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[No. 22] EPA does not and should not care about public health issues associated with crumb rubber infill and crumb rubber playground mulch. SynTurf.org, Newton, Mass. 29 December 2015. The latest pronouncement from the EPA about tire crumb rubber, entitled The Use of Recycled Tire Materials on Playgrounds & Artificial Turf Fields at http://www2.epa.gov/chemical-research/use-recycled-tire-materials-playgrounds-artificial-turf-fields (accessed 25 November 2015) and here, is an example of astroturfing—a term that refers to the practice of masking a message to make it appear as though it is genuine; t is a form of public deception, whitewashing, sophistry.

In 2008, EPA conducted its Scoping-Level Field Monitoring Study of Synthetic Turf Fields and Playgrounds and declared that playing on these fields was perfectly safe. Now, in reaction to national spotlighted concerns about the ill-effects of playing on ground up used tire crumbs, the EPA is backing off slightly its earlier proclamation by using exculpatory language in qualifying the earlier study – that was a “limited study” or “the purpose of the limited study was to test a method for measuring possible emissions from using synthetic turf on playgrounds and ball fields” or that the purpose of the study “[was] not to determine the potential health risks of recycled tire crumb in playgrounds or in synthetic turf athletic fields.”

The question is: So, EPA, what was that 2008 study all about and who put you up to it? The answer: The White House wanted to know if putting crumb rubber/rubber mulch on WH’s playground was okay for the users. To answer that question, EPA turned to its primary source for all answers about the environmental health implications of any product, process or procedure—the industry. Of course, reams of self-serving material safety data sheets showed nothing of concern, same as multitude industry-sponsored “research studies.”

The EPA has been the primary promoter of the use of ground up used tires in playing fields even though it has known since the 1990s that crumb rubber contains untold amounts of carcinogen and other substances of concern to human health. Scrap Tires: Handbook on Recycling Applications and Management for the U.S. and Mexico (EPA publication 20110) has served as a resource for developing scrap tire markets in the border region between Mexico and the United States, an area where scrap tires are an especially problematic waste. The Handbook summarized as of 2010 the existing studies pertaining to environmental and human health risks of various scrap tire uses including crumb rubber, all of which found no issues of concern.

Given this degree of involvement in promoting crumb rubber in playing fields, EPA still has the temerity to deflect its role in promoting this scourge by declaring that “[s]tates and local governments [are] the primary agencies that regulate the management of used tires, including options for recycling, reuse and disposal,” and that “[they] have historically viewed tire crumbs as a useful product in many applications, including playing fields.” Whence do these entities get their information about the safety of the infill and rubber mulch? They get their answer from the purveyors of these fields and their vote-hungry political allies and starry-eyed boosters—i.e., the industry.

Now that substances of concern other than lead have received national attention (see  Julie Foudy, “Turf Wars: How Safe Are The Fields Where We Play?,” on espnW.com, 24 November 2015, at http://espn.go.com/espnw/news-commentary/article/14206717/how-safe-fields-where-play ) the EPA says that it “supports more comprehensive efforts to identify potential exposures to tire crumbs and better assess risks.” A recent letter from Barnes Johnson, Director of EPA’s Office of Resource Conservation and Recovery, has assured Environment and Human Health, Inc. (www.ehhi.org) that “[t]he Agency is aware of the more recent public health questions that have been raised over the use of recycled tire crumb materials in artificial turf fields and playgrounds. The Agency’s highest priority is protecting public health and the environment, and we will carefully review any new findings or information.” See letter here.

The letter bearing Barnes Johnson’s signature was in response to a letter that EHHI has sent to EPA Administrator regarding the issues associated with crumb rubber in children playgrounds and fields. Who got to respond? The Director of EPA’s Office of Resource Conservation and Recovery. How credible or sincere is EPA’s assurance that protecting the public health is the Agency’s highest priority? Not very. First, that is not EPA’s job. Second, EPA is in league with the industry that loves to dump all sorts of externalities on the public and the environment. Third, EPA was the hatchery for the use of crumb rubber and rubber mulch under albeit misguided environmentalism.

Instead of enlisting the scientific and medical expertise of independent research health institutes and professionals, the EPA toots that it and “other federal agencies are working with the California’s Office of Environmental Health Hazard Assessment [OEHHA] to provide their expertise for a comprehensive evaluation of tire crumbs. According to EPA, “[t]his evaluation is being designed to provide information needed to make more informed decisions about the safety of crumb rubber. It involves a series of scientific studies to determine if chemicals in crumb rubber can potentially be released under various environmental conditions and what, if any, exposures or health risks these potential releases may pose to players who frequently play on synthetic fields constructed with tire crumb.” Where will OEHHA turn to provide information needed to make more informed decisions about the safety of crumb rubber? If the past is any indication, OEHHA will turn to the industry.

According to Foudy (supra), the OEHHA study is being funded by CalRecycle, the state agency responsible for recycling used tires; it funded past California studies on synthetic fields. A statement on CalRecycle's website says, “The ongoing challenge for CalRecycle is to continue to develop viable markets for the remaining 6.3 million waste tires that are being landfilled annually.” In an effort to recycle used tires rather than create environmentally troublesome stockpiles of tires in California, “the California Tire Recycling Act authorized CalRecycle to award grants and loans to businesses and public entities for activities that could expand markets for used tires.” One such grant program is for crumb rubber. CalRecycle says it has awarded $2.78 million to schools and communities to install crumb-rubber turf fields since 2002. CalRecycle’s 2015 Grant Program Report concludes by discussing the 2010 California study results: “At the conclusion of the study, OEHHA did not find any significant risk to human health (either cancer or non-cancer) from tire-derived crumb rubber used in artificial sports fields. Accordingly, CalRecycle believes that the use of recycled tires in playgrounds or crumb rubber used as infill for artificial sports fields is appropriate.” The report goes on to say that “since 2001, CalRecycle has awarded, through various grant programs, approximately $45 million to cities, counties, and school districts for playgrounds, running tracks, landscaping, infill for artificial sports fields, and other uses.”

Should anyone really believe that the OEHHA study will sing a tune different from what its benefactor would want sung? According to EPA, OEHHA’s study will “involve[ ] a series of scientific studies to determine if chemicals in crumb rubber can potentially be released under various environmental conditions and what, if any, exposures or health risks these potential releases may pose to players who frequently play on synthetic fields constructed with tire crumb.” (Emphasis added by SynTurf.org). The use of the term “potentially” is what will enable the worst of results from any objective study be interpreted by EPA in a fashion that would lead to the conclusion that crumb rubber does not pose an actual harm to the environment and human health, or that any actual emanation from the fields does not pose any more risk than before.

 


[No. 21] EPA Spokeswoman: New science is needed to answer questions about turf safety; existing studies do not comprehensively address the recently raised concerns about children’s health risks from exposures to tire crumb. According to a news story on NBC.com (9 November 2015), “[i]n October, the House Committee on Energy and Commerce sent a letter to the EPA asking the agency to weigh in on whether crumb rubber is safe for young athletes, and cited the NBC News reports. The bipartisan panel gave the EPA till Friday, Nov. 6 to answer the 10 questions about what tests have been conducted to determine whether the product poses any health risk and what investigators have found. On Friday, EPA spokesperson Liz Purchia told NBC News that the agency was ‘in the process of responding’ to the Energy Committee's list of questions. Purchia said ‘new science’ is needed to answer questions about turf safety and that ‘existing studies do not comprehensively address the recently raised concerns about children's health risks from exposures to tire crumb.’ ‘We know communities want more information as they make decisions to repair and replace their playing fields or as they consider a number of alternate materials available in the market today. Source: Mark Schone, “Senators Call for ‘Independent’ Study of Crumb Rubber,” on NBC.com, 9 November 2015, at http://www.nbcnews.com/storyline/artificial-turf-debate/senators-call-independent-crumb-rubber-turf-study-n459001 .

