ECHA publishes SEAC draft opinion

ECHA has opened the window for a public consultation on the SEAC Draft Opinion on the Microplastics REACH restriction. This is the final opportunity to comment on what is proposed. Together with the SEAC draft opinion, ECHA also published the final opinion by the Risk Assessment Committee (RAC). As previously advised, RAC is recommending a ban on the sale of polymeric infills, to be implemented after a six year transitional period.

With SEAC currently not expressing a firm opinion on whether a ban or derogation based on risk management methods (containment) is most appropriate, ESTC is hopeful that SEAC can still be convinced to either maintain this position or opt for derogation.

We need your input!
If you can provide further reasons why a ban should not be introduced, or provide evidence that containment will achieve the objectives of the restriction, especially beyond what has already been said, it will help us promote our argument.

Send your feedback to alastair@estc.info by 14 August latest to allow ESTC’s Technical Director Alastair Cox to formulate an industry response.

Next step
The final opinions by RAC and SEAC will be used by the European Commission in their discussions directly with the Member States. ESTC has produced this flyer to explain you the process.

ESTC will continue to lobby for derogation based on risk management methods (containment). We are speaking directly with member states on this matter and we have commissioned a report from Swedish environmental consultants that have expertise in this area.

With the CEN Technical Report on Methods of Minimizing Infill Migration from Synthetic Turf Fields to be published on 22nd July, the industry will soon have all the tools to promote this preferred option. All that is left is to convince SEAC and the European Commission that polymeric infill dispersion can be controlled this way.

Opening up about the end of synthetic turf

The ESTC End of Use Working Group reflects the entire synthetic turf value chain. Its purpose is to collect and build on the experience and best practices to recapitalise on old synthetic turf. Working Group chairman Eric O’Donnell reports.

The recycling and removal of synthetic turf has become a hot topic in recent debates. With most markets in Europe having reached a point where the first installations of synthetic turf have come up for replacement, it appears that few owners of synthetic turf fields have been prepared for the question of ‘what to do with the old turf?’ In light of the growing environmental awareness in society and the drive towards a more sustainable future, ESTC has recognised a need to establish a Working Group to guide the preparation thereof, and to disseminate relevant information.

Members of the ESTC End of Use Working Group represent the entire synthetic turf value chain. Members include raw material suppliers BASF, Dow, and Total, together with removal and recycling companies Advanced Sports Installations Europe, PR Recycling, and Re-Match, complemented by manufacturing and installation companies FieldTurf Tarkett, Sport Group (Polytan, Melos and Astroturf), and TenCate Grass Group (Ten Cate yarns and GreenFields).

Sharing knowledge

Although the debate about old synthetic turf and the re-use of reclaimed materials is fairly new, the collective knowledge and experience that members of the Working Group have, is massive. The Working Group will benefit from this with immediate effect. The Working Group has established the following agenda:

  1. To improve knowledge of waste streams and of what can be done with the ‘waste’.
  2. To share knowledge and experience with regards to what the industry is doing to tackle waste, recycling, and the carbon footprint.
  3. To highlight best practice for processes which facilitate recycling. These best practices should help with the publication of an ESTC Guideline.
  4. To educate buyers and end-users about what to expect when they intend to make use of a recycling/reuse/repurpose service.

Adding value

Providing old synthetic turf is removed correctly and removed by a company that pursues a higher purpose, synthetic turf has an advantage in that all the components can be used for another purpose. This requires all companies in the synthetic turf value chain to recognise (and, where necessary, to adopt) the waste hierarchy that most societies, these days, pursue.

 

 

One of the main agenda points for this Working Group is the establishment of an End of Use passport for old synthetic turf. Where a Product Datasheet would provide insight into what a synthetic turf field was made of, the ESTC End of Use passport would help track fields that have been removed and establish the new purpose that has been given to the various components.

 

On 1st July 2020, Working Group chairman Eric O’Donnell will update ESTC members and invitees about the plans and progress of the Working Group.

Would you like to attend this webinar? Let us know by registering yourself here.

Guideline for recommissioning a field after lockdown

Handy tips and guidance on how to recommission a synthetic turf field after lockdown have all been captured in the ESTC Guidelines for Preparing your synthetic turf field for use after lockdown.

The document has been drafted by the ESTC Maintenance Working Group. The one-page document addresses all important aspects clubs and municipalities have to consider. It also discusses how to deal with the implications of COVID-19.

You can download the guideline here

CEN publishes new standards

Three more European Standards have been published by the European Standards Committee (CEN). ESTC has played an important role in initiating and drafting these documents.

CEN has announced that the following standards are now available for purchase:

  • EN 17409 Surfaces for sports areas. Code of practice for the sampling of performance infills used within synthetic turf surfaces
  • EN 17326 Surfaces for sports areas. Determination of dimensional stability of shock pads used within sports systems
  • EN 17324 Surfaces for sports areas. Test method for the determination of the resistance to dynamic fatigue of shock pads and sports surfaces

Copies of these standards can be purchased from the respective National Standards Organisation. As the announcement was only made last week, it is possible that some countries will not have the translated versions available yet, as work to translate these documents might still be in progress.

