ESTC comments on the proposed ban on sale of microplastic infill

ESTC identifies risks and opportunities from the proposed ban on the sale of infill materials classified as intentionally added microplastics

ESTC (the EMEA Synthetic Turf Council) notes the publication of the European Commission’s recommendations on the introduction of restrictions for the placing of intentionally added microplastics onto the European market (Annex XVII REACH1).  The Commission’s recommendation is for a ban2 on the future sale of intentionally added microplastic infill (most commonly end of life tyre shred) for synthetic turf systems, as the most effective way to reduce microplastic emissions. The option for derogation via risk management methods (RMMs) has been removed from the proposal as it was not considered viable by the Commission to meet its reduced emissions objectives.

ESTC has adopted environmental care as its core strategy and is involved in multiple projects focused on the environment. ESTC agrees with the goals of the European Commission and ECHA to reduce the emissions of intentionally added microplastics as part of the wider European Green Deal for climate neutrality by 2050. In this light, ESTC worked hard with many stakeholders (including international sports federations) to help develop the CEN Technical Report 175193 for infill control and mitigation. Independent research has shown the efficacy4 of RMMs, but the Commission appears to be concerned about the practicability and enforceability of such methods and has therefore opted for the ban option.

ESTC notes that the European Commission is proposing a six year transition period before the new restriction becomes effective. However, current surfaces are expected to be usable for at least 10 years and many existing fields may struggle to achieve their full-service life due to an inability to purchase the materials required for on-going maintenance, forcing communities, schools and sports clubs to either replace their surfaces prematurely or risk deteriorations in the quality and safety of their fields. ESTC therefore calls for the transition period to be extended to at least 10 years to enable those that have recently invested in new fields to obtain the full operational life they anticipated.

ESTC is pleased to note that the proposed ban will be at the point of sale, putting the responsibility for compliance onto suppliers and installation/maintenance contractors and not field owners, which should simplify the adoption of legislation.
The proposed legislation does not require any retrospective actions to be undertaken to current fields and this is also welcomed by ESTC as this would have been a significant burden on facility owners and operators. ESTC does, however, encourage everyone to ensure their fields are managed and maintained responsibly so they do not allow infill to migrate into the environment including the adoption of the guidance outlined in CEN Technical Report 17519 for all new fields that will use microplastic infills during the transition phase.

The ban of intentionally added microplastic will not change the benefits of turf systems to the millions of people enjoying them each year. Synthetic turf fields offer high quality and long-lasting surfaces that allow communities throughout Europe to benefit from the health, social inclusion and mental wellbeing advantages that sport and physical activity provides in a wide range of different climates.

This decision will be a challenge to the majority of European markets in which infills classified as microplastics have proven to be the most popular. Although a lot of research and development efforts have been taking place in the period leading up to the decision of the European Commission resulting in very promising alternative solutions, the industry will find it challenging in all markets to fully transition within the proposed period of 6 years. This further reinforces the request to extend the transition period to at least 10 years to allow for a more controlled changeover.

ESTC awaits full clarification on the wording of the new restriction as it works its way through the legislative process, and to working with all relevant stakeholders to support the development and implementation of turf systems towards a greener future that can be enjoyed throughout Europe.

Links:
https://echa.europa.eu/documents/10162/05bd96e3-b969-0a7c-c6d0-441182893720
2https://ec.europa.eu/transparency/comitology-register/screen/documents/083921/1/consult?lang=en
3 CEN TR 17519 Guidance on how to minimise infill dispersion into the environment – for a copy, contact your national standards institute
4https://www.estc.info/wp-content/uploads/2020/09/Ecoloop-Report-Effectiveness-RMMs.pdf

 

PAH content of infill materials : EU regulation becomes effective today

July last year, the European Union (EU) published Regulation (EU) 2021/1199  controlling the polycyclic aromatic hydrocarbons (PAHs) content of infill materials. The law becomes effective from today 9th August 2022. This means that all infills made from:

  • rubber or other vulcanized or polymeric material
  • of recycled or virgin origin,
  • or obtained from a natural source,

must not have a total content sum (of the eight specified PAHs) of more than 20 mg/kg.

