Public Comment - Methodology

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PUBLIC SUBMISSION

As of: 3/15/16 5:47 PM
Received: March 08, 2016
Status: Posted
Posted: March 14, 2016
Tracking No. 1k0-8odw-v9vh
Comments Due: April 18, 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-2016-0002-0011
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill 0923-16PJ Comment on
FR Doc # 2016-03305

Submitter Information
Name: William Barrett
Address: 21740
Email: wbbarrett@gerstelus.com

General Comment
Early chemical analysis studies, such as published by Brown,et.al. offer data from The
Connecticut Agricultural Experiment Station which used solid phase micro extraction (SPME)
technology. This technique has know limitations and new more sensitive techniques have been
brought to market by a number of technology providers. One of the more interesting and likely
more sensitive tools would be a large volume dynamic static headspace followed by for
example, high resolution mass spectrometry.
Certainly, using more advanced and appropriate analytical technologies is imperative in
properly understanding what if any emissions might be found from crumb rubber and turf
fields.

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PUBLIC SUBMISSION

As of: 3/24/16 9:31 AM
Received: March 18, 2016
Status: Posted
Posted: March 23, 2016
Tracking No. 1k0-8oko-5r2s
Comments Due: April 18, 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-2016-0002-0014
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill 0923-16PJ Comment on
FR Doc # 2016-03305

Submitter Information
Name: Christopher Peterson
Address: 98109
Email: Chris@impresys.com

General Comment
I am a concerned parent from the Seattle area.
Please include the following in analysis:
1. Exposure from off-gassing when field temperatures rise to over 100 degrees in Summer
2. Exposure from off-gassing in indoor facilities with inconsistent air circulation and high
ceilings (Starfire sports complex, Tukwila. Wa)
3. Exposure from broken skin injuries (turf burns) when combined with on-field bacteria and
when not removed properly from skin
4. Exposure when a piece of crumb rubber enters a player's eye, and stays in overnight
5. Exposure from long term contact with skin, such as pellets that stay inside shoes for months
on end
6. Exposure from crumb rubber inhaled through nose or throat
7. Exposure from crumb rubber swallowed and lodged in intestines
8. Exposure from long term contact with skin (such as forearms) when not properly or fully
cleaned (builds up on child's skin the way oil builds up on the hands of a mechanic)
9. Exposure from long term inhalation at close range (12 inches from surface) which happens to
goalies who dive into the substance repeatedly in drills and catch balls ejecting the substance
into their faces
10. Publish raw data and testing summaries, durations for public review

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PUBLIC SUBMISSION

As of: 4/28/16 11:22 AM
Received: April 15, 2016
Status: Posted
Posted: April 22, 2016
Tracking No. 1k0-8p39-1hhr
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-2016-0002-0024
Comment on FR Doc # 2016-03305

Submitter Information
Name: Jerome Silbert M.D.
Address: 06437
Email: waterpartnership@SBCglobal.net

General Comment
I am a physician trained in pathology with boards in anatomic pathology, clinical pathology and
blood banking. I have been following the controversy over tire crumb rubber for several years
and have reviewed a number of the published studies on this matter.
I congratulate the governmental agencies for taking up this important matter to establish
whether ground up tires used on artificial grass fields in the form of crumb rubber is a suitable
for children to play on.
After reviewing a number of studies I must conclude that, thus far, the studies are totally
inadequate to establish the safety of tire crumb rubber for artificial grass playing fields.
Background:
A recent study at Yale University was done on shredded tires and tire crumb rubber by Gaboury
Benoit, Professor of Environmental Chemistry, Professor of Environmental Engineering, CoDirector of the Hixon Center for Urban Ecology, Director of the Center for Coastal and
Watershed Systems.
Crumb rubber from tires is a very heterogeneous material coming from tires that have many
different chemical compositions so it is legitimate to include shredded tires that are used on

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playgrounds as well as crumb rubber that is used in artificial grass to see to what chemicals
children will be exposed. Professor Gaboury's findings were quite shocking.
96 chemicals were 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 those
chemicals found that have had some government testing done on them, there were 12
carcinogens, and 20 irritants.
There is no dispute over the fact that there are carcinogens and toxic compounds in tires and
products made from tires. The claims of safety rely upon assumptions about whether exposure
to these chemicals (and metals) are within levels recognized as safe.
There are number of reasons why I believe the studies thus far are totally inadequate.
1) When the determination is made that the exposure to toxins and irritants is within safe levels
it is based on studies of the toxicity of each individual chemical. If all the chemicals are shown
to be within safe levels of exposure the conclusion is made that there is minimal if any risk.
This conclusion is totally unjustified because it does not take into account that the exposure is to
many of these chemicals simultaneously. It is well established that when toxic chemical
substances are combined together (termed the combination effect) they can cause adverse
effects to human health, even if the individual chemical substances are within levels considered
safe. It is my hope that you will take this into account when you do your safety assessments.
2) To my knowledge, there have been no in vivo studies regarding frequent and close contact
with tire crumb rubber. There is a requirement for these kinds of studies for pharmaceuticals
and for pesticides. But apparently not for tire crumb rubber. Instead of assuming that exposure
levels are safe, Particularly when the exposure is to a complex mixture of toxic agents and
irritants, it only makes sense to do toxicity studies with living systems that are actually exposed
to the complex mixture to which children will be exposed.
I find it a serious flaw even in pesticide testing that only the active agent in the pesticide is
tested for in vivo toxicity when, in actuality, the way the pesticide is used is in combination
with a mixture of chemicals designed to enhance the pesticides toxic effect and, in many cases
in combination with other pesticides.
When such studies are conducted, it should be kept in mind that crumb rubber fields can reach
very high temperatures in the sun and give off larger amounts of volatile organic compounds.
In there is to be any confidence in your study, in vivo toxicity testing needs to be done with the
crumb rubber to which children and athletes are actually exposed.
3) Amy Griffin a goalkeeper for the U.S. National team has been informally tracking American
soccer players with cancer since 2009, when she noticed a number of young athletes who'd
played soccer on artificial fields were getting sick.
In 2014 Griffin, had heard from 38 soccer players who'd been diagnosed with cancer (mainly
non-Hodgkin's lymphoma). That tally has climbed to 220 athletes - 166 of them soccer players.
Of the soccer players, 102 were former goalkeepers who spent more time on the ground and

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were more exposed to crumb rubber than their teammates.
This points to the need of a epidemiological study to see if there is indeed an abnormal increase
in cancers among athletes that play regularly on artificial turf with crumb rubber infill.
Important to note is that lymphomas often have a long lag time between exposure and
manifestation of the disease.
Thank you for this opportunity to comment.
Respectfully,
Jerome A. Silbert, M.D.

