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