We are writing with an urgent request to immediately stop the planned use of an artificial rubber surface for the soccer field and playground in the Bainbridge Park Enhancement Project. It is of critical importance that the chosen material be safe for children and the surrounding environment. The current selection contains toxic chemicals that put vulnerable children at risk, and safer alternatives should be considered immediately.

During the July 14, 2025 City Council meeting, Chantell O’Neal, the Assistant Director of Engineering for the City, provided a brief overview of the Bainbridge Park Enhancement Project and the status of current construction. Of specific interest, Chantell noted that the material for the soccer field will be a “bonded poured-in-place rubber surface (minute 21:39).” Chantell highlighted that there was a thorough review and evaluation of options to select materials—including public noticing, review, and workshops, and that information is available on the City’s website. However, upon review of the project’s webpage—none of that information is available for consideration on the project’s webpage (https://www.city.fortbragg.com/departments/public-works/bainbridge-park-enhancement-project).

It is of critical importance to the community that the material for both the playground and the soccer field is safe for kids and the surrounding environment. As outlined below, children are uniquely vulnerable to the effects of toxic chemicals associated with poured-in-place rubber because their organ systems are developing rapidly, their detoxification mechanisms are immature, and they have more hand-to-mouth exposure to environmental contaminants than adults. Adult caregivers who spend time at playgrounds, especially pregnant women, the elderly, or those with medical vulnerabilities such as asthma, can also be affected by chemicals in surfacing materials. In addition, there are alternatives that do not put at risk kids, caregivers, or the surrounding environment which should be immediately considered by the City of Fort Bragg. 

Of interest along the coast, statewide there have been a number of recent playground projects that have been prohibited from use of Poured-in-Place surfacing by the California Coastal Commission because of the pollutants to humans and the environment (see Coastal Commission 2024 Memo, Potential adverse environmental effects of proposed Poured-in-Place rubber playground surfacing product and recommendations for alternative materials):

• July 11 2024: CDP 5-23-0345 Newport Mesa Unified School District (NMUSD): https://documents.coastal.ca.gov/reports/2024/7/Th15b/Th15b-7-2024-report.pdf Special Condition No. 1 prohibits the proposed Poured-in-Place rubber playground surfacing product and similar types of materials; Special Condition No. 2 indicates the types of acceptable playground surfacing materials to minimize the discharge of hazardous chemicals and microplastic pollution into the environment.
• May 7 2025: CDP 1-22-0509 City of Crescent City Beachfront Park: https://documents.coastal.ca.gov/reports/2025/5/w10a/w10a-5-2025-report.pdf Special Condition 9C prohibits the use of synthetic/artificial turf/grass; Special Condition 9 which prohibits the proposed Poured-in-Place rubber playground surface product and similar types of materials; Special Condition 10 which indicates the types of acceptable playground surfacing material(s) to minimize the discharge of hazardous chemicals and microplastic pollution into the environment. 
• June 11 2025: CDP 5-24-0064 City of Los Angeles, Department of Recreation and Parks. https://documents.coastal.ca.gov/reports/2025/6/w9a/w9a-6-2025-report.pdf Special Condition 1 prohibits the proposed Poured-in Place rubber playground surfacing product and similar types of materials; Special Condition 2 indicates the types of acceptable playground surfacing materials to minimize the discharge of hazardous chemicals and microplastic pollution into the environment. 

Therefore, we urge City Staff and, Councilmembers, and General Public to immediately stop use of the poured in-place rubber for the soccer field and playground, and to instead utilize a safe, acceptable surface material that avoids and minimizes discharge of hazardous chemicals and microplastics into the environment.

Health and Environmental Risks from Poured-in-Place Playground Surfaces
There are documented health and environmental contamination risks associated with poured-in-place (PIP) rubber playground surfaces from pollutants (see the Figure 1) including Polycyclic Aromatic Hydrocarbons (PAHs), phthalates, and volatile organic compounds. In general, PIP is made from granulated particles processed from materials such as waste tires, thermoplastic elastomer (TPE), or ethylene propylene diene terpolymer rubber (EPDM), and held together with chemical binders and adhesives like thermoplastic vulcanizate (TPV). In TPV, a vulcanized product such as EPDM is combined or coated with a thermoplastic, such as polypropylene. 

