Public Comment of the National Center for Health Research on USDA Proposed Rule on New Program on Natural Grass and Sod Products, Docket AMS-LP-21-0028

Jeana Harbison, Director
Research and Promotion Division
Livestock and Poultry Program, AMS, USDA
Room 2625–S, STOP 0251
1400 Independence Avenue SW,
Washington, DC 20250– 0251.

October 16th, 2023
Doc. No. AMS-LP-21-0028
Pages 71306-71323

Dear Ms. Harbison:

I am writing on behalf of the National Center for Health Research in support of the proposed rule to establish an industry-funded promotion, research, and information program for natural grass sod products.

The National Center for Health Research is a nonprofit public health think tank located in Washington, D.C. We conduct and synthesize research that has implications for the health and safety of adults and children, and we do not accepted funding from companies that make the products that we evaluate.

We are very concerned about the impact of artificial turf on the health and safety of children and adults, due to the lead and endocrine-disrupting chemicals in artificial turf, as well as the increase in injuries compared to grass fields. In addition, artificial turf retains heat, often reaching temperatures of 150-180 degrees Fahrenheit on warm, sunny days. For these and other well-documented reasons, artificial turf poses health and environmental problems that natural grass does not. We are therefore pleased that the proposed Natural Grass Sod Promotion, Research, and Information Order was submitted to the U.S. Department of Agriculture (USDA) by Turfgrass Producers International (TPI), a group of natural grass sod producers.

Improvements to natural grass options and information will help reverse the proliferation of artificial turf in homes and fields in the U.S., and enable communities to make informed decisions that will have important benefits to public health. We also encourage the Office of Management and Budget (OMB) to agree to new information collection requirements that may be needed to implement the program.

Diana Zuckerman, Ph.D
President
National Center for Health Research
1001 Connecticut Ave, NW, Suite 1100
Washington, DC 20036