 

 


[No. 20] Congress wants to hear from EPA about harm from crumb rubber. In a letter, dated 23 October 2015, the US House of Representative’s Subcommittee on Environment and the Economy (a subcommittee of the Committee on Energy and Commerce) has asked the US Environmental Protection Agency to respond to the following questions by no later than 6 November 2015:

1. In 2009, EPA issued a study entitled "A Scoping-Level Field Monitoring Study of Synthetic Turf Fields and Playgrounds." The study did not find contaminants being released from the turf above levels of concern but noted that additional study was needed to fully characterize the risks. Has EPA conducted the additional testing needed to fully assess the hazards and exposures associated with crumb rubber on artificial turf athletic fields?

2. Other federal agencies, such as the Consumer Product Safety Commission and the Centers for Disease Control and Prevention, have also done work to evaluate the potential risks that exist from synthetic turf and recycled rubber tire crumbs. What interactions has EPA had with other federal agencies on this matter? Do those studies provide EPA with additional relevant information to assess the hazards and exposures associated with crumb rubber on artificial turf athletic fields?

3. Are you aware of other scientific studies on the hazards and/or exposures associated with crumb rubber on artificial turf athletic fields? Do you have access to such studies? Do such studies provide EPA with sufficient information to adequately assess the hazards and exposures associated with crumb rubber on artificial turf athletic fields?

4. To the best of your knowledge, do chemical substances, or a chemical substance, in crumb rubber present a hazard to human health? If so, has the Agency determined whether exposure to such a chemical from crumb rubber presents an unreasonable risk to human health? If so, please explain in detail and describe what other uses are made of crumb rubber that could lead to human exposure.

5. Are you aware of any studies about carcinogens present in field sports generally? Do data indicate that risk is greater for female athletes than for male athletes, for soccer players than for lacrosse, field hockey, or football players, and for one position in soccer more than for others?

6. What does the Agency know about the incidence (percentage of population by sex and age level) of cancers in the general population? To the best of your knowledge, is the incidence for persons who play on fields treated with crumb rubber higher than in the general population?

7. If data indicate a higher incidence of cancer for female athletes, particularly soccer goalies, are you aware of any studies on other potential sources of exposure to carcinogens, for example, chemicals used in equipment distinct to goalies such as gloves, jerseys, or in the goal itself such as paint, piping, or synthetic goal netting? Do any such studies meet EPA's guidance criteria for assessing risk?

8. If there is a distinct correlation linking soccer-play to cancer, are there data indicating a minimum threshold for risk? For example, does the cancer appear in persons who have played at any age or any degree of frequency, or is concern focused on a particular age cohort, or only after a certain level of exposure?

9. Has EPA identified a specific pathway of exposure to hazardous materials in crumb rubber, e.g., inhalation, ingestion, or skin absorption?

10. Are you aware of any industry standards that set limits for exposure to crumb rubber based on potential health hazards? What analysis supports those standards?

SynTurf.org’s Note: It is odd that this kind of inquiry is made of an organization that has been promoting the use of used tire crumb rubber, rubber material and rubber mulch on playing surfaces, not to mention the use of rubber mulch in gardens. Why aren’t the congressional health and labor committees not asking these questions?  For the pdf text of the letter go here.


[No. 19] US EPA no longer promotes the use of recycled tires on artificial turf fields and playgrounds. SynTurf.org, Newton, Mass. 1 March 2015. In 2013, Public Employees for Environmental Responsibility (PEER – www.peer.org ) asked the EPA to remove from its official publications EPA’s 2009 Scoping-Level Field Monitoring Study of Synthetic Turf Fields and Playgrounds, rescind the Press Release that accompanied the study, and undertake a more expansive and externally peer-reviewed study concerning the potential human health and environmental effects. The study had claimed that there was a low level of concern in samples of recycled tires from ballfield and playground surfaces. The EPA responded by inserting a notice on the Press release stating that “This news release is outdated . Please visit EPA tire crumb study web page for the most current information.” Furthermore, the EPA updated its tire crumb web page state that the study was of a “very limited nature” and therefore it was “not possible to extend the results beyond the four study sites or to reach any more comprehensive conclusions without the consideration of additional data.” to more accurately reflect the study objective and results. At the time the action of the EPA was characterized by PEER as a retraction by the EPA from its position about the use of crumb rubber in fileds and playgrounds. The press coverage of the actions also resulted in headlines like “EPA says more studies needed on artificial turf fields,” “EPA not entirely confident playground turf is safe for children.” See http://www.synturf.org/epa.html (Item No. 17).

Fast forward to 2015!  According to an investigative report by Melody Gutierrez, “Critics say EPA played dual role in recycled tire controversy,” in San Francisco Chronicle, 21 February 2015, at  http://www.sfchronicle.com/bayarea/article/Critics-say-EPA-played-dual-role-in-recycled-tire-6094382.php#/0 (here), [t]he U.S. Environmental Protection Agency has terminated its longtime campaign to promote the use of recycled tires on artificial turf fields and playgrounds, amid growing concern from critics in California and elsewhere who fear the material poses a health risk to people.” This position is buttressed “by environmental groups and health advocates [that] say the EPA failed to thoroughly study the health effects of the so-called [crumb rubber] because the agency was vested in promoting recycling of the material as a solution to the nation’s growing stockpile of scrap tires.”  The report quotes a former EPA toxicologist, Suzanne Wuerthele, as saying that “the EPA made a mistake in promoting this. This was a serious no-brainer. You take something with all kinds of hazardous materials and make it something kids play on? It seems like a dumb idea.”

According to the report, the “EPA efforts to promote recycled tires on athletic surfaces date back to a 1991 agency report on various ways to reduce the nation’s scrap tire stockpile. The report said the tire piles posed a health risk because they were ideal breeding grounds for mosquitoes, which can spread diseases, and provided potential fuel for hazardous and toxic fires. Using recycled tire material on playgrounds and sports fields, among other possibilities, had potential, the report noted. By 2003, the agency had partnered with environmental agencies in California and other states and with rubber manufacturers to create the Scrap Tire Workgroup, which promoted the use of recycled tires — including in playgrounds and artificial turf — and developed strategies to counter concerns about the toxicity and volatility of the material. One strategy outlined in the Workgroup’s 2007 marketing plan involved designating the EPA as the chief marketer to persistently promote the use of ground rubber while at the same time compiling and producing studies to respond to health and safety concerns over the material. Another strategy involved encouraging states to provide subsidies to cities and school districts that installed recycled tire material on playgrounds and athletic fields.”

The report further found that, “[i]ndeed, millions of dollars in subsidies have been handed out. …During the time the EPA was involved in the Scrap Tire Workgroup, the agency issued a 2009 study on the health effects of crumb rubber, saying it found low levels of concern even though it identified 30 compounds found in tires, including known carcinogens and toxic substances such as arsenic, lead and cadmium. But in 2013, the EPA backed off that earlier statement. The agency said its 2009 study — often cited by industry groups to validate the safety of crumb rubber — was limited in scope and that no conclusions should be drawn by it.”

According to the report, “[n]ow, the EPA is further distancing itself from the crumb rubber controversy. According to a spokeswoman for the EPA, Laura Allen, “the agency is no longer affiliated with the Workgroup and has no current initiatives to reduce tires in landfills. The agency ended staff participation in the independent Workgroup in May 2014, and closed out administrative participation at the end of the year.” When asked if health concerns played a part in the EPA’s decision to withdraw from the group, Allen told The Chronicle that [t]here were various factors taken into consideration.”

A member (Kirk Souza) of Turf Gras Forum (https://twitter.com/turfgrassforum) in   Medway, Massachusetts, asked the investigative reporter Melody Gutierrez  (San Francisco Chronicle) if the EPA would issue a press release regarding its ending of the crumb rubber additive in artificial turf fields. Ms. Gutierrez  replied: ”The EPA won’t be putting out a press release on this. In fact, they weren’t forthcoming with details while I was reporting this story. However, I was able to get the agency to acknowledge that at the end of last year, they pulled out of the Scrap Tire Workgroup. A multi-agency and industry group that works to promote markets for recycled tires. The EPA also ended all other efforts to assist industry groups and states in increasing demand for recycled tires. I think the EPA was hoping to quietly stop promoting the material.”  Go here for Souza-Gutierrez correspondence.

