Public Comment - Children/Health Concerns

Page 1 of 1

PUBLIC SUBMISSION

As of: 2/26/16 12:07 PM
Received: February 24, 2016
Status: Posted
Posted: February 26, 2016
Tracking No. 1k0-8o4t-63wg
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-2016-0002-0005
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 hope there is consideration as to how the crumb rubber impacts children's health. Children as
young as 4 and 5 are playing on this surface on a regular basis. Their pregnant mothers and their
toddler siblings who join them at the field are also being exposed.

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PUBLIC SUBMISSION

As of: 4/14/16 1:40 PM
Received: March 31, 2016
Status: Posted
Posted: April 11, 2016
Tracking No. 1k0-8otb-cum9
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-2016-0002-0015
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill 0923-16PJ Comment on
FR Doc # 2016-03305

Submitter Information
Name: Christina Majorowicz
Address: 98021
Email: [email protected]

General Comment
I want to express my support for these studies and my relief that these federal agencies are
finally focusing some attention on this potentially very serious health issue for anyone who
spends time on artificial turf which contains crumb rubber infill. I hope that these studies will
address how young children in particular are affected by exposure to crumb rubber (early stage
development) when they are playing on these fields, eating post-game snacks on the field, and
tracking crumb rubber into their homes. Thank you.

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4/14/2016

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PUBLIC SUBMISSION

As of: 4/14/16 1:42 PM
Received: April 06, 2016
Status: Posted
Posted: April 11, 2016
Tracking No. 1k0-8ox6-5g5r
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-2016-0002-0016
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill 0923-16PJ Comment on
FR Doc # 2016-03305

Submitter Information
Name: Melissa Pruess
Address: 92117
Email: [email protected]

General Comment
I am a concerned parent and am happy to see our government agencies taking a closer look at
crumb rubber infill and its potential effects on children. Small children play on these fields and
there needs to be a comprehensive look at their exposure in particular, based on the prevalence
of "hand to mouth" behaviors in small children... not just the risks of inhaled exposure or
accidental ingestion. Smaller children have a totally different absorption rate that older kids and
adults and if there is even a chance that this material can be hazardous in any way, it should be
banned completely from the elementary school levels and replaced with one of the several
available alternatives to crumb rubber.

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PUBLIC SUBMISSION

As of: 4/28/16 11:17 AM
Received: April 14, 2016
Status: Posted
Posted: April 22, 2016
Tracking No. 1k0-8p2k-60pc
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-2016-0002-0020
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill 0923-16PJ Comment on
FR Doc # 2016-03305

Submitter Information
Name: Jodie Williamson
Address: 44443
Email: [email protected]

General Comment
I am relieved that this is being taken very seriously. I am a parent who has crumb rubber mulch
in our public school elementary playground. Knowing the children put it in their mouths, throw
it, dig in it it is of great concern. Children explore their surroundings and are exposed at a much
higher rate. I hope all of this will be taken into account. I also hope the study will be done in a
more appropriate situation when kids are playing on the fields and not a still field with nothing
being kicked up. Also one of the leading studies only used 1/3 ounce ingestion rate over the
course of an athletes career and this does not seem a likely ingestion rate, especially for smaller
children.

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4/28/2016

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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: [email protected]

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: 4/28/16 11:38 AM
Received: April 27, 2016
Status: Posted
Posted: April 28, 2016
Tracking No. 1k0-8pb6-npxf
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-2016-0002-0040
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
As a soccer player and a parent of a soccer player who's played multiple years on these surfaces
in California, I would hope the study would adequately address the effects of the excessive heat
created by the fields, which have been measured at up to 160 degrees. Even in breezy areas,
such as San Francisco, the fields themselves emit high heat (one we measured was 120 degrees
on an 80-degree day). How does the temperature affect first the parts of the body in most direct
contact with it: the feet? How does it affect the body's processes in a 90-minute game played at
high velocity? How does it affect the ability of players to recover from games? (My personal
observation on recovery times has shown a vast increase in recovery needed because of heat
stress and dehydration.) I came to this concern after witnessing near heat-stroke by referees,
watching games in which a teenage goalkeeper yelled out, in the middle of a serious
competition, "I am too hot!" -- he literally was having difficulty keeping his feet on the ground
-- and after my own son became ill not once, but twice, requiring a week-long hospitalization
for a condition that can be both caused and greatly advanced by high heat.
The two other heat-related issues that are concerning are:
- the dissemination of chemicals in the turf .... are they more breathable in high heat?
- climate: do these "hot spots" (and the removal of cooling, living material, including trees,
shade and grass) further burden already plant-deprived cities & suburbs of California?

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PUBLIC SUBMISSION

As of: 5/3/16 6:19 PM
Received: May 02, 2016
Status: Posted
Posted: May 02, 2016
Tracking No. 1k0-8pe9-f189
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-2016-0002-0046
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill 0923-16PJ Comment on
FR Doc # 2016-03305

Submitter Information
Name: California Safe Schools
Address: 90012
Email: [email protected]

General Comment
California Safe Schools, a children's environmental health and environmental justice coalition
would like to comment on Docket No. ATSDR-2016-0002, which proposes two studies that
will investigate the chemical composition, and use of crumb rubber infill in synthetic turf,
including the potential for exposure, and links between tire crumb rubber exposure and human
health.
We respectfully request that the study consider including research to determine when chemicals
in tire crumb rubber may be released under various environmental conditions. We also would
like the studies to identify, and examine the exposure pathways and health risks these potential
releases may pose to athletes and other individuals who come in contact with tire crumb rubber
playing, working, or participating in events on these fields and play areas.
To date, existing research and information on tire crumb rubber has been incomplete and based
largely on an unsupported theory that there is limited exposure. We are requesting that these
two studies please consider an analysis of all health and environmental risks from tires, tire
crumb rubber, and their various proposed uses which include, but may not be limited to: athletic
fields, playgrounds, play mats, gardens, driveways, sidewalks, and pathways.
We would like the studies to please include detailed accounts of athletes, parents, soccer
coaches and other individuals regarding their personal experience and health effects that they

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Page 2 of 3

believe were directly related to interacting with tire crumb rubber.
Examples include, but are not limited to: allergic reactions such as asthma, nasal, eye, ear and
throat irritation when swallowing the material, rashes related to the off gassing and dust
generated from the materials disintegrating, various cancers, hormonal and neurological
disorders, and burns sustained when temperatures on the fields rise, often exceeding 140
degrees on hot days.
We request the two studies be full, comprehensive, and that they address new questions and
concerns, tackle the gaps in research, and include the synergistic and cumulative impacts to
health.
Because of the tire shredding process into crumb rubber, there are unique mixtures of tire crumb
at each field, and the tires are manufactured throughout the world. As a result, the unique
cumulative impacts and synergistic effects of exposures are especially important to both human
health and the environment.
California has discovered more than thirty hazardous chemicals in tire crumb rubber. Of
particular concern is carbon black, a substance that has been classified as a cancer-causing
chemical by the state. Other tire ingredients can include but are not limited to; arsenic,
cadmium, chromium, mercury and dangerous hydrocarbons.
Studies have also found that crumb rubber can emit gases that can be inhaled. Athletes,
children, and other individuals playing on these fields and areas where tire crumb rubber are
installed or used are often exposed to these materials for years.
According to one parent whose child has played for more than a decade, parents and coaches
are urged to bring sterilized tweezers to the games played on fields with tire crumb rubber in
order to physically remove tire crumb pellets from abrasions.
The tire crumb rubber exposure is not only on the fields where it enters their clothing, shoes
socks, hair, ears, eyes, nose, ears mouth and often ingested. Leaving the fields, it remains in
their clothing, in the seats and floors of vehicles transporting the individuals to and from the
fields, and in their showers.
Given all of the above, we hope that there will be a moratorium placed on installing any new
fields with tire crumb rubber, and exposure to already installed fields with tire crumb rubber
should require posting advising individuals of the known chemicals in tire crumb rubber.
We urge you to discourage the continued funding for installation of tire crumb rubber fields
while the studies are being conducted. Many of these proposed fields are being placed in
environmental justice communities who already have a disproportionate amount of
environmental concerns. These communities in particular, deserve a Right to Know about the
materials being used and chemicals they are being exposed when playing.
We ask that you consider epidemiology studies, and include studying particulates from tire
crumb rubber released in the air, water, and soil.
Our children and athletes should not be treated as lab rats or guinea pigs and we cannot forget
that tires are considered to be too toxic to be placed landfills, yet continue to be used in areas
where athletes and children play.
Thank you for this opportunity to comment.

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Respectfully,

Robina Suwol
Founder & Executive Director
California Safe Schools
1000 North Alameda, Suite 240
Los Angeles, California 90012
818.785.5515 office
818.261.7965 cell
www.calisafe.org

Attachments
MAY 1 FINAL CALIFORNIA SAFE SCHOOLS COMMENTS TIRE CRUMB STUDY

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May 1, 2016

May 1, 2016
Docket No. ATSDR-2016-0002
California Safe Schools, a children’s environmental health and environmental justice coalition
would like to comment on Docket No. ATSDR-2016-0002, which proposes two studies that will
investigate the chemical composition, and use of crumb rubber infill in synthetic turf, including
the potential for exposure, and links between tire crumb rubber exposure and human health.
We respectfully request that the study consider including research to determine when chemicals
in tire crumb rubber may be released under various environmental conditions. We also would
like the studies to identify, and examine the exposure pathways and health risks these potential
releases may pose to athletes and other individuals who come in contact with tire crumb rubber
playing, working, or participating in events on these fields and play areas.
To date, existing research and information on tire crumb rubber has been incomplete and based
largely on an unsupported theory that there is limited exposure. We are requesting that these two
studies please consider an analysis of all health and environmental risks from tires, tire crumb
rubber, and their various proposed uses which include, but may not be limited to: athletic fields,
playgrounds, play mats, gardens, driveways, sidewalks, and pathways.
We would like the studies to please include detailed accounts of athletes, parents, soccer coaches
and other individuals regarding their personal experience and health effects that they believe
were directly related to interacting with tire crumb rubber.
Examples include, but are not limited to: allergic reactions such as asthma, nasal, eye, ear and
throat irritation when swallowing the material, rashes related to the off gassing and dust
generated from the materials disintegrating, various cancers, hormonal and neurological
disorders, and burns sustained when temperatures on the fields rise, often exceeding 140 degrees
on hot days.

1

We request the two studies be full, comprehensive, and that they address new questions and
concerns, tackle the gaps in research, and include the synergistic and cumulative impacts to
health.
Because of the tire shredding process into crumb rubber, there are unique mixtures of tire crumb
at each field, and the tires are manufactured throughout the world. As a result, the unique
cumulative impacts and synergistic effects of exposures are especially important to both human
health and the environment.
California has discovered more than thirty hazardous chemicals in tire crumb rubber. Of
particular concern is carbon black, a substance that has been classified as a cancer-causing
chemical by the state. Other tire ingredients can include but are not limited to; arsenic, cadmium,
chromium, mercury and dangerous hydrocarbons.
Studies have also found that crumb rubber can emit gases that can be inhaled. Athletes,
children, and other individuals playing on these fields and areas where tire crumb rubber are
installed or used are often exposed to these materials for years.
According to one parent whose child has played for more than a decade, parents and coaches are
urged to bring sterilized tweezers to the games played on fields with tire crumb rubber in order to
physically remove tire crumb pellets from abrasions.
The tire crumb rubber exposure is not only on the fields where it enters their clothing, shoes
socks, hair, ears, eyes, nose, ears mouth and often ingested. Leaving the fields, it remains in their
clothing, in the seats and floors of vehicles transporting the individuals to and from the fields,
and in their showers.
Given all of the above, we hope that there will be a moratorium placed on installing any new
fields with tire crumb rubber, and exposure to already installed fields with tire crumb rubber
should require posting advising individuals of the known chemicals in tire crumb rubber.
We urge you to discourage the continued funding for installation of tire crumb rubber fields
while the studies are being conducted. Many of these proposed fields are being placed in
environmental justice communities who already have a disproportionate amount of
environmental concerns. These communities in particular, deserve a Right to Know about the
materials being used and chemicals they are being exposed when playing.
We ask that you consider epidemiology studies, and include studying particulates from tire
crumb rubber released in the air, water, and soil.
Our children and athletes should not be treated as lab rats or guinea pigs and we cannot forget
that tires are considered to be too toxic to be placed landfills, yet continue to be used in areas
where athletes and children play.
Thank you for this opportunity to comment.
2

Respectfully,

Robina Suwol
Founder & Executive Director
California Safe Schools
1000 North Alameda, Suite 240
Los Angeles, California 90012
818.785.5515 office
818.261.7965 cell
www.calisafe.org

3

4

Page 1 of 2

PUBLIC SUBMISSION

As of: 5/3/16 6:21 PM
Received: May 01, 2016
Status: Posted
Posted: May 02, 2016
Tracking No. 1k0-8pe0-l9e6
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-2016-0002-0048
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill 0923-16PJ Comment on
FR Doc # 2016-03305

Submitter Information
Name: Amy Ziff

General Comment
As the mother of three growing children I am concerned about the growing incidence of crumb
rubber and synthetic playing surfaces across this country. Increasingly, our children are exposed
to synthetic playing surfaces -- from playgrounds to gym class, recreational sports to the
sidelines. While we all desire to be more environmentally conscious, why are we using crushed
up, milled tires on plastic "grass" and calling it safe without any study? Why are we using
plastic surfaces over natural ones that we have evolved with over millennia, again without any
study?
My business is to study toxics, as the Founder of MADE SAFE, my organization looks at
products that are made without any known toxicants and puts a certification label on them.
Where there are questions we exercise the Precautionary Principle and wait for more science to
emerge. For the work we do, we rely on the use of available science. What I do know for sure is
that there is a tremendous amount of existing science to make those of us "in-the-know"
question the use of the synthetic plastic on these fields along with ground up tires.
The synthetic turd is highly likely to contain endocrine disruptors, as most flexible plastics do,
and they are prone to leach, especially when they get very hot as these fields do on warm days.
Does that matter? We don't know because it hasn't been studied. And those tires. The very same
tires that are considered "toxic waste" when you dispose of them through regular means are
then ground up for children and teens to play on. We know tires contain PAH's and heavy
metals along with other toxins commonly found on roads -- but have those effects on children

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been studied? Not in this exact scenario.
So what we have are known toxic substances being used in a new way -- using our growing
children as guinea pigs -- and we are allowing this to happen all across America without first
conducting a proper study. When are we going to put children first? If anything is worthy of a
study by the EPA I can't think of anything more valuable than where our children will play.
I hope the EPA studies crumb rubber and artificial turf materials and once and for all
scientifically identifies it as the toxic substance it is and bans crumb rubber on turf fields
forever.
Thank you,
Amy Ziff
Founder and Executive Director,
MADE SAFE
www.madesafe.org

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PUBLIC SUBMISSION

As of: 5/3/16 6:22 PM
Received: May 01, 2016
Status: Posted
Posted: May 02, 2016
Tracking No. 1k0-8pe0-9l1y
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-2016-0002-0049
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill 0923-16PJ Comment on
FR Doc # 2016-03305

Submitter Information
Name: Tanya Murphy

General Comment
As a concerned parent of two middle schoolers who play on turf day in and day out, please take
this away from their environment. Here is a List of Carcinogens and Other Dangerous
Chemicals in Tires
http://www.ehhi.org/turf/findings0815.shtml and here is a Health Based Consumer Guide:
http://media.wix.com/ugd/fd0a19_f5aa0824698341499b4228ebabf90cb5.pdf
Thanks,
Tanya Murphy

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PUBLIC SUBMISSION

As of: 5/3/16 6:23 PM
Received: May 01, 2016
Status: Posted
Posted: May 02, 2016
Tracking No. 1k0-8pdy-gu1b
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-2016-0002-0051
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill 0923-16PJ Comment on
FR Doc # 2016-03305

Submitter Information
Name: Rhonda Sherwood
Address: 06820
Email: [email protected]

General Comment
As the mother of two college aged boys and a founding board member of the Mount Sinai
Children's Environmental Heath Center in New York, I am deeply concerned about the fact that
children who play soccer, football, lacrosse, and baseball must, on a daily basis, practice and
play on turf fields that contain crumb rubber. Why is it illegal for me to dispose of automobile
tires in my local dump (due to the toxic runoff from rain falling on the tires), yet the same tires
can be ground up and sprinkled on my children's sports fields? Every day our children are
playing on fields that contain carcinogens and I fear these young athletes will grow up and find
their cancer incidence to be higher than their non turf playing predecessors.
When my sons were in middle and high school, I saw:
- baseball players slide into home base and create a spray of crumb rubber that covered other
players' faces
- football players get crumb rubber on their mouth guards that they subsequently put into their
mouths
- kids sitting on the sidelines of a lacrosse field sifting crumb rubber in their hands like it was
sand
Through inhalation, dermal exposure and ingestion, our children are being exposed to
carcinogens. If this were a work site/OSHA situation, I'm sure the government would ban

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crumb rubber immediately. Why don't our children deserve the same safety consideration? I
hope the EPA studies crumb rubber and once and for all scientifically identifies it as the toxic
substance it is and bans crumb rubber on turf fields forever.
Thanks for listening,
Rhonda Sherwood
Founding Vice Chairman
Mount Sinai Children's Environmental Health Center
New York, New York

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PUBLIC SUBMISSION

As of: 5/3/16 6:24 PM
Received: May 01, 2016
Status: Posted
Posted: May 02, 2016
Tracking No. 1k0-8pdw-u7hh
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-2016-0002-0052
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill 0923-16PJ Comment on
FR Doc # 2016-03305

Submitter Information
Name: Steven Gilbert
Address: 98105
Email: [email protected]

General Comment
My very you young 3-4 year old granddaughters plays soccer or at least kicks the ball around How do you intend ti keep her from eating the crumb rubber ? She is very curious about thus
black stuff and naturally wants to taste it.
also a few other questions
Why is the CPSC not already testing and regulating this material as a children's product given
the pervasive and targeted use for children's play areas? (See recent reports from Duluth MN on
tire crumb playgrounds as examples of what is going on all over).
Will the study be looking at combinations of personal exposures low to the surface directly with
tire crumb on under active use?
Why are they not studying child exposure on tire crumb playgrounds? Why are they leaving it
to the CPSC to (maybe) do?
How will the study, as planned, help answer the question, "Are synthetic turf fields and
playgrounds with crumb rubber infill safe for children of all ages to play on?"
What are the plan and the timeline for gathering all of the data to answer the above safety
question to a reasonable degree of certainty?
How do the agencies plan to obtain toxicity data that would be needed for a components based
health risk assessment model?

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Page 2 of 2

Do they plan on conducting toxicity testing for all the components for which toxicity data is
currently missing? Where will they get the data for interaction effects? Do the agencies plan on
testing the toxicity of crumb rubber as a whole?
Why isn't an epidemiological study the first priority? Are there plans for one? If so, when will it
be done?
What about the effects of small rubber particles on the eco-system? Are there plans to study the
effects of run-off on marine life?
why not use the precautionary principle - test before it is used with kids ?

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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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Page 2 of 2

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

https://www.fdms.gov/fdms/getcontent?objectId=0900006481f9cec2&format=xml&showor... 5/3/2016

Page 1 of 1

PUBLIC SUBMISSION

As of: 5/3/16 6:28 PM
Received: May 02, 2016
Status: Posted
Posted: May 03, 2016
Tracking No. 1k0-8pef-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

https://www.fdms.gov/fdms/getcontent?objectId=0900006481f9f73e&format=xml&showor... 5/3/2016

AAP Headquarters
141 Northwest Point Blvd
Elk Grove Village, IL 60007-1019
Phone: 847/434-4000
Fax: 847/434-8000
E-mail: [email protected]
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: [email protected]

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 [email protected].

