Public comments and responses

Page 1 of 1

PUBLIC SUBMISSION

As of: 4/11/17 11:12 AM
Received: April 04, 2017
Status: Posted
Posted: April 11, 2017
Tracking No. 1k1-8vn1-y0nv
Comments Due: April 11, 2017
Submission Type: Web

Docket: ATSDR-2017-0002
Characterization of Exposure Potential during Activities Conducted on Synthetic Turf with
Crumb Rubber Infill 0920-17OB
Comment On: ATSDR-2017-0002-0001
Characterization of Exposure Potential during Activities Conducted on Synthetic Turf with
Crumb Rubber Infill 0920-17OB 2017-02760
Document: ATSDR-2017-0002-0002
Characterization of Exposure Potential during Activities Conducted on Synthetic Turf with
Crumb Rubber Infill 0920-17OB Comment on FR Doc # N/A

Submitter Information
Name: Zach Laris
Organization: American Academy of Pediatrics

General Comment
Thank you for the opportunity to provide comments. The American Academy of Pediatrics'
comments are attached.

Attachments
AAP Crumb Rubber Turf Comments 2017-04-04

https://www.fdms.gov/fdms/getcontent?objectId=090000648253a213&format=xml&show... 4/11/2017

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]

Executive Committee
President
Fernando Stein, MD, FAAP
President-Elect
Colleen A. Kraft, MD, FAAP
Immediate Past President
Benard P. Dreyer, MD, FAAP
CEO/Executive Vice President
Karen Remley, MD, FAAP
Board of Directors
District I
Wendy S. Davis, MD, FAAP
Burlington, VT
District II
Warren M. Seigel, MD, FAAP
Brooklyn, NY
District III
David I. Bromberg, MD, FAAP
Frederick, MD
District IV
Jane Meschan Foy, MD, FAAP
Winston-Salem, NC
District V
Richard H. Tuck, MD, FAAP
Zanesville, OH
District VI
Pam 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

April 5, 2017
Leroy A. Richardson
Information Collection Review Office
Centers for Disease Control and Prevention
1600 Clifton Road NE
MS-D74
Atlanta, Georgia 30329
Docket No: ATSDR-2017-0002
Dear Mr. Richardson:
On behalf of the American Academy of Pediatrics (AAP), a non-profit professional
organization of 66,000 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 ongoing project “Characterization of Exposure
Potential during Activities Conducted on Synthetic Turf with Crumb Rubber
Infill''.
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. We look forward to utilizing the findings of the first phase of the
project. This data can help future researchers, including independent pediatric
experts, better understand the chemical composition of crumb rubber infill and its
potential effects on children’s health.
The Federal Register Notice of February 10, 2017 requests input on this study as it
enters its exposure characterization component. The AAP continues to believe in
the practical utility of this research in helping children and adolescents avoid
environmental hazards and any associated deleterious health effects.
Much of the data collected for the current phase of the study will be collected
during the summer months. We urge you to consider exposure to the collected
hazardous materials not only at temperatures like that of a hot summer day, but at
other temperatures as well because children play on these surfaces year-round. The
crumb rubber playing surface can still get quite hot due to sun exposure at springlike or cooler temperatures, and still pose a risk to children and adolescents. We
also urge you to study the degradation by-products that develop as crumb rubber
breaks down, and what children’s exposure to those by-products may be.

We support the undertaking of surveys and focus groups of parents/caregivers as part of the
CPSC’s work on this topic, as well as the CPSC’s focus on outdoor playgrounds that may be
built with crumb rubber “mulch” or unitary tiles. Although not the focus of the current exposure
study, research into children’s playground exposure to chemicals is imperative. To enhance the
efficacy of future studies, we strongly urge CPSC to consider a broad age range of children.
Developmentally appropriate mouthing behaviors begin in infancy 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 and therefore important to capture this exposure in any examination of
the health risks of tire crumb.
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. Additionally, the AAP
is concerned about young athletes and sports participants who will play on these surfaces
routinely throughout their lives on a near-daily basis. Given the potentially serious health
outcomes, such as cancer, it is appropriate that ATSDR, EPA, and CPSC continue to study the
health risks associate with crumb rubber.
Thank you again for the opportunity to provide input on this important research topic. 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,

Fernando Stein, MD, FAAP
President
FS/avg

Page 1 of 2

PUBLIC SUBMISSION

As of: 4/11/17 11:14 AM
Received: April 07, 2017
Status: Posted
Posted: April 11, 2017
Tracking No. 1k1-8vpd-s2iw
Comments Due: April 11, 2017
Submission Type: Web

Docket: ATSDR-2017-0002
Characterization of Exposure Potential during Activities Conducted on Synthetic Turf with
Crumb Rubber Infill 0920-17OB
Comment On: ATSDR-2017-0002-0001
Characterization of Exposure Potential during Activities Conducted on Synthetic Turf with
Crumb Rubber Infill 0920-17OB 2017-02760
Document: ATSDR-2017-0002-0003
Characterization of Exposure Potential during Activities Conducted on Synthetic Turf with
Crumb Rubber Infill 0920-17OB Comment on FR Doc # N/A

Submitter Information
Name: Juan Bohorquez
Address: 33178
Email: [email protected]