SynTurf.org Note: It is our position that no further study needs to be conducted on what crumb rubber contains or what harm can come from exposure over time to the toxins and carcinogens that are known to be present in crumb rubber. Stop using this product as matter of common sense! Consider the images in this video https://www.youtube.com/watch?v=-9sAVZazKX4 (“San Francisco tire crumb chemicals health warnings,” by SF Parks, uploaded 22 February 2015), showing masked crews installing crumb rubber infill on artificial turf fields. Now consider the vulnerability of a soccer player whose kick sends up tire dust in the air to be inhaled by her or another player. Or consider the goalie who does not only wallows in this mire when she dives to block shots repetitively at practices and games but also how tire dust can come off of the ball that she stops with her hands (catching it with counter-force usually chest high). These factors may well explain why an overwhelming number of the cancer-stricken players on Amy Griffin’s list are soccer players and among them overwhelmingly are goalies.

What we know the ingredients in crumb rubber and we know about the toxicity and carcinogenicity of each ingredient. This is evidence enough to prove to a jury in a civil case by the preponderance of the evidence that a player’s ailment in all likelihood is the result of having been exposed over time to any or any combination of these harmful ingredients.


[No. 18] EPA’s List of Carcinogens and Other Harmful Substances in Tires. In an undated document [1997 is the date of the most recent source cited in the document] on the EPA’s website at http://infohouse.p2ric.org/ref/11/10504/html/intro/openfire.htm  (home page at http://www.epa.gov/osw/conserve/materials/tires/fires.htm ) (or click here), EPA states that “[o]pen tire fire emissions include ‘criteria’ pollutants, such as particulate, carbon monoxide (CO), sulfur oxides (SOx), nitrogen oxides (NOx), and volatile organic compounds (VOCs). They also include ‘non-criteria’ hazardous air pollutants, such as polynuclear aromatic hydrocarbons (PAHs), dioxins, furans, hydrogen chloride, benzene, polychlorinated biphenyls (PCBs); and metals, such as arsenic, cadmium, nickel, zinc, mercury, chromium and vanadium.” With thanks to Environment and Human Health Inc. for bringing this document to our attention, here is the list of the substances identified by the EPA as carcinogens: Acenaphthene, Acenaphthylene, Arsenic, Benz(a)anthracene, Benzene, Benzo(a)pyrene, Benzo(b)fluoranthene, Benzylchloride, Butadiene, Carbon tetrachloride, Chloroform, Chromium, Chrysene, Coal tar pitch (volatile), 1,2-Dichloropropane, Dibenz(a,b)anthracene, Ethylene dichloride, Hexachloroethane, Lead, Methylene chloride, Nickel, Phenol, Styrene, 1,1,2-Trichloroethane, and Trichloroethylene.

To the aforelisted alphabet soup of carcinogens one should add also ortho-Toluidine. See  http://www.synturf.org/crumbrubber.html  (Item No. 35, SynTurf.org’s Note).

According to the EPA “Data from a laboratory test program have also shown that open tire fire emissions contain 16 times more mutagenic compounds than from residential wood combustion in a fireplace, and 13,000 times more mutagenic compounds than coal-fired utility emissions with good combustion efficiency and add-on controls. The emissions from an open tire fire can pose significant short-term and long-term health hazards to nearby persons (e.g. firefighters, residents, etc.). These health effects include irritation of the skin, eyes, and mucous membranes, respiratory effects, central nervous system depression, and cancer.”

[No. 17] EPA’s response to PEER’s Request for Correction should lead to a moratorium on the use of crumb rubber infill in artificial turf fields. SynTurf.org. Newton, Mass. 29 December 2013. On 21 March 2013, the Executive Director of Public Employees for Environmental Responsibility (PEER – www.peer.org ), Jeff Ruch, sent a Request for Correction on behalf of his organization to the United States Environmental Protection Agency (EPA), asking that EPA to remove from its official publications the 2009 Scoping-Level Field Monitoring Study of Synthetic Turf Fields and Playgrounds that had been done by the EPA’s National Exposure Research Laboratory. At the time, PEER also requested that the EPA rescind the study’s accompanying Press Release [Press Release, Limited EPA Study Finds Low Level of Concern in Samples of Recycled Tires from Ballfield and Playground Surfaces (December 10, 2009), issue a public statement about the rescinded study, and undertake a more expansive and externally peer-reviewed study concerning the potential human health and environmental effects.

After reviewing PEER’s request, in a letter to PEER, dated 16 December 2013, Acting Assistant Administrator of the EPA’s Office of Research and Development, Lek Kadeli, informed PEER that EPA has put a heading in bold font on the 2009 press release that now states “THIS NEWS RELEASE IS OUTDATED. PLEASE VISIT THE EPA TIRE CRUMB STUDY WEB PAGE FOR THE MOST CURRENT INFORMATION: http://www.epa.gov/nerl/features/tire_crumbs.html  .” See http://yosemite.epa.gov/opa/admpress.nsf/d0cf6618525a9efb85257359003fb69d/c8d28e3f9f3ca0a4852576880053bed4!OpenDocument  . The EPA has agreed further to update the EPA Tire Crumb web page ( http://www.epa.gov/nerl/features/tire_crumbs.html )  to more accurately reflect the study objective and results. 

The text of the EPA letter to PEER is available here. For news coverage of the EPA decision, see Phyllis Swebilius, “More studies needed on artificial turf fields, EPA says,” in West Hartford News, 26 December 2013, available at http://www.westhartfordnews.com/articles/2013/12/26/news/doc52bc52d8d1149522476319.txt  and Kate Sheppard, “EPA Not Entirely Confident Playground Turf Is Safe For Children,” on Huffington Post, 23 December 2013, at http://www.huffingtonpost.com/2013/12/23/turf-safety-epa_n_4494726.html  . PEER’s press release, dated 23 December 2013, and entitled – EPA Retracts Synthetic Turf Safety Assurances: New Agency Posting Stresses Uncertainty amid Wide Range of Chemical Exposures is available at  http://www.peer.org/news/news-releases/2013/12/23/epa-retracts-synthetic-turf-safety-assurances/  .

SynTurf.org Note: In SynTurf.org’s opinion, the most significant aspect of the EPA’s response to PEER’s requests is that, after a review of the literature on crumb rubber, the EPA identified a number of compounds or materials that may be found in tires. This formal recognition of the existence of the substances in crumb rubber infill that children play in should be cause of concern to the EPA’s Office of Children’s Health Protection (Michael Firestone[!]) and Office of Pollution Preventions and Toxins (Tala Henry). These substances that listed in the appendix of the letter to PEER are acetone, aniline, arsenic, barium, benzene, benzothiazole, cadmium, chloroethane, chromium, cobalt, copper, halogenated flame retardants, isoprene, latex, lead, manganese, mercury, methyl ethyl ketone, methyl isobutyl ketone, naphthalene, nickel, nylon, phenol, pigments, polycyclic aromatic hydrocarbons, polyester, rayon, styrene – butadiene, toluene, and trichloroethylene.

According to EPA letter to PEER, in response to parental concerns about toxicity of crumb rubber in playing fields, in 2009 EPA developed an agency workgroup that initiated a limited-scale scoping study to test a study protocol and monitoring methods for generating environmental data associated with the use of recycled tire material on synthetic turf fields and playgrounds. Data were collected at a limited number of sites.