Sincerely,

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

Page 1 of 1

PUBLIC SUBMISSION

As of: 5/3/16 6:28 PM
Received: May 02, 2016
Status: Posted
Posted: May 03, 2016
Tracking No. 1k0-8pef-4vnd
Comments Due: May 02, 2016
Submission Type: Web

Docket: ATSDR-2016-0002
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill 0923-16PJ
Comment On: ATSDR-2016-0002-0003
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill ATSDR-2016-0002
Document: ATSDR-2016-0002-0059
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill 0923-16PJ Comment on
FR Doc # 2016-03305

Submitter Information
Name: Jeff Ruch
Address: 20910
Email: [email protected]
Organization: PEER

General Comment
See attached

Attachments
5-2-16_PEER Comments _Federal Artificial Turf Research Action Plan

https://www.fdms.gov/fdms/getcontent?objectId=0900006481f9ff86&format=xml&showori... 5/3/2016

Comments on

Federal Research Action Plan on Recycled Tire Crumbs Used on
Playing Fields and Playgrounds
Submitted by

Public Employees for Environmental Responsibility (PEER)
May 2, 2016

Introduction
Many parents have remarked on their children looking like “coal-miners” after playing in tire
crumb on playgrounds or fields, , and that their white soccer balls quickly turn dark gray to
black as they roll on these artificial surfaces, in contrast to the green chlorophyll stains from
playing on grass.
Yet, there is poor official understanding of what exactly is in the tacky fine tire-derived material
coming off the tire crumb playgrounds and fields sticking to objects and children alike and the
possible short and long term impacts on human health.
There can be no disagreement, and indeed government and independent experts and the industry
concede, that there are a litany of substances in tire crumb and plastics, many of which are
known to be harmful to various body systems (e.g. as carcinogens, hormone disruptors,
neurotoxins, inflammatory irritants etc)and most of the rest have not been tested. There remains
an array of unknowns about the effects on children being in direct contact – some for hours a day
and in a variety of conditions – with shredded tire pellets containing known toxic substances
such as but not limited to lead, arsenic, cadmium, chromium, mercury, carbon black,
benzothiazoles and a number of dangerous hydrocarbons.
Public Employees for Environmental Responsibility (PEER) is submitting the following
comments on the proposed multi-agency federal study into the human health and eco-impacts of
widespread use of shredded tires in playgrounds and sports fields:
I. Research Action Plan Is Poorly Designed and Will Raise More Questions than It
Answers
Announced in February to address to growing public concerns “about the safety of recycled tire
crumb used in playing fields and playgrounds in the United States,” the Obama administration
directed the U.S. Environmental Protection Agency (EPA), the Centers for Disease Control and

Prevention/Agency for Toxic Substances and Disease Registry, and the Consumer Product
Safety Commission (CPSC) to undertake a “coordinated Federal Research Action Plan.” That
plan, however, will not produce definitive guidance as it is geared to diagnose the array of “data
and knowledge gaps” including what precise mix of chemicals is in “recycled tire crumb” and
the potential pathways for human exposure.
The very preliminary nature of this initiative, however, may delay rather than hasten public
health safeguards, especially for very young children spending hours a day on turf playgrounds
and sports fields:


There will be no moratorium on building new tire crumb fields while the research
continues. Nor will parents be given warnings about the potential risks already identified;



Even for the chemical exposures identified previously or through these studies, there are
no longitudinal studies proposed to learn the effects of long-term exposure, especially to
children. Instead, toxicity reviews will be confined to “existing databases” which are few
and seriously incomplete at best. As a result, the key question of what level of childhood
exposure should be of concern will be left largely unexamined; and



Some of the plan’s elements are an utter waste of resources, such as CPSC being tasked
with “exploring conducting a survey of parents to get first hand perspectives on potential
exposures from playground surface materials.” The Consumer Product Safety
Commission does not need a survey to know that children come into intimate contact
with playground surfaces and play with any loose shredded or granular surface by
building with it, pouring it over each other, burying each other in it and sometimes
ingesting it in the process.

II. There Should Be a Focus on Lead
The scattered design of this effort threatens to deflect attention away from several already
identified toxic substances. One of the most obvious of immediate concern is lead – one of the
most harmful neurotoxic substances for children often but irregularly and unpredictably found in
both tire crumb and plastic components of synthetic turf systems.
As CDC’s National Center for Environmental Health warns:
“Reducing children’s exposure to lead is one of the greatest environmental health
accomplishments in the past 20 years. However, there is no safe level of lead, and
children are still being exposed to lead and other environmental hazards.” 1
Moreover, there is no identified safe blood lead level in children. Lead exposure can affect
nearly every system in the body. The effects are especially insidious because lead exposure often
occurs with no obvious symptoms, it frequently goes unrecognized.2
1

Healthy Homes/Lead Poisoning Prevention Program CDC 24/7: Saving Lives. Protecting People from Health
Threats http://www.cdc.gov/nceh/information/healthy_homes_lead.htm
2
http://www.cdc.gov/nceh/lead/ and http://www.cdc.gov/nceh/information/healthy_homes_lead.htm

Lead has been identified in synthetic turf fields as early as 2008 but was not addressed in any
systemic way due to lack of standards or required testing (although the CPSC could have
required the testing mandated for children's products since 2008 under the Children’s Product
Safety Improvement Act (CPSIA).
In fact, the CPSC tested synthetic turf carpets and found lead at varying levels depending on
sample age, but then, astoundingly, concluded the whole synthetic turf system was always and
everywhere safe for children, based on inappropriate modelling rooted in two incorrect
presuppositions: 1) that there is a safe level of blood lead for children; and 2) ingestion is the
only mode of exposure, which it is not since inhalation and dermal exposure are obvious routes
as well.3
To this day the synthetic turf industry cites the still CPSC-posted “OK to Install, OK to Play On”
press release4 which has been disavowed, in front of Congress, by CPSC Commissioner Kaye.5
A 2012 study on artificial turf done for the New Jersey Department of Environmental Protection
found artificial fields made of tire crumb can contain highly elevated levels of lead much greater
than the allowed levels for children, noting “concerns with regard to potential hazards that may
exist for individuals and in particular children who engage in sports activities on artificial fields”;
and that “Inhalable lead present in artificial turf fields can be resuspended by even minimal
activity on the playing surface.”6
Scientists from Rutgers recently participated in a study which found lead and other toxins in the
both the plastic rug (supplied by the industry) and tire crumb infill. Lead was also was found in
simulated body fluids meaning there is little or no protection of any kind against the lead getting
out of the material into the body:
“Since it is possible that children may be exposed to potentially high concentrations of
lead while using artificial turf fields we recommend, at a minimum, all infill and fibers
should be certified for low or no lead content prior to purchase and installation.”7
The study also found lead and chromium in both the tire crumb and the plastic rug and simulated
body fluids at sometimes extremely high levels even in new field carpets:
“Lead was detected in almost all field samples for digestive, sweat, and total extraction
fluids with digestive fluid extract of one field sample as high as 260 mg/kg. Metal
concentrations were not markedly different across the three different sample types (new
infill, new turf fiber, tire crumb field sample). However, one of the ‘new’ turf fiber
3

http://www.peer.org/assets/docs/epa/3_21_13_CPSC_Complaint.pdf
http://www.cpsc.gov/en/Newsroom/News-Releases/2008/CPSC-Staff-Finds-Synthetic-Turf-Fields-OK-to-InstallOK-to-Play-On
5
https://www.youtube.com/watch?v=7crcxR8aYjo
6
http://www.nj.gov/dep/dsr/publications/artificial-turf-report.pdf
7
“Bio-accessibility and Risk of Exposure to Metals and SVOCs in Artificial Turf Field Fill Materials and Fibers”
2014 Brian T. Pavilonis1,Clifford P. Weisel1, Brian Buckley1, and Paul J. Lioy
http://www.ncbi.nlm.nih.gov/pmc/articles/PMC4038666/pdf/nihms565643.pdf
4

samples contained relatively large concentrations of chromium (820 mg/kg) and lead
(4400 mg/kg) compared to the other samples tested… [The] variability of lead contained
in the infill material is large and can span more than two orders of magnitude. One field
[tire crumb] sample did contain a high lead level (260 mg/kg) which was on the same
order of magnitude as the NJ DEP cleanup value (400 mg/kg).”
In evaluating and regulating lead in synthetic turf, the Division of Health Assessment and
Consultation of the Agency for Toxic Substances and Disease Registry concluded that:
“Synthetic turf can deteriorate to form dust containing lead at levels that may pose a risk
to children. Given elevated lead levels in turf and dust on recreational fields and in child
care settings, it is imperative that a consistent, nationwide approach for sampling,
assessment, and action be developed. In the absence of a standardized approach, we offer
an interim approach to assess potential lead hazards when evaluating synthetic turf.”8
But no such approach has ever been instituted. Indeed, as reported in USA Today in 2015:
“The CDC in 2008 said communities should test recreational areas with turf fibers made
from nylon, and they should bar children younger than 6 from the areas if the lead level
exceeded the federal limit for lead in soil in children's play areas. But some communities
have refused to test their fields, fearing that a high lead level would generate lawsuits or
force them to replace and remove a field, which costs about $1 million, according to a
2011 New Jersey state report. Forty-five of 50 New Jersey schools and towns contacted
in 2009 by epidemiologist Stuart Shalat would not let him test their turf-and-rubber
fields, Shalat's report states. The EPA also found, in 2009, that ‘it was difficult to obtain
access and permission to sample at playgrounds and synthetic turf fields.’”9
Industry also admits that its products contain lead. In testimony before the Maryland State
House, a representative of the company FieldTurf when asked point-blank by one delegate:
“Is there lead in your products?” The company executive answered,
“There’s lead in a lot of things in this world…Yes, there’s lead in our products.”10
Both old and new fields keep showing up with lead in them when tested. But the distribution is
not homogeneous and is unpredictable with demonstrated high level content hotspots which
could evade representative sampling. Some tested fields have little or no lead, while some have
high levels and some fields have both high and low levels within the same field (both carpet and
tire crumb infill). There is no way of knowing if any of the components of a given field contain
lead, and how much, without stringent and thorough testing of each field. Unfortunately for the
children, fields with high lead remain in use. However, no one is monitoring, let alone
regulating, artificial turf for lead or other toxins in either old or new fields.

8

Van Ulirsch et al (Environmental Health Perspectives. 2010 Oct;118(10):13459 http://www.ncbi.nlm.nih.gov/pubmed/20884393
9
http://www.usatoday.com/story/news/2015/03/15/artificial-turf-health-safety-studies/24727111/
10
http://wtop.com/montgomery-county/2016/03/md-lawmakers-seem-information-artificial-turf-schools/

In short, the priority for any federal efforts should be to ensure that all playing surfaces for
children are lead-free. The CDC has repeatedly stressed that every effort should be made to
eliminate all unnecessary sources of lead in the environment, especially a child's environment.
Lead in artificial turf is not only totally unnecessary but dangerous to health at any level.
III. Federal Action Plan Should Be Tied to Some Action
No matter how hazardous, artificial turf is essentially unregulated. Under a revised rule of the
Resource Conservation and Recovery Act (RCRA), recycling of hazardous waste may be
considered “legitimate” and therefore exempt from RCRA requirements, even if the end product
it creates is more toxic than other similar products on the market. This applies even where the
end-product is used by children. According to EPA:
“If a hazardous secondary material has been reclaimed and made into a product that will
be used by children, and that product contains hazardous constituents that are not in
analogous products, that product will likely need to be closely scrutinized.”11
Therefore, the EPA does not prohibit the unnecessary incorporation of hazardous constituents
into these products, or even guarantee close scrutiny of this recycling even when children are
involved. Thus, manufacturers that use hazardous wastes to make products for children are no
longer subject to RCRA safety requirements.
To fill this void in public health safeguards, PEER makes three recommendations:
1. The three participating agencies should issue a joint public statement urging that tirecrumb not be installed as play surfaces for children under age 13 until a thorough risk
assessment and analysis of toxic pathways has been completed.
2. The CPSC should declare playgrounds and sports fields in elementary schools to be a
children’s product.
Spurred by outrage over importation of toxic Chinese-made toys, in 2008 Congress mandated
safeguards for children’s products by imposing a lead content limit of 100 parts per million and
third-party testing to ensure compliance. Playgrounds made with shredded tires, however,
generally exceed this lead limit. In fact, the only test the CPSC ever conducted found nearly half
of the fields that it sampled contained lead in amounts more than three times this legal limit (and
they did not test tire crumb infill but only carpets).
In 2012, the Commission declined to classify crumb rubber playgrounds and elementary school
sports fields as a children’s product in response to a PEER request saying that it needed evidence
of promotion and marketing directed at children. In 2013, PEER submitted evidence of
companies like TotTurf and KidWise Outdoor Products marketing products under names such as
PlaySafer and Play Tuff Tiles using sales slogans declaring “softer on little knees” and “keep
kids safe.”12

11
12

http://www.epa.gov/oecaerth/cleanup/rcra/index.html
http://www.peer.org/news/news-releases/move-to-make-synthetic-playgrounds-lead-free.html

In response to this submission, on September 27, 2013 the CPSC informed PEER that it had
tasked its Office of Compliance and Field Operations with a “review and determination of
whether any enforcement action is appropriate.”13 A year later PEER inquired and ultimately
submitted a formal request under the Freedom of Information Act to find out the outcome of this
review. The Commission declined to reply and PEER filed a lawsuit in federal district court to
compel the answer.
That lawsuit ultimately produced documents that that the CPSC had decided not to enforce toxic
lead limits required by law for children’s products in artificial turf playgrounds. On July 20,
2015, CPSC sent a letter to U.S. Senator Elizabeth Warren (D-MA) which contained the
following statement:
“Upon further exploration, Compliance staff concluded, at that time, specific product
enforcement was unlikely to be the best option, based upon the need for individual health
assessments, among other factors. To my knowledge, this information has also been
communicated to PEER.”14
This statement is curious in several respects, beyond that this decision was never shared with
PEER:


The children’s product enforcement route does not require a health assessment. It only
requires a test for lead content – a test which is supposed to be done by the manufacturer;



In response to the PEER Freedom of Information Act lawsuit and a subsequent FOIA
about the basis for the letter to Senator Warren, the CPSC has not been able to locate any
paper trail documenting this decision. A request for clarification received no written
answer. Another email suggests the decision was never reduced to writing; and



If enforcement was not “the best option,” CPSC cannot identify what other options it
examined.

In short, this federal research action plan is proposed solely because the CPSC has abdicated its
legal duty to protect children on playgrounds from chemical exposure.
3. Standardize and monitor ingredients used in artificial fields.
There should be stringent testing of all the colors and of the backing of the carpet for total lead
content (chromium and cadmium should also be tested for) as well as testing of many samples of
the infill.
These products contain an ever-changing “witches brew” of chemicals with wide variations even
in the same field.- so undetectable, low and very high levels can all be found in the same field.
Since there is not standardization, monitoring or regulation of the source material, there is no
way that any study or combination of studies, including the ones proposed, can identify with
certainty just what people are being exposed to on these fields from one field to another or even
13
14

http://www.peer.org/assets/docs/cpsc/11_12_13_CPSC_child_product_referral.pdf
http://www.peer.org/news/news-releases/cpsc-drops-artificial-turf-playground-safety-review.html

within a given field. Certainly any assurance of health safety can never be made given the
knowledge of definite toxins present and the sheer magnitude of the unknowns.
At the same time, there is a lack of Material Safety Data Sheets (MSDS) for the source material
i.e., the tires themselves.
A single company MSDS is an anomaly and indeed its partial list of ingredients raises many red
flags. Most tire companies have asserted they do not need to file MSDS, stating:
“Tires meet the definition of article as defined by the OSHA Hazard Communication
Standard (29 CFR 190.1200) and are exempt from MSDS requirements.”
This ingredient labeling is even more important since pulverizing of the material makes all the
ingredients exponentially more available to interact with and affect living things including
people the smaller the pieces get.

In summary, the federal research action plan is inadequate and must be tied to some actions,
including immediate actions available to CPSC, if it is to do any good.
###

Page 1 of 1

PUBLIC SUBMISSION

As of: 5/3/16 6:30 PM
Received: May 02, 2016
Status: Posted
Posted: May 03, 2016
Tracking No. 1k0-8pei-xo5g
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-2016-0002-0061
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill 0923-16PJ Comment on
FR Doc # 2016-03305

Submitter Information
Name: Cindy Million
Address: 22302
Email: [email protected]

General Comment
My son's school has a crumb rubber play ground surface. The other day, I saw a neighbor's
9-month-old baby crawling on the surface. She fell and ended up with crumb rubber over her
face and hands. A piece of crumb rubber made it into her mouth before her mom could stop it.
How many other times has that happened? How many other babies have been ingesting the
crumb rubber? My son plays on the surface every day before lunch. I asked the school if his
class could wash their hands before lunch. I was told that there isn't enough time. So only my
son is allowed to wash his hands. The city soccer league has 4-year-olds playing on crumb
rubber athletic fields, and they eat half-time snacks on the field, without any hand washing.
We know what's in crumb rubber. We know what our kids are getting exposed to--whether it's
breathing in the VOCs, getting particles in their cuts when they fall, or ingesting the particles or
dust that results from the particle break-down. Kids should NOT be playing on carcinogens.
And yet they are. How can you let kids play on carcinogens when there's absolutely no longterm safety data? I've read through existing research articles. They have small sample sizes,
they are short-term, they are based on models not people. Please use common sense -carcinogens, endocrine disruptors, and heavy metals are not a good playing surface for children.
Please start considering our children's overall chemical burden and not the turf industry.

https://www.fdms.gov/fdms/getcontent?objectId=0900006481fa08ca&format=xml&showor... 5/3/2016

Page 1 of 1

PUBLIC SUBMISSION

As of: 5/3/16 6:34 PM
Received: May 02, 2016
Status: Posted
Posted: May 03, 2016
Tracking No. 1k0-8pel-3fcr
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-2016-0002-0067
Comment on FR Doc # 2016-03305

Submitter Information
Name: Anonymous Anonymous

General Comment
Children have unique developmental vulnerabilities to the synergistic affects of unregulated
toxins in their environment. When exposed at a critical point in development the results can be
life altering
Our kids are not a science experiment. This has to stop. A recycling need cannot come before
the health of our children.

https://www.fdms.gov/fdms/getcontent?objectId=0900006481fa1aad&format=xml&showor... 5/3/2016

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: [email protected]

General Comment
See attached file(s)

Attachments
ME comment re federal review of AT

https://www.fdms.gov/fdms/getcontent?objectId=0900006481fa18ec&format=xml&showor... 5/3/2016

MONTGOME RY COUNTY CO UNCI L
R O C K V I L L E , M A R Y L AN D
Comment on “Collections Related to Synthetic Turf Fields with Crumb Rubber Infill”
From: Montgomery County, Maryland Councilmember Marc Elrich (At-large)
Date: May 2, 2016
As an elected official, I have been confronted with the issue of whether artificial turf playing
fields are safe and whether public funds should be used to construct and maintain these fields. I
represent the almost one million residents of Montgomery County, Maryland; our county is one
of the wealthiest and best-educated counties in the country. My staff and I have grappled with
questions surrounding artificial turf for years, and the more we have examined the issue, the
more we realize how little is known and how few questions can be adequately answered.
I appreciate the attempt by the federal agencies to tackle this issue, and on behalf of many of my
constituents and based on years of reviewing research and conversations with scientists, parks
managers, school administrators, elected officials, residents and other concerned individuals, I
make the following comments, observations and requests. I have five major points and then
follow them with additional information to support those points.
1. Clarify that the questions and goals outlined in this study will not answer the question of the
true safety/toxicity of AT with tire crumb infill. Characterizing chemical composition and
“exposure potential” are insufficient tools. This study will not satisfactorily answer the
question: are artificial turf fields safe for children to use over the long-term? An
epidemiological study is necessary. Only a long-term controlled epidemiological study could
provide meaningful answers about human safety. University of Washington soccer coach
Amy Griffin continues to collect names of soccer players, other athletes and other frequent
users of artificial turf fields (like marching band participants). This information raises
serious concern, and the federal agencies need to consider how they can collect information
that could analyze actual uses and outcomes.
2. Any and all toxicity studies must address and examine cumulative and combined effects of
toxic chemicals. Artificial turf contains a variety of chemicals that interact with each other
and in the body. Without studying their synergistic effects, the study will exclude some
important considerations. (See below for scientific comment on this issue.)
3. All potential health impacts should be viewed specifically and separately for children.
Studies should examine exposure for children. “Environmental exposure for children is quite
different. They take in much more of everything than adults. Their brains and nervous
systems are developing quite rapidly – referred to as “unique windows of vulnerability.”
(Joel Forman, MD, Mt. Sinai Medical School, Program Director of the Pediatric Residency

Program, Children's Environmental Health Center) Towards that end, I urge you to consult
extensively with Dr. Forman, Dr. Phillip Landrigan and other researchers associated with the
Childrens Environmental Health Center at Mt. Sinai Medical School.
4. For a federal study to be useful to local jurisdictions and residents, it must acknowledge and
address the myriad of issues and concerns that are inextricably intertwined. The chemical
composition of crumb rubber infill is an important issue, but it is not the only issue. The
blades, carpet, carpet backing and the color of the blades are all integral to any meaningful
assessment. Other issues should be examined and acknowledged: the heat impact for the
field users as well as serious environmental concerns, including the “heat island” effect and
impacts on waterways, aquatic life and wildlife.
5. Every step of the way, the involved federal agencies must be mindful of their possible biases.
I would refer you to the EPA website announcing this study: “Limited studies have not
shown an elevated health risk from playing on fields with tire crumb, but the existing studies
do not comprehensively evaluate the concerns about health risks from exposure to tire
crumb.” (https://www.epa.gov/chemical-research/federal-research-action-plan-recycled-tirecrumb-used-playing-fields) Such a statement is misleading and should be deleted. Results
from “limited studies” have been mixed. If “limited studies” refers to EPA’s prior studies, it
should be noted that they were not simply limited but also quite possibly flawed, and
therefore, not an appropriate basis for any general statements.
(http://www.peer.org/news/news-releases/epa-retracts-synthetic-turf-safety-assurances.html)