Additionally, all infill materials places on the market must be marked with a unique identification number of the batch to allow traceability to enable the compliance of the batch to the new regulation to be verified.
Enforcement of new regulation will be undertaken by national authorities in each member state.

Whilst primary responsibility for ensuring compliance with the new law will be with the companies that produce the infill, contractors installing synthetic turf surfaces or replacing infill as part of a maintenance contract can also be considered to be placing the product onto the market (i.e., they are selling it to the field owner) so they also need to ensure the products they offer and use are compliant.

As stated in the new law, infill materials that are currently in use, may remain in place and continue to be used.

UK REACH publishes work programme for 2022-2023

On June 30, 2022, UK Reach published its work programme for 2022/23.   . This includes topics that will be of interest to ESTC members operating in the UK market as follows.

Priorities for the 2022-2023 UK Reach Work Programme 

1. Per- and polyfluoroalkyl substances (PFAS)

Description of proposal

A proposal to investigate the risks of per- and polyfluoroalkyl substances (PFAS) and consider how best to manage any identified risks.

Agreed action

The Environment Agency, with HSE, is conducting an RMOA which will make recommendations on how to manage the identified risks of using PFAS. The appropriate authorities intend to act on the recommendations in the RMOA, when published, which may indicate that a restriction is the most appropriate option to control any identified risks.

Primary hazards

Various hazards depending on the sub-group of PFAS: persistent, bioaccumulative, toxic (PBT).

Rationale

PFAS are a large group of synthetic chemicals, consisting of several thousand individual substances. These substances are used in a wide range of product types, such as stain repellents, lubricants, packaging, electronics, and in fire-fighting foams, because they have several desirable technical properties (such as oil resistance, water resistance and low chemical reactivity).

However, their persistence in the environment means any adverse impacts may be difficult to mitigate. Long-term, some PFAS accumulate in living tissue (bioaccumulate) and can significantly affect human health and wildlife by causing cancer, interfering with hormonal systems (endocrine disruption) and some PFAS are toxic to reproduction. Many of those that are not bioaccumulative are still likely to accumulate in surface and ground waters, including drinking water supplies, where removal is difficult. In March 2022 the European Chemicals Agency (ECHA) submitted a proposal under EU REACH to restrict PFAS in firefighting foams. Several EU member states also intend to submit a broader proposal in January 2023 to restrict the manufacture, placing on the market and use of PFAS. Between December 2021 and January 2022, HSE conducted a call for evidence as part of the ongoing RMOA on PFAS under UK REACH. This provided an opportunity for interested parties to provide technical and socio-economic information on PFAS and inform development of the RMOA. Other areas of developing policy will also contribute to the RMOA, such as the work on persistent, mobile and toxic (PMT) substances.

The recommendations from the RMOA will be published on the HSE website in summer 2022, which may indicate that a restriction is an appropriate measure to control the identified risks. The appropriate authorities, with HSE, will consider the recommendations as soon as possible after publication.

2 Intentionally added microplastics

Description of proposal

A proposal to investigate the risks of intentionally added microplastics.

Agreed action

An evidence project to review emissions of intentionally added microplastics and the risks they pose (both to human health and the environment), including a socio-economic assessment.

Primary hazards

While there is some uncertainty regarding the hazards involved, intentionally added microplastics are likely to be persistent in the environment and cause physical obstruction. They may also contain chemical hazards from additives in the plastics and absorb pollutants in the environment.

Rationale

Intentionally added microplastics are often added to products, such as paints, infill material on sports pitches, and detergents, to serve a specific purpose. However, the risks that microplastics pose are not well characterised. Existing concerns relate mainly to environmental risks, but more recent studies suggest there are also risks to human health.

