[No. 7] Consumer Product Safety Commission “corrects” is earlier publication on artificial turf. On 30 July 2008, the CPSC issued a press release [08-348]. On 21 March 2013, Public Employees for Environmental Responsibility (PEER) requested that CPSC “rescind and correct its online and printed information declaring artificial turf to be ‘OK to install, OK to play on,’” and take other actions under the Information Quality Act (IQA) and the Consumer Product Safety Commission’s (CPSC) Information Quality Guidelines (Guidelines). On 31 May 2013, the Assistant Executive Director of CPSC’s Office of Hazard Identification and reduction denied PEER’s request. On 28 June 2013, PEER appealed the denial, asserting that the CPSC’s July 2008 Analysis and Assessment of Synthetic Turf Grass Blades and accompanying press release did not satisfy the Guidelines’ standards for objectivity because it did not use reliable data sources; did not use sound analytic techniques; did not have a clear policy for correcting the errors in the study as they stood or in light of new reliable data from elsewhere; and the press materials were not supported by the admittedly limited study conducted by CPSC staff.
On 28 August 2013, the Executive Director of the CPSC dismissed the appeal, denying PEER’s request that the CPSC to remove information, disseminate warnings, and commission an independent study. The July 2008 analysis, the Director ruled, described the assessment’s limited scope, used best date available at the time, and relied upon valid analytic techniques. However, given the limitations of the CPSC’s July 2008 assessment, CPSC found that an explanatory note was warranted at the start of the July 2008 bulletin. The language of the note as it now appears on the publication, states:
Note: CPSC staff advises consumers to read and interpret the following press release carefully. The press release announces that CPSC staff evaluated certain samples from synthetic athletic fields in 2008, and determined at that time that young children were not at risk from lead exposure on synthetic fields. As noted in the linked evaluation, staffs assessment was subject to specified limitations including sample size. The exposure assessment did not include chemicals or other toxic metals, beyond lead. CPSC staff continues to recommend that children wash their hands after playing outside, including after using synthetic athletic fields.
[No. 06]Consumer Reports criticizes CPSC’s position on lead in artificial turf. On September 5, 2008, ConsumerReprts.com published apiece entitled “Federal agencies at odds over artificial turf recommendations.” The article is available http://blogs.consumerreports.org/safety/2008/09/lead-in-turf.html .The article highlighted the positions taken by the U.S. Consumer Product Safety Commission, which thinks says turf fields are safe to play on, and the Centers for Disease Control, which recommends certain precaution and following certain hygienic protocols when playing on artificial turf fields. In questioning the CPSC’s position, the article criticizes the agency’s limited research and its inadequate methodology. The publication pointed out CPSC’s belief that even some fields contain some lead, they do mostly fall within the acceptable range. Consumer reports pointed out that the AmericanAcademy of Pediatrics “has stated that there is no safe level of lead exposure. Yet, the CPSC’s conclusions express risk in terms of what they have established as harmful levels. We think their analysis and conclusions should be consistent with those of the medical community. They should take into account that athletic fields are not the only source of exposure to lead and that it's important to eliminate avoidable sources of exposure.” For the text of the article, go tohttp://blogs.consumerreports.org/safety/2008/09/lead-in-turf.html or click here.
[No. 05] Connecticut Attorney General slams CPSC’s turf report as dangerously deceptive. On August 19, 2008, the Connecticut Attorney General Richard Blumenthal called on the CPSC to remove and revise its recent turf study because it is “dangerously deceptive.”“There is a clear and present danger that municipal and state decision makers -- as well as parents and citizens -- will rely on this unconscionably deficient report,” which is “replete with unsound scientific methodology and conclusions, and unreliable findings.” “It may lead to unsupportable and unwise commitments by towns and cities or their boards of education to build or replace athletic fields.” The text of the press release is available at http://www.ct.gov/ag/cwp/view.asp?A=2341&Q=421482and here.
[No. 04] Connecticut Congresswoman slams CPSC’s turf report as hasty and flawed. On August 7, 2008, the U.S. Congresswoman Rosa DeLauro of Connecticut sent a letter to the acting chairwoman of the U.S. Consumer Product Safety Commission, slamming the agency’s report on lead in synthetic turf fields as hasty and flawed. She called for a thorough investigation. The texts of the press release and letter are available athttp://www.house.gov/delauro/press/2008/August/Flawed_Report_8_8_08.htmland here.