Additional information and commentary:
Regarding points 1 and 2 above:
How we think about levels of concern of chemicals is changing and evolving.
A recently published scientific paper, “What Can Epidemiological Studies Tell Us about the
Impact of Chemical Mixtures on Human Health?” explains:
“Although there is growing concern that exposure to chemical mixtures during critical
periods of human development could increase the risk of adverse health effects including
allergic diseases, cancer, neurodevelopmental disorders, reproductive disorders, and
respiratory diseases, researchers primarily study chemicals as if exposure occurs
individually. This one-chemical-at-a-time approach has left us with insufficient
knowledge about the human health effects of exposure to chemical mixtures.” [Emphasis
added.] http://ehp.niehs.nih.gov/15-10569/
Another study from 2015 suggests that the combination of “safe” chemicals may increase
cancer risk:
“Our analysis suggests that the cumulative effects of individual (non-carcinogenic)
chemicals acting on different pathways, and a variety of related systems, organs, tissues
and cells could plausibly conspire to produce carcinogenic synergies.” [Emphasis added.]
http://carcin.oxfordjournals.org/content/36/Suppl_1/S254.full?sid=db47f5ec-47a2-4879bf30-6da9c076003d#ref-8

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In commenting on the above study, the director of the National Institute of Environmental Health
Sciences, Linda Birnbaum (who was not involved in the study), said
“….We live in a chemical soup,…Considering the safety of individual chemicals is a lot like
looking at the trees, but missing the forest, Birnbaum said. When doing research to determine
chemical safety, “we’ve got to start thinking more about what reality is,” she said. This could
mean sweeping changes in rules about the levels of chemicals considered safe in drinking water,
food, and air. I’d like to see regulators and policy makers start looking at the totality of the
exposure instead of one chemical at a time,” she said. [Emphasis added.] (“Combinations of
'safe' chemicals may increase cancer risk, study suggests,” Los Angeles Times, by Sasha HarrisLovett, 7/1/15 http://www.latimes.com/science/sciencenow/la-sci-sn-chemical-combinationssafety-cancer-20150626-story.html)
While the 2015 report is important and significant, this general idea and information is not new.
As the President’s Cancer Panel pointed out in its 2008-2009 annual report, federal
environmental laws not only leave many known carcinogens completely unregulated, they also
“fail to address the potential hazards of being exposed to combinations of chemicals”. [Emphasis
added] (Environmental Working Group, http://www.ewg.org/research/rethinkingcarcinogens/executive-summary)
The true impact of chemical exposure could take decades to be measured.
A telling example is a study of 9,300 daughters born to mothers who had been exposed to the
pesticide DDT, which was banned in 1972 because of its effects on the environment, especially
the eggs of the bald eagle. EPA labeled DDT as a probable carcinogen, and multiple studies
linked DDT exposure to breast cancer, but then a 2014 meta-analysis found no significant
association. But then this mother-daughter study showed that the prior studies were looking at
the wrong generation – the daughters of women exposed to DDT - were associated with almost a
fourfold increase in breast cancer, independent of the mother's history of breast cancer. The
study, which covered a span of 54 years, also determined that those with higher levels of
exposure were diagnosed with more advanced breast cancer. The study results are dramatic, but
they took 54 years. (“Startling link between pregnant mother’s exposure to DDT and daughter’s
risk of breast cancer,” by Ariana Eunjung Cha, The Washington Post, 6/17/15
https://www.washingtonpost.com/news/to-your-health/wp/2015/06/16/ddts-breast-cancer-legacypregnant-mothers-exposure-linked-to-four-fold-increase-in-daughters-risk/ and
http://press.endocrine.org/doi/10.1210/jc.2015-1841)
You will not have “safety” answers in 2016 or one or two years later. Please acknowledge this
fact and address epidemiological questions.
Further points to consider:
Federal agencies should not reference “prior studies” without including and acknowledging the
following studies, which raise serious concern about artificial turf. One study raises the
possibility of inhalable lead.
The study states “…if the lead is present to any appreciable extent in the wipes it will likely
be present in the breathing zone of players who are active on these fields, and that
furthermore, these levels potentially exceed ambient EPA standards. (“An Evaluation of

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3

Potential Exposures to Lead and Other Metals as the Result of Aerosolized Particulate
Matter from Artificial Turf Playing Fields Submitted to:Alan Stern, Dr.P.H. New Jersey
Department of Environmental ProtectionSubmitted by: Stuart L. Shalat, Sc.D. (July 14,
2011) http://www.nj.gov/dep/dsr/publications/artificial-turf-report.pdf) Note that many
facilities would not allow testing.
Other studies have raised serious concerns about tire crumb and lead exposure.
A 2014 study found lead and other toxins in the both the plastic rug and tire crumb infill.
Lead was also was found in simulated body fluids meaning there is little or no protection of
any kind against the lead getting out of the material into the body. "Since it is possible that
children may be exposed to potentially high concentrations of lead while using artificial turf
fields we recommend, at a minimum, all infill and fibers should be certified for low or no
lead content prior to purchase and installation."
("Bio-accessibility and Risk of Exposure to Metals and SVOCs in Artificial Turf Field Fill
Materials and Fibers" Brian T. Pavilonis, Clifford P. Weisel, Brian Buckley, and Paul J.
Lioy http://www.ncbi.nlm.nih.gov/pmc/articles/PMC4038666/pdf/nihms565643.pdf 2014)
No two fields are alike because each field contains 30,000 to 40,000 ground up tires, which
come from a multitude of manufacturers.
“Every turf field has to be analyzed in detail to be sure it doesn’t have a problem,’
said Paul Lioy, a professor of environmental and occupational medicine at the Robert
Wood Johnson Medical School in New Jersey.” [Emphasis added.] (“Feds promote
artificial turf as safe despite health concerns,” by Thomas Frank USA Today, 3/16/2015
http://www.usatoday.com/story/news/2015/03/15/artificial-turf-health-safetystudies/24727111/)
"Not surprisingly, the shredded tires contain a veritable witch’s brew of toxic
substances," Gaboury Benoit, Ph.D., Yale Professor of Environmental Chemistry and
Engineering. (“Study: Artificial turf contains carcinogens,” by Tony Spinelli, 7/3/15
http://www.theridgefieldpress.com/48210/study-artificial-turf-containscarcinogens/#ixzz47WNF1FSf)
Additionally, the information required from field managers around the country is time-intensive
as outlined in the Federal Register, and the attempt to reach a maximum of 40 fields nationally is
insufficient. So the time required from the individuals is large and the amount of information
collected will not be much more than anecdotal.
The fields heat is a health hazard. It is hotter than asphalt and much hotter than grass.
At the Women’s World Cup in Edmonton, Canada, in June 2015, the air temperature was 75
degrees, and “the heat from the carpet approaching 120 degrees at kickoff…Research, partly
funded by the city of Las Vegas, found artificial turf above 122 degrees is considered unsafe for
sustained athletic use and that, depending on the air temperature, turf can get as hot as 180
degrees…This was a temperature where if you put your hand down on it, you could only hold it
for five seconds or so before it would burn,” Dale Devitt, director of the Center for Urban Water
Conservation at the University of Nevada Las Vegas told the Vegas Sun. [Emphasis added.]

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4

(“The artificial turf at the Women’s World Cup was reportedly 120 degrees at kick off,” by
Marissa Payne, The Washington Post, 6/6/2015
http://www.washingtonpost.com/news/early-lead/wp/2015/06/06/the-artificial-turf-at-thewomens-world-cup-was-reportedly-120-degrees-at-kick-off/)
Environmental impacts of artificial turf should also be noted.
Artificial turf fields create “heat islands” – an environmental hazard.
The extreme heat “is not only a hazard for users, but also can contribute to the ‘heat island
effect,’ in which cities become hotter than surrounding areas because of heat absorbed by
dark man-made surfaces such as roofs and asphalt.” (“Synthetic Turf: Health Debate Takes
Root” by Luz Claudio, Environmental Health Perspectives 2008 March; 116(3): A116–
A122. http://www.ncbi.nlm.nih.gov/pmc/articles/PMC2265067/
“Columbia University climate researcher Stuart Gaffin analyzed thermal images generated
from NASA satellite maps of New York City. He wanted to figure out how urban trees may
help cool down neighborhoods. When Gaffin noticed a bunch of hot spots on the maps,
he assumed they were rooftops…two turned out to be turf fields" says Gaffin. In
retrospect, he says he should have realized that, because they're a perfect sunlight-absorbing
system.” (“High Temps On Turf Fields Spark Safety Concerns,” by Allison Aubrey,
National Public Radio, 8/7/2008
http://www.npr.org/templates/story/story.php?storyId=93364750)
Artificial turf appears to contribute to elevated levels of zinc in the water.
“There is a potential risk to surface waters and aquatic organisms associated with whole
effluent and zinc toxicity of stormwater runoff from AT fields.” (“Artificial Turf Study,
Leachate and Stormwater Characteristics,” July 2010 Conn. Department of Environmental
Protection
“Crumb rubber derived entirely from truck tires may have an impact on aquatic life due to
the release of zinc. For the other three types of crumb rubber, aquatic toxicity was found to
be unlikely.” Pg. 2
“Zinc concentrations are higher than the surface water standards.” Pg. 29
(“An Assessment of Chemical Leaching, Releases to Air and Temperature at Crumb-rubber
Infilled Synthetic Turf Fields” May 2009 from staff at NY State Department of
Environmental Conservation)
Plastic artificial turf blades will likely disintegrate and degrade with some ending up in bodies of
water and in the food of wildlife either directly or via landfills; plastics of various sizes are
already threatening aquatic life. The impacts of larger sized plastics is more widely known, but
now more is being discovered about the serious effects of microplastics. (“Ingested microscopic
plastic translocates to the circulatory system of the mussel, Mytilus edulis (L).” by Browne
MA1, Dissanayake A, Galloway TS, Lowe DM, Thompson RC, Environmental Science &
Technology, 7/1/2008 http://www.ncbi.nlm.nih.gov/pubmed/18678044) “As plastic breaks into
smaller pieces, it is more likely to infiltrate food webs. In laboratory and field studies, fish,
invertebrates and microorganisms ingest micrometer-sized particles…” (“Classify plastic waste

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5

as hazardous,” by Chelsea M. Rochman, Mark Anthony Browne, Eunha Hoh, Hrissi K.
Karapanagioti, Lorena M. Rios- Mendoza, Hideshige Takada, Swee Teh, Richard C. Thompson.
Nature, 2/14/13.)
Confusion over focus of the undertaking:
While the official federal register announcement does not mention playgrounds, the EPA’s
website explaining this study refers to “this coordinated Federal Research Action Plan on
Recycled Tire Crumb Used on Playing Fields and Playgrounds…”
(https://www.epa.gov/chemical-research/federal-research-recycled-tire-crumbs-used-playingfields) It would be better to included playgrounds, especially since children are particularly
vulnerable to toxic chemicals, but at a minimum the information disseminated should be
consistent between postings.
Conclusion:
As should be apparent from the above information and comments, my staff, constituents and I
have spent numerous hours reviewing these issues. I am deeply concerned that the study as
designed will offer the false hope of absolute answers. We may not know for many years the
true and complete impacts of artificial turf fields. I have concluded that we should adhere to the
precautionary principle and minimize use of artificial turf fields. Instead, we need to focus our
research and energy on improving natural grass fields, which already can be designed to
withstand heavy rains and avoid rain-outs. Increasing knowledge and experience is helping
expand the usage of these fields. The public focus should be on the best practices that give the
greatest use of natural grass fields with the least amount of fertilizers, pesticides and water.

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Page 1 of 1

PUBLIC SUBMISSION

As of: 5/3/16 6:38 PM
Received: May 02, 2016
Status: Posted
Posted: May 03, 2016
Tracking No. 1k0-8pen-xk2y
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-2016-0002-0073
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill 0923-16PJ Comment on
FR Doc # 2016-03305

Submitter Information
Name: Sarah Evans
Address: 10029
Email: [email protected]
Organization: Children's Environmental Health Center, Icahn School of Medicine at Mount
Sinai

General Comment
See attached file(s)

Attachments
Mount Sinai CEHC Comment on ATSDR-2016-0002

https://www.fdms.gov/fdms/getcontent?objectId=0900006481fa1dad&format=xml&showor... 5/3/2016

Children’s Environmental Health Center
Department of Preventive Medicine
Icahn School of Medicine at Mount Sinai
One Gustave L. Levy Place, Box 1217
New York, NY 10029-6574

May
 2,
 2016

Leroy
 A.
 Richardson,
 Information
 Collection
 Review
 Office

Centers
 for
 Disease
 Control
 and
 Prevention

1600
 Clifton
 Road
 NE.,
 MS-­‐D74
 Atlanta,
 Georgia
 30329.

Federal
 eRulemaking
 Portal:
 Regulation.gov

Re:
 Docket
 No.
 ATSDR-­‐2016-­‐0002

To
 Whom
 It
 May
 Concern:

We,
  the
  Children’s
  Environmental
  Health
  Center
  (CEHC)
  of
  the
  Icahn
  School
  of
  Medicine
  at
  Mount

Sinai,
 strongly
 support
 the
 Federal
 Research
 Action
 Plan
 on
 Recycled
 Tire
 Crumb
 Used
 on
 Playing
 Fields

and
 Playgrounds.

 It
 is
 our
 hope
 that
 this
 study
 will
 exhaustively
 address
 data
 gaps,
 characterize
 crumb

rubber
  constituents,
  assess
  exposure
  pathways
  under
  realistic
  play
  conditions,
  and
  consider
  health

effects
  to
  vulnerable
  populations.

  Based
  upon
  the
  presence
  of
  known
  toxic
  substances
  in
  tire

rubber,
  the
  CEHC
  has
  issued
  a
  call
  for
  a
  moratorium
  on
  the
  use
  artificial
  turf
  generated
  from

recycled
 rubber
 tires
 pending
 comprehensive
 safety
 studies.

As
 pediatricians,
 epidemiologists,
 and
 laboratory
 scientists
 at
 the
 Children’s
 Environmental
 Health

Center
 of
 the
 Icahn
 School
 of
 Medicine
 at
 Mount
 Sinai,
 which
 hosts
 one
 of
 10
 nationally
 funded

Pediatric
 Environmental
 Health
 Specialty
 Units,
 we
 have
 received
 numerous
 phone
 calls
 from

concerned
 parents
 and
 physicians
 regarding
 the
 wide
 scale
 use
 of
 recycled
 rubber
 surfaces
 on
 school

grounds
 and
 in
 park
 properties.

 This
 led
 us
 to
 conduct
 a
 review
 of
 the
 risks
 and
 benefits
 of
 artificial

playing
 surfaces,
 during
 which
 we
 found
 significant
 gaps
 in
 the
 evidence
 supporting
 the
 safety
 of

recycled
 rubber
 turf
 products.
 The
 hazards
 associated
 with
 recycled
 tire
 rubber,
 coupled
 with
 the

unique
 vulnerability
 of
 children
 have
 led
 us
 to
 recommend
 that
 these
 products
 never
 be
 used
 as

surfaces
 where
 children
 play.

The
 major
 chemical
 components
 of
 recycled
 rubber
 are
 styrene
 and
 butadiene,
 the
 principal

ingredients
 of
 the
 synthetic
 rubber
 used
 for
 tires
 in
 the
 United
 States1.
 Styrene
 is
 neurotoxic
 and

reasonably
 anticipated
 to
 be
 a
 human
 carcinogen2.

 Butadiene
 is
 a
 proven
 human
 carcinogen
 that
 has

1

 Denly
 et
 al
 A
 Review
 of
 the
 Potential
 Health
 and
 Safety
 Risks
 from
 Synthetic
 Turf
 Fields
 Containing
 Crumb
 Rubber
 Infill.

May
 2008.

 http://www.nyc.gov/html/doh/downloads/pdf/eode/turf_report_05-­‐08.pdf

2

 ATSDR
 Toxicological
 Profile
 for
 Styrene,
 November
 2010.
 http://www.atsdr.cdc.gov/toxprofiles/tp53.pdf.

Children’s Environmental Health Center
Department of Preventive Medicine
Icahn School of Medicine at Mount Sinai
One Gustave L. Levy Place, Box 1217
New York, NY 10029-6574

been
 shown
 to
 cause
 leukemia
 and
 lymphoma3.

 Shredded
 and
 crumb
 rubber
 also
 contain
 lead,

cadmium,
 and
 other
 metals
 known
 to
 damage
 the
 developing
 nervous
 system4,5.
 Potentially
 harmful

chemicals
 have
 been
 detected
 in
 the
 air
 above
 rubber
 turf
 such
 as
 benzathiazole
 and
 polycyclic

aromatic
 hydrocarbons
 (PAHs),
 both
 of
 which
 are
 linked
 to
 cancer6.

Recommendations:
 To
 be
 informative,
 comprehensive
 studies
 should
 consider,
 at
 a
 minimum:

•   Exposure
 assessment
 under
 realistic
 playing
 conditions.

Studies
 should
 consider
 weather
 conditions
 such
 as
 extreme
 heat,
 potential
 for
 increased

exposures
 as
 turf
 degrades
 over
 time,
 as
 well
 as
 extended
 exposure
 times
 that
 may
 occur
 when

rubber
 pellets
 are
 transported
 home
 on
 the
 bodies
 and
 clothing
 of
 players.

•   All
 possible
 routes
 of
 exposure:
 inhalation,
 ingestion
 and
 dermal
 absorption.

Individuals
  are
  exposed
  to
  harmful
  substances
  when
  crumb
  rubber
  pellets
  touch
  their
  skin
  or

are
  swallowed,
  and
  possibly
  from
  breathing
  chemicals
  released
  into
  the
  air
  from
  the
  surface.

While
  manufacturers
  claim
  that
  a
  number
  of
  scientific
  studies
  indicate
  low
  risk
  of
  harm
  from

recycled
  tiring
  playing
  surfaces,
  these
  studies
  were
  not
  conducted
  in
  a
  rigorous
  manner

comprehensive
 enough
 to
 prove
 safety.

•   Potential
 health
 effects
 not
 only
 of
 individual
 chemicals,
 but
 also
 of
 mixtures
 of
 chemicals
 to

determine
 their
 additive
 and
 synergistic
 effects.

It
 is
 important
 to
 note
 that
 risk
 of
 harm
 due
 to
 exposures
 from
 recycled
 rubber
 turf
 has
 been

assessed
 only
 for
 single
 chemicals,
 yet
 children
 are
 exposed
 to
 numerous
 harmful
 chemicals
 in

aggregate
 during
 play
 on
 these
 surfaces.

 It
 is
 widely
 recognized
 that
 carcinogens
 and
 other

environmental
 toxins
 act
 in
 an
 additive
 or
 multiplicative

 fashion,
 making
 risk
 assessment
 of
 the

chemical
 mixtures
 present
 in
 recycled
 rubber
 critical
 for
 a
 comprehensive
 safety
 assessement7.

3

 International
 Agency
 for
 Research
 on
 Cancer,
 2008.
 http://monographs.iarc.fr/ENG/Monographs/vol100F/mono100F-­‐
26.pdf

4

 Timothy
 Ciesielski
 et
 al.
 Cadmium
 Exposure
 and
 Neurodevelopmental
 Outcomes
 in
 U.S.
 Children.
 Environ
 Health

Perspect.
 2012
 May;
 120(5):
 758–763.

 27.
 doi:
 10.1289/ehp.1104152

5

 CDC
 (2012)
 Low
 Level
 Lead
 Exposure
 Harms
 Children:
 A
 Renewed
 Call
 for
 Primary
 Prevention.

http://www.cdc.gov/nceh/lead/acclpp/final_document_010412.pdf

6

 Connecticut
 Department
 of
 Public
 Health
 (2010)
 Human
 Health
 Risk
 Assessment
 of
 Artificial
 Turf
 Fields
 Based
 Upon
 Results

from
 Five
 Fields
 in
 Connecticut.
 http://www.ct.gov/deep/lib/deep/artificialturf/dph_artificial_turf_report.pdf

7

 Goodson
 WH
 et
 al
 2015.
 Assessing
 the
 carcinogenic
 potential
 of
 low-­‐dose
 exposures
 to
 chemical
 mixtures
 in
 the

environment:
 the
 challenge
 ahead.
 Carcinogenesis
 36(Suppl
 1):S254–S296.

Children’s Environmental Health Center
Department of Preventive Medicine
Icahn School of Medicine at Mount Sinai
One Gustave L. Levy Place, Box 1217
New York, NY 10029-6574

•   The
 unique
 vulnerability
 of
 very
 small
 children
 as
 well
 as
 individuals
 in
 certain
 “Windows
 of

Susceptibility”
 such
 as
 pregnancy
 and
 the
 pubertal
 period.

Children
 and
 fetuses
 are
 particularly
 sensitive
 to
 exposure
 to
 toxic
 chemicals
 due
 to
 their

developing
 organ
 systems
 and
 immature
 enzymatic,
 hepatic,
 and
 renal
 function.
 In
 addition,

children’s
 developmentally
 appropriate
 hand
 to
 mouth
 behaviors,
 high
 respiratory
 rates

compared
 to
 adults,
 and
 close
 proximity
 to
 the
 ground
 lead
 to
 increased
 potential
 for
 toxins
 to

be
 inhaled,
 absorbed
 through
 the
 skin
 and
 even
 swallowed
 by
 children
 who
 play
 on
 recycled

rubber
 surfaces.

