May 19, 2025
Dear Councilmember Lewis-George and the Committee of Facilities,
Thank you for the opportunity to speak at the Environmental and Safety Hazards on DPR Properties Roundtable on May 5, 2025, and for the opportunity to provide additional information for the record in response to the questions I was asked.
To follow up on your questions about recycling: When they are removed, artificial turf and poured-in-place playground surfaces pose a serious problem for Washington, DC and other communities. While companies that manufacture or install artificial turf often claim that their products are recyclable, that claim is very misleading, and most of these “end-of-life” products are not recycled for 2 reasons:
#1. Artificial turf is extremely difficult and expensive to recycle because it is necessary to separate all of the component materials used (i.e., infill, rubber, plastic), and most can’t or won’t be recycled at all.
#2. Few places, if any, in the U.S. will recycle any part of artificial turf. There were plans to open a turf recycling plant in Rush Township, Pennsylvania, but as of late 2023, the plant had not been opened. As a result, the turf that the company was planning to recycle was being stored in nearby communities, where it continued to pose an environmental health threat.[1]
A coalition of companies in Europe (primarily in Denmark and the Netherlands) has recently developed a more successful recycling system, but most (if any) of the artificial turf waste from the United States is not being exported to those recycling plants. For those reasons, all the plastic grass carpet and almost all the other components of artificial turf end up in landfills or are dumped illegally in the U.S., and the chemicals will contaminate the area where they are dumped and the surrounding community, as well as the air we breathe. Additionally, wind and rain cause the infill to migrate to grass, dirt, streams, and other water. The scientists at the University of Massachusetts raised concerns about “the potential for synthetic surfacing to produce contaminated runoff water” when these giant rolls of turf and piles of damaged rubber end up stacked in landfills or other dumping sites.
They noted that, “numerous studies show that metals such as zinc, and toxic chemicals such as PAHs and phthalates, can leach from tire material into the environment.”[2]
This issue was discussed in the complaint filed by Public Employees for Environmental Responsibility (PEER) with the Federal Trade Commission in 2022, where they highlighted how misleading artificial turf marketing can be.[3] The scientists and advocates from PEER also noted that the dangers posed to health by PFAS and other toxic chemicals in artificial turf, recycled tire crumb, or PIP playground surfaces cannot be solved by recycling or reusing artificial turf or rubber playground materials. For example, when something is known to contain PFAS, it is considered hazardous waste, and there are no companies that we know of that will recycle these items.
Disposal options for artificial play surfaces (including artificial turf and PIP) were also outlined in the Playground Surfacing Report published by the Toxic Use Reduction Institute (TURI) at the University of Massachusetts. In Table 3, on page 10, of their comprehensive scientific report, the costs, maintenance requirements, and disposal options for numerous play surfaces and infill options are discussed.[4] Notably, both artificial grass and rubber PIP are disposed of in landfills. Although there are a few very limited recycling or reuse options for a minuscule portion of the artificial turf, none are listed for rubber PIP. Page 6 of this report also highlighted that almost all playground surfaces (rubber tiles, PIP, and artificial turf) are made using adhesives to combine the layers or components, and that products covered in adhesive are not recyclable. So, even if the individual elements can be separated, it is unlikely that the artificial turf or PIP will be recycled.
If watered regularly and maintained as recommended by the manufacturers, artificial turf may last 10 years, but when a playing field becomes damaged or dangerously hard, it has to be replaced. Due to the lack of recycling options, if we continue the cycle of replacing artificial turf fields with more artificial turf, these end-of-life turf fields will keep creating problematic plastic waste.
To follow up on your questions about lead dust and other heavy metals on playgrounds:
The safety of PIP or other rubber surface playgrounds has not been studied as much as artificial turf, although studies of the lead in PIP playground surfaces conducted by the Ecology Center in Michigan have found that some of the recycled tire crumb that has come to the surface has very dangerous levels of lead. A major remaining question is how much toxic chemicals and metals are released from the surface, in the invisible dust on the surface that gets on children’s skin, or in the dust and particulate matter in the air that they breathe. In 2023, a new study was featured on WUSA9 that highlighted the findings of a Georgetown research group that discovered hazardous materials in some playground material. [5]
The Georgetown researchers were not identified by name in the news program, but our staff were able to reach out to learn more about their findings. As a result, the president of the National Center for Health Research was invited as a guest lecturer at a class there. In their study of 10 potentially toxic heavy metals on playground surfaces, the researchers from Georgetown found that chromium (Cr), copper (Cu), arsenic (As), and thallium (Tl) could reach levels of concern. Because there are no clear guidelines on what amount of most of these metals is considered safe, the researchers also highlighted a need for clearer regulations to help keep playgrounds safe for kids.[6] Although the Georgetown researchers found that the levels of lead dust in their study did not seem excessively high, keep in mind that the Ecology Center testing found numerous pieces of tire crumb on DC playgrounds that were dangerously high, while some pieces were low in lead. As a result, the average lead level in the dust on the playground surface would depend on which part of the playground surface was studied, and an average lead level could seem low even if some of the dust was dangerously high in lead.
Sincerely,
Tess Robertson-Neel
Health Policy Fellow
National Center for Health Research
References
[1] Rodgers, B. (2023, March 20). PA officials say turf recycler is violating environmental laws. PhillyBurbs. https://www.phillyburbs.com/story/news/environment/2023/03/20/pa-officials-say-turf-recycler-is-violating-environmental-laws/69995371007/
[2] Toxics Use Reduction Institute. (2023). Playground surfacing: Choosing safer materials for children’s health and the environment (TURI Report No. 2018-003). https://www.turi.org/content/download/11986/188696/file/TURI%2BReport%2B2018-003.%2BPlayground%2BSurfacing.pdf
[3] Public Employees for Environmental Responsibility. (2022, March 7). False artificial turf recycling claims ripped. https://peer.org/false-artificial-turf-recycling-claims-ripped/
[4] Toxics Use Reduction Institute. (2023). Playground surfacing: Choosing safer materials for children’s health and the environment (TURI Report No. 2018-003). https://www.turi.org/content/download/11986/188696/file/TURI%2BReport%2B2018-003.%2BPlayground%2BSurfacing.pdf
[5] WUSA 9. (2023, Oct 6). A Georgetown University team exposes hazardous materials in some playground material [Video]. YouTube. https://www.youtube.com/watch?v=soqJ4b1HLu0
[6] Winz, R., Yu, L. L., Sung, L. P., Tong, Y. J., & Chen, D. (2023). Assessing children’s potential exposures to harmful metals in tire crumb rubber by accelerated photodegradation weathering. Scientific Reports, 13(1), 13877. https://doi.org/10.1038/s41598-023-38574-z