[No. 03] CPSC says, ‘Turf industry should get out the lead, but fields are okay to play on!' SynTurf.org, Newton, Mass. August 3, 2008. On July 30, 2008, the Office of Information and Public Affairs at the U.S. Consumer Product safety Commission issued Release # 08-348: CPSC Staff Finds Synthetic Turf Fields OK to Install, Ok to Play On. The Release referenced an evaluation “of various synthetic turf fields” by the CPSC staff, which concluded that “young children are not at risk from exposure to lead in these fields.” The Release is available on-line at http://www.cpsc.gov/cpscpub/prerel/prhtml08/08348.html (or here) and the Evaluation is available at http://www.cpsc.gov/library/foia/foia08/os/turfassessment.pdf (or here). Here are results of the Evaluation, as stated in the Release:
CPSC staff evaluation showed that newer fields had no lead or generally had the lowest lead levels. Although small amounts of lead were detected on the surface of some older fields, none of these tested fields released amounts of lead that would be harmful to children.
Lead is present in the pigments of some synthetic turf products to give the turf its various colors. Staff recognizes that some conditions such as age, weathering, exposure to sunlight, and wear and tear might change the amount of lead that could be released from the turf. As turf is used during athletics or play and exposed over time to sunlight, heat and other weather conditions, the surface of the turf may start to become worn and small particles of the lead-containing synthetic grass fibers might be released. The staff considered in the evaluation that particles on a child’s hand transferred to his/her mouth would be the most likely route of exposure and determined young children would not be at risk.
The CPSC’s evaluation concerned only the presence of lead in carpet fibers or paint that is applied to the carpet. It did not analyze lead that is often contained in the crumb rubber. No other aspect of artificial turf fields was considered. Nor did the CPSC consider the possibility of potential risk to children in whom the micron of lead ingested or inhaled from artificial turf may well be the tipping point for rendering the accumulated lead level in a child to an unacceptable level.
The presence to lead is not just in the old carpet. As the Release stated, “CPSC staff evaluation showed that newer fields had no lead or generally had the lowest lead levels.” This is not exactly declaring the turf “lead free,” particularly when it is not made clear what constitutes a “newer field.” By all measure, the turf field at Saunders Stadium in South Boston ( http://www.synturf.org/lead.htmlItem No. 9) that was ripped out in June of this year was “newer,” it being in its fifth year. SynTurf.org collected a sample of field’s yellow-lined turf and sent it to from that site was sent for a lead-testto the Center for Environmental Health in Oakland, California. Using a X-ray Fluorescence analyzer, the CEH reported the “yellow turf” to have 7,997 parts per million (mg/kg) of lead. The U.S. Environmental Protection Agency has established 400 ppm as allowable level of lead in children’s play areas. The Massachusetts Department of Environmental Protection would allow soil in lined landfills with maximum lead contamination of 2,000 ppm, and only 1,000 ppm in unlined landfills.
The CPSC is nevertheless concerned about lead in artificial turf. The Release stated, “Although this evaluation found no harmful lead levels, CPSC staff is asking that voluntary standards be developed for synthetic turf to preclude the use of lead in future products. This action is being taken proactively to address any future production of synthetic turf and to set a standard for any new entrants to the market to follow.” As for now, As an overall guideline, CPSC staff recommends young children wash their hands after playing outside, especially before eating.” On Wednesday, July 30, 2008, the U.S. House of representatives voted 424-1 to ban lead in kids’ products. The legislation “would impose the toughest lead standards in the world, banning lead beyond minute levels in products for children 12 or younger.” Associated Press, “House votes to ban lead in kids’ [products,” in The Boston Globe, July 31, 2008, Business section, page E3, available also at http://www.boston.com/business/articles/2008/07/31/house_votes_to_ban_lead_in_kids_products/ . Perhaps, with a Democrat in the White House, come January 2009, the CPSC could order the elimination of lead from artificial turf products.
Following the CPSC Release, the turf industry went into spin mode and extracted every ounce of propaganda for its cause – it took the point that CPSC had made about lead and turned it into a declaration or clean bill of health for the turf as a whole. See, for example, “FieldTurf Applauds 'Clean Bill of Health' Given to Synthetic Athletic Fields by U.S. Consumer Product Safety Commission,” in PrimeNewswire, July 30, 2008, available at
The CPSC’s characterization of turf fields as safe for kids drew fire from Environment and Human Health, Inc of North Haven, Connecticut, and the Center for Environmental Health, in Oakland, California.
