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55 Walkers Brook Drive,Reading,MA 01867(HQ)
Tel:978.532.1900
February 4, 2022
Bree D. Sullivan, P.E.
Chief Civil Engineer
163 Libbey Parkway
Weymouth, MA 02189
Re: Synthetic Turf and PFAS
Dear Ms. Sullivan:
Weston &Sampson Engineers, Inc. (Weston &Sampson) has prepared this letter regarding the potential
for environmental impacts related to synthetic turf at your request. The focus of the information provided
is poly and perfluorinated alley substances (PFAS) that may be present in the synthetic turf system. The
evolving scientific understanding of the complex chemistry, environmental fate, exposure routes and
lack of regulatory limits, makes presentation and discussion of PFAS presence and potential risks
challenging. Below, we have briefly summarized some key information regarding PFAS. At the end of
this letter, we provide a concise set of takeaway points that should assist in providing answers to
frequently asked questions regarding PFAS in synthetic turf fields.
PFAS BACKGROUND
PFAS are a manmade suite of compounds utilized in many consumer products to provide durable
waterproof coatings and in aqueous film forming foam (AFFF) used for firefighting. The scientific
community is rapidly evolving its understanding of PFAS in the environment. Many PFAS have been
shown to be very resistant to water, oil and degradation under typical environmental conditions. Some
PFAS are water soluble and can be ingested via this exposure route. These soluble PFAS have also
been shown to bioaccumulate in plants, animals and humans. Therefore, PFAS are considered to be
contaminants of emerging concern (CECs), which are those chemicals that present potentially
unacceptable human health effects or environmental risks, and either: (1) do not have regulatory
cleanup standards, or (2) regulatory standards are evolving due to new science, detection capabilities
or pathways, or both.
PFAS are contained in thousands of commercial daily use products including food packaging,
cookware, and waterproof textiles used in jackets and boots. Due to their presence in so many products
and their environmental persistence, PFAS are now ubiquitous in the environment. PFAS has been
detected in human blood, surface water sediments, surface and groundwater, and wildlife across the
globe. Although the scientific research into PFAS is evolving, there is evidence there may be adverse
health effects associated with long-term exposure to some PFAS compounds. The primary focus of
USEPA and other regulatory agencies for exposure to PFAS is through consumption of soluble PFAS in
contaminated drinking water. Based on the limited research studies to date and what is known about
the chemical composition of PFAS, dermal (skin) contact with PFAS containing materials is expected to
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pose minimal health risk. Similarly, based on available research and chemical composition, most PFAS
compounds do not appear to be volatile and are expected to pose minimal health risk through inhalation.
SYNTHETIC TURF MANUFACTURE
Synthetic turf grass is made by extruding a mixture of primarily polyethylene plastic into a mold shaped
as blades of grass. Typically, a processing agent is utilized within the polyethylene mixture to assist
with effective plastic injection into a mold and ease removing the blades from the mold. It is our
understanding that the predominant processing agent being used by the plastic grass manufacturers
is polyvinylidene fluoride-co-hexafluoropropylene (PVDF-HFP). PVDF-HFP is a polymeric PFAS. This
copolymer is a very large molecule and not soluble in water. In addition, because the processing aid is
mixed into the plastic being molded, it becomes bound into the polyethylene blade as part of the plastic
matrix.
A review of the potential toxicity of PVDF-HFP does not bring up any relevant toxicity data. There is no
reference to PVDF-HFP in EPA Integrated Risk Information Systems (IRIS) or the CDC's Agency for Toxic
Substances and Disease Registry (ATSDR). This is likely because PVDF-HFP is considered inert. PVDF-
HFP is a common component used in medical devices — stents, meshes, replacement joints, etc.
Studies documented from Boston Scientific and others indicate PVDF-HFP is biocompatible, inert and
insoluble. It appears to be very commonly used in medical devices. It has many different uses including
food packaging and water purification (used within the plastic in water filters). Based on current
information, high molecular weight fluoropolymers are believed to be too large to cross cell membranes
and are therefore believed to pose less risk to human and ecological health relative to nonpolymer PFAS.
To our knowledge no other PFAS are being intentionally utilized in the manufacture of synthetic turf
system components.
PFAS REGULATION
Drinking Water
The USEPA has set a health advisory for perfluorooctanesulfonic acid (PFOS) and perfluorooctanoic
acid (PFOA) in drinking water of a sum total of 70 parts per trillion (ppt). Massachusetts Department of
Environmental Protection (MADEP) has developed drinking water standard of 20 ppt for the sum of six
PFAS compounds (PFAS6) including both acid and anionic forms of the following:
• perfluorohexanesulfonic acid (PFHxS)
• perfluoroheptanoic acid (PFHpA)
• perfluorooctanesulfonic acid (PFOS)
• perfluorooctanoic acid (PFOA)
• perfluorononanoic acid (PFNA)
• perfluorodecanoic acid (PFDA)
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Surface Water
Currently neither the USEPA nor MADEP have set a surface water guidance/standard concentrations for
PFAS. There is draft MADEP Method 1 GW-3 groundwater standards that are protective of migration of
constituents in groundwater to nearby surface water bodies.
Soils
MADEP has set standards for the PFAS6 in soil. Method 1 S-1/GW-1 concentrations are protective of
potential leaching into groundwater and Method 1 S-1/GW-2&3 is protective of direct contact exposure.
The table below summarizes the soil limits.
MADEP Soil Standards-parts per billion
PFAS Leaching to Groundwater Direct Contact
perfluorohexanesulfonic acid (PFHxS) 0.30 300
perfluoroheptanoic acid (PFHpA) 0.50 300
perfluorooctanesulfonic acid (PFOS) 0.72 300
perfluorooctanoic acid (PFOA) 2.00 300
perfluorononanoic acid (PFNA) 0.32 300
perfluorodecanoic acid (PFDA) 0.30 300
Consumer Products
No federal standards or regulatory limits are presently set for consumer products containing PFAS. The
European Union regulates chemicals contained in consumer products via the Registration, Evaluation,
Authorization and restriction of Chemicals (REACH) regulation. REACH is a European Union regulation
(1907/2006/EC) restricting the levels of specific chemical substances in all imported goods. PFOS and
PFOA are listed as restricted compounds by REACH. California Prop-65 provides a list containing a
wide range of naturally occurring and synthetic chemicals that are known to cause cancer or birth
defects or other reproductive harm. If a product contains chemicals on this list, a warning must be
provided on the product. PFOA and PFOS have been on the Prop-65 list since 2017. As of December
311 2021, PFNA and PFOS transformation and degradation precursors will be added to the Prop-65 list.
TESTING METHODS
There are thousands of PFAS compounds. Because PFAS are emerging contaminants, accredited
laboratories only have the ability to test drinking and surface water for 30 specific PFAS compounds via
two EPA accredited methods at this time. Both methods quantify the PFAS6 regulated by MADEP.
No EPA approved methods exist for testing of environmental media other than drinking water and
surface water or for consumer products. This has led laboratories to develop their own modifications to
the EPA methods to test these materials. Many of these modified method results are accepted by state
regulators for reporting of 30 specific PFAS compound concentrations, including the PFAS6. It is these
methods that must be used when analyzing artificial turf grass, shock pads and infill materials.
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SYNTHETIC TURF TESTING RESULTS
A number of communities in Massachusetts and New Hampshire have engaged in synthetic turf
sampling and analyses for PFAS. The test methods utilized identify 24 to 30 individual PFAS. A
summary of the testing results by various preparation methods is included below.As there are no federal
or state regulatory standards for PFAS in or leaching from synthetic turf, the results are compared to the
MADEP soil standards for leaching to groundwater and direct contact and to the Vermont Department
of Environmental Conservation (VTDEC) PFAS in Background Soils study. The VTDEC study collected
samples across the state to determine what the "background" levels of PFAS are away from known
PFAS sources. Analyses results from synthetic turf system materials and soils collected from an existing
athletic field located in Nantucket, Massachusetts are summarized below:
PFAS6 Concentration Summary
(parts per billion)
Brock Brock VTDEC MADEP MADEP
PFAS Greenfield Fill Shock Bkgd S-1/GW-1 S-1/GW-
Tu rf In-Fill Pad soil 1Soil 2 (median) Leaching 2&GW-
3
Contact
PFHxS ND/3.08 ND/2.84 ND/9.52 ND/0.273 ND/0.291 0.120 0.30 300
PFHpA ND/3.08 ND/2.84 ND/9.52 ND/0.273 EST/0.137 0.190 0.50 300
PFOA ND/3.08 ND/2.84 ND/9.52 EST/0.091 EST/0.272 0.400 0.72 300
PFOS ND/3.08 ND/2.84 ND/9.52 0.696 0.399 0.680 2.00 300
PFNA ND/3.08 ND/2.84 ND/9.52 EST/0.115 EST/0.191 0.160 0.32 300
PFDA ND/3.08 ND/2.84 ND/9.52 EST/0.208 EST/0.102 0.095 0.30 300
ND—None Detected at Reporting Limit
EST—Estimated Value Below Reporting Limit
Review of the testing results indicates:
• None of the PFAS6 were detected in the synthetic turf system components.
