Ban Toxic Petrochemical Playgrounds, Build Nature Playgrounds #BanPetrochemicalPlaygrounds
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San Francisco Parks and Recs held a groundbreaking event in April, 2019 for renovating 5 San Francisco Playgrounds, with more to come. All approved designs have poured in place (PIP) rubber or artificial turf as a playground surface, which replaces traditional sand. The cost of renovating 13 playgrounds is over 40 million dollars! When playgrounds are built of plastic and rubber, their lifecycle is 8-10 years, after that they need to be trashed and replaced with new, more expensive crap, made of petrochemicals again, locking municipalities in vicious cycles of fundraising and using public money to finance it. The average cost per playground is $3 million dollars. The poured in place rubber is advertised to the public as safe, and low maintenance. But is it safe, and how low maintenance is it?
Most people believe that poured in place rubber lasts a lifetime. This is just simply not true. The average life of a poured in place rubber surface is 10 years with the proper maintenance. Poured-in-place surfaces have a top color layer that is only 3/8" to 1/2" in thickness. Without regular maintenance and repairs this color layer will prematurely break down and expose the fragile cushion layer below. Early detection, proper repairs, and maintenance by experts are critical in extending the life of the investment. Glue/sealant with UV protection, which holds the rubber granules in the top layer together, wears away due to dirt and grime left on the surface, plus exposure and use. Rubber color granules get exposed and break away from the surface. When the surface is new, it needs to re resealed annually, to prevent the granulation, and any small cracks need to be repaired. But once the granulation is already happening, it means that the color-wear layer is now too thin, safety compliance is now an issue. Crack and hole repairs are numerous and expenive. A new color-wear layer must be added on top. When this is not done at the right time, holes and peeling of the top layer become trip hazards, and the fragile safety cushion layer is exposed and rapidly deteriorates. Rotting occurs and spreads. Safety issues become many and serious. Constant repairs become too costly. Tear out and replacing the surface is required. Surface is not safe to fall on anymore, because the cushion layer failed.
I often go to Dolores Park, which has a playground renovated in 2012. I can't help but notice multiple holes, with some of them patched. Most of the surface is cracked, with black shredded tires layer picking through. It is beyond repair, and not safe anymore. It has only been 7 years. It cost over 3 million dollars to renovate that playground. The rubberized surface failed to last even 10 years, because it wasn't properly maintained, it was not sealed annually, it was not washed regularly, the top layer was never changed. The only maintenance conducted is patching holes. But it doesn't make the surface safe again, because it is at the last stage of deterioration, when the patching doesn't help. The entire surface needs to be replaced, not just the top, but also the cushion level. The deteriorated rubber surface on playgrounds of San Francisco Dolores Park are real examples of how low cost promise turned into high cost venture.
Most people believe that rubber safety surface is the safest thing that the child can fall onto. But is this true? When the playground surfacing safety Standards were originally written over 20 years ago, the predominant impact attenuating playground surfacing materials installed in playgrounds were organic non rubber-based products. Over the decades we have witnessed a steady decline in the usage of organic non rubber-based products and the increased usage of inorganic rubber-based products. After several decades it would be reasonable to assume that in addition to a reduction in mortality rates resulting from playground equipment falls, the general injury rates would also be showing a decline in both frequency and severity. But this is not the case. Australian playground safety institute conducted a study, which showed that over the last decade when more and more playgrounds were being commissioned with impact attenuated rubber - based products, we have witnessed a steady 20% increase in the injury rate (adjusted for population). This observation is counter-intuitive to what one would expect until one examines the type of injuries and correlates this with the physics of the impact forces associated with the falls. Surface material properties such as the percentage bounce, the penetration depth over which the impact is absorbed, and the time interval over which the impact is absorbed greatly affect the instantaneous impact forces associated with the child’s fall onto the playground surface. The impact forces associated with falls onto rubber-based products can be 10 times greater than those associated with organic products such as woodchip and bark. Rubber safety surfaces do not provide sufficient attenuation. Rubber safety surfaces create rebound injuries. Because of the way in which rubber deforms and bounces back, the brain hits the inside of the skull first on the down stroke and then on the rebound. Neurosurgeons tell us that the rebound damage is often much worse than the initial impact. Rubber safety surfaces create long bone injuries. It has long been known in the playground surfacing industry that the fall attenuation standards do not address broken arms and legs. The assumption is that if the worst-case situation, head trauma, is taken care of, that other less critical injuries will also be ameliorated. Clearly, this is not the case.
