NCHR Letter to Belvedere City Council Regarding Rubber Playground Surfaces

March 19, 2021


To the Belvedere City Council and City Manager:

I am writing at the request of residents of Belvedere to explain what is known and not known about the health risks of PIP (poured in place) rubber playground surfaces.  I am writing on behalf of the National Center for Health Research, located in Washington, D.C.

The Center is a nonprofit research center, staffed by scientists, medical professionals, and public health experts.   I’m a scientist trained in epidemiology at Yale Medical School, I’ve previously conducted research at Yale and Harvard, and I’ve also worked in the U.S. Congress and White House.  Our Center conducts and explains research that can improve the health and safety of adults and children.  We do not accept funding from companies whose products we evaluate, so I have no conflicts of interest.

Like artificial turf, rubber playground surfaces expose children to many risky chemicals.  Lead and other dangerous chemicals are in crumb rubber (whether recycled or “virgin”).  Because of public health concerns, crumb rubber is increasingly being replaced by other materials, but those materials have some of the same risks as well as other risks.  This matters to all of us, because children who play on these surfaces are likely to be exposed day after day and year after year.

The beautiful rubber playgrounds, as shown on the left, look great when they are new, but they deteriorate.  On the right you can see a local playground – the red rubber PIP has worn off, and underneath is the crumb rubber that contains lead and other toxic chemicals which the children are touching, and in some cases putting in their mouths.

                             

What are these materials made of?   Many of us think of rubber as natural, coming from a rubber plant, but the substance that comes from a rubber plant is actually latex. Whether from recycled tire rubber or “virgin” rubber, the rubber used in tires, playgrounds, or as infill for artificial turf is made from petroleum.   And, they also contain lead.

It is well established that there has been lead in PIP playgrounds.  The American Academy of Pediatrics warns that there is no safe level of lead for children. The Ecology Center in Ann Arbor, Michigan is a nonprofit scientific group that found that there was rubber shred in playgrounds that had lead levels over 1,951 pp, which is clearly dangerous.

In the photo below, which I took at a community playground, you can see that many of the small particles that make up playground material look like colorful pieces of candy, such as tic tacs or black licorice. That’s why children eat them.

The rubber playground surfaces also contain endocrine disrupting chemicals – these are chemicals that affect our hormones.  The science is clear that exposure to hormone disrupting chemicals can cause or exacerbate numerous health problems, most of which are not uncommon in U.S. children:

  • Attention Deficits
  • Early Puberty
  • Obesity
  • Asthma

Not all children will be exposed to enough of these materials to be harmed, but some will.  Some children will be more vulnerable to these exposures than others, some will spend more time on the playgrounds and therefore have more exposure, and some will eat crumb rubber that contains dangerous levels of lead as well as other chemicals.

You don’t have to take my word for it.  Here is a sign that was posted on a local field.   The infill in artificial turf is the same material that is used in PIP.

The photo below shows 2 children playing in tire crumb that was washed off from an artificial turf field in the rain, and which ended up on a playground.

The dangers of these materials are not confined to the ground, because the chemicals are released into the air.  You can’t see them, although on hot days you can sometimes smell them.  In addition, the rubber particles get in children’s ears and noses and sometimes kicked up into the air when they play.  Children and athletes breathe in these invisible chemicals, lead, arsenic, and particulate matter when they play.  And sometimes small children eat them.

Here’s a photo showing how these pieces of rubber shred in a deteriorated rubber playground surface can appeal to a young child as something that would be good to eat.

What About Safety Tests?

I’ve heard FieldTurf representatives and others who sell or promote artificial turf say that their products meet all safety standards.  But that’s misleading, because there are no tests on human health that are required prior to getting artificial turf or playgrounds on the market in the U.S.

Although the U.S. Government restricts lead and many endocrine disrupting chemicals from children’s toys and other children’s products, there are not yet any such restrictions on artificial turf and playgrounds.

Two final issues I will briefly mention:  heat and hardness.

Rubber playgrounds get very hot, on hot days but also on nice sunny days.  You can see in this photo that a playground is 180 degrees.  Even the hottest days don’t get that hot on grass, dirt, or engineered wood fiber.

Regarding hardness, we know that some parents assume that the rubber surfaces protect children from harm if they fall.  But, although the rubber feels spongy when it is relatively new, it gets hard over time.  In contrast, engineered wood fiber is a safe, ADA-compliant alternative for playground surfaces, which also feels spongy and can be easily raked to keep it that way.  In contrast, when rubber playground surfaces get hard, they don’t recover — they need to be replaced.

In conclusion, there are many scientists and medical experts who have studied the potential risks of PIP.  Some local governments have admitted finding lead dust on many of these surfaces.  With engineered wood fiber as a safer alternative, why would Belvedere want to expose their children to hormone disrupting chemicals when they play?

Sincerely,

Diana Zuckerman, PhD

President