Thank
 you
 for
 the
 opportunity
 to
 provide
 you
 with
 our
 professional
 opinion.

 We
 would
 be
 more
 than

happy
 to
 answer
 any
 questions
 that
 you
 might
 have.

Kind
 Regards,

Robert
 Wright,
 MD,
 MPH

Director,
 Mount
 Sinai
 Children’s
 Environmental
 Health
 Center

Sarah
 Evans,
 PhD,
 MPH

Research
 Scientist

Children’s
 Environmental
 Health
 Center

Homero
 Harari
 ScD,
 MSc

Research
 Scientist

Children’s
 Environmental
 Health
 Center

Page 1 of 1

PUBLIC SUBMISSION

As of: 5/3/16 6:40 PM
Received: May 02, 2016
Status: Posted
Posted: May 03, 2016
Tracking No. 1k0-8pep-dxpb
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-2016-0002-0075
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
I am a researcher for the Safe and Healthy Playfields Coalition, in Washington, DC.
The attached files are part the comments we would like to submit to ASTDR to support the
Federal Research on the Use of Tire Crumb in Playfields. ASTDR 2016-0002-0003.
First is a document that was submitted to OEHHA for its study on tire crumb safety, and is
relevant to your study. Second is a look up table for tire crumb volumes on fields, and runoff
volumes. If it would be interesting, the calculation data is available.
Many thanks for the chance to comment on this important topic.

Attachments
OEHHA meeting materials 2-8-16 for ASTDR2016-002-0003
TOTAL RUNOFF AND TIRE CRUMB VOLUMES TABLE

https://www.fdms.gov/fdms/getcontent?objectId=0900006481fa2f35&format=xml&showor... 5/3/2016

OEHHA / CalRecycle Synthetic Turf Scientific Advisory Panel Meeting 2/8/2016 – reference materials

ATHLETES AND PARENTS
California Synthetic Turf Scientific Advisory Panel Meeting - 2/8/2016

REFERENCE MATERIALS
Submitted by Safe Healthy Playing Fields Coalition www.safehealthyplayingfields.org

1

OEHHA / CalRecycle Synthetic Turf Scientific Advisory Panel Meeting 2/8/2016 – reference materials

In addition to stirring up the tire crumb particulates and tire crumb dust …
2

OEHHA / CalRecycle Synthetic Turf Scientific Advisory Panel Meeting 2/8/2016 – reference materials

… the on the field activity acts as a mortar and pestle to further break down the tire crumb into dust.
3

OEHHA / CalRecycle Synthetic Turf Scientific Advisory Panel Meeting 2/8/2016 – reference materials

CHEMICALS & TIRE CRUMB
Hundreds of chemicals and additives make up tire crumb. Some of the toxic chemicals found
in tire crumb synthetic turf include, but are not limited to; 1,3-butadiene, benzene, polycyclic aromatic
hydrocarbons (PAHs), manganese, zinc, lead, benzothiazole, butylated hydroxyanisole,
n-hexadecane, 4-(t-octyl) phenol, and phthalates.
Carbon black is the most prevalent chemical component of tire crumb. Carbon black is a nanoparticulate powder produced by the incomplete combustion of heavy petroleum products and
hydrocarbons. (Carbon black was not included in the “List of Chemicals of Potential Concern” in the
Synthetic Turf Study Scientific Advisory Panel Meeting materials).
Even though tire manufacturers are not required to divulge how much carbon black they use in
each tire -- it is generally recognized that carbon black makes up well over 25% (by weight) of a tire.
The current California Synthetic Turf Study lists the percentage as 38% (West Coast Rubber Materials Data Sheet).

carbon black

OEHHA listing for carbon black

The State of California’s Office of Environmental Health Hazard Assessment (OEHHA) lists
carbon black as a chemical known to cause cancer, (“airborne, unbound particles of respirable size”).
In 2006, the International Agency for Research on Cancer (IARC) determined carbon black’s
classification as a Group 2B carcinogen.
The Occupational Safety and Health Administration (OSHA) has set the legal limit for carbon
black exposure in the workplace as 3.5 mg/m3 over an 8-hour workday. The National Institute for
Occupational Safety and Health (NIOSH) has set a recommended exposure limit (REL) of 3.5 mg/m3
over an 8-hour workday. At levels of 1750 mg/m3, carbon black is considered immediately dangerous
to life and health.
An average tire crumb synthetic turf football field contains over 150 tons of carbon black
material. (This does not include the field’s apron -- sidelines and end zones. The larger soccer fields
and sports multiplexes would also contain more material)
Over 40,000 tires are used per playing field, (football field / soccer field).
An average passenger tire includes 7.5 pounds of carbon black.
40,000 x 7.5 = 300,000 pounds of carbon black per regulation football field.

4

FieldTurf.com
RubberNews.com / Crain Communications, Inc.,

OEHHA / CalRecycle Synthetic Turf Scientific Advisory Panel Meeting 2/8/2016 – reference materials

TIRE CRUMB SAMPLE

The sampled tire crumb is from infill material intended for an athletic field.

Tire crumb sample in container with lid, calibration slide, and ruler (6 inch / 15 cm).

5

OEHHA / CalRecycle Synthetic Turf Scientific Advisory Panel Meeting 2/8/2016 – reference materials

TIRE CRUMB PARTICULATES -- SIZE RANGE & CONTOURS
(This series of images zooms in on a single microscope calibration slide – images A-E)

A
Tire crumb and tire dust samples - placed on a calibration slide alongside metric ruler.

B

C
Calibration slides’ circle diameter is less than 4mm.

D

E
Each of the smallest divisions on the calibration slide equals 0.01 mm.
6

OEHHA / CalRecycle Synthetic Turf Scientific Advisory Panel Meeting 2/8/2016 – reference materials

ELECTRON MICROSCOPE / TIRE CRUMB DUST

HITACHI TM3000 electron microscope.

Electron microscope image of tire crumb dust at 500 microns.

Image of tire crumb dust at 200 microns.

Image of tire crumb dust at 2mm.

7

OEHHA / CalRecycle Synthetic Turf Scientific Advisory Panel Meeting 2/8/2016 – reference materials

BIO-EXPOSURE -- LODGING AND ENTRAPMEMT POTENTIAL
OF TIRE CRUMB PARTICULATES AND DUST
Respiratory Tract

Gastrointestinal Tract

trachea ~ 1 inch diameter (= 2.54cm = 25.4 mm)
bronchioles ~ 1- .5 mm or less
alveoli ~ .1 - .05 mm

esophageal ulcers ~ 2.5 cm
colon ~ 2.5-3.0 cm diameter
(gases from material trapped in the colon can be absorbed)

colon diverticula ~ 3.0 mm to 3.0 cm
folds of intestinal lining - up to 8mm in depth
intestinal appendix ~ 9 cm long / 7-8 mm diameter

(particles in the narrower sections of the respiratory system
can remain for extended periods and damage organ walls)

nose, (particles can be deposited & trapped in nose)

Tire crumb and tire crumb dust on calibration slide -- calibration slide circle’s diameter is less than 4mm.
8

OEHHA / CalRecycle Synthetic Turf Scientific Advisory Panel Meeting 2/8/2016 – reference materials

Users of the fields also include infants -- and passive activities.

9

OEHHA / CalRecycle Synthetic Turf Scientific Advisory Panel Meeting 2/8/2016 – reference materials
The chemicals found in the tire particulates, and gases of tire crumb synthetic turf can enter the human
body through open cuts, inhalation, ingestion, etc. Athletes and parents ask for the panels’ consideration of
the following variables regarding the chemicals and their physiological impact on the athletes. They might
include -- but not be limited to;
Indefinite source of tire crumb;
•the inconsistency (or lack of standardization) of the chemical makeup of the heterogeneous particles, i.e.;
- variability of 100s of tire manufacturers, including multiple countries of origin,
(see pages 1 through 8 of Tire Manufacturer Plant Codes http://www.harriger.com/tire1.htm)
- variability of years of manufacture,
- variability of tire types and models,
- variability of tire components; (tread, side wall, lining, etc.)
- variability of environmentally absorbed chemicals (lead, diesel exhaust, etc.)
• the sample size (depth & dimension) relative to available amount of tire crumb particulates per field.
Condition of tire crumb samples;
•new tire crumb application vs. previous (environmentally affected) tire crumb application
• accounting for granular convection (brazil nut effect)
•the range of particulate sizes (initial tire crumb applied to field, relative to a "treated/washed" sample as
suggested at the OEHHA workshops) (the smaller the individual particulates, the greater the total surface area).
• variability of ossification of tire crumb sample particulates
• field conditions (in relation to rain/watering activity, intensity of play activity, heat, etc.)
• sample location on field (i.e. corners, penalty kick areas, in front of goal, mid-field, etc.)
Impacts of tire crumb chemicals on human body;
•the individual as well as cumulative types of chemical impacts of the tire chemicals on the human body (i.e.
carcinogens, mutagens, sensitizers-agents, etc.)
• the person’s length of exposure time to chemical gases (polyaromatic hydrocarbons PAHs, etc.),
• the variety of intake mechanisms; respiration, ingestion, and dermal uptake (including open wounds)
• the number & duration of exposures (1 time exposure vs. cumulative) creating a chemical buildup within body.
• the cumulative types of exposures – large particle exposures, small particulate exposures, other chemical
exposures (including phthalate exposure from the plastic turf), & gas exposures (including heat variability), etc.
•the abrasive impacts of large (sharp) tire particles during intense respiration (inhalations and exhalations) on
lining of respiratory organs,
• the irritability (ulcerative and inflammatory) impact of tire particles (sharp) on various organ linings
• the amount of time chemicals are exposed to various organs of the body (i.e. trachea, lungs, bronchioles,
alveoli, intestines, appendix, etc.),
• the indirect transport routes of particle within body (i.e. traveling from respiratory system then swallowed into
alimentary system),
• the transport time of particle within body,
• the absorption of tire particulates and chemicals into transport systems, (i.e. the bloodstream, lymphatic
system),
• the distribution of tire chemicals in secondary exposures, (i.e. chemicals and metabolites may be distributed
and stored in various parts of the body, such as fat or bone, and remain in the individual for many years).
• the variety of potential metabolizing processes for conversion of tire chemicals into metabolites (metabolites
may be more toxic than the original chemical which was absorbed)
Condition and precondition of user or athlete;
• the respiration rate of athlete -- resting rate vs. exertion rate (resting an average athlete will breathe in and
out about 12 times a minute bringing in about 6 liters of air per minute. In conditions of physical exertion, up to
10,000 liters may be exchanged),
• the effect of hyperventilation or respiratory alkalosis on tire chemical interactions
• the age, sex, genetic background, previous exposures, diet and other factors of person exposed to tire crumb
and synthetic turf chemicals (i.e. infant, elderly, athlete,)
• the precondition of person (i.e. prior exposures to a toxin, asthmatic condition, autoimmune deficiency,
bezoars)
10

OEHHA / CalRecycle Synthetic Turf Scientific Advisory Panel Meeting 2/8/2016 – reference materials

ADDRESSING SOME COMMON MISUNDERSTANDINGS REGARDING TIRE CRUMB:

waste tire stock pile

spreading tire crumb on top of plastic turf

• Tire crumb is not covered by the plastic turf.
The tire crumb is poured on top of the plastic turf and is directly exposed to the athletes or children.
• The toxic chemicals used in tires have not been encapsulated through vulcanization.
Vulcanization is a temporary binding process that involves adding more chemicals. The tire, as it ages; dries,
hardens, and breaks down into a dust. The increased surface area of tire crumb and trampling hastens this process.
• The tire crumb used in the United States is not a less toxic mixture -- and the repurposed tires used on synthetic turf
are not limited to tires manufactured in the United States.
1) Hundreds of recipes are used to make tires. The ingredients used in the United States, (as well as throughout the
world), are secret, (or proprietary), information.
2) 30,000 to 40,000 tires are used per single athletic field. Determining the origin of each tire pulled from various
stockpiles is a difficult and unrealistically time consuming process of finding and identifying a tiny (usually well worn)
numerical code embedded on the tire, then matching it with an international index of hundreds of international
manufacturers. (see pages 1 through 8 of Tire Manufacturer Plant Codes http://www.harriger.com/tire1.htm)
• Cryogenic “cleaning” of the tire crumb does not remove the toxic chemicals.
Cryogenic cleaning is a process whereby the tire is frozen and then pulverized, to remove the steel belts and
other large components. The shattering of the frozen tire creates sharp angular edges,
• Potential high lead readings found in synthetic turf samples are not limited to the plastic turf.
Lead has been found in infrequent, but significant spikes, in the tire crumb. This is potentially due to
environmental uptake, (i.e. picked up from the lead weights historically used to balance tires), as well as highway
environmental exposures (i.e. lead paint, vehicle exhausts, etc.).

Soccer goalies ingest and inhale a greater amount of tire crumb.
11

OEHHA / CalRecycle Synthetic Turf Scientific Advisory Panel Meeting 2/8/2016 – reference materials

TIRE CRUMB AND TIRE DUST

12

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: [email protected]

General Comment
Dear Federal Agencies:
I am a concerned parent with a background in environmental law and a lacrosse player and
coach. Because of my education, I understand and appreciate the dangers inherent with repeated
exposure to toxins. Since I am a coach and player, I have also spent many hours on tire crumb
fields. I have witnessed how children are exposed to the fine particulate. After reading all the
available literature, my wife and I concluded the risks far outweigh any benefits of using fields
with tire crumb. Regardless of your final conclusions, it is clear that tire crumb is beyond our
capacity to thoroughly investigate - as I will discuss below. So we will never let our three young
children play on tire crumb. A generation of young Americans relies on you for similar
protection.
Later this year, when the federal government issue its preliminary statement regarding the
safety of tire crumb on synthetic turf fields, the most important messages to communicate to
concerned parents are: 1) Tire Crumb is a "Moving Target" - tire manufacturers frequently
change tire ingredients. So any formal study conclusion only speaks to existing fields. Any field
installed after a study, or any field not studies, may contain chemicals that were not examined in
past studies - including any federal study. So for all the millions of dollars of resources the
federal government is about to spend on this study, any conclusions can only speak to actual

https://www.fdms.gov/fdms/getcontent?objectId=0900006481fa2055&format=xml&showor... 5/3/2016

Page 2 of 3

fields that were studied. A study can only be backwards looking by its very nature since there
can be zero confidence that manufacturers will not change tire ingredients. This must be clearly
communicated. 2) Compound based risk assessment can only be done on chemicals and
compounds that have regulatory risk frameworks. Tire crumb contains numerous chemicals and
compounds with no regulatory risk frameworks. Therefore, any formal study will necessarily
contain significant data gaps. 3) Given that tire crumb contains multiple chemicals and
compounds with no risk frameworks, epidemiological studies and animal studies are the only
available methods of study to overcome this intrinsic problem. If there are no significant
epidemiological studies undertaken or planned, this must be communicated. If there are no
animal studies planned, this must be communicated.
If the three points of focus above were communicated clearly and prominently, it would help
educated field users to truly understand that sometimes, a problem is beyond our ability and
present capacity to accurately make predictions or draw conclusions regarding safely. If the
federal government was realistic in this endeavor, it would recognize this from the very start.
And given what we know about the multiple carcinogens, mutagens and reprotoxins in this
material, the government should conclude from the start that tire crumb is simply too risky to
use in such close proximity to children.
Sweden Concluded that Tires should Not be Used
Such a position would not be novel or unprecedented. The Swedish agency tasked with
reviewing tire crumb on synthetic fields recommended that tires should not be used as material
on synthetic turf fields for exactly these reasons. Sweden wisely concluded that given the
complexity and the inherent unknowns regarding tire crumb use on turf fields, they simply
should not be used.
"Tyres contain substances of very high concern
Tyres contain several substances that are substances of very high concern. These substances
maypersist in the environment, they may be bioaccumulative, carcinogenic, reprotoxic, or
mutagenic. This is true of, for example, polycyclic aromatic hydrocarbons (PAHs), phthalates
and certain metals. These substances should not be released into the environment and thus
waste tyres should not be used for synthetic turf surfaces.
KemI's Recommendations:
Do not select synthetic turf that contains substances of very high concern when laying new
surfaces
Material that contains substances of very high concern should not be used, as specified by the
environmental objectives of the Swedish parliament. This means that granulate formed from
recycled rubber should not be used when laying new surfaces of synthetic turf. The Norwegian
authorities have issued a similar recommendation."
http://www.wellesleyma.gov/pages/WellesleyMA_SpragueResources/Swedish%20Study.doc
In addition to Sweden and Norway, whole countries that have recommended that tires not be
used on turf fields, municipalities like as New York City have has banned tire crumb since 2009
for their schools and parks.

https://www.fdms.gov/fdms/getcontent?objectId=0900006481fa2055&format=xml&showor... 5/3/2016

Page 3 of 3

Similarly in 2009, the L.A. Unified School district has banned tire crumb. The list grows larger
by the week. In early 2015, Montgomery County, Maryland's most populous, banned tire crumb
by a unanimous vote of the council.
Please honor the precautionary principal and recommend a complete ban on the use of tire
crumb on turf fields and playgrounds. See attached for full comments.
Regards,
Jonathan Damm

Attachments
Comments on ASTDR 2016-0002 by Jonathan Damm

https://www.fdms.gov/fdms/getcontent?objectId=0900006481fa2055&format=xml&showor... 5/3/2016

Comments on ASTDR 2016-0002-0003
Federal Research Action Plan on
Recycled Tire Crumbs Used on Playing Fields and Playgrounds
Submitted to Federal Register May 2, 2016
By Jonathan R. Damm
Dear Federal Agencies:
I am a concerned parent with a background in environmental law and a lacrosse player
and coach. Because of my education, I understand and appreciate the dangers inherent
with repeated exposure to toxins. Since I am a coach and player, I have also spent
many hours on tire crumb fields. I have witnessed how children are exposed to the fine
particulate. After reading all the available literature, my wife and I concluded the risks far
outweigh any benefits of using fields with tire crumb. Regardless of your final
conclusions, it is clear that tire crumb is beyond our capacity to thoroughly investigate –
as I will discuss below. So we will never let our three young children play on tire crumb.
A generation of young Americans relies on you for similar protection.
Later this year, when the federal government issue its preliminary statement regarding
the safety of tire crumb on synthetic turf fields, the most important messages to
communicate to concerned parents are: 1) Tire Crumb is a “Moving Target” – tire
manufacturers frequently change tire ingredients. So any formal study conclusion only
speaks to existing fields. Any field installed after a study, or any field not studies, may
contain chemicals that were not examined in past studies – including any federal study.
So for all the millions of dollars of resources the federal government is about to spend
on this study, any conclusions can only speak to actual fields that were studied. A study
can only be backwards looking by its very nature since there can be zero confidence
that manufacturers will not change tire ingredients. This must be clearly communicated.
2) Compound based risk assessment can only be done on chemicals and
compounds that have regulatory risk frameworks. Tire crumb contains numerous
chemicals and compounds with no regulatory risk frameworks. Therefore, any
formal study will necessarily contain significant data gaps. 3) Given that tire crumb
contains multiple chemicals and compounds with no risk frameworks, epidemiological
studies and animal studies are the only available methods of study to overcome this
intrinsic problem. If there are no significant epidemiological studies undertaken or
planned, this must be communicated. If there are no animal studies planned, this
must be communicated.
If the three points of focus above were communicated clearly and prominently, it would
help educated field users to truly understand that sometimes, a problem is beyond our
ability and present capacity to accurately make predictions or draw conclusions
regarding safely. If the federal government was realistic in this endeavor, it would
recognize this from the very start. And given what we know about the multiple
carcinogens, mutagens and reprotoxins in this material, the government should
1

conclude from the start that tire crumb is simply too risky to use in such close proximity
to children. The following links provide examples of chemicals of concern in tire crumb.
http://www.albany.edu/ihe/Synthetic_Turf_Chemicals.php
http://www.ncbi.nlm.nih.gov/m/pubmed/22352997/
http://www.ehhi.org/turf/new_study_jun2015.shtml http://southlakesturf.org/wpcontent/uploads/2015/02/Pg-31.jpg
http://southlakesturf.org/wp-content/uploads/2015/02/Attachment-1-Crumb-RubberChemicals.pdf
Sweden Concluded that Tires should Not be Used
Such a position would not be novel or unprecedented. The Swedish agency tasked with
reviewing tire crumb on synthetic fields recommended that tires should not be used as
material on synthetic turf fields for exactly these reasons. Sweden wisely concluded that
given the complexity and the inherent unknowns regarding tire crumb use on turf fields,
they simply should not be used.
Tyres contain substances of very high concern
Tyres contain several substances that are substances of very high concern.
These substances maypersist in the environment, they may be
bioaccumulative, carcinogenic, reprotoxic, or mutagenic. This is true of, for
example, polycyclic aromatic hydrocarbons (PAHs), phthalates and certain
metals. These substances should not be released into the environment and thus
waste tyres should not be used for synthetic turf surfaces.
KemI’s Recommendations:
Do not select synthetic turf that contains substances of very high concern
when laying new surfaces
Material that contains substances of very high concern should not be used, as
specified by the environmental objectives of the Swedish parliament. This means
that granulate formed from recycled rubber should not be used when laying new
surfaces of synthetic turf. The Norwegian authorities have issued a similar
recommendation.
http://www.wellesleyma.gov/pages/WellesleyMA_SpragueResources/Swedi
sh%20Study.doc
In addition to Sweden and Norway, whole countries that have recommended that tires
not be used on turf fields, municipalities like as New York City have has banned tire
crumb since 2009 for their schools and parks. http://www.nydailynews.com/newyork/city-yields-ground-crumb-rubber-turf-wars-article-1.389543
Similarly in 2009, the L.A. Unified School district has banned tire crumb.
http://usatoday30.usatoday.com/sports/2009-06-10-artificial-turf_N.htm
The list grows larger by the week. In early 2015, Montgomery County, Maryland’s most
populous, banned tire crumb by a unanimous vote of the council.
http://www.mymcmedia.org/councilmember-berliner-applauds-council-turning-the-page2

on-artificial-turf/ Recently, the city of Hartford, CT banned Tire Crumb as well.
http://ctmirror.org/2016/02/12/a-shifting-ground-for-artificial-turf-in-connecticut/
There are many other communities taking similar action. A Google search will provide
you with plenty of evidence. Industry lobbyists and representatives will likely tell you that
these are just reactionary measures because of sensational headlines of anecdotal
news about goalies with cancer. I will discuss the goalies with cancer below. First,
Sweden and Norway took their precautionary measures in 2006, well before the news
about goalies with cancer in 2014. It was enough for them to understand what is in tire
crumb. They didn’t need to conduct a generation long experiment to decide if it is safe.
They erred on the side of caution, which is a reasonable measure given the multiple
chemicals of concern, carcinogens, PAHs, VOCs, phthalates, heavy metals and
endocrine disruptors. All these things are in tire crumb. There is no debate about that.
Over the last ten to twenty years, parents have been increasingly aware that they
should take reasonable steps to protect their kids from having toxins bioaccumlate in
their kids’ bodies. So countries and municipalities that are avoiding tire crumb are not
simply acting because they are scared, they are taking prudent and reasonable
measures to minimize exposure to dangerous toxins. BPA and phthalates are good
examples. These chemicals are not banned by EPA and really not heavily regulated as
far as I understand.
Exposure
But the science is pretty clear at this point that we should protect children from
unnecessary exposure to endocrine disruptors. When developing kids are on a tire
crumb field, they often ingest tire crumb. They either ingest actual particles or they
ingest micro particles that get mixed into their sweat as it runs over their skin and into
their mouth. The attached document from the safe healthy playing fields coalition
illustrates how small particles actually are. The picture below is from the attachment.
But look at how small the dust is. The larger black spot is a highly magnified piece of tire
crumb. The specs are microscopic dust. The picture of the woman illustrates how easily
the dust can be transferred from a field to a sweaty person and into their mouth.