What is playground rubber surface is made of? There was a community meeting held in 2018 for renovating Washington Square playground, where the following information was presented to the public about PIP rubber surfacing: Synthetic Rubber is not a recycled product. The Cushion Layer IS a recycled rubber. It is Encapsulated in a polyurethane binder which renders it inert in the environment, even if exposed through holes or cracks in the top Wearcourse layer. The synthetic rubber is not the crumb rubber that is being re-circulated in the media. That is ‘raw’ ground recycled rubber.
But is the above claim true? First, Synthetic Rubber is not a recycled product, but that doesn't mean it is safe. Second, cushion layer is made of recycled tires, and incapsulated polyurethane binder. But it is not inert to the environment, because it does decompose! When it is exposed through holes and cracks, children come into direct contact with it. Not only they touch it, but also put into their mouths. It also gasses off, when heated up, releasing both carcinogenic fumes and greenhouse gasses.
What is current EPA position on a topic? The U.S. Environmental Protection Agency has terminated its longtime campaign to promote the use of recycled tires on artificial turf fields and playgrounds, amid growing concern from critics in California and elsewhere who fear the material poses a health risk to people.
Laura Allen, spokeswoman for the EPA, said the agency is no longer affiliated with the Scrap Tire Workgroup and has no current initiatives to reduce tires in landfills. The agency ended staff participation in the independent Workgroup in May 2014, and closed out administrative participation at the end of 2014. The agency also says more testing on waste tire infill is needed and that states and local agencies should be responsible for conducting that research.
The EPA made a mistake in promoting this. That’s my personal view,” said Suzanne Wuerthele, a former EPA toxicologist who is now retired. “This was a serious no-brainer. You take something with all kinds of hazardous materials and make it something kids play on? It seems like a dumb idea.”
The agency said its 2009 study — often cited by industry groups to validate the safety of tire infill — was limited in scope and that no conclusions should be drawn by it. There's a new study which started in 2016, and still ongoing. The California Office of Environmental Health Hazard Assessment (OEHHA) is conducting a multi-year study of the potential health effects associated with use of synthetic turf fields that contain crumb rubber infill and playground mats that were made with crumb rubber. This work is being performed in collaboration with researchers at the Lawrence Berkeley National Laboratory, University of California, Berkeley and University of Arizona. They were able to extract over 182 chemical substances, some of them known carcinogens and irritants, and some of them have unknown effect on humans, since they have never been tested.