 A number of PAHs have been identified as known or suspected human carcinogens by the International Agency for Research on Cancer. Many of these PAHs (e.g. benz(a)anthracene, benzo(a)pyrene, benzo(k)fluoranthene, benzo(b)fluoranthene, indeno(1,2,3-c,d)pyrene, chrysene, and dibenz(a,h)anthracene) have been found in waste tire rubber, in the air around the rubber, or in leachate from the rubber. Tires are made from styrene butadiene rubber (SBR) and a variety of added chemicals and materials including stabilizers, fillers, and vulcanization agents. Many chemicals found in tires are known to be hazardous to human health or the environment; these include polyaromatic hydrocarbons (PAHs), volatile organic compounds (VOCs), 6-phenylenediamine (6PPD), and heavy metals such as lead and zinc, and other chemicals of concern including organophosphate esters (OPEs). Several VOCs are known carcinogens (i.e. benzene and hexane), and metals (i.e. lead) found in waste tires. Even low levels of lead can result in behavior and learning problems, slowed growth, and anemia in children. Concerns associated with other chemicals found in tires (e.g. phthalates) include endocrine disruption. 

With respect to environmental risks, numerous studies show that metals such as zinc, and toxic chemicals such as PAHs and phthalates, can leach from poured-in-place surfaces into the surrounding environment through stormwater runoff. Even small amounts of these toxicants can create negative effects on aquatic life. Synthetic materials also contribute to plastic and microplastic pollution as the pieces migrate outside of intended play areas and break down into smaller pieces over time. 

Safe Alternatives for Bainbridge Park
There are a variety of safer alternatives available to use for resurfacing the playground and soccer field at Bainbridge Park. Acceptable playground surfacing materials to minimize the discharge of hazardous chemicals and microplastic debris should include the following (recommendations provided here are adopted from recently authorized playground projects identified above CDP 5-23-0345; CDP 1-22-0509; CDP 5-24-0064):

A.      Natural Materials. Natural materials such as engineered wood fiber (EWF); cork PIP surfacing; loose-fill materials such as sand, pea gravel, wood chips, bark, or pieces of natural rubber; and mats, pads, or tiles made from natural rubber (not waste tire rubber) shall be the preferable choice for playground surfacing materials, where feasible. Mats, pads, or tiles that do not contain waste tire material may be installed on top of EWF or loose-fill playground materials to create wheelchair-accessible pathways to playground equipment, and/or to prevent displacement of loose-fill materials in high-use areas such as under swings. EWF with a resin binder (“bonded EWF”) may also be used to create wheelchair-accessible pathways in the playground. Though the materials described in this section are preferable, the materials discussed in Section B below may be used instead in the circumstances described therein.

B.      Low-Toxicity Non-granular Plastics. Playground surfacing products made from types of plastics that have documented low toxicity to humans and the environment shall be acceptable if use of natural surfacing materials is not feasible. Any plastic products used for the top surface of the playground shall contain only non-granular plastics, not resin-bonded granules, to minimize microplastic pollution. Acceptable low-toxicity non-granular plastic playground surfacing products shall include, but are not limited to: 

a.      Woven or non-woven roll-out polyester beach access mats that provide wheelchair-accessible pathways across sand. 

b.      Injection-molded polyvinyl chloride (PVC) interlocking perforated tiles that integrate with loose-fill surfacing materials to provide wheelchair-accessible pathways and/or to prevent displacement of loose-fill surfacing materials under high-use playground equipment (such as swings and slides). These tiles may also be used throughout the playground when installed on top of a cushioning pad. The cushioning pad beneath these tiles shall not contain waste tire material. 

c.      Cross-linked polyethylene foam (XPE) shock pads may be used as a cushioning material, such as under injection-molded interlocking perforated PVC tiles, to provide fall protection under playground equipment or throughout the playground.

References

·         California Coastal Commission. 2024. Potential adverse environmental effects of proposed Poured-in-Place rubber playground surfacing product and recommendations for alternative materials. (CDP No. 5-23-0345, Newport Mesa Unified School District). https://documents.coastal.ca.gov/reports/2025/6/W9a/W9a-6-2025-exhibits.pdf#page=29  

·         U.S. Environmental Protection Agency, and Centers for Disease Control and Prevention. (April 2024). Synthetic Turf Field Recycled Tire Crumb Rubber Research Under the Federal Research Action Plan. Final Report Part 2- Exposure Characterization Volume 1. https://www.epa.gov/system/files/documents/2024-04/tcrs-exposure-characterization-volume-1.pdf 

·         Booker, N.W., et al. (2024). Children and Athletes at Play on Toxic Turf and Playgrounds. National Center for Health Research, Washington D.C. https://www.center4research.org/children-athletes-play-toxic-turf-playgrounds/ 

·         University of Massachusetts. 2023. Playground Surfacing Choosing Safer Materials for Children's Health and the Environment. https://www.uml.edu/docs/Playground_surfacing_report_Dec2023_tcm18-377890.pdf 