• Several Non-PFAS6 compounds were observed in the synthetic turf system components
at "estimated" concentrations below the reporting limit (<1 ppb).
• The soil samples collected from the existing athletic field areas (Soil -1 and 2) reported
the PFAS 6 compound PFOS at concentrations comparable to those seen in the VTDEC
Background Soil study and well below the MADEP concentrations for leaching to
groundwater or direct contact.
• Several "estimated" concentrations of PFAS6 and other individual PFAS were also
reported in both soil samples.
• The PFAS concentrations in the existing athletic field soils appear to be related to the
ubiquitous presence of PFAS in our environment (i.e. "background").
Note that no synthetic turf system has yet been specified for the Norton athletic fields. Prior to installation
of synthetic turf, analysis of each of the turf components for PFAS is recommended. Additionally,
collection of soil from the area of the proposed installation may be helpful to understand the PFAS that
may already be present at the Site through atmospheric deposition (i.e., background concentrations).
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The study completed for Martha's Vineyard also performed testing for PFAS leaching. This test
submerges the materials in water that has been augmented to reflect rainwater that is at least 10 times
as acidic as typical rainwater in the northeast and stirs it for 24 hours. SPLP uses a solution that has a
pH of 4.2, versus the pH of typical rainwater in Massachusetts of 5.5. The water is then tested for PFAS.
The results of these tests indicate that "estimated" or very low levels of PFAS6 and other individual PFAS
leach from the proposed synthetic turf materials. These concentrations are well below the MADEP
drinking water standard.
Destructive testing of the synthetic turf components was also performed during the Martha's Vineyard
study (TOP Assay). This analysis exposes the materials being tested to a caustic (think something like
Draino) and high heat (185 F) to breakdown "precursor" PFAS into PFAS that are measurable by the
laboratory methods. Please note the preparation of the sample does not represent natural conditions.
Also, this is a very simplified description of the method and data interpretation. The TOP results reported
1 of the PFAS6 and 2 other PFAS at "estimated" concentrations.
The Martha's Vineyard consultant indicates that the concentrations of PFAS observed by all of the
analyses performed on synthetic turf components are "...consistent with background concentrations in
natural soil or at concentrations well below referenced risk-based standards...
Weston &Sampson Conclusions regarding Synthetic Turf Testing Results:
Based upon the information we have reviewed to date we have made the following conclusions:
1. Individual PFAS compounds were detected at concentrations generally below laboratory
reporting limits in the synthetic turf system materials.
2. The "estimated" PFAS concentrations in synthetic turf components are similar to
background soil levels and are indicative of the ubiquitous nature of PFAS.
3. The PFAS concentrations in synthetic turf are not indicative of their use as a
manufacturing additive which would be expected at much higher concentrations.
4. The PFAS concentrations in the synthetic turf are below published background
concentrations in natural soils and below the measured PFAS concentrations in soil at
the existing athletic fields in Nantucket.
5. Leaching testing of the synthetic turf system components indicate PFAS do not leach at
concentrations near or above MADEP drinking water regulation levels.
6. Aggressive TOP assay testing reports "estimated", low levels of PFAS, similar to
"background". This appears to indicate that the PFAS processing aid PVDF-HFP is not
broken down into soluble PFAS, under the aggressive testing method conditions.
It is the opinion of Weston & Sampson that the trace concentrations of PFAS were consistently at or
below laboratory detection limits calling into question the precision and validity of the results. Therefore,
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we believe the trace levels of PFAS identified pose No Significant Health Risk to field users or the
environment.
Suggested Discussion Points
While the science regarding PFAS is evolving, the following points of discussion represent our
understanding based on the science that is currently available.
• No standards exist for PFAS concentrations in consumer products.
• The synthetic turf grass is likely manufactured using a polymeric PFAS (PVDF-HFP) as
processing aid. PVDF-HFP is a common component used in medical devices and is
biocompatible, inert and insoluble.
• Multiple tests performed on the synthetic turf system components proposed for the project report
PFAS concentrations as either "none detected" or so low they are "estimated". All regulated
PFAS (PFAS6) and unregulated PFAS concentrations reported are well below the MADEP
drinking water and soil exposure standards.
• PFAS6 concentrations in soil samples collected at the existing athletic fields are higher than
those reported from the synthetic turf system components. The soil concentrations are similar
to "background" concentrations seen in a Vermont study and well below the MADEP
concentrations for leaching to groundwater or direct human contact.
• PFAS in soil is likely to be more bioavailable than PFAS in synthetic turf. The PFAS in soil can
be ingested as dust and dirt on the skin. In order to liberate detectable levels of PFAS from the
synthetic turf, aggressive laboratory extraction methods were required. It is unlikely the installed
synthetic turf system would see such conditions in real life.
• We believe the trace levels of PFAS identified in the synthetic turf system components pose No
Significant Health Risk to field users or the environment.
If you have any questions or comments regarding this letter or need any additional information, please
do not hesitate to contact our office at 617-412-4480.
Sincerely,
WESTON & SAMPSON ENGINEERS, INC.
Marie Rudiman Steven LaRosa
Senior Risk Assessor/Toxicologist Team Leader
/norton athletic fields/pfas letter norton 2021.01.26.docx
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ENCLOSURE 4b
2021 Hayley Aldrich Letter to a school considering turf
fields
Re: Evaluation of Health and Environmental Effects:
Synthetic Turf
H A L E Y&A L D R I C H,INC.
3 Bedford Farms Drive
Bedford, NH 03110
603.625.5353
2 June 2021
File No. 0200977-000
TO: Dr.Tara Gohlmann
Chief Operating Officer/Chief Financial Officer
Buckingham Browne & Nichols School
80 Gerry's Landing
Cambridge, mA 02138
FROM: Jay Peters
Senior Technical Expert, Risk Assessment
Haley&Aldrich, Inc.
Subject: Evaluation of Health and Environmental Effects: Synthetic Turf
The purpose of this memorandum is to provide a summary of recently published studies and reports
that evaluate the safety(health and environmental risks) of using synthetic turf athletic fields, with
focus on chemicals contained in or associated with synthetic turf and association of synthetic turf with
"Heat Islands".
There are approximately 13,000 synthetic turf athletic fields in the United States and more than 1,200
are being added each year. Similarly,the European Chemicals Agency(ECHA) estimates that there are
131000 large synthetic turf fields in the European Union. There are no state or federal laws that prohibit
installation of synthetic turf fields.
A synthetic turf field consists of three main components, including turf blades (the portion of the system
that mimics grass blades), a backing material that holds the turf blades in place (similar in concept to
backing material that holds household carpet together), and an infill material.The purpose of the infill
material is to keep the grass blades standing "up", provide cushioning for the system, and provide
appropriate foot to surface interaction (e.g.,traction) as well as feeling underfoot(e.g., soft versus firm).
Turf blades and backing material are made from polyethylene/and/or polypropylene (plastic family).
There are several materials that are used as infill, but a common infill material and the one that is
proposed for use at the Buckingham, Brown & Nichols (BB&N) new athletic facility is a mixture of sand
and encapsulated crumb rubber;this is the same infill material that BB&N has installed at their turf field
at the Upper School—Franke Field.
Crumb rubber, also referred to as recycled crumb rubber, consists of small rubber fragments (between
0.25 and 4 millimeters in diameter)that are created by recycling tires. There has been a lot of focus on
crumb rubber as an infill material, primarily due to allegations in 2014 that exposure to crumb rubber is
associated with higher rates of cancer. However, evaluation of those allegations by the Washington
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2 June 2021
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Department of Public Health as well as researchers (e.g., Bleyer et al., 2018) determined that there is no
link between use of synthetic turf fields with crumb rubber infill and increased incidence of cancer. In
addition, over 100 scientific,peer-reviewed,published studies have been performed worldwide
evaluating the potential health risks associated with using crumb rubber. We are not aware of any
peer-reviewed scientific studies which draw an association between adverse health effects and use of
crumb rubber. Based on the body of evidence,the following state, national and international agencies,
governing bodies, and academic institutions have concluded that the use of crumb rubber in athletic
fields does not pose a significant human health risk, including (among others)the following:
• Dutch National Institute for Public Health and Environment
• Norwegian Institute of Public Health
• EU - European Chemical Agency(ECHA)
• Connecticut Department of Public Health
• New York City Department of Health
• New York State Department of Health
• The Washington State Department of Health and researchers from the University of Washington
School of Public Health
In addition, in 2015 the Massachusetts Department of Public Health(DPH)evaluated health concerns
related to the use of crumb rubber infill material for artificial turf fields in Medway, Massachusetts,
and concluded that"the scientific literature continues to suggest that exposure opportunities to
artificial turf fields are not generally expected to result in health effects". A communication
documenting the MA DPH evaluation is provided as Attachment 1.