What does simple research tells us about rubber surfacing? Playground safety surfacing often involves the use of recycled rubber tire products such as poured rubber, rubber tiles or loose rubber mulch. Poured-in-Place is a 2-layer system consisting of a cushion layer, made of shredded tires or SBR (Styrene Butadiene Rubber) and polyurethane, and a top surface consisting of recycled post-industrial or new (virgin) EPDM (Ethylene Propylene Diene Monomer) rubber and polyurethane. Both Styrene and Butadiene are known carcinogens. Crumb rubber made from recycled tires contains lead, arsenic, benzene and other carcinogens that are released into the air and groundwater over time. Also, this crumb rubber doesn’t stay in place. It sticks to skin, shoes and clothing and therefore can end up in our schools, vehicles and homes. The recycled tires can not be placed in landfills due to their toxicity. The Federal regulatory framework established in RCRA resulted in a loophole allowing used waste tires to escape toxicity and apparently safety scrutiny when they are shredded and “repurposed” for children’s sports fields, playgrounds and garden mulch. As we understand it, a basic used tire is considered a waste product, and in fact considered a toxic waste product due to corrosive, carcinogenic and flammable ingredients (which may have a reporting exemption). However, under RCRA, when a waste tire is shredded and therefore “repurposed” it is then considered a “product” and evidently loses the regulatory scrutiny that might have kept a pulverized, inhalable version of a tire away from contact with children’s skin, lungs and clothing. The US Consumer Product Safety Commission declares that crumb rubber, and synthetic turf are exempt from child safety standards because it is not a children's product. Federal agencies have given blanket safety assurances for parents, athletes and schools despite a growing body of evidence documenting chemical exposure and other risks from synthetic turf. If one looks at the number of studies on synthetic turf fields that have attempted to estimate the risk to young students and athletes from the exposures to chemicals contained in the fields, you will see the problem. The findings of each of the studies are based on a startlingly limited number (2 to 12) of actual samples of crumb rubber (each weighing no more than few ounces), on a small number of fields - most without any testing of the crumb rubber (4 to 6 fields at most). There is no study that is a comprehensive systematic assessment of the risk. Instead, a natural experiment is being conducted in which thousands of children are being exposed on playing fields to rubber 1) known to contain carcinogens and 2) documented to produce cancer in workers in the tire manufacturing plants. The results of this human health experiment is to determine whether there is enough exposure to carcinogens in synthetic turf fields to cause cancer in the children who play on these fields. Now that there is strong indication that cancer has appeared in one segment of the student groups that have played on synthetic turf, (soccer goalies in particular as well as others) the experiment is allowed to continue with health departments standing by until they can obtain positive statistical confirmation of the cancer hazard. Crumb rubber infill contains a large number of chemicals known to be toxic to humans. These include chemicals associated with cancer, asthma, and other adverse health effects. There is no "safe" threshold level for exposure to carcinogens. The only way to eliminate cancer risk from these chemicals is to eliminate exposure.
So, if we know that safety surfaces made of recycled and EPDM rubber are toxic, not safer than natural materials to fall onto, and expensive, why is it still in the playgrounds and artificial turf fields, and new playgrounds are being made of it? One reason so many play spaces are made of crumb rubber is that the state gives away money to encourage its use. To keep some tires out of landfills, California’s recycling department has given $42 million in grants since 2005 to communities that use materials made from old tires. That 12,000 fields were in built in schools and sports facilities, most in the past 4 years, is a situation that results from well intentioned but misguided efforts to recycle and use of tens of millions of waste tire generated annually in the US. (California alone reports receipt of about 40,000,000 tires annually; CalRecycle 2016.) Waste tires can be used for many purposes (concrete girders, rubber mats, fuel) but using them for play fields has very impressive profit margins. A single field uses about 40,000 tires, and it was an expeditious, fairly simple process to sort, shred, bag and ship to a school anxious to update its field. However, this profitable industry has transferred the contamination load from a tire waste site (landfill, used tire distribution center) to communities and school fields where children are in direct contact with the toxic substances in the tire and plastics in pulverized, inhaleable, ingestible form. Currently 4,760,000,000 pounds of loose, unencapsulated, pulverized waste tires, are spread across play surfaces of more than 12,000 fields in schools, sports centers, and playgrounds, putting hundreds of thousands of players and families, including school children across the US, into direct, unimpeded contact with enormous quantities of at least 11 known carcinogens, over 90 known harmful substances, and myriad dangerous gas/particulate mixtures.
Californian lawmakers keep rejecting bills aimed at artificial turf. Organized labor is often a powerful force in the Democratic-controlled Legislature, and the unions that opposed the crumb rubber bill, are big political spenders with influential lobbyists.
The International Union of Painters and Allied Trades (which includes artificial turf installers) has poured at least $1.2 million into California campaigns over the last five years, while the State Building and Construction Trades Council has spent $5.3 million. Tire recyclers, school construction groups and labor unions that lobbied against the bills, argued it was scientifically unwarranted and would eliminate jobs. The last bill, California Senate Bill-47, was a watered down version of previous bill, and only required to hold community meetings to discuss alternative materials.