TS prepares WG

Groundworks for a PEFCR Working Group have been laid, with the ESTC Technical Secretariat having finished the first phase of the project.

The Product Environmental Footprint Category Rules (PEFCR) project was initiated by the European Commission last year. It aims to establish official Life Cycle Assessment procedures for industry sectors. Following a thorough application process, the EU decided to cover synthetic turf in the project. ESTC was selected to represent the synthetic turf industry among four other industries.

Earlier this year, ESTC, in accordance with the rules set by the European Commission, established a Technical Secretariat (TS). With the assistance of specialised consultants, the TS will coordinate the process for establishing and testing an LCA for the synthetic turf industry. It is anticipated that this will take two years.

The TC has now compiled a list of the materials and processes that ESTC will ask the European Commission to provide. These secondary data sets are intended for use in the PEFCR. Items on the list range from the basic polymers used for the production of yarn, to end-of-use disposal of synthetic turf surfaces. Secondary data sets define the LCA or environmental impact values attributed to each material and process used throughout the life of a synthetic turf product. Providing these datasets ensure that all companies use the same values when calculating the LCA for their specific product. When a secondary data set is not provided it is the responsibility of the company undertaking the LCA to determine the value (in a defined way). The more that the EC is able to provide, the simpler it will be for the members in the future.

Establishing Working Group

The work of the PEFCR Technical Secretariat is one of a number of ESTC’s active projects. To ensure members are kept informed, an Environmental Regulation Working Group is being established. ESTC members are now invited to express their interest in participating in this working group by sending an email to info@estc.info.

Working groups form the heart of our organisation. The combined knowledge and experience of participants go a long way to guide the drafting of, or establishing of, guidelines and protocols that can make a difference. Recent achievements include the production of the ‘ESTC Performance Guide for Shock Pads’ as well as the ‘ESTC Quality Guide for Landscaping Turf’. Both documents serve as important tools for establishing the quality of synthetic turf components. ESTC also played an important role in the drafting of the guidance on how to minimise infill dispersion into the environment. This document is currently being reviewed by the European Standards Committee (CEN). Once published it will be compulsory for the market in Europe to consider the various measures to minimise infill dispersion that are proposed in this document before realising a synthetic turf field fitted with the relevant solutions.

The ESTC Environmental Regulation Working Group will play an essential role for the future of synthetic turf. It will help ESTC lobby to ensure that the increasing desire to regulate our industry does not become unnecessarily onerous or create major market difficulties.

FIH latest affiliate member of ESTC

EMEA Synthetic Turf Council (ESTC) is pleased to announce that the Fédération Internationale de Hockey (FIH) has joined ESTC as an affiliate member. The affiliate membership enables FIH to interact directly with the synthetic turf industry and to participate in the various ESTC knowledge forums.

ESTC Director General Stefan Diderich calls the membership a milestone for both the synthetic turf industry and the international hockey community. “FIH and ESTC share the ambition of sustainable and durable synthetic turf fields that don’t compromise on affordability and game experience. Having FIH onboard will help speed up the process as ESTC represents the entire synthetic turf value chain for synthetic turf for different applications. FIH will certainly also benefit from knowledge gained or best practises observed in other synthetic turf applications and which our members have achieved.”

Hockey, through the innovative leadership of the FIH, has over 40 years’ experience of playing on synthetic turf fields and now fully embraces this type of playing surface, using it for all high-level competitions. Looking to the future, the FIH is working with the synthetic turf industry to develop surfaces that perform as desired, but without the need to water them first.

Commenting on the FIH joining the ESTC, Jon Wyatt, FIH Sport and Development Director, says that playing on synthetic turf has made hockey the fast, exciting and technically skilful game that is now played by millions of people around the world. By joining the ESTC, the FIH will be able to strengthen its relationships with the companies producing the surfaces that hockey needs. It will also help to ensure that FIH is part of the debate as questions around sustainability, maximising opportunities and returns on investment and environmental considerations become ever more important.

European Code of Practice

Following the decision by the European Chemical Agency (ECHA) to draft a restriction limiting the quantities of polycyclic aromatic hydrocarbons (PAHs) allowed in infill materials used in synthetic turf surfaces it became apparent to ESTC that there should be a pan-European method of sampling infills to allow testing to verify that they comply with the restriction. The need was identified to prevent individual countries from introducing their own sampling procedures and making it very difficult for suppliers to comply without complex production procedures. Through our close links with the European Standards Committee CEN TC 217, ESTC proposed that a European Standard for the sampling of performance infills used within synthetic turf surfaces should be developed. This work commenced on March 2018 and ESTC is pleased to be able to advise the formal vote for publication of the European Standard recently closed with a positive outcome. The document is now with CEN and EN 17409: Code of practice for the sampling of performance infills used within synthetic turf surfaces will now be published as European Standard and automatically as a national standard in European countries.

