprehensively evaluate the concerns
15
about health risks from exposure to tire crumb" . In the absence of convincing
evidence of safety, we recommend that children not play on recycled rubber surfaces
that contain known carcinogens and neurotoxins and support a ban on the use of
these products.
We urge your support of HB 5139 in order to protect the health of the children of
Connecticut. Thank you for the opportunity to provide you with our professional
opinion. We would be more than happy to answer any questions that you might have.
Kind Regards,
Robert Wright, MD, MPH
Director, Mount Sinai Children's Environmental Health Center
("'
,.-\
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7/| File Type | application/pdf |
| Author | sgd8 |
| File Modified | 2016-07-11 |
| File Created | 2016-07-11 |