NCHR’s Comments at EPA’s 2021 CHPAC Meeting

November 2, 2021

Thank you for the opportunity to speak today on behalf of the National Center for Health Research. I am Dr. Meg Seymour, a senior fellow at the center. Our center is a non-profit public health organization that analyzes and explains scientific and medical information pertaining to the safety and effectiveness of consumer products, medical products, and exposures in the environment, in order to improve policies, programs, services, and products. We do not accept funding from companies that make the products that we evaluate.

We were very pleased to hear of the EPA’s recent decision to classify certain PFAS chemicals as hazardous and efforts to develop a National Primary Drinking Water Regulation for certain PFAS substances that will create legally enforceable maximum contaminant levels and treatment protocols for drinking water. We strongly urge the EPA to develop and maintain a focus on environmental justice when developing these rules. PFAS is everywhere, but some communities bear the burden more than others. EPA should work in partnership with those most affected, listening to their needs in order to protect their health.

We also urge the EPA to focus more attention on how rubber playground surfaces and artificial turf fields pose a health risk to children and youth. The lead and endocrine disrupting chemicals  — whether PFAS or other EDCs – that are on those fields and surfaces are putting children at risk all over the country. In addition to the chemical exposure, the chemicals cause those surfaces to be 40-60 degrees hotter on warm and sunny days, which can cause heat stroke, burns, or other very dangerous risks. Federal requirements for safety testing are urgently needed to replace the voluntary standards currently in place. 

Although the EPA has reviewed some data on artificial turf, there needs to be a thorough investigation of its impact on childens’ health. Schools and communities across the country have been misled when the manufacturers of these play surfaces claim that they have passed all federal standards. Unfortunately, there are currently no federal requirements for safety testing of these products before they are sold. It makes no sense to have some endocrine disrupting chemicals banned from children’s toys and products and then have those same children, and their older siblings, exposed to equally dangerous chemicals day after day and year after year on these fields and playgrounds. Standards must be developed, required, and enforced. As we have in years past, we strongly urge the EPA to conduct research on how currently used materials for artificial turf and playgrounds can pose risks to the health of the children who play on them, and to develop standards to regulate the safety of these materials.