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PUBLIC SUBMISSION

As of: 4/28/16 11:30 AM
Received: April 17, 2016
Status: Posted
Posted: April 22, 2016
Tracking No. 1k0-8p4m-mych
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-2016-0002-0030
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill 0923-16PJ Comment on
FR Doc # 2016-03305

Submitter Information
Name: Kathryn Vallance
Address: V8R5T7
Email: kathrynvallance@yahoo.ca

General Comment
1. Will you address nano-particles, nano tubes and carbon black which are all known
components of tire manufacturing?
2. Will you consider that families playing on crumb rubber have "continual exposure" to the
material as it gets on the bodies, in the sports bags, the cars, homes, laundry, air vents of
everyone at the games.
3. Will you include pregnant women, and toddlers in your study as they are also exposed?
4. Will you review regulatory levels of chemical exposure at tire plants that have been set as
acceptable and have still produced groups of workers with elevated levels of cancer and heart
disease?
5. Will you have cooperation of any tire manufactured to determine what chemicals have gone
into making tired over the last 30 years focusing on the era of the tire that is most likely to be
used in the crumb rubber on the fields today?
6. Will you consider the vulnerability of children, their growing bodies, increased breathing rate
and their expisure to the field because they are smaller?
7. Will you consider that regular exposure to a variety of carcinogenic chemicals on a regular
basis may in fact be as harmful to a child's body as the rare exposure to a moderate - highly
toxic chemical?

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PUBLIC SUBMISSION

As of: 4/28/16 11:32 AM
Received: April 18, 2016
Status: Posted
Posted: April 22, 2016
Tracking No. 1k0-8p55-a6g4
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-2016-0002-0033
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill 0923-16PJ Comment on
FR Doc # 2016-03305

Submitter Information
Name: Kevin McKeon

General Comment
Lacking conclusive scientific evidence regarding crumb rubber, we must accept that the
growing discussion is about RISK assessment, RISK mitigation, and RISK level acceptance.
These risks include heat stresses and injuries and, according to a recent Yale study, exposure to
99 chemicals variously listed as irritating, harmful, and suspected/known carcinogens.
Government Exposure Limits are not health-based, they are risk-based...a compromise of many
factors: environmental, scientific, financial, political, and business-friendly issues. All credible
studies prove the presence and probable exposure to these chemicals. Turf manufacturers and
installers recognize this and require users to release them from health and safety liability claims.
Studies and satellite imagery prove the creation of "heat islands" on and over crumb rubber
fields. The surface is monitored and watered when overly hot. Vigorous play in these conditions
results in burns, dehydration, heat stress, or heat stroke. Kids bodies, being closer to the heat
source, with a higher surface-area/body-mass ratio, producing more body heat per unit mass,
and sweating less than adults, are particularly susceptible to heat stresses.
Over time, crumb rubber reacts with light, heat, air, seasonal temperature fluctuations,
mechanical agitation from play and maintenance operations, etc., becoming hard, brittle,
cracked, discolored, and powdered; this hardening and cracking can be noticed on old sneakers.
The CDC's 2008 advisory says that as turf ages and weathers, "lead is released in dust that
could then be ingested or inhaled." This rubber erosion happens down to the molecular level,
resulting in a persistent atmospheric chemical contamination over the playing fields and their

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immediate areas. (More on this later).
The most dangerous item of this disintegration process could prove to be carbon nanotubes.
About 30% of a tire is composed of carbon black; puff out a candle...that black, wispy stuff is
carbon black. Engineered carbon nanotubes (and other engineered nanoparticles...zinc, titanium,
etc.) are made in specific shapes to give strength and durability to tires. It is the long thin nature
of engineered carbon nanotubes that has scientists comparing them with asbestos; studies
suggest that inhaling carbon nanotubes could lead to the same cancer and breathing problems
that prompted a ban on asbestos, and carbon nanotube exposure tests on mice result in the
formation of lesions known as granulomas. From Dr. Kathleen Michels, Neuroscientist,
Administrator, National Institute of Health: "...it has the potential to wreck everything in its
path. First, it has been declared a possible carcinogen by the US government and by the World
Health Organization. Then, carbon black used in tires consists of the purest, smallest (ultra-fine)
nanoparticles giving them a unique potential toxicity throughout the body. ...when you
pulverize tires for use in children's playing fields, they become more available to interact with
the environment and people with weathering and the impact of each child's footfall and
body...When children's life-long health is at stake, the precautionary principle should apply."
Toxicologist Dr. David Brown, Emeritus, (Public Health Toxicologist and Director of Public
Health Toxicology for Environment and Human Health, Inc.) says that tire crumb off-gases 24
harmful materials, and that the amount of off-gassing increases as the tire crumb heats. Carbon
black, which makes up 30% of black tires, is carcinogenic and breaks down into very small
particles called nano-particles. Those small carbon black particles attach onto the surface of the
gases, which then penetrate into the deep lung as the child breathes. These gas/particle mixtures
are 10-20 times more toxic than the materials alone. We know from air pollution studies that
looked at these mixtures that they cause serious disease." These nanoparticles are known to pass
the blood/brain barrier, attacking at the molecular level; some scientists state the need for
studying the effects of nanotubes on DNA function.
During heat mitigation operations, water is sprayed over the field causing evaporative cooling.
The rising water vapor picks up these nanotubes and atmospheric contamination mentioned
earlier, causing an unseen but dangerous "fog of chemicals" within which the kids are playing.
The resultant risk to our kids safety and health is intuitively obvious, and as part of their
decision process, the decision makers should apply The Precautionary Principle: "When an
activity raises threats of harm to human health or the environment, precautionary measures
should be taken even if some cause and effect relationships are not fully established
scientifically." Examples of the essence of the Precautionary Principe are: "an ounce of
prevention is worth a pound of cure", "better safe than sorry", "look before you leap", and the
well known medical oath "First, Do No Harm".

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PUBLIC SUBMISSION

As of: 4/28/16 11:34 AM
Received: April 21, 2016
Status: Posted
Posted: April 22, 2016
Tracking No. 1k0-8p74-bdt4
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-2016-0002-0035
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill 0923-16PJ Comment on
FR Doc # 2016-03305

Submitter Information
Name: C Ellis
Address: 30707
Email: charles-ellis@hotmail.com

General Comment
How will the issue of inhomogeneity be addressed when testing crumb rubber?
This is the inherent problem of arriving at definitive testing results when considering the total
mass of crumb rubber
in a playground, sports pitch, or any other use.

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PUBLIC SUBMISSION

As of: 5/3/16 6:26 PM
Received: May 01, 2016
Status: Posted
Posted: May 02, 2016
Tracking No. 1k0-8pdh-ydk3
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-2016-0002-0056
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill 0923-16PJ Comment on
FR Doc # 2016-03305

Submitter Information
Name: Anonymous Anonymous

General Comment
I am happy to hear that more comprehensive studies are under way on crumb rubber and its
exposures, however I am deeply troubled with hearing it is going in at my child's elementary
school this year and all of his succeeding schools for the rest of his public education at San
Diego Unified School District. I substitute taught at an elementary school with a new crumb
rubber field and the children were rolling in these fields, eating their snacks and dropping their
water bottles on the field, and I even saw some of them making mountains out of the tire pellets.
It was in their hair, around their mouth, on their hands, and quite possibly on their water bottles
and snacks that were dropped on the artificial turf. It didn't look right at all and it's not right.
Our kids aren't possibly going to be ingesting this stuff or getting it in their eyes or an open
wound, they are RIGHT NOW! And NOBODY can tell us that it's safe!
I hope these studies will look extensively into ingestion and dermal contact with young
children, ages 1-10, with years of exposure to crumb rubber, but I wonder....how can that be
done in a 1-2 year study? I know that science can take decades to prove a chemical is unhealthy
or even deadly. How many decades did it take to prove cigarettes and asbestos were dangerous?
How many decades will it take to prove the same of crumb rubber? All while our children are
the canaries in the coal mine. I hope all schools and communities can put a ban on crumb rubber
until these studies are complete. Inform parents of those kids that are playing on this kind of turf
and that proper cleaning after playing on them and the restriction of food and drinks needs to be
posted and made aware to the parents/children/athletes. There are safer, non-toxic alternative
infills out there; new and improved products to look at. Crumb rubber is old,outdated and was a
bad idea to begin with. Let's stay with natural turf or keep the dirt, it's better for our

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environment as well. Our children and our Mother Earth deserve better!
I will look forward to what the studies will find.