Some uses of intentionally added microplastics are already regulated within the UK. During 2018 and 2019 the four UK administrations separately introduced bans on microbeads in certain wash-off personal care products and cosmetics  (which sometimes contain microbeads as exfoliants).

In January 2019 a proposal was submitted under EU REACH to ban the placing on the market of microplastics as a substance, on its own or in a mixture in a concentration equal to or greater than 0.01% weight for weight (w/w). Both the Committee for Risk Assessment (RAC) and Committee for Socio-economic Analysis (SEAC) under EU REACH agreed that introducing a restriction was the most appropriate measure to address the risks.

The Environment Agency submitted comments on behalf of several government bodies in response to the consultation on the 2019 EU proposal for restricting microplastics supporting the application of the precautionary principle (considering risk reduction measures when the risk is uncertain). They also stated that any measures adopted on this basis must be proportionate, based on cost-benefit analysis, and subject to review when new information becomes available. Defra will commission an evidence project to assess the scale of the risks and identify the most effective measures to address them in the short to medium term.  It will also help identify wider evidence gaps that need to be addressed in the longer term to support a more strategic approach to managing intentionally added microplastics.

Substances not considered a priority in 2022 to 2023

3  Restriction of polycyclic aromatic hydrocarbons (PAHs) in rubber crumb used for synthetic sports pitches

Description of proposal

A proposal to restrict the placing on the market of rubber granules and mulches as infill material on synthetic turf sports pitches or in loose form on playgrounds.

Primary hazards

Carcinogenic.

Rationale

Rubber crumb, used in sports pitches, is often produced from end-of-life tyres. There was a concern in the EU that this could lead to rubber crumb containing high levels of PAHs, leading to a risk for users of synthetic turf pitches and some playgrounds.

Entry 50 of Annex XVII under UK REACH already restricts the use of extender oils in the production of rubber tyres if they contain more than 1 milligram per kilogram (mg/kg) of some PAHs (and 10mg/kg in total). Substances classed as category 1A or 1B carcinogens (known or presumed carcinogenic in humans) and listed under appendix 1 or 2 (including PAHs) are also restricted under entry 28 of Annex XVII.

In 2022, an amendment to entry 50 of the Annex XVII of EU REACH came into force limiting PAHs to 20mg/kg in granules or mulches used as infill material in synthetic turf pitches or in loose form on playgrounds or in sport applications. The amendment applies from 10 August 2022.

A study conducted by Sport England and submitted to the public consultation on the ECHA restriction found that 95% of the material in use within the UK falls within the limit set in the 2022 amended entry 50 of Annex XVII under EU REACH. A study conducted for the ECHA restriction dossier similarly found that most pitches across the EU (and including the UK) are already compliant with the restriction.

In 2020 the Sports Pitch Construction Association (SAPCA) introduced a code of practice setting a concentration limit of 20mg/kg in rubber infill material manufactured by its members. The aim is to reduce the use of infill material that is non-compliant with the concentration limits set by the EU restriction. SAPCA continues to work closely with the UK government on this issue.

The effectiveness of existing restrictions on PAHs and the precautionary measures taken by the sports sector means this is not a priority for action this year. However, the appropriate authorities will continue to consider whether a restriction under UK REACH may be required when setting priorities in future work programmes, should evidence suggest the voluntary code is not being adhered to.

The full work programme can be viewed here : (Rationale for prioritising substances in the UK REACH work programme, 2022 to 2023 – GOV.UK (www.gov.uk)

Draft German test method to determine microplastics emissions due to wear

The German based Forschungsgesellschaft Landschaftsentwicklung Landschaftsbau e. V.(Landscape Development and Landscaping Research Association) (FLL) have been working with the German synthetic turf industry to develop a test method to assess the potential for synthetic turf fibre yarns to wear and create microplastics. The researchers have published their draft test method and are currently inviting comments on their work. Comments should be submitted in writing to the FLL office (s.kramps@fll.de) by 31 August 2022.