·         Massey, R., et al. (2019). Athletic Playing Fields: Choosing Safer Options for Health and the Environment. Toxics Use Reduction Institute, University of Massachusetts Lowell. https://www.turi.org/var/plain_site/storage/original/application/b9727dedf5860ae7e83e3226d058b7ee.pdf  

·         Pollard, L. and R. Massey. (2023). Playground Surfacing: Choosing Safer Materials for Children's Health and the Environment. Lowell Center for Sustainable Production and Toxics Use Reduction Institute, University of Massachusetts Lowell. https://www.uml.edu/docs/Playground_surfacing_report_Dec2023_tcm18-377890.pdf  

·         U.S. Consumer Product Safety Commission. (2015). Public Playground Safety Handbook. https://www.cpsc.gov/s3fspublic/325.pdf   

·         U.S. Access Board. (2007). Accessible Play Areas: A Summary of Accessibility Guidelines for Play Areas. https://www.access-board.gov/files/ada/guides/play-areas.pdf 

·         State of California-Office of Environmental Health Hazard Assessment (OEHHA), Contractor’s Report to the Board. Evaluation of Health Effects of Recycled Waste Tires in Playground and Track Products. January 2007. https://www2.calrecycle.ca.gov/Publications/Details/1206 

·         Benoit G, Demars S. Evaluation of organic and inorganic compounds extractable by multiple methods from commercially available crumb rubber mulch. Water, Air, & Soil Pollution. 2018;229:64. https://doi.org/10.1007/s11270-018-3711-7 3.  

·         Anderson SE and Meade BJ. Potential Health Effects Associated with Dermal Exposure to Occupational Chemicals. Environmental Health Insights. 2014; 8(Suppl 1):51– 62. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC4270264/    

·         Ecology Center. 2019. Report on lead in pour in place (PIP) rubber playground at Janney Elementary School, 4130 Albemarle St. NW, Washington, DC. https://drive.google.com/file/d/1UfMzsVQ0EZKquGlnUKBgkspohIod9D-H/view 

·         Ecology Center. 2025. Playgrounds Should be Fun and Toxic-Free. https://www.ecocenter.org/playgrounds-should-be-fun-and-toxic-free#:~:text=Additionally%2C%20tires%20are%20known%20to,within%20artificial%20turf%20were%20low 

·         Ecology Center. 2025. Playground Surfaces. https://www.ecocenter.org/our-work/purchasing-safer-cities/goals-sustainable-purchasing/playgrounds-and-sports-fields-0 

·         Landrigan, P. 1998. Environmental Hazards for Children in USA. International Journal of Occupational Medicine and Environmental Health, 11(2), 189–94.

·         U.S. Consumer Product Safety Commission. 2015. Public Playground Safety Handbook. Retrieved from https://www.cpsc.gov/s3fs-public/325.pdf 

·         Surface America. (n.d.). Recreational and Athletic Surfacing. Retrieved November 14, 2018, from https://www.surfaceamerica.com/product/playbound-poured-in-place/ 

·         Game Time. 2018. Poured in place rubber. Retrieved November 14, 2018, from https://www.gametime.com/playgroundsurfacing/poured-in-place-rubber 

·         US Playground Surfacing. (n.d.). Unitary Rubber Accessibility Matting. Retrieved from https://usplaygroundsurfacing.com/unitary-rubber-surfacing/ 

·         The Rubber Company. (n.d.). Rubbagrass® Rubber Grass Mats. Retrieved from https://therubbercompany.com/safetysurfacing/grass-matting-safety-surfacing/rubbagrass-rubber-grass-mats 

·         Toxics Use Reduction Institute. 2017. Sports turf alternatives assessment: preliminary results, infill made from recycled tires. Retrieved from https://www.turi.org/Our_Work/Community/Artificial_Turf/Infills_Recycled_Tires 

·         Llompart, M., Sanchez-Prado, L., Pablo Lamas, J., Garcia-Jares, C., Roca, E., & Dagnac, T. 2013. Hazardous organic chemicals in rubber recycled tire playgrounds and pavers. Chemosphere, 90(2), 423–431.

·         Tian, Z., Zhao, H., Peter, K. T., Gonzalez, M., Wetzel, J., Wu, C., … Kolodziej, E. P. 2021. A ubiquitous tire rubber-derived chemical induces acute mortality in coho salmon. Science (New York, N.Y.), 371(6525), 185–189.

·         Moreno, T., Balasch, A., Bartrolí, R., & Eljarrat, E. 2023. A new look at rubber recycling and recreational surfaces: The inorganic and OPE chemistry of vulcanised elastomers used in playgrounds and sports facilities. Science of The Total Environment, 868, 161648.