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PUBLIC SUBMISSION

As of: 5/3/16 6:27 PM
Received: April 29, 2016
Status: Posted
Posted: May 02, 2016
Tracking No. 1k0-8pcl-qb2u
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-2016-0002-0057
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill 0923-16PJ Comment on
FR Doc # 2016-03305

Submitter Information
Name: David Marker

General Comment
See attached file(s)

Attachments
Westat comments on Synthetic Turf Fields with Crumb Rubber Infill

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“Collections Related to Synthetic Turf Fields with Crumb Rubber Infill”
Date Posted: Feb 18, 2016;
Federal Register Number: 2016-03305
Docket No. ATSDR-2016-0002
Comments to the ATSDR PRN - ``Collections Related to Synthetic Turf Fields with
Crumb Rubber Infill.''
ATSDR and EPA have requested comments on “ways to enhance the quality, utility, and clarity
of the information to be collected.” Our comments address whether the current design is robust
enough to capture the breadth of uses, and therefore exposures, for the population of the
United States.
Survey #1 plans to enroll “10 facilities in each of the four US census regions.” A large
percentage of the 12,000 synthetic turf fields are at high schools, while others are at postsecondary institutions or are not connected to educational facilities. The key questions the
survey hopes to ask concern activity use patterns, field maintenance, and other procedures
potentially affecting exposure. These are likely to vary greatly not only by region, but by the
operating entity and the typical age of users. Large and small school districts may have very
different patterns of maintenance. Some schools may tightly control access to their students,
while others may make the fields available to many sporting events by children of many ages.
Our concern is that 40 facilities will not capture this great variety of operating conditions and
users. Table 6 of Part B of the ICR indicates, for example, that only 2 outdoor fields older than 5
years would be included from throughout the Midwest. EPA’s Office of Children’s Health
Protection has as its mission to ensure that EPA considers the unique risks to children as part of
risk assessments and other activities. To understand these unique risks will require understanding
access to these fields by people of different ages, and the maintenance and related characteristics
of those fields.
To collect the information needed to address these concerns will require significantly more than
40 fields to be enrolled in survey #1.
Survey #2 is to characterize exposure potential during activities conducted on synthethic turf
with crumb rubber infill. The proposed design anticipates collecting this information from 60
people connected to a subset of these 40 fields. Again, the great variety of ages of users of the
fields will not be adequately captured by collecting data from only 60 people. For example, Table
8 of Part B of the ICR anticipates responses from around 6 youth 6-to-8 years old. We urge that
a larger sample be considered.

-2We recognize that these two studies are viewed as pilot scale, they are not meant to provide
national estimates. That is a reasonable approach if the findings are to be used to design a future
study that would indeed measure the types and level of risk. Such a national study (along with
the decision-making resulting from the findings of the study) would greatly benefit if the pilot is
robust enough to provide insights into the great variety of conditions and uses found across this
country.
David Marker
Associate Director and Senior Statistician
Westat
DavidMarker@Westat.com

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PUBLIC SUBMISSION

As of: 5/3/16 6:28 PM
Received: May 02, 2016
Status: Posted
Posted: May 03, 2016
Tracking No. 1k0-8pef-tfe5
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-2016-0002-0058
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill 0923-16PJ Comment on
FR Doc # 2016-03305

Submitter Information
Name: Ami Gadhia
Organization: American Academy of Pediatrics

General Comment
See attached file(s)

Attachments
AAP Crumb Rubber Comments FINAL

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AAP Headquarters
141 Northwest Point Blvd
Elk Grove Village, IL 60007-1019
Phone: 847/434-4000
Fax: 847/434-8000
E-mail: kidsdocs@aap.org
www.aap.org
Reply to
Department of Federal Affairs
Homer Building, Suite 400 N
601 13th St NW
Washington, DC 20005
Phone: 202/347-8600
Fax: 202/393-6137
E-mail: kids1st@aap.org

May 2, 2016
Pat Brysse, Ph.D.
Director
Agency for Toxic Substances and Disease Registry
Centers for Disease Control and Prevention
1600 Clifton Road NE
MS–D74
Atlanta, GA 30329
Docket No: ATSDR–2016–0002

Executive Committee
President
Benard P. Dreyer, MD, FAAP
President-Elect
Fernando Stein, MD, FAAP
Immediate Past President
Sandra G. Hassink, MD, FAAP
Executive Director/CEO
Karen Remley, MD, FAAP
Board of Directors
District I
Carole E. Allen, MD, FAAP
Arlington, MA
District II
Warren M. Seigel, MD, FAAP
Brooklyn, NY
District III
David I. Bromberg, MD, FAAP
Frederick, MD
District IV
Jane M. Foy, MD, FAAP
Winston Salem, NC
District V
Richard H. Tuck, MD, FAAP
Zanesville, OH
District VI
Pamela K. Shaw, MD, FAAP
Kansas City, KS
District VII
Anthony D. Johnson, MD, FAAP
Little Rock, AR
District VIII
Kyle Yasuda, MD, FAAP
Seattle, WA
District IX
Stuart A. Cohen, MD, FAAP
San Diego, CA
District X
Sara H. Goza, MD, FAAP
Fayetteville, GA

Dear Dr. Brysse:
On behalf of the American Academy of Pediatrics (AAP), a non-profit professional
organization of 64,000 primary care pediatricians, pediatric medical subspecialists, and pediatric surgical specialists dedicated to the health, safety and
well-being of infants, children, adolescents, and young adults, we appreciate the
opportunity to provide input on the Agency for Toxic Substances and Disease
Registry (ATSDR) information collection regarding the proposed study of health
risks associated with crumb rubber, used frequently in playing fields used by
children and adolescents.
The AAP applauds ATSDR, the Environmental Protection Agency (EPA), and the
Consumer Product Safety Commission (CPSC) for devoting resources to the study
of exposures and possible human health risks from crumb rubber playing fields and
playgrounds. As you know, there has been significant news coverage of possible
adverse health outcomes associated with these playing surfaces. However, there are
large data gaps in our knowledge of the precise health effects of playing on these
surfaces, particularly for infants, children, adolescents, and young adults. Given the
potentially serious health outcomes, such as cancer, it is appropriate that ATSDR,
EPA, and CPSC undertake a study of the health risks associate with crumb rubber.
The AAP urges you to focus your study and analysis on in particular on the public
health impacts, including those in children.
The Federal Register Notice of February 18, 2016 indicates that the agencies may
engage with stakeholders prior to study initiation. The AAP supports this step, and
urges that among the stakeholders you consult should be pediatricians with
expertise in environmental health, toxicology, and sports medicine, particularly
with regards to the second study, the “Characterization of Exposure Potential
during Activities Conducted on Synthetic Turf with Crumb Rubber Infill.” For
example, these pediatricians may be able to assist ATSDR in identifying the
population that routinely performs activities that would result in a high level of
contact to crumb rubber surfaces.

