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 when a child falls. The granules and mulches are often made from scrap end-of-life tyres (ELTs) that are broken up and ground down into 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 about the safety of artificial sports pitches and playgrounds.

What are the health risks to humans?

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. 

 

Further investigation to clarify uncertainties

ECHA's report 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, the Agency 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 sent its evaluation to the European Commission on 28 February 2017. 

In addition to ECHA's findings, the Dutch National Institute for Public Health and the Environment (RIVM) had conducted a study on the health risks of rubber granules used in the Netherlands in early 2017, which confirmed that playing sports on these fields is safe.

However, similarly to the conclusions 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 proposing a restriction to limit the concentration of eight PAHs in granules or mulches used as infill material in synthetic turf pitches or in loose form for use in sports applications and on playgrounds. The restriction dossier was received by ECHA on 20 July 2018.

Proposed restriction by the Netherlands

The proposed restriction 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 recommended to lower the combined concentration limit for those eight PAHs found in rubber granules 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).

Committee opinions

On 20 September 2019, the Committee for Socio-economic Analysis (SEAC) adopted its final opinion by simple majority, supporting the Netherlands’ proposal to restrict the eight PAHs and the earlier opinion of the Committee for Risk Assessment (RAC) in June 2019.

The opinion proposes to lower the total concentration limit of the eight PAHs to 20 mg/kg. The aim is to ensure that the cancer risk from PAH exposure remains at a low level for those that come into contact (by inhaling or touching) the granules and mulches. This includes footballers and children playing on the pitches or playgrounds and workers installing and maintaining the surfaces.

The proposal will not affect existing fields but will ensure that the material used for maintaining (refilling) the fields is below the new limit.

European Commission decision

The Commission is expected to prepare its proposal following ECHA committees’ opinion. Following the standard procedure, the Commission’s proposal to amend Annex XVII to REACH will be submitted to a Member State vote in the REACH Committee, followed by a period of scrutiny by the European Parliament and the Council.

Is that it?

Many of the infill types used are also microplastics (see hot topics page) and this issue is being discussed in RAC and SEAC in the context of the proposed restriction on intentionally added microplastics.

If necessary, ECHA will also look at the health and potentially also the environmental impacts of other substances contained in rubber granules derived from end-of-life tyres.

Planned timetable for restriction proposal on PAHs in granules and mulches used as infill

 

Future timings are tentative

  Timing
Intention to prepare restriction dossier 30 June 2107
Call for evidence 23 July – 18 October 2017
Workshop hosted by RIVM 24 November 2017
Submission of restriction dossier 20 July 2018
Public consultation of the Annex XV dossier  19 September 2018 – 19 March 2019
RAC opinion 7 June 2019
Draft SEAC opinion 14 June 2019
Public consultation on draft SEAC opinion 19 June 2019 – 19 August 2019
Combined final opinion submitted to the Commission October 2019
Draft amendment to the Annex XVII (draft restriction) by Commission Within 3 months of receipt of opinions
Discussions with Member State authorities and vote 2019-2020
Scrutiny by Council and European Parliament Before adoption (3 months)
Restriction adopted (if agreed) 2020