David Brown, Sc.D., the Public Health Toxicologist, Environment and Human Health, Inc. (www.ehhi.org) made the following preliminary observations about the the CPSC’s methodology and assumptions:
The USCPSC report sampled only 10 tests on four fields. There were three samples on three fields and one sample on one other field. How many fields are there in the United States? The answer of course is thousands.
The table is padded with other turf data (less than 10) from unspecified sources with no relevancy to the fields in actual use.
They wiped an area 50 cm long and 8 cm wide (18 inches long and 3 inches wide). Your hand is about 4 inches wide and 8 inches long.
Next they divided the amount of lead found by 5 -- because they assumed that the hand is not as efficient at picking up lead as their wipe. They then divided that number obtained again by 2 -- because they assumed that only half of the lead could be taken from one's hand and then become ingested.
Their determination of a safe reference exposure:
1.They compared the exposure to a blood level of 10 ug/dl as their level of concern - although current peer reviewed literature clearly demonstrate health effects in children below that level.
2.They than reference a position that chronic ingestion of lead should not exceed 15 ug/day. They then incorrectly assumed that the "not to be exceeded" level was an acceptable exposure level, which it is not.
This rationale makes no sense because of the following incorrect assumptions:
Assumption 1. The child has no other exposures to lead each day. The assumption is clearly incorrect based on population studies published by the centers for Disease Control and Prevention.
Assumption 2. During an athletic activity the child only touches the surface with one hand one time each day. This assumption is ludicrous if anyone has observed any athletic activity on any playing field.
Assumption 3. That four fields would be considered adequate to evaluate the safety of the thousands of fields in the United States and then to characterize to the American people that this is a NATIONWIDE evaluation. UNBELIEVABLE
Assumption 4. It is acceptable to ignore the key chemical reaction between the acidity in the moisture on the surface and the release of lead bound in the material. A reading in a basic high school chemistry text shows that highly soluble lead carbonate dust is formed when items containing lead are exposed to air containing carbon dioxide in humid atmosphere such as occurs every morning when dew forms on the surface of the fields
Assumption 5. Most of the lead on the surface is not released on the first pass over the surface. While there may be multiple passes over the surface there is no basis for a division by 5 or any other number, most of the lead is released by the first touch although additional lead is picked up with further wipes. If the CPSC had wiped the field 100 times would they have divided the amount obtains on their sample wipe by 100?
It should be apparent to even the most casual observer that the CPSC test report cannot support any conclusion with respect to the health risk of children to exposure to lead from artificial turf fields. Moreover, lead has never been the only or even major concern from the health scientists.
In an e-mail, dated 31 July 2008, Nancy Alderman, the President of EHHI wrote:
The story being told in response to the U.S. Consumer Product Safety Commission (USCPSC) declaring that synthetic turf fields safe because they do not contain lead, is extremely misleading. This declaration of "safety" is misinforming the public about what the potential risks from synthetic turf really are.
Environment and Human Health Inc. (EHHI) remains as concerned as ever about the synthetic turf fields that are being installed by schools and towns all over the United States. EHHI is a 9 - member, nonprofit organization composed of physicians, public health professionals and policy experts dedicated to protecting human health from environmental harms through research, education and improving public policy. EHHI is supported by foundations and receives no funding from either businesses or corporations.
When Environment and Human Health, Inc., (EHHI) researched the health issues presented by synthetic turf fields it looked at the ground-up rubber tire in-fill that is a major component of synthetic turf. The in-fill is made of used rubber tires. In some states used rubber tires are considered a "hazardous" waste and in other states they are considered a "special" waste.
When the he U.S. Consumer Product Safety Commission (USCPSC) tested the fields they only tested the plastic or nylon fake grass for lead. Not finding lead in their extremely small sampling of fields --- the USCPSC then declared all fields safe. They never even looked at the ground-up rubber tire in-fill for its health risks - which remain an enormous worry.
When the Connecticut Agricultural Experiment Station tested the ground-up rubber tire in-fill they found the following five compounds.