Making communities discuss alternative materials — such as cork, coconut fibers or rice husks —would “chill the entire industry,” Mike West, communications director for the International Union of Painters and Allied Trades, said after the California Senate Bill-47 "Environmental health: artificial turf" was defeated in 2016.
Most of the studies that have been conducted admit that the infill contains chemicals, however they then conclude that these chemicals do not actually pose a health threat to the children who will play on the artificial turf fields. An organization of physicians and public health professionals Environment and Human Health Inc, concludes that it does not agree with that assumption and asks how that assumption can possibly be correct. No entity providing the crumb rubber provides any quality control, identification of source, or analytical analysis of the contents of the rubber used. Along with these claims, industry is also using alternative names for infill products, making the issue of choosing infills for synthetic turf fields even more confusing. Often when talking about waste tire crumb rubber the initials “SBR” are used. Those initials stand for styrene butadiene rubber and it is simply another name for waste tire crumb rubber. The public is now asked to deal with the initials “EPDM” rubber — which industry is touting as a safer material to use as infill instead of waste tire crumb rubber . Environment and Human Health Inc. (EHHI) is concerned that as the public becomes more aware of the dangers of waste tire crumb rubber infill for synthetic turf fields, industry is pushing another rubber infill product called EPDM rubber. As parents are more concerned about the potential health risks that crumb rubber can pose to their children, industry is advising many towns and schools to pay more and get what they are calling “virgin” rubber, which they are claiming is a safe material for children and students to play on.
EPDM stands for ethylene propylene diene monomer rubber. This product is also a synthetic rubber and like the waste tires that make crumb rubber, EPDM contains harmful chemicals as well as carbon black. With industry’s claim that EPDM is a “safer” material than crumb rubber, they are able to charge more for it. Because of the health risks that crumb rubber infill can potentially pose, that crumb rubber material is currently under federal investigation by multiple agencies. While it is true that crumb rubber infill is made from waste tires and contains carcinogens and heavy metals and therefore poses a health risk for those who play on it, EPDM is also a rubber product and has many of the same health exposure issues as crumb rubber. Both EPDM rubber, as well as waste tire crumb rubber, contain chemicals and heavy metals that pose a health threat to children and students who play on them.
How about industry’s claims of EPDM safety? The Safety Data Sheet for EPDM says the product is a possible cancer hazard — and can be an irritant to lungs, eyes and skin. As well, the International Agency for Research on Cancer (IARC) evaluation is that carbon black is possibly carcinogenic to humans and that short-term exposure to high concentration of carbon black dust is a respiratory irritant. Neither EPDM rubber nor crumb rubber have been proven safe for children and students to play on. These products were not designed to be put where children play. SBR is used to make tires and EPDM is used for hoses, cable joints, car hoses and vehicle sealants. The safest surface for students to play on is grass — there is no safer surface.
Children are more susceptible than adults to a variety of environmental hazards, for several reasons:
1. Children's organ systems are developing rapidly. A toxic exposure during a critical window of development can have life-long consequences.
2. Children's detoxification mechanisms are also immature, so an exposure that might not have an important effect on an adult could have an important effect on a child.
3. In addition, children have many years in which to develop disease. Cancer, in particular, is a disease with long latency: disease can develop many years after exposure. For this and other reasons, it is particularly important to avoid carcinogenic exposures during childhood.
There has been no comprehensive assessment of the data on cancer among athletes exposed to crumb rubber from artificial turf exposures. However, the evidence collected to-date indicates a basis for concern and an urgent need for closer scrutiny. Most notable is that the ratio of lymphomas and leukemia is the reverse of that expected in the general population for that age group. Such a reverse in the pattern of cancers present is considered a signal that an active chemical carcinogen is present. Given the high stakes, it is prudent to take action to protect children from this known hazard rather than wait for definitive evidence of harm.
