Granules and mulches on sports pitches and playgrounds

For many years, sports players have used all-weather pitches for football, gaelic sports, rugby, lacrosse and other sports. These artificial playing surfaces often use rubber granules as infill to make the pitches more durable, weather-proof and to add shock absorption and traction.

Playground surfaces also often use loose rubber mulches underneath swings, slides and other playground equipment to cushion the ground in the event that a child falls.

The granules and mulches are usually made from scrap end-of-life tyres (ELTs) that are broken up and ground down into to smaller forms.

The granules and mulches may contain a number of potentially hazardous substances including polycyclic aromatic hydrocarbons (PAHs), metals, and phthalates, and they may also release volatile organic hydrocarbons (VOCs) and semi-volatile organic hydrocarbons (SVOCs). The presence of these hazardous substances has led to concerns on the safety of artificial sports pitches and playgrounds. 

What is the health risk?

In June 2016, the European Commission asked ECHA to assess whether the presence of such substances in recycled rubber granules in synthetic pitches could pose a health risk to the general population, including children, professional players and workers installing or maintaining the pitches. This was driven by claims of increased cancer risk to children playing on these pitches, which in recent years have appeared in the media of several EU Member States.

ECHA assessed the health risks, looking at exposure through skin contact, ingestion and inhalation. The findings were published in February 2017, with ECHA concluding that there was, at most, a very low level of concern from exposure to the granules.

The risk of getting cancer after a lifetime’s exposure to the rubber granules was judged to be very low, given the concentrations of PAHs measured at the European sports grounds where samples were taken. The concentrations were seen to be well below the legal limits applicable.

The level of concern about the presence of heavy metals was considered negligible, as the levels are below the limits currently allowed in toys in the EU.

There were also no concerns identified in relation to the concentration levels of phthalates, benzothiazole and methyl isobutyl ketone as they were also below the levels that would lead to health problems.

The report did, however, note that, where the rubber granules were used indoors, the volatile organic compounds emitted might lead to a heightened level of skin and eye irritation.

Why is there a need for further investigation?

The report also highlighted some uncertainties that would warrant further investigation. For instance, there was a concern over how representative the studies carried out were for the whole of Europe (given that samples were not taken from all Member States).

As such, ECHA suggested a number of actions to be taken to counteract these uncertainties and to reflect good practice:

  • Consider a restriction under the REACH Regulation so that rubber granules are only supplied with very low concentrations of PAHs and any other relevant hazardous substances.
  • Owners and operators of existing (outdoor and indoor) fields should measure the concentrations of PAHs and other substances in the rubber granules used in their fields and make this information available.
  • Producers of rubber granules and their umbrella organisations should develop guidance to help manufacturers and importers of (recycled) rubber infill test their material.
  • European sports and football associations and clubs should work with producers to ensure that information about rubber granules in synthetic turf is understandable to the players and the general public.
  • Owners and operators of existing indoor fields with rubber granule infills should ensure adequate ventilation.
  • Players using the synthetic pitches should take basic hygiene measures after playing on artificial pitches.

ECHA’s sent its evaluation to the European Commission on 28 February 2017.   

So, what is happening to clarify the uncertainties?

The Dutch National Institute for Public Health and the Environment (RIVM) published a study on the health risks of rubber granulates used in the Netherlands in December 2016, which confirmed that playing sports on these fields is safe.

However, similarly to the conclusion of ECHA’s report, the study provided a recommendation to further reduce the legal concentration limits of PAHs in rubber granules, in particular considering those applicable to consumer articles.  

The Netherlands followed this up by announcing its intention to prepare a restriction dossier to limit the concentration of eight polycyclic aromatic hydrocarbons (PAHs) in granules used as infill material in synthetic turf pitches or in loose forms for use in sports applications and on playgrounds on 30 June 2017.

This dossier was received by ECHA on 20 July 2018.  

What is the content of the restriction dossier?

The restriction dossier assesses the human health risk from eight PAHs to professional footballers (including goalkeepers), children playing on the pitches, and workers involved in installing and maintaining the pitches and playgrounds.

On the basis of the assessment, the Netherlands is recommending to lower the combined concentration limit for those eight PAHs found in rubber crumb and mulches used in synthetic turf pitches, playgrounds and at other sports facilities to 17 mg/kg.

The current concentration limits applicable for supply to the general public are set at 100 mg/kg for two of the PAHs (BaP and DBAhA) and 1 000 mg/kg for the other six (BeP, BaA, CHR, BbFA, BjFA, BkFA).

Next steps

ECHA's committees will now check whether the restriction dossier conforms to the requirements of Annex XV to REACH. If so, the consultation on the dossier will begin in September 2018.

Once the consultation begins, interested parties will have six months to comment on the suggested restriction and its anticipated impacts.

ECHA committees will assess the dossier and formulate their opinions. ECHA’s Committee for Risk Assessment (RAC) will adopt its opinion in July 2019. The Committee for Socio-economic Analysis (SEAC) will give their expert opinion on the proposal by September 2019, taking into account the submitted information.

The opinions of both committees will be submitted to the European Commission. The final decision will be taken in a comitology procedure with scrutiny involving the Member States and the European Parliament.

Is that it?

In addition to the Netherlands’ restriction dossier, ECHA will continue to look at the health and potentially also the environmental impacts of other substances contained in rubber granules derived from end-of-life tyres. This investigation may lead to the restriction of further substances.

Planned timetable for rubber crumb restriction proposal

 

Intention to prepare restriction proposal
30 June 2017
Call for evidence
23 July – 18 October 2017
Workshop hosted by RIVM
24 November 2017
Submission of the restriction proposal
20 July 2018
Public consultation of the Annex XV report (if conformity is passed)
September 2018 – February 2019
RAC opinion
July 2019
Public consultation on SEAC opinion
July 2019 – August 2019
SEAC opinion
September 2019
Combined final opinion submitted to Commission
Without undue delay
Draft amendment to the Annex XVII (draft restriction) by Commission
Within 3 months of receipt of opinions
Discussions among Member State authorities
2019-2020
Restriction adopted (if agreed)
2020