NCHR Comments on CPSC Agenda and Priorities for FY2020/2021

Diana Zuckerman PhD, National Center for Health Research; May 1, 2019

Diana Zuckerman, Ph.D., President of the National Center for Health Research
Comments on the U.S. Consumer Product Safety Commission
Agenda and Priorities for FY2020/2021

The National Center for Health Research is a nonprofit research center staffed by scientists, medical professionals, and public health experts who analyze and review research on a range of health issues.  Thank you for the opportunity to share our views concerning the Consumer Product Safety Commission’s (CPSC) priorities for fiscal years 2020 and 2021.  We greatly respect the essential role of the CPSC, as well as the challenges you face in selecting the most important priorities.

We want to start by emphasizing two issues involving chemicals in products that affect our health and our children’s health, artificial turf and playground surfaces and organohalogen flame retardants.  We also want the CPSC to consider expanding its role in providing guidelines for the production of sport and recreational helmets to reduce the risk of head injuries.  These issues are clearly consistent with CPSC priorities.

Artificial Turf and Playground Surfaces

This issue needs to be a priority, because children are exposed to these synthetic rubber and plastic fields and playgrounds day after day, year after year.  We appreciate the CPSC’s ongoing efforts to investigate the safety of crumb rubber on playgrounds and playing fields.  As your study using focus groups to examine children’s use of playgrounds and exposure to playground surfaces has shown, children who use playgrounds with artificial surfaces could be exposed to the chemicals in these surfaces.1  Unfortunately, the materials that make up these surfaces are often treated as “trade secrets,” making it impossible to know what is in them and to compare the safety of various products.  Meanwhile, the companies that make these products often make claims regarding safety that are not supported by well-designed studies or standards.  In fact, we have repeatedly heard erroneous claims in testimony at the state and local government level – erroneous claims that CPSC has concluded these materials are safe.  As we all know, CPSC has not yet drawn conclusions of safety or harm.

We encourage you to closely evaluate the research that has been done, focusing on independently funded research of short-term and long-term safety issues.  We also urge you to carefully examine the EPA/CDCs studies when they are completed, to ensure that the studies were well designed, appropriately implemented, and accurately interpreted.  We need information that can protect our children from harm.

We strongly urge you to convene a Chronic Hazard Advisory Panel (CHAP) to examine the short-term and long-term risks of different types of artificial turf used in playing fields and children’s playgrounds.

The rubber and plastic that make up these surfaces contain chemicals with known health risks, which are released into the air and get onto skin and clothing.  Crumb rubber – whether from recycled tires or “virgin rubber”– includes endocrine disruptors such as phthalates, heavy metals such as lead and zinc, as well as other carcinogens and skin irritants such as some polycyclic aromatic hydrocarbons (PAHs) and volatile organic compounds (VOCs).2,3,4,5,6  Other plastic or rubber surfaces also contain many of these chemicals.7  While one-time or sporadic exposures are unlikely to cause long-term harm, children’s repeated exposures over the years, especially during critical developmental periods, raise the likelihood of serious harm.  There are few activities that children experience for as many hours in their early years as playgrounds and playing fields.

In addition to the long-term risks of cancer and hormone disruption, these fields can also cause short-term harms.  Artificial turf generates dust which may exacerbate children’s asthma.8,9  Fields heat up to temperatures far higher than ambient temperature, reaching temperatures that are more than 70 degrees warmer than nearby grass; for example, 180 degrees when the temperature is in the high 90’s and 150-170 degrees on a sunny day when the air temperature is only in the 70’s.10,11,12,13  We have measured the temperatures ourselves and been shocked by the results.  These temperatures can cause heat stress and burns.

Fields made of crumb rubber have been marketed as reducing injuries compared to grass.  However, research has shown that this is not the case.  We have spoken to students terribly harmed by turf burn, and studies have indicated increased risk for some types of injuries, including joint, foot, and brain injuries.14,15,16,17,18,19   That is the reason that only two Major League Baseball parks use artificial turf and why the soccer World Cup is now always played on grass.

