LA California Public Comment Submission on Artificial Turf

September 16, 2024


I am writing as President of the nonprofit National Center for Health Research to share scientific information about artificial turf, which I am confident will help you determine what is best for the children and adults in your community. I am writing at the request of many of your constituents to share the information we have provided to Members of Congress, state and federal agencies, state and local legislators, parents, and others who want to ensure that our children are not exposed to dangerous chemicals when they play on artificial turf or playgrounds. Our nonprofit think tank is located in Washington, D.C. Our scientists, physicians, and health experts conduct studies and scrutinize research.

Our goal is to explain scientific and medical information that can be used to improve policies, programs, services, and products. We understand that these issues are hotly debated, but some information is more accurate than others. For example, if you look at the maintenance contract for an artificial field, you will see that it needs to be watered regularly to keep its warranty in place. In addition, artificial turf fields use herbicides and pesticides, just as grass fields do. Although grass fields and artificial turf fields both require water and pesticides, well-designed grass fields are safer for players and for the environment, and will last much longer and be more cost-effective.

In the last few years, scientists have learned more about lead and PFAS in artificial turf, as well as the risks of some of the newer infill materials that are available to replace tire crumb. Tire crumb has well-known risks, containing chemicals that have the potential to increase obesity; contribute to early puberty; cause attention problems such as ADHD; exacerbate asthma; and eventually cause cancer. However, other infill materials also have similar, serious risks and the plastic grass carpet also has many risks. For example, it is well known that “particulate matter” can cause lung problems and eventually cause lung cancer. For that reason, silica and other infill materials are of great concern. Although companies often claim that their products do not contain PFAS, that claim is not accurate because it is based on inadequate testing. There are thousands of PFAS chemicals, and some worrisome PFAS chemicals have been found in BrockFILL tested by independent researchers, for example. Misleading reassurances are common. For example, the manufacturer claims that BrockFILL “meets the requirements of the FIFA quality programme for synthetic turf systems as well as those of World Rugby” those requirements do NOT evaluate long-term safety for either children or adults. Unfortunately, there are zero testing criteria for artificial turf materials’ long-term safety, making such claims misleading as well as meaningless. In addition to the infill, the plastic grass itself exposes children and adults to dangerous levels of PFAS, microplastics, and other toxic chemicals as well. PFAS are of particular concern because they enter the body and the environment as “forever chemicals,” which means that they are not metabolized and do not deteriorate, accumulating over the years. Federal agencies such as the EPA and the U.S. Consumer Product Safety Commission have been investigating the safety of these products. Despite claims to the contrary, none have concluded that artificial turf is safe. The 2024 EPA report is not a “risk assessment” evaluating the impact of artificial turf fields on children; it focused only on tire crumb, not on PFAS, microplastics, or other exposures typical of artificial turf fields whether or not they have tire crumb infill. Unfortunately, the EPA report was focused on issues that were selected many years ago, and not on the exposures the health issues and environmental issues of greatest concern today. Although some will point to the EPA report as a ‘clean bill of health” for artificial turf, that is completely untrue.

As you probably know, the American Academy of Pediatrics states that no level of lead exposure should be considered safe for children, because lead can cause cognitive damage even at low levels. Some children are more vulnerable than others, and that can be difficult or even impossible to predict. The Centers for Disease Control and Prevention (CDC) warns that the “plastic grass” made with nylon or some other materials also contains lead. Whether from infill, plastic grass, or rubber playground surfaces (including PIP, which is made with tire crumb on the top layer or underneath the top “poured in place” layer), the lead doesn’t just stay on the surface. With wear, the materials used in rubber playground surfaces turn to dust containing lead and other chemicals that is invisible to the eye and is inhaled by children when they play. In addition, PIP surfaces wear out and crack, and the tire crumb are then on the surface. We would be glad to provide additional information upon request.