Tuesday, June 14, 2016

EPA Moving Toward White House Review Of Federal Synthetic Turf Plan

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.
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 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."
Research Plan
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 itsMay 2 comments.
Environmental Risks
Meanwhile, the environmental groupDelaware 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."
Industries' Concerns
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." -- Maria Hegstad

Monday, June 6, 2016

Response to Updated Fields Master Plan from Green & Open Somerville

Dear Mayor Curtatone, Honorable Aldermen, Luisa, Brad, Arn, and Jill,

I have read through the updated plan and there has clearly been a lot of work put into this document; I appreciate that many people have spent time and effort to write it. However, I am discouraged. I know the City is balancing many differing needs, desires, and interest groups, and while I understand that it is impossible to make all people 100% happy, I do think that there is a way to increase the use we get out of these fields while at the same time keeping them grass, and increasing the quality and quantity of Somerville's green space. 

There are a few issues that require further explanation.

1. On page 88 under FAQs: Maintenance and Best Practices, the Sports Turf Managers Association is cited as recommending 500 hours of use on a natural grass field. I have also seen this attribution in City presentations, as well as from Weston and Sampson regarding Lincoln Park. I spoke to Kristen Althouse, education manager at STMA, in March of this year, to get more information on this recommendation because it was a lot lower than multiple professional grass field managers were saying grass could take. She said that STMA does not have a recommendation for a maximum use on natural grass fields. She said enough people have asked about this that they were working on coming up with a recommendation, but "there are so many variables that go into determining the number of usage hours a field can withstand – soil type, turfgrass type, weather, maintenance practices, sport being played, etc. Also, STMA is researching these variables over the course of the next year and hopes to have some technology available to the public to help calculate the number of hours natural grass fields can withstand and still remain safe." 

2. On the same page, you say "the June 2013 Gale Athletic Fields Assessment & Master Plan commissioned by the City estimates that 'based on original field construction and current maintenance practice…each natural turf field is capable of experiencing no more than 250 team uses per year without detrimental break down of the turf.' They define a team use as '10-20 persons using the field for a 1-2 hour event.' The event number translated to maximum time equals 500 hours." Considering that the Gale study was basing their estimate on field construction and current maintenance, this needs to be reconsidered. Our fields were all poorly constructed and have had abysmal maintenance. Since the whole point of a new Parks and Rec department is to better maintain our fields, and since an entire section of the revised plan addresses how to better maintain our newly constructed fields, Gale's recommendation is no longer valid. 

3. On page 38 under best practices, natural grass diamond sports fields have an 800 hour use limit. On page 56, Trum is listed as a field "in relatively good condition that we do not intend to overhaul." On page 84, the chart says that Trum Field has 2,094 hours of permitted use, which is over two and a half times the permitted hours recommended for best practices. Please explain the discrepancy of why a field in relatively good condition that is currently sustaining over 2,000 hours of permitted use, needs to be reduced to 800 hours of use.

4. A year's rest time is recommended in the plan after a grass field is seeded and before it can be used. After Chip Osborne's organic grass care forum in Swampscott in April, which Luisa Oliveira and Jill Lathan attended, I spoke with Chip about rest requirements on grass fields. He agreed that a newly seeded grass field does need months of rest, if not a year, but that a sodded field could be used much sooner. While it is more expensive upfront, in his experience he said a sod field is about the same money in the end. I would like the City to talk to Chip or someone else equally knowledgeable about this to learn more about a sod option.

5. On page 89 I believe number 4 refers to organic grass care. Perhaps number 3 does as well, though that is unclear. I go back to Chip Osborne's forum and his assertion that an organically-maintained grass sports field is not only the best choice for the environment, it actually produces the strongest, healthiest, most durable grass field. It doesn't have to be a choice of health vs. usability, because organic gives you both, at least according to Chip, who happens to be an expert in this field. I again beg you to speak to him about this option. He has done it in Marblehead, MA, which has similar use requirements and certainly is in a similar climate to Somerville.

6. Adding artificial turf fields at Winter Hill and Healey is, once again, putting plastic into two of our least green areas of town. I understand that currently there is asphalt at these locations, so we are not removing green space, but think about the rare opportunity we have to actually legitimately add green space in an area of vulnerability.
7. The City is right to address the obesity epidemic. We must find ways to get our residents active and exercising. However, I have not heard any organized youth sports group say that there is more demand to join than the fields can accommodate. Based on available City numbers and the 2010 census, approximately 1,660 (or 18% of our under-18 population and 2% of the total population) play in organized youth sports requiring fields. Turf might allow fewer rainouts but would not increase participation.

Let's focus on athletic activities for the 82% of our youth not in organized field sports. The money used to cover our grass fields in plastic could be better used to increase access to basketball and other exercise programs for more kids. And in the summer, when organized sports are on hiatus, more children would use a grass field than a turf one because grass fields are cooler. On a 93 degree day in September of last year, the artificial turf field at the East Somerville Community School was registering 140 degrees at 2:30 in the afternoon. If we are concerned about the health of our youth, we should make sure that they have access to healthy, cool, natural outdoor spaces. Our fields are the majority of Somerville’s green space. In a city with the smallest amount of green space in Massachusetts, we can’t afford to lose any of our fields to plastic.

8. On page 76 it mentions an RFP for a Fields Maintenance Plan consultant. Who is writing this? What are the guidelines that will be used to determine their qualifications if we do not currently even know what is needed to properly maintain a grass field? 

9. Speaking to the economics of fields, considering that a grass field can be properly maintained for a fraction of the cost of installing an artificial turf one, and considering Somerville needs to fund an additional $50 million for the GLX, as well as construction on the High School, wouldn't it behoove us to attempt a few years of proper maintenance of our grass fields before we pay millions of dollars for the proposed artificial turf fields in this plan? It could end up saving us millions of dollars. And grass improvements can begin immediately.

10. On page 61 it says, regarding artificial turf fields, that "fortunately, there are a number of safe and healthy options to choose from." Currently, crumb rubber's potential catastrophic health concerns are finally being evaluated by the EPA. However, no matter what infill is used, whether it be crushed tires or expensive and short-lived corkonut, or something in between, there is no getting around the fact that the plastic playing surface is hot, its carbon footprint is enormous, its recyclability at the end of its lifespan dubious and expensive, and its destruction of living green space certain. Once plastic is laid down, the space will not be returned to living plants without extreme expense. It contributes to global warming, both in its production and in its heat output. Grass is cool. In this time on our planet where not just scientists but the general population now believes that human-induced climate change is upon us, it does not make sense to increase our heat output and use of environmentally destructive materials. We need to make sacrifices if we want Earth to remain livable. We are faced with a choice: plastic perfection on our sports fields vs. the health of the planet we will leave for our grandchildren.

We truly can achieve significantly greater use of our grass fields with a little guidance. We have nationally-recognized industry leaders working in the greater Boston area. Please consult with them before we permanently destroy the little green space that we have. I have given Arn, Brad, Luisa, and Jill the contact info for a few of these experts, but I am happy to resend it if need be. 

Somerville needs more green space and more use of our fields. We are trusting the City to thoroughly investigate all options as they move forward with improvement plans.


Renée Scott
Green & Open Somerville