The test method has also been submitted to CEN TC 217 for consideration and inclusion in the new European Standard EN 15330-6 Surfaces for sports areas – Synthetic turf sports surfaces, Part 6: Specification for synthetic turf carpets, that is currently under development. Once the drafting of prEN 15330-6 has been completed, it will be published for public comment following the normal CEN Enquiry protocols. This will give the industry a second chance to review and comment on the draft test method.

2022.05.27 draft test method – reply form

2022.05.27 draft test method

The EC adopts revised recommendation on the use of PEFs

Product Environmental Footprints (PEF) are the method of environmental life cycle analysis that the European Commission has developed for products and services being placed onto the European market.  The PEF method measures and communicates  the environmental performance of goods, services and organisations across their whole lifecycle. They cover 16 environmental impacts, including climate change, and impacts related to water, air, resources, land use and toxicity, and give a comparison of environmental performances between similar products and companies active in similar sectors.

ESTC is currently working with the European Commission to establishing the Category Rules that will describe how PEFs for synthetic turf surfaces should be calculated, a project which is funded under the LIFE programme of the EU.

Last week, the Commission adopted a revised Recommendation on the use of PEFs. Announcing the new Recommendation the Commission stated that using PEFs will help companies to calculate their environmental performance based on reliable, verifiable, and comparable information, and for other actors, such as public administrations, NGOs and businesses to have access to such information. It will incentivise industry to manufacture products that have a better environmental performance, helping the EU’s European Green Deal and circular economy ambitions.

Commissioner for Environment, Fisheries and Oceans, Virginijus Sinkevičius said: “The EU Environmental Footprint (PEF) methods are the most reliable, comparable and verifiable way to know the real environmental footprint of a product or organisation to date. Europeans are increasingly aware of their own environmental footprint, and many want to make environmentally friendly choices in their daily lives. These methods will help to improve environmental performance and help achieve a truly clean and circular economy”.

Full details about the new EC recommendation can be found on : https://ec.europa.eu/environment/news/environmental-footprint-methods-2021-12-16_en

CEN to develop new standard on minimum durability, environmental and toxicological requirements

Recognising the increasing regulatory focus on the environmental and sustainability properties of synthetic turf sports surfaces, the European Standards committee CEN TC 217 WG6 has agreed to develop a new standard to specify minimum durability, environmental and toxicological requirements for tufted, woven, and knitted carpets used in synthetic turf sports surfaces. It is envisaged this new standard will be applicable to all forms of synthetic turf sports surfaces, including those used outdoors and indoors as either single sport or multi-sports areas.

It is hoped that the need for new legal regulations will be reduced or eliminated by the development of this standard. It will form part of a series including:

EN 15330-1 – Surfaces for sports areas – Synthetic turf sports surfaces Part 1 sports performance and player welfare requirements

EN 15330-4 – Surfaces for sports areas – Synthetic turf sports surfaces Part 4 requirements for shockpads

EN 15330-5 – Surfaces for sports areas – Synthetic turf sports surfaces Part 5 requirements for infill materials used within synthetic turf and textile sports surfaces

EN 15330 parts 4 and 5 are currently under development by CEN TC 217 WG6. The existing EN 15330-1 will be updated to reflect the changes being proposed.

It is envisaged that this new standard will become a very important document for the synthetic turf industry. ESTC will continue to be actively involved in its development, but individual members are encouraged to participate via their national standards organisations. Development of the new standard will commence in early Decemeber. It is hoped it will be published by the end of 2024 latest.

ESTC publishes guide on end of life synthetic turf

Upon the initiative of the ESTC End of Life Working Group, a new guidance document relating to End Of Life solutions for the synthetic turf industry has been created. As the demand and need to dispose of end of life synthetic turf surfaces in an environmentally-sensitive way grows, ESTC members are making major investments in new technologies that are allowing the surfaces to be reprocessed in an environmentally-sustainable way for the first time. Recognising and wishing to encourage these developments, ESTC has produced this guide to assist everyone involved with the end of life disposal of synthetic turf sports fields. It highlights current options and best practice and gives an overview on the legal obligations that need to be considered before a surface is disposed of.