Tire crumb playgrounds and synthetic turf fields concentrate tens of thousands of pulverized waste tires into an area in which children play in. Children’s activities re-suspend dust and microscopic particulate matter, increasing inhalation, ingestion and dermal exposure. Warm sunny days cause rubber surface to superheat, exponentially increasing the off gassing of toxic VOCs and SVOCs. Children are unlikely to be intentionally exposed to a more toxic environment anywhere in this country.
The industry’s persistent arguments that the material is not a children’s product are ridiculous, self serving and inaccurate, since the product is clearly and unambiguously marketed to schools and is now used by hundreds of thousands, if not millions of children. Those arguments, and the loophole, have been to the detriment of the health and safety of our children.
While rubber includes some natural rubber (called latex) from rubber trees, it also contains phthalates (chemicals that affect hormones, see Phthalates and Children’s Products), polycyclic aromatic hydrocarbons (PAHs), volatile organic compounds (VOCs) and other chemicals known or suspected to cause adverse health effects. PAHs, for example, are natural or human-made chemicals that are made when oil, gas, coal or garbage is burned. According to the EPA, breathing air contaminated with PAHs may increase a person’s chance of developing cancer, and the Agency for Toxic Substances and Disease Registry (ATSDR) states that PAHs may increase the risk for cancer and also increase the chances of birth defects. A 2012 study analyzing rubber mulch taken from children’s playgrounds in Spain found harmful chemicals in all, often at high levels. Twenty-one samples were collected from 9 playgrounds in urban locations. The results showed that all samples contained at least one hazardous chemical, and most contained high concentrations of several PAHs. Several of the identified PAHs can be released into the air by heat, and when that happens children are likely to inhale them. While the heat needed to do this was very high in some cases (140 degrees Fahrenheit/ 60 ºC), many of the chemicals also became airborne at a much lower temperature of 77 ºF (25 ºC). The authors concluded that the use of rubber tire waste on playgrounds “should be restricted or even prohibited in some cases.
Supporters of crumb rubber advocate for it because of its durability and lifespan. But for example, City of Portsmouth's consultants, Weston & Sampson, concluded that an artificial field is not necessarily cheaper, just capable of more use in a variety of weather conditions. Installation and material costs vary, but the 12-year life-cycle cost for a soil-based natural grass field was estimated at $790,000 by Weston & Sampson, and $1.5 million for synthetic turf.
The New York City parks department stopped using crumb rubber on new fields in 2008. The Los Angeles Unified School District did the same in 2009. The city of Hartford has banned all rubber products that are used as mulch in children’s playgrounds and infill in synthetic turf fields. At the professional sports level, all but one of twelve Major League Baseball teams that once used artificial turf have switched back to natural grass. A 2010 survey of the National Football League found that over 82 percent of athletes thought artificial turf was more likely to contribute to injury. Many Dutch football clubs have announced they will cancel training on such fields or stop using them altogether, after the documentary came out on Dutch television in 2016, which exposed how industry lobbying got toxic artificial sports fields exempted from new EU REACH rules. The Zembla documentary revealed that artificial football fields made from old tires are likely to expose football players to cancer risk. Sweden also joined the ban. Even more, Sweden’s environment agency said that new measures are needed to protect waterways and marine life by curbing the release of microplastics from fields and playgrounds made with artificial turf. While there is still some uncertainty related to the spread of tiny rubber and plastic particles, artificial turf is thought to be a major source of contamination that can find its way into waterways, according to the agency. Eventually, particles can flow to the sea via the air, snow, rainwater, or wastewater.
What is San Francisco doing about crumb rubber and artificial turf? You would think that the city which is considered a cradle of all innovation would be pioneering environmentally friendly practices related to playground facilities and sports fields, especially in a wake of global warming? Sorry, planet. Sorry, children. When big buck is involved, children and planet usually are the ones who suffer. In 2015 city installed 4 artificial soccer fields near Beach Chalet. There was a lawsuit against the Beach Chalet soccer field installation of synthetic turf, joined by CA Sierra Club. But it was lost. And communities and playground designers are loosing battles with San Francisco Parks and Recs, because Parks and Recs want to phase out all sand placygrounds and replace them with rubber.