Evaluation of Chemicals in Synthetic Turf
Evaluating health risks of using synthetic turf fields requires resolution of the following questions:
1. Are chemicals present in crumb rubber?
2. What are the concentrations of chemicals present in the crumb rubber?
3. How much of the chemical concentrations can people be exposed to (a term referred to as
bioavailability)?
4. How much contact with crumb rubber could occur?
5. Is the combination of bioavailable chemical concentration and contact with crumb rubber at a
level that can be considered safe? (Would the possible exposure to chemicals in the crumb
rubber pose a health concern?)
Risk assessment is the process of resolving these questions. The US Environmental Protection Agency
(USEPA) and the Massachusetts Department of Environmental Protection (MassDEP) have established
systematic procedures for evaluating health risks (see for example, USEPA(1989), MassDEP (1995 and
2014)). Those procedures are applied to determine if chemicals present in soil, air, and groundwater are
safe (i.e., are associated with insignificant health risks). The same procedures have been applied by
various entities, as described below,to evaluate the safety of synthetic turf.
ICH
Buckingham Browne & Nichols School
2 June 2021
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Several recent studies have reported on the chemical composition of crumb rubber(e.g., Perkins, et al.
(2019);TURI (2020); Celeiro et al (2018; 2021a; 2021b); Gomes et al (2021)). These studies highlight the
presence of chemicals that may be contained in crumb rubber, including substances known or suspected
of causing cancer in humans, including certain polyaromatic hydrocarbons (PAHs) such as
benzo(a)pyrene and certain volatile organic compounds (VOCs) such as benzene.
Understanding the chemical composition of crumb rubber is an important step in evaluating whether
the material could pose a potential health concern (Step 1). To help resolve whether the chemicals in
synthetic turf are safe, we have reviewed various studies and reports that have evaluated Steps 2
through S above. The following provides a summary of recent studies that address this.
• Pavilonis et al. (2014). This research group collected 8 samples of crumb rubber infill material
and 8 samples of synthetic turf fibers from various manufacturers as `new' (i.e., not yet placed
on fields) and `used' (i.e., in-place in 7 synthetic turf playing fields in New Jersey). Samples were
subjected to extractions using simulated gastric fluids and simulated sweat and were analyzed
for metals and semi-volatile organic compounds (SVOCs). SVOCs and metals were not detected
in the fluid extracts from the `new' samples,whereas some metals were detected in the fluid
extracts from samples collected from playing fields. Health risks were estimated by assuming
athletes ages six through adulthood used the fields 3 hours per day, 130 days per year, and were
exposed to the metals measured in the fluid extracts by incidentally ingesting crumb rubber,
breathing in crumb rubber particles, and having crumb rubber particles stick to their skin. The
researchers concluded that health risks associated with use of synthetic turf fields with crumb
rubber infill were orders of magnitude below regulatory levels used to define safety
thresholds.
• Peterson et al. (2018). This research group applied the systematic procedures for risk
assessment as cited above using all available study data as of 2017 that reported chemical
concentrations in crumb rubber and in air samples collected near synthetic turf fields (37 crumb
rubber studies with 103 samples and 139 chemicals evaluated; 9 air studies with 93 samples and
213 chemicals evaluated). Health risks were evaluated by assuming that athletes (ages 6 to 18
years) and young children and adults as spectators contact crumb rubber by accidentally
ingesting it, getting it stuck on their skin, and breathing air above the fields (representing air
quality that could be affected by the synthetic turf field),4 days per week for 8 months of the
year(139 days per year). To provide a comparison of health risks between use of synthetic turf
fields with crumb rubber infill and natural turf fields,the same exposure assumptions were used
to evaluate health risks associated with background concentrations of metals and PAHs in soil.
The results of the study showed that cancer risks for use of synthetic fields were below USEPA's
de minimis risk level of 1x10-6 and MassDEP's risk threshold of 1x10-5, and that risks for health
effects other than cancer were below the EPA and MassDEP threshold value of 1. Furthermore,
the evaluation showed that risks estimated for use of synthetic turf fields are lower than risks
estimated for natural turf fields which contain ambient background levels of metals and PAHs
in the soil. The authors concluded that the evaluation demonstrated that use of synthetic turf
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2 June 2021
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fields containing recycled crumb rubber infill would not result in unacceptable health risks to
children or adults under USEPA's risk assessment guidelines.
• USEPA (2019). USEPA collected crumb rubber from 9 tire recycling facilities, 15 indoor turf fields
and 25 outdoor turf fields from throughout United States and analyzed the samples SVOCs,
metals, and microbes. The study also measured the bioavailable fraction of metals in the
samples and the emissions of VOCs at both 77-and 140-degrees F. Key findings from the study
are:
o Metals and SVOC concentrations were similar to those reported in other studies that
examined the chemical content of crumb rubber.
o Emissions of VOCs were generally not detectable at 77F. Emissions of some VOCs
increased slightly for some VOCs at 140F. Nevertheless, even at 140F, emissions were
very low.
o Approximately 3%of the metals concentrations were estimated to be bioavailable if the
crumb rubber is ingested, and less than 1%were estimated to be bioavailable if the
crumb rubber sticks to skin and the metals transfer from the rubber through the skin.
o The type and number of bacteria in samples of crumb rubber were similar to those
present in environments where synthetic turf is not present. The reported cited
literature indicating that crumb rubber infill harbors fewer bacteria than natural turf.
The study completed by EPA helps address Steps 1 through 3 above. EPA has not yet used the
results of its investigation to evaluate health risks (Steps 4 and 5 above). However,they
conclude that "these findings support the premise that while many chemicals are present in the
recycled crumb rubber, exposure may be limited based on what is released into air or biological
fluids".
We further evaluated the analytical data for crumb rubber that was reported on by EPA(2019)
to help provide context for the results in terms of crumb rubber safety. Specifically, we
compared the 90t" percentile concentrations of metals and SVOCs, as reported by USEPA in
Tables 4-34 and 4-36 of their report, to screening levels published by MassDEP and USEPA.
Specifically,the MassDEP screening levels are the Massachusetts Contingency Plan (MCP) S-
1/GW-3 soil standards,which would be applicable to evaluation of soil in a natural turf field
located where the BB&N field is proposed, and the USEPA Regional Screening Levels (RSLs)for
residential soil for substances which are not published in the MCP.The 90t" percentile
concentration was used because it is a statistic that is consistent with the value that MassDEP
recommends for assessing exposures to soil during activities such as recreational uses of a
playing field (MassDEP, 2014).
ICH
Buckingham Browne & Nichols School
2 June 2021
Page 5
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Sy n t Iiii e,t�c Tug rf F i e,I d s B e,,n z ot Iiii�a 0,1 e 31 N A,
Sy n t Iiii e,t i c Tug rf F it e,I d s Di Lint yll plitIlialate 3.51 HOG 13,
Synth etc Tug rf F i e,I ds Bis(2.-etIliV11 Iiii exyll) 1,101u1011 190 a
plitIli a I ate
Sy n t Iiii e,t�c Tug rf F�e,I d s An i II i n e, 1.2 195, 13,
Sy n t Iiii e,t i c Tug rf F it e,I d s 4 t e,,rt,-,,octly 11 p Iiii e,no II 27' RA
Syntl1i etc Tu rf F�e,I ds n-H exa d eca n e, 2.E, RA
a-,MassDEP MCP1,Standard(S-1/GW-3)(31,10 UOR 40.101975(61)(a)
bl-,USEPIA RegibnaIIII Screen iiing Le,'YelI"foir (Iliazard'iiindex=!1;lcancer riiisk=I,E-06)
RA-N olt.Ava I a bi I e-,
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As indicated, the concentrations of all chemicals except bis(2-ethylhexyl)phthalate, cobalt and
zinc are below their respective screening levels. The screening level for bis(2-
ethylhexyl)phthalate is based on a de minimis cancer risk level. The 90t" percentile
concentration of 100 mg/kg is only 10% higher than the screening level, indicating that the
concentration of bis(2-ethylhexyl)phthalate is still within a range this is considered to be safe by
MassDEP. The screening levels for cobalt and zinc are based on the assumption that the metals
are 100% bioavailable. If the 90t" percentile concentrations were adjusted for the bioavailability
of the metals in the crumb rubber, as reported by USEPA in Table 102 of their report,the value
for cobalt would be 3.4 mg/kg (at 1.2%for maximum bioaccessibility) and zinc would be 475
mg/kg (at 2.5% maximum bioaccessibility), which are both below the screening levels.
