|[No. 01] The Westport Brief: Citizens Question Safety of Rubber Crumb in Artificial Turf, by Guive Mirfendereski, www.SynTurf.org, Newton, Mass., Launched: September 28, 2007; Revised with corrections and a section on Wellesley, Mass.: September 30, 2007; revised November 12, 2007.
THIS article provides a recounting of the efforts of a few concerned mothers in Westport, Connecticut, who raised questions about dangers of artificial turf and in the process got the state’s attention.
Previously, surveys and tests had claimed that the crumb rubber, which is made mostly of ground up used tires, posed no threat to human health. That myth is now being debunked by the results of a new test commissioned by Environment and Human Health, Inc., a North Haven, Connecticut, non-profit organization (http://www.ehhi.org) dedicated to protecting human health from environmental harms through research, education and improving public policy.
In the words of EHHI’s director of toxicology, Dr. David Brown: “Although the health implications are unclear, the evidence is sufficient to create a burden of proof of safety before more fields are installed. Therefore, EHHI stands by its recommendation that no new fields that contain ground up rubber tire crumbs be installed until additional research is been done.”
The saga that eventually has become the Westport brief began neither this year nor in Connecticut. Its origins lie in the work of William Crain and Junfeng Zhang in the spring and Summer 2006. The duo became interested in the possible presence of toxicants in the rubber granules that are applied loosely on the surface of the artificial turf field. Because the granules are much more accessible to children and athletes than they had supposed, they decided to analyze a sample for two possible sets of toxicants -- polycyclic aromatic hydrocarbons (PAHs) and toxic metals. The duo first collected a sample from Manhattan's Riverside Park in May 2006, and they gathered a second sample in June 2006 from a different part of the park. The analyses on both samples were conducted at the Environmental and Occupational Health Sciences Institute of Rutgers University. Dr. Crain paid for the analyses.
The PAH results for the first sample showed six PAHs were above the concentration levels that the New York State Department of Environmental Conservation (DEC) considered sufficiently hazardous to public health to require their removal from contaminated soil sites. The study also stated that it was highly likely that all six PAHs are carcinogenic to humans. The PAH results for the second sample showed the concentration levels of the six PAHs were above the DEC's tolerable levels for soil.The analyses revealed levels of zinc in both samples that exceed the DEC's tolerable levels. Lead and arsenic also were present, and many scientists believe that these metals should not be introduced into the environment at all.
”We want to emphasize that the findings are preliminary,” the professors wrote. “PAHs in rubber might not act the same way as in soil, and we do not yet have information on the ease with which the PAHs in these rubber particles might be absorbed by children or adults -- by ingestion, inhalation, or absorption through the skin.” They concluded: “However, the findings are worrisome. Until more is known, it wouldn't be prudent to install the synthetic turf in any more parks.”
In Spring 2007, three Westport residents -- Tanya Murphy, Stacy Prince and Patricia Taylor – began asking questions about the harm that may come to children from the crumb rubber used on artificial turf fields. The town had two synthetic turf fields and planned to install two more. Armed with the Crain-Zhang study in Rachel’s Democracy & Health News, Stacy Prince contacted the local officials and a reporter from Westport News, Frank Luongo. Luongo’s coverage of the story piqued Patricia Taylor’s interest in the subject and she contacted first Prince, then Environment and Human Health, Inc. In May 2007, Tanya Murphy published a piece in Westport News, entitled “Organic Fields Are the Way to Go” and contacted EHHI with her concerns bout the harmful effect of the ground-up tires used in turf.
Enter, Environment and Human Health, Inc.
To parents of school age children and environmentalists, Environment and Human Health, Inc. is well known for its pivotal role in a series of state laws dealing with banning pesticides from school and day care centers, and regulating the sale and storage of lawn care pesticides. Previously, Dr. Brown had been helpful to Patricia Taylor’s understanding of the state’s voluntary program and federal regulations pertaining to remediation that Westport had to undertake in order to clean up a contaminated site that it had purchased for school use.
EHHI is composed of physicians, public health officials and policy experts. Nancy Alderman, MES, is the president. Besides Ms. Alderman and the aforementioned Dr. Brown, the organization’s board of directors includes also Susan Addiss, past Commissioner of Health of the State of Connecticut; Dr. Barry Boyd, an oncologist at Greenwich Hospital; Mark Cullen, professor of Medicine and Public Health at Yale University School of Medicine; Robert LaCamera, Clinical Professor of Pediatrics at Yale University School of Medicine; William Segraves, Associate Dean of Yale College and Dean's Adviser on Science Education; Hugh Taylor, an associate professor at Yale University School of Medicine’s Department of Obstetrics, Gynecology and Reproductive Sciences and Department of Molecular, Cellular and Developmental Biology; and John Wargo, who is Director of the Yale Program on Environment and Health and author of Our Children's Toxic Legacy. The board also includes Russell Brenneman, co-Chair of the Connecticut League of Conservation Voters and co-Chair of the Connecticut Greenways Committee.
