Microplastics restriction proposal : SEAC’s opinion

The European Chemical Agency’s (ECHA) Committee for Socio-economic Analysis (SEAC) met Tuesday (8th December) to finalise and adopt its opinion on a restriction proposal to control the use of intentionally added microplastics. Following an extensive consultation process, based on their draft opinion published in June, SEAC is understood to have retained the two possible options to control the releases of polymeric infill materials from synthetic turf sports pitches; these being either a ban on the placing on the market of polymeric infill, or the mandatory use of risk management measures to prevent the infill leaving the sports field. It is understood that SEAC has concluded these two options have different costs to society, but also different levels of effectiveness in preventing releases. SEAC’s opinion will be published in early 2021. Previously ECHA’s Risk Assessment Committee (RAC) had opted to recommend a ban on the sale of polymeric infills, but with a six-year implementation period.

Following the adoption of SEAC’s opinion, ECHA will send the opinions of both committees and its restriction proposal to the European Commission. Restrictions under the REACH Regulation are proposed by the European Commission, voted by the EU Member States in the EU’s REACH Committee, and scrutinised by the European Council and the European Parliament.

Noting the conclusion of SEAC’s work, ESTC Director General Stefan Diderich is pleased to understand that the committee has maintained its previously stated view that it is for the Member States to decide if the priority is minimising infill loss through a ban on its sale and use, despite the adverse implications for many; or to introduce risk management measurers that greatly reduce the release, but still allow fields to benefit from the many positive attributes polymeric infills provide. Diderich understands that SEAC has acknowledged the recent publication of the CEN Technical Report TR17519, which details how risk management procedures can be implemented, and the EcoLoop report that ESTC submitted to SEAC during the consultation period, which shows how these risk management procedures can reduce infill migration by up to 98 percent.  Looking ahead, Diderich recognises that ESTC will need to continue to engage with all relevant bodies to try to ensure that they recognise that synthetic turf fields provide great, safe, all-weather sports facilities for the many millions of players that us them every year across Europe, but at the same time, ensure the synthetic turf industry acts responsibly and proactively to take steps to help protect the environment.

Investment in RMMs the right thing to do

As third-generation synthetic turf fields will be around for many years, an investment in risk management measures (RMMs) is the right thing to do, and, in fact, is a legal obligation.

During a webinar hosted by ESTC Affiliate Member BSNC from the Netherlands, Director General Stefan Diderich reminded delegates of their duty of care. “Protecting the environment is a legal duty that applies to any person. In most legal systems, this is recorded as the duty of care. As the current scrutiny of synthetic turf by the European Commission focuses only on the question of whether the placement onto the market of polymeric infill should be banned, the political process does not affect 3G fields already in existence. However, in the interests of the environment, society and the industry, it would be the right thing to do anyway, to fit these fields with mitigating measures to prevent the spread of polymeric infill,” he said.

The European Commission is currently reviewing options to reduce microplastic pollution from many different sources, including polymeric infill from third-generation fields. One of the options is to ban the placement onto the market of infills, effective January 2028, another being to make it compulsory to fit risk management measures.

Many solutions available

Risk management solutions are only effective when a combination of protocols, products and procedures are implemented. “Owners and users of a third-generation synthetic turf field need to understand that infill is a vital component that guarantees the durability and safety of the field. That is why it is important to use only the official entry and exit to the field. That is also why these access points should be fitted with traps to capture the infill that might stick to players’ shoes or socks after they have used the field.” Diderich also pointed out the importance of maintaining a field correctly. “Due to sliding tackles or ball surface interaction, the infill migrates to the sides of the field. It is important to recognise the presence of access infill on the sides of the field when maintaining it. Adjusting vehicle speed or ensuring leaf blowers will blow inwards are small but effective steps to keep the infill inside the field perimeter.” While these steps can help make significant improvements, the installation of containment barriers is inevitable. “Due to the low particle weight, wind or water running off a field can act as carriers. Containment barriers can go a long way to stop these mediums from transporting the polymeric infill of a field.” Guidance on risk management measures can be found in the ESTC Infill Containment Guideline.

