3 Reasons
Why California Needs to Post Prop 65 Health Warnings
at Tire Crumb Synthetic Turf Fields
NOW
Why California Needs to Post Prop 65 Health Warnings
at Tire Crumb Synthetic Turf Fields
NOW
The State of California, Cal Recycle, & OEHHA currently know that: (a)
1) Over 38% of tire crumb is composed of material that is listed by OEHHA as "known to cause cancer". (b)
2) A typical tire crumb field also includes hundreds of tons of inhalable & ingestible particles made from chemicals known to; be toxic, cause birth defects, and/or cause reproductive harm (c) -- including lead. (d)
3) Children and young adults are the groups most frequently, repeatedly exposed to the chemicals found in tire crumb synthetic turf. (e)
1) Over 38% of tire crumb is composed of material that is listed by OEHHA as "known to cause cancer". (b)
2) A typical tire crumb field also includes hundreds of tons of inhalable & ingestible particles made from chemicals known to; be toxic, cause birth defects, and/or cause reproductive harm (c) -- including lead. (d)
3) Children and young adults are the groups most frequently, repeatedly exposed to the chemicals found in tire crumb synthetic turf. (e)
The current Federal, (Trump), administration threatens to destabilize the very government agencies responsible for protecting children's health.
In California, smoking tobacco products is prohibited within 250 feet of a youth sports activity, (a measure which was decisively passed by CA Senate Bill 977). Yet today, very few California parents are even aware of the health risks associated with tire crumb chemicals.
Parents will continue to unintentionally expose their children to a significant toxic chemical risk, which is possibly not of their choosing, until California requires the posting of warning signs at the entrance of tire crumb fields.
In California, smoking tobacco products is prohibited within 250 feet of a youth sports activity, (a measure which was decisively passed by CA Senate Bill 977). Yet today, very few California parents are even aware of the health risks associated with tire crumb chemicals.
Parents will continue to unintentionally expose their children to a significant toxic chemical risk, which is possibly not of their choosing, until California requires the posting of warning signs at the entrance of tire crumb fields.
Explanatory Footnotes
(a) OEHHA is the California Office of Environmental Health Hazard Assessment which is a department within the California Environmental Protection Agency (Cal/EPA) -- with responsibility for evaluating health risks from environmental chemical contaminants. CalRecycle is the California Department of Resources Recycling and Recovery.
In 2016 OEHHA convened a scientific advisory panel to provide advice on a multiyear study.
(b) OEHHA reports that over 38% of the material found in tire crumb is "known to cause cancer" – which includes the petroleum derivative, carbon black, (listed as a Prop 65 chemical in 2003) .
(Carbon black should not be confused with nontoxic materials such as activated charcoal or graphite.)
The carbon black used in tires is a material that is produced by the incomplete combustion of a variety of heavy petroleum products. The specific sources for carbon black chemicals are not standardized -- they can include;
(a) OEHHA is the California Office of Environmental Health Hazard Assessment which is a department within the California Environmental Protection Agency (Cal/EPA) -- with responsibility for evaluating health risks from environmental chemical contaminants. CalRecycle is the California Department of Resources Recycling and Recovery.
In 2016 OEHHA convened a scientific advisory panel to provide advice on a multiyear study.
(b) OEHHA reports that over 38% of the material found in tire crumb is "known to cause cancer" – which includes the petroleum derivative, carbon black, (listed as a Prop 65 chemical in 2003) .
(Carbon black should not be confused with nontoxic materials such as activated charcoal or graphite.)
The carbon black used in tires is a material that is produced by the incomplete combustion of a variety of heavy petroleum products. The specific sources for carbon black chemicals are not standardized -- they can include;
- FCC tar (fluid catalytic cracking),
- ethylene cracking tar, (ethylene is produced in the petrochemical industry by steam cracking. In this process, gaseous or light liquid hydrocarbons are heated, inducing numerous free radical reactions),
- coal tar (coal tar is one of the by-products when coal is made into coke and coal gas. It is a complex mixture of phenols, polycyclic aromatic hydrocarbons (PAHs), and heterocyclic compounds).
(c) Individual measurements for chemicals found in tire crumb samples vary. OEHHA reports variability in reported samples differing by as much as 75 times. The precise chemical makeup of each tire is considered proprietary information, (industry secrets). No government agency requires tire manufacturers to divulge the exact chemical makeup of the ingredients used in their products.
Additionally, the chemical recipes or chemical makeup of tire models tend to shift and change throughout the years. Each tire has an individual country of origin -- involving hundreds of manufacturing factories throughout the world. (Determining the countries of origin of each of the worn waste tires used on a tire crumb field, from their imprinted codes, is not possible.)
(d) It is generally accepted that no level for lead exposure to humans is considered safe. The lead found in tire crumb is in addition to, and should not to be confused with, the lead found in the plastic synthetic turf -- about which the State of California sued the manufacturers and won in 2008.