The aforementioned comprise an extraordinary group of experts in the field of medicine and public policy. So when they, the EHHI speak, others listen:
“In the spring of 2007 Environment and Human Health Inc., received numerous inquiries about health concerns with respect to children’s exposures to ground-up rubber tire “crumbs” that are the in-fill material in the new synthetic turf fields. Such fields have been installed, or are being proposed, in towns all over Connecticut and many other states.
“The safety information about the new synthetic fields has mainly focused on the health benefits from the reduction of joint injuries due to the use of the rubber tire crumbs in the new fields. Public health analysis of the health risks from human exposures from the rubber crumb has not been adequately addressed up to this point.
“Research finds that the new synthetic fields are surfaced with a product called “in-fill” that is made from recycled tires. This material is referred to as “tire crumbs” and constitutes the primary playing surface. We estimate these crumbs to be as much as 90% by weight of the fields. The tire crumbs are roughly the size of grains of course sand. They are made by shredding and grinding used tires. Tire crumb materials are spread two to three inches thick over the field surface and packed between ribbons of green plastic used to simulate green grass.
“Review of the immediately available literature about these new fields found that similar health concerns had been raised in other states as well as in other countries. In addition to athletic fields, shredded tires are being used on playgrounds and as gardening mulch.
“There have been some studies done on the health effects from exposures to the rubber crumb material, but many of these studies present only partial assessments of the human health risk potential. As well, many studies have major data gaps with respect to the chemicals released, as well as the actual levels of exposures to humans and the environment.
”From the information that is available, it was found that tire crumbs contained volatile organic hydrocarbons (VOCs) with carcinogenic potential, which could be extracted from the crumbs in the laboratory. Health reports from workers in the rubber fabrication industry and in the rubber reclamation industry describe the presence of multiple volatile organic hydrocarbons, semi-volatile hydrocarbons and other toxic elements in the air. Studies at tire reclamation sites report the leaching of similar sets of chemicals into the ground water. Occupational studies document a spectrum of health effects ranging from severe skin and eye irritation and respiratory irritation to three forms of cancer.
“The relationship between exposures to the rubber workers and those experienced by people using athletic fields or children in playgrounds covered with ground-up rubber tire material is not known, but we do know that many of the same chemicals that rubber workers are exposed to are being released from the ground-up rubber tire crumbs.
“Based on uncertainty with respect to what these exposures mean for children’s health, as well as the environmental leaching of the materials into the ground water, EHHI decided to initiate an exploratory study with the Connecticut Agricultural Experiment Station to determine the chemicals released into the air and water under ambient conditions.”
On July 9, 2007, the EHHI issued a press release asking for a moratorium on the installation of new fields until the CAES study is completed. The release stated that EHHI's public health toxicologist was concerned that some organic compounds from the crumb rubber could affect children's respiratory health as well as having other health effects.
Enter, Connecticut Agricultural Experiment Station: The CAES Study
Established in 1875, the Connecticut Agricultural Experiment Station (CAES) in New Haven, Connecticut, is a state-sponsored research institution that aims to develop, advance, and disseminate scientific knowledge, improve agricultural productivity and environmental quality, protect plants, and enhance human health and well-being through research for the benefit of Connecticut residents and the nation. As its motto “Putting Science to Work for Society” suggests, the mission of the Station is to seek solutions across a variety of disciplines for the benefit of urban, suburban, and rural communities.
In June 2007 EHHI contacted CAES’s Department of Analytical Chemistry to ascertain if the Department’s laboratory would be willing to examine crumb rubber produced from used tires. Given time and personnel limitations, the Department agreed to conduct a very modest study of the material. Funding in the amount of $2000 was received from EHHI to offset the cost of items such as analytical and instrumental supplies and chemical standards. On August 8, 2007, the Department released its preliminary results and on August 17th CAES issued its report, entitled “Examination of Crumb Rubber Produced from Recycled Tires.” The results came back positive, showing that hazardous metals in the turf granules leach into water, and that at 140 degrees Fahrenheit (a temperature that synthetic turf can reach during summer), other toxic chemicals are released into the air.
The study posed and answered three questions:
1. Are compounds volatilizing or out-gassing from the tire crumbs? It found organic compounds volatilizing from tire crumbs, consisting mainly of benzothiazole, butylated hydroxyanisole, n-hexadecane and 4-(t-octyl) phenol.
2. What is the identity of the volatilized compounds derived from the tire crumbs? It identified benzothiazole, hexadecane, 4-(tert-Octyl)-phenol and butylated hyroxyanisole or BHT alteration product among the main compounds that out-gassed for crumb rubber in vapor phase concentrations.
