TCS0027
Written evidence submitted by Viv Mitchell and Nigel Maguire
Viv Mitchell – Is a concerned citizen who started researching about 3G Crumb Rubber Artificial Pitches when the local council decided to install one next door to a primary school. She came across several articles and research papers raising significant concerns over a potential link to cancer and wondered why our government would want to put at risk the health and wellbeing of our children.
Nigel Maguire – Took early retirement from his role as a Chief Executive in the NHS to look after his son Lewis who had Hodgkin’s Lymphoma and died last year having played several years week in week out on 3G Crumb Rubber Artificial Pitches. He has spent 3 years raising awareness of the potential dangers of 3G Crumb Rubber Artificial pitches.
We submit the following evidence regarding concerns over the increasing spread of 3G Crumb Rubber Artificial Pitches and their impact on the health and wellbeing of individuals and on the environment.
1.We are very concerned about the carcinogenic, toxic chemicals and substances in the tyre dust particles from road vehicles. This is a major cause of air pollution, along with vehicle exhaust fumes. These chemicals and substances cause extremely serious illnesses, resulting in needless deaths. We really need to consider the impact this has and consider safer alternatives.
1.1 Then, when the tyres are worn out, they are banned from landfill as they are hazardous waste. But then someone came up with the bright idea to grind them down into granules (Crumb Rubber) and spread them all around our country, topping off plastic support layers to act as infill for the plastic grass filaments. These are known as 3G rubber crumb artificial turf football and sports pitches.
1.2 The European Commission under intense lobbying chose to change their classification of crumb rubber from an article to a mixture thereby allowing much higher levels of toxins and carcinogens to be present than would be allowed for a consumer product. Everyone playing on 3G crumb rubber pitches is exposed to carcinogenic chemicals that are 100-1,000 times more toxic than ordinary plastic articles and up to 2,000 times more toxic than children's toys. There should not be skin contact with mixtures, but there obviously is with rubber crumb. Children should NOT be anywhere near crumb rubber artificial turf sports pitches, their immune systems are immature which makes them more susceptible to cancers and other serious illnesses. Many children have become seriously ill who have played regularly on 3G crumb rubber sports pitches, some have died. The lack of research is astounding and yet sports governing bodies and the government continue to say they are perfectly safe to play on. This is neither right nor acceptable. Adults can choose whether or not to play on this carcinogenic rubbish, just as they do with smoking and drinking alcohol, but children do not.
1.3 Government and sports authorities held meetings and decided that it wasn't in the public interest to disclose the cancer risks. They had also previously agreed that there should be warning signs posted by these pitches, but this hasn't happened.
1.4 According to Environment Agency Reports, our government already knows that crumb rubber (tyre-derived plastic) is always hazardous waste and unsuitable for sport surfaces, so why is this rubbish even being used as loose unbound infill in 3G crumb rubber artificial turf sports pitches?
1.5 Once these 3G pitches are installed, they are sprayed with even more chemicals: flame-retardants to prevent fires, to stop weeds growing and to prevent the sports players from catching MRSA from vomit, spittle, sweat and blood. These chemicals blow around the surrounding areas, affecting people who are not on the pitch. This is particularly dangerous when pitches are situated next to schools and homes. This is yet another reason why these pitches should be sited well away from built-up areas.
1.6 There is no life in the pitch, but the crumb is mistaken for food and eaten by the birds, bees, insects and other creatures, poisoning the food chain along the way, the same way as it does in the oceans.
1.7 During play the rubber granules are swallowed, they stick to games kits and the players' bodies, get inside boots, transfers to their cars and homes, sports centres, schools, etc. The crumb gets washed off into the water systems. According to FIFA and Eunomia, about 72,000 tonnes annually end up in our EU oceans, poisoning their way up the food chain. Some of these substances, particularly endocrine disruptive chemicals, have been found in orca whales, affecting their fertility. We must consider the distinct possibility that these same chemicals are affecting human life in exactly the same way.