With regard to the first study contemplated, “Determination of Field Operating Procedures, Use
Conditions, and Chemical Composition of Crumb Rubber Infill in Synthetic Turf Fields,”
facilities should be required to supply samples from their synthetic turf fields with crumb rubber
infill. This additional data can help future researchers, including independent pediatric experts,
better understand the chemical composition of crumb rubber infill and its potential effects on
child health.
We also support the undertaking of surveys and focus groups of parents/caregivers as part of the
CPSC’s work on this study, as well as the CPSC’s focus on outdoor playgrounds that may be
built with crumb rubber “mulch” or unitary tiles. As part of its investigation of outdoor
playgrounds, we strongly urge CPSC to consider a broader age range of children than those
between the ages of 3 and 5, as mouthing behaviors can start in infants, and continue in older
children. Mouthing and sucking activity among infants and very young children is a very
common and necessary part of early childhood behavior that satisfies both nutritive (e.g. breast
or bottle feeding) and non‐nutritive (e.g. pacifier, toy, blanket) needs. Research indicates that
from two months of age to 36 months, children engage in mouthing behavior between 20
minutes to 2.5 hours per day, with a decline as children increase in age (and in some children
with a cessation of such behaviors after age 5). Given this developmentally appropriate behavior,
it is understandable why very young children would readily put loose tire crumb “mulch”
materials in their mouths.
The AAP also supports the agencies investigation of various types of crumb rubber infill,
including loose tire crumb and unitary crumb rubber surfaces. However, we urge you to consider
exposure to these materials not only at room temperature and at temperatures simulating a hot
summer day, but also at spring-like or cooler temperatures, as the crumb rubber playing surface
can still get quite hot due to sun exposure, and still pose a risk to children and adolescents.
Thank you again for the opportunity to provide input on this information collection. If we can be
of any further assistance, please do not hesitate to contact Ami Gadhia in our Washington, D.C.
office at 202/347-8600 or agadhia@aap.org.

Sincerely,

Benard P. Dreyer, MD, FAAP
President
BPD/avg

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. 1k0-8pej-4ph1
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-2016-0002-0065
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill 0923-16PJ Comment on
FR Doc # 2016-03305

Submitter Information
Name: Erik Glavich
Organization: National Association of Manufacturers

General Comment
See attached comments on behalf of the following organizations:
American Chemistry Council
Halloween Industry Association
Institute of Scrap Recycling Industries, Inc.
Juvenile Products Manufacturers Association
National Association of Manufacturers
National Retail Federation
Retail Leaders Industry Association

Attachments
Comments_CrumbRubber_2016-05-02_final

https://www.fdms.gov/fdms/getcontent?objectId=0900006481fa10d9&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:

Notice with Comment Period: Information Collection Related to Synthetic Turf Fields with
Crumb Rubber Infill (Docket No. 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.” We represent manufacturers, their suppliers
and other key stakeholders that would be impacted by the action sought through the information
collection request. Our collective members are committed to providing safe products, and we
appreciate the opportunity to provide these comments.
Since the industries in which our members belong are much broader than those directly
related to the synthetic turf and playground industries, it is vital that the most effective safety
regime be based on the highest quality information available, sound science and objective risk
assessments. Any effort to respond to possible risks associated with the use of crumb rubber
should involve robust analysis that focuses on the actual use in specific products and involves a
cooperative engagement with stakeholders.
I.

Introduction

The recycled rubber used in synthetic turf and playgrounds is used in a multitude of
products throughout the economy, so the research to be conducted could have broad and
significant implications. Therefore, although the information collection request does not
specifically reference the Federal Research Action Plan on Recycled Tire Crumb Used on
Playing Fields (“Federal Research Action Plan”), the notice does request information intended to
implement the plan, including specifically comments on the necessity of the proposed collection
and ways to enhance the quality, utility and clarity of the collected information.
These comments express our urging that the agencies conducting research as outlined
in the Federal Research Action Plan engage in a comprehensive and thoroughly objective
analysis of all available peer-reviewed research concerning crumb rubber and its composition.
The agencies must apply sound scientific methodologies to their research, including proper
sampling controls. Moreover, the research and analysis should be applied in proper context so
that constituents found in recycled rubber and their exposure to users of synthetic turf fields are
properly represented (e.g., trace amounts of a chemical compound that pose no potential health
hazard should be represented properly). Implementing the suggestions within our comments will
help assure that the research is defensible and credible and actually addresses the concerns
that prompted it in the first place.

II. The Federal Research Action Plan Should Provide Detail on the Planned
Actions of the U.S. Consumer Product Safety Commission
The Federal Research Action Plan provides an overview of the research to be
conducted by ATSDR, the EPA and the U.S. Consumer Product Safety Commission (“CPSC”).
However in the supporting materials provided by the CDC’s Information Collection Review
Office, it is unclear as to what specific action the CPSC will engage and how the CPSC has
guided or will influence the activities of and research conducted by ATSDR and the EPA. For
example, the supporting statement indicates that ATSDR and the EPA “consulted directly with
the White House Council of Environmental Quality and the Consumer Product Safety Council
(CPSC) to obtain their views on the public health issue/concern surrounding crumb rubber infill
in synthetic turf.”1 However, there is no discussion in the supporting materials of what those
views are and how they will affect the research to be conducted.
Moreover, the supporting statement describes that ATSDR and the EPA will conduct two
studies “in collaboration with the CPSC.” This statement implies that the CPSC will be actively
engaged throughout the research project for which the information collection request applies.
The statement also mentions that the “CPSC has indicated its own plans to conduct a limited
study of playground material with recycled tire material,” but asserts that there will be no
duplication of efforts because the studies to be conducted by ATSDR and the EPA do not
incorporate playground material.2 However without detailed information on the planned activities
of the CPSC, the scope of the CPSC’s research is unclear and there is not sufficient support for
the assertion by ATSDR and the EPA that the information collection request avoids
unnecessary duplication. The Federal Research Action Plan indicates that the CPSC will
“convene discussions with members of the public and organizations with an interest in studying
tire crumb” including athletes, parents and coaches; government agencies; and industry
representatives. The CPSC will reportedly explore “conducting a survey of parents to get firsthand perspectives on potential exposures from playground surface materials” and will “conduct
additional work on the safety of playgrounds.”
We request that the materials supporting the information collection request include
additional information on the activities on which the CPSC has engaged and will engage. We
also encourage ATSDR, the EPA and the CPSC to provide more detailed information on the
CPSC’s planned activities in the Federal Research Action Plan. To our knowledge, the CPSC
has not issued publicly any detailed information on its activities. Therefore, it is difficult for the
public to ascertain that the three agencies are indeed avoiding unnecessary duplication or
requesting information that is necessary for determining the health effects of crumb rubber in
playing fields and other environments.
III. The Agencies Must Objectively Analyze All Available Peer-Reviewed Research
Similar to our concerns over the lack of transparency on the activities of federal agencies
like the CPSC, the agencies conducting research must engage in a comprehensive and
thoroughly objective analysis of all available peer-reviewed research concerning crumb rubber
and its composition, including studies on exposure. There has been much research on the
issue, and it is vital that the agencies avoid selection bias when determining key knowledge
gaps, which is one of the specific objectives indicated in the Federal Research Action Plan. To
avoid unnecessary duplication, the agencies must properly consider all available peer-reviewed
1
2

See “Supporting Statement Part B—Collection.”
Ibid.