“Given the very limited nature of this study (i.e., limited number of components monitored, samples sites, and samples taken at each site), EPA wrote to PEER, “and the wide diversity of tire crumb material, it is not possible to extend the results beyond the four study sites or to reach any more comprehensive conclusions without the consideration of additional data.” Nevertheless, at the time, the Consumer Product Safety Commission and the Centers for Disease Control and Prevention, and the EPA recommended that young children wash their hands frequently after playing outside and always before they eat.

“When considering future study designs and implementation,” EPA stated, “the research needs to carefully consider issues associated with identifying and gaining site access, and benefits of obtaining the data versus the resource burden, and the implementation of other methods for generating data to address specific research hypotheses. Future studies will need a carefully developed and implemented communications plan to promote the value of the research and gain access to the required facilities.”

The Swedes Got it Right in 2006! As reported on this site, in 2006  the Swedish Chemicals Inspectorate (KemI) recommended that “[m]aterial 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.” See http://www.synturf.org/crumbrubber.html (Item No. 07) and http://www.synturf.org/wrapuparticles.html (Item No. 06). The idea was that if tires are disposed of in special way and treated as hazardous waste in landfills, then no logic would sustain their re-incorporation into the environment in granulated form. 

Then, why did crumb rubber ended up in our playing fields? According to an e- statement distributed by EHHI on 26-27 December 20133, the public health toxicologist at the Connecticut-based Environment and Human Health, Inc. (www.ehhi.org) , David Brown, Sc.D,  believes that it is important to bear in mind the factors that were used – even by some well-meaning recycling advocates and environmentalists – that justified the introduction of a crumb rubber into the lives of thousands of American children by grinding-up rubber tires and placing the crumb in their playgrounds and synthetic turf playing fields. In answering the question, “What was industry's model for making this happen?,” Dr. Brown stated the following:

1) Ground-up rubber tires provided a cheap, and in fact profitable, way to dispose of an otherwise hazardous material that was difficult to dispose of;

2) A relatively new EPA regulation that allowed the reformulation of a hazardous material, such as tires, to then be deemed safe if it was reformulated into a "new" product;

3) Academic engineering Departments making health decisions about the safety of ground up rubber tires;

4)  Industry’s  supported biased science that they then placed in "peer" reviewed publications;

5)  Massive public relations efforts by industry that overwhelmed thoughtful decision makers;

6) Failure of Public Health Communities and Education Departments;

7) Clever strategies by industry by which they would find an anonymous person to offer $100,000 or more  to then be matched by local organizations for the purpose of installing each million dollar synthetic field;

8) The installation of a synthetic field could claim local “jobs” -- as local contractors were given these profitable projects;

9) Outside “experts” were provided to dispute and discredit all those who urged caution and health warnings;

10) International corporations developed political influence at the federal, state, and community levels.

It is not sufficient to demand that the federal agencies meet minimal obligations, which they have failed to do - but the model for pushing rubber tires on children must be revealed.

“Finally,” according to Dr. Brown, “as sobering as it may be, it is necessary to look at the damage done.  Thousands of American children have been exposed to cancer causing chemicals during their formative and most sensitive years.” “The exposures are not trivial and they continue at schools and playgrounds,” he wrote.

Call for a moratorium. If there is any time for the application of the precautionary principle to the use of crumb rubber in artificial turf fields and other synthetic playing surfaces it is now. According to this 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. In this context the proponent of an activity, rather than the public, should bear the burden of proof. The process of applying the precautionary principle must be open, informed and democratic and must include potentially affected parties. It must also involve an examination of the full range of alternatives, including no action. http://www.synturf.org/precautionaryprinciple.html .   

A person suited to lead on this issue nationally is the former Attorney-General of the State of Connecticut, Richard Blumenthal, who currently serving in the United States Senate. As reported on this web site in 2008 Blumenthal was instrumental in getting the EPA to investigate the potential threats related to artificial turf. See http://www.synturf.org/epa.html (Items No. 3 and 4).

It is high time that we get it right too. The least that we can do for now is to ask and pout into place a moratorium in the us of crumb rubber and plasticized infill in artificial playing surfaces.

 


[No. 16] Consumer Reports: “New EPA study fails to alleviate concerns over artificial turf.” According to an item on the Consumerreports.com (Safety blog, January 8, 2010):

 

In an effort to confront ongoing questions about the safety of artificial turf, the Environmental Protection Agency recently released the results of a small study measuring toxins in specific types of artificial turf made with recycled tire material or “tire crumb.”

The limited study, which measured levels of particulates, heavy metals and volatile organic compounds (VOCs), took various samples from four states at only eight sites—six ball fields and two playgrounds—out of about 5,300 synthetic surfaces currently in use. While levels of contaminants found in the air around the fields and in or on samples of turf material itself were, on average, below levels of concern, some findings did suggest contamination. The results are not considered to be conclusive. Instead, the findings and data collection methods are paving the way for more comprehensive future studies, which the EPA says have been lacking to date.

Such future studies will be important to resolving conflicting conclusions from federal agencies. In June 2008, the Centers for Disease Control issued a health advisory on the potential of exposure to lead in artificial turf. The next month, the Consumer Product Safety Commission issued a press release suggesting that synthetic turf is "OK to install, OK to play on." Notably, unlike the recent EPA tests, which focused on a broader array of contaminants, the information from the CDC and CPSC is specific to hazards only from lead in the synthetic grass fibers embedded in the turf.

This Spring government agencies are expected to review the EPA study and other relevant findings, and decide whether additional safety research is needed in an EPA-convened meeting.

As we’ve said before, we believe a more thorough study is needed to adequately assess all the risks associated with all types of materials used in artificial playing fields. Meanwhile, school officials and parents who are concerned should follow the “Take precautions” advice in our earlier blog posting on the CDC health advisory.

 

Kristi Wiedemann, “New EPA study fails to alleviate concerns over artificial turf,” on

ConsumnerReports.org, January 8, 2010, available at http://blogs.consumerreports.org/safety/2010/01/new-epa-study-fails-to-alleviate-concerns-over-artificial-turf.html .

 


[No. 15] EPA: Artificial turf study too small to rule out potential threat from lead. On April 29, 2008, Dale Kemery, the spokesman for  the U.S. Environmental Protection Agency said that the agency was to investigate the potential threat from lead in artificial turf. On December 10, 2009, the EPA announced the results of its study.  According to a news report in the Philadelphia Inquirer (December 11, 2009), according to the EPA,  “there was no cause for immediate concern from lead and other toxins in artificial-turf fields and playground surfaces made from recycled tires.” But “The EPA cautioned, however, that the 123-page study was too small to rule out potential health threats.”  “Peter Grevatt, who oversees children's health issues at the EPA, said the agency would hold a meeting in the spring, possibly in May, to bring together officials from these states and the federal agencies to discuss what the next step should be. Grevatt said the workshop would explore whether a more comprehensive study was warranted.” 

According to the Inquirer, “Air and surface samples for the EPA study … were taken from three athletic fields or complexes in North Carolina, Georgia, and Ohio, and from one playground in the Washington area.” The testing was so limited, Grevatt said, that the agency was "not in a position to draw any conclusions on a national basis."“Between August and October last year, the EPA took air samples from about three feet above the surfaces - roughly the nose level of children - to determine the inhalation risk. The agency also collected samples wiped from the turf blades.”

“All samples came back at levels within acceptable standards, Grevatt said, but testing was not done for all toxins.” “The tires might contain arsenic, cadmium, chromium, manganese, mercury, lead, benzene, latex, and other compounds. Some of elements are carcinogenic and some can cause brain dysfunction.”

“Suzanne Wuerthele, a retired toxicologist with the EPA's Denver office who alerted the agency to the potential health threats about two years ago, said the agency should have sampled a representative number of fields that use the different types of tires before issuing any findings.” “They pay lip service up front to the limitations to the study and then come to their conclusions and say, 'Don't worry, we have no problems right now.' They shouldn't give the wrong impression,” Wuerthele said.
Source: Jan Hefler, “EPA: No urgent concern over artificial field surfaces,” in Philadelphia Inquirer, December 11, 2009, available at http://www.philly.com/philly/news/local/79035017.html . For a copy of the EPA’s Press Release go to http://yosemite.epa.gov/opa/admpress.nsf/d0cf6618525a9efb85257359003fb69d/c8d28e3f9f3ca0a4852576880053bed4!OpenDocument or click here.