3

They inhale fine tire crumb dust. They inhale VOCs. They absorb chemicals and oils
from tire plasticizers either directly through their skin or in open wounds. It gets in their
noses. It gets in their eyes. There are multiple exposure routes.
Bioavailability
Based on limited study, industry representatives like to assert that the chemicals in tire
crumb are somehow not bioavailable. But there are studies that contradict that. For
example, there is a study from South Korea that concludes that lead in EPDM rubber
particulate is indeed bioavailable. It should not be any different for metals in particulate
and dust like tire crumb. “Conclusions - Results of this study confirm that the
exposure of lead ingestion and risk level increases as the particle size of crumb
rubber gets smaller.” http://www.ncbi.nlm.nih.gov/pmc/articles/PMC3278598/
So it is reasonable for parents to take precautions in their daily lives to protect their
children from toxins. People wash fruit, they off-gas products, they avoid flame
retardants, and they avoid endocrine disruptors and PAHs in their children’s products.
The list goes on. So when municipalities ban tire crumb, they are simply acting in the
same reasonable and cautious way that their populations act every day. Why would
parents want to take reasonable steps to protect their children from harmful
toxins in their daily lives, then turn around and expose their kids to all the same
chemicals of concern and even worse? It does not make sense to take one step
forward and two steps back.
Avoiding tire crumb is not a reactionary measure to sensational news; it is wisdom and
common sense. Using tire crumb where kids play is reckless and out of step with a
growing population of educated American’s approach to toxins around children. It is
truly mind boggling that there are individuals in the federal government that consider
this even remotely as a good idea.
Every day, we learn how toxins bioacumulate in the body. Folks take careful steps to
protect their families. By even pretending that somehow a field full of all the same
chemicals of concern could be tolerable under any circumstance is just plainly behind
the times. The only reason there has not already been a mass revolt is that there has
not been an opportunity to educate the millions of people that need the education. But if
the same people who avoid BPA and phthalates in their childrens’ products actually
learned in detail just how full of toxins their kids’ fields are, they would put it all together.
So please don’t pretend that somehow different rules apply just because kids are
running around an exercising. It is illogical to think that exercising somehow mitigates
the harms and risks. If anything, it makes it worse.

4

Goalies with Cancer – Only 5000 blood Cancers a Year
What about those soccer goalies with cancer? Anything short of a serious statistical
analysis would be too bad. It appears that there are only around 5000 blood cancers a
year under the age of 24. There are now over 100 goalies on Amy Griffin’s list. Most
have blood cancers. Given so few kids with blood cancers in a given year, it seems very
unlikely that one person would be able to put together a list of so many people with two
things in common 1) plays one particular position (goalie), and 2) plays mostly on one
particular kind of field (tire crumb). And there are still not that many tire crumb fields
nationally – around 12,000. So Amy Griffins list should be taken very seriously.

http://www.cancer.gov/research/progress/snapshots/adolescent-young-adult
Carbon Black
Any investigation must also look closely at carbon black. Carbon black makes up about
1/3 of a tire. That means about 1/3 of a tire crumb field is also carbon black. Carbon
black is a known animal carcinogen and a possible human carcinogen. Nanoparticles in
carbon black have been theorized to present asbestos like concerns.
http://www.turfandrec.com/index.php?option=com_content&task=view&id=2986 If this is
not looked at very closely, it would be a monumental oversight. Will the study look
closely at carbon black exposure?
Carbon Nanotubes
“Inhaling carbon nanotubes could be as harmful as breathing in asbestos, and its
use should be regulated lest it lead to the same cancer and breathing problems that
prompted a ban on the use of asbestos as insulation in buildings, according a new study

5

posted online . . . by Nature Nanotechnology.”
http://www.scientificamerican.com/article/carbon-nanotube-danger/
"[Ti]res enhanced with CNT (carbon nanotubes) appear to have improved mechanical
properties, such as tensile strength, tear strength and hardness of the composites, by
almost 600%, 250% and 70% respectively, comparing with those of the pure SBR
composites (styrene‐butadiene rubber)." http://www.iosrjournals.org/iosrjmce/papers/vol11-issue4/Version-1/B011410711.pdf
This concern with carbon nanotubes goes back to the “Moving Target” concern I
discussed in the first page of this document. Tires are waste products that are not
designed for use, ingestion, inhalation and absorption by children. Any slew of
potentially carcinogenic material could make their way into the next generation of tires,
and probably will. This should be unacceptable from the start.
Past studies have been negligent in how they collect data. They underestimate
exposure. The 2008 EPA study set up a particle collector and had kids run by
periodically. The particle collector was surrounded by a small 3 foot fence. That is not
realistic exposure replication. In order to replicate a goalies exposure, you would literally
have to kick the tire crumb fly-out into the collector again and again for hours and hours.
Past studies also use simulated body fluids that do not accurately extract all the
chemicals in tire crumb. The Yale study found 12 carcinogens.
http://www.ehhi.org/turf/findings0815.shtml Industry critics claim that Yale used to harsh
an extraction method. But there is no debate that the carcinogens were present. One
can make an argument that prior extraction methods based on simulated body fluids
were not stringent enough.
I am attaching the written testimony of Dr. Wright from the Mount Sinai Children’s
Environmental Health Center.
https://dl.dropboxusercontent.com/u/101177270/CEHC%20RB%205139%20Testimony
%20Feb%2016%202016.pdf
It says it all. In short:
1. "Given the hazards associated with recycled tire rubber, it is our recommendation that
these products never be used as surfaces where children play."
2. "[W]e found significant gaps in the evidence supporting the safety of recycled rubber
turf products."
3. "Children are uniquely vulnerable to harmful exposures from recycled rubber
surfaces."
4. "In the absence of convincing evidence of safety, we recommend that children not
play on recycled rubber surfaces that contain known carcinogens and neurotoxins and
support a ban on the use of these products."

6

I hope the federal government takes the same reasonable position. Even if you do not,
a large portion of the population will continue to act prudently and will avoid using fields
with tire crumb. You might as well act responsibly and protect those that do not have the
fortune to be as educated on the dangers of bioaccumulated toxic exposure.
Heat - 120 degrees
A few comments on heat - I read that the fields would be tested at two temperatures.
One would be at room temperature or average outdoor temp. The other would be at a
higher temperature to mimic a hot day. I hope you paid attention to the temperatures at
the women’s soccer world cup. The temperatures of the turf were not just hot, they were
astonishingly hot. It was measured at 120 degrees! So please measure it at that
temperature. Anything else would be a sham.
https://www.washingtonpost.com/news/early-lead/wp/2015/06/06/the-artificial-turf-atthe-womens-world-cup-was-reportedly-120-degrees-at-kick-off/
Industry MSDS
The Synthetic Turf Council has a MSDS that makes clear there are certain precautions
that their installer should take. They include washing frequently, wearing a respirator,
and wearing eye protection to name a few (see next page). But importantly, this is the
industries own material. How can they be asserting on the one hand that children are
safe to play on tire crumb and then at the same time, warning their installers to take
very deliberate and thorough measures to protect themselves from tire crumb as they
install it?
It is very puzzling to try to understand how this material is safe for players who get the
same if not more exposure than installers. Kids who roll in tire crumb, eat tire crumb,
drink tire crumb in sweat, inhale tire crumb, absorb tire crumb, and grow up on tire
crumb are getting absolutely no warnings like the installers. It is a terrible injustice and
wildly hypocritical.

7

https://www.dropbox.com/s/yvszy6bgtsis39a/STC%20MSDS.pdf?dl=0

8

Why should kids not receive the same warnings when they get even more exposure
than installers? When parents are educated on this seeming hypocrisy, they see right
through industry assertions that the material is safe. If you conclude that tire crumb is
safe as well, you will have to explain why installers receive special warnings about
wearing respirators and washing.

9

There should be signs on every field that provide the same warnings to parents and
players.

These are just some thoughts that hopefully provide some insight as to why you should
categorically conclude that tire crumb is too risky to use where children play. Please do
the right thing and recommend that there be a moratorium on the use of tire crumb on
synthetic turf fields and playgrounds.
Please consider attachments 1 and 2 as a fully incorporated part of this document and
part of my formal comments as well.
Regards,
Jonathan R. Damm
Reston, VA 20191
[email protected]
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.

26



Total Runoff for 12,000 fields based on number of fields per MSA, accounting for
rainfall in that MSA, and added together for 2016 is: 23,370,639,827 gallons… for
a single year.

The calculations were made to illustrate the scale and scope of this product, and to characterize the
reach of exposures from the field surface into the airway, and into the water pathway.

8. INGREDIENTS IN TIRE CRUMB: Lack Of Uniformity, High Variation, Multiple Toxins
Tire crumb appears to be a composite material, heterogenous with multiple known carcinogens,
pathogens, and mutagens. The material is not uniform, comes from multiple sources and lots, and can
be mixed with plastics and materials of unknown origin. The material can have anticlumping agents,
flame retardant additives, paint, and strengthening or characteristic enhancing additives. Shredding of
tires can cause small pieces of steel or metals to be included in the material from steel belted tires.
Some tire crumb is from newer depositories from recalled tires, some from landfills, and some have
been subjected to a variety of weather and conditions. Leachate and off gassing could be variable, with
the expectation that newly installed/poured material off-gassing is higher than from an older field, but
we expect those rates would vary with the age of the tires from which the tire crumb was made.

9. HETEROGENEOUS, MULTIPLE TOXINS, UNKNOWN ORIGIN: To say that tire crumb infill comes from
multiple sources, is an understatement: dispensaries, landfills in the US, landfills abroad, collection
centers, factory waste from China, factory waste from the US and abroad. Some of the newer marketed
blends included multi colored sport shoe waste, shoe factory waste, and many unidentified synthetic
materials. Just as tire companies may add anything to their “recipe” for a tire, an infill provider may
offer materials that could have anything added into the blend. Tire plugs, tire polishes, tire coatings, and
materials picked up on the roads should be considered. And even if it is known that there are only tires
in the blend, there is a broad variation in the ingredients based on the use of the tire, and the
manufacturer. Those tires may look the same, but from a toxicity standpoint their variation and the
unknowns in the “recipe” create a margin of uncertainty that makes any claim of known safety for
inhalation or ingestion impossible. If a vendor says he or she knows what is in a lot of tire crumb, and
that is known to be safe, then they ignored the materials in the product. Since we never know what is

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in any field for sure, and if we know that they have tire crumb, they cannot be demonstrated safe for
children to inhale, ingest, nor play upon.

10. What Is In Tires? SOME GROUPS WENT LOOKING

Since it was difficult from MSDS or any other source to identify the components in tires or tire crumb,
some groups studied them directly.

11. Environment and Human Health Inc, and Yale University Study
EHHI, Inc. in cooperation with Yale University studied samples of rubber mulch, and new tire crumb with
the intent of characterizing their ingredients.
The summary text of their characterization study is found here:
http://www.ehhi.org/turf/metal_analysis2016.shtml
http://www.ehhi.org/turf/findings0815.shtml

The EHHI/Yale Study list of components found is explained this way:

The shredded rubber tire playground mulch samples tested were provided by the manufacturer and
were purchased in new bags of rubber mulch for use in gardens and playgrounds. The rubber tire infill
for synthetic turf fields was obtained as new infill material from installers of synthetic turf fields. There
were 5 samples of infill from 5 different installers of fields and 9 different samples of rubber mulch
taken from 9 different unopened bags of playground mulch.

RESULTS
There were 96 chemicals found in 14 samples analyzed. Half of those chemicals had no
government testing on them - so we have no idea whether they are safe or harmful to health. Of

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those chemicals found that have had some government testing done on them these are the findings
with their health effects.

TWELVE (12) KNOWN CARCINOGENS
2-Mercaptobenzothiazole/ Carcinogen, toxic to aquatic life
9,10-Dimethylanthracene/ Carcinogen, respiratory irritant and can cause asthma
Bis(2-ethylhexyl) phthalate/ Carcinogen, may cause damage to fetuses
Fluoranthene / Carcinogen, Fluoranthene is one of the US EPA's 16 priority pollutant, A PAH.
Heptadecane/ Carcinogen
2-mercaptobenzothiazole / Carcinogen
Phenol, 4-(1,1,3,3-tetramethylbutyl)/Carcinogen
Phenanthrene/ Carcinogen - A PAH
Phthalimide/ Carcinogen, skin, eye and lung irritan. A Fungicide
Pyrene, 1-methyl- /Carcinogen
Tetratriacontane /Carcinogen, eye and skin irritant. Can cause systemic damage to central nervous
system.
Pyrene/ Carcinogen, toxic to liver and Kidneys, a PAH
Carbon Black/ Carcinogen
Carbon Black makes up to 20% to 30 % of every tire. It is used as a
reinforcing filler. Carbon Black is listed as a carcinogen by the International Agency for Research on
Cancer (IARC).

Carbon Black, as such, was not analyzed by the Yale Study because Carbon Black is made up of a

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number of chemicals – some of which were found in the Yale study.
Carbon Black is not one chemical -- it is made up of many chemicals - often of petroleum products.
Furthermore, carbon black has no fixed composition, even of the many compounds it contains. Carbon
black from different sources will have
differing compositions. In our method, carbon black will register as
a series of substances extracted from it. There is no carbon black
molecule, it is a mixture.

TWENTY (20) KNOWN IRRITANTS

1,4-Benzenediamine, N-(1,3-dimethylbutyl)-N'-phenylIrritant - causes skin and eye irritation, toxic to aquatic life
1,4-Benzenediamine, N-(1-methylethyl)-N'-phenylIrritant - causes skin and eye irritation, toxic to aquatic life
2(3H)-Benzothiazolone
Irritant - causes skin and lung irritantation
2-Dodecen-1-yl(-)succinic anhydride
Irritant - causes eyes, skin and lungs irritation
3,5-di-tert-Butyl-4-hydroxybenzaldehyde
Irritant - causes irritation to eyes, skin and lungs.
Anthracene
Irritant - causes skin, eye and respiratory irritation. Breathing it can irritate the nose, throat and lungs
causing coughing and wheezing.

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Benzenamine, 4-octyl-N-(4-octylphenyl)Irritant - causes eye and skin irritation
Benzenesulfonanilide
Considered hazardous, very little testing has been done on it.
Benzothiazole, 2-(methylthio)Irritant - causes Skin and eye irritation.
Dehydroabietic acid
Toxic to aquatic organisms
Docosane
Irritant - causes Skin irritation
Hexadecanoic acid, butyl ester
Irritant - causes eye, skin and lung irritant. Can cause reproductive effects.
Methyl stearate
Irritant - causes eye, skin and lung irritation.
Octadecane
Irritant - causes kin, eye and respiratory irritation
Octadecanoic acid also known as Stearic acid
Irritant - causes skin, eye and respiratory irritation
Oleic Acid
Irritant - causes skin and eye irritation
Phenol, 2,2'-methylenebis[6-(1,1-dimethylethyl)-4-ethylIrritant - causes skin, eye and respiratory irritation

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Tetradecanoic acid
Toxic to aquatic organisms. Skin and eye irritant.

Anthracene, 2-methyl-

Acute aquatic toxicity, Not much data available - what there is shows it to be an eye, skin and lung
irritant

Anthracene, 9-methylAcute aquatic toxicity, serious eye irritant

13. Carbon Black

Carbon black plays an extraordinary role in tires, and in their toxicity and potential for harm from
exposures. Well known from decades of air pollution studies, urban epidemiological studies, carbon
black causes lung cancer, brain cancer, kidney cancer, heart disease, neurological disorders, and
cognitive degenerative disease.

A known carcinogen (WHO), we have found variations in percentages of the amount of carbon black in
a tire, from 30%-68%. (EHHI/Yale Study; NY STUDY, .pdf, pp19-20.) Carbon black breaks down into many
sized particles, including PM10/PM2.5. That size particle was shown to cause several types of cancer,
including brain cancer, kidney cancer, kidney disease, bladder cancer, and neurological disease and
cognitive impairment disorders. (CITE; Harvard Mexico Studies and Urban Cohort Studies) We know for
sure that carbon black is in tires, in part from simple observation of color.

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14. THE NY STUDY CHARACTERIZES TIRE CRUMB THIS WAY:
“The components of Firestone’s and Dow Chemical Company’s rubber are summarized in technical
specification documents. Although they are only two of many different rubber manufacturers, a
similarity between the two vendors is readily apparent, even between three different types of rubber,
solution-SBR, cold polymerized emulsion SBR, and high cis2-4 polybutadiene rubber. In general, the
following similarities were observed between the two manufacturers for the compounds used to
produce the rubber:

• The polymer used to produce solution-SBR contained approximately 18-40% bound styrene.

• The oil content in the polymer ranged from 27.3-32.5% in solution-SBR and cold polymerized emulsion
SBR. Oils used include aromatic oil, high viscosity naphthenic oil, and treated distillate aromatic extract
oil.

• Besides the polymer used, the other components of the rubber were similar between manufacturers
and the relative proportions (parts by weight) of these other components ranged as follows:

o Carbon black: 50.00 – 68.75
o Zinc oxide: 3.00
o Stearic acid: 1.00 – 2.00
o Sulfur: 1.5 – 1.75
o N-tert-butyl benzothiazole sulfonamide (TBBS): 0.9 – 1.50
o Naphthenic or aromatic oil: 5.00 – 15.0

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The components summarized above are the principal components of the major type of rubber (SBR)
used for the manufacturing of crumb rubber and therefore have the potential to have a significant
presence in crumb rubber. As discussed in subsequent sections of this report, some of these
components have been found to be prevalent in crumb rubber, including zinc (from the zinc oxide),
benzothiazole compounds (from TBBS), and PAHs (possibly from the oils used). These compounds may
be attributed to the SBR used in the manufacturing of crumb rubber.”