3. Can organic or elemental components be leached from the tire crumbs by water? It found the elements zinc, selenium, lead and cadmium to be among the main substances that leach into water from crumb rubber.
The CAES study concluded:
“The laboratory data presented here support the conclusion that under relatively mild conditions of temperature and leaching solvent, components of crumb rubber produced from tires (i) volatilize into the vapor phase and (ii) are leached into water in contact with the crumbs. We note with interest that when we placed the black crumbs in direct sunlight at an exterior air temperature of 88 ºF, a thermometer inserted directly into the crumbs registered 55 ºC (=131 ºF). Selection of 60 ºC, therefore, is not beyond a reasonable temperature range accessible under field conditions.
“Based on these data further studies of crumb rubber produced from tires are warranted under both laboratory, but most especially field conditions. In particular examination of compounds volatilizing from the crumbs under exterior conditions and collected at varying heights and seasonal conditions at installed fields should be compared with background levels. It is also logical to determine airborne particulate matter deriving from the product under the same conditions.” 
Bottom-line: On the basis of the information attributed to the Material Safety Data Sheet for each chemical, benzothiazole is a skin and eye irritant that can be harmful if swallowed or inhaled; hexadecane is a carcinogen, while 4-(tert-Octyl)-phenol can cause burns and is destructive of mucous membranes.” The fourth chemical -- butylated hyroxyanisole -- is an irritant.
The EHHI Report on the CAES Study
On August 29, 2007, EHHI released its report on the study just conducted on rubber crumb at the Connecticut Agricultural Experiment Station. Titled Exposures to Recycled Tire Crumbs used on Synthetic Turf Fields, Playgrounds and as Gardening Mulch.
In the words of the EHHI Report “Summary and conclusions” section:
“The Connecticut Agricultural Experiment Station study conclusively demonstrates that the tire crumbs and tire mulch release chemical compounds into the air and ground water. Thus, tire crumbs constitute a chemical exposure for humans and the environment. It is clear the recycled rubber crumbs are not inert, nor is a high temperature or severe solvent extraction needed to release metals, volatile organic compounds or semi-volatile organic compounds. The release of airborne chemicals and dust is well established by the current information. The Connecticut Agricultural Experiment Station research conclusively demonstrates that release can occur under ambient conditions experienced in the summer in Connecticut.
“Those published health assessments that indicate de minimis risk should not be applied to the synthetic turf paradigm and may not be appropriate for playgrounds with open layers of recycled tire crumbs.
“Health endpoints of concern are numerous, including acute irritation of the lungs, skin and eyes, chronic irritation of the lung, skin and eyes. Knowledge is somewhat limited about the effects of semi-volatile chemicals on the kidney, endocrine system, nervous system, cardiovascular system, immune system, developmental effects and the potential to induce cancers.
“There are still data gaps that need to be filled in and additional studies are warranted.
It is prudent to conclude that there will be human exposures to chemicals released during the use of synthetic turf fields.
“The excess amount of zinc in the rubber tire mulch makes it unacceptable to be used in gardens.”
The heart of EHHI Report consisted of a discussion of the “potential health and environmental risks” associated with the use of crumb rubber in artificial turf. The CAES study “found out-gassing and leaching from synthetic turf rubber crumbs under aqueous ambient temperatures. Several compounds were present, but four compounds gave the highest responses on GC/Mass spectrographic analysis. The four compounds conclusively identified with confirmatory tests were: benzothiazole; butylated hydroxyanisole; n-hexadecane; and 4-(t-octyl) phenol. Approximately two dozen other chemicals were indicated at lower levels. These chemicals were released in laboratory conditions that closely approximate ambient conditions.”
According to EHHI, the chemicals identified in the CAES Study have the following reported actions:
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, neurotoxicant, 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.
Furthermore, the study detected metals that were leached from the tire crumbs. Zinc was the predominant metal, but selenium, lead and cadmium were also identified.
“Many, if not most, of the compounds present in tire crumbs and shreds have incomplete testing for human health effects. In some cases a partial assessment can be based on the estimated actions of chemical class or on structural activity characteristics. Ascertaining the toxic actions of the chemicals identified in the analytical test is dependent on the levels of research that have been performed and reported in the appropriate literature.”
According to EHHI Study, [t]he toxic actions of concern from the materials that were released from recycled crumb rubber include severe irritation of the respiratory system; severe irritation of the eyes, skin and mucous membranes; systemic effects on the liver and kidneys; neurotoxic responses; allergic reactions, cancers; and developmental effects.
