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Statement of Commissioner Elliot F. Kaye on the Status of Urgently-Needed Federal Playground and Artificial Turf Safety Efforts

December 12, 2017

All across America, children spend countless hours on playgrounds and sports fields developing their minds and their bodies.  These playing surfaces should provide a safe space that fully supports their growth.  Instead, parents, coaches and athletes throughout the U.S. are legitimately concerned about real questions that have been raised about the health impacts to our children from chemical exposure from the crumb rubber infill used on many playgrounds and fields.  As a parent and as a policymaker, I strongly share those concerns. 

Our approach to playing surfaces should be very simple – no one should be exposed to harmful chemicals.  Period. 

A number of us have worked extremely hard to make this issue a priority for coordinated federal study and, as necessary, strong action.  Staff scientists at the U.S. Environmental Protection Agency, Centers for Disease Control and Prevention/Agency for Toxic Substances and Disease Registry and the U.S. Consumer Product Safety Commission have made critical contributions to the Federal Research Action Plan (FRAP) on Recycled Tire Crumb Used on Playing Fields and Playgrounds.[1]  It is important that this work continue as quickly as possible and with the necessary funding and resources. 

In the meantime, some manufacturers have agreed to a voluntary standard, ASTM F3188, which calls for them to sell crumb rubber infill that does not exceed certain levels of some heavy metals.  While this is a very small step in the right direction, there is a real chance it intentionally or unintentionally will be used to provide a false sense of security for purchasers and users of artificial turf.

Here are just some of the severe flaws with relying on this voluntary standard as an assurance of safety:

  1. It only applies to infill materials intended for use in “sports surfaces” and does not explicitly apply to materials used on playgrounds.  This omission is particularly disconcerting when you consider that our youngest – and thus most vulnerable – children are the ones using playgrounds on a daily basis;
  2. It addresses only a few chemicals of concern in the infill materials that it does cover, leaving other chemicals of concern such as additional heavy metals, Volatile Organic Compounds (VOCs), Semi-volatile Organic Compounds (SVOCs), particulates and microbes unaddressed; 
  3. Even for the chemicals it does address, it does not consider all routes of actual real-time exposure;
  4. It does not include requirements for any other components of the product such as fabrics, adhesives, underlayment or coatings;
  5. It does not require any kind of independent verification or third-party testing;
  6. It contains no specific aging of samples or sampling method, which is another critical omission because only proper sampling ensures valid test results, even for a limited standard such as this one; and
  7. The voluntary standard is just that – voluntary.  All of industry does not have to comply with its requirements.   

These are tremendous shortcomings, yet you would never know that from some of the statements made about the standard.  Those statements are a disservice to safety and to consumers rightly looking for more than mere praise of a tiny and potentially very misleading step.

Here is what this voluntary standard does not mean.  It does not mean the government (or any other legitimate, independent body) has concluded its exhaustive research and declared crumb rubber safe.  It does not mean that the products covered by the standard have been proven safer than alternatives.  And it most definitely does not mean that a product that complies with this standard is safe. 

Here is all you can take from the creating of this voluntary standard: If you or your community is set on installing and using a crumb rubber play surface, and if the community has the choice between a manufacturer who claims to follow the standard and one who will not provide that certainty, and the community chooses the one who claims to follow the standard, maybe your child will be exposed to fewer of the chemicals of concern in any surface installed after the standard is in effect. 

We cannot lose sight of the fact that there is a better and more productive path forward for our nation than relying only on this standard.  After an unconscionable delay, the government finally began last year a legitimate and comprehensive interagency study of this critical safety question.  This interagency task force published a status report in December 2016.[2]  One year later, this effort must remain a genuine federal government priority so that parents can know without worry that their children can use these spaces to safely play, grow, develop and to help reach their full potential. 


Statement of Commissioner Elliot F. Kaye on the Status of Urgently-Needed Federal Playground and Artificial Turf Safety Efforts (PDF)

[1] See, e.g.,….

[2] See…;

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