1.8 As the 72,000 tonnes of rubber crumb that pollute our EU oceans annually are classified as a mixture, the chemicals contained are equivalent to the chemicals in 7,200,000-72,000,000 tonnes of plastic articles, leaching out and poisoning sea creatures.
1.9 After a few years the 3G pitch will reach the end-of-use and will have to be disposed of. According to FIFA, this is either incinerated or, ironically, still ends up in landfill. There are no recycling facilities in the UK. The Netherlands have "artificial turf mountains" with discarded 3G pitches piled up high as they don't know what to do with them. Some of these turf mountains have caught fire, spreading toxic smoke and fumes everywhere.
1.10 FIFA would rather have cork infill. Gianni Infantino, FIFA President, would rather have natural turf pitches.
1.11 Eunomia measures to combat marine pollution from tyre-derived plastics (rubber crumb) have been rejected as stakeholders would lose money! But what good is money when children are dying and our world is being destroyed?
1.12 There are many other uses for this toxic waste banned from landfill that will not harm our children and our world in the same way, much less dangerous if used in bounded projects.
1.13 Surely, you don't need a PhD to see how absolutely dangerous this is to human health, our environment and oceans.
1,14 The health of our children needs to be considered otherwise the future will be very bleak. How will the NHS cope with all the unnecessary cancers? There has been a 50% increase in childhood cancers over the past 30 years. Why? Surely we should look at the obvious reasons for this.
1.15 Our children need protecting, they need to grow up and be healthy. Please consider implementing the same age restrictions for playing on rubber crumb as for tobacco and alcohol, all equally dangerous for children. And please also consider having a moratorium on building new 3G pitches until safer alternatives can be found. This will save the lives of many children and save the NHS money too.
Specifically in response to your terms of reference we would like to submit the following:
1. Why are toxic chemicals used in consumer products? What benefit do they offer? How are levels of toxicity measured?
2.0 Tyre dust is in the air that we breathe, from the millions of vehicles travelling along our roads and one of the main causes of air pollution, full of toxic carcinogenic chemicals.
2.1 These toxic chemicals are also in 3G crumb rubber artificial football and sports pitches. These contain carcinogenic chemicals, endocrine disruptive chemicals and chemicals dangerous to aquatic life, chemicals such as chrysene, benzo(a)pyrene, benzo(e)pyrene, benzene, PAHs, phthalates, lead, arsenic, mercury, carbon black, amongst many others.
https://www.researchgate.net/publication/328505343_Evaluation_of_Potential_Carcinogenicity_of_Organic_Chemicals_in_Synthetic_Turf_Crumb_Rubber
Yale University - " Utilizing ADMET Predictor™, a computational programme to predict carcinogenicity and genotoxicity, 197 of the identified 306 chemicals met our a priori carcinogenicity criteria. Of these, 52 chemicals were also classified as known, presumed or suspected carcinogens by the US EPA and ECHA."
" Importantly, the majority of crumb rubber constituents were not listed in the US EPA (n=207) and ECHA (n=262) databases, likely due to an absence of evaluation or insufficient information for a reliable carcinogenicity classification. By employing a cancer hazard scoring system to the chemicals which were predicted and classified by the computational analysis and government databases, several high priority carcinogens were identified, including benzene, benzidine, benzo(a)pyrene, trichloroethylene and vinyl chloride."
https://www.echa.europa.eu/documents/10162/13563/annex-xv_report_rubber_granules_en.pdf
European Chemicals Agency (ECHA)
https://ntp.niehs.nih.gov/ntp/about_ntp/bsc/2017/june/publiccomm/stephanattach2_20170628_508.pdf
2.4 Due to the EC lobbying RIVM to change their classification for crumb rubber from an article to a mixture, the carcinogenic levels for the PAHs in the crumb are 100-1,000 times more toxic than in articles and up to 2,000 times more toxic than in toys. Please read:
https://bigwobber.nl/wp-content/uploads/osd/20171221/449.pdf
https://zembla.bnnvara.nl/data/files/3233821473.pdf
https://www.volkskrant.nl/sport/hoe-de-lobby-in-brussel-het-rubber-in-het-kunstgras-hield~b048bd8c/
2.5 The current concentration limits for PAHs supplied to the general public are 100 mg/kg for two of the PAHs and 1,000 mg/kg for the other six PAHs, this is the level for mixtures. The level for articles is 1.0 mg/kg. The level for toys is 0.5 mg/kg.