Benzothiazole: Skin and eye irritation, harmful if swallowed. There is no available data on cancer, mutagenic toxicity, teratogenic toxicity, or developmental toxicity.
Butylated hydroxyanisole: Recognized carcinogen, suspected endocrine toxicant, gastrointestinal toxicant, immunotoxicant (adverse effects on the immune system), neurotoxicant (adverse effects on the nervous system), skin and sense-organ toxicant. There is no available data on cancer, mutagenic toxicity, teratogenic toxicity, or developmental toxicity.
n-hexadecane: Severe irritant based on human and animal studies. There is no available data on cancer, mutagenic toxicity, teratogenic toxicity, or developmental toxicity.
4-(t-octyl) phenol: Corrosive and destructive to mucous membranes. There is no available data on cancer, mutagenic toxicity, teratogenic toxicity, or developmental toxicity.
Zinc: There is a very large amount of zinc that is added in the manufacturing of tires and therefore there is a great deal of zinc in ground-up rubber tire in-fill.
Besides those chemicals, rubber tires often contain:
Saying these fields are now safe because they do not contain lead is like saying that diesel exhaust is safe because it does not contain lead - or cigarettes are safe because they don't contain lead - neither of course is true.
On July 30, 2008, the Center for Environmental Health (www.cehca.org ), in Oakland, California, issued a press release calling attention to fatal flaws in CPSC’s findings on artificial turf. “The Center for Environmental Health is disappointed but not surprised that the CPSC has today released a flawed analysis of the dangers to children from artificial turf.” stated Executive Director, Michael Green. “CPSC’s turf analysis uses a lead standard that is 30 times less protective than California law and an approach that wasdesigned for testing arsenic-treated wood that was not developed for use with turf.” said Caroline Cox, CEH Research Director. The CPSC evaluation is based on the outdated assumption that exposure of 15 micrograms of lead per day is acceptable for children. The California standard is 30 times more protective, and current science suggests that no level of exposure to lead is safe for children. For example, the U.S. Public Health Service states, “No safe blood lead level in children has been determined.” The CPSC evaluation does not consider that children will contact turf multiple times while playing, thus making multiple exposures to lead likely. The CPSC, based only on what the agency calls “limited hand sampling,” minimizes the potential for children to be exposed to lead, by assuming that children will be exposed to five times less lead than the agency’s protocol actually found. The CPSC’s data shows clearly that lead exposure increases dramatically as turf ages. CPSC ignores the problem that exposure estimates from new turf significantly underestimate real-life exposure. To date, CEH has tested over 150 turf samples, including dozens of samples sent to the nonprofit by concerned customers. By contrast, CPSC’s report shows they tested only 14 samples. Source: CEH (Press release), “Consumer Watchdog Finds Fatal Flaws in CPSC Findings on Artificial Turf,” July 30, 2008, available at http://www.cehca.org/press-releases/eliminating-toxics/consumer-watchdog-finds-fatal-flaws-in-cpsc-findings-on-artificial-turf/ .
The U.S. Consumer Product Safety Commission is looking into the presence of lead in artificial turf fields. See http://www.synturf.org/lead.html (Item No. 01). This page is dedicated to the CPSC's proceedings in this regard. It is apt that the first item published here be the letter from the New Jersey Department of Health and senior Services to the CPSC that prompted the agency to begin an investigation in to safety of artificial turf fields.
For the text of the letter from Dr. Eddy Bresnitz, Deputy Commissioner of New Jersey Department of Health and Senior Services and State Epidemiologist, dated Trenton, April 11, 2008, to Patricia Semple, Executive Director of the U.S. Consumer Product Safety Commission, Washington, D.C. click here.
[No. 02] CPSC testing of artificial turf results due in late summer. According to
[No. 01] CPSC’s roundtable on lead to meet May 13. On May 13, 2008, the U.S. Consumer Product Safety Commission will host a roundtable on the current lead legislation about the use of lead in consumer products. Among those expected to participate in the roundtable is Hardy Poole, Director of Regulatory and technical Affairs of the national textile Association. Also featured is Rick Doyle, the President of the Synthetic Turf Council. Poole may well speak to the issue of lead in turf fibers, while Doyle is expected to address the presence of lead or its toxicity in artificial turf fields. For the agenda of the meeting and name of other participants, click here.