In regard to cancer, some of the compounds are identified as known or suspected carcinogens. “One especially relevant report addressed exposures in a factory in Taiwan that made tire crumbs. In that study, mutagenic actions that were four to five times higher than in controls were shown in extracts of particulate matter collected in the air. These results indicate that the organic-dissolved portion of rubber particles contains various nitre-containing vulcanization stabilizers and accelerators, as well as process degradation products. Benzothiazole and 9-octadecenamide were identified as structures that would be converted to the N-nitrosamines under certain conditions.” Furthermore, “[a] 2006 Rutgers University study of tire crumbs taken from synthetic turf fields in New York City identified six polycyclic aromatic hydrocarbons (PAHs) at levels that reportedly exceeded the regulatory levels in New York State. These six compounds are highly likely to be carcinogenic to humans.”
In regard to allergic responses, there is cause for a moderate level of health concern. “Inadequate data is available to address the concerns about allergic reactions, but it is possible that sensitized individuals will respond to the exposures. With so many children having asthma today, this is a real concern.”
The most common action identified in the literature for the chemicals identified in the CAES is skin, eye and respiratory irritation. “Other actions reported are thyroid effects, neurological effects and systemic toxicity related to the liver and the kidneys. There is insufficient exposure information to assess whether these effects would be seen with the releases from recycled tires used on synthetic turf field or in gardening mulch.”
In regard to the release of metals to environmental media, the EHHI report stated: “The metals zinc, cadmium and lead were also identified as contaminants from tire rubber released into ground water. With the exception of zinc, there is insufficient data to assess the health or environmental risks of any of these metals. It appears clear that the zinc levels are high enough to be phytotoxic if they enter the ground water or soil. It is doubtful that there is any human toxicity from zinc at the levels reported, but such a conclusion would have to be tested by more careful study.”
“Finally,” the EHHI report stated, “the particulate exposures due to tire dust and chemicals contained in the dust that can be released in the lungs are especially troublesome. Nearly every test adequate to assess the risk that was reported found one or two dozen compounds released from particulates. There are processes in the body that can release the chemicals contained in the rubber particles. Moreover, potent carcinogens are found in the tire dust. Only the assumption of limited exposure could support the conclusions of low cancer risk.”
On the basis of the CAES Study, EHHI urged a moratorium on the installation of artificial turf fields until studies can be made of health risk from exposure to crumb rubber. “Nancy Alderman, president of EHHI, said, "There is enough information now concerning the potential health effects from chemicals emanating from rubber tire crumbs to place a moratorium on installing any new fields or playgrounds that use ground-up rubber tires until additional research is undertaken."
Pivotal to EHHI’s call for a moratorium was a set of studies from Norway and Sweden. Each of them “recommended that there be no further construction of fields with rubber tire crumbs. Norway's concern is that some people are allergic to latex and latex is a component of the ground-up tires. Sweden considers the rubber crumbs to be a hazardous substance.”
The Press Conference: Enter, Attorney General
Contemporaneous with the release of the EHHI Report, on August 29, 2007, EHHI held a press conference at the state house in Hartford to announce the “Release of Report on Potential Health Effects of Rubber Tire “Crumb” in new Synthetic Fields.” Convened at 11 AM in Hearing Room 1-B of the Legislative Building, the presenters included Nancy Alderman, the President of EHHI, the organization’s Director of Toxicology, Dr. David Brown, and Susan Addiss, past Commissioner of the Connecticut the Department of Health and now EHHI’s Director of Health Education. Also present were Tanya Murphy and Patricia Taylor, who, according to the media advisory announcing the press conference, were the “Westport, CT mothers who brought this issue to the attention of Environment and Human Health, Inc. in an effort to protect their children.”
At the press conference, EHHI “repeated a call for a moratorium on installing any new artificial turf fields that use ground-up rubber tires as part of the composition until more research is conducted. The organization also suggested that individuals have limited exposure to already-installed fields.”
The most significant part of the day belonged to the state Attorney General Richard Blumenthal. He took to the podium after EHHI’s presentation and “pledged to provide $200,000 from the state over the next two years for additional testing.” He “urged parents and the school communities not to panic about the artificial turfs but to be aware of the potential effects.” “There is a need for more studies, information and awareness,” he said. “This kind of particle can be dangerous to youth. They pose issues to health, and people need to be aware.”
The Massachusetts Connection
The press conference was a monumental achievement for CAES, EHHI and the Westport moms who instigated a much-needed debate about crumb as a public health issue. One basking in the glow of the moms’ achievement was Kurt Tramposch, MPH, a public health consultant from Wayland, Massachusetts. He is the cofounder of the Massachusetts Association of Health Boards and of the environmental activist group Mass Toxics Network. Tramposch’s pet peeve with artificial turf is the potential leaching of rubber crumb toxins into water wells and storm-water drains. Because some 40,000 tires are used to create the crumb for a single soccer field, when Tramposch looks over an artificial turf field he sees a tire dump.