2

research so that the findings developed through the current project are thorough, objective and
a true representation of the potential risks associated with crumb rubber exposure.
IV. Researchers Must Incorporate Proper Scientific Controls and Other Sound
Scientific Methodologies in the Sampling of Recycled Rubber
We have concerns that proper scientific controls (e.g., sampling from grass fields and
other areas surrounding synthetic turf fields) have not been contemplated by the agencies as
they embark on this research. Without parallel sampling from soil and air near synthetic turf
fields, the researchers would compromise the reliability of their findings. Scientific controls not
only provide a reference point for the sample results that are the focus of the research, they also
provide context. For example, a chemical compound found in crumb rubber may be found
naturally in the surrounding soil. Without this information, researchers could draw incorrect
assumptions that would bias their results. In fact, the failure to provide information on
surrounding areas could actually misinform the public if the agencies only report on the recycled
rubber used in synthetic turf fields or playgrounds.
Furthermore, the analytical test methodologies and other processes used by the
researchers should be in accordance with accepted guidelines and/or protocols as established
by federal guidelines, international standards and/or voluntary consensus standards. The
agencies should not rely on published research projects that were not reproducible or properly
vetted. It is vital that the researchers employ sound scientific methodologies.
V. Researchers Must Report Findings in Proper Context
Importantly, the identification of chemical compounds in recycled rubber must include
context, which should include a baseline below which the presence of those constituents has
already been determined to present no known health hazards. Simply reporting the presence of
chemical compounds without regard to whether the levels found present any cause for concern,
including the bioavailability of those chemicals, ignores sound science and would needlessly
misinform the users of the facilities. 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 that at which there is any health concern.
VI. Agencies Must Establish a Scientific Review Panel
To improve coordination among the federal agencies conducting research and the stateled research that has been and will be conducted, we strongly urge the agencies to establish a
scientific review panel to oversee the project. This panel should be comprised of subject matter
experts from industry, academia and the research community and would help minimize any
duplication of efforts by the agencies. Importantly, the scientific review panel should provide
comments on agencies’ efforts. Finally, the panel should ensure that all research activity
conducted by the agencies is thorough and objective and that the agencies comply with all
applicable laws, regulations and guidance for scientific research.
VII. Conclusion
As ATSDR, the EPA and the CPSC move forward in implementing the Federal Research
Action Plan, we encourage the agencies to employ sound scientific principles, including a
thorough and objective analysis of all available peer-reviewed research. The researchers also
3

must incorporate proper scientific controls and provide proper context for their findings. Finally,
we strongly urge the agencies to commit to conducting their research in an open and
transparent manner in accordance with Office of Management and Budget and agency-specific
guidelines for information quality and peer review. The agencies must place the highest priority
on ensuring that information, data and methodologies are sound and subject to public review
and input. Thank you for your time and consideration.

Sincerely,
American Chemistry Council
Halloween Industry Association
Institute of Scrap Recycling Industries, Inc.
Juvenile Products Manufacturers Association
National Association of Manufacturers
National Retail Federation
Retail Leaders Industry Association

4

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

COUNCIL OFFICE BUILDING, 100 MARYLAND AVE. ROCKVILLE, MARYLAND 20850 - 240/777-7966

2

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 6:39 PM
Received: May 02, 2016
Status: Posted
Posted: May 03, 2016
Tracking No. 1k0-8peo-o930
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-2016-0002-0074
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill 0923-16PJ Comment on
FR Doc # 2016-03305

Submitter Information
Name: Jean Barish
Address: 10028
Email: jeanbbarish@hotmail.com

General Comment
Attached are my comments regarding Collections Related to Synthetic Turf Fields with Crumb
Rubber Infill 0923-16PJ
FR Doc # 2016-03305
Thank you for your consideration.
Jean B Barish, Esq., MS

Attachments
FR Doc # 2016-03305

https://www.fdms.gov/fdms/getcontent?objectId=0900006481fa2584&format=xml&showor... 5/3/2016

JEAN B BARISH, Esq., MS
jeanbbarish@hotmail.com
212-249-5060
May 2, 2016

Leroy A. Richardson
Information Collection Review Office
Centers for Disease Control and Prevention
1600 Clifton Road NE, MSD-74
Atlanta, GA 30329
Re: Docket No. 2016-03305
Dear Mr. Richardson:
Thank you for this opportunity to comment on the proposed Federal research on the toxicity of synthetic
turf athletic fields with rubber tire crumb infill. I have worked as a research scientist, a consumer
advocate, and an attorney specializing in health care law. I am also affiliated with several environmental
organizations that have been concerned about this issue. One of these organizations, Action for
Nature, recognized Claire Dworsky as an AFN Eco-Hero for her study on the toxicity impact of synthetic
turf with rubber tire crumb. (http://actionfornature.org/2011_winners.aspx;
http://www.scgh.com/featured/success-stories/4th-graders-research-reveals-dangers-of-artificialturf/nggallery/image/image-463)
Rubber tires are a complex blend of materials and chemicals, many of which are carcinogenic,
neurotoxic, eye and throat irritants, and toxic to many organ systems. These chemicals include but are
not limited to polynuclear aromatic hydrocarbons (PAHs); phthalates; volatile organic compounds
(VOCs); heavy metals including lead, zinc, iron, manganese, and mercury; nanoparticles such as
carbon black; and dioxin. Additionally, a great deal of dust and particulate matter, including
nanoparticles, are created during play on an artificial turf field. All of this harmful material can enter the
body by inhalation, ingestion, dermal contact and eye contact. Other health and safety concerns
include sports injuries; infections from methicillin-resistant Staphylococcus aureus (MRSA); overheating
of the fields; and; disposal problems. Finally, the use of artificial turf with rubber tire crumb also raises
environmental concerns.
Many cities and school districts have chosen not to install turf with rubber tire crumb after considering
the health and environmental risks. For example, the City of New York Parks and Recreation and
Department has not used rubber tire crumb infill since 2008. And in 2009 the Los Angeles Unified
School District served manufacturers of artificial turf with Proposition 65 Notices claiming that artificial
turf with SBR infill contains unacceptable levels of lead and carbon black. LAUSD no longer uses turf
with rubber tire crumb. Several school districts in Sonoma County in Norther California have also
decided not to use rubber tire crumb infill, and the San Francisco Recreation and Parks Department is
planning to replace worn out fields with safer, organic infill. These are just a few examples of schools
and municipalities throughout the country that no longer use synthetic turf with rubber tire crumb.