2.6 There should not be human skin contact with mixtures but there obviously is skin contact with 3G rubber crumb. Children are exposed to PAH levels 100-2,000 times more toxic than toys. Children should not be playing on 3G fields, they are most at risk as their immune systems are immature. Children are getting ill, some are dying and families are being destroyed. It is not acceptable that our children's lives should be put at risk.
2.7 The cocktail effects from these and other chemicals in rubber crumb have not been researched.
2,8 Then there are even more chemicals that are sprayed on these pitches to prevent the growth of weeds, fire and MRSA from blood, sweat, spittle and vomit. These chemicals will blow over the surrounding areas, and endangering many people who are not on the pitch.
2.9 Not forgetting the endocrine disruptive chemicals also in the crumb, for example bisphenol A (BPA).
https://pbs.twimg.com/media/DmP1MpjWwAAYUiR?format=jpg&name=900x900
2. What new technologies and materials are being developed to reduce the use of toxic chemicals? Are they widely available and affordable for producers?
3. There are many much safer alternatives that can be used which are widely available, from more sustainable sources, some more affordable, some slightly higher.
3.1 You are already aware that all these chemicals are incredibly dangerous to human health as well as our environment and oceans.
3.2 These chemicals and substances contained in 3G crumb rubber football and sports pitches in sports centres and school playgrounds all over our country. Pitches in or near schools are unnecessarily exposing young children to the risk of cancer every single day they are at school and they do not even have to be playing on the pitch. This is not good.
3,4 Each pitch contains approximately 120 tonnes of rubber crumb equivalent to 20,000 to 30,000 ground up tyres. The plastic equivalent of 2,000,000 plastic bags are used just for the grass filaments. Then there are several supporting layers made from the same materials. Everyone playing on these pitches is exposed to hundreds of chemicals, carcinogens, DNA altering chemicals, endocrine disruptive chemicals, etc.
3.5 There are many alternatives to 3G rubber crumb infill in artificial turf fields that will not harm our children, our environment and oceans. Natural turf is the safest; there are hybrid and non-infill pitches; organic infills, cork and coconut. All these are safer than 3G crumb rubber. But the FA only funds crumb rubber installations, no other infill is funded.
FIFA would rather have cork, this is also much better for the environment -
https://football-technology.fifa.com/media/1230/artificial_turf_recycling.pdf
Gianni Infantino, FIFA President, would rather have natural grass -
3. Which toxic chemicals pose a significant risk to human health? How pervasive is the risk? Who is most at risk? How do producers make consumers aware of health risks identified in their products?
4. All these chemicals pose more than significant risks to human health, children most susceptible as they have immature immune systems.
4.1 There should be warning signs posted at each 3G rubber crumb pitch, but there aren't. This was exposed by The Telegraph https://www.telegraph.co.uk/news/2018/06/11/sport-chiefs-fail-warn-players-3g-pitch-cancer-risk/
4.2 Murfitts is one of the top suppliers of crumb rubber infill, also from above Telegraph article. They admit that regulations governing cancer-causing chemicals in such infill are "totally illogical".
4.3 Murfitts is clearly a world leader in new approaches to the composition of rubber crumb. Surely, with coated rubber crumb costing only 5% more than ordinary uncoated rubber crumb, this should be the only rubber crumb infill used if you want to continue using it. It will save many lives.
https://www.northamptonchron.co.uk/sport/saints-duo-post-pictures-of-injuries-picked-up-on-saracens-artificial-surface-1-8833120
4.4 Two Saints players have posted pictures of their injuries on social media after Saturday's game on Saracens' artificial surface at Allianz Park.