About a month or so prior to the August 29th press conference, Patricia Taylor had sought out Tramposch. Her research into the health risks of artificial turf had identified a group of citizens in Wayland who had challenged the town for putting down a turf field so close to the town’s water wells. When on November 21, 2006, the town’s Conservation Commission decided to clear the project, Tramposch and Thomas Sciacca and eight others were ready to appeal that decision to the Massachusetts Department of Environmental Protection, asking the department to determine if the water quality issues were properly addressed by the commission. In March 2007 the department sent a letter to the town stating that the town must make sure the field drained safely and way from the water wells. On May 17, 2007, the department affirmed the conditions that the town’s conservation commission had placed on the project. On June 1, 2007, the “Wayland 10” appealed the department’s decision, requesting an adjudicatory hearing.
In May 2007, Tramposch, Siacca and company found the leverage they needed. It appeared in the form of a letter from the United States Department of the Interior’s Fish and Wildlife Service. The letter told the Massachusetts Department of Environmental Protection that the Wayland-10’s concerns about toxicity of the leachate from rubber crumb from the proposed field should be addressed. By July 23, 2007, Tramposch and other Wayland “minutemen” managed to get the Town of Wayland to agree to a rigorous testing and monitoring of the run-off and leachate from artificial turf field in order to protect the town’s drinking water and wetlands. According to the agreement, the town will hire an independent consultant to test for contaminants that may leach from the synthetic turf, which, as designed, is comprised of 40,000 ground-up rubber tires. Under the agreement, the town will take steps to remediate problems if the consultant finds contaminants that endanger drinking water or wetlands. In exchange for these built-in safeguards and independent oversight, the residents agreed not to pursue further litigation pertaining to the field project.
The exploits of the “Wayland-10” soon became news in Westport, Connecticut. By August 17,2007, Westport News already was referring to the Wayland case. “Closer to home,” wrote Frank Luongo, “municipal officials in Wayland, Mass., according to information distributed by [Alderman of EHHI], have agreed to monitor the drainage from a synthetic playing field under construction at the town's high school in response to residents' concerns about the possible contamination of town wells, which are located near the school, by run-off from the rubber granules used as in-fill.” “The Wayland story focuses on the potential leaching of chemicals like polycyclic aromatic hydrocarbons (PAHs), which contain known carcinogens, and on the concern of town officials about possible litigation, if they failed to monitor run-off from the high school field,” Luongo wrote. He also reported that the Massachusetts Department of Environmental Protection would not conduct a further review of the rubber crumb granules, the use of which the department described as a "well-established practice" and an "acceptable recycling of tire rubber." Not in Sweden or Norway, however.
The press conference in Hartford was not the first time for Tramposch going to another jurisdiction to lend moral support to citizens questioning artificial turf. A few months before the turf debate was joined fully in Westport, the Town of Wellesley, Massachusetts, had seen itself divided over turf – and Tramposch was there in the audience the night that turf went down at the Wellesley’s Annual Town Meeting in March 2007.
On February 6, 2007, Wellesley’s school committee had moved quickly through the proceedings and approved the installation of two artificial turf fields at the Sprague Elementary School. The few and very brief comments by citizens who opposed the plan made no difference to the majority of the committee to hurry the process along. It was recommended that the issue in the shape of Article 22 of the Warrant be offered for approval of the voters at the Annual Town Meeting that was scheduled for March 26-27, 2007.
The tide began to turn in favor of the opponents of the Sprague project when on March 5, 2007. The town’s selectmen voted to institute user fees on youth athletic programs as a way to pay for the proposed turf fields if the public were to vote down the funding of the fields with debt. In voting against user fees, the lone selectmen, David Himmelberger, questioned the safety of the turf plan as a whole. “I have grave reservations about this vote and about this project … I don’t think the Sprague student community should be placed at risk to gain more fields … this product has never been evaluated for use by elementary school kids. There are latex allergy issues and asthma issues that haven’t been addressed,” he was reported as saying.
By the time of the Annual Town Meeting a critical number of citizens had garnered siffcient attention and literature to educate the town meeting members on the potential health risks associated with artifcial turf. The first time Article 22 came up for a vote, it was defeated. The defeat did not deter the propoents of the proejct to call for reconsideration of the vote. The recosideration came a week later at the Town Meeting on April 10-11, 2007, after five hours of debate in the span of two nights. On the 11th the majority of members at the meeting voted for the resolution to fund the turf fields, but the measure fell short of the needed two-thirds majority to pass.