·         International Agency for Research on Cancer. 2018. Agents classified by the IARC monographs, Volumes 1-123. Retrieved from https://monographs.iarc.fr/agents-classified-by-the-iarc/ 

·         U.S. Environmental Protection Agency. 2016. Federal Research Action Plan on Recycled Tire Crumb Used on Playing Fields and Playgrounds, Status Report. Retrieved from https://www.epa.gov/sites/production/files/2016-12/documents/federal_research_action_plan_on_recycled_tire_crumb_used_on_playing_fields_and_playgrounds_status_report.pdf 

·         U.S. Environmental Protection Agency. (n.d.). Learn about lead. Retrieved from https://www.epa.gov/lead/learn-about-lead 

·         Massey, R., Pollard, L., Jacobs, M., Onasch, J., & Harari, H. 2020. Artificial turf infill: a comparative assessment of chemical contents. New Solutions, 30(1), 10–26.

·         Tarafdar A, Oh MJ, Nguyen-Phuong Q, Kwon JH. Profiling and potential cancer risk assessment on children exposed to PAHs in playground dust/soil: a comparative study on poured rubber surfaced and classical soil playgrounds in Seoul. Environ Geochem Health. 2020 Jun;42(6):1691-1704. doi: 10.1007/s10653-019-00334-2. Epub 2019 May 27. PMID: 31134396. 

·         State of California-Office of Environmental Health Hazard Assessment (OEHHA), Contractor’s Report to the Board. Evaluation of Health Effects of Recycled Waste Tires in Playground and Track Products. January 2007. https://www2.calrecycle.ca.gov/Publications/Details/1206 

·         Benoit G, Demars S. Evaluation of organic and inorganic compounds extractable by multiple methods from commercially available crumb rubber mulch. Water, Air, & Soil Pollution. 2018;229:64. https://doi.org/10.1007/s11270-018-3711-7 3.  

·         Anderson SE and Meade BJ. Potential Health Effects Associated with Dermal Exposure to Occupational Chemicals. Environmental Health Insights. 2014; 8(Suppl 1):51– 62. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC4270264/    

·         Ecology Center. 2019. Report on lead in pour in place (PIP) rubber playground at Janney Elementary School, 4130 Albemarle St. NW, Washington, DC. https://drive.google.com/file/d/1UfMzsVQ0EZKquGlnUKBgkspohIod9D-H/view 

·         Ecology Center. 2025. Playgrounds Should be Fun and Toxic-Free. https://www.ecocenter.org/playgrounds-should-be-fun-and-toxic-free#:~:text=Additionally%2C%20tires%20are%20known%20to,within%20artificial%20turf%20were%20low 

·         Ecology Center. 2025. Playground Surfaces. https://www.ecocenter.org/our-work/purchasing-safer-cities/goals-sustainable-purchasing/playgrounds-and-sports-fields-0 

·         Mount Sinai Institute for Exposomic Research. 2022. Artificial Turf and Children’s Health. https://www.healthandenvironment.org/assets/images/webinarimages/Evans%20Slides.pdf 

·         Children’s Environmental Health Network. 2025. Health Implications Associated with Crumb Rubber and Artificial Turf. https://cehn.org/health-implications-associated-with-crumb-rubber-and-artificial-turf/ 

·         U.S. EPA & CDC/ATSDR. (2019). Synthetic Turf Field Recycled Tire Crumb Rubber Research Under the Federal Research Action Plan Final Report: Part 1 - Tire Crumb Characterization (Volumes 1 and 2). (EPA/600/R-19/051). U.S. Environmental Protection Agency, Centers for Disease Control and Prevention/Agency for Toxic Substances and Disease Registry. https://www.epa.gov/sites/default/files/2019-08/documents/synthetic_turf_field_recycled_tire_crumb_rubber_research_under_the_federal_research_action_plan_final_report_part_1_volume_1.pdf 

·         Massey R, Pollard L, Jacobs M, Onasch J, Harari H. Artificial Turf Infill: A Comparative Assessment of Chemical Contents. New Solut. 2020 May;30(1):10-26. doi: 10.1177/1048291120906206. Epub 2020 Feb 23. PMID: 32089037. https://pubmed.ncbi.nlm.nih.gov/32089037/ 

·         Collaborative for Health & Environment. 2023. Playground Surfacing: Fun & safety without toxic chemicals. https://www.healthandenvironment.org/latest-research/blog/playground-surfacing-fall-protection-and-fun-without-toxic-chemicals#:~:text=PIP%20unitary%20surfacing%20draws%20its,can%20also%20get%20very%20hot