PART 1 o 2: Response to the Board of Health's "Position Statement Synthetic Turf - 2013"

On October 30th, the Swampscott Board of Health (the “BofH”) issued its “Position Statement Synthetic Turf – 2013” (the “Statement”) recommending that certain alleged health concerns “be thoroughly addressed before moving forward with a synthetic turf project, including proof, beyond a reasonable doubt, that the chemicals associated with a synthetic turf do not pose a risk to human health, namely children’s health, and to the environment.”  As the former Chairman of the Athletic Field Study Committee (“AFSC”) and a current Executive Member of the Friends of Swampscott Athletic Fields, I write to assure residents and town officials of Swampscott that the AFSC reviewed carefully numerous health and environmental studies regarding the health concerns raised in the Statement and addressed the majority of them in our Findings and Recommendations provided to the Board of Selectmen on February 14, 2013.  I write to inform the public in greater detail about these alleged risks associated with products that might be used in the construction of an artificial turf field and, more importantly, to alleviate some of the unwarranted fears that the BofH appears to have raised.

The BofH’s Concerns

The BofH declares that the following health and/or environmental risks are associated with an artificial turf field:

·         The type of infill used in some artificial turf fields may contain various chemicals, exposure to which can pose a risk for human health or the environment;

o   Response:  The BofH focuses solely on one type of infill (the little granules used to simulate soil) – so-called “crumb rubber” from recycled tires; the AFSC proposes a quality, non-toxic, heavy-metal free alternative infill or an encapsulated infill that poses no such risks;

·         Certain synthetic grass has contained lead, which is commonly known to be a serious health risk;

o   Response: Synthetic grass containing lead is no longer used in the industry;

·         Tests conducted by BYU found that the surface temperature on some artificial turf fields can exceed 130° F when ambient temperatures are approximately 80° F, which can cause temporary heat and stress related illness; and

o   Response: Light-colored alternative infill substantially reduces such temperatures, and recreation official can simply close the field if temperatures reach unsafe levels;

·         Artificial turf fields can trap bacteria and the products used to disinfect them are “not declared safe, non-toxic or harmless for human health and the environment.”

o   Response:  Quality disinfectants are EPA registered as safe; wholly organic cleansers have also been used just as effectively to destroy and eliminate harmful bacteria.

1.         The BofH’s Infill and Synthetic Grass Concerns Are Moot, Exaggerated and/or Outdated.

            a.         The BofH’s Infill Concerns are Moot.

The BofH’s concerns about chemicals contained in crumb rubber and synthetic grass are moot, exaggerated and/or outdated.  The BofH’s concerns are exaggerated because, as discussed below, it chooses to ignore the clear majority of reputable governmental and private studies that have concluded that the use of plain crumb rubber infill for outdoor artificial turf fields is not a threat to human health or the environment.  The BofH’s concerns are moot because the AFSC elected to use a quality alternative to crumb rubber so that Town Meeting and its residents could focus solely on whether Swampscott is in a financial position to afford the proposed renovations.  And the BofH has known this for a year now.  As Chairman of the AFSC, I informed the BofH at its November 13, 2012 public meeting that the AFSC would recommend – and ultimately did recommend – the use of alternative, non-toxic infill products or an encapsulated crumb rubber that reduces by over 70% the already trace off-gassing that plain crumb rubber infill produces, while still providing a high-quality artificial turf infill.  And again at the May 2013 Annual Town Meeting at which the BofH attended, I reiterated that the proposed artificial turf field would not contain plain black crumb rubber.  Accordingly, the first concern of the BofH is moot.

b.         The BofH’s Crumb Rubber Infill and Lead-Filled Synthetic Grass Concerns Are Exaggerated and/or Outdated.

The BofH’s crumb rubber and synthetic grass concerns are also exaggerated and place unnecessary fear in the minds of Swampscott residents.  During its research, the AFSC found no federal, state or local environmental protection agency (or its equivalent) that declared, after detailed study, that modern artificial turf fields are a public health hazard.  Not one.  In our Findings and Recommendations, the AFSC conducted a thorough study of artificial turf fields and their components.  I personally read a number of these detailed studies.  Trust me, they are detailed, reaching over 80-120 pages in some cases.

Modern artificial turf fields are infill-type systems in which rubber granules (or an equivalent infill) are added to a flexible synthetic grass carpet to hold and stand the synthetic blades in place and provide a cushioned playing surface.  Sand may also be mixed with the infill.  The synthetic grass and infill are underlain with a crushed stone base and drainage pipes to facilitate rapid draining of the playing surface.  Several manufacturers provide this type of system for use on athletic fields.  Long gone are the days of “Astro-turf”:  short pile nylon fibers containing unacceptable levels of lead on top of a concrete surface.  Today’s artificial grass is made primarily of polyethylene that contains no lead.  Herein lies the out-of-date nature of the BofH’s Statement.  It reads that some synthetic grass contains lead, citing a New Jersey study from 2008.  But even a cursory read of that study reveals that the researchers tested 12 fields, finding that 10 of 12 fields were made of polyethylene and contained very low (and thus acceptable) or undetectable amounts of harmful chemicals.  The two fields that contained lead utilized old-fashioned nylon.  No reasonable proponent of a modern artificial turf field would propose the use of nylon-based synthetic grass.

Still, it would be misleading of me to suggest that public debate does not continue over potential environmental and health risks associated with the use of artificial turf, and particularly, crumb rubber infill.  Crumb rubber is made from recycled tires, which, as the Statement correctly reads, contains various chemicals that are considered volatile organic compounds (“VOCs”) or semi-volatile organic compounds (“SVOCs”), including poly aromatic hydrocarbons (“PAHs”).  Certain of these chemicals are known to cause cancer if exposed to heightened levels over sufficient periods of time.  While neither the town nor the BofH has conducted an independent analysis of synthetic turf systems, nationally and internationally a large body of research has been commissioned by government health agencies, universities, independent laboratories, and health and environmental organizations. 