While the vote in Wellesley was about the funding of the turf project, one cannot dismiss or underestimate the persuasiveness of the health and safety issues that may have played a role in the outcome of the vote. During the debate that prceded the vote, the members heard from Tom Brown, a lawyer, who noted that “no study had ever been done on the long-term health effects of FieldTurf on small children.” Christine Olaksen said she “worried about younger children possibly ingesting the loose crumb rubber granules that compose the turf’s infill.” Larry Kaplan, a practicing physician, argued that the risks were too great for the town to install the turf without more careful discussion: “The science is not definite, but the potential threat to our children’s health is,” he said. “The onus should be on the manufacturer to prove that their product is safe, rather than on the consumer.”
Business as Usual: Plowing Ahead with Turf
The parks and recreation bureaucracy, public health officials, school administrators, athletes, booster clubs, coaches and athletic directors, parents, and elected public officials have found it very difficult to buy into the alarm raised by the EHHI and a few Westport moms. Not only the called for a moratorium on construction of new fields has gone unheeded, the local governments in the sate have plunged right ahead with the installation of new fields.
“Even Blumenthal, who advocates further study, said there should not be a rush to stop using or installing the fields. He said his four children, two of whom are in college, all played on artificial turf,” wrote Lisa Chamoff in The Stanford Advocate. "I can understand the confusion and doubt because we don't have all of the answers," she quoted Attorney General Blumenthal saying, "I'm simply trying to be completely honest, as a non-scientist and a non-technician, in digesting what I've read and heard from experts, which is that there are several points of view."
Moms Back in Action: Demanding risk management
At the August 29th EHHI press conference in Hartford, Attorney General Blumenthal had suggested that parents in communities where synthetic turf fields were installed to “manage the risk” by “addressing symptoms” and “reducing exposure on hot days.” He cautioned parents to take measures like hand washing and cleaning the clothing and skin of their children directly after they’d played on synthetic turf fields to reduce their exposure and limit their risk.
On September 14, 2007, Patricia Taylor and Stacy Prince launched a formal complaint with the Westport Weston Health District, demanding that the local public health authority investigate the potential risk to children and environment and issue guidance and oversight while the crumb rubber infill found on synthetic turf fields undergoes further testing. “While you are conducting your investigation,” the complaint stated, “we demand that you limit this potential risk due to crumb rubber infill by limiting or eliminating play on Westport’s synthetic turf fields as a precautionary measure.” Moreover, “we demand that you reduce the risk due to exposure to crumb rubber infill by mandating that children shower and change clothes after using the town’s synthetic turf fields.” Also, “we demand that you fully inform the public of all possible risk due to exposure to crumb rubber infill,” and “educate and inform the public about the ongoing state-funded, state-conducted scientific investigation of crumb rubber products.” Lastly, the Westport moms demanded that the health authority “offer to test the well water of residents for contamination due to crumb rubber infill, free of charge, until such time as the town has conducted ground water mapping, at which point testing can be limited to those wells reasonably considered ‘downstream’ of the fields.”
According to one news item reported on September 18, 2007, the director of the health district, Susan Jacozzi, had not had a chance to sift through all the research materials that Taylor and Prince had submitted, which included the CAES and EHHI studies. Jacozzi promised to thoroughly review their requests. Jacozzi further stated, the turf studies that she had reviewed in the past had been limited in scope, and so she would be looking for any new data in the material submitted by Taylor and Prince. She admitted that she had seen the CAES Study and that the issues raised in it needed to be further studied. “We need to gather more information,” Jacozzi told Jeremy Soulliere of the Norwalk Hour. 
Yet according to another news item reported on September 20, 2007, the district health director, Susan Jacozzi, sounded dismissive of potential health risks of turf fields. "There is not enough evidence that says there is a public health risk from using the fields,” she told Bonnie Adler of Westport Minuteman. The director stated that she has looked at a lot of the literature regarding potential human risk regarding the fields and there is simply not enough information or testing to recommend closing fields or reducing their use, but she is working with the state Department of Public Health and is reviewing the information as it comes in. "Our opinion has not changed as of this point about closing the fields. We do agree that more testing has to be done, and that it should be done on the actual fields and not under laboratory conditions," Jacozzi told Adler.
On September 25, 2007, the Westport Weston Health District formally responded to the Taylor-Prince complaint. In a letter to the two moms, Susan Jacozzi sated” We strongly agree with Attorney general Blumenthal that additional testing is needed – testing conducted on the fields and not in a laboratory. We support his call for a statewide $200,000 study that will give some guidance to municipalities in this state. Until that study, or some other examining the playing fields themselves, we see no reason to change the present usage of the synthetic turf fields.” Furthermore, the response promised to plan a community forum later this fall to examine in detail what is known about the health risks of artificial turf and what the Health District recommends about field usage, at which the complainant will have an opportunity to present their case to the public at large. Finally, Jacozzi, wrote: “We will, upon request from the home owner of any property in immediate proximity to the synthetic turf fields, test any private water for the presence of the 4 VOCs that the CAES study indicated might be present because of the crumb rubber.” Curiously, the Health District has not offered to test for the metals identified by CAES that leach from crumb rubber.