SynTurf.org Note: No sooner the EPA’s press release hit the stands that the purveyors of artificial turf, crumb rubber, and tire recyclers along with their trade associations issued/planted “news” stories/statements asserting that EPA says it is all okay with this product. Not a word about the doubt that EPA itself has. Please bear in mind that EPA measures toxicity against standards that are mostly in relation to the environment – not from a public health point of view. For example, while environmentally might be okay for EPA to have 200 or 400 parts per million of lead in playground soil – pediatricians would not even consider 40 part per million as safe. 


 



[No. 14] EPA is dragging its feet on testing artificial turf fields. According to a news story in the Philadelphia Inquirer (October 13, 2009), “It’s been more than a year since the Environmental Protection Agency began looking to see if the turf releases such chemicals and might be harmful to children. With turf fields continuing to open at a rate of roughly 800 a year … federal officials are under increasing pressure to say whether any risk exists. Some watchdog groups say the EPA is stalling. ‘If safeguarding children's health is a top priority at EPA, why can't this multibillion-dollar agency afford to take a hard look at what is in our playgrounds, schoolyards and athletic fields?’ said Jeff Ruch, director of Public Employees for Environmental Responsibility (PEER).” In 2008, “[t]he Consumer Product Safety Commission … launched a limited study to see if the fibers posed a health threat. In July, the commission said there wasn’t any. That left the EPA to assess the tire crumbs used as cushioning for the turf. Used tires typically contain numerous toxic chemicals, including mercury and lead. And about 25,000 tires go into an average football field. Last fall, the agency did a limited test at three fields with tire crumbs to see if a full study was warranted, spokesman Dale Kemery said. The raw data – collected at nose level of children, about three feet above the fields – so far show minimal risk, he said, but the results are still being analyzed.” “Suzanne Wuerthele, a retired toxicologist who worked in the EPA regional office in Denver for 23 years, said the EPA could move faster. She alerted the agency to tire-crumb concerns about two years ago. ‘There is methodology they can use now. They can take the particles of respirable size and chemically analyze what's in them to see if they’re safe,’ she said. This has been done for 20 years, she said. In January 2008, the Denver regional office warned EPA headquarters that pulverized recycled tires may contain arsenic, cadmium, chromium, manganese, mercury, lead, benzene, latex, and other compounds. Some are carcinogenic and some can cause brain dysfunction.” For more of this story, go to Jan Hefler, “Schools await a U.S. report on artificial turf,” in Philadelphia Inquirer, October 13, 2009, available at http://www.philly.com/philly/news/homepage/20091013_Schools_await_a_U_S__report_on_artifical_turf.html

 


[No. 13] PEER says, EPA Punts on Risks to children from playground tire crumb. On September 14, 2009, Public Employees for Environmental Responsibility issued a press release saying that the EPA admits it did not perform the promised scientific studies of health dangers to children from playground tire crumb. For the text of the press release go to http://www.peer.org/news/news_id.php?row_id=1241 or click here – or read on:

 

For Immediate Release: September 14, 2009
Contact: Kirsten Stade (202) 265-7337

EPA PUNTS ON RISKS TO CHILDREN FROM PLAYGROUND TIRE CRUMB — Agency Admits It Did Not Perform Promised Scientific Studies of Health Dangers

Washington, DC — Contrary to its public statements, the U.S. Environmental Protection Agency is not conducting studies on potential health effects to children from contact with shredded tires on playgrounds, according to correspondence released today by Public Employees for Environmental Responsibility (PEER). Despite serious concerns raised by its own scientists about health risks to children, the agency continues to endorse use of ground rubber (called “tire crumb”), on playgrounds without examining the extent of childhood exposure from ingestion or inhalation of toxic chemicals found within tires.

Every year millions of pounds of tires are recycled into and placed on playgrounds to reduce injuries from falls. In fact, tire crumb was added to the White House playground constructed for the Obama children.

Records obtained earlier this year by PEER under the Freedom of Information Act (FOIA) document EPA scientists strongly urging the agency to immediately “assess toxicological risks of tire crumb in situations where children are exposed.” On May 29, 2009, PEER wrote EPA Administrator Lisa Jackson asking her to 1) revoke her agency’s endorsement of tire crumb until research shows it is safe for children; 2) issue an interim public health advisory; and 3) coordinate with other agencies in a risk assessment.

In a reply to PEER dated July 8th, Peter Grevatt, an EPA Senior Advisor on Children’s Health wrote:

“One of EPA Administrator Lisa Jackson’s top priorities is protection of children from harmful environmental exposures….In response to possible concerns raised by one of our regional offices, EPA initiated a limited field study to assess the potential for exposure to constituents of potential health concern in playgrounds and synthetic turf athletic fields constructed with tire crumb. We hope to release the study results later this summer….”


A week earlier, EPA spokesman Dale Kemery previewed study results in the June 30th edition of the Philadelphia Inquirer indicating that “the raw data shows there is no inhalation danger to children who play on various types of artificial fields and play surfaces.”

In July, PEER submitted another FOIA request for a copy of that study and any other “scientific assessments, studies or field monitoring by EPA personnel or contractors concerning possible health effects from use of recycled tire crumbs in playgrounds.” In a final answer to that FOIA dated September 11, 2009, Eric Wachter, director of the EPA Office of the Executive Secretariat conceded:

“The Agency has not conducted research to evaluate children's ‘health effects’ from tire crumb constituents.”

Wachter wrote that EPA only did a “literature review” in 2008 and after that began a “very limited methods evaluation study” of “available monitoring methods for characterizing environmental contaminant concentrations at those recreational fields” but has not yet finished even that.

“The polite way to say it is EPA misled parents and the public into believing it was actually addressing potential toxic exposure risks to kids,” stated PEER Executive Director Jeff Ruch. “Incredibly, EPA takes the position it does not know enough to withdraw its endorsement of playground tire crumb. Common sense and a precautionary approach to children’s health dictate that EPA should not endorse something that it has not examined.”

EPA is slated to receive a 40% budget increase, the biggest in its history, boosting FY 2010 taxpayer support to above $10 billion a year.

“If safeguarding children’s health is a top priority at EPA, why can’t this multi-billion dollar agency afford to take a hard look at what is in our playgrounds, schoolyards and athletic fields?” asked Ruch. “At a minimum, EPA should pull its endorsement tomorrow and issue a health advisory until it has answers.”



For previous PEER-related postings please go to:
http://www.synturf.org/epa.html (Item Nos. 10 and 12).


[No. 12] FOIA-ed EPA documents by PEER (see previously posted story at http://www.synturf.org/epa.html (Item No. 10).

 

Organized chronologically

 

EPA Denver Memorandum re Potential Risk of Tire Crumb (January 17, 2007). Go to

 

Issues associated with identifying possible risk related to the use of tire crumb & artificial turf (June 2008). Go to

 

Purpose of Tire Crumb & Synthetic Turf Scoping-level Field Monitoring (Draft, July 15, 2008). Go to

 

Information for informing the public and press about possible childhood exposure to contaminants resulting from contact with tire crumb and artificial turf (Daft of July 30, 2008). Go to

 

PEER’s letter to Linda Jackson, Administrator, EPA, Washington DC (May 29, 2009), asking for expeditious EPA action at minimum: Revoke EPA’s endorsement of tire crumb until the research has concluded that it is safe for children; Issue an interim public health advisory; and Outline a coordinated approach, working with other agencies, for assessing risk. Go to

 


[No. 11] San Francisco: CBC5-TV reports on EPA’s scoping of crumb rubber and artificial turf fields. CBS5-TV (San Francisco), “EPA Rethinks Risks of Artificial Playground Turf,” June 4, 2009, text is available at http://cbs5.com/environment/playground.turf.safety.2.1032286.html and video is available at http://cbs5.com/video/?cid=172 . Also on You Tube, as “Dangers to Pets & Children – EPA & artificial synthetic turf,” at http://www.youtube.com/watch?v=2PYH_sbRknI&feature=channel_page .