Based on this evaluation, the chemicals in crumb rubber as reported by USEPA, would not pose
significant health risks and therefore would be considered safe for use as infill in synthetic turf
fields.
• Schneider et al. (2020). This paper reports on the outcome of the European Risk Assessment
Study on Synthetic Turf Infill. It uses measurements of chemicals detected in crumb rubber infill
to estimate health risks to bystanders (young children) and athletes ages 4 to 35 years who were
assumed to contact infill material. More specifically,the study assessed substances that were A)
detected in rubber infill material, B) could volatilize from the rubber infill material, or C) could
be extracted at sufficient quantity into simulated gastric or sweat fluid or simply had particularly
hazardous properties. Using the bioavailable chemical concentrations,the evaluation
characterized risks for the bystanders and athletes assumed to contact infill material 1.5 to 4
hours per day, 112 to 240 days per year. The study concluded that estimated risks for use of
synthetic turf fields with crumb rubber infill were below guidelines used by both the European
Union and the USEPA.
• Pronk, eta al. (2020). Similar to testing reported on by Schneider et al. (2020) and USEPA
(2019), Pronk et al. collected rubber infill samples from 100 pitches in the Netherlands (6
samples per pitch resulting in 600 total samples of rubber infill material) and analyzed them for
SVOCs and metals. Samples were also subjected to extraction by simulated gastric and sweat
fluids, and VOC emissions were measured in samples incubated at 140F. Using the bioavailable
chemical concentrations, the evaluation characterized risks for study populations similar to
those evaluated by Schneider et al. (2020). The study concluded that chemical concentrations
in crumb rubber infill complied with concentration limits set for mixtures of substances in
Europe, and that health risks were below regulatory guidelines.
• Tetra Tech (2021). Tetra Tech evaluated the chemical composition of a synthetic turf system
proposed to be installed as a component of the Martha's Vineyard Regional High School Athletic
Fields Project. The evaluation included chemical analyses of each turf system component (turf
carpet, shock pad, glue and bonding agents, and infill)for SVOCs, metals, and per-and poly-
fluoroalkyl substances (PFAS). Testing was performed to evaluate both total and leachable
concentrations. The analytical results were used in a risk assessment to evaluate possible
pathways for migration of chemicals to the environment, potential exposure to human and
III u��
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environmental receptors, and possible health and environmental risks. The risk assessment was
completed by comparing detected concentrations to standards and screening levels that are
protective for exposure to soil in a residential yard setting(i.e., high frequency contact by
toddlers, young children, adolescents and adults), and protective for migration to groundwater
that is used as drinking water.
Based on the results of the risk assessment Tetra Tech concluded that:
o Concentrations of metals were similar to or less than those that naturally occur in soil
and were below standards and screening levels.
o Most SVOCs were not detected, and those that were detected were below standards
and screening levels.
o None of the six PFAS compounds regulated by MassDEP were detected.Two PFAS
compounds (PFPeA and 6:2FTS)that are not regulated by MassDEP were in synthetic
turf system samples detected at low (estimated) concentrations that were also below
available standards published for other PFAS compounds.
o None of the compounds analyzed were detected at concentrations that would pose a
concern for leaching to groundwater.
The Tetra Tech report also evaluated PFAS using a procedure which evaluates the potential for
transformation of a certain class of PFAS compounds (known as precursors) into other PFAS
compounds,to mimic conditions that could hypothetically occur under some environmental
conditions. The results of the procedure indicate that two additional PFAS compounds (PFHpA)
and PFBA could be generated through transformation of PFAS precursor compounds. Although
these two PFAS compounds are not regulated by MassDEP,the concentrations yielded by the
procedure were less than MassDEP soil standards for regulated PFAS compounds.
A significant aspect of the Tetra Tech study is that it evaluated each of synthetic turf system
components for chemicals that have historically been evaluated in crumb rubber infill (e.g.,
metals and PAHs), as well as PFAS. PFAS is not a chemical that is added to synthetic turf
components, nor is it used to manufacture tires which are recycled to create crumb rubber.
Therefore,there is no reason to suspect that it would be present in synthetic turf carpeting or
crumb rubber infill. However, questions concerning PFAS in synthetic turf were raised in a 2019
article that was published in the Boston Globe and The Intercept. A critical review of the
findings cited in those articles is provided in Attachment 2. In summary,the findings reported in
the articles indicate that PFAS compounds were detected but at concentrations that are within
the range of background concentrations found in soil. Subsequent to the evaluation provided in
Attachment 2, MassDEP published PFAS standards for soil. A review of the PFAS concentrations
reported in the articles indicates that they are below MassDEP's PFAS standards for soil,
indicating that the PFAS reported in the articles would not pose harm to people or the
environment.
The testing completed by Tetra Tech, demonstrated that none of the PFAS compounds
regulated by the MassDEP were detected in any of the synthetic turf systems components, and
that PFAS compounds would not leach from any of the synthetic turf system components at
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levels that would be a concern for groundwater or surface water. As with other studies, the
Tetra Tech study also documented that metals and PAHs in synthetic turf are not a concern for
harm to people or the environment.
We note that the infill material tested by Tetra Tech is not a crumb rubber infill material (i.e., it
is a wood fiber material called BrockFill).Therefore,the analytical results and conclusions of the
Tetra Tech report as they relate to the infill material are not necessarily applicable to the infill
material proposed for the BB&N athletic field project. However, since the results of the Tetra
Tech report indicate that the synthetic turf system would not pose any significant risks to human
health or the environment, it can be concluded that turf carpeting and bonding agents alone
would not pose any significant risks.
In summary, the presence of chemicals in synthetic turf materials have been well documented.
However,numerous studies and reports have also demonstrated that the chemicals that are in the
synthetic turf cannot come out of the materials at concentrations that would harm people or the
environment. Consequently,synthetic turf systems, including turf blades and crumb rubber infill, are
safe for contact by people and will not harm groundwater or surface water.
Evaluation of "Heat Island" and Synthetic Turf
A Heat Island is an area where the temperature is higher than in the surrounding area. Heat Islands are
caused by reduced natural landscape in urban areas,the properties of urban materials (pavement,
roofing, aggregate-based building materials), urban geometry(dimensions and spacing of buildings
which can trap heat), heat generated by human activities (e.g., automobiles, air conditioning), and
weather and geography. In particular,the combination of urban materials and urban geometry can
create large thermal masses that cannot easily release heat. According to the USEPA1, Heat Islands
often build throughout the day and become more pronounced at night due to the slow release of heat
from urban materials.
The surfaces of synthetic turf fields get warmer than the surfaces of natural turf fields. However,the
differences in temperatures vary depending on weather conditions (e.g., sunny versus cloudy) and time
of day. Several studies have examined the differences in heating between synthetic turf fields and
natural turf fields. A comprehensive study by Jim et al. (2017) indicates that:
• On sunny days, surface temperatures of synthetic turf fields can be 30 to 40 degrees C higher
than surfaces of natural turf fields. On cloudy days (defined as days when cloud cover reduced
solar radiation to approximately one-half that of sunny days) surface temperatures of synthetic
turf fields may be approximately 20 degrees C higher than natural turf fields, and on overcast
days (defined as days when cloud cover reduced solar radiation to approximately one-quarter
that of sunny days)there is essentially no difference in field surface temperatures.
11 www.epa.gov/heatislands/learn-about-heat-islands
Buckingham Browne & Nichols School
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• Despite substantial surface temperature differences between synthetic and natural turf fields on
sunny days, there is only a few degrees (centigrade) difference in air temperature between
synthetic turf and natural turf fields at 20 inches and 40 inches above the playing field surface,
and essentially no difference in air temperature at 60 inches above the field surfaces. This
difference becomes smaller as daytime heating increases, with 20-and 40-inch air temperatures
above synthetic turf nearly equaling those above natural turf during the afternoon hours. On
cloudy and overcast days there is essentially no difference in air temperatures between
synthetic turf and natural turf fields at 20-and 40-inches above the playing field surfaces.
