Comments re:
California Office of Environmental Health Hazard Assessment, (OEHHA)
March 10, 2017 meeting and presentation materials
California Office of Environmental Health Hazard Assessment, (OEHHA)
March 10, 2017 meeting and presentation materials
The California Office of Environmental Health Hazard Assessment, (OEHHA), supplied meeting materials to their Synthetic Turf Science Advisory Panel days before their meeting on 3/10/2017.
The following comments were sent from the public for the panel and OEHHA's consideration.
The following comments were sent from the public for the panel and OEHHA's consideration.
Regarding:
Task 1: Expert, public, and interagency consultation and input
http://zembla.vara.nl/nieuws/dutch-university-research-shows-use-of-rubber-infill-for-artificial-grass-should-be-avoided
Section 2 Exposure Pathways Studies
Section 2A. / Task 3 - Time Activity Behavior Pattern Study Timeline
Section 3 Bioassessibility Study / Section 3A Biofluid Compositions
1.2. Dermal Exposure— Bioaccessibility Measurements Using Artificial Sweat and Sebum Mixture
Section 4B. Phase 2 Field Study - Validate and modify field sampling protocol
Section 4C -- Phase 3 Field Study
Task 6: Health Assessment from play on synthetic turf fields and playground mats
Task 1: Expert, public, and interagency consultation and input
- The cited OEHHA meeting material omits the scientific dispute regarding the opinion of the Dutch (RIVM), Ministry of Health, Welfare and Sport -- which concluded that “Playing sports on synthetic turf fields with rubber granulate is safe”. In opposition, University Amsterdam (VU) scientists reached the conclusion that “rubber granules in fact release chemicals which may cause harmful effects in humans”.
http://zembla.vara.nl/nieuws/dutch-university-research-shows-use-of-rubber-infill-for-artificial-grass-should-be-avoided
- The OEHHA materials state that, “OEHHA also met with the Rubber Manufacturers Association and the Carbon Black Association”. It would support transparency to disclose who attended these meetings and present any minutes, recordings, and/or transcripts of the meetings. The same transparency towards all private meetings is important -- but particularly meetings with parties that have financial and commercial interests, or other vested interests.
Section 2 Exposure Pathways Studies
- The examples of “Exposure Routes” omit exposures which occur directly into the bloodstream via open cuts.
- The “Examples of Exposure Parameter” does not acknowledge that the infill material is so chemically variable, (samples ranging from 1.7-fold to 85-fold higher, as per OEHHA/Vidair), – that ingestion parameters based on frequency, exposure duration, location, and exposure route are valueless as indications of dosage.
Section 2A. / Task 3 - Time Activity Behavior Pattern Study Timeline
- An “activity behavior pattern study” may not be a useful expenditure of either time or financial resources. There are a myriad amount of activities and exposure scenarios beyond athletics that are associated with synthetic fields – including the behavior of infants and children with direct contact and access to the infill material.
Section 3 Bioassessibility Study / Section 3A Biofluid Compositions
- Bioassesibility findings would be affected by the variable states and size of the material sampled -- which can range from gaseous, to nano-particulate, to dust size, to granular.
- Bioassesibility findings would be affected by the duration of the chemical’s exposure within the body. Some material may pass through quickly, while other material may become lodged or entrapped for extended lengths of time (potentially days).
1.2. Dermal Exposure— Bioaccessibility Measurements Using Artificial Sweat and Sebum Mixture
- The study omits compromised skin -- due to common athletic abrasions and “turf burn”.
Section 4B. Phase 2 Field Study - Validate and modify field sampling protocol
- The sampling of the fields should be transparent and open to the public.
- The amount of infill “kicked-up” will be dependent on the turf manufacturer, type, and style of plastic grass used, as well as the depth of the infill material used. (This significant variability is quite evident in television broadcasts of sports).
Section 4C -- Phase 3 Field Study
- The composition of an infill sample will be an inconstant combination of weathered particles and newly introduced particles. This is because infill material migrates from the field – in response,” new” (un-weathered) infill material is regularly added to the pre-existing material for replenishment, and as “patches” in various areas of the field. The dust from the Brazil nut effect will most likely vary accordingly
Task 6: Health Assessment from play on synthetic turf fields and playground mats
- The parameters for making an assessment are not clearly defined.
2b. The study does not clarify how it simulates action on the field. In the real world, there is mechanical grinding of the crumbs and artificial grass to create new dust and particulate matter – thus increasing the surface area that can off-gas. This mechanical grinding of the grass and tire crumb from athletes running on the field is an important part of the aging of the field.
Bioavailability –It is important to recognize that since chemical reactions occur at the surface of materials, surface area of the crumb rubber is critical. I believe only PM2.5 will make it into the alveoli. This must be accounted for if PM2.5 is not used in the leaching. Similarly, the smallest particles will be the ones most likely to stick to the skin. Using crumbs without accounting for the size of the particles actually inhaled, ingested via hand to mouth behavior, or stuck to the skin can lead investigators to underestimate bioavailability by several orders of magnitude.
On page 126, why do OEHHA personnel need a warning about heat stress, heat exhaustion, and dehydration, and exposure hazards from chemicals on turf fields, before entering the fields? I thought OEHHA declared the fields safe. If OEHHA staff get this warning, shouldn’t this warning be given to children before they enter the field? Maybe posted somewhere?
“Before entering the field, the LBNL and OEHHA field leads will hold a tailgate meeting to go over the safety protocol. OEHHA field lead will present the emergency facility information and discuss potential physical (e.g., trips and falls, slip hazards, heat exhaustion and heat stress, dehydration, proper lifting techniques, use of personal protective equipment including eye protection, potential exposure hazards from chemicals applied to or that are on the turf, hygiene techniques and first aid) and biological hazards (e.g. bug bites).”
cd
Bioavailability –It is important to recognize that since chemical reactions occur at the surface of materials, surface area of the crumb rubber is critical. I believe only PM2.5 will make it into the alveoli. This must be accounted for if PM2.5 is not used in the leaching. Similarly, the smallest particles will be the ones most likely to stick to the skin. Using crumbs without accounting for the size of the particles actually inhaled, ingested via hand to mouth behavior, or stuck to the skin can lead investigators to underestimate bioavailability by several orders of magnitude.
On page 126, why do OEHHA personnel need a warning about heat stress, heat exhaustion, and dehydration, and exposure hazards from chemicals on turf fields, before entering the fields? I thought OEHHA declared the fields safe. If OEHHA staff get this warning, shouldn’t this warning be given to children before they enter the field? Maybe posted somewhere?
“Before entering the field, the LBNL and OEHHA field leads will hold a tailgate meeting to go over the safety protocol. OEHHA field lead will present the emergency facility information and discuss potential physical (e.g., trips and falls, slip hazards, heat exhaustion and heat stress, dehydration, proper lifting techniques, use of personal protective equipment including eye protection, potential exposure hazards from chemicals applied to or that are on the turf, hygiene techniques and first aid) and biological hazards (e.g. bug bites).”
cd
Liberated cloud of nanoparticle sized particulates- either carbon nanotubes or other nanolevel materials added as ingredients or ground down from carbon black dust that coats the balls and the players (and their lungs, plus at the nanolevel may easily enter cells to wreak havoc)
km
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