On September 28, 2007, Taylor and Prince sent a rejoinder to the Health District. “Our approach is that children's health shouldn't be jeopardized while we wait two years for field tests to confirm that crumb rubber is hazardous to human health,” they wrote. “Your approach is that children should be exposed to that risk,” pending evidence to the contrary. “It's ironic and sad that you use the questions [CAES and EHHI studies] pose as an excuse to ignore the urgency of their main message [that] Under relatively mild conditions of temperature and leaching solvent, compounds of crumb rubber produced from tires (i) volatize into the vapor phase and (ii) are leached into water in contact with the crumbs." “So does Attorney General Blumenthal's suggestion that we take reasonable precautions when using the fields,” Taylor and Prince continued. “While we appreciate your willingness to test well water of residents who live near turf fields,” they noted, “you'll probably want to be testing for toxic leachates -- zinc, cadmium, selenium, and lead -- as well as VOCs.”
Emerging Consensus: Let’s talk, study and test
Earlier on the same day that Taylor and Prince sent their rejoinder to the Health District, September 28, Frank Luongo from Westport News reported on the statements that the director of the health District had made about turf testing September 25 when she was on her way to a meeting about mold issues in Westport’s public schools. As reported by Luongo:
“Westport Weston Health District (WWHD) is now looking favorably on proposed on-site testing of the turf fields … WWHD Director Susan Jacozzi told the Westport News that she agrees with state Attorney General Richard Blumenthal that $200,000 in state funds should be committed to the testing of turf fields at their locations … Jacozzi and Parks and Recreation Director Stuart McCarthy are scheduled to participate next Wednesday [October 3, 2007] in a discussion to be held on the safety of the fields by the Health and Human Services Committee of the Representative Town Meeting (RTM).
“In supporting Blumenthal's recommendation regarding the turf fields, Jacozzi said that she was influenced by the same laboratory study by the Connecticut Agricultural Experiment Station (CAES) that caught the attorney general's attention.
“CAES called last month for on-site testing to determine whether the leaching and out-gassing of chemical compounds from the rubber granules used on the fields, as discovered in its laboratory tests under relatively mild conditions, might reach levels high enough to be hazardous for health and the environment.
“Jacozzi described CAES as a 'reputable state agency,' and said that it was time to spend money on testing the actual fields and move the issue out of the laboratory.”
Even though nobody is rolling up the turf carpet any time soon in Connecticut or other places, the Westport brief and the exploits of the “Wayland-10” in Massachusetts show that talking, studying and testing is fast emerging as a politically convenient and mollifying response to citizen actions that challenge the environmental and health risks of artificial turf. Exactly when and where the first carpet will be rolled up and disposed as a health hazard will remain to be seen. While one stays tuned for further developments, it bears recalling that many of the proven contemporary health hazards were deemed once to be without risk and, in fact, were encouraged.
 David Brown, Turf Wars: Debate continues on safety of fake grass, TheDay.com, September 16, 2007
http://www.theday.com/re.aspx?re=484e58b1-f47d-4b3d-be5b-db7bfbf5f7ea. David Brown, Sc.D., a public health toxicologist, is past Chief of Environmental Epidemiology and Occupational Health at the Connecticut State Department of Health, and past Deputy Director of the Public Health Practice group of ATSDR at the National Centers for Disease Control and Prevention (CDC).
 Crain, PhD, is a professor of psychology at The City College of New York and president of Citizens for a Green Riverside Park. Junfeng (Jim) Zhang, PhD, is a professor of environmental and occupational health at the University of Medicine and Dentistry of New Jersey. Crain is the author of “Reclaiming Childhood: Letting Children Be Children in Our Achievement-Oriented Society.”
 William Crain and Junfeng Zhang, “Hazardous Chemicals in Synthetic Turf,” Summer 2006, published in Rachel’s Democracy & Health News, No. 871: Hazards of Synthetic Turf, September 07, 2006 (http://www.rachel.org/bulletin/index.cfm?issue_ID=2568). Rachel’s Environmental & Health News is a publication of Environmental Research Foundation, New Brunswick, New Jersey.
 Crain and Zhang, above at note 3.