• Synthetic turf surfaces and the air above synthetic turf fields heats and cools more rapidly than
those associated with natural turf.
• The solar radiation released by natural and synthetic turf fields during nighttime is the same,
meaning that that synthetic turf does not `hold heat' and release it after sunset. This
observation reflects that fact that synthetic turf has a poor heat storage capacity, which is
reflected in the rapid changes in surface temperature profiles of synthetic turf as compared to
natural turf, and the observation that synthetic turf surfaces return to the same temperature as
natural turf surfaces when solar radiation is reduced (e.g., late afternoon/evening on sunny days
and the duration of the day on overcast days).
The location of the new BB&N athletic facility is presently occupied by a paved (asphalt) parking lot.
Unlike synthetic turf, asphalt continues to release heat once daytime heating is discontinued. In fact, a
study by Yang et al. (2020) demonstrated that asphalt surfaces that are heated by the sun (i.e., `sunny
day' conditions) continue to release heat for several hours after heating is discontinued (i.e., after
sunset). Consequently, replacing the existing asphalt parking lot with synthetic turf fields will improve
environmental conditions by decreasing the existing Heat Island effects contributed by the paved
parking lot.
Collectively, this information suggests that, while synthetic turf field surfaces get warmer than natural
turf field surfaces, air temperatures above synthetic turf surfaces warm only marginally more than
those above natural turf field surfaces, and that synthetic field surfaces do not retain heat once day-
time heating is discontinued. These differences are substantially minimized on cloudy days and do not
exist on overcast days. Moreover, the information suggests that replacing the existing asphalt
parking lot with a synthetic turf field will improve environmental conditions by reducing paved
surfaces that continue to emit heat after sunset. In that respect, synthetic turf fields are different than
urban systems (aggregate buildings, roof tops, and pavement) which are associated with contributing to
Heat Island effects which by the nature of those materials continue to release heat well into the
nighttime hours. Given that the BB&N athletic field will not be surrounded by buildings made of urban
materials, effects associated with urban geometry and lack of air movement will not be a factor. Finally,
consider that the athletic field proposed by BB&N is replacing an asphalt parking lot. It is therefore not
removing any pre-existing green space and thus not reducing natural landscape that already exists.
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References
1. Bleyer, Archie, and Theresa Keegan. 2018. "Incidence of Malignant Lymphoma in Adolescents
and Young Adults in the 58 Counties of California with Varying Synthetic Turf Field Density." Cancer
Epidemiology 53 (April): 129-36. : . .cane
2. Celeiro, Maria,Thierry Dagnac, and Maria Llompart. 2018. "Determination of Priority and Other
Hazardous Substances in Football Fields of Synthetic Turf by Gas Chromatography-Mass Spectrometry: A
Health and Environmental Concern." Chemosphere 195 (March): 201-11.
i. . r
3. Celeiro, Maria, Daniel Armada, Nuno Ratola,Thierry Dagnac,Jacob de Boer, and Maria Llompart.
2021a. "Evaluation of Chemicals of Environmental Concern in Crumb Rubber and Water Leachates from
Several Types of Synthetic Turf Football Pitches." Chemosphere 270 (May): 128610.
. . . . .
4. Celeiro, Maria, Daniel Armada,Thierry Dagnac,Jacob de Boer, and Maria Llompart. 2021b.
"Hazardous Compounds in Recreational and Urban Recycled Surfaces Made from Crumb Rubber.
Compliance with Current Regulation and Future Perspectives."Science of The Total Environment 755
(February): 142566. i. . i
5. Gomes, Filipa O., M. Rosario Rocha,Arminda Alves, and Nuno Ratola. 2021. "A Review of
Potentially Harmful Chemicals in Crumb Rubber Used in Synthetic Football Pitches."Journal of
Hazardous Materials 409 (May): 124998. i. d10.101���
6. Jim, C. Y. 2017. "Intense Summer Heat Fluxes in Artificial Turf Harm People and Environment."
Landscape and Urban Planning 157 (January): 561-76.
7. Massachusetts Department of Environmental Protection (MassDEP). 1995. Massachusetts
Department of Environmental Protection, Bureau of Waste Site Cleanup, "Guidance for Disposal Site
Risk Characterization, In Support of the Massachusetts Contingency Plan." Interim Final Policy
#WSC/ORS-95-141,July 1995 and updates
8. MassDEP. 2014. Massachusetts Department of Environmental Protection, Bureau of Waste Site
Cleanup, Massachusetts Contingency Plan, 310 CMR 40.0000, 25 April 2014 and updates.
9. Massachusetts Department of Public Health (MADPH). Letter from Suzanne K. Condon,
Associate Commissioner Director, Bureau of Environmental Health to Stephanie Bacon, Health Agent,
Office of Board of Health, Medway, MA. March 23, 2015.
ICH
Buckingham Browne & Nichols School
2 June 2021
Page 11
10. Pavilonis, Brian T., Clifford P. Weisel, Brian Buckley, and Paul J. Lioy. 2014. "Bioaccessibility and
Risk of Exposure to Metals and SVOCs in Artificial Turf Field Fill Materials and Fibers." Risk Analysis 34
(1): 44-55. L_____EL ......L_
i.pr 10.1111 risa.12081
11. Perkins AN, Inayat-Hussain SH, Deziel NC, et al. 2019. "Evaluation of potential carcinogenicity of
organic chemicals in synthetic turf crumb rubber." Environ Res. 2019;169:163-172.
doi:10.1016/j.envres.2018.10.018
12. Peterson, Michael K.,Julie C. Lemay, Sara Pacheco Shubin, and Robyn L. Prueitt. 2018.
"Comprehensive Multipathway Risk Assessment of Chemicals Associated with Recycled ("crumb")
Rubber in Synthetic Turf Fields." Environmental Research 160: 256-268
13. Pronk, Marja E.J., Marjolijn Woutersen, and Joke M. M. Herremans. 2020. "Synthetic Turf
Pitches with Rubber Granulate Infill:Are There Health Risks for People Playing Sports on Such Pitches?"
Journal of Exposure Science& Environmental Epidemiology 30(3): 567-84.
s: i. r
14. Schneider, Klaus,Anne Bierwisch, and Eva Kaiser. 2020. "ERASSTRI - European Risk Assessment
Study on Synthetic Turf Rubber Infill-Part 3: Exposure and Risk Characterisation."Science of The Total
Environment 718 (May): 137721.h11ps:.ZLdoLor . i
15. Tetra Tech. 2021. "Synthetic Turf Laboratory Testing and Analysis Summary Report, Martha's
Vineyard Regional High School Athletic Fields Project (DRI 352-M4), Oak Bluffs, Massachusetts."
February 26, 2021.
16. TU RI association. 2020.
r . ractsheet.Artificial%20Tu[f.September2O2
17. Unites States Environmental Protection Agency (US EPA). 1989. "Risk Assessment Guidance for
Superfund,Volume 1. Human Health Evaluation Manual (Part A), Interim Final". Office of Emergency and
Remedial Response. Washington, D.C. EPA/540/1-89/002.
18. US EPA, Office of Research and Development. 2019. "July 2019 Report:Tire Crumb Rubber
Characterization." Reports and Assessments. US EPA.July 24, 2019.hh1tps.-J e a o v�ch�em i�ca I
reser I - - - i - - r i i
19. Yang, Hailu, Kai Yang,Yinghao Miao, Linbing Wang, and Chen Ye. 2020. "Comparison of Potential
Contribution of Pavement Materials to Heat Island Effect."Sustainability. June 10, 2020.
\\haleyaldrich.com\share\CF\Projects\0200977\Deliverable\06022021_HAI_BB&N memo-health and heat effects.dou
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Attachment 1
Massachusetts Department of Public Health Evaluation of Health Concerns
Related to Synthetic Turf
fpl{�{i�P�re�i The Commonwealth o Massachusetts
Executive Office of Health and Human Services
Department of Public Health
Bureau of Environmental Health
250 W Street, Boston, MA 02108-4619
Phone: 617-624w5757 Fax: 6
cHARL S .�E TT 617-624,,5286A �suGmmrnor ter
KARYN E.POLITO MONICA SHAREL#MD,MPH
Ueutenant Governor
ommlWoner
Tel:617. 244M
www.mme.gov/dph
March 23, 2015
Stephanie Bacon, Health Agent
Office of Board of Health
155 Village Street
Medway, IAA 02053
Dear Ms. Bacon:
Thank you for your letter of February 24, 2015, in which you requested that the
Massachusetts Department of Public Health, Bureau of Environmental Health
(MDPH/BEH), evaluate health concerns related to the use of crumb rubber infill material
for artificial turf fields in Medway, Massachusetts. As you are likely aware, our office had
previously evaluated this issue in a series of letters to the Town of Needham ham Board of
Health in 2008, 2011, and 2013.