General Comment
Due to the high volume of use of synthetic turf, and it's use of rubber tire parts which are
typically considered dirty, it's easy to see that many people might be curious as to its potential
environmental and human health effects. Many such studies have been performed, measuring
levels of exposure in humans through proxy measurements, such as levels of Hydroxypyrene in
the urine of football players (Rooij & Jongeneelen, 2009)as well as its effect on water as it
makes its way to ground water (Cheng, Hu, & Reinhard, 2014). So far these searches have
found little evidence of direct human exposure to many of the harmful chemicals that would be
suspect from the rubber tires, but a close look at the extant data shows that it is lacking.
In Cheng's paper reviewing extant data on the environmental and human health effects of
artificial turf up until October 2013 it is observed that there are few problems that come from
artificial turf fields. The evidence shows no exposure hazards to humans in any of the chemicals
that are commonly searched for, including heavy metals and high aromatic hydrocarbons. But
the paper emphasizes that there are gaps in the data, as it is not well understood how the rubber
degrades over time as it is exposed to the sunlight, changes in temperature and rainwater.
Similarly, investigations of exposure don't find a link between activity on an artificial turf field
and individual levels of certain chemicals, but lack the proper statistics to make a conclusive
claim. The investigation makes use of only seven volunteers, three of which are excluded from

https://www.fdms.gov/fdms/getcontent?objectId=09000064825446c7&format=xml&show... 4/11/2017

Page 2 of 2

the results due to high backgrounds. (Rooij & Jongeneelen, 2009)
Thus further investigations of human exposure, such as the one proposed, are necessary. It is
important to understand the human health effects of these fields as they become more
widespread, even if previous data suggests there is no connection. In fact I would argue that the
sample size proposed is far too small, with 12,000 fields in use nationwide there can easily be
over 100,000 people in constant contact with the artificial turf. 70 people is too small a sample
size to make any conclusions. It is also necessary to survey if the effects of field use changes as
the age of the field changes, and whether the conditions to which a field is exposed as it ages
change the amount of exposure a user might face.
While the data point to few human health impacts, they do point to adverse effects on water
runoff caused by artificial turf fields. Tests on the environmental effects of artificial turf fields
point to significantly raised levels of zinc in water caused by artificial turf fields. Zinc is a
heavy metal which can lead to stunted growth in nearby plants and adverse developmental
effects in people. This runoff should be characterized and solutions to mitigate its impact should
be engineered quickly before large scale environmental degradation takes hold. (Groenevelt,
1998) (Cheng, Hu, & Reinhard, 2014)
In short, this investigation should be made, but it should be considered a part of a greater
investigation which more adequately measures the human health and environmental effects of
artificial turf.

References:
Cheng, H., Hu, Y., & Reinhard, M. (2014). Environmental and Health Impacts of Artificial
Turf: A Review. Environmental Science & Technology,48(4), 2114-2129.
doi:10.1021/es4044193
Rooij, J. G., & Jongeneelen, F. J. (2009). Hydroxypyrene in urine of football players after
playing on artificial sports field with tire crumb infill. International Archives of Occupational
and Environmental Health,83(1), 105-110. doi:10.1007/s00420-009-0465-y
Groenevelt, P. (1998). Utilisation of crumb rubber as a soil amendment for sports turf. Soil and
Tillage Research,47(1-2), 169-172. doi:10.1016/s0167-1987(98)00089-0

Attachments
Turf

https://www.fdms.gov/fdms/getcontent?objectId=09000064825446c7&format=xml&show... 4/11/2017

Due to the high volume of use of synthetic turf, and it’s use of rubber tire parts which are
typically considered dirty, it’s easy to see that many people might be curious as to its potential
environmental and human health effects. Many such studies have been performed, measuring
levels of exposure in humans through proxy measurements, such as levels of Hydroxypyrene in
the urine of football players (Rooij & Jongeneelen, 2009)as well as its effect on water as it makes
its way to ground water (Cheng, Hu, & Reinhard, 2014). So far these searches have found little
evidence of direct human exposure to many of the harmful chemicals that would be suspect from
the rubber tires, but a close look at the extant data shows that it is lacking.
In Cheng’s paper reviewing extant data on the environmental and human health effects of
artificial turf up until October 2013 it is observed that there are few problems that come from
artificial turf fields. The evidence shows no exposure hazards to humans in any of the chemicals
that are commonly searched for, including heavy metals and high aromatic hydrocarbons. But
the paper emphasizes that there are gaps in the data, as it is not well understood how the rubber
degrades over time as it is exposed to the sunlight, changes in temperature and rainwater.
Similarly, investigations of exposure don’t find a link between activity on an artificial
turf field and individual levels of certain chemicals, but lack the proper statistics to make a
conclusive claim. The investigation makes use of only seven volunteers, three of which are
excluded from the results due to high backgrounds. (Rooij & Jongeneelen, 2009)
Thus further investigations of human exposure, such as the one proposed, are necessary.
It is important to understand the human health effects of these fields as they become more
widespread, even if previous data suggests there is no connection. In fact I would argue that the
sample size proposed is far too small, with 12,000 fields in use nationwide there can easily be
over 100,000 people in constant contact with the artificial turf. 70 people is too small a sample
size to make any conclusions. It is also necessary to survey if the effects of field use changes as
the age of the field changes, and whether the conditions to which a field is exposed as it ages
change the amount of exposure a user might face.
While the data point to few human health impacts, they do point to adverse effects on
water runoff caused by artificial turf fields. Tests on the environmental effects of artificial turf
fields point to significantly raised levels of zinc in water caused by artificial turf fields. Zinc is a
heavy metal which can lead to stunted growth in nearby plants and adverse developmental
effects in people. This runoff should be characterized and solutions to mitigate its impact should
be engineered quickly before large scale environmental degradation takes hold. (Groenevelt,
1998) (Cheng, Hu, & Reinhard, 2014)
In short, this investigation should be made, but it should be considered a part of a greater
investigation which more adequately measures the human health and environmental effects of
artificial turf.

References:
Cheng, H., Hu, Y., & Reinhard, M. (2014). Environmental and Health Impacts of
Artificial Turf: A Review. Environmental Science & Technology,48(4), 2114-2129.
doi:10.1021/es4044193
Rooij, J. G., & Jongeneelen, F. J. (2009). Hydroxypyrene in urine of football players after
playing on artificial sports field with tire crumb infill. International Archives of Occupational
and Environmental Health,83(1), 105-110. doi:10.1007/s00420-009-0465-y
Groenevelt, P. (1998). Utilisation of crumb rubber as a soil amendment for sports
turf. Soil and Tillage Research,47(1-2), 169-172. doi:10.1016/s0167-1987(98)00089-0

Due to the high volume of use of synthetic turf, and it’s use of rubber tire parts which are
typically considered dirty, it’s easy to see that many people might be curious as to its potential
environmental and human health effects. Many such studies have been performed, measuring
levels of exposure in humans through proxy measurements, such as levels of Hydroxypyrene in
the urine of football players (Rooij & Jongeneelen, 2009)as well as its effect on water as it makes
its way to ground water (Cheng, Hu, & Reinhard, 2014). So far these searches have found little
evidence of direct human exposure to many of the harmful chemicals that would be suspect from
the rubber tires, but a close look at the extant data shows that it is lacking.
In Cheng’s paper reviewing extant data on the environmental and human health effects of
artificial turf up until October 2013 it is observed that there are few problems that come from
artificial turf fields. The evidence shows no exposure hazards to humans in any of the chemicals
that are commonly searched for, including heavy metals and high aromatic hydrocarbons. But
the paper emphasizes that there are gaps in the data, as it is not well understood how the rubber
degrades over time as it is exposed to the sunlight, changes in temperature and rainwater.
Similarly, investigations of exposure don’t find a link between activity on an artificial
turf field and individual levels of certain chemicals, but lack the proper statistics to make a
conclusive claim. The investigation makes use of only seven volunteers, three of which are
excluded from the results due to high backgrounds. (Rooij & Jongeneelen, 2009)
Thus further investigations of human exposure, such as the one proposed, are necessary.
It is important to understand the human health effects of these fields as they become more
widespread, even if previous data suggests there is no connection. In fact I would argue that the
sample size proposed is far too small, with 12,000 fields in use nationwide there can easily be
over 100,000 people in constant contact with the artificial turf. 70 people is too small a sample
size to make any conclusions. It is also necessary to survey if the effects of field use changes as
the age of the field changes, and whether the conditions to which a field is exposed as it ages
change the amount of exposure a user might face.
While the data point to few human health impacts, they do point to adverse effects on
water runoff caused by artificial turf fields. Tests on the environmental effects of artificial turf
fields point to significantly raised levels of zinc in water caused by artificial turf fields. Zinc is a
heavy metal which can lead to stunted growth in nearby plants and adverse developmental
effects in people. This runoff should be characterized and solutions to mitigate its impact should
be engineered quickly before large scale environmental degradation takes hold. (Groenevelt,
1998) (Cheng, Hu, & Reinhard, 2014)
In short, this investigation should be made, but it should be considered a part of a greater
investigation which more adequately measures the human health and environmental effects of
artificial turf.

References:
Cheng, H., Hu, Y., & Reinhard, M. (2014). Environmental and Health Impacts of
Artificial Turf: A Review. Environmental Science & Technology,48(4), 2114-2129.
doi:10.1021/es4044193
Rooij, J. G., & Jongeneelen, F. J. (2009). Hydroxypyrene in urine of football players after
playing on artificial sports field with tire crumb infill. International Archives of Occupational
and Environmental Health,83(1), 105-110. doi:10.1007/s00420-009-0465-y
Groenevelt, P. (1998). Utilisation of crumb rubber as a soil amendment for sports
turf. Soil and Tillage Research,47(1-2), 169-172. doi:10.1016/s0167-1987(98)00089-0

Page 1 of 1

PUBLIC SUBMISSION

As of: 4/12/17 9:02 AM
Received: April 11, 2017
Status: Posted
Posted: April 12, 2017
Tracking No. 1k1-8vrv-ojjh
Comments Due: April 11, 2017
Submission Type: Web

Docket: ATSDR-2017-0002
Characterization of Exposure Potential during Activities Conducted on Synthetic Turf with
Crumb Rubber Infill 0920-17OB
Comment On: ATSDR-2017-0002-0001
Characterization of Exposure Potential during Activities Conducted on Synthetic Turf with
Crumb Rubber Infill 0920-17OB 2017-02760
Document: ATSDR-2017-0002-0005
Characterization of Exposure Potential during Activities Conducted on Synthetic Turf with
Crumb Rubber Infill 0920-17OB Comment on FR Doc # N/A

Submitter Information
Name: Anonymous Anonymous
Organization: ISRI

General Comment
See attached file(s)

Attachments
EPA Letter 4-11-17 FINAL

https://www.fdms.gov/fdms/getcontent?objectId=090000648254bf85&format=xml&show... 4/12/2017

Davis, Stephanie I. (CDC/ONDIEH/NCEH)
From:
Sent:
To:
Subject:
Attachments:

Burroughs, Kennya L. (CDC/OD/OADS) on behalf of OMB-Comments (CDC)
Wednesday, April 12, 2017 8:52 AM
Davis, Stephanie I. (CDC/ONDIEH/NCEH)
FW: Proposed Data Collection – Agency for Toxic Substances and Disease Registry
(ATSDR) and Department of Health and Human Services (HHS) – ATSDR-2017-0002
EPA Letter 4-11-17 FINAL.pdf

Please see, attached document. 

Kennya 

From: Billy Johnson [mailto:[email protected]]  
Sent: Tuesday, April 11, 2017 2:42 PM 
To: OMB‐Comments (CDC)  
Subject: Proposed Data Collection – Agency for Toxic Substances and Disease Registry (ATSDR) and Department of 
Health and Human Services (HHS) – ATSDR‐2017‐0002 

Filed through federal rulemaking portal.   

William H. Johnson 
Chief Lobbyist 
1250 H  Street, NW 
Suite 400 
Washington, DC  20005 
(202) 662‐8548 ‐ direct 
(202) 714‐4259 ‐ cell 

The Institute of Scrap Recycling Industries, Inc. (ISRI) is the "Voice of the Recycling Industry." ISRI and its 21
chapters represent approximately 1,300 companies operating in nearly 4,000 locations in the U.S. and 34 countries
worldwide that process, broker, and consume scrap commodities, including metals, paper, plastics, glass, rubber,
electronics, and textiles. With headquarters in Washington, DC, ISRI provides education, advocacy, safety and
compliance training, and promotes public awareness of the vital role recycling plays in the U.S. economy, global trade, the
environment and sustainable development. Generating more than $105 billion annually in U.S. economic activity, the
1

scrap recycling industry provides nearly half a million Americans with good jobs. For more information about ISRI, please
visit www.isri.org.

2

April 11, 2017
Mr. Leroy A. Richardson
Information Collection Review Office
Centers for Disease Control and Prevention
1600 Clifton Road, N.E., MS-D74
Atlanta, Georgia 30329
Re: Proposed Data Collection – Agency for Toxic Substances and Disease Registry (ATSDR) and
Department of Health and Human Services (HHS) – ATSDR-2017-0002
On July 11, 2016, ATSDR and EPA were granted emergency clearance to conduct a three-part
study of crumb rubber, which expired January 31, 2017. In the Federal Research Action Plan on Recycled
Tire Crumb Used on Playing Fields (“FRAP”), issued in February 2016 and formed the basis for the
initial Information collection on this project, the Agencies stated “[b]y the end of 2016, the agencies
anticipate releasing a draft status report that describes the preliminary findings and conclusions of the
research through that point in time.” During early discussions with industry, EPA anticipated completion
of the study in 2017. The Notice now indicates that EPA is asking for an additional two years’ clearance
to complete the study.
This further delay is not warranted given (1) the wide body of peer-reviewed literature that finds
little to no risk associated with recycled crumb rubber, including additional findings that were not
considered and therefore not reported in EPA’s data gap analysis issued December 31, 2016; (2)
duplicative ongoing research, including notably by California’s Office of Health Hazard Assessment
(OEHHA); and (3) the effects of regulatory uncertainty caused by EPA’s delays on the recycled rubber
industry.
Instead, we urge the Agencies to (1) re-evaluate the existing literature, particularly with regard to
both the cumulative scientific value of the multitude of studies cited in the December 31, 2016 data gap
analysis, as well as new research reported since then, all of which find little or no risk to human health
from exposure to recycled rubber; (2) share any preliminary data with California OEHHA to avoid
duplication of effort and resources; and (3) promptly issue a statement to reassure the public that, based
on the extensive research conducted to date, there is no evidence that exposure to recycled rubber presents
a significant risk to human health.
Background
The initial impetus for this study was based on speculation that recycled rubber used in synthetic
athletic fields and playgrounds causes cancer. Specifically, in 2015, a college soccer coach hypothesized
that crumb rubber infill was the cause of incidents of cancer among soccer players in Washington State.
The coach compiled an admittedly anecdotal list of soccer players who had contracted cancer and offered
this to news outlets.

1

Nonetheless, NBC and ESPN ran widely viewed, one-sided shows focusing on anecdotes that
gave credence to the theory on a cancer cluster around soccer players and cited the Yale study without
noting its obvious shortcomings or the more than 90 studies that did not find any significant health risks
related to recycled rubber infill. The NBC and ESPN shows resulted in understandably alarmed parents,
and President Obama directed the Agencies to conduct this study. Earlier this year, the Washington State
Department of Health rejected these unsubstantiated claims.
Since the Agencies announced this study program, municipalities and schools across the country
have in many instances decided to either delay installation of new athletic fields and playgrounds until the
study is completed or use far less tested alternative materials due to the new uncertainty surrounding
recycled rubber created by the study. As a result, recycled rubber suppliers have seen their orders drop by
more than 30%, leading to subsequent job losses.
EPA’s Study is Causing Environmental Harm and May Reduce Children’s Fitness
The ironic impact of local decision makers eschewing recycled rubber in favor of less-tested
alternative infills or natural turf is that these surfaces actually result in significantly reduced playtime for
children.
As a result of the regulatory uncertainty caused by the prolonged studies, purchasers of athletic
fields and playgrounds, mostly municipalities, recreation departments, and schools, either have delayed
decisions to purchase synthetic turf fields with recycled rubber or have selected alternative infills or
natural grass. Moreover, synthetic turf fields provide a safe, all-weather playing surface. Availability of
synthetic turf during or after rain events increases field play time by a factor of five. Accordingly,
synthetic turf fields lead to more active, healthier kids. In considering health, it is also important to note
the shock absorption qualities of recycled rubber on playgrounds, which bring added safety for youths in
the event of falling and other accidents. Environmental factors also matter with regard to maintenance, as
grass fields result in increased water usage, pesticides, herbicides, and fertilizers that would not be used
with a synthetic turf field.
Decisions to keep or install grass fields rather than install synthetic turf with recycled rubber have
negative impacts on both the environment and the health of the users. It is important to note that each
synthetic turf field with recycled rubber that is not installed results in approximately 25,000 to 30,000
used tires either going to a landfill or to an incinerator. The recycled rubber and synthetic turf industries
provide an endpoint for used tires that removes them from the waste stream. Accordingly, EPA’s
requested two-year delay in assuring communities that recycled rubber is appropriate for use on athletic
fields and playgrounds will result in millions of additional tires in the waste stream rather than having
them recycled for a beneficial use.
EPA’s Research is Duplicative of Other State, University, and International Studies
The research landscape has changed since the federal agencies began their review of recycled
crumb rubber in early 2016, and even more so since the release of the December 31, 2016 Interim Status
Report. Before wasting additional resources and exacerbating the adverse impacts that the study has
created, we urge EPA to re-evaluate the research by considering (1) the cumulative scientific value of all

2

of the studies that have reported little or no adverse health impacts from recycled rubber and (2) the
several new studies that affirm the safety of recycled rubber. In addition, EPA should carefully consider
the prudence, given what we already know about the safety of the product, of duplicating research already
under way with California OEHHA, and which is on a similar timeline as EPA’s new proposed timeline.
EPA’s study of recycled rubber is duplicative of the current study being conducted by California
OEHHA. Both studies include multi-pathway exposure analysis. When EPA began its review of recycled
rubber in early 2016, EPA’s projected completion was approximately two years in advance of California
OEHHA’s projected completion, so the undersigned supported EPA’s efforts to bring clarity more
quickly to parents confused and needlessly concerned as a result of the speculation fueled by the NBC and
ESPN reports. With EPA’s new two-year extension request, the federal study is now on pace to be
completed approximately the same time as the California OEHHA study. Since the two similar studies are
now on the same schedule, EPA can share its preliminary raw data with California OEHHA, but
duplicative exposure analyses would be redundant and a waste of federal resources.
A critical flaw in the data gap analysis is, while EPA identified the strengths and weaknesses of
each known published study of recycled rubber, EPA failed to assess the cumulative scientific value of
the various studies in demonstrating the safety of recycled rubber. While it is important to identify data
gaps when evaluating the state of the science for a chemical or product, it is generally accepted scientific
methodology that analysis should (1) identify where there are limited data that prevent making informed
decisions, and (2) identify where the data are strong in other research and might overcome some of the
limitations identified.
For instance, if multiple individual studies each have a small sample size but all have reasonably
consistent results, it is likely that the strength of that consistency can overcome the small sample size of
each study individually. As another example, if no one study has studied all relevant exposure routes
simultaneously, yet there are studies that collectively have evaluated different routes, once again the
combined data might be a strength that offsets the lack of one study that has evaluated all routes at once.
Because EPA’s initial data gap analysis fails to assess the cumulative scientific value of the more than 90
studies it reviewed, the Interim Status Report does not present an accurate evaluation of the strengths and
weaknesses of the totality of all of the available data. The research when viewed as a whole would allay
parents’ concerns about their children’s health when playing on synthetic turf containing recycled rubber.
The primary issue identified by EPA is that there has not been a systematic chemical
characterization of recycled rubber, combined with a multi-pathway health risk assessment. The
aforementioned study by California’s Office of Health Hazard Assessment (OEHHA) will address the
point of having a multi-pathway health risk assessment, which is well-underway in its progress.
Furthermore, EPA states that there are only limited biomonitoring studies and no epidemiology studies
available. Notwithstanding the point that these statements fail to account for the cumulative scientific
value of the literature reviewed, new research published since EPA’s Interim Status Report, closes the
data gaps such that the merits of continuing EPA’s study should be re-evaluated.
Since the EPA Interim Status Report, three new studies have become available: (1) a Washington
Department of Health (WDOH) cancer cluster investigation, (2) a Dutch government (RIVM) risk
assessment, and (3) a European Chemicals Agency (ECHA) study released in February, 2017 of the
health effects of playing on recycled rubber infill fields including exposure to metals, PAHs, and volatiles
3

through skin contact, inhalation, and ingestion that concluded there is a very low level of concern and
found no reason to advise against playing on fields using recycled rubber infill. All three of these studies
conclude, as almost all of the previous 90+ studies on this issue, recycled rubber does not present
significant health concerns for users of synthetic turf fields.
Washington State
The ultimate irony, however, is that the Washington Department of Health (“WDOH”) has since
refuted the soccer cancer cluster theory, and actually found fewer instances of cancer among soccer
players than expected when compared to Washington residents of the same ages. Yet the subsequent
studies sparked by her unfounded hypothesis continue on, and the subsequent regulatory uncertainty has
delayed purchasing decisions while the public awaits the Agencies’ findings.
The WDOH study had two main goals: 1) to compare the number of cancers among soccer players on the
coach's list to the number expected in a normal population, and 2) to describe the demographics of the
individuals on the list, including factors related to cancer. The WDOH report concluded, "Using Coach
Griffin's list to identify soccer players with cancer, this investigation found less cancer among the soccer
players than expected based on rates of cancer among Washington residents of the same ages. This
finding does not suggest that soccer players, select and premier soccer players, or goalkeepers in
Washington are at increased risk for cancer compared to the general population. In addition, the currently
available research on the health effects of artificial turf does not suggest that artificial turf presents a
significant public health risk. Assurances of the safety of artificial turf, however, are limited by a lack of
adequate information on potential toxicity and exposure."
Dutch and European Studies
Interestingly, the two studies by the Dutch government/RIVM and ECHA provide additional
information on toxicity and exposure, thereby addressing the issue brought up by WDOH. The RIVM
evaluated the exposure to chemicals in recycled rubber via skin, ingestion, and inhalation, using rubber
samples from 100 different fields. They concluded that, "…because the substances are more or less
‘enclosed’ in the granulate, which means that the effect of these substances on human health is virtually
negligible." The risk assessment by ECHA reported nearly identical findings. They evaluated 50 samples
of new recycled rubber, as well as more than 100 fields in use. They concluded, "ECHA has considered
exposure to rubber granules by skin contact, ingestion, and inhalation of substances evaporating from the
granules, as well as dust formed by the granules themselves. ECHA concludes that there is at most a very
low level of concern from exposure to recycled rubber granules."
Given these three new studies as well as the strength of the existing scientific evidence, we would
encourage the agencies to reevaluate the existing evidence, in particular in relation to how the safety of
other common consumer products has been evaluated. We feel that the existing evidence has only been
strengthened with each new study, and that the time has come for the agencies to acknowledge that the
current scientific evidence consistently has supported the safety of this product and remove the regulatory
uncertainty surrounding this material.

4

Conclusion
We urge the Agencies to (1) re-evaluate the available research to apply a more cumulative analysis
to the available research and include recent data points that further affirm the safety of recycled rubber;
(2) conclude their effort with a definitive public statement that makes clear that the agency has not found
issues of concern based on its own research to date, but will aggressively investigate should future
evidence indicate that is appropriate; and (3) support the study being done by California OEHHA by
providing it with the research done to date. The need for a duplicative federal study, especially given the
new research that has now been done, is unjustifiable.
At the very least, EPA’s activities must not result in regulatory uncertainty and result in harm to
the environment or the communities they serve. EPA already has ample evidence to support a statement
affirming the use of recycled rubber in synthetic turf fields and playgrounds. Any further delays in
concluding the study and reassuring communities will cause further harm to the environment and those
who would have purchased playing surfaces with recycled rubber but for the regulatory uncertainty being
sustained by the delayed federal study.

Respectfully,
The Safe Fields Alliance
The Recycled Rubber Council
The Synthetic Turf Council
The Institute of Scrap Recycling Industries, Inc.

5

Response to Public Comments received for the 60-day FRN for “Characterization of Exposure Potential during
Activities Conducted on Synthetic Turf with Crumb Rubber Infill”

Response to public comment #1
Thank you for your interest in the joint U.S. Environmental Protection Agency (EPA) and the Centers for
Disease Control and Prevention/Agency for Toxic Substances and Disease Registry (ATSDR) study on
“Characterization of Exposure Potential during Activities Conducted on Synthetic Turf with Crumb
Rubber Infill”. Federal researchers understand the interest and importance of better characterization
of children’s exposure to tire crumb rubber constituents in synthetic turf fields. For the exposure
characterization study activity described in this information collection request, players, including
children and adolescents, on a number of fields from the four US census regions will be recruited. The
different field locations should allow for a variety of field conditions, including temperature differences
and different age and weathering patterns of the fields. The research is designed to improve our
understanding of the chemicals children and adults may be exposed to and the types of activity and
contact information needed to better characterize the inhalation, dermal, and ingestion pathways of
exposure for adults and children using synthetic turf fields.
Research on children’s exposures at playgrounds with tire-derived rubber surfaces is not included in
this information collection request, which focuses on synthetic turf fields. We have forwarded your
comment to the Consumer Product Safety Commission, whose research efforts are aimed at
identifying and assessing the risks associated the use of recycled tire crumb rubber in playground
surfaces.

Page 1 of 5

Response to Public Comments received for the 60-day FRN for “Characterization of Exposure Potential during
Activities Conducted on Synthetic Turf with Crumb Rubber Infill”

Response to public comment #2
Thank you for your interest in the joint U.S. Environmental Protection Agency (EPA) and the Centers for
Disease Control and Prevention/Agency for Toxic Substances and Disease Registry (ATSDR) study on
“Characterization of Exposure Potential during Activities Conducted on Synthetic Turf with Crumb
Rubber Infill”. The exposure characterization study is a pilot-scale effort aimed at collecting
information on how people might be exposed to chemicals in crumb rubber infill while playing on
synthetic turf fields. For the exposure characterization study, players, including children and
adolescents, on a number of fields from the four US census regions will be recruited. The different
field locations should allow for a variety of field conditions, including temperature differences and
different age and weathering patterns of the fields. Because the activity will not involve a statisticallybased sampling design, the research will not provide data intended for nationwide generalizations.
However, while the sample size is likely not sufficient for determining statistical differences, the
exposure characterization study will fill essential data and knowledge gaps regarding the potential for
human exposure during activities on synthetic turf fields. The information gained from the research
activities conducted under the Federal Research Action Plan will help answer some key questions and
will be used to identify future follow-up activities that could be conducted to provide additional
insights about potential risks.
Federal researchers understand the concern regarding the water runoff caused by synthetic turf fields.
The State-of-the-Science Literature Review/Gaps Analysis included in the December 2016 Status
Report (https://www.epa.gov/chemical-research/december-2016-status-report-federal-researchaction-plan-recycled-tire-crumb) identified nearly 30 articles or reports relevant to chemical leaching
from tire crumb rubber and/or ecological toxicity and risk. However, examining the potential for
ecological exposure and risks are beyond the scope of the current research activity which focuses on
the better understanding the potential for human exposure for people using synthetic turf fields.

Page 2 of 5

Response to Public Comments received for the 60-day FRN for “Characterization of Exposure Potential during
Activities Conducted on Synthetic Turf with Crumb Rubber Infill”

Response to public comment #3
Thank you for your interest in the joint U.S. Environmental Protection Agency (EPA) and the Centers for
Disease Control and Prevention/Agency for Toxic Substances and Disease Registry (ATSDR) study on
“Characterization of Exposure Potential during Activities Conducted on Synthetic Turf with Crumb
Rubber Infill”.
As part of the work under the Federal Research Action Plan on Recycled Tire Crumb Used on Playing
Fields and Playgrounds, the Agency for Toxic Substances and Disease Registry (ATSDR) and the United
States Environmental Protection Agency (US EPA) were granted a six-month emergency OMB approval
for a research protocol titled “Collections Related to Synthetic Turf Fields with Crumb Rubber Infill”
(OMB Control No. 0923-0054, expiration date 01/31/2017) on July 22, 2016. The research goals of the
protocol’s pilot-level investigations are to evaluate and characterize: the chemical composition and use
of crumb rubber infill in synthetic turf using a convenience sample of nine tire recycling manufacturing
plants and 40 facilities that use synthetic turf fields (tire crumb characterization study) and the human
exposure potential to constituents in crumb rubber infill (exposure characterization study).
Since the six-month emergency Paperwork Reduction Act clearance was granted, ATSDR and US EPA
completed the field work portion of tire crumb characterization study field work, which included
sampling 40 synthetic turf fields with crumb rubber infill across the United States after garnering
consent from field managers. These activities are reported in the "Status Report on the Federal
Research Action Plan on Recycled Tire Crumb Used on Playing Fields and Playgrounds." The Status
Report was released on December 30, 2016.
The new information collection request (ICR) is submitted under the typical (non-emergency) ICR
process as a two-year request to complete the exposure characterization portion of the study; it is the
intention of researchers to complete the remaining research and reporting activities as soon as
possible. Ideally, the work will be completed by the end of the calendar year 2017. The timeline will
depend in part on the availability of resources and most importantly on the availability and recruitment
success of research participants. To provide more context for potential research timeline impacts, we
describe below the technical aspects of collecting exposure characterization data that are needed to
help fill important data gaps for a range of synthetic field users and to appropriately frame information
generated as part of the tire crumb rubber characterization.
This new ICR proposes to use fields previously identified during the tire crumb characterization study
to investigate the potential for human exposure to environmental constituents from contact with
crumb rubber infill. The exposure characterization study is a pilot-scale effort aimed at collecting
information on how people might be exposed to chemicals in crumb rubber infill while playing on
synthetic turf fields. The study will use a questionnaire to determine different activities adults and
children have on synthetic turf fields that may affect their potential exposures to chemicals in synthetic
turf fields. In this study, we aim to include persons who have the potential for higher exposures,
including children. Specifically, we plan to recruit and enroll children ages 6-17 and college-age
individuals who engage in physical activities on synthetic turf fields with crumb rubber infill, in addition
to adults. In addition to the questionnaire, we will use pre-existing video to collect information on
types and frequencies of activities on synthetic turf fields, along with clothing and protective
Page 3 of 5

Response to Public Comments received for the 60-day FRN for “Characterization of Exposure Potential during
Activities Conducted on Synthetic Turf with Crumb Rubber Infill”

equipment usage. A subset of the participants in the exposure characterization study, including
children, will be asked to participate in an exposure measurements sub-study. In the exposure
measurements sub-study, several types of samples will be collected. Personal air samples and ambient
on-field air samples will be collected during the sports or training activity on the synthetic turf field;
dermal wipe samples will be collected immediately following the activity. Air samples will be analyzed
for metals, volatile organic compounds (VOCs), and semi-volatile organic compounds (SVOCs); dermal
wipe samples will be analyzed for metals and SVOCs. Urine and blood samples will be collected at
three time points around the sports or training activity, one sample pre-activity, one sample postactivity, and one sample 24 hours later. These samples will be archived for future analysis.
While previous and recent studies to date have not shown an elevated health risk from playing on
fields with tire crumb rubber, these studies have limitations, particularly with regard to exposure
assessment. The State-of-the-Science Literature Review/Gaps Analysis included in the December 2016
FRAP Status Report (https://www.epa.gov/chemical-research/december-2016-status-report-federalresearch-action-plan-recycled-tire-crumb) identified several important exposure-related data gaps.
These include limited information on human activity pattern information for synthetic field users,
limited data needed to better characterize dermal and ingestion exposure pathways, variability in
exposures, biomonitoring, limited aggregate and cumulative assessments, and no epidemiological
investigations identified prior to the Washington Department of Health report in December 2016.
Most previous risk assessments and recent Netherlands RIVM and the European Chemicals Agency
reports have relied in part on default and/or assumed exposure factors and assumptions, with limited
information available to support dermal and ingestion pathways in their assessments. While the recent
RIVM and ECHA reports have many strengths, they largely focused on soccer player and worker
exposure scenarios while important U.S. scenarios, for example American football with potentially
higher field material contact rates, have not been considered. The recent Washington state
Department of Health investigation of cancer in Washington soccer players did not find an increased
risk of cancer compared to the general population, but the authors noted that “Assurances of the
safety of artificial turf, however, are limited by lack of adequate information on potential toxicity and
exposure”. The WADOH study only looked at cancer rates in soccer players compared to state-wide
cancer rates and did not consider other types of field users, such as football players. Although these
recent reports provide additional information, the State-of-the-Science Literature Review/Gaps
Analysis was not intended to make any conclusions or recommendations regarding the safety of the
use of recycled tire crumb rubber in synthetic turf fields and playgrounds. The review was intended to
identify important data gaps for guiding and designing future research efforts needed to further
address questions regarding exposures, including those that are the subject of this ICR.
The exposure characterization research activities included in the current information collection request
are not duplicative of previous research efforts and are aimed at reducing some important exposure
data gaps that still remain. To date, there has been no comprehensive evaluation of exposure to tire
crumb rubber constituents in the United States. Previous exposure studies are limited, often due to
small sample size, limited geographic coverage, limited number/type of constituents measured,
incomplete exposure pathway assessment, lack of biomonitoring sample collection, and absent or
inadequate collection of exposure factor information needed to move away from default and assumed
Page 4 of 5

Response to Public Comments received for the 60-day FRN for “Characterization of Exposure Potential during
Activities Conducted on Synthetic Turf with Crumb Rubber Infill”

exposure factors. Existing research in the United States is also limited in examining differences in
exposures between adult and child synthetic field users, and across different types of athletic and
physical training activities. Additional information is needed to better understand exposures in indoor
facilities, with very limited information available in the United States. While this effort won’t provide
all the answers about whether synthetic turf fields are safe, it represents the first time that such a large
study is being conducted across the U.S. The study will provide a better understanding of potential
exposures that athletes and others may experience and will help answer some of the key questions
that have been raised.
There are other studies currently being conducted, primarily by the California Office of Environmental
Health and Hazard Assessment (OEHHA). While there are some similar efforts between the FRAP and
the California OEHHA activities, their activities are limited to the state of California and may not reflect
conditions and factors important for understanding exposures to synthetic field users across the
United States. Consultation between the federal research team and Cal-OEHHA researchers is ongoing.
The researchers will identify and implement methods and approaches that will, where feasible,
produce comparable data. This could effectively expand the overall U.S. research sample size and will
provide additional insight into potential exposure variability. There are also important differences
between the federal and Cal-OEHHA studies that will provide complimentary data for improved
exposure assessment. There is no duplication of efforts with the Washington State Department of
Health study as their cancer incidence investigation looked only at cancer incidence rates among
soccer players and did not investigate the potential chemical exposures as related to play on synthetic
turf fields.

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