 

 

[No. 10] PEER: EPA endorsed use of crumb rubber in playing fields without analyzing its potential toxicity. On June 7, 2009, SynTurf.org reported on the U.S. Environmental Protection Agency’s re-thinking on the use of crumb rubber in playing fields and playgrounds. See http://www.synturf.org/epa.html (Item No. 9). On June 4, 2009, the Public Employees For Environmental Responsibility (PEER) released a memorandum, entitled, “Safety of shredded tires in playground under question - EPA Endorsed Use without Analyzing Toxic Potential but Belated Studies in Limbo  (Contact: Jeff Ruch, Executive Director, (202) 265 7337). Here is the full text: 

 

News Releases

 For Immediate Release: June 4, 2009

Contact: Jeff Ruch (202) 265-7337

 

SAFETY OF SHREDDED TIRES IN PLAYGROUNDS UNDER QUESTION — EPA Endorsed Use without Analyzing Toxic Potential but Belated Studies in Limbo

Washington, DC — The U.S. Environmental Protection Agency is having second thoughts about the safety of shredded tires as fill in playgrounds, according to agency documents released today by Public Employees for Environmental Responsibility (PEER). EPA admits that it does not know the extent of childhood exposure from ingestion or inhalation of an array of toxic chemicals found within tires.

Every year millions of pounds of tires are recycled into ground rubber, (called “tire crumb”) and placed on playgrounds to reduce injuries from falls. Both EPA and the U.S. Consumer Product Safety Commission (CPSC) have endorsed the use of tire crumb for years but neither agency ever investigated the potential toxicity to children from direct contact with tire ingredients, such as arsenic, cadmium, chromium, mercury and a number of dangerous hydrocarbons. Despite these huge knowledge gaps, both agencies still endorse use of tire crumb, which is increasingly being marketed for backyard use.

Documents obtained by PEER under the Freedom of Information Act indicate that –

  • EPA lacks the information to “assess toxicological risks of tire crumb in situations where children are exposed” but has recommended tire crumbs for public recreational use since 1991;
  • Agencies are issuing contradictory advice to consumers. In June 2008, for example, the Centers for Disease Control issued an advisory for potential lead exposure from artificial turf, while weeks later, CPSC issued a press release downplaying the lead risk based on very limited testing; and
  • EPA plans to conduct its first field monitoring studies but admits that these limited tests will leave many questions unanswered.

“Kids roll around in this stuff, put it into their mouths and rub it into their skin and hair,” stated PEER Executive Director Jeff Ruch, pointing out that tire crumbs are often painted in bright colors enticing to very young children. “Despite the growing concerns of its own scientists, EPA has issued no public statement of caution and still promotes tire crumbs in playgrounds.”

Significantly, EPA has refused to release documents to PEER describing the status of the agency’s proposed field studies, which the agency had described as very limited and not representative of “tire crumb sources [or] turf field types”. Nor has EPA scheduled a proposed workshop with states and other relevant federal agencies to coordinate research and health monitoring.

“In essence, EPA is burying its head in the tire crumbs,” Ruch added, noting that states have fruitlessly asked EPA for guidance. “This is yet another instance where EPA has mindlessly embraced a supposed ‘win-win’ solution for a solid waste problem without considering potential side effects.”

PEER is asking EPA Administrator Lisa Jackson to 1) revoke her agency’s endorsement of tire crumb until the research has concluded that it is safe for children; 2) issue an interim public health advisory; and 3) outline a coordinated approach, working with other agencies, for assessing risk. If Ms. Jackson does not respond, PEER will ask the appropriations panels handling the EPA budget to mandate these actions.

###

Read the 2008 warning memo on “Potential Risks of Tire Crumbs” from EPA Region 8

View the June 2008 EPA PowerPoint presentation summarizing issues

See the July 2008 EPA draft talking points to answer public and press inquiries

Look at the weaknesses and limitations in EPA’s planned testing

Peruse PEER letter to Lisa Jackson


[No. 09] EPA is taking a second look at crumb rubber, quietly. The following is by

Rita Beamish (Associated Press, San Francisco), “INSIDE WASHINGTON: Gov't studies playground risks,” June 3, 2009, available at http://www.google.com/hostednews/ap/article/ALeqM5hZSHB-Sok5f2Nyz_q1imcIpDd6SwD98JV4MG3 , or click here. The AP report  is also available in a number of other daily news papers, such as “EPA reevaluating the use of recycled tires in playground,” in The Boston Globe (June 5, 2009, page A6) or at its website http://www.boston.com/news/health/articles/2009/06/05/epa_rethinks_use_of_recycled_tires_in_playgrounds/  or

“Shredded Tires on Play Surfaces Could Be Toxic, EPA Admits,” in Environment News Service (June 4, 2009) http://www.ens-newswire.com/ens/jun2009/2009-06-04-091.asp :

 

For years, the Environmental Protection Agency has endorsed the use of ground-up tires to cushion the surfaces of children's playgrounds and sports fields — a decision now being reconsidered because of concerns among the agency's own scientists about possible health threats.

The concerns are disclosed in internal agency documents about a study the EPA is conducting of air and surface samples at four fields and playgrounds that use recycled tires — the same material that cushions the ground under the Obama family's new play set at the White House.

Recycled-rubber surfaces have been popular for decreasing playground injuries and providing resiliency and cheap, weatherproof maintenance. But doubts were raised by research suggesting potential hazards from repeated exposure to bits of shredded tire that can contain carcinogens and other chemicals, according to the documents.

The EPA scientists cited gaps in scientific evidence, despite other reviews showing little or no health concern. They urged their superiors to conduct a broad health study to inform parents on kids' safety.

Results from the agency's limited study, which began last year, are expected within weeks.

"From everything I've been able to see, I'm not sure there's an imminent hazard but it's something we're investigating," said Michael Firestone, EPA's head of children's health protection. "It's critical to take a look at all the data together."

The government has not decided if broader testing is necessary.

Communities from New Jersey to Oregon have raised concerns about children touching, swallowing or inhaling lead, metals and chemicals like benzene, zinc and breathable particles from synthetic fields and play yards.

Last week, New York state officials said they found no significant health or environmental concerns in a study of leaching and breathable air above sports fields with so-called tire crumb, tiny rubber infill pellets that help anchor the synthetic grass blades. Other local studies have reached similar conclusions, examining artificial grass or tire crumb. Several have recommended additional research.

"If they really find it's something toxic, I would be concerned," said Alejandro Arroyo, a teacher watching his high school students from June Jordan School for Equity play soccer at San Francisco's Crocker Amazon Park. The scent of tire rubber wafted over the busy, five-field complex as a dozen third-graders flopped onto artificial turf infused with gravel-sized, black rubber.

"We practice here, we eat lunch here," Arroyo said. "Everybody does that. It's a family park."

Scrap tire mulch cushions the ground under the play set that President Barack Obama's daughters use at the White House. It was recommended by the National Recreation and Park Association, which relies on the industry's safety assurances and recommendations by the Consumer Product Safety Commission for cushioning the impact of falls, said Richard Dolesh, public policy officer for the park association.

But New York City officials say their new sports fields no longer will use tire crumbs. Connecticut asked the EPA to study the matter shortly after the EPA's Denver regional office recommended the same.

The EPA memo was sent to Washington from the Denver office in January 2008, saying that until more was known, the EPA should take a neutral stance instead of sanctioning recycled tires for play areas. The documents, obtained under the Freedom of Information Act, were provided to The Associated Press by the Public Employees for Environmental Responsibility, an advocacy group that objects to the EPA's endorsement of using recycled tires without a broad scientific risk evaluation.