In response, MDPH BEH staff have evaluated more recent information on potential
exposure opportunities to artificial turf components, including crumb rubber infill, and
evaluated health concerns, including cancer, in relation to exposure to such turf. Decent
media reports on soccer players, particularly goalies that have played on artificial turf,
and the incidence of some cancers have been expressed. These reports raised
concerns about the possible association between playing on crumb rubber fields and
the development of cancers, notably, non-Hodgkin's lymphoma, Hodgkin Lymphoma,
and ostesarcorna. We also evaluated information you provided on the content of the
speck produce used in Medway. Our review is summarized below.
U dated Literature Rev*
Our previous evaluations noted that crumb rubber infill has been found to contain
chemicals, including polycyclic aromatic hydrocarbons PAH # volatile organic
compounds Cs , and metals. We further stated that although these chemicals are in
the material itself, information available at that time did not suggest significant exposure
opportunities to the chemicals in the materials such that we would expect health effects,
We noted that the most relevant sturdy on this topic at the time was a study conducted
by the California Office of Environmental Health Hazard Assessment CA EHH .
Since that time, the CA OEHHA conducted additional evaluations of chemical
concentrations in air above crumb rubber turf fields under active use (CA OEHHA
2010). Air samples were taken above fields and analyzed for VOCs and metals.
Results suggested that adverse health effects were unlikely to occur from inhalation of
Gs or metals in particulates above these fields. To assess the potential for skin
infections duce to bacteria or to skin abrasions on these fields, tests for bacterial
contamination were performed and the frequency of skin abrasions was assessed.
Researchers found fewer bacteria detected on the artificial turf compared to natural turf,
suggesting that the risk of infection to athletes using these fields was actually lower.
However, more skin abrasions were observed in athletes using artificial turf fiefs than
natural turf fields, and the study authors made various recommendations to help prevent
skin abrasions e.g., protective equipment or clothing) and prompt treatment of skin
abrasions.
In another study, the state of Connecticut conducted air sampling at four outdoor
artificial turf fields with crumb rubber infills (most relevant to Medway) under summer
conditions (Simcox et al. 2011). Air measurements were taken using stationary air
sampling monitoring devices as well as personal samplers (placed on people using the
fields). They concluded that exposure opportunities to turf contaminants were not
associated with elevated health risks and suggested that their findings were consistent
with other studies available at the time. A letter prepared by the Connecticut
Department of Public Health reiterates these conclusions (CTDPH 2015).
A 2014 study by researchers at the Rutgers Robert Wood Johnson Medical School i
New Jersey evaluated opportunities for exposures to PAHs, sernivolatile organic
compounds (BMOCs), and heavy metals from exposures to artificial turf fibers and
crumb rubber infills by measuring these constituents in simulated body fluids digestive
fluids, lung fluids, sweat) that represented different routes of exposure (ingestion,
inhalation, dermal). This bioaccessibility study aimed to provide a better measure of the
actual amount of these contaminants that might be absorbed into the body after
exposure. The researchers found that PAHs were routinely below the limit of detection
and BMOCs that have environmental regulatory limits to use for comparison were
identified at levels too low to quantify. Some metals were detected but at concentrations
at which health risks were low, with the exception of lead from the field sample
collected. That sample indicated lead at levels in the simulated digestive fluids that the
authors reported could result in blood lead levels above the current U.S. centers for
Disease Control and Prevention (CDC) reference value for blood lead in children 5
u dQ. It should be rioted that the lead concentration of the materials used in this study
included a sample of turf fiber with a lead concentration of 4,400 mg/kg. This level
contrasts with information on the Medway artificial turf components, which reportedly
either contained lead at 39 mg/kg crumb rubber infill or had no lead (turf fibers) (see
discussion later in this letter). Based on the lead result from this one field sample} the
authors suggested that components of artificial turn fields should be certified for low or
no lead content prior to use. Overall, however, the authors concluded that opportunities
for exposure to constituents in these fluids presented very lover risk among all
populations that would use artificial turf fields Pavilonis et W. 2014).
A study conducted in 2010 in the Netherlands assessed the exposure of soccer players
to PAHs after playing sports on a rubber crumb field. Urine testing in participants
indicated that uptake of PAHs by the participants following exposure to artificial turf with
rubber crumb infiil was minimal. If there is any exposure, the authors reported, uptake is
minimal and within the normal range of uptake of PAHs from environmental sources
and/or diet observed in healthy individuals (van I ooij and Jongeneelen 2010).
It is probably worthwhile to also note that IIHBEH reviewed testing data for artificial
turf for the Torn of Needham, as reported in our letters of 2011 and 2013 to the
[Needham Board of Health. The Town of Needham contracted with an environmental
testing firm to conduct environmental tests including, air measurements of volatile
organic compounds taken in the laboratory and heavy metals (arsenic, cadmium,
chromium, lead, mercury, selenium, zinc)content of crumb rubber materials. Our review
and conclusions for that testing, did not indicate exposures of health concern.
Material in Medway
IIPHIBH reviewed available information provided by the Medway Board of Health
regarding the specific materials used in the Medway fields. These included the APT
Gridiron turf system and Liberty Tire Recycling 10+20 Bhp Dubber Crumb Brantford, ON.
Among the materials provided for these products were statements or test results for
various constituents in these products.
APT submitted a written statement dated October 29, 2014, that reported That the APT
Gridiron turf systems (essentially the grass fibers of the artificial turf) are manufactured
and installed without the use of any lead or heavy metals. They reported that this
included all materials used for the turf fibers and backings, to other documentation
about this product, including any testing results, was provided to support this statement.
With respect to the 10 20 BM Crumb Rubber infill product, laboratory testing results
were provided for this product, although R is not clear whether the testing was for the
materials specifically used in turf applied in Medway. Testing was conducted for metals
content as well as emissions of volatile organic compounds Cs . It appears that
testing included the following; 1 testing for VOCs emitted into a confined air space in
the laboratory after heating the product to 73 degrees F; and 2 content testing for eight
heavy metals, including lead. The laboratory compared results to criteria established by
the Greenguard certification program, part of Underwriters Laboratory, that uses among
its criteria for certification health-based levels derived by the CA EHHA.
Testing results for metals content of the product indicated a lead concentration of 39
mglkg, which is less than the current Consumer Product Safety Improvement Act
(CPSIA) limit of 100 mg/kg: for lead in children's products lirsch et al. 2010). No other
metals were detected.
Test results measuring emissions off-gassing from heated material were provided ire
measurements that cannot be compared to any health-based standards or guidelines
and thus, I PH H did not further evaluate this information. Typically, when certain
products raise health concerns, health agencies review Material Safety Data Sheets
(MSDS). An MSDS provides information on health risks associated with use of the
product. An industry group, Synthetic Turf council, provides a sample template NABOB
for crumb rubber infill material (Synthetic Turf Council 2014). Although this sample
NISDS is not specific to any particular product, it appears to be applicable to crumb
rubber in ill in general. In the section under hazardous Ingredients,"the I SDS notes
that the product can contain fine fibers that may cause irritation symptoms (e.g., itching,
irritation of mucous membranes, eye irritation). The i SDS notes that the crumb rubber
material is generally thought to be a nuisance dust.
Concerns About Cancer Among Soccer PlaverQa
As noted earlier in this letter, some recent nears reports suggested that the incidence of
cancers among soccer players, particularly goaltenders exposed to artificial turf, might
be atypical. These reports included many cancer types, but some focused specifically
on NHL, Hodgkin Lymph rna, and o teo arcorna in three individuals. We thought it
would be helpful to provide additional information on cancers in general and known risk
factors for NHL, Hodgkin Lymphoma, and osteo arcorna.
Cancer in General
Understanding that cancer is not one disease, but a group of diseases, is very
important. research has shown that there are more than 100 different types of cancer,
each with separate causes, risk factors, characteristics and patterns of survival. A risk
factor is anything that increases a person's chance of developing cancer and can
include hereditary conditions, medical conditions or treatments, infections, lifestyle
factors, or environmental exposures. Although risk factors can influence the
development of cancer, most do not directly cause cancer. An individual's risk for
developing cancer may change over time dine to many factors and it is likely that
multiple risk factors influence the development of most cancers. In addition, an
individual's risk may depend on a complex interaction between their genetic make-up
and exposure to environmental agents, including infectious agents and/or chemicals,
This may explain why some individuals have a fairly low risk of developing a particular
type of cancer as a result of an environmental exposure, while others are more
vulnerable.