4.5 Bad grazes such as this risk carcinogenic chemicals directly entering the bloodstream, and the player will need antibiotics.
AVOID CONTACT WITH SKIN AND EYES
CAN CAUSE IRRITATION
AVOID BREATHING VAPOUR
MAY CAUSE COUGHING AND LUNG IRRITATION
IF SKIN CONTACT OCCURS, WASH SKIN THOROUGHLY WITH SOAP AND WATER
IF EYE CONTACT OCCURS, RINSE IMMEDIATELY WITH PLENTY OF WATER FOR AT LEAST 15 MINUTES
WARNING: KEEP OUT OF REACH OF CHILDREN
4.6 Crumb Rubber producer's MSDS on an Environment Agency Report shows that it is UNSUITABLE for sport surfaces but this is being ignored –
https://www.pharosproject.net/uploads/files/sources/1828/1330040519.pdf
4.7 Another Environment Agency Report shows that rubber crumb is always hazardous waste –
https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/321419/LIT_8273.pdf
4.8 Please read this from Zembla, Dangerous Play –
https://zembla.bnnvara.nl/nieuws/dangerous-play
4. How does the Government measure the health risks of toxic chemicals? What actions does the Government take to limit consumers’ exposure to toxic chemicals? Should maximum residue limits (MRLs) be applied to toxic chemicals in consumer products? Are current trading standards sufficient to monitor toxic chemicals in consumer products (e.g. children’s toys) and food?
5. The current concentration limits for PAHs supplied to the general public are 100 mg/kg for two of the PAHs and 1,000 mg/kg for the other six, if classified as a mixture, the level for articles is 1.0 mg/kg, the level for toys is 0.5 mg/kg.
5.1 There should not be skin contact with mixtures but there obviously is skin contact with 3G rubber crumb. Children playing on 3G crumb rubber pitches are exposed to PAH levels 100-2,000 times more than when playing with toys.
5.2 The Government is not taking any actions at all to limit exposure to these and other toxic chemicals in 3G crumb rubber. In fact, they have completely ignored the 3G rubber crumb cancer risks and, with various sports organisations, decided that it was not in the public interest to disclose the cancer risks!
5.3 This was obtained through a FOI application –
https://www.thesun.co.uk/news/7102721/sport-and-health-officials-agreed-not-to-go-public-on-cancer-concerns-linked-to-artificial-3g-pitches/
5.4 The Government and FA despite issuing a press release confirming they would issue guidance on taking reasonable precautions to reduce exposure to Crumb Rubber have failed to post warning signs by 3G rubber crumb pitches - https://www.telegraph.co.uk/news/2018/06/11/sport-chiefs-fail-warn-players-3g-pitch-cancer-risk/
5.5 We would like to see Trading Standards monitor these toxic chemicals on every single pitch in the UK, especially in relation to children's exposure to these very dangerous chemicals. Until the level of PAHs is the same as for toys at 0.5 mg/kg, then children should NOT be allowed anywhere near these pitches, whether in sports centres or in their school grounds, where their lives are needlessly put at risk.
Environmental concerns
5. What is the environmental risk from toxic chemicals? As part of its commitment in the 25 Year Environment Plan, what measures is the Government taking to reduce harmful chemicals in the environment? Will these measures be effective?
6. The environment risks will be catastrophic for the future life of our planet. The 25 Year Environment Plan is much too long, we need to take action now, we do not have time to waste, our world will reach the point-of-no-return well before 25 years.
6.1 As the chemicals in crumb rubber are 100-1,000 times more toxic than articles, the chemicals in the 72,000 tonnes of crumb that pollute our EU oceans annually are equivalent to 7,200,000-72,000,000 tonnes of ordinary plastic articles. This is very detrimental to the food chain.