Leroy A. Richardson
May 2, 2016
Page 2

In view of the growing concern about the health and environmental hazards of these fields, your
research should be done rigorously and thoroughly. To assure the studies will provide meaningful
information, please consider the following recommendations:
Study Recommendations
It is important that samples of rubber tire crumb are taken from an adequate number of fields
throughout the country. There are many variables that must be considered to assure adequate
sampling, including but not limited to the following: age of the fields; weather conditions to which the
fields are exposed such as temperature, humidity, precipitation; use of the fields; age of the fields;
source of the tire crumb; location on the field from which the samples are taken. Rubber tire crumb
comes from a huge variety of tires that have been manufactured all over the world. This lack of
homogeneity of the rubber tire crumb must be accounted for in your research.
Numerous studies have identified several categories of chemicals found in rubber tire crumb, including
but not limited to: polyaromatic hydrocarbons; phthalates; dioxins; semivolatile compounds;
nitrosamines, and; heavy metals. These should all be measured.
Rubber tires contain nanotubules. These should be measured.
There is also off-gassing of volatile compounds on synthetic turf fields, as well as the dispersal of
particulates into the air. These volatiles and particulates should also be measured on indoor and
outdoor fields under various ambient and play conditions when the fields are in use.
There is growing concern about the health risks of exposure to nanoparticles and carbon black. These
particles are able to cross biological membranes such as the blood-brain barrier and access cells,
tissues and organs. The risk of exposure to nanoparticles and carbon black should be studied.
(Nanoparticles – known and unknown health risks. Peter HM Hoet, Irene Brüske-Hohlfeld and Oleg V
Salata. Journal of Nanobiotechnology 20042:12.
http://jnanobiotechnology.biomedcentral.com/articles/10.1186/1477-3155-2-12). See also:
“Understanding the mechanism of toxicity of carbon nanoparticles in humans in the new millennium: A
systemic review,” Mukesh Sharma. Indian Journal of Occupational and Environmental Medicine, vol.
14(1), 2010, web publication June 24, 2010, abstract available at
http://www.ijoem.com/article.asp?issn=00195278;year=2010;volume=14;issue=1;spage=3;epage=5;aulast=Sharma ; Peter Gehr “Nanoparticles
can penetrate brain tissue,” on the website of the Federal Office for the Environment (FOEN) (also
BAFU in German), March 2010, available at
http://www.bafu.admin.ch/dokumentation/umwelt/10649/10659/index.html?lang=en ; “Toxic Potential of
Materials at the Nanolevel,” Mädler,and Ning Li, Science, 3 February 2006: 622- 627, abstract at
http://www.sciencemag.org/cgi/content/abstract/311/5761/622.

Leroy A. Richardson
May 2, 2016
Page 3

In addition to surveying field representatives to determine facility use and characteristics, please survey
players, coaches, and spectators. This will provide more reliable information regarding field uses and
conditions.
In addition to air monitoring, dermal sampling, and urinalysis, mucous membranes such as the oral
cavity, nasal passages, and conjunctiva of players should also be sampled. Dermal sampling should
include all exposed areas of the body, including the face and scalp.
Exposure characterization should also include contact with clothing and shoes, and the impact that has
on the spread of material off-site. This is especially important since many people report that rubber tire
crumb is tracked into cars and homes, and that players’ clothing is covered with black dust after a
game.
The risk of increased skin, muscular and joint injury caused by synthetic turf versus natural turf should
be studied.
All impact studies should account for demographic variations in users of the fields, including age,
gender, and race.
One of the adverse health impacts of artificial turf fields is related to the fact that the fields get much
hotter than natural grass fields. Synthetic surface undesirably absorbs, retains and emanates heat at
temperatures and rates that can be dangerous. (https://www.pitchcare.com/magazine/concerns-overheat-stress-on-3g-surfaces.html) The health hazards of playing on these hot fields should be studied.
Analysis of the health hazards of rubber tire crumb must also analyze the cumulative risk of exposure to
the synthetic turf with rubber tire crumb, defined in the US EPA document “Framework for Cumulative
Risk Assessment” as “the combined risks from aggregate exposure (i.e., including all relevant routes) to
multiple agents or stressors.” (U.S. EPA 2003. Framework for Cumulative Risk Assessment. PA/630/P02/001A. Washington, DC)
Please review the Material Safety Data Sheets (MSDS) for the manufacturer of rubber tire crumb and
evaluate these for information about health and safety hazards.
In addition to an analysis of the constituents of rubber tire crumb and exposure levels, the synthetic turf
fibers also contain chemicals of concern, including but not limited to phthalates, quaternary ammonium
bocides, BPA, acetone, elastomers, and heavy metals. A chemical analysis of a representative sample
of turf fibers should be done.

Leroy A. Richardson
May 2, 2016
Page 4

Other Considerations
The following comments are also submitted for your consideration:
Epidemiological Studies
There is a growing data base of soccer players exposed to fields with rubber tire crumb that have
developed cancer. Notably, there is a disproportionate number of young people lymphomas in this
population. (http://www.ehhi.org/turf/cancer_patterns_1114.shtml) Epidemiological research is
necessary to more accurately assess the health impacts of playing on artificial fields with rubber tire
crumb. This research should study the incidence of cancer, as well as allergies, asthma and other
respiratory disorders, gastrointestinal disorders, autoimmune diseases, neurological conditions, skin
conditions, and the like. There is already a great deal of information about the components of rubber
tire crumb. Epidemiological research is the next step that should be taken to determine whether
exposure to these toxins on the playing field increases the risk of cancer and other health problems.
The testing your agency proposes will never capture what is really going in the real life exposures of a
generation of young people. A national agency such as NCI or CDC has the resources to do the
necessary epidemiological research. It should begin as soon as possible in order to protect a the young
people who are now playing on these fields.
Animal Studies
Several experts I have spoken to have recommended that your research includes animal studies in
order to better assess exposure risks. Please include animal studies in this project or explain why you
do not plan to include it.
Environmental Impacts
Rubber tire crumb can also impact the environment, especially if the field is built above an aquifer.
Chemicals from rubber tire crumb can leach into this underlying aquifer, as well as spill into waste
water, poisoning drinking water and impacting aquatic life. Additionally, synthetic turf fields with rubber
tire crumb can impact the ecosystems where they are installed. Accordingly, please address the
following issues in your research:
Include consideration of the impact of these fields on rainwater and other waters that flow through the
turf that will pick up particulates that could then enter the public water system or adjoining waterways.
Include consideration of the impact of these fields on all animal species in the surrounding ecosystems.

Leroy A. Richardson
May 2, 2016
Page 5

Disposal
The environmental impact of disposal of the fields and the rubber tire crumb infill should also be
studied. It is important to understand the regulatory control of the disposal of these fields. Do they end
up in landfills? Can they be recycled? What is the impact of the particulates on the environment when
they must be removed at the end of their lifespan or the repurposing of the fields?
Precautionary Principle
The Precautionary Principle stands for the proposition that when an activity raises threats of harm to
human health or the environment, precautionary measures should be taken even if some cause and
effect relationships are not fully established scientifically.
(http://unesdoc.unesco.org/images/0013/001395/139578e.pdf) Much has been written about the
Precautionary Principle, but in its simplest terms it means that there is a social responsibility to protect
the public from exposure to harm when scientific investigation has found a plausible risk. These
protections can be relaxed only if further scientific findings emerge that provide sound evidence that no
harm will result.
You are encouraged to apply the Precautionary Principle in analyzing the data from your studies.