Cancers in general have long latency or development periods that can range from 10 to
30 years in adults, particularly for solid tumors. In some cases, the latency period may
be more than 40 to 50 years. It is important to motet however, that latency periods for
children and adolescents are significantly shorter than for adults.
Hod kin Lymehoma
Hodgkin Lymphoma is most common in young adults between the ages of 15 and 40,
especially in individuals in their 20s. Among adolescents, it is the most common type of
cancer.
Hodgkin Lymphoma occurs specifically in a type of B lymphocyte or white blood cell)
called the Reed-Sternberg cell while other lymphomas (non-Hodgkin's types) occur in
different cells.
Established risk factors for Hodgkin Lymphoma include: exposure to the Epstein-Barr
virus E ; a previous diagnosis of mononucleosis Orono is caused by the E ;
family history; and certain hereditary conditions (such as ataxia telangiectasia
associated with a weakened immune system. The Epstein-Barr virus is very prevalent in
the general population. Even though most of us have been exposed to the virus (which
remains latent in our bodies), most people do not develop mononucleosis or Hodgkin
Lymphoma. EBV is thought to account for about 20% or 25% of the diagnoses o
classical Hodgkin's in the US.
Higher socioeconomic status is also a possible risk factor. This is thought to be due to
delayed infectious exposures in childhood.
Occupational exposures as risk factors have been studied extensively and none have
emerged as established risk factors. Likewise, there is very little evidence linking the
risk of Hodgkin Lymphoma to an environmental exposure, other than the EB .
Non-Hod kin Lym
hornaiL
NHL refers to a diverse group of cancers that are characterized by an increase in
malignant cells of the immune system. Each subtype of NHL may have different risk
factors associated wfth its development. The specific cause of NHL in most individuals
is unknown.
Although some types of NHL are among the more common childhood cancers, more
than 95% of diagnoses occur in adults. incidence generally increases with age, and
most diagnoses occur in people in their 60s or older.
Established risk factors for NHL include a weakened immune system, associated with
various medical conditions, and exposure to various viruses, An increased risk is faced
y individuals taking immunosuppre sant drugs following organ transplants; individuals
with autoirr mune disorders, such as rheumatoid arthritis and lupus; and individuals who
have taken certain chemotherapy drugs for other cancers. Several viruses have been
own to play a role in the development of NHL, including the human immunodeficiency
virus (HIV), the human T-cell leukemia/lymphoma virus HTL # , and the Epstein-Barr
virus.
Exposure to high-dose radiation (for example, by survivors of atomic bombs and nuclear
reactor accidents and possibly by patients who have received radiation therapy for a
previous cancer) may pose an increased risk. Some studies have also suggested that
exposure to chemicals such as benzene and certain herbicides and insecticides may be
linked with an increased risk of NHL. Smoking has been associated in some studies
with certain types of NHL.
steosarcoma
steosarcorna is a type of malignant bone cancer which accounts for about 2% of
childhood cancers in the United Mates. It is the most common type of cancer that
develops in bone and comprises about 66% of malignant bone tumors in children in
Massachusetts. Most osteo arcor as occur in children and young adults between the
ages of 10 and 30. Teenagers comprise the most commonly affected age group and
are at the highest risk during their growth spun. However, osteo arcoma can occur in
people of any age, with about 0% of all o teosarcornas occurring in people over the
age of 60.
Established risk factors for o teosarcoma include certain inherited syndromes (such as
retlnoblastorna, the Li-Fraumeni syndrome, and others)and certain bone diseases
(such as Paget disease of the bone and hereditary multiple osteochondrormas).
Individuals with these syndromes and bone diseases have an increased risk of
developing osteosarcorna. People who have received radiation treatment for a previous
cancer may have a higher risk of later developing oteosarcorna in the area that was
treated. Being treated at a younger age and with higher doses of radiation both
increase the risk. Because the risk of osteosarcoma is highest between the ages of 10
and 30, especially during the teenage growth spurt, experts believe that there may be a
fink between rapid bone growth and the risk of a bone tumor. children with
osteosarcora are often tall for their age, which supports the link with rapid bone
growth. Other than eradiation, there are no known lifestyle or environmental risk factors
associated with osteorcorn . Asides from these risk factors, the causes of most
osteosarcomas are unknown.
Surnmary
In summary, the scientific literature continues to suggest that exposure opportunities to
artificial turf fields are not generally expected to result in health effects. Testing results
on the crumb rubber infill indicated lead content less than CPSIA statutory limits
established for children's products. For the turf fibers, APT provided a statement that
this material slid not have lead used in its manufacture, but no additional documentation
was provided.
With respect to cancer concerns reported in media stories, it is important to note that
the reports of cancers were of a wide variety of different types, each with its own set of
risk factors. In addition, our staff reviewed cancer incidence data for the Torn of
Medway. The Massachusetts Cancer Registry eI is a population-based surveillance
system that began collecting information in 1982 n Massachusetts residents diagnosed
with cancer in the state. All nearly diagnosed cancer cases among Massachusetts
residents are required by law to be reported to the MCR within sic months of the date of
diagnosis MGL, c.111, s.111 B . This information is kept in a confidential database and
reviewed for accuracy and completeness.
Available information on the occurrence of cancers in children luring in Medway
indicates no diagnoses of Hodgkin Lymphoma, NHL, or osteosarcorna have been
reported to the MCR in a search of their files from 2006 to the present. Although it is
possible that a very recent diagnosis may not yet have been reported to the MC , the
fact that there are no reports of such cancers is reassuring.
Although available resources cannot support IVIDPH conducting environmental testing of
this material, we would be happy to assist the Town of Medway in developing a
sampling and analysis plan as well as provide technical support in interpreting results,
similar to the assistance that we provided to the Town of Needham.
As we stated in our letters to Needham officials, while available information does not
indicate exposure opportunities of health concern, MDP BEH continues to recommend
common sense ways to minimize any potential exposure to chemicals that may be
contained to synthetic turf fields made of crumb rubber. 1 DPH BEH suggests washing
hands after playing on the field and before eating, particularly for younger children with
frequent hand-to-mouth activity, and taking off shoes before entering the house to
prevent tracking in any crumb rubber particles. Also, there are studies that indicate heat
levels on artificial turf fields may rise as outdoor temperatures increase (New York State
2009). Thus, for protection of the players, I DPH BEH recommends increasing
hydration, taking frequent breaks, and watering down the field to cool it on hot days to
prevent the potential for burns or heat stress. Finally, based on recent work in
Califomia, MDPH/BEH recommends that steps be taken to minimize the potential for
skin abrasions e.g., protective equipment) and that skin abrasions be treated promptly
to prevent potential infections.
We Dope this information is helpful to you and Medway residents, if you have any
questions, Tease feel free to contact us at 617-624-5757.
Sincerely,
K. Condon, Associate Commissioner
Director, ureau of Environmental health
References
American Cancer Society. 2 15a. Detailed Guide: Hodgkin disease. Available at
h�t -cancer. r n r ind isease/deta iledg uid efindex.. Last updated March
.
American Cancer Society. 2015b. Detailed Guide: Non-Hodgkin lymphoma. Available at
tt w. an .er. r n r anon-h a kinlyM2 „may ile g i e/ink. Last updated
March 11.
American Cancer Society, 201 c. Detailed Guide: Osteosarcoma. Available a
hft**/Avww.cancer.or ancer/osteosarcoma/detailedauidefindex. Last updated n ar
6.
California Office of Environmental Health Hazard Assessment. 2010. Safety Study of
Artificial Turf Containing Crumb Rubber Infili Made from Recycled Tires: Measurement
f Chemicals and Particulates in the Air, Bacteria in the Turf, and Skin Abrasions
Cuased by Contact with the Surface. OEHHA, Pesticide and Environmental Toxicology
Branch, Funded by the Depa ent of Resources Recycling and Recovery.very. October
20109 121 p.
Connecticut Department of Public Health. 2015. Recent lens Concerning Artificial Turf"
Fields. Letter to Local Health Departments and Districts, January 20, 2015. Connecticut
Department of Public Health, Hartford, CT.
New York State Department of Environmental Conservation and New York State
Department of Health. 2009. An Assessment of Chemical Leaching, Releases to Air and
Temperature at Crumb-lnfilled Synthetic Turf Fields.
Pavil nis# BT; CP Weisel; B. buckley; and PJ Lioy. 2014. Bl accessiblity and Risk of
Exposure to Metals and BMOCs in Artificial Turf Field Fill Materials and Fibers. Risk
Anal. 3444- .
