NCHR’s Comments to EPA’s Children’s Health Protection Advisory Committee

December 11, 2020

Thank you for the opportunity to speak today on behalf of the National Center for Health Research. I am Dr. Meg Seymour, a senior fellow at the center. Our center is a non-profit public health organization that analyzes and explains scientific and medical information pertaining to the safety and effectiveness of consumer products, medical products, and exposures in the environment, in order to improve policies, programs, services, and products.  We do not accept funding from companies that make the products that we evaluate.

We are glad that the EPA is concerned about PFOAs, PFAs, and other endocrine disrupting chemicals, and these exposures are of great concern to us.  In addition to products in the home such as cookware and carpeting, we are concerned about exposures from endocrine disrupting chemicals and lead in artificial turf, as well as playground surfaces made with rubber.  The rubber is sometimes from recycled tires, and sometimes “virgin rubber”, but in either case is made from petroleum and contains lead and endocrine disrupting chemicals. We have reviewed the scientific data regarding the health risks of these materials and the toxic chemicals that they contain.

The EPA has reviewed some data on artificial turf, but has not examined the specific impact on children’s health and has not examined exposure to the rubber surfaces on playgrounds that children use day after day, week after week, year after year. Of particular importance, these fields and playgrounds are often on school property, making children a captive audience during a non-pandemic school year. A 2018 study by Yale researchers on the chemicals in artificial turf found that 20% were probable carcinogens, and 40% were irritants that can cause asthma or other breathing problems.  Further, it is known that exposure to lead causes cognitive damage, and exposure to endocrine disrupting chemicals can cause attention problems, exacerbate early puberty and obesity, and as noted in the previous cited study may eventually cause cancer.  Based on these known risks of lead and chemical exposure, we urge the EPA to conduct research on how currently used materials for artificial turf and playground materials can pose risks to the health of children who play on them, and to develop standards to regulate the safety of these materials.  In addition, the infill from artificial turf does not stay in place, but instead goes home in children’s clothes and on their skin, and is washed away to nearby grass and streams.

There is no exposure to lead that is considered safe for children.  Endocrine disrupting chemicals are likely to be particularly harmful for growing children. The manufacturers of these play surfaces often claim that they have passed all federal standards, but there are currently no federal requirements for safety testing of these products before they are sold. This needs to be corrected, and standards need to be developed and required.

To date, the materials used for these products are often not disclosed publicly, making independent research into potential risks difficult to conduct. We therefore urge the EPA to dedicate more resources towards studying the chemicals and metals contained in artificial turf and playground surfaces, and focus on ensuring that the materials used are safe for children who will be frequently exposed and/or who might be particularly vulnerable because of other health conditions and other exposures.

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