15. Phthalates are a regulated toxin, and PEER filings covered some of the toxicity and regulatory
discussion. Please refer to http://www.peer.org/campaigns/public-health/artificial-turf/newsreleases.html

16. ZINC

Coastal Marine Resource Center Study, found fatal levels of zinc in leachate from tire crumb fields. This
amount would cause fatal impacts to aquatic ecosystem within 48 hours. This is a notable amount, and
though was assessed in terms of environmental health, indicates presence.

Menichini and Abate Study: “Zn concentrations (1 to 19 g/kg) and BaP concentrations (0.02 to 11 mg/kg)
in granulates largely exceeded the pertinent standards, up to two orders of magnitude”. “Zinc and BaP
concentrations are high in rubber largely exceeding the Italian soil standards”.

17. METALS: MERCURY, CHROMIUM, ARSENIC

The highest median values were found for Zn (10,229 mg/kg), Al (755 mg/kg), Mg (456 mg/kg), Fe
(305 mg/kg), followed by Pb, Ba, Co, Cu and Sr. The other elements were present at few units of mg/kg.
The highest leaching was observed for Zn (2300 μg/l) and Mg (2500 μg/l), followed by Fe, Sr, Al, Mn and

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}

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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

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*.
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28. Other sources of information on Lead in tire crumb fields:

www.ehhi.org/turf/
www.safehealthyplayingfields.org
www.synturf.org

[FOOTNOTE SYN TURF]Where on the Synturf page on lead you can find:
No. 36] Mayo Clinics tips to protect children from lead in artificial turf. April 2015.
No. 35] Durham, New Hampshire: Lead scare at UNH, s Memorial Field. November 2012.
No. 34] Beware of lead content in exotic color artificial turf fields! September 2012.
No. 33] Odessa, Texas: Eager fans will not be given pieces of the artificial turf field. September 2012.
No. 32] U.S. Federal panel increases child protection against lead. February 2012.
No. 31] UNLV researcher spreads word about the need to test artificial turf fields. December 2010.
No. 30] Environmental Health Sciences study (2010): Deteriorating synthetic turf dust containing lead
may pose a risk to children. October 2010.
No. 29] Concord, Mass.: Town replaces fake grass fields, officials insist nothing is wrong with the lead
levels! July 2012

28. TWELVE (12) CARCINOGENS found and HOW DO THEY INTERACT:
The Yale Study identified the presence of so many carcinogenic materials in a single material that it
raises many more questions about interaction of PAHs with metals, and combination impacts. The

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.

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31. Flame Retardants

Flame retardants can be added to a tire in production, or applied post production in a shipping setting or
possibly as tire crumb. Since flame retardants are known carcinogens with health issues of concern, and
will be on the surface of the waste tire crumb, tire infill providers need to know if they are present, and
purchasers need to know that the material contains flame retardants prior to purchase.

32. Tires and Tire Crumb Additives
Myriad products exist to clean, protect, condition, and color tires. We wonder if they are components
of tire crumb?

33. Road Waste Picked Up By Tires
Tires spend their lives on roadways, of course, and can pick up many materials in their travels. Debris,
hydrocarbons, ….

34 CARINOGENIC, PATHOGENIC, and MUTAGENIC ingredients in tires cannot be removed by
shredding tires into tire crumb and must be assumed to be accessible.

35. Tire crumb and repurposed rubber appear to be the same thing, with interchangeable use… but
are they the same? We would like clarification.

We would like clarification about the distinction between the tire crumb, repurposed crumb rubber,
and crumb rubber. Specifically if using the term “repurposed rubber crumb” implies uniformity of
ingredients? Does that term imply tires are not used? If so, what are the ingredients in repurposed
rubber crumb and how do they differ from tire crumb?

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,

44

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.

45

46

47

43. VERY COMPLEX PICTURE From TOXICOLOGY PERSPECTIVE: Tire crumb material is complex from a
toxicology perspective, largely due to the chemical complexity presented by multiple known toxic
components and variation. It has been described as a “toxic soup” of ingredients for which we have no
consistent data on proportions or levels. Characterization of ingredients’ margin of error is unknown..

Testing must be done at the field levels using accepted sampling plans that have been statistically
shown to be valid. Not fields have been tested in sufficient detail to determine or rule out any
exposures or risks. A look at testing protocols for lead in urban soil sites illustrate the level of
attention required and show the degree that current testing has fallen short of that needed for
decision making for children’s health.
44. CONTACT PATTERNS, FIELD USE and ADJACENT BUILDING CONTAMINATION
Exposure is likely determined by ingredients in surface, activity, and number of children or users on
field. Each school or community field has high use and high contact patterns, such as hosting contact
sports, like football, lacrosse, soccer, and baseball, athletic camps, workshops and practices. In those
sports, children dive into the field materials. As a child runs or skids or slide tackles, a column of
material rises up, as does the dust and particulate that surround the tire crumbs themselves.

Testing for exposure need to list weather conditions including humidity, wind speed, and
precipitation, temperature on field surface and ambient air temperature. Number of children on
field, and activity level of that play needs to be recorded, video would be most interesting.

Children of all ages use the fields for multiple sports, recreation and school events. Artificial turf tire
crumb fields abound in elementary schools and at indoor and outdoor sports centers where children of
all ages and all stages of development play soccer, lacrosse, football, track, cheerleading, band, and use
the field for general recreational school activities. In the fields with which we are familiar, families with
members of all ages use the fields; and the community holds events, picnics, special fairs, and activities.
Some fields are immediately adjacent to a school building.). That there are many uses, and probably
many levels of contact and exposure is an important part of characterizing exposures, but both low dose
exposures AND high contact exposure scenarios and use need to be examined, with appropriate
epidemiological process.

48

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

49

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.

50

The proper characterization of this material needs to account for adsorption characteristics of carbon
black, and other interactions

54. The point is, that it is impossible to locate hotspots for all toxins in every field, and incorrect to
extrapolate the risk for a whole field from a single sample or even multiple samples, since every
sample is unique. So, while hotspots can easily be missed in a field, the unfortunate child that dives
into that particular part of a field has an exposure that can actually be life threatening, but missed in
its entirety in the sampling based risk assessment.

55. In fact, since the tire crumb creates multi sized “dust” particles, and off gases, it is impossible to
prove that even a single field is safe from inhalation or ingestion exposures from tire dust particulate,
off-gassing components, multiple toxins and combinations of toxins, and heat.

56. Importance of the Heat Factor: Source of direct injury and chemical catalyst

HOT HOT HOT HOT EXTREMELY HOT FIELDS
Grass playfields remain close to the temperature of ambient air, and are often much cooler. Asphalt
playgrounds used to have a use limit of 141F and many schools remove children from playgrounds
when temperatures get hot. With tire crumb based turf fields, surface temperatures can soar on even
mild sunny days.

Tire crumb fields “superheat” to levels that are routinely over 150F on a sunny spring day, and in a
recent study conducted on a sunny day Utah, found to be close to boiling point, 190F, according to the
Penn State Field Turf Heat Study. The study found that tire crumb field surfaces are hotter than ambient
air, and increase in heat in a non-linear function with each additional degree Kelvin of heat, hence the
designation “superheating”. To draw an example, on a Labor Day Weekend in DC area, with ambient
temps of 82F, the field surface temperature hit 164F by noon on several fields used in a busy,
tournament for about 1000 children, both boys and girls, ages 8-15. Those levels are known to melt
plastic cleats, require tubs of water on the sidelines to cool down shoes, and create heat-related injury

51

including heat stroke, nausea, heat exhaustion, and dehydration in children and all users. It is not
unusual for children players to vomit, faint, and suffer dehydration from hot conditions on the fields.

57. Marketing and sales for these fields tout their usability in all conditions as a benefit (more practice
and play hours), but in fact, the heat build up on fields makes them very uncomfortable during many
days and conditions. In DC, there are over 100 days of sunshine each year, and most are during the
spring, summer and fall, making the fields uncomfortably hot and possibly dangerously hot for a third of
a year. A calculus should be made on the percentage of safe days to play based on field yield risk, and
heat.

58. Tire crumb fields do not have any protection from heat, and so they are irrigated to be cooled
down, but the effect is temporary.

59. To our knowledge, there has been no well known place for doctors nor parents to report heat
injury, though they are commonplace. (This author specifically remembers a hot, poor air quality day in
August in 2014 in Washington DC when during a single practice, 4 soccer players vomited, another child
was taken to the hospital after passing out, and another sidelined himself against the coach’s wishes,
due to extreme dizziness and nausea.)

60. Reluctance to Report? Yet, it is curiously uncommon for school teachers, coaches and parents to
remove the children from the fields, due to temperature. We cannot explain that in rational terms.

We have also noted another curious effect: as football, soccer and lacrosse increase in popularity and
competition in the US, competition for spots on high performance teams is fierce. There is a perception
from strong sales and marketing of the fields, that the turf fields present a competitive edge for a
school, a club or even a teenager trying to get into college, and are worth the high price paid. As
psychologist Dr. Wendy Miller, explains, “ it is a culture where high performance parents, players and
schools might be willing to overlook these injuries, thinking that to complain would jeopardize their
child’s access to a competitive team. This thinking could easily lead to the silencing of reporting of
injuries.”

52

Heat injury reporting needs to be included in the survey questionnaires, and victims of heat injury and
illnesses need to have a place to report, with impunity.

61. HEAT MAKES THE CHEMICAL DYNAMICS ABOVE A FIELD VERY COMPLEX
In addition to the serious issue of direct injury from hot playfields to young children, or anyone, the
super hot fields present a very challenging chemical situation.
Dr. David Brown, ShD, toxicologist, professor and former Deputy Director of Public Health Practice
Group at ATSDR/ CDC explains that, “the unintended, and largely unstudied chemical consequences of
what comes off such an enormous quantity of high surface area material, in amounts and sequence that
is scientifically accurate is very difficult to predict and model. Since the chemicals in the area above the
field could change instantaneously, the conditions are critically important (number of players,
temperature, time from last rainfall, etc.), as is the sampling methodology. But no one has been able to
come close to modeling the actual yield, we only know the materials by characterization with samples,
and that variation in samples is so broad as to almost be meaningless, since it could be easy to miss
harmful exposures.”

62. Analyzing the field yield on a hot day is very complex, and challenging to even trained toxicologists.
The superheating of the fields makes gases yield at faster rates as temperatures on the tire crumb
surface increases. So, as a day heats up, it is very likely that the yield increases directly with temperature
increase; a hot day creates more gases. Based on well understood scientific laws, we presume that the
gas yield from the field at surface temperature of 50F (a cloudy day in January in DC) would be
considerably less than a field surface temperature of 158F measured last week. If more gases are
escaping the surface, then there are more “opportunities” for particulate to adsorb onto the surface of
the gases, creating very dynamic series of compounds, none of which would be recommended to
inhale.. The changes in the chemical composition over the fields as their temperatures rise is very
difficult to test and model. These changes happen in an instant… as a threshold is reached… and the
exposures can increase sharply. It is a very sophisticated and difficult challenge to model. But what is the
most important is not only that the 24 gases that escape tire crumb (Norway Study) create dangerous
mixtures but those gas/particulate mixtures, (and air) create a vector for deep lung exposures of all the

53

materials in the tire crumb field. So, on poor air quality days, when there are many children on the field
and a lot of stirring up of the material, the fields could present enormous risk.

63. We are concerned about the range of yield levels, but, we are most concerned about the
intermittent risk to children during those hot periods (a hot, poor air quality summer day during
children’s soccer camp week in Washington DC, for example) when the fields are likely yielding more
gas, and therefore particulate has more “carriage” into lungs, respiration rates are higher, skin is
exposed, and perspiration is highest. All these are likely factors in exposure. It is during those days when
exposures are probably highest, and high enough overwhelm a developing immune system.

64. Exposure Study Needs To Focus On Worst Case Conditions
We acknowledge that the level of yield from the fields might vary widely with material variation, and will
also vary with outdoor weather (temperature, wind, humidity and sun) conditions. Taking averages from
fields across the country will be meaningless, and will only help the industry to expand its message of
“found no harm”. An analogy might be to determine the health of a forest taking 4 samples from 40
locations, evenly spaced, but the sampling might easily miss a blazing forest fire. That one day might
destroy living material exponentially, but it could easily be missed. Dangerous exposures can be
unpredictable in this material due to the scope and scale, the toxic character, and the superheating
characteristic.

65. A better approach is to carefully detect high yield days, and look THAT DAY for exposures in a
child’s body during those periods. Since the exposures might attenuate, the work would have to be
done expeditiously. The harmful exposures may or may not be detectable a day or a month later in a
child. Monitor both genders, for patterns that might lead to that awful air quality soccer camp in the
city on a tire crumb field, on days when vomiting and melting shoes are commonplace. A focus on the
impacts from the high end of those yields we believe will present exposures that are clearly, and
unequivocally harmful from both heat injury perspective and toxicity exposure potential. We do not
know for sure if the carcinogenic exposures from low dose regular exposures or from high dose “events”
are more dangerous, but both need to be studied as separate situations, not as an average.

54

66. We urge your team to focus the study resources on primary measurements made in high use
scenarios on hot days, and refrain from the approach used in earlier studies that look at chemical
compositions during winter or rain conditions on limited number of fields.

67. The only reliable way to assess the risk to children from a particular field, or groups of fields, is to
look at their direct exposures, and importantly look at bloodlevels of the known substances.
Cooperation from both high use athletes and those exposed to chronic levels of materials will be
important.

68. The Study Needs To Focus Also On Low Dose Exposure Risks
Trained immunotoxicologists look at the impacts of chronic low dose exposures to metals, PAHs, VOCs
and many other materials in tire crumb. Their input is crucial to understanding risk of exposure in a
developing child.

69. Characterization Mistakes
Studies look convincing, but miss the forest for the trees.
Tire recycling and tire crumb industry reports are quick to point out that when they find harmful
materials in their samples, they are under the known safety limits. There are two interesting fallacies in
that reasoning.

First, since the samples in several studies are few and not uniform, they fail to acknowledge the
statistical significance of finding known regulated toxic material in 2 million pounds of powdered tires…
if one finds the needle, is it luck, or is it because needles are more prevalent than expected?

Proof of presence is meaningful! For example, in the NY Study, PAHs were found, as were metals,
benzothiazoles, and many substances. Their presence indicates a risk.

In a child’s product, since many materials are not known how they affect children, just knowing they are
there is enough to use a precautionary principle and prevent the exposure. Arguing that the materials

55

appear under a limit (especially if that quantity is an average of multiple samples), or there is no
established limit (because it has not been studied), are not as meaningful as the proof of their presence.

Second, though the conclusions of the industry reports may be of no harm found/safety, a close look at
the data itself on PAHs, lead, cobalt, chromium, etc. is useful, since a) it proves presence, and b) at
levels that suggest risk for chronic exposure. Chronic exposure risk is the subject of a great deal of new
cancer research, and we care about all the materials, including those which are potentially toxic.

70. ARGUMENT FOR MORATORIUM BASED ON KNOWN CHARACTERIZATION FOR TIRE CRUMB
Because of the:

a. known loss of 1-30 tons of material from the fields during the 8-10 year “life of the field”
into air and water
b. ingredients list: over 50% of its components are known carcinogens and pathogens, [cite
Yale Study]
c. massive scope and scale of this product, (the amount of material and surface area of
these fields is enormous; scale/millions of pounds in each installation),
d. inability to control the levels of toxic exposure to children, or even properly characterize
them due to immense variation and chemical complexity of what happens on a hot day
over a field, and around children. We cannot suggest mitigation strategies for the
danger, because the material is inconsistent,
e. Even if we did know for sure what was in each field, and suggest mitigation techniques
and protections…. All the tire company has to do is change their recipe, or many recipes,
as they do continually, and the study is worthless. Children are still being exposed to
whatever is in the tire, the lot or that particular field..

71. Moving Target Analogy

56

Even if the study were completely successful, and the tire crumb material categorized properly, the
trouble is, tire manufacturers could change the “recipe” for tires… and in fact they do this regularly…
and the study results will be useless, or at best, diminish in usefulness.

Any attempt to study tire crumb safety on turf fields is analogous to trying to hit a moving target. Tire
crumb is a waste product. Tires are not designed or intended to be used as infill for turf fields.

Ingestion, inhalation and absorption of fine particulate by children is not a consideration of tire
manufacturers as they choose chemicals and compounds for their tires. Nor are they bound to maintain
any safety considerations for such use by children.

So any study of present day tire crumb is a futile endeavor, because such study tells us nothing about a
field that gets installed immediately after the study. Tire manufacturers often change the chemical
composition of tires and will likely do so again.

Even if a field passed safely concerns in a present day study, a new field could easily fail a hypothetical
study conducted the day after the present study. So unless every field was tested using the exact same
methodology after every installation, there is absolutely no way to assure the user that their new field is
safe. Those new fields could easily have an entirely different chemical composition simply because tire
manufacturers changed their tire ingredients.

So the present Federal Study is only a backwards looking study, not forward looking. Any conclusion
must be transparent and clear on that issue - upfront and center. Otherwise the public is being misled
into a false sense of security.

57

72. Sampling: Not Appropriate For Tire Crumb
The core pediatric toxicology problem in industry based safety studies, is that there appears to be an
assumption that tire crumb is a uniform material, and behaves uniformly. It does not. There also
appears to be an assumption that sampling will be an accurate method for studying tire crumb risk to
children, and it is not. Sampling will not be accurate to assess a nonuniform, heterogeneous material
with multiple known toxic ingredients, high direct contact (dermal, hand to mouth, breathing zone)
for pediatric use. Sampling cannot produce a single sample that is representative of the whole field, or
even a part of the field, other than the sample itself.

73. Methodology needs to study PERFECT STORM exposure conditions, and be able to calculate
exposures during those relatively dangerous days.

Nor can sampling in the way it is proposed (samples from 40 fields across the US), illustrate impacts
from a perfect storm of exposure conditions on a particular field, say, during an intense soccer camp in
in summer in Washington, DC with high ambient and field surface temperatures (ie 160F), bad air
quality, no wind, when working athletes are breathing in particulate with high VOC, PAH,
benzothiazoles, and carbon black… and many more compounds, on a particularly high yield day.
Averages cannot be relied upon in sampling for this type of product, since they will further obscure the
risk from exposures to hot spots of high risk material that are on fields. Averaging the results from a
national distribution in various weather conditions simply obscures the acute risks further; it is useless
for risk analysis. In layman’s terms, it is like studying a forest using “x” number samples, but missing the
forest fire that is blazing away at a nearby area of the park. For a child, it means that she plays on a field
that was called “SAFE TO PLAY”, after sampling, but in fact she might easily have been covered with
multiple materials known to cause cancer, and in fact, that might be a regular event. The uncertainty of
exposure frequency makes the risk higher, not less.

74. The core of the methodology used in the 50 studies asserted by the tire recycling industry were
based on simple characterization of a single sample, but not on realistic, combined, nor worst case
(the most important) use scenarios.

58

75. Multiple carcinogen and multiple pathogen combined effects need to be measured. Single
material measurements could be only a fraction of the exposures, since the material exposures are likely
to be from combinations of materials.

76. BIOMONITORING FRONT AND CENTER

Because sampling presents inconclusive results, a methodology that relies on biomontioring will be
more meaningful. We suggest that more sophisticated approach be considered. Personal sampling
monitors attached to children, dermal, urine, breathing analyses, and particularly, blood and tissue
samples from frequent users, players on “Perfect Storm Days” and those expected to have chronic low
dose exposures. We understand that biomonitoring raises more issues, but absent a good model,
empirical data is the most reliable way to accumulate actual evidence of exposures and to be able to
establish a reliable causal link to the cancers and diseases we predict from exposures.

77. IMMUNOTOXICOLOGY SUPPORT: RECRUIT THE BEST PEDIATRIC IMMUNOTOXICOLOGISTS AND
RESEARCHERS. Some researchers and epidemiological professionals are already on the trail of better
ways to identify actual exposures, and can create biomarker groups as indicators of presence of illness
or exposures. These researchers have background in immunological toxicology, and can track subtle
changes in an immune system that might be precursors to serious disease, like cancer, kidney disease,
brain changes, and lung disease. It is possible to create biomarker group to prove tire crumb exposures
in users and we believe that the preliminary proof of concept step could be accomplished in less than 6
months with cooperative athletes, and study volunteers, and modest budget. While we will not list them
here, for protection of their privacy and frankly, for fear of industry retribution, we will nonetheless let
you know that we have found multiple professionals who are capable and willing to work on this task,
provided a protective forum and IRB standards are in place.

78. Immunotoxicology support: look carefully at the ages those immune system markers in all
children who are using these fields, understanding that some metabolic types, and ages may be more

59

vulnerable than others. In fact, there are early indications that certain age groups, such as
prepubescent females (age 8-11), may be more vulnerable to exposures to benzothiazoles, plastics,
phthalates, and endocrine disruptors in general, and therefore might be at higher risk to contract cancer
or disease from low dose particulate exposures from tirecrumb, and the plastic “grass” carpet
particulate. We need to establish the datum from players to study this. We still do not know, but some
indications exist. For that reason, we respectfully request that the study team include toxicologists and
epidemiologists that are trained to keep these concepts front and center.