The code of practice describes three procedures: one for sampling during production, one for sampling from deliveries to site, and one for sampling from installed fields. ESTC will ensure that ECHA are aware of the code of practice as soon as it is published and encourage them to refer to it in the restriction they are currently finalising for performance infills.

It is important to note that code of practice does not specify how the PAH content of performance infills should be measured. The European Commission has asked CEN to develop a harmonised test method for measuring the PAH content in rubber and plastic items (For details see https://ec.europa.eu/jrc/en/news/new-test-methods-plastic-and-rubber-product-safety). ESTC is not participating in this very specialised topic, but understand that the work is ongoing.

ESTC environmental activities taking shape

ESTC has formed two new Working Groups that will each focus on specific aspects of the environment.

The End-of-Use Working Group will focus solely on all aspects related to synthetic turf that will no longer be of use to its original owner. It will discuss and work on documentation related to the correct removal and disposal procedures of synthetic turf products. Eric O’Donnell of Sports Labs has volunteerd to chair this Working Group.

The second newly formed Working Group will focus on drafting the category rules for the Product Environmental Footprint (PEF) of synthetic turf.

As communicated before, following a thorough application process, ESTC has been selected as representative of one of 5 industries to participate in the project initiated by the European Commission. This working group will also handle all issues related to microplastics. Colin Young of the TenCate Grass Group has volunteered to chair the PEF CR & Microplastics Working Group. He will be assisted by a Technical Secretariat who will represent the synthetic turf industry in the PEF CR project from the European Union. Furthermore, ESTC has selected the consultant Pré to assist us in understanding the technical requirements and guiding us through all paperwork associated with the project.

Support publication of the CEN guideline!

ESTC encourages you to reach out to your national standards organisation to notify them that you support the publication of ‘Guidance on how to minimise infill dispersion into the environment’ by the European Standards Committee. The support is essential as we understand that the European Chemical Agency’s Risk Assessment Committee (RAC) is likely to recommend a market ban on polymeric infill materials.

The ballot by CEN to authorise the publication of the report has just commenced, with a closing date in early June. The draft report has been prepared with input from ESTC, experts representing their national standards organisations and international and national sports associations.

Publishing this guideline is essential to show the European Commission that the industry is serious about minimising infill migration from synthetic turf fields.

Good design minimises infill migration and makes ban unnecessary
From what we have been told, the European Chemical Agency’s Risk Assessment Committee (RAC) is likely to recommend a ban effective six years after the new restriction comes into effect. This would mean that from 2027/28 polymeric infill would no longer be available to the market.

RAC is one of only two committees that will advise the European Commission on the proposed ban. The other committee is the Social and Economic Assessment Committee (SEAC). Their meeting has been postponed until June or later. SEAC looks at the broader implications and alternative options whereas RAC tends to take a conservative approach because their primary focus is on the scientific aspects of a draft restriction.

Once the opinions of both committees are finalised, they will be sent to the European Commission to enable them to decide on the final content of the microplastics restriction. The Commission does not have to follow the recommendations of RAC or SEAC.

ESTC and others have already expressed views on the socioeconomic impact of any ban. We have proposed alternative ways to minimise infill migration through field containment methods. We hope SEAC will give this due consideration.

Get your copy!
Good field design and construction, containment features within perimeter fencing, edging details, access points and stormwater drainage systems are just a few examples of how infill migration can be managed. To give this guidance enhanced status and ensure publication throughout Europe, ESTC proposed that the European Standards Committee (CEN) responsible for synthetic sports surfaces, develop and publish a technical report on this subject.

We encourage you to obtain a copy of the national edition (Dutch, German, Belgium, British, etc) of the draft report from your national standards organisation (DIN, AFNOR, NEN, BSI, etc) and to notify the national standards organisation that you support the publication of the report. Please convince the national standards organisation of the importance of registering a positive vote. If the publication of the report does not receive enough support, ESTC’s submissions to ECHA will less likely influence their recommendations to the European Commission.

The CEN report reference is FprCENTR 17519, Surfaces for sports areas – Synthetic turf sports facilities Guidance on how to Minimize Infill Dispersion into the Environment (Leitfaden zur Minimierung des Risikos von Umweltkontaminationen durch Kunststoffrasenfüllungen).

We also invite you to share this information with national sports associations and other interested parties to get as much support as possible.

You can download the English version of the CEN document here. Please note that most national standards organisations will have the document available in your native language.

ESTC congress postponed until November

ESTC has decided to postpone its 2020 congress. With countries having implemented travel restrictions because of the coronavirus, hosting a conference with many members absent would defeat the purpose of the event.

The new dates for the event will be 16 – 18 November. The congress will still take place at the Ambassadeur Hotel in Juan-les-Pines, near Nice.

The booking form and updated programme (where applicable) for the November event, will be distributed in due course.