Various government and private studies respecting crumb rubber or synthetic grass have concluded that (a) there are no public health concerns regarding the potential inhalation of VOCs, SVOCs or particulates in the breathing zone or by inadvertent ingestion; (b) artificial turf harbors fewer bacteria (e.g., antibiotic resistant Staphylococci) than natural turf; (c) the rate of skin abrasions per 1,000 player hours is two- to three-fold higher on artificial turf relative to natural turf; (d) more concussions occur on natural grass; (e) use of black-colored crumb rubber can increase surface temperatures to degrees exceeding 150º F on hot days; (e) rotational resistance injuries occur at no greater frequency or intensity than on quality natural grass fields; and (f) after a year of leach testing, no lead, selenium, or cadmium was found, and only trace amounts of zinc – well below water quality standard minimums – was found.  See California Dept. of Resources, Recycling and Recovery, Safety Study of Artificial Turf Containing Crumb Rubber Infill Made from Recycled Tires:  Measurements of Chemicals and Particulates in the Air, Bacteria in the Turf, and Skin Abrasions Caused by Contact with the Surface, 2-3 (Oct. 2010); Human Health Risk Assessment of Artificial Turf Fields Based upon Results from Five Fields in Connecticut (CT Dept. of Pub. Health, July 28, 2010) (concluding that the use of outdoor artificial turf fields was not associated with elevated health risks, and noting that their conclusions were consistent with the findings and studies conducted by New York City, New York State, the US EPA and Norway, which tested different artificial turf fields under different weather conditions); French Nat’l Inst. for Indus. Env. and Risks, Environmental and Health Evaluation of the Use of Elastomer Granulates (Virgin and from Used Tyres [sic]) As Filling in Third-Generation Artificial Turf, 13 (2007) (“From an ecotoxological point of view, the nature of percolates having passed through 3rd generation artificial pitch are proven to be without impact on the environment, irrespective of the type of [infill]”); see also U.S. EPA, Playgrounds and Synthetic Turf Fields (Dec. 12, 2011) (stating that “EPA does not believe that the field monitoring data collected provides evidence of an elevated health risk resulting from the use of recycled tire crumb in playgrounds or in synthetic turf athletic fields.”); Letter from Bedford Bd. of Health to Bedford Outdoor Recr. Area Study Comm., (Sept. 11, 2012) (citing a number of the above studies in support of conclusion that artificial turf field components do not cause heightened risk to human health). 

One private company believes otherwise.  A study by Environmental & Human Health, Inc., conducted for the Connecticut Agricultural Experiment Station, concluded that plain crumb rubber releases chemical compounds into the air and ground water and thus constituted a chemical exposure for human beings and the environment, but further stated that more research was needed.  See Brown, David R. Artificial Turf:  Exposures to Ground-Up Rubber Tires:  Athletic Fields, Playgrounds, Gardening Mulch (Environmental & Human Health, Inc. 2007).  Tthe Connecticut Department of Public Health subsequently issued a fact sheet about synthetic turf and concluded, “Based upon current evidence, a public health risk appears unlikely.”  CT Dept. of Pub. Health, Fact Sheet, Artificial Turf Fields:  Health Questions, 1-2 (Oct. 2007) (citing studies from NJ, CA, Norway and Sweden concluding there is no public health threat); NY Dept. of Public Health, Fact Sheet:  Crumb-Rubber Infilled Synthetic Turf Athletic Fields (Aug. 2008) (same).

It is widely known that Massachusetts has strict environmental regulations.  The Commonwealth would hardly allow the Executive Office of Energy and Environmental Affairs to award PARC Grants to municipalities seeking to install artificial turf fields with plain crumb rubber infill if it had legitimate concerns that it was dangerous to health or the environment.  To be sure, the Commonwealth has recently awarded PARC Grants to Gloucester, Tewksbury and Salem for artificial turf fields, and each of them is using or plans to use plain crumb rubber as its infill product.  Moreover, the Massachusetts Department of Public Health informed the town of Needham that it was satisfied with the majority of studies indicating that plain crumb rubber is safe for humans and the environment, but it also suggested using an alternative infill product – the same one that the AFSC recommended to make this issue moot.  See Letter from Mass. Dept. of Pub. Health to Needham Bd. of Health (April 29, 2008) (recognizing that the comprehensive study in California concluded that “exposure opportunities to [crumb rubber] materials would not be expected to result in health effects”).

The AFSC’s research found that thermoplastic elastomer (“TPE”) infill is a sound alternative to crumb rubber infill and its quality exceeds that of any organic infill (such as cork blends or coconut husk mixes).  Because good quality TPE is manufactured specifically from virgin plastics, it does not contain any of the VOCs, SVOCs or PAHs found in crumb rubber infill.  TPE infill is non-toxic, heavy metal free, available in a variety of colors and keeps surface temperatures 30% cooler than black crumb rubber.  TPE is also long lasting and is 100% recyclable and reusable.  TPE infill offers consistent performance and g-max ratings over a wide temperature range.  TPE products have been approved by countries with strict rules and tight controls on building materials, such as the Dutch Soil Quality Decree and the INTRON Certification Institute.  Unfortunately, TPE costs up to $70,000 more per field than crumb rubber infill.  Another infill, encapsulated crumb rubber, reduces by 70% the already trace amount of off-gassing that plain crumb rubber produces, is less expensive than TPE, and also comes in light colors to reduce surface temperatures.

See PART 2 of 2.