79. LOW DOSE EXPOSURE CONCEPTS and CONCERNS
Based on what we know now about low dose exposures to VOCs, PAHs, benzothaizoles, styrenes,
carbon black, plastics, plasticizers, and metals, even at low, sub acute exposures, the fields could be very
dangerous. That possibility was not considered in the CPSC study, EPA study, nor in mulitiple industry
studies. These need to be assessed:



Chronic exposure to metals, plastics and plasticizers



Chronic exposure to carbon black mimics air pollution exposures



Immune system reactions



Endocrine disruption exposures from plasticizers and phthalates,



Exposures from multiple low doses and chronic exposures

80. The study should calculate yield of material that leaves the fields, and how it leaves the fields.
How much in the air , water pathways, and with users (in shoes, cars, etc.) Interviews with schools
and vendors need to establish the replacement quantities of these fields, and how often new material
is put into place, since it would affect exposures, and give an indication of gross yields. We estimate
that the fields lose from 1-30 tons (estimated) of material, so exposures and impacts need to be
measured in adjacent buildings, soils, and stormwater systems. With 12,000 existing facilities, this
may need to be the subject of additional studies conducted to also assess if the fields shall be
regulated as point source contamination under Clean Water Act and Clean Air Act. It is a very
important metric, and a perfect opportunity to include it, with little incremental cost, in your study.

60

81. INTEGRITY STANDARDS. To track the history of the emergence of this product is to track effective
lobbying for regulation changes that favored the tire industry, and the tire recycling industry. This
industry took advantage of an enormous quantity of recalled and used tire stockpiles, and heavily sold
and marketed the materials to schools, and sports centers where millions of children play. Central to the
steps that catapulted this industry forward was the removal of the designation of artificial turf fields as
children’s products, based on the rationale that adults played on them, too. Yet the fields continue to be
sold to elementary schools and to sports centers brimming with elementary, middle and high school
players. The sales oriented industry was willing to submit children, schools and communities to the
materials in tires in enormous amounts, and call them safe. As this claim is deeply questioned now, we
also urge you to NOT allow the sampling or data collection to be conducted by an interested party,
including schools, sports centers, athletic group personnel or administrators, field installers or
laboratories or consultants hired by those groups, and establish peer reviewed standards for testing.

82. Any group or individual who does participate in the study, including regulatory staff, needs to sign
an affidavit certifying that she or he, and her/his group has not received compensation or benefits in
any form, including but not limited to sales commissions, direct payment, compensation, bonuses,
grass to artificial turf grant, field financing, water savings rebates (State of California and possibly
others), or physical benefits including but not limited to uniforms, facility enhancements (restrooms,
concession stands, parking lots, storage facilities, etc.), stadium components, or field equipment of
any sort, from the field installers or tire crumb field industry and its assigns, and has no financial
conflict of interest. The document should be filed with an appropriate agency and made public.

83. We ask for full transparency on all parts of the study process for parents, interested parties, and
schools.
OUR REQUESTS TO ASTDR/CDC/CPSC/EPA
Request
1. Regulate tire crumb and rubber mulch as children’s product

61

Background
PEER filed formal request;
12,000 fields x 30,000 tires is the
amount of existing material in
children’s use; see table A for
details on volumes and surface area
sizes, children/schools. Known
carcinogenic material and known

contact.
2. Remove “safe to play, safe to install” or any other references that imply safety from all
EPA, CPSC and CDC websites and public information sources
3. Place all PEER artificial turf filings in Federal Record

PEER Formal Request; agencies
must remove all endorsements of
safety.
http://www.peer.org/campaigns/p
ublic-health/artificial-turf/newsreleases.html

4. Issue a directive to public health agencies to disseminate warnings regarding unknown
risks from lead exposure from AT fields, as well as exposures to carbon black, known
carcinogens, PAH, VOCs into air and water pathways; direct hospital systems and medical
systems to screen for tire crumb field use, and report results
5. Use only independent lab or consultants unassociated with tirecrumb industry, adhering
to high ethics guidelines; transparent process for review; affidavit of no conflict of interest
6. Commission a primary study, conducted by independent, peer reviewed group such as
CDC to examine existing cancers AND illness in tire crumb field users and maintenance
workers of tire crumb fields
7. Mandate Cal Recycle Study corrections to methodology; mandate methodology peer
review; and mandate to impose Prop 65 rule based on OEHHA’s own findings on
carcinogenic exposure
8. Convene a conference for presentation of risks and concerns from parent groups, cancer
survivors to Federal Research Team
9. Convene series of webinars and open comment opportunities
10. Allow public health and environmental advocacy groups in Federal Research Team
with complete transparency
11. Establish a collection point for recording experience of victims and those who may
have suffered injury from use of the fields, including heat injury, concussion or head
trauma, cognitive disorder, illness, and cancer for study and documentation; victim
hotline; for both child and adult contact with fields
12. Funding to identify potential biomarkers of exposure; conclusive marker study in users
13. Conduct blood monitoring and studies on existing cancer survivors.
14. Conduct cancer cluster study on soccer player cluster, and identify additional clusters
such as maintenance workers and installers
15. Provide full transparency with all interested parties
16. Conduct full epidemiological study of tire crumb on playfields existing and predictive
17. Study forms and questionnaires should include data collection on what is released
from fields into air, adjacent areas, water pathways, and quantified. Replacement
quantities for tire crumb fields should be quantified and examined as a metric that
indicates yield.
18. Based on release/yield figures, and other inputs, tire crumb fields should be evaluated
for compliance with Clean Water Act and Clean Air Act, and regulated accordingly.
19. We request that OEHHA study methodology be peer reviewed by your agencies
before it begins, taking into account the comments received in this proceeding.
20. OEHHA Study Process and Methodology Concerns: How will those be considered?
21. Consider explicit protection from retribution steps be put in place to protect
researchers, players, and concerned parents from retribution

62

For parents, schools, athletic groups,
and communities; conduct parent
outreach webinars

Needs participation from
CDC/CPSC/EPA staff so parents
and public can have direct contact

Page 1 of 1

PUBLIC SUBMISSION

As of: 5/3/16 6:48 PM
Received: May 02, 2016
Status: Posted
Posted: May 03, 2016
Tracking No. 1k0-8per-rnvy
Comments Due: May 02, 2016
Submission Type: Web

Docket: ATSDR-2016-0002
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill 0923-16PJ
Comment On: ATSDR-2016-0002-0003
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill ATSDR-2016-0002
Document: ATSDR-2016-0002-0085
Collections Related to Synthetic Turf Fields with Crumb Rubber Infill 0923-16PJ Comment on
FR Doc # 2016-03305

Submitter Information
Name: Tracy Stewart
Address: 02053
Email: [email protected]

General Comment
Synthetic Turf Fields with Crumb Rubber Infill ATSDR-2016-0002
Submitted by: Tracy Stewart
May 2, 2016
Please accept the following attached letter of inquiry and concern along with supporting
documents as noted.
NOTE: I AM HAVING DIFFICULTY UPLOADING MY DOCUMENT TITLED "Heat" and
"heat 2" and require assistance.

Attachments
COVER LETTER_STEWART_Synthetic Turf Fields with Crumb Rubber Infill ATSDR
ATSDR-2016-0002_STEWART_Medway Athletic Fields Follow-Up
ATSDR-2016-0002_STEWART_Medway Turf Submittal 6-30-14-2

https://www.fdms.gov/fdms/getcontent?objectId=0900006481fa207f&format=xml&showor... 5/3/2016

Synthetic Turf Fields with Crumb Rubber Infill
ATSDR-2016-0002
Submitted by: Tracy Stewart
May 2, 2016
Please accept the following letter of inquiry and concern along with supporting documents as
noted.
Background: I am a mother to a 10 yr old child who participates in sports throughout the year
including soccer. In the town of Medway Massachusetts where we reside there are currently 3
synthetic turf fields constructed with the use of tire-crumb rubber infill. (voted in May 2014 and
opened in April 2015) These fields are located on the grounds of our public High School and are
used during the school day by the physical education classes and various outdoor groups.
During the off hours when school is not in session, sports groups both independent and schoolorganized use the fields.
This spring my husband and I chose to defer our daughter’s soccer practices which were held on
the synthetic turf fields.
I have been an active and vocal resident regarding the concerns of tire-derived materials as
outlined below.
While I oppose the use of any tire-derived material in spaces where athletes or children play;

many “studies” and resources offer no definitive information. It is the desire of parents to
obtain definitive answers through the launch of this investigation known as Synthetic Turf
Fields with Crumb Rubber Infill ATSDR-2016-0002.
Concerns that need to be proven:
• HEAT: The dangers of heat were documented in Medway MA in June of 2015 as found in
attachment ATSDR-2016-0002_HEAT_STEWART

The Thermal Physics of Artificial Turf By Tom Sciacca found in: ATSDR-20160002_HEAT_STEWART2

• OFF-GASSING, see concerns addressed in attachment regarding off-gassing visible in
sunny conditions.

Regulatory issues need to be addressed and action taken:
• Use as a Children’s product: It is commonly known that Children as young as age 4 are
playing youth sports both indoors and outdoors on synthetic turf fields and playgrounds
made with tire-derived crumb rubber and rubber mulch

HEALTH:
Asthma: ?
Inhalation: ?
Cumulative exposure: ?

I strongly believe that the industry has dominated the conversation for many years through paid
consultants and hefty marketing budgets. Our government needs to listen to the parents and
athletes while also gaining first-hand experience from our perspective. The health risk associated
with tire-derived waste products used on sports field and playgrounds is extremely suspect. I
hope the agencies with consider the exposures and causes that may be associated with various
disease and illness from lung irritation through the more serious exposures leading to the
possibility of cancer.

Thank you for your consideration,
Tracy Stewart

Board of Select men
Z!ennis 7' Crowley, Chair
:Jolm :71 Joreslo, Vice-CA air
!J&cf,ad:71 7J '-9nnocenzo, Clerk
.91enn ZJ. 7rindad e

Medwa y Town Hall
155 Village Street
Medway, MA 02053
Phone (508) 533-3264
Fax (508) 321-4988

2J(aryjane WN!e

TOW N OF MED WAY
COMM ONWE ALTH OF MASS ACHU SETTS

Novem ber 3, 2014
Dear Residents:
During the last few weeks , the Board of Selectmen have received conce
rns from a
group of reside nts regard ing the safety of the mater ials being used as
infill at the
athlet ic compl ex at Medw ay High School. Specifically, these conce rns
have arisen
again follow ing a press story on NBC Nightl y News earlie r in Octob er.
That story,
however, broug ht forwa rd conjec ture and specu lation rather than scient
ific eviden ce
that a real hazard or risk is prese nt in these fields. With little in the way
of new
inform ation, the story raised fears that were broug ht forth at the outse
t of our fields
progra m, fears that were appro priate ly addressed and answe red as recent
ly as this
spring . Now, with our projec t nearin g compl etion, we again find ourse
lves as a
comm unity pausin g to be certai n that the path we have chose n for this
projec t is
indeed safe for all. As your Board of Selectmen, that is our respo nsibili
ty and you can
be certain that we take that respo nsibili ty very seriou sly.
Since the outse t of this projec t, one point is very clear: everyo ne, from
volunt eer
comm ittee members, to our electe d and appoin ted Board s, to staff alike,
is in fact
workin g toward a most comm on goal. That goal is the creati on of a new
modern field
system that is not only multi- dimen sional but most impor tantly, one
that is safe for all
those who may use it. This latter point is very clear upon a review of
the projec t
specif ication s, as well as a review of the certifi cation s and attest ations
on our
produ cts used in and on the fields. In fact, our specif ication s direct ly
require that the
turf mater ials used are lead free, and that the infill substa nce is made
with materials
that meet or exceed safety standa rds. Further, the Town has also receiv
ed a holdharml ess statem ent for any claims "relate d to hazar dous mater ials (e.g.
lead, zinc) or
other enviro nmen tal impac ts." These are signifi cant safety and legal
protective
measures that have been built into this projec t right from the beginn
ing, measures
that would not be possib le if our produ ct was anyth ing but safe. And,
since the NBC
story aired, our volunt eers and staff have again sough t to confir m this
data with our
design profes sional s and the agent s representing the manu factur es
of our produ cts.
To that end, this Board has again received assura nces that the produ
cts designed and
specif ied for the Town of Medw ay will result in a safe playin g surfac e.

FIELDS PROJECT SAFETY LEITER - NOVEMBER 3, 2014(PA GE #2)

As noted from design throug h project constru ction, the Town has placed deman
ds
upon the design firm, Gale Associ ates, to produc e docum entatio n to verify that
this
produc t's history is well known from a safety and use perspective. To date, the
inform ation received has been quite positive. In fact, as presented by Gale,
"it should be noted that crumb rubber from recycled tires has been
incorpo rated into recrea tional surface s since the early 1970's where it can be found
in
playgro und and runnin g surface s. Such use has been a recycli ng alterna tive
encour aged by the United States Environmental Protec tion Agenc y (USEPA).
As a
direct result, crumb rubber has been a highly tested and researched material.
While
there are alternative infill produc ts available (EPDM, TPE, Cork, Coconut), they
remain
relatively untested in terms of their performance, long term stabilit y, health, safety
and
environ mental risks."
Again, please be assure d that your Board of Selectmen recognizes the concer
ns that
some have raised relative to the NBC report. However, the sugges ted options
of
switch ing infill materia ls or simply halting the projec t may pose even greate r health,
environ mental and financi al risks to our Comm unity, risks that are at best
unnece ssary and at worst irrespo nsible based upon the conjec ture and innuen
do that
the aired story was based upon. Rather at this time, it is clear that the Town has
indeed taken the approp riate steps to ensure safety for all, and will continu e to
do so
as we move toward final comple tion of the fields comple x. That said, please be
reminded, as stated at the Octobe r 21 Board of Selectmen meeting, if any factual
and
scienti fic data is presen ted to the Town from State or Federal author ities that
contra dicts our curren t unders tanding , then we will respon d to that accord ingly
as
well.
What sets Medway apart from others is the commi tment, the cooperation, and
the
caring of her residen ts. Those qualitie s are again most eviden t here, and those
qualitie s will ensure that we as a Comm unity and in particu lar this Board will make
the
best decisio n today and in the future regard ing the safety of our fields and all
public
places.
Thank you!
Very truly yours,
Your Medway Board of Selectm en
Dennis P. Crowley, Chair
John A. Foresto, Vice-C hair
Richard A. D'lnnoc enzo, Clerk
Glenn D. Trindade
Maryjane White

Gale Associates, Inc.

,.._,,",'>"~"'"'*''"'-"'<1~"'"""="'"m'~~""~'"<"·""'~"'"'"'~~--~"""'~~-=""

'-=~=~·•=••="'"""-"-'

Meets Criteria for:

Certification Details

Chemical Emissions
Heavy Metals
Lead

Certificate Number: 902709
Status: Certified
Period: 5/20 I I - 5/20 I 5
Restrictions: NONE

'""'""""""'~"'""""''"""""==-"""~"""'"""'"~"'"""""''"'"""

~"""~.~~-~=~-~""~~

·-""~"""~'"""""""'"""""""""'"'''""'"""''"'~""""'''"''""'"'"'"'""-"""'-"'""''""~=r""""~~=''"""''~~~"

Reference Standard: GGPS.006 GREENGUAAD Standard for Synthetic Turf Systems and Components
Product Type: Component- infill

Specified IVOCs must produce an air concentration level no greater than 11100 the Thre$hold UmitValue (TLV) industrial workplace standard and no greater
than 112 the CA Chronic
Reference Ex!XJsure level (CREL) following usage definition in GGPS.006 GR.EENGUARD Standard for Synthetic Turf Systems and Components.
Total lead content meets the requirements of 90ppm in surface coatings (per Consumer Product Safety Improvement Act (CPSIA) of 2008).

Heavy metal limits are based on ASTM f963..()8 and the European Standard "Safety of toys," EN 71: Part 3: 199-4, Amendments -AC:. 2000 /AC: 2002.

GREENGUARD Certification affirms that products meet the criteria of the referenced standard and the requirements of the specific certification program.
Certification testing is conduaed according to a consistent. defined protocol.

-

"~,~~"""'-~""'~-=-·-==~~

,,.,

"""""""'""'"-·~~~-_,

,_ _ _.
GGPC.006/I.

\Y'.\.\\

.SyntheticTurfCoundl.\)1 g

Syn the tic Turr··
CO UNC IL

Gui deli nes for
Cru mb Rub ber Infill Use d
in Syn thet ic Tur f Fiel ds

·,v\·.·\\

.SyntheticTurfCouncil in~

Synthetic urr··
COU NCIL

Guidelines for Crumb Rubber Infill Used in Synthetic
Turf Fields

Printed October 2010
Revised October 23,2014

Copyright© 2010 by the Synthetic Turf Council
400 Galleria Parkway, Suite 1500
Atlanta, GA 30339

No part of this document may be reproduced or transmitted in any form or by any means,
electronic or mechanical, including photocopy, recording or any information storage or
retrieval system now known or to be invented, without permission in writing from the
Synthetic Turf Council, except by a reviewer who wishes to quote brief passages in a review written for inclusion in a magazine, newspaper or broadcast. The Synthetic Turf
Council is a non-profit, educational organization and possesses all rights pertaining to this
publication.

\\'\\'\\ SyntheticTurfCouncil (JIg

Synthetic urf'"
COU NCIL

Table of Contents
•

Purpose and Objectives ........................................................................................ .l

•

General Characteristics .........................................................................................2

•

Processing Standards ............................................................................................ 3

•

Certification Compliance.......................................................................................3

•

Packaging and Pallets............................................................................................4

•

Field Quality Testing and Sampling ......................................................................S

•

Standard Format MSD$ .........................................................................................7

•

About the Synthetic Turf Council ..........................................................................l l

\\ \\W

SyntheticTurfCouncil Top: 1 x 4's (measuring%" thick x 3.5" wide); gaps< 3"
=> Structural: 2 x 4's (measuring 1.5" x 3.5"), minimum of 3
=> Bottom: 1 x 4's (measuring%" thick x 3.5" wide), minimum of 3

Field Quality Testing and Sampling
Equipment:
•

Sampling stick

•

Sample splitter

•

Sample tray (width= 12", length= 12", Depth= 3")

•

High precision scale (0.01 gram)

•

Tweezers

Sampling:
•

Randomly select 3 bags (super sacks) per load ofinfill material.

•

Record the bag information such as bag number, lot number, date shipped, bill of lad·
ing number, etc.

•

Place the sampling stick into the bag vertically 3 times in 3 different locations and collect 3 samples.

•

Place the 3 samples into a plastic bag.

•

Repeat above steps until at least 3000 grams of crumb rubber are obtained.

•

Shake the collected sample well.

STC© October 2010, rev. 10/23/2014

5

c:

\\"\\'\' .SyntheticTurfCouncil.l :!,

Cownponent

EENGUARD

Synthetic Turf Certified

Liberty Tire
Turf Infill-Lockport, NY
Meets Criteria for:
Chemical Emissions
Heavy Metals
Lead

Certification Details
Certificate Number: 902708
Status: Certified
Period: S/20 I I - S/20 I S
Restrictions: NONE

Reference Standard: GGPS.006 GREENGUARD Standard for Synthetic Turf Systems and Components
Product Type: Component- in1ill

Specified IVOCs must produce an air concentration level no greater than 1/100 the Threshold Limit Value (TLV) industrial workplace standard and no greater than 112 theCA Chronic

Reference Exposure Level (CREL) following usage definition in GGPS.006 GREENGUARO Standard for Synthetic Turf Systems and Components.
Total lead content meets the requirements of 90ppm in surface coatings {per Consumer Product Safety Improvement Act (CPSIA) of 2008).
Heavy metal limits are based on ASTM F963-08 and the European Standard "Safety of toys," EN 71: Part 3: 1994, Amendments -AC: 2000 /AC: 2002.

GREENGUARD Certification affirms that products meet the criteria of the referenced standard and the requirements of the specific certification program.
Certification testing is conducted according to a consistent. defined protocol.