 Ibid. “Junfeng Zhang, a professor of environmental and occupational health at the University of Medicine and Dentistry of New Jersey, has found that the granules contain worrisome levels of zinc and lead, as well aspolycyclic aromatic hydrocarbons that are likely to be carcinogenic. Some preliminary research by others suggests that it might be difficult for these toxic chemicals in the granules to get into the body through skin contact, ingestion or inhalation, but more research is needed.” William Crain, “Turf Wars,” Op-Ed Contributor, The New York Times, Nytimes.com, N.Y. Region/Opinions, September 16, 2007
http://www.nytimes.com/2007/09/16/opinion/nyregionopinions/16NJcrain.html?ref=nyregionopinions. This op-ed piece appeared in the hard copy of the September 16th edition of The Sunday New York Times edition for the Connecticut region.
 Lisa Chamoff, “Turf used on athletic fields prompts concern,” The Advocate [Stamford], September 16, 2007 (http://www.stamfordadvocate.com/news/local/scn-sa-turf3sep16,0,5089996.story?coll=stam-news-local-headlines. Westport now apparently has four turf fields -- two at Staples High School, one at Kings Highway Elementary School and one at Saugatuck Elementary School. See, Bonnie Adler, “Parents question safety of synthetic fields,” Westport Minuteman, September 20, 2007 (http://www.zwire.com/site/news.cfm?newsid=18836015&BRD=1654&PAG=461&dept_id=12915&rfi=6).
 Nancy O. Alderman, MES, is past member of the Governor’s Pollution Prevention Task Force; past member of the National Board of Environmental Defense; recipient of the CT Bar Association, Environmental Law Section’s Clyde Fisher Award, given in recognition of significant contributions to the preservation of environmental quality through work in the fields of environmental law, environmental protection or environmental planning, and the New England Public Health Association's Robert C. Huestis/Eric Mood Award given to individuals for outstanding contributions to public health in the environmental health area.
 See above at note 1.
 Susan S. Addiss, MPH, MUrS, is also past President of the American Public Health Association; past member of the Pew Environmental Health Commission, Vice-Chair of Connecticut Health Foundation Board.
 D. Barry Boyd, MD, is also Affiliate Member of the Yale Cancer Center. His research areas include environmental risk factors for cancer as well as cancer etiology, including nutrition and the role of insulin and IGF in malignancy. He is the founder and director of Integrative Medicine at Greenwich Hospital – Yale Health System.
 Mark R. Cullen, MD, is also Director of Yale's Occupational and Environmental Medicine Program and co-editor of the Textbook of Clinical Occupational and Environmental Medicine.
 Robert G. LaCamera, MD, was a primary care pediatrician in New Haven, Connecticut, from 1956 to 1996 with a sub-specialty in children with disabilities.
 William A. Segraves, PhD, is also a research scientist and lecturer at Yale University Department of Molecular, Cellular and Developmental Biology. His research areas include molecular biology of hormone action in reproduction and development.
 Hugh S. Taylor, MD, is also chief of the Division of Reproductive Endocrinology and Infertility, Yale University School of Medicine. He is of no relation to Patricia Taylor, one of the Westport moms.
 John P. Wargo, PHD, is also a professor of Risk Analysis and Environmental Policy at Yale University's School of Forestry and Environmental Studies. His book Our Children's Toxic Legacy won the American Association Publisher's competition as best scholarly and professional book in an area of government and political science in 1997.
 Russell L. Brenneman, a Connecticut environmental lawyer is past President of the Connecticut Forest and Park Association. He chairs the Connecticut League of Conservation Voters Education Fund and is adjunct faculty in public policy at Trinity College, Hartford. He is the former chair of the Connecticut Energy Advisory Board.
 Crain, “Turf Wars,” above note 6.
 Letter from Massachusetts Department of Environmental Protection to Thomas Siacca, dated May 17, 2007, re Wetlands/Wayland DEP File #322-0661, Superseding Order of Conditions (Rachel Freed, Acting Section Chief, Wetlands and waterways Program, and Nancy M. White, Environmental Analyst, Wetlands and Waterways Program).
 Letter from Elizabeth A. Herland, Refuge Complex Manager, Fish and Wildlife Service, US Dept of the Interior, Sudbury, Mass., to Nancy White, Northeast Regional Office, Mass. DEP, Wilmington, Mass., dated May 15, 2007.
 In the matter of Wayland Boosters Association, Mass. Dept. of Environmental Protection, DEP Docket No. 2007-085, File No.322-661 – Wayland, dated July 23, 2007.
 Letter from Patricia Taylor and Stacy Prince, Westport Conn., to Susan M. Jacozzi, Director of Health, Westport Weston Health District, Westport, Conn., dated September 14, 2007.
 Letter from Susan M. Jacozzi, Director of Health, Westport Weston Health District, Westport, Conn., to Stacy Prince and Patricia Taylor, Westport Conn., dated September 25, 2007.
 Letter from Patricia Taylor and Stacy Prince, Westport Conn., to Susan M. Jacozzi, Director of Health, Westport Weston Health District, Westport, Conn., dated September 28, 2007.