Thank you for your consideration of these comments.
Sincerely,
Jean B Barish, Esq., MS

Page 1 of 1

PUBLIC SUBMISSION

As of: 5/3/16 6:41 PM
Received: May 02, 2016
Status: Posted
Posted: May 03, 2016
Tracking No. 1k0-8peq-eye3
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-2016-0002-0076
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill 0923-16PJ Comment on
FR Doc # 2016-03305

Submitter Information
Name: Glen Sjoblom
Address: 22066
Email: gsjoblom@cox.net

General Comment
See attached file(s)

Attachments
CDC letter

https://www.fdms.gov/fdms/getcontent?objectId=0900006481fa34bd&format=xml&showor... 5/3/2016

Dr. Thomas Frieden, Director
Center for Disease Control and Prevention
1600 Clifton Road N. E.
Atlanta, Georgia 30329
I am writing to you as a former Director of the EPA Office of Radiation
Programs and with considerable career expertise in the area of
environmental and occupational risk assessment.
An issue before CDC, EPA and the Consumer Product Safety Commission
at this time is whether to continue the use of crumb rubber in artificial
turf fields. There are now some 12 thousand of these playing fields all
over America, and a typical field uses crumb rubber particles made by
pulverizing perhaps 30,000 used tires, approximately 1 million pounds
per field. This use of used tires began in a small way about 30 years ago,
when there had been public outcry to EPA over fires involving used tires
in landfills and in piles of used tires.
The early studies of this use of crumb rubber were mainly aimed at
developing another method of disposal of used tires, well before the
development of more modern methods of hazardous waste
management. These early studies were superficial and did not make a
critically objective examination of the exposure pathways by which
volatile chemicals and tiny particulates would be released and exactly
how they would expose our young athletes, and what the effects would
likely be.
Your agency must now make the determination of whether to continue
to allow this use of tire crumb. I believe that the EPA has been and is
conflicted, by virtue of the historical proponents of this use within the
EPA Office of Solid Waste. CDC has the necessary expertise in all the
areas of toxicology, epidemiology, cancer registry, exposure
measurements and risk analysis, and does and must not be burdened by
the mistakes of the past.
In the United States, there is a growing public concern that allowing this
use of crumb rubber was a huge mistake by EPA. There are perhaps a
dozen carcinogens which have been reported in the rubber particles, as
well as the main constituents of rubber polymer, 1,3 butadiene and
1

carbon black. The fields can reach over 150 degrees, and disturbing the
crumb rubber including thermal deterioration of the material, can
release large amounts of very small particulates, and volatile chemicals,
which can reach deeply into lungs of young athletes, while they are
under physical exertion.
The studies of the past have not even determined or examined the high
exposure scenarios involving athletes diving into the field surface,
resulting in repeated high ingestion and inhalation. This is not a chronic
low-dose situation, but an intermittent high dose situation. The
previous studies have mainly involved sampling above the undisturbed
fields, and a few have tried using breathing zone monitors. A much
better understanding of the actual exposure scenario is needed, through
inquisitive observation of conditions of play and investigation, followed
by careful design of the quantitative measurements that will truly
determine actual intakes.
Many of the chemicals in tire crumb are suspected to be human
carcinogens, and the best toxicologists should be asked to estimate risk
factors, particularly for the diseases that have been reported. There
have been a substantial and growing number of actual health effects and
deaths, which have been reported among soccer players, particularly
young goalies in Washington State. A few useful documents are shown
below:
http://boston.cbslocal.com/2015/03/18/i-team-health-concernsraised-over-artificial-turf-fields/
https://www.youtube.com/watch?v=91svvfuF7iY
It is important to use conservative assumptions, because the critical
population group is younger and therefore more sensitive to the
chemicals and particulates.
The health effects experience in the tire making industry should be
useful as background, since many of the same substances are involved,
albeit in a much better controlled industrial environment, in which
2

some occupational exposures are acknowledged as a condition of
employment.
CDC should determine if there are additional cancer clusters in other
parts of the country, in addition to the reports from Washington State.
It is not acceptable to only test the crumb rubber in the laboratory as
has been done in the past. The ongoing studies should be specifically
directed to measuring the airborne volatile organic chemicals and fine
particulates being released from several existing fields that have been in
place for many years. One such field is located at Mira Costa High
School in Manhattan Beach, California, where my 12 year old grandson
plays flag football. When I observed a game there in December, there
was a very noticeable odor of rubber, as well as large amounts of
surface particulate material, and a cloud of fine black dust resulting
from the athlete’s feet. Even in December, the surface was hot from the
solar radiation on the black surface, and this undoubtedly degrades and
volatizes the complex moist rubber polymer and produces a mixture of
organic materials, both volatile and very small particulates. I have read
reports stating surface temperatures of 150-200 degrees F. I became
very concerned when I observed the current situation.
The protocol for the new studies should include use of traditional fine
air particulate samplers and volatile samplers on several fields with
degraded surfaces, during athletic games, as well as in breathing zone
monitoring of athletes playing. Standard methods should be used for
this monitoring, and I suggest the application of the PM-10 and PM-2.5
analysis methods for particulates. The only truly acceptable exposure
level determined by these methods is NO actual exposure to our young
athletes, but the level of 50 micrograms per cubic meter air standard
may be a useable starting point.
In Fairfax County, Virginia, where I live, there are many of these fields,
but the Great Falls Citizens Association refused to go along with the use
of crumb rubber, and the Local Lacrosse Association found another fill
material. I am also aware that Montgomery County, Maryland has
passed an ordinance allowing only natural fill materials on playing
fields, and have shown that there are acceptable substitute materials
which have the same playability features, without the adverse health
3

implications. This year, the Virginia Legislature considered a three-year
moratorium on the use of crumb rubber, and while it was tabled
pending the ongoing risk analysis, the close vote in committee indicates
a growing recognition continuing use of this material is not acceptable.
I strongly recommend that you will pay close attention to the design of
ongoing studies, and subsequently make the correct the risk
management decision, and require the phase out the use of this material
in playing fields.
Sincerely,

Glen L. Sjoblom
815 Seneca Rd.
Great Falls, Virginia 22066

4

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
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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

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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
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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

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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.)

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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

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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
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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.

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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
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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.

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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

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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)
20



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..

21

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

25

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.

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

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

29

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.

30

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

34

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

35

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}

37

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

38

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

39

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*.
40

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

41

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.

42

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?

43

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

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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.”

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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

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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.

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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

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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.

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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.

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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

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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.

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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 6:44 PM
Received: May 02, 2016
Status: Posted
Posted: May 03, 2016
Tracking No. 1k0-8per-4adj
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-2016-0002-0080
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill 0923-16PJ Comment on
FR Doc # 2016-03305

Submitter Information
Name: Amy Stephan
Organization: Safe and Healthy Playing Fields Coalition

General Comment
Thank you for the opportunity to comment on this important proceeding on behalf of the Safe
and Healthy Playing Fields Coalition we respectfully submit our comment and supporting
material in the attached document. We hope to have the opportunity to provide additional
comments and participate directly in this important study.

Attachments
SHPFC FINAL ASTDR 2016-0002-0003Comments

https://www.fdms.gov/fdms/getcontent?objectId=0900006481fa356c&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

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, neurotoxic, and endocrine disrupting
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,
SHPFC Comments ASTDR-2016-0002-0003 1

because of risk of ingestion and inhalation exposure to all the ingredients in
tires. On warm, sunny days the surface temperature routinely reaches over
150 F, which presents direct, well-known heat injury risks to children. The
heat increases off-gassing of the tire components, increasing the likelihood
of pulmonary 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,
carcinogens, phthalates, carbon black and other harmful substances, 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 parents, coaches, scientists, public health professionals, toxicologists,
neurobiologists, educators, researchers, plastics engineers, medical
doctors, waste management and remediation professionals 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
2 SHPFC COMMENTS ASTDR-2016-0002-0003

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 numerically and organized into: 1. General
Comments, 2. Characterization and methodology comments; 3.Summary
List of requests. A number of supporting documents are also submitted as
part of our comments.