Bianc o, NJ; A Eracker; G. Ginsberg; B Foal; B. Golernblewski; T. Kurland; and C.
Hedrnan. 2011. Synthetic Turf Field Investigation in Connecticut. J T x Envlron Health,
Pert : 4 1 :1133-1 14 .
Synthetic Turf Council. 2014. Guidelines for Crumb Rubber Infill Used in Synthetic Turf
Fields. Printed October 2010, Revised October 23, 2014. Atlanta, GA.
lirscht G; K Gleason; S. Gerstenberger; D Moffett; G. Pulliam, T ahmed; and J.
Fagliano. 2010. Evaluating and Regulating ing Lead in Synthetic Turf. Envir n. Health
Perspect•, 1 1 ■1 34 34 .
von Rooij, DJ, and PJ Jorgeneelen. 2010. Hydro cyp gene in urine of football players
after playing on artificial sports field with the crumb rubber infill. Int Arch Occup Environ
Health, 31 .1 g -11 . DI. 1 .1 s42 - 9- 4 -y.
Attachment 2
Evaluation of PFAS in Synthetic Turf as Reported by Boston Globe and The
Intercept
TO: Patrick Maguire; Synthetic Turf Stakeholders
FROM: Stephen R. Clough, Ph.D., DABT
Senior Environmental Toxicologist
DATE: 25 October zo19
SUBJECT: Low Levels of PFAS Detected in Samples of Discarded Turf
Recent news articles from both the Boston Globe (Toxic chemicals are found in blades of artificial turf)
and The Intercept (Toxic PFAS chemicals found in artificial turf) have reported analytical laboratory
results of synthetic turf sampled for the presence of perfluorinated alkyl substances (PFAS). This
information, however, is of a preliminary nature as the results having not been peer-reviewed nor have
the concentrations been put into context (e.g. compared to ambient levels reported for soils in
unimpacted locations).
In lieu of this information, suppliers of synthetic turf have been contacted to determine if PFAS are
utilized in the manufacture of their products (PFAS is not present in recycled tires and therefore crumb
rubber). Vendors and manufacturers of turf products have, in the past, stipulated that all of their
products meet California Prop 65 and European REACH standards of safety. Moving forward, Activitas
Inc. wants to ensure that all products used in the construction of their synthetic turf fields meet the
highest levels of quality assurance and safety, which includes minimizing exposure and subsequent risk
to any potentially toxic chemicals of concern.
Background. PFAS are a family of highly fluorinated alkyl compounds used in a host of commercial and
consumer products to provide durable waterproof coatings. Because of the nonspecific methods used
to generate thousands of different types of PFAS, little has been done in terms of understanding their
fate and transport. The scientific community is therefore evolving its understanding of PFAS in the
environment. PFAS are considered to be contaminants of emerging concern (CECs). CECs are
chemicals that have the potential to affect human health or present an environmental risk, and either:
(1) do not have regulatory cleanup or health-based standards and/or (2) regulatory standards are
evolving due to new science, detection capabilities or exposure pathways. PFAS are "ubiquitous" in the
environment because a) they have been used in hundreds of different consumer products (e.g. carpet,
waxes, lubricants, nonstick coatings, firefighting foams, leather, etc.) for over 6o years and b) they do
not degrade and tend to concentrate in wildlife. Additionally, the carbon-fluorine bond affords
detection of most PFAS at infinitesimally low levels, thus allowing observation in all media: air, soil,
sediment, groundwater, surface water, animals and humans. Because the amount of peer-reviewed
information available on PFAS is voluminous, it is recommended the reader peruse "fact sheets"
available in States that are affected by environmental releases(e.g. ITRC PFAS Fact Sheets).
Toxicity research is also evolving, and several large epidemiological studies have "linked" exposure to
adverse health effects in humans following long-term drinking water exposure to PFOA and PFOS
compounds. The primary exposure route that the USEPA and State regulatory agencies have identified
is through consumption of PFAS in contaminated drinking water. Based on research studies and what
is known about the chemical composition of PFAS, dermal (skin) exposure to PFAS containing
materials is not significant and thus poses a negligible human health risk. Similarly, due to the high
water solubility of PFAS and low volatility, these compounds pose a negligible health risk via the
inhalation exposure pathway.
Review of Methods. While the preliminary results following the sampling and analysis of discarded turf
appears to indicate that PFAS may be present in both the backing and the blades of synthetic turf, a
more careful evaluation of the information from the newspaper articles has identified the following
issues that may bias an uninformed reader:
oc It is well documented at both the State and Federal level that cross-contamination during
sampling is a very important issue and, given the ubiquity of PFAS, is a common problem in the
field. Technicians need to go through meticulous training to avoid contaminating the sample
with materials containing PFAS or fluorine (including gloves, clothing, sampling items,
containers, notebooks, makeup, perfumes, etc.). The articles do not mention what precautions
were taken in the field, and the results would be suspect if Massachusetts Department of
Environmental Protection standard operating procedures were not followed.
oo There is no certified method for analyzing PFAS concentrations in materials other than a US
EPA method for analyzing PFAS in drinking water. Since the samples were synthetic turf and
not drinking water, the methods used for analysis were likely not certified and therefore, the
results are questionable. Additionally, the article incorrectly compares apples to oranges,
stating "...the swatch of turf from Franklin contained Zgo parts per trillion of one of the most
common PFAS chemicals, well above federal safety standards for drinking water." The
laboratory results from a solid `swatch"would be reported as nanograms per kilogram (ng/kg),
but a standard for drinking water would be nanograms per liter(ng/L). Thus the comparison of
a PFAS in a bulk sample to a drinking water advisor is misleading.
oo The article noted that an additional eight samples were analyzed for total fluorine and assumed
that total fluorine is an indication that PFAS is present.Total fluorine, however, is a non-specific
method and thus a poor proxy for PFAS. The method can be biased by the presence of many
non-PFAS compounds. For example, some anionic surfactants applied to the field drain may
contain fluorine. Many consumer products also contain fluorine such as toothpaste,
mouthwash and household cleaners. The presence of fluorine, therefore, does not necessarily
indicate PFAS compounds are present.
Evaluation of the Analytical Results and Potential Exposure/Risk. If one assumes in good faith that
the results are correct,what does a concentration of 190 parts per trillion (o.19 ug/kg)of PFOS in
synthetic turf mean? A review paper by Vedagiri and Loso(Remediation Journal, 201.q) identified the
range of PFOS levels in soil samples taken from "ambient"or"background"locations in 21 States"with
no known point source"of PFAS. In other words, samples were taken from rural, uncontaminated areas
that were away from urban/suburban impacts. The range of concentrations for PFOS,which was
detected in every soil sample taken in North America (N=38), was o.o18- 2.55 µg/kg (range of PFOA
was 0.059—1.84 ug/kg). The concentrations in the eastern U.S. are much higher(>o.184ug/kg). Thus,
a concentration of o.19 ug/kg PFOS in a swatch of used turf falls into this uncontaminated
concentration range which would be considered "clean". While synthetic turf is not soil,the fields do
receive atmospheric deposition of dust which is recognized as a major PFAS transport mechanism.
Moving forward, concentrations in swatches would need to approach 2.5 parts per billion of PFOS (and
1.8 ug/kg PFOA)to raise a concern in terms of categorizing used turf as a potentially hazardous
material.
These authors also compared these values to a residential soil Risk Screening Level of 1,26o ug/kg
which applies to both PFOS and PFOA. All the background concentrations were well below the safe soil
RSL"by two to three orders of magnitude". The concentrations of PFOS in soil cited by ITRC's recent
"Fact Sheets"(Table 4-2)that are protective of both human health and underlying groundwater are
also much greater than the value of o.19 ug/kg cited by the recent articles. Based on these
comparisons, human health risk is negligible.
Finally, it is noteworthy to mention, based on the conclusions of US EPA's recent Synthetic Turf
Research Action Plan,that bioavailability of toxic chemicals(e.g. metals, polycyclic aromatic
hydrocarbons) in synthetic turf is very low(<_3%). Thus reporting "total" PFAS that would be bound up
in the matrix of the turf backing or plastic blades would overestimate what an athlete would actually be
exposed to following contact.
Based on the above information, which addresses analytical uncertainties, concentrations relative to
clean background locations, potential exposure, and subsequent human health risk, one may conclude
that the discovery and reporting of ultratrace levels of PFAS in used synthetic turf appears to be
overstated if not misleading.
Activitas, Inc. will continue to monitor this important issue and strive to keep all synthetic turf products
free from any potentially toxic constituents of concern. We will also provide updates on this subject as
additional information becomes available.