To download the document, click here.

ESTC organises webinar on how to deal with end of life turf

Today there are over 35,000 full size synthetic turf fields and many thousands of synthetic turf smaller community areas, tennis courts, etc.  That means that in the next 10 years or so over 245 million square meters of synthetic turf will reach its end of life. At the time these facilities were built end-of-life disposal was not a major consideration for many. As environmental awareness grows, the need to dispose of these surfaces in a sustainable way is becoming ever more important.

ESTC members are making major investments in new technologies that are allowing the surfaces to be reprocessed in an environmentally sustainable way for the first time. Recognising and wishing to encourage these developments ESTC has produced a Guide to assist everyone involved with the end-of-life disposal of synthetic turf sports fields. It highlights current options and best practice and gives an overview on the legal obligations that need to be considered before a surface is disposed of.

Apart from giving a full review of this End of Life Guide, we have invited an expert panel of speakers that will address a number of hot topics related to the end of life disposal of synthetic turf systems.

Panel of industry experts 

  • Paul Fraser (Fieldturf Tarkett)
  • Alastair Cox (ESTC / FIH)
  • Stefaan Florquin (Re-Match)
  • Don Lauritsen (GBN)
  • Alejandro Navazas (EuRIC)
  • Eric O’Donnell (Sports Labs)

Session Moderator : Eric O’Donnell, chair of the ESTC Task Force End of Life

For details and registration, click here : https://www.estc.info/event/webinar-end-of-life/

 

New ECHA Investigation Report on substances in infill material

NEW ECHA ANNEX XV INVESTIGATION REPORT
Prioritisation and preliminary risk assessment of SUBSTANCES IN INFILL MATERIAL

The European Chemical Agency (ECHA) has recently published a new Annex XV Investigation Report “Investigation into whether substances in infill material cause risks to the environment and human health that are not adequately controlled – prioritisation and preliminary risk assessment”. The report can be downloaded here.  It has been prepared in response to concerns about the risks posed by substances in plastic and rubber granulates used on synthetic turf pitches, this follows a request by the European Commission, submitted to ECHA in August 2017. The conclusions of the report are as follows:

  • The preliminary human health risk assessment does not exclude a potential for cobalt and zinc in infill to pose risks to human health and that these substances should therefore be considered for risk management.
  • The preliminary environmental risk assessment does not exclude the potential for cadmium, cobalt, copper, lead, zinc, 4-tert-octylphenol, 4,4´-isopropylidene diphenol (BPA), bis(2-ethylhexyl)phthalate (DEHP), benzyl butyl phthalate (BBP) and benzothiazole-2-thiol to pose risks to the environment and that these substances should therefore be considered for risk management.
  • It is recommended any further work to establish whether there is a risk for human health or to the environment from these substances is undertaken  by preparation of an Annex XV (REACH) restriction proposal

The report also notes that if the proposed restriction on the use of intentionally added microplastics bans the use of polymeric infill on synthetic turf pitches, the need for risk management measures for the substances identified in this new report may not be required. However, the report does state that in the event of polymeric infill being banned, non-microplastic uses of recycled ELT may still require further risk managements measures. ESTC consider this could potentially include the use of ELT tyre granulate in-situ rubber shockpads, athletics track surfacing, etc.

ESTC supports restricting the presence of any substances in synthetic turf systems that have been shown to pose an unacceptable risk to human health or the environment.  However, we note that the report fails to include information from a number of recent studies and reports that have been published.  One of the studies is the European Risk Assessment Study on Synthetic Turf Rubber Infill (ERASSTRI), this concluded that the current levels of substances present in European sourced ELT derived rubber granules  do not pose a risk to human health. This study has been independently published, in peