EPA Moving Toward White House Review of Federal Synthetic Turf Plan
Monday, June 6, 2016
Risk Policy Report
EPA MOVING TOWARD WHITE HOUSE REVIEW OF FEDERAL SYNTHETIC TURF PLAN
By Maria Hegstad
EPA and other federal agencies collaborating on a research plan for investigating the human health risks of playing on fields and playgrounds made with tire crumb rubber are awaiting the results of an external peer review before seeking White House approval of the plan, while at the same time reviewing public comments questioning the plan.
The agencies' "Synthetic Turf Fields with Tire Crumb Rubber Infill Research Protocol" document is currently going through external peer review managed by a contractor, an EPA spokesman says. "After the peer-review is complete, the next step is for the research protocol document to go through the [White House] Information Collection Request (ICR) review process before the research can proceed . . ."
The research plan must undergo scrutiny from the White House Office of Budget and Management because the research involves collecting information from more than 10 people or entities. The spokesman did not indicate when the peer review will conclude, saying only that the results of the review will be posted on EPA's website.
EPA and the Agency for Toxic Substances Disease Registry (ATSDR) are leading the federal research project, while the Consumer Product Safety Commission (CPSC) is also collaborating. EPA and ATSDR released in February a plan for two new studies, one intended to "characterize field use procedures and conditions," by recording field use and maintenance patterns at 40 synthetic turf fields spread across the United States, according to ATSDR's Feb. 18 Federal Register notice. Relevant documents are available on InsideEPA.com. (Doc. ID 191565)
The second study is thought to be "the first assessment of activities conducted on synthetic turf for the purpose of characterizing potential exposure patterns," according to the notice, by surveying people who frequently use synthetic turf fields.
The Federal Register notice adds that "if time and resources allow, we will conduct a full exposure characterization sub-study among a subset of the respondents. If possible, we will use the facilities sampled in the first study to conduct activities for the full exposure characterization of facility users. The exposure characterization sub-study will likely include but is not limited to field environment and material sampling, personal air monitoring, dermal sampling, and urine collection."
The research plan is drawing a mixed reaction from environmentalists and industry, with advocates pressing for a ban on the use of such fields by children younger than 6 years old until the research is complete and industry groups urging the agencies to clarify in any communications about the studies the levels of contaminants in the tire crumb rubber used to make the synthetic turf as well as reporting the chemicals and contaminants identified.
In its May 2 comments, Public Employees for Environmental Responsibility (PEER) criticizes the federal research plan, saying that it will only delay action, that it should focus more on lead and there should be some link to regulatory action. PEER calls for the agencies to "issue a joint public statement urging that tire-crumb not be installed as play surfaces for children under age 13 until a thorough risk assessment and analysis of toxic pathways has been completed"; to standardize and monitor the components used to make artificial turf, and for CPSC to declare playground and sports fields at schools to be children's products. The last action would place the grounds under the third-party testing requirements of the 2008 CPSC Improvement Act, which among other things limits lead content in children's products to 100 parts per million.
Similar concerns are raised by the Safe and Healthy Playing Fields Coalition, which joins PEER's call for CPSC to declare the artificial playgrounds and fields children's products, and expands the request by calling on the agencies to place a moratorium on construction of any new fields of this type. Further, the group describes concerns of cancer clusters of youth soccer players, particularly goaltenders, who they say have the greatest exposure to tire crumb rubber in artificial turf. The group notes the efforts of one Washington state soccer coach to gather the names and information on some 200 youth soccer players diagnosed with various cancers, the majority of them goaltenders.
"We respectfully request that an official study of the soccer player cancer cluster be initiated by [the Centers for Disease Control & Prevention] immediately," the group writes in its May 2 comments.
Meanwhile, the environmental group Delaware Riverkeeper Network, argues that in addition to human health concerns, the components of synthetic turf fields and playgrounds also pose environmental risks. The group's April 29 comments point to studies indicating that "[a]s rubber degrades it can leach toxic substances which can contaminate soil, plants and aquatic ecosystems."
The group argues that "it is also clear that additional study for water and other natural resources is needed."
By contrast, the Synthetic Turf Council, representing makers and installers of synthetic turf, calls on EPA and the other agencies to alter the federal research plan to add sampling controls of air and soil near the synthetic fields selected for the study, consider the risks and benefits of alternatives to synthetic fields, and report chemical components within synthetic fields "in context with regard to health-based guidelines," the association's May 2 comments say.
The group explains that "the identification of chemical compounds in recycled rubber must include context, i.e., a baseline below which the presence of those constituents has been determined to present no significant health hazards (e.g., health-based standards for toys) . . . if the presence of chemicals found at low levels is reported, the Agencies must provide context to that report by noting (if so) that the chemical compounds are present only at levels below which there is any significant risk. And, the Agencies should note whether such chemicals are also present in natural grass and dirt fields, especially those in urban and suburban settings, where contributions from pollutants deposited from vehicular exhaust, paint chips, and other dusts and debris are common."
The group adds that the industry uses two health-based guidelines in creating the synthetic fields, including European, CPSC and EPA lead standards in toys and soils and "Human health risk assessment models to estimate additional cancer risk from exposure to [polycyclic aromatic hydrocarbons (PAHs)] via the dermal and ingestion exposure pathways are benchmarked against exposure to background level of PAH's and arsenic in urban and rural soils."
The industry association explains that it has communicated its concern with local sampling controls to California's Office of Environmental Health Hazard Assessment(OEHHA), which is conducting its own research into synthetic turf fields and tire crumb rubber playgrounds. The sampling controls allow discovery of other potential sources of chemicals beyond the tire crumb rubber, the industry association argues, and as a reference to chemicals that may be found on grass fields and soils.
"Finally, failing to utilize adequate sampling controls will call into question the validity of the results of the federal research. We note that California OEHHA staff had initially not included control soil sampling in its research, but is reconsidering that position based on comments at a recent Public Meeting of its Synthetic Turf Scientific Advisory Panel . . ."
An industry coalition including the American Chemistry Council, National Manufacturers' Association and others raises these concerns as well, while also urging the agencies to analyze all existing peer-reviewed studies and to create a scientific review panel.
The industry groups call on the agencies to "engage in a comprehensive and thoroughly objective analysis of all available peer-reviewed research concerning crumb rubber and its composition, including studies on exposure. There has been much research on the issue, and it is vital that the agencies avoid selection bias when determining key knowledge gaps, which is one of the specific objectives indicated in the Federal Research Action Plan."
Regarding the review panel, the industry groups say that it "should be comprised of subject matter experts from industry, academia and the research community and would help minimize any duplication of efforts by the agencies. Importantly, the scientific review panel should provide comments on agencies' efforts."