"It appears that there are valid reasons to take a broader perspective of all potential risks associated with crumb rubber" through a full-blown health study, said the memo from Assistant Regional Administrator Stephen Tuber.

Withdrawing the EPA's endorsement would be premature, EPA spokesman Dale Kemery said.

"Nobody has the evidence at this point" to scientifically justify pulling back, he said.

Along with its own research, the agency will consider studies in New Jersey, California, Connecticut and New York to determine whether more testing is needed. A shortcoming of EPA's study is the small number of locations examined, according to the documents.

The Synthetic Turf Council, an advocacy trade group, says laboratory-based claims of toxicity don't reflect actual conditions.

"The science is clear that synthetic turf crumb rubber infill fields do not present a human health or environmental risk," said Rick Doyle, president of the group.

The Consumer Product Safety Commission concluded last summer that synthetic fields pose no lead hazard for kids. It tested turf fibers for lead at a handful of fields. It did not examine chemicals in tire crumbs interspersed with the turf, or playgrounds where children handle mulch made from shredded tires.

A health advisory from the federal Centers for Disease Control and Prevention said older fields may be riskier for lead as wear kicks up turf dust. Not all turf fibers contain lead. The CDC urges eliminating all nonessential uses of lead, which can cause neurological damage in children.

Chemicals in recycled tires could vary by location because tire manufacturers differ, EPA scientists said.

Rep. Rosa DeLauro, D-Conn., who had criticized the CPSC's effort and pressed the EPA for a comprehensive investigation, welcomed the environmental agency's role.

"This is not about creating panic among parents or calling for the closure of fields made from synthetic turf," she said in an e-mail. But people "need accurate answers about the safety and health effects of these fields to make the best possible decisions about where children and others are playing."

 

Copyright © 2009 The Associated Press. All rights reserved.


[No. 08] Newton, Mass.: Woe to our “protectors”! SynTurf.org, December 23, 2008. Due to editorial constraints, among other things, typically an item like the following will not be covered by SynTurf.org. However, of late, many proponents of artificial turf have taken the misguided liberty to site last summer’s “study” by the US Consumer Product Safety Commission as proof that artificial turf is safe. In contradistinction to this already-discredited “study,” other government agencies like the CDC and EPA have indicated some concerns over artificial turf. But of late, the EPA has come under fire for not doing a thorough job of evaluating risks to health and the environment due to bureaucratic constraints and industry influences, one of which is to keep secrets from the public.

 

SynTurf.org believes the following teaser from Susanne Rust and Meg Kissinger, “EPA veils hazardous substances,” in Milwaukee Journal Sentinel, December 20, 2008, available  http://www.jsonline.com/watchdog/watchdogreports/36514449.html warrants the reader’s attention to the full text (also available in PDF here):

 

The U.S. Environmental Protection Agency routinely allows companies to keep new information about their chemicals secret, including compounds that have been shown to cause cancer and respiratory problems, the Journal Sentinel has found.

The newspaper examined more than 2,000 filings in the EPA's registry of dangerous chemicals for the past three years. In more than half the cases, the EPA agreed to keep the chemical name a secret. In hundreds of other cases, it allowed the company filing the report to keep its name and address confidential.

This is despite a federal law calling for public notice of any new information through the EPA's program monitoring chemicals that pose substantial risk. The whole idea of the program is to warn the public of newfound dangers.

The EPA's rules are supposed to allow confidentiality only “under very limited circumstances.”

[No. 07] USA Today -- Turf  makes it in a story on kids being exposed to toxic air. On December 8, 2008, USA Today published a report by Blake Morrison and Brad Heath,  entitled “Health risks stack up for students near industrial plants.” Across U.S., kids exposed to toxic air.” Here is an excerpt: “The EPA has taken many steps toward making children safer. It has worked with schools to improve air quality inside buildings, primarily by identifying toxic cleaners and other chemicals that might harm students. Today the EPA is investigating whether athletic fields made with synthetic turf expose children to unsafe levels of toxic chemicals. What the agency hasn't done is use its models, as USA TODAY did, to look for potential problems around schools.” For more of this story, go to Blake Morrison and Brad Heath, “Health risks stack up for students near industrial plants,” USA Today, December 8, 2008, available at

http://www.usatoday.com/news/nation/environment/school-air1.htm .


[No. 06] EPA is in bed with the devil. SynTurf.org, Newton, Mass. September 4, 2008. In a culture that uses salt as a preservative of animal foods no misfortune is greater than seeing salt itself go bad. This is the feeling that one gets from seeing the U.S. Environmental Protection Agency’s courting of the artificial turf industry as a “green” alternative to land-filling used tires and plastics. Never mind that this refuse ends up in playing fields and playgrounds in the form of synthetic surfaces. To learn more about this unholy alliance, go to EPA GreenScapes page (http://www.epa.gov/epaoswer/non-hw/green/pubs.htm), and see the document entitled “Recycled Rubber Products in Landscaping Applications (TellUs Institute, Boston, Mass. May 12, 2003), available at.

http://www.epa.gov/epaoswer/non-hw/green/pubs/rubber.pdf (Rubber from scrap tires is a waste material that is ideal for use in landscaping applications. By using recycled rubber products, landscapers can create cost-effective, high quality, and environmentally beneficial projects. The landscaping market is potentially large enough to recover all the scrap tires that are currently discarded in landfills or tire piles). Also, see http://www.epa.gov/garbage/tires/ground.htm (Athletic and Recreational Applications).

A reader has alerted SynTurf.org of recently seeing a “GreenScapes” truck with “FieldTurf” clearly marked on its side.  The truck was cruising by the Redhill Park in San Anselmo where a new FieldTurf field is under construction.  According to the reader, the FieldTurf touts being approved “as an allied member of the U.S. Environmental Protection Agency’s GreenSpaces program.” See http://www.fieldturf.com/specialFeatures.cfm?specialFeatureID=331&lang=en . O, Joy!

 

 


[No. 05] In the aftermath of CPSC’s lead-in-turf report, U.S. Rep. urges EPA to look into other concerns. SynTurf.org, Newton, Mass. August 10, 2008. The report a week ago by the U.S. Consumer Product Safety Commission was a dismal failure in that it was limited to the issue of lead in turf fields that the industry has blamed on the old model carpet and manufacturing processes. Lead is a sexy attention getter, but was not really as much an issue with turf fields as is the leachate of zinc and off-gassing of a variety of substances that cam pose serious health and environmental risks. For a review of findings by the Environment and Human Health, Inc. (www.ehhi.org) please go to http://www.synturf.org/justwords.html (No. 09: EHHI on CPSC Report: In the words of Nancy Alderman).
Let’s face it, CPSC has been a non-actor in the past 8 years. It has done little, if anything, to initiate tests or studies of products in the public interest. What it has done, it has been in reaction to the clamor by activists and states’ own initiatives to regulate or ban products that pose risk of harm to children and adults.
Perhaps fearing that the equally lackadaisical U.S. Environmental Protection Agency might follow in the footsteps of the CPSC, on August 8, 2008, U.S. Congresswoman Rosa L. DeLauro (Connecticut, 3rd district) wrote to Administrator Stephen L. Johnson, urging the EPA not to limit its review of artificial turf to the results of the CPSC. “Clearly,” she wrote, “additional study is needed before synthetic turf fields can definitely be declared safe.” DeLauro critiqued the limitations of the CPSC’s assumptions and protocols, and drew the EPA’s attention to the discovery of various other substances that emanate from turf fields, none of which were addressed by the CPSC.
“The potential health effects of the chemicals in synthetic turf must also be weighed along with other potential health risks, such as the risk of an overheated playing field and increased risk of methicillin-resistant Staphylococcus aureus (MRSA) infections,” she wrote. Furthermore, “It is my understanding that a number of chemicals in addition to lead have been found in the crumb rubber, including benzothiazole (a skin and eye irritant), butylated hydroxyanisole (a carcinogen), n-hexadecane (a severe irritant), 4-(t-octyl) phenol (an irritant), phthalates (endocrine and reproductive toxicant, suspected developmental toxicant), and other chemicals.” CPSC report did not address any of them.
For the text of DeLauro’s letter to EPA, go here.
 