GGPC.006~\

®

Air Quality Sciences
January 15, 2013

Liberty Tire Recycling, LLC
Mr. David Forrester
14 North Pine Circle
Belleair, FL 33756
Subject:

AQS Project 90270, Profile Study Test Results

Dear David:
Thank you for choosing Air Quality Sciences, Inc. (AQS), an ISO 17025 accredited testing laboratory, for
your analytical needs. Attached to this letter are profile study test results, including predicted room
concentrations.
Predicted Levels Compared to

GREENGUARD IAQ Criteria

Sample Description

TVOC

Formaldehyde

Total Aldehydes

./

./

./

10+20 BM Rubber Crumb, Brantford, ON
,; ·meets erlter!a; / ~ ·meets within

2'6."1~: X~

over by more than 25% of criteria

Predicted Levels Compared to

GREENGUARD Children & Schools Criteria

Sample Description

10+20 BM Rubber Crumb, Branlford, ON
"' ·meets cntena:

meet'£ wtthm 25%:

y

X~

TVOC

Formaldehyde

Total
Aldehydes

CRELITLV

./

./

v'

---

Issues

over by more than 25% of criter1a

AQS appreciates your business. Soon you will be contacted by your GREENGUARD Program Account
Manager, John Testa (678) 444-4082.
Please keep in mind that all information obtained as part of the profile study testing is confidential as per
the signed Testing Agreement. For more technical information about the GREENGUARD program, please
visit, http://greenguard.org/en/technicaiCenter.aspx.
Sincerely,

~;11,j~
Allyson M. McFry
Chemistry Laboratory Director
Attachment:

AQS Report No. 90270-86

2211 Newmarket Parkway
Atlanta, GA 30067
770-933-0638 • Fax 77Q-933-0641

@

CONFIDENTIAL

Air Quality Sciences

Test data and interpretation applicable to
GREENGUARD Certification Program only

SYNTHETIC TURF PROFILE STUDY TEST REPORT
PRELIMINARY ASSESSMENT FOR GREENGUARD CERTIFICATION
Profile study data provides a preliminary estimate of the product's potential to qualify for GREENGUARD Certification

PREPARED FOR: LIBERTY TIRE RECYCLING, LLC
PRODUCT 90270-P0860AA; 1 0+20 BM RUBBER CRUMB, BRANTFORD, ON
ANALYTE

GREENGUARD
MAXIMUM
ALLOWABLE
LIMIT

24HR
EMISSION FACTOR
1Jglm2 •hr

168 HR
ESTIMATED
CONCENTRATION

TVOC

o.Smglnr

1,440

O.D15 mg/m•

Formaldehyde

0.0135ppm
11100TLV&

12.0

< 0.001 ppm

Individual VOCs

Yes (See Tables 1 through 3)

~CREL

BQl denotes below quantifiable level of 0.041Jg based on a standard 18 L a•r coUection volume for TVOC and 1nd1VIdual VOCs and
0.1 pg based on a standard 45 L air collection volume for formaldehyde and total aldehydes.
The predicted concentrations are based on a standard soccer field turf area usage (1 ,505 m2) in a stadium with ASHRAE 62.1-2010
ventilation conditions (94,423 m! in volume and 0.73 ACH) and assumed decay parameters (kT = 0.005; kF = 0.005; ~ = 0.005).
Analyses based on EPA Compendium Method T0·17 and ASTM D 6196 for VOCs by thermal desorption followed by gas
chromatography/mass spectrometry (TDIGC/MS), and EPA Method T0-11A and ASTM D 5197 for selected aldehydes by high
performance liquid chromatography (HPLC).

Heavy Metals

Arsenic
{AS)

Barium
fBal

GREENGUARD
MAXIMUM
ALLOWABLE
LIMIT (mg'lcg)

25

1,000

75

60

60

90

60

500

MEASURED
VALUE

< 2.5

< 100

<7.5

<6.0

<6.0

<9.0

<6.0

<50

Cadmium Fhromium Mercury
{Cdl
{Hill
fCrl

Lead
{Pb)

Antimony Selenium
{Se)
fSbl

(EN71·3. 1994 and Amendments ·A 1.2000/Ac.2002)
Test Method: Soluble heavy metals content analysis was determined by Inductively Coupled Plasma Spectrometry.

CPSIA Lead Content

GREENGUARD
MAXIMUM
ALLOWABLE
LIMIT

MEASURED
VALUE

(mglkg)

PRODUCT
COMPLIANCE

38.0

Yes

(mglkg)

RESULTS

< 90

Total Lead Content in Substrate. Consumer Product Safety Improvement Act (CPSIA) of 2008 reduced to EN requirements.
Per ASTM F963-08, the CPSIA and the European Standard QSafety of toys EN 71: Part 3: 1994
Consumer Product Safety Improvement Act (CPSIA) of 2008
H.

Metal testing completed by a CPSC approved laboratory.
Volatile organic compound (VOC), including aldehyde, testing was completed by AQS, Inc.
This test data is provided for general infonnational purposes only. The data indicate the level of emissions from the designated
product and how they compare to the emission criteria of the GREENGUARD lAO standards. This data does not imply that the
product has been qualified to meet the requirements of the GREENGUARD Certification Program nor does it imply that the product
is or is not certified by the GREENGUARD Certification Program.

2211 Newmarket Parkway
Atlanta, GA 30067
770·933·0638 • Fax 770..933·0641

Page 1 of 7

Released by Air Quality Sciences, Inc.
Date Prepared:
January 15, 2013
AQS Project#:
90270
AQS Report #:
90270·86
©2013 Air Quality Sciences, Inc.

An ISO 17025 Accredited IAQ Firm
This test is accredited and meets the requirements of ISO!IEC 17025 as verified by ANSI·ASQ National Accreditation Board/ACLASS.
Refer to certificate and scope of accreditation AT~1297

CONFIDENTIAL
Test data and interpretation applicable to
GREENGUARD Certification Program only

EMISSIONS TESTING PARAMETERS

Customer:

Liberty Tire Recycling, LLC

AQS Sample Identification:

AQS 90270-P0860AA

Product Description:

SYNTHETIC TURF; 10+20 BM Rubber Crumb, Brantford, ON
(one-sided area= 0.0361 m•)

Product Loading:

0.42

Test Conditions:

1.0 ± 0.05 ACH
50%RH±5% RH
23"C ± 1"C

Test Period:

12/05/12-12/06/12

Test Description:

The product was received by AQS on 12/03/12 as packaged
and shipped by the customer. The package was visually
inspected and stored in a controlled environment
immediately following sample check-in. Just prior to loading,
the product was unpackaged, prepared for the required
loading, and poured into a tray to expose the top surface
only. The sample was placed inside the environmental
chamber, and tested according to the specified protocol.

m•tm•

Environmental chamber test foNowing ASTM 0 5116 in a 0.09 ± 0.007 m~ chamber.

Page 2 of7

Released by Air Quality Sciences, Inc.

Date Prepared:
AQS Project #:
AQS Report#:
©2013AirQuality

January 15, 2013
90270
90270·86
Sciences. Inc.

CONFIDENTIAL
Test data and interpretation applicable to
GREENGUARD Certification Program only

TABLE 1
EMISSION FACTORS OF IDENTIFIED INDIVIDUAL VOLATILE ORGANIC
COMPOUNDS AT 24 ELAPSED EXPOSURE HOURS
PREPARED FOR: LIBERTY TIRE RECYCLING, LLC
PRODUCT 90270-P0860AA; 10+20 BM RUBBER CRUMB, BRANTFORD, ON

CAS
NUMBER

EMISSION
FACTOR
(1Jg/m2 •hr)

COMPOUND IDENTIFIED

107-21-1

1,2-Ethanediol (Ethylene glycol)1

281

95-16-9

Benzothiazolet

226

108-94-1

Cyclohexanone

73.9

108-10-1

2-Pentanone, 4-methyl (Methyl isobutyl ketone, MIBK)1

61.1

1120-21-4

Undecane

60.7

7206-29-3

6-Dodecene, (Z)-*

56.1

Decane1

49.3

124-18-5
17302-32-8

Nonane, 3,7-dimethyl*

45.0

62-53-3

Aniline

37.1

91-57-6

Naphthalene, 2-methyl

35.9

62016-14-2

Octane, 2,5,6-trimethyl*

34.2

934-74-7

Benzene, 1-ethyl-3,5-dimethyl

33.7

98-55-5

3-Cyclohexene-1-methanol, a.,a.,4-trimethyl
Formamide, N-(1, 1-dimethylethyl)-*

28.9

Dodecane

27.9

1758-88-9

Benzene, 2-ethyl-1 ,4-dimethyl*

26.5

17312-55-9

Decane, 3,8-dimethyl*

26.2

95-93-2

Benzene, 1,2,4,5-tetramethyl

26.0

91-17-8

Naphthalene, decahydro-•

25.0

2425-74-3
112-40-3

17312-53-7

28.6

Decane, 3,6-dimethyl*

23.3

123-48-8

3-Heptene, 2,2,4,6,6-pentamethyl-*

21.2

1678-93-9

Cyclohexane, butyl

19.0

Octane, 2,3,6-trimethyl*

17.8

Tridecane

16.8

62016-33-5
629-50-5

Page 3 of 7

Released by Air Quality Sciences, Inc.
Date Prepared:
January 15,2013
AQS Project#:
90270
AQS Report#:
90270-86
©2013 Air Quality Sciences, Inc.

CONFIDENTIAL
Test data and interpretation applicable to
GREENGUARD Certification Program only
CAS
NUMBER

138-86-3
96-48-0

EMISSION
FACTOR
(1Jg/m2 •hr)

COMPOUND IDENTIFIED

Limonene (Dipentene; 1-Methyl-4-(1methylethyl)cyclohexene)
2(3H)-Furanone, dihydro (Butyrolactone)

16.4
16.1

25551-13-7

Trimethylbenzene (AIIIsomers)t

15.9

77376-84-2

Tert. -butylaminoacrylonitryl*

15.4

17302-36-2

5-Ethyldecane*

14.9

91-20-3

Naphthalene t

14.9

106-42-3

Xylene (para and/or meta)t

14.7

874-35-1

1H-lndene, 2,3-dihydro-5-methyl*

14.4

Decane, 3, 7-dimethyl-*

14.4

57-55-6

1,2-Propanediol (Propylene glycol)

14.2

68-12-2

Formamide, N,N-dimethylt

13.7

Nonane, 4,5-dimethyl*

13.7

Phend

13.2

2958-76-1

Naphthalene, decahydro-2-methyl*

13.0

764-96-5

5-Undecene, (Z)*

11.1

1680-51-9

Naphthalene, 1,2,3,4-tetrahydro-6-methyl*

11.1

4292-75-5

Cyclohexane, hexyl*

10.8

475-20-7

Longifolene

10.6

Nonane, 4-methyl

9.9

147-47-7

Quinoline, 1,2-dihydro-2,2,4-trimethyl-*

9.9

629-62-9

Pentadecane

9.6

109-02-4

Morpholine, 4-methyl*

8.9

17312-57-1

Dodecane, 3-methyl*

8.7

622-96-8

Benzene, 1-ethyl-4-methyl (4-Ethyltoluene)

8.4

119-64-2

Naphthalene, 1,2,3,4-tetrahydro

8.4

629-59-4

Tetradecane

8.4

90-12-0

Naphthalene, 1-methyl

7.9

871-83-0

Nonane, 2-methyl

7.7

17312-54-8

17302-23-7
108-95-2

17301-94-9

489-40-7
99-87-6
62016-30-2

1H-Cycloprop[e]azulene, 1a,2,3,4,4a,5,6, 7b-octahydro1,1 ,4,7-tetramethyl-, [1aR-(1 aa,4a,4aj3,7ba)]*
Benzene, 1-methyl-4-(1-methylethyl) (p-Cymene; 4lsopropyltoluene)
Octane, 2,3,3-trimethyl-*
Page 4 of 7

7.5
7.5
7.2

Released by Air Quality Sciences, Inc.
January 15, 2013
Date Prepared:
90270
AOS Project #:
90270·86
AQS Report#:
©2013 Air Quality Sciences, Inc.

CONFIDENTIAL
Test data and interpretation applicable to
GREENGUARD Certification Program only

CAS
NUMBER

EMISSION
FACTOR
(1Jg/m2 •hr)

COMPOUND IDENTIFIED

110-12-3

2-Hexanone, 5-methyl*

6.5

100-52-7

Benzaldehyde

6.5

18321-36-3

Benzene, (1,1-dimethyl-2-propenyl)-*

6.3

1678-92-8

Cyclohexane, propyl

6.3

4904-61-4

1,5,9-Cyclododecatriene•

6.0

41446-63-3

7-Tetradecene, (E)*

6.0

61141-72-8

Dodecane, 4,6-dimethyl*

6.0

53927-61-0

Benzenamine, N-(2 ,2-dimethylpropyi)-N-methyl-•

5.5

581-40-8

Naphthalene, 2,3-dimethyl*

5.5

2051-30-1

Octane, 2,6-dimethyl

5.3

Propanoic acid

5.3

N-tert-Butylacetamide*

4.8

79-09-4
762-84-5

Analysis based on EPA Compendium Method

T0~17

and ASTM D 6196 for VOCs by thermal desorption followed by gas

chromatography/mass spectrometry (TD/GC/MS).

Quantifiable level is 0.04 ~g based on a standard 18 Lair collection volume.
*Indicates NIST/EPAINIH best library match only based on retention time and mass spectral characteristics.
toenotes quantified using multipoint authentic standard curve. Other VOCs quantified relative to toluene.

Page 5 of 7

Released by Air Quality Sciences. Inc.
Date Prepared:
January 15, 2013
AQS Project #:
90270
AQS Report#:
9027Q-86
@2013 Air Quality Sciences, Inc.

CONFIDENTIAL
Test data and interpretation applicable to
GREENGUARD Certification Program only

TABLE2
EMISSION FACTORS OF TARGET LIST ALDEHYDES
AT 24 ELAPSED EXPOSURE HOURS
PREPARED FOR: LIBERTY TIRE RECYCLING, LLC
PRODUCT 90270-POBSOAA; 10+20 BM RUBBER CRUMB, BRANTFORD, ON
.

CAS
NUMBER
4170-30-3

COMPOUND IDENTIFIED

EMISSION
FACTOR
(1Jg/m2 •hr)

2-Butenal

BQL

75-07-0

Acetaldehyde

BQL

100-52-7

Benzaldehyde

4.8

5779-94-2

Benzaldehyde, 2,5-dimethyl

BQL

529-20-4

Benzaldehyde, 2-methyl

BQL

Benzaldehyde, 3- and/or 4-methyl

BQL

123-72-8

Butanal

BQL

590-86-3

Butanal, 3-methyl

BQL

50-00-0

Formaldehyde

12.0

66-25-1

Hexanal

BQL

110-62-3

Pantanal

BQL

123-38-6

Propanal

BQL

620-23-5 /1 04-87-0

Analysis based on EPA Method T0·11A and ASTM D 5197 for selected aldehydes by high performance liquid chromatography
(HPLC).
BQL = Below quantifiable level of 0.1 JJ9 based on a standard 45 Lair collection volume.

Page 6 of7

Released by Air Quality Sciences, Inc.
Date Prepared:
January 15, 2013
AQS Project #:
90270
90270-86
AQS Report#:
©2013 Air Quality Sciences. Inc.

CONFIDENTIAL
Test data and interpretation applicable to
GREENGUARD Certification Program only

TABLE3
REGULATORY LIST
PREPARED FOR: LIBERTY TIRE RECYCLING, LLC
PRODUCT 90270-P0860AA; 10+20 BM RUBBER CRUMB, BRANTFORD, ON
< ()

CAS
NUMBER
107-21-1
96-48-0
110-12-3
106-10-1
62-53-3
108-94-1
50-00-0
68-12-2
91-20-3
90-12-0
91-57-6
108-95-2
79-09-4
25551-13-7
106-42-3

COMPOUND

CAL
PROP. 65

1,2-Ethanediol (Ethylene glycol)
2(3H)-Furanone, dihydro (8utyrolactone)
2-Hexanone, 5-methyl
2-Pentanone7 oz/sy

SECONDARY BACKING
TOTAL CARPET WEIGHT
PERMEABILITY
PERFORATIONS
TUFT BIND
SAND / RUBBER INFILL

ROLL WIDTH
ROLL LENGTH

Supplier/Installer Required Experience
(specification section 32 18 23)

Gridiron PRO ST
42 oz/sy
APT MFPE350DM
Proprietary PE formulation for superior wear
resistance
10,800 denier

Meets Intent of Spec
Yes
Yes

350 microns polyethylene diamond shape
2.5”
Green
1/2"
6.0 oz/sy
13 pic polybac
26 oz/sy urethane
74 oz/sy
24.5 in/hr
Standard
10.5 lbs/force
Ambient Rubber with Silica Sand
3.5 lbs/sf Rubber (53.8%)
3 lbs/sf Sand (46.2%)
6.5 lbs/sf Total Infill Weight
15’
Up to 240’
Submitted

Yes
Yes
Yes
Yes
Yes

Yes
Yes
Yes

The synthetic turf manufacturer must have completed a
minimum of twenty-five (25) synthetic turf installations in
the last 5 years, each in excess of 75,000 square feet.

Submitted

Yes

Turf Installation Crew: Synthetic turf installation crew
shall have installed a minimum of ten (10) outdoor
athletic field systems of similar type measuring 75,000
square feet or greater. The Turf Installation Crew shall
contain at least three (3) members who have installed at
least five (5) similar outdoor turf installations each greater
than 75,000 square feet. The designated crew foreman
shall have installed at least ten (10) similar outdoor turf
installations greater than 75,000 square feet, and shall
be subject to the approval of the Engineer. The crew
foreman shall be on site during all turf installation
procedures, and shall not be replaced without Owner
approval. Installation crew and foreman shall submit a
list of previously installed projects, by type, size, and
location for the Owner’s representative inspection at the
pre-construction conference and prior to start of Work.

Submitted

Yes

15’
Up to 240’
The synthetic turf shall be manufactured and supplied by
a company which has been in business continuously for
a period of a minimum of five (5) years under the same
name and ownership and with at least five (5) years’
experience in the manufacture and supply and of the
type of materials specified herein on projects of
comparable size to this Project.

16-18 oz/sy urethane
63 oz/sy
> 40 in/hr
Finger-Unit Drainage
9 lbs/force
Cryogenic Rubber with Silica Sand
3 lbs/sf Rubber (32.6%)
6.2 lbs/sf Sand (67.4%)
9.2 lbs/sf Total Infill Weight
15’
Up to 240’

Yes

Yes
Yes
Yes
Yes
Yes
Yes

Historically Approved

6/30/2014
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Medway High School
Turf Review Comparison Sheet
Submittal Requirement / Product Data

Submittal Requirements
(specification section 32 18 23)

Performance Specification
The General Contractor shall submit a list of previously
installed projects, to include individual owner contact
information,
by
the
proposed
Synthetic
Turf
Supplier/Installer, along with crew and foreman
qualifications at the pre-construction conference that
demonstrates
compliance
with
the
minimum
requirements of this section, 1.02, Paragraphs 1-3.

Revolution

Gridiron PRO ST
Submitted

Meets Intent of Spec
Yes

Submit a signed statement from the Infilled Synthetic Turf
System Manufacturer that the Drawings and
Specifications have been reviewed by a qualified
representative of the Infilled Synthetic Turf System
Manufacturer and major materials suppliers, and that
they are in agreement that the materials and installation
methods to be used for the Infilled Synthetic Turf System
are proper and adequate for use as a multi-purpose
athletic field in New England.

Submitted

Yes

Submit a recent reference list for the turf system
manufacturer/installer of at least five (5) outdoor high
school or college installations, each in excess of 80,000
S.F. incorporating the monofilament synthetic turf system
proposed for this project in compliance with this
specification. Minor variations in infill design in projects
cited for experience are acceptable.

Submitted

Yes

Submit a recent reference list for the turf system
manufacturer/installer of at least fifteen (15) outdoor
installations, each in excess of 80,000 S.F. incorporating
a tufted polyethylene infilled turf system.

Submitted

Yes

Job resumes of Infilled Synthetic Turf System
Manufacturer’s
Installation
Supervisor
(showing
supervision of at least ten (10) similar infilled turf
installations) and Infilled Synthetic Turf System Installers.

Submitted

Yes

Cut Sheets for all materials required under this Section
(turf, fiber, sand, rubber, etc.) including third party ASTM
certified lab gradation reports.

Submitted

Yes

Provide a sample written 8-year labor and materials
warranty from the Infilled Synthetic Turf System
Manufacturer.
Provide a sample Written Third Party Insured Warranty.

Submitted

Yes

Submitted

Yes

A signed letter on turf manufacturer company letterhead
holding the Owner, Designer and all other project
consultants harmless for any violation of patent rights or
infringements and claims related to hazardous materials
(e.g. lead or zinc) or other environmental impacts.

Submitted

Yes

Historically Approved

6/30/2014
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Medway High School
Turf Review Comparison Sheet
Submittal Requirement / Product Data

Performance Specification
Provide a carpet seaming plan.

Revolution

Gridiron PRO ST
Submitted

Meets Intent of Spec
Yes

Supply shop drawings (including details) at an approved
scale for location, installation, and erection of the
synthetic turf anchoring system
Provide a striping and marking plan for all intended
sports in compliance with NFHS, MIAA, and the
Drawings for approval by the Owner and Designer.

Submitted

Yes

Submitted

Yes

Provide color samples of manufacturer’s standard
monofilament polyethylene fiber for approval.

Submitted

Yes

Provide a minimum of 12” x 12” sample of monofilament
polyethylene carpet. Provide additional carpet samples
for other colors required under this Section.

Submitted

Yes

Provide 12” long sample of seaming tape.

Submitted

Yes

Provide certified sieve analysis of sand and rubber infill
materials for approval.

Submitted

Yes

Provide a 1-quart sample of the infill mix at the
Designer’s approved mix ratio.

Submitted

Yes

Synthetic Turf Supplier/Installer shall provide a written
statement that their product is lead free prior to
installation.

Submitted

Yes

6/30/2014
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