(e) Children have been found to be especially susceptible, and vulnerable to chemical uptake and its potential life-long impacts. Accumulation of chemicals through daily exposures is problematic. By design, users of tire crumb synthetic fields come in direct contact with the particles -- and both users and spectators at the fields can intake the particles through multiple pathways simultaneously. Exposure routes include inhalation, ingestion, dermal uptake, and directly into the bloodstream through open cuts and wounds. The ingested chemicals can accumulate and have a prolonged half-life within the body.
Additionally, the chemical recipes or chemical makeup of tire models tend to shift and change throughout the years. Each tire has an individual country of origin -- involving hundreds of manufacturing factories throughout the world. (Determining the countries of origin of each of the worn waste tires used on a tire crumb field, from their imprinted codes, is not possible.)
(d) It is generally accepted that no level for lead exposure to humans is considered safe. The lead found in tire crumb is in addition to, and should not to be confused with, the lead found in the plastic synthetic turf -- about which the State of California sued the manufacturers and won in 2008.
(e) Children have been found to be especially susceptible, and vulnerable to chemical uptake and its potential life-long impacts. Accumulation of chemicals through daily exposures is problematic. By design, users of tire crumb synthetic fields come in direct contact with the particles -- and both users and spectators at the fields can intake the particles through multiple pathways simultaneously. Exposure routes include inhalation, ingestion, dermal uptake, and directly into the bloodstream through open cuts and wounds. The ingested chemicals can accumulate and have a prolonged half-life within the body.
Only inconclusive data can be expected from the sampling of a highly variable material, (like tire crumb). Especially when the samples amount to only grams, (or smaller), taken from a massive sampled source that is in the tons, which has been spread out over what amounts to, (literally), football fields – found in thousands of outdoor installations across California.
1) The majority of users of tire crumb fields tend to be youth or children. Children have been found to be especially susceptible to chemical uptake and their potential life-long impacts. Accumulation of chemicals through daily exposures is common. By design, users of tire crumb synthetic fields come in direct contact with the particles -- and both users and spectators at the fields can intake the particles through multiple pathways simultaneously. (b)
2) The average sized tire crumb field contains hundreds of tons of inhalable material containing chemicals known to; be toxic, cause birth defects, cause reproductive harm, and/or cause cancer. (c) Tire crumb samples have also consistently been found to contain lead. (d)
3) Over 38% of tire crumb is composed material -- that is "known to cause cancer" by the State of California. (e)
Would Californians care if they knew? For context, in 2016, Californians voted to prohibit smoking tobacco products within 250 feet of a youth sports activity, (Senate Bill 977).
Every day that California fails to follow its mandate of enabling parents to make an informed choice about chemical exposures for their children by simply posting a sign -- most parents will continue to unwittingly put their children at risk, or in a situation that is not of their choosing.
Every day that California fails to follow its mandate of enabling parents to make an informed choice about chemical exposures for their children by simply posting a sign -- most parents will continue to unwittingly put their children at risk, or in a situation that is not of their choosing.
Lauren Zeise, OEHHA Director (916) 322-6325
To submit comments to OEHHA please send emails to SyntheticTurf@oehha.ca.gov (a) Proposition 65 is a California law containing a statutory requirement that prohibits businesses from knowingly exposing individuals to listed substances without providing a clear and reasonable warning. Proposition 65 is administered by the California Office of Environmental Health Hazard Assessment, (OEHHA).
(b) The precise chemical makeup of tire is considered proprietary and is treated as an industry secret. No government agency requires tire manufacturers to divulge the exact chemical makeup of the ingredients used in their products. Additionally, the chemical recipes or makeup of tire models tend to shift and change throughout the years. According to OEHHA individual measurements for chemicals found in tire crumb samples vary and fluctuate by as much as 75 times. Each tire has an individual country of origin of manufacture -- with hundreds of manufacturing factories spread throughout the world. (It should be noted that determining the country of origin of each individual waste tire from its imprinted code is unrealistically difficult -- if not impossible.
(c) The lead found in tire crumb is not to be confused with the lead that was historically found in the plastic blades of synthetic turf.
(d) Generally no level for lead exposure to humans is considered safe
(e) (OEHHA, Carbon Black – 2003)
Carbon Black should not be confused with more benign materials such as activated charcoal or graphite. Carbon black is a material that is produced by the incomplete combustion of a variety of heavy petroleum products. The specific source for carbon black is not standardized. It may come from - FCC tar (fluid catalytic cracking), - coal tar (coal tar is one of the by-products when coal is made into coke and coal gas. It is a complex mixture of phenols, polycyclic aromatic hydrocarbons (PAHs), and heterocyclic compounds), and - ethylene cracking tar, (ethylene is produced in the petrochemical industry by steam cracking. In this process, gaseous or light liquid hydrocarbons are heated, inducing numerous free radical reactions). Carbon black is introduced into the tire manufacturing process in a microscopic nanoparticlulate form. Prior to being trampled on in the fields, the waste tires are ground into particles that range in size from microscopic particulates to approximately the size of a grain of sand. (e) Exposure routes include inhalation, ingestion, dermal uptake, and directly into the bloodstream through open cuts and wound. The ingested chemicals can accumulate and have a prolonged half-life within the body.
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