[No. 04] EPA will also look into thermoplastic elastomer (TPE) substitute for crumb rubber infill. SynTurf.org, Newton, Mass. May 24, 2008.

The U.S. Environmental Protection Agency has recently assembled a group of Agency experts to better understand the nature and extent of potential exposure to hazardous chemicals when children and others come into contact with fields and playgrounds where tire crumb infill is used. SynTurf.org has learned that the Agency’s Office of Prevention, Pesticides and Toxic Substances (OPPTS) “will provide information on thermoplastic elastomer (TPE) infill to the working group,” according to Maria J. Doa, Director of National Program Chemicals Division at the EPA. The point was communicated by Doa in a letter to Ms. Kim Mahoney of Wellesley, Mass. Click here for the letter.
The prompting of the EPA is the result of month’s long communication from Mahoney to the Connecticut Attorney General, Richard Blumenthal, and the EPA. For the exchange between Mahoney and Blumenthal click here. For Mahoney’s letters to officials at the EPA click here.
The subject of TPE is of particular interest to Mahoney, because in Wellesley many opponents of a plan to install artificial turf fields at Sprague Elementary School relented when the TPE was offered up as a substitute for crumb rubber infill. SynTurf.org carried the story in January of this year. See http://www.synturf.org/wellesleybrief.html (Item No. 1) 

The Agency “workgroup is in the process of reviewing the published literature, identifying information gaps and data needs, and evaluating the need to generate scoping level monitoring data which may be necessary to model possible childhood exposures,” wrote Doa.

The U.S. Consumer Product Safety Commission (CPSC) has initiated work to evaluate the potential environmental, health and safety hazards associated with artificial turf products.  “EPA will continue to coordinate efforts relating to artificial turf and infill materials with its Federal partners including CPSC and CDC, as well as with the states, as necessary,” Doa said in her letter to Mahoney.


[No. 03]  EPA Agrees to Investigate Artificial Turf Fields; Connecticut AG Lauds Decision. SynTurf.org, Newton, Mass. May 1, 2008. The following is a press release from the office of the Attorney General of the State of Connecticut, dated May 1, 2008 (http://www.ct.gov/ag/site/default.asp and http://www.ct.gov/ag/cwp/view.asp?Q=414328&A=2795):

 

Attorney General Richard Blumenthal today announced that - days after he and U.S. Sen. Rosa DeLauro called on the U.S. Environmental Protection Agency (EPA) to investigate the potential threats related to artificial turf - the agency has agreed to investigate.

"I am pleased the EPA has heeded our call - recognizing its responsibility to know the facts about lead and other potentially harmful chemicals in artificial turf," Blumenthal said. "The EPA should complete this research as quickly as possible because the health risks are potentially urgent as children play every day on these fields across America, and communities make profoundly far-reaching decisions about building new ones. Hopefully, the EPA will complete an authoritative study before the new school year begins this Fall. We will cooperate and assist in every way possible.

"On playing fields throughout Connecticut, we are playing with the health of our children. We must address the unknowns and do the research necessary to protect our children's health, as well as environmental concerns. Preliminary studies have already revealed troubling possible risks involving lead and other dangerous chemicals in artificial turf. Recycled rubber tires are replacing grass in fields across the state and nation, raising serious questions about the potential environmental risks, including possibly harmful runoff into streams and other waterways."


 

[No. 02] Rep. DeLauro in her own words. For a video clip of Rep. DeLauro speaking to the press about her letter to the EPA, see New England Cable News (Brian Burnell, Conn., “Hazardous Turf: Are playing fields safe?,” April 29, 2008) here http://www.necn.com/Boston/Sports/Hazardous-turf-/1209413937.html#.

 

 


[No. 01] U.S. Congresswoman DeLauro asks the U.S. Environmental Protection Agency to weigh in on artificial turf. By Guive Mirfendereski, SynTurf.org, Newton, Mass. April 29, 2008. Yesterday, the U.S. Congresswoman Rosa DeLauro (Connecticut’s 3rd Congressional District) and state Attorney General Richard Blumenthal sent a joint letter to the U.S. Environmental Protection Agency, asking that the agency investigate the toxicity of synthetic athletic fields, in particular a full and detailed study of the risks posed by crumb rubber.

"We want an immediate, prompt, focused study of the dangers of lead, zinc, and other chemicals in nylon fibers and rubber crumbs," Blumenthal told the New Haven Register.

Blumenthal, according to the Register, “expects the EPA to release results as soon as they are available.” “Blumenthal said he is contacting other attorneys general in hopes of mobilizing a national demand for the study,” reports the register. Abram Katz, “DeLauro asks EPA study on fake turf,” in New Haven Register, April 29, 2008, available at

http://www.nhregister.com/WebApp/appmanager/JRC/BigDaily;jsessionid=9TcqLWbGcvn2rt6W4FfzQRbN2THtXGJp8HWr92ZQZrc5TkqZbF3w!-1774020359?_nfpb=true&_pageLabel=pg_article&r21.content=/NHR/_RSSFeed/News/TopStoryList_Story_1967037&r21.pgpath=/NHR/News.

Congresswoman DeLauro is the second highest ranking Democratic woman in the House of Representatives. She sits on House Appropriations and Budget Committees. She is active in promoting safety, particularly with regard to toys. Her website is www.house.gov/delauro/index.html.

In the aftermath of the EHHI study last summer, Blumenthal pledged appropriations for further study of artificial turf fields. The EHHI study can be accessed at http://www.ehhi.org/turf.  For the outline of the EHHI study, its results and how it came about and Connecticut’s strides in the direction of seeking a comprehensive study of artificial turf fields, see http://synturf.org/thewestportbrief.html (Items Nos. 1-3). For what crumb rubber contains and its toxicity issues, see http://synturf.org/crumbrubber.html. Also see the Warnings! section of this website.

Below is the text of the letter as communicated to SynTurf.org by Rep. DeLauro’s press office:

April 28, 2008

Administrator Stephen L. Johnson

U.S. Environmental Protection Agency
1200 Pennsylvania Avenue NW
Washington, D.C. 20460

Dear Administrator Johnson:
            
We are requesting an Environmental Protection Agency (EPA) study of the health and environmental impacts of chemicals in synthetic turf, especially the potential danger posed by possible toxins to children and families.
            
These fields are composed largely of recycled ground rubber tires that release harmful chemicals and dust into the air and leach contaminants into groundwater.  The state of New Jersey recently closed two synthetic turf fields when the state’s epidemiologist discovered levels of lead ten times the amount allowed in contaminated soil.  Preliminary tests by the Connecticut Agricultural Experiment Station on synthetic turf have also found troubling evidence about toxins that could pose health risks. 
 
Such potential health risks are national in scope, because there are approximately 3500 synthetic fields currently in use nationally, and 800 additional fields installed each year at high schools, universities, stadiums, and public parks.

           
State agencies are beginning to examine the health threat posed by synthetic turf.  The Consumer Product Safety Commission has initiated an investigation into the health hazards of lead in synthetic turf.  Civic groups in New York City have called for a moratorium on the use of synthetic fields.  The EPA – the federal agency charged with protecting human health and safeguarding the natural environment - should immediately start an investigation.

The possible health risks of synthetic turf have the potential to impact thousands of children and families, and they warrant immediate attention. Thank you for looking into this urgent issue.  Please call us with any questions or concerns, and we look forward to hearing from you.

                                                                                          
Sincerely,

Rosa L. DeLauro                                                                               

Member of Congress                                                                        


Richard Blumenthal
CT Attorney General


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