PART I: GENERAL COMMENTS:
1. CPSC/CDC/EPA should use their existing authority to immediately
enforce regulations on tire crumb playgrounds and athletic fields as a
children’s product, since thousands of fields have been installed in
child-care facilities and schools that serve hundreds of thousands of
children.

2. We have grave concerns about their safety to human health and the
environment, since known harmful components in the field material
are released into both air and water pathways, and provide ample
opportunity for both acute and chronic low to high dose exposures
with every use of the field to known toxics such as lead, chromium,
mercury, zinc, PAH, VOC, carbon black, styrene, benzothiazoles, and
plasticizers. Intermittent ‘Hotspots’ of high levels of toxins such as
lead are of particular concern for exposure. (See comments on
Characterization). Every tire crumb playground and synthetic turf field 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
SHPFC Comments ASTDR-2016-0002-0003 3

several cancers) from both low dose and high dose exposures to the
ingredients in tires is staggering. Based on the known potential for
exposures to children, and the finding of a group of now over 200 soccer
players with cancer (the group represents the reach of a single soccer
coach, implying that this group may be the ‘tip of an iceberg’ of affected
individuals), 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 crumb fields to all users, particularly
children. They are likely unaware that the previous CPSC claims that the
fields are “SAFE TO INSTALL; SAFE TO PLAY ON” have been repealed.

4 SHPFC COMMENTS ASTDR-2016-0002-0003

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/newsreleases.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/publichealth/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.
SHPFC Comments ASTDR-2016-0002-0003 5

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 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.

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
6 SHPFC COMMENTS ASTDR-2016-0002-0003

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)



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 midtwenties 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
SHPFC Comments ASTDR-2016-0002-0003 7

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..

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
8 SHPFC COMMENTS ASTDR-2016-0002-0003

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 the 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. Public health and medical professionals sometimes 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
SHPFC Comments ASTDR-2016-0002-0003 9

cost-benefit analysis that will show a 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, offgassing, 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.
1 SHPFC COMMENTS ASTDR-2016-0002-0003
0

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.
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.
SHPFC Comments ASTDR-2016-0002-0003 1
1

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, noninhalable, 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 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.
1 SHPFC COMMENTS ASTDR-2016-0002-0003
2

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 regular, daily contact with at least 1000 athletes and students. At

SHPFC Comments ASTDR-2016-0002-0003 1
3

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..

1 SHPFC COMMENTS ASTDR-2016-0002-0003
4



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.



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.

SHPFC Comments ASTDR-2016-0002-0003 1
5

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 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:
1 SHPFC COMMENTS ASTDR-2016-0002-0003
6

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 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
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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 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

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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.
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
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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
Tetradecanoic acid
Toxic to aquatic organisms. Skin and eye irritant.
Anthracene, 2-methylAcute 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
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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, airborne 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 and potentially smaller. 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).
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 1840% bound styrene.

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• 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
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
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Coastal Marine Resource Center Study, found levels of zinc in leachate from
tire crumb fields with fatal impacts to an aquatic ecosystem within 48
hours.
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 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
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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-oflead-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
19. The Centers for Disease Control (CDC) in contrast
warned and continues to warn that" there is no safe level of lead" to
expose children to.
http://www.cdc.gov/nceh/lead/>
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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):1345-9
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-tirecrumb-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 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 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
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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*.
28. Other sources of information on Lead in tire crumb fields:
www.ehhi.org/turf/
www.safehealthyplayingfields.org
www.synturf.org
At www.synturf.org , a sampling of findings of lead on fields is available on
the page on lead:
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.
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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 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]

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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.
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

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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 CARCINOGENIC, PATHOGENIC, Endocrine disrupting and other
harmful 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?
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.
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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
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very very complex product. So, 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
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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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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
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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.
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
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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 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.
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51. Lead, chromium, mercury and arsenic could be present in
hotspots, 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
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could release that material as the fields are pounded with running feet, or
possibly on a hot day. 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, offgassing 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.
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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
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
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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.”

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

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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
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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 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.

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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.

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
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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 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
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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
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.
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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.
72. Sampling: Not Appropriate For Tire Crumb
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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 non-uniform, 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
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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.
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 biomonitoring 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
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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
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

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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.

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
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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.
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OUR REQUESTS TO ASTDR/CDC/CPSC/EPA
Request
1. Regulate tire crumb and rubber mulch as children’s product

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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

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

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

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Page 1 of 2

PUBLIC SUBMISSION

As of: 5/3/16 6:46 PM
Received: May 02, 2016
Status: Posted
Posted: May 03, 2016
Tracking No. 1k0-8per-6zzd
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-2016-0002-0083
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill 0923-16PJ Comment on
FR Doc # 2016-03305

Submitter Information
Name: SHPFC Fairfax Chapter
Organization: Safe Healthy Playing Fields - Fairfax County Chapter

General Comment
These Comments were also submitted by the Safe and Healthy Playing Fields Coalition. The
Fairfax Chapter is submitting them as well in order to document our support for the comments.
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

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Page 2 of 2

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 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 revenue-generating 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.

Attachments
SHPFC FINAL ASTDR 2016-0002

https://www.fdms.gov/fdms/getcontent?objectId=0900006481fa2070&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

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
SHPFC Comments ASTDR-2016-0002-0003 1

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 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
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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:
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
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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 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
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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/newsreleases.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/publichealth/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.

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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.

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.
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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)



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 midtwenties 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
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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..

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
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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 percentage of children will get sick
SHPFC Comments ASTDR-2016-0002-0003 9

(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, offgassing, 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.

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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.
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.
SHPFC Comments ASTDR-2016-0002-0003 1
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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, noninhalable, 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 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.
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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 regular, daily contact with at least 1000 athletes and students. At

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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..

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

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.



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.

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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 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:
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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 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
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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 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

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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.
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
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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
Tetradecanoic acid
Toxic to aquatic organisms. Skin and eye irritant.
Anthracene, 2-methylAcute 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
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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.
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 1840% bound styrene.
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• 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
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

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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 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.
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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-oflead-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
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.
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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):1345-9
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
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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}
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 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 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
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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*.
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.
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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 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
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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.
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
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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?
36. We would also like access to all MSDS/SDS of tire crumb
manufacturers and tire companies, and the ability to ask questions about
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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,
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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, 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.

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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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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
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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.
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
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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 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.
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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
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could release that material as the fields are pounded with running feet, or
possibly on a hot day. 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, offgassing 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.
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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
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
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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.”

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

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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
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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 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.

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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.

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
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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 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
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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
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.
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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.
72. Sampling: Not Appropriate For Tire Crumb
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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
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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.
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
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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
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

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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.

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
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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.
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OUR REQUESTS TO ASTDR/CDC/CPSC/EPA
Request
1. Regulate tire crumb and rubber mulch as children’s product

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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

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

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

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