 Organohalogen Flame Retardants 

The National Academies of Sciences, Engineering, and Medicine is expected to finish the scoping plan to assess the hazards of organohalogen flame retardants (OFRs) later this year.20  We encourage you to convene a CHAP to use this scoping plan to evaluate OFRs and to develop regulations to address OFRs in children’s products, upholstered residential furniture, mattresses/mattress pads, and the plastic casing of electronic devices.  In addition, it is essential to consider current flammability standards to determine if there are changes that would improve their safety from chemical exposures as well as exposures during a fire.

OFRs are not bound to products to which they are added, so they migrate out of products and into dust.  This allows them to get onto our skin and food and into the air.  Furthermore, due to their widespread use and the long-lasting nature of OFRs, consumers are continuously exposed to OFRs.21  In addition, many OFRs bioaccumulate in our food supply.22,23,24,25  As a result, OFRs are present in nearly all people in the U.S.26,27

CPSC should focus on this issue because of the potential for hormone disruption, altered brain development, reduced ability to get and stay pregnant, and the timing of puberty.23,28,29,30,31  While not all OFRs have been sufficiently studied to determine whether all are unsafe, those that have been sufficiently studied have proved to be harmful to health.

While the Commission and consumers are concerned about fire hazards as well, it seems that these flame retardants may not be effective at preventing deaths in real world situations.32,33  When the chemicals burn during a fire, the inhaled smoke is more toxic to humans, and exposures could result in serious harms, including death.

Helmets for Sport and Recreational Activities

We also urge the CPSC to focus new attention on the safety of helmets intended to protect against brain injuries during athletic activities.  Currently, CPSC only provides guidelines for bicycle helmets.  However, many organized sports and recreational activities use helmets to reduce the risk for severe head injuries, including baseball, football, snow sports, skiing/snowboarding, and climbing.  They are not necessarily designed to prevent mild concussions.34  We encourage you to consider developing guidelines for helmets for other sports to ensure that they reduce this risk without interfering with vision or hearing or other safety concerns. We encourage CPSC to consider how design changes could improve the ability of helmets to prevent severe head injuries as well as mild concussions.

There are up to 3.8 million concussions reported each year related to sport or recreational activities, with most reported for children and adolescents.35  However, this number is likely an underestimate.36  While concussion injuries due to sport and recreation activities are typically less severe than from other causes, there is potential for long-term effects for some people that harm their health and quality of life.37  In general, it is widely accepted that helmets can reduce the risk of concussion and other head injuries.  However, there is much room for improvement and helmet design components can reduce the risk that a head injury causes a concussion.38,39

Final Thoughts

CPSC has a key role to play in protecting children and adults from harmful products used in their daily life.  Flame retardants and many different chemicals in artificial turf and playground surfaces get into the air and dust and thus into our bodies.  These chemicals tend to have greater risks for fetuses and children.  There are large gaps in our knowledge about the chemicals in the products on the market, because the companies do not provide that information to the public.  Ideally, the potential health impact of all of these chemicals would be evaluated in the final product before it was sold.  Since that is not happening, we must constantly play catch-up to identify health risks, often years after millions of children and adults have been exposed.  Too often, the lack of independently funded and publicly available research has been used to mislead the public.  Claims that “there is no evidence of harm” are misunderstood to mean “there is no harm.”  While research is lacking regarding the exact extent of the dangers of many of these products, there is already sufficient evidence that probable carcinogens and other toxic chemicals are being used.

Brain injuries from contact sports have become a concern to families across the country.  Helmets have been assumed to reduce the risk of concussion and other head injuries, but the lack of publicly available and understandable scientific evidence about which helmets work best under what circumstances means that families ca not make informed decisions.  Meanwhile, there are design components that could be improved to make helmets more effective at preventing injury.

While reducing exposures to dangerous products is key, there will always be some potential for harm.  Whether those harms are from the intended use of a consumer product or an unintended but foreseeable use, CPSC has a very important role to play in reducing harm.  For that reason, improving the timeliness and targeting of information campaigns to warn parents and children about harmful products is also a key task of the CPSC.


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