6.2 Eunomia measures for EPR and an EU-wide ban were rejected amongst others.
6.3 They decided that money was more important than human life and our environment, our world.
6. How are flame retardant treated products currently disposed of and what problems have been identified with these methods of disposal? What is international best practice for disposal?
7. 3G crumb rubber artificial football/sports pitches are sprayed with fire retardants, therefore our children are exposed to even more chemicals. Also this is not considered when disposing of a rubber crumb pitch. In fact, there are no recycling facilities in the UK. These are either incinerated or disposed off in landfill, which rather defeats the landfill ban that lead to the creation of rubber crumb.
7.1 Please see FIFA Document, 3.3 LANDFILL AND INCINERATION –
https://football-technology.fifa.com/media/1230/artificial_turf_recycling.pdf
7.2 And this from the Telegraph –
https://www.telegraph.co.uk/football/2018/09/12/major-new-fears-emerge-absence-recycling-plan-3g-pitches/
7.3 Also, this from Zembla, The Artificial Turf Mountain –
https://www.youtube.com/watch?v=Y5o3J7uy4Tk
7. Is current legislation on producer responsibility and management of waste sufficient for recyclers to identify toxic chemicals in products? Should materials treated with flame retardants be available for use as recycled material in consumer products?
8. No. We believe that EPR should be implemented for every single toxic product. It is the only way, no question whatsoever.
8.1 No toxic materials should ever to be recycled into any consumer products, and particularly not into children's products.
11. How should substances of very high concern (SVHC) be regulated after the UK leaves the EU? How should the Government manage risk from newly identified toxic chemicals after the UK has left the EU?
9. We think they should be regulated even more stringently than they are now. We should be the world leader and have the highest standards in the world.
9,1 We have to put human health, all living creatures, our environment and oceans before everything else if we want to have healthy populations and a liveable world.
12. What steps can the Foreign and Commonwealth Office take to influence other countries to reduce the manufacturing and improve control of toxic chemicals in consumer products?
10. We could be the world leader towards a safer and less toxic world, by putting human health and our environment ahead of making money. Show that we care about people and our world not just about money.
10.1 We could start by banning the use of crumb rubber (tyre-derived plastics).
10.2 If not totally banned, then ban the use of 3G crumb rubber artificial turf football and sports pitches by children. This won't save the environment and oceans but will help save our children.
10.3 Implement the same age restrictions for the use of crumb rubber pitches as that for tobacco and alcohol, all equally dangerous to health.
10.4 Also if not totally banned, then please at least ban the installations of 3G crumb rubber artificial turf pitches near schools, homes, parks, hospitals.
10.5 Enforce at least some of the rejected Eunomia measures - EPR, raising awareness, ban, etc.
10,6 These measures would help to keep our children safe but every single use of rubber crumb will still damage the environment and oceans.
10.7 In twenty years, 1,440,000 tonnes of rubber crumb will pollute our EU oceans, even more as this increases over time. As mentioned previously, the chemicals in rubber crumb are 100-1,000 times more toxic than in articles, therefore the chemicals released to our EU environment will be equivalent to that in 144,000,000 -1,440,000,000 tonnes of plastic articles. This will be absolutely catastrophic to marine life and the food chain. This threat to life on earth must be taken seriously.
10.8 Any single one of these chemicals in crumb rubber and the ones sprayed on the pitch to prevent MRSA etc will be dangerous, but the combined effects of the cocktail of these chemicals will not be good at all. No-one has tested the interactions of these chemical cocktails.
10.9 As mentioned in the introduction, tyre dust is also one of the causes of air pollution along with exhaust fumes. Crumb rubber is also used in road surfaces. So, tyre dust, whether on or in the road or on a 3G sports pitch, greatly increases the health and environmental risks. We must start thinking of alternative ways to travel that will not cause harm.
10.10 We have to put human health and life ahead of making money. Too many children have died, and families destroyed.
10.11 Why should our children risk their lives when they just want to have fun running around and kicking a ball?
Dying to play football!
Absolutely crazy!
March 2019