Officials also refuse putting warning signs on playgrounds and soccer fields, which say that the rubber surfaces and infill contain known carcinogens to avoid panic. By doing so, they actually break a law: Proposition 65 requires businesses to provide warnings to Californians about significant exposures to chemicals that cause cancer, birth defects or other reproductive harm. By requiring that this information be provided, Proposition 65 enables Californians to make informed decisions about their exposures to these chemicals. You probably saw new warnings about acrylamide in grocery stores (this chemical can from on surface of some food when fried or baked, and poses cancer risk). So, the change of getting cancer from acrylamide is actually low, but it is required to put warning signs about it. Synthetic rubber, both recycled and virgin, contains 128 chemicals, toxic and/or carcinogenic. Yet, we see no signs. When asked why, officials said it is to avoid panic. There should be panic! Your children play on carcinogenic surface every day, touch it and eat it. Because that is what children do.
As a parent of 2 young children I feel helpless, since I can't protect my children from exposure to carcinogens. I started avoiding playgrounds as much as possible, but my son's school has a playground wit rubber surface, where he plays every day. When you try to find something to do with your children, you see rubber and plastic everywhere. It is depressing. Also, kids get easily bored on those new multi-million dollars playgrounds, that city of San Francisco is installing. And then, every ten years or so, when that equipment became outdated, out-of-code, and out of compliance, it is going to be dumped in the trash and replaced without a thought, sometimes at great sacrifice to other, more pressing program needs, and certainly at great cost to the environment. When kids get bored, they start using equipment in ways for which it was not designed, and that causes accidents, some of which result in deaths. The cost of equipment is very high, especially in relation to its play value, the kind and amount of play per child, per dollar. It has always been costly, but now that the price of oil is a daily, global issue, prices for play components with a petrochemical base will continue to soar even more. The environmental impact of manufacturing, shipping, and then trashing playground equipment every ten years is very high. The equipment-based playgrounds are not sustainable, and are therefore environmentally costly. Manufacturing playground equipment causes more rapid consumption of the Earth’s limited natural resources than can be replaced by nature. This is why there is now a worldwide movement to keep human use of natural resources at a level that can be sustained by nature. There is now an overwhelming body of research showing a direct link between exposure to nature and the physical, mental, and emotional well-being of children. This also means that children are sick less often when exposed to nature, which lessens the overall costs to families associated with children being sick.
Why doesn't San Francisco join in the growing trend on nature playgrounds? Natural playgrounds, long popular in Europe, are popping up all over the United States and the Portland metro area is at the forefront of this back-to-nature movement, fueled in part by the enduring message in Richard Louv’s decade-old book, Last Child in the Woods: Saving Our Children From Nature-Deficit Disorder. Louv pinpointed an uncomfortably familiar change in modern childhood: Kids are not playing outside as much as we did, or as did our parents before us. The reasons why are well-known: The lure of technology and the over-scheduling of structured, adult-led activities, parental fear of playing outdoors unsupervised (whether for natural risks or stranger danger) and restricted access to natural areas. The growing trend of natural playgrounds aims to harness some of nature’s allure and impact, while offering it in a contained, safer and more available setting. Playing outside doesn’t just give kids exercise. Research shows it helps kids with coordination and problem solving, cuts down on stress and frustration, and teaches them to risks, testing the limits of their abilities. Plus, kids who play outside learn to love nature — and they’re inheriting an Earth that will very much need their protection.
I ask San Francisco Mayor to ban high-cost rubber and plastic playgrounds, toxic to our children, and replace them with natural playgrounds. Making the decision to go with a Natural Playground is financially sound and very cost-effective. Nature playground are timeless. It is also a place for community to gather.
I ask San Francisco Mayor to enforce proposition 65, and place warning signs on all existing playgrounds and synthetic turf fields, which are using synthetic rubber, both recycled and virgin rubber, since all rubber used for safety surfaces contains carcinogens in the amounts that are harmful to young children. #BanPetrochemichalPlaygrounds
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