RMMS are effective

Studies by the Dutch organisation for applied scientific research (TNO) and Swedish consultancy firm Ecoloop have established that infill migration from 3G fields can be reduced to 2mg/m2 per annum. “This is a third of the maximum quantity of polymeric infill leaving a field the European Chemicals Agency (ECHA) has proposed to accept, providing a field is fitted with risk management measures,” Diderich points out. He hopes that the European Commission will accept the 7mg/m2 per annum ECHA proposes. “Society can’t do without synthetic turf. Most cities don’t have the space to provide enough grass surfaces, not to mention the budget shortage for maintaining the field. Third-generation fields that are fitted with risk management measures will allow society to continue working on their physical and mental health, while the environment is also protected for microplastic pollution from polymeric infill.”

 

Infill dispersion can be managed

A combination of appropriate field design, good maintenance routines and improved player’ hygiene can limit infill dispersion to only 2g/m2, says Swedish consultancy firm Ecoloop.

Earlier this year, ESTC commissioned Ecoloop to undertake a study to describe typical use of synthetic turf fields in the EU and to quantify the extent of infill transport due to common activities on third-generation synthetic turf fields.

The Swedish consultants have studied all the literature available on these topics. They have identified three zones:

  • The field of play where the infill is meant to be
  • A control zone to where the infill can migrate and accumulate. This zone is designed with this in mind, hence the infill cannot move out of the area
  • An uncontrolled zone, to where infill should not migrate.

They conclude that infill migration into uncontrolled zones on fields in common use in the EU can be controlled by up to 97%. If adopted, use of mitigating measures and good practices could help limit the uncontrolled migration of infill to about 2 g/m2. This is below the 7g/m2 proposed by ECHA’s Socio-Economic Analysis Committee (SEAC).

Mitigating measures

Examples of mitigating measures are barriers, decontamination grates, boot cleaning brushes and filters. These will help maintain the infill within the boundaries of the containment zone of the field. Earlier this year, the European Standards Committee released CEN TR 17519 Surfaces for sports areas – Synthetic turf sports facilities Guidance on how to Minimize Infill Dispersion into the Environment, which documents these and other mitigating solutions. These solutions are endorsed by the various sports governing bodies, with FIFA even incorporating these in their latest ‘Handbook of test methods.

In addition, adoption good practices by maintenance crews as well as players and officials will result in capturing infill before it leaves the perimeter. With these stakeholders handling and storing maintenance equipment correctly, as well as use of boot cleaning stations and decontamination grades, the dispersion of infill could be further controlled.

The Ecoloop report shows that if all parties using synthetic turf fields with polymeric infills act responsibly and implement the recommendations of the CEN technical report, infill migration can be controlled. Therefore, banning the sale or use of polymeric infill shouldn’t be necessary.

ESTC is calling on ECHA to recommend infill for 3G synthetic turf to be granted derogation from the proposed restrictions on intentionally added microplastics, on the basis that the recommendations of the CEN technical report become mandatory for all new and existing fields.

You can download the full report here.

5 Days left to answer 5 questions

Please don’t forget that ECHA’s deadline to respond to the draft opinion of its Socio-Economic Analysis Committee (SEAC) on the restriction dossier on intentionally added microplastics, expires on 1st September 2020.

Those wishing to convince SEAC that the market is not ready yet to do away with polymeric infill for third generation synthetic turf fields, will have to answer the following 5 questions:

  1. Will there be enough alternative synthetic turf systems that meet relevant performance standards available, and in sufficient quantities, for all types of pitches by the end of the six-year transitional period proposed?
  2. How many pitches would need to be replaced before the end of their expected lifetime and what would the impacts of such a replacement be?
  3. Is there evidence to suggest that indoor artificial pitches should be treated differently from outdoor pitches?
  4. Is it true that only 10-20% of pitches would need to be replaced be?
  5. Is it correct that the average cost of containment is considered to be 30,000 € per field?

Please note that SEAC wants answers to these questions to be substantiated with evidence. The comments can be submitted online by following this link.

ESTC response

A comprehensive ESTC response will be submitted by the end of the week latest. Our response will be substantiated by the literature review undertaken based on results from our own tests in Sweden. Here, consultancy company Ecoloop concluded that published data from various studies  shows that, providing a synthetic turf field is fitted with mitigating measures, maintenance correctly by responsible operators and players use boot cleaning brushes, etc., infill dispersion can be limited to max. 7 gr/m2 per year.

The value World Rugby sees in ESTC

World Rugby has become the latest ESTC affiliate. Marc Douglas of World Rugby explains the value they see in joining the governing body for the synthetic turf industry.

With all the major suppliers in the synthetic turf value chain, as well as all the major sports governing bodies already being members, it makes logical sense that World Rugby would join ESTC.  Marc Douglas : ‘We will now have unrestricted access to the industry. As synthetic turf systems are made up of a variety of individual components of which the alignment and collective cooperation determines the final performance, the interaction we can now have with companies further down the value chain will certainly add value to the relationship we already have with our Preferred Turf Producers partnerships and our Accredited Test Institutes. These partnerships are very important to us and we have very good relationships with each of them. ESTC events will provide a perfect opportunity to catch up and engage with all areas of the industry.’

‘Fields must be Regulation 22-compliant if they are to be used for any form of contact rugby so we rely on the industry in general to help get that message out. We look forward to, through membership of ESTC, having more input from the entire synthetic turf value chain. This will further add value to the honest feedback we try to collect from our Preferred Turf Producers and our Accredited Test Institutes.’

Working Groups contribution

ESTC Working Groups are at the heart of ESTC activities. As a member, World Rugby can now participate in discussions and contribute to ESTC publications. ‘In the past our interaction with these working groups was limited. Now we can join the table and participate in the discussions taking place in the Shockpad, Yarn, Infill, as well as the Environmental Legislation Working Group meetings. The latter has become particularly important as it covers current issues like recycling or appropriate field design to mitigate infill dispersion. These are issues we take very seriously. The various publications and standards produced by ESTC are relevant to all owners and users of synthetic turf fields. Most compliant rugby fields are in Europe, so any outcome from the microplastics discussion has a material effect on what we do. However, rugby is also growing in popularity, so the fact that ESTC represents the industry within the EMEA region, has an extra added value. At the same time, we are also an Associate Member of the Synthetic Turf Council in North America as we recognise the challenges that being a minority sport pose to the work our member Unions in the area do in complying with Regulation 22. That membership and partnership is also important to us to further improve the game and the surfaces on which it is played. Being able to participate in drafting new documentation will enable us to further help educate end users about synthetic turf for rugby and how it can benefit other sports and athletes. We know from experience how difficult it is to get relevant information out.’

Adding value to members

Earlier this year, Marc hosted a webinar to update ESTC members about the latest developments regarding synthetic turf within World Rugby. ESTC members can certainly look forward to more of these exclusive opportunities. ‘The annual ESTC Congress and Working Group meeting will provide us with another opportunity to meet and listen to the industry, as well as to provide feedback from the rugby community. The webinars ESTC hosts will also provide us with a platform to interact with the industry. Last but not least, I also foresee that our membership will add value to the One-Turf vision that reflects best practice in the areas of player welfare, performance, sustainability, and longevity as developed by FIFA, World Rugby, and FIH. As FIFA and FIH are already members of ESTC, we are now able to collectively engage with the industry and take this concept to another level.’

ESTC Letter to the members released

The latest issue of our ‘Letter to the members’ has been released! This edition of the quarterly newsletter updates members about the latest developments regarding polymeric and biodegradable infills, the FIFA Technical Advisory Group meeting, activities within the ESTC Working Groups, and achievements by members.

Being the sole industry body for the synthetic turf industry within the EMEA region, ESTC takes its responsibility of educating and informing the market very seriously. The ESTC Letter to our members is only one of the many benefits ESTC members receive.

Not a member yet? Join us or sign up for our external newsletter to ensure you stay in the loop.

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 to flyer 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 use

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 updated ESTC members about the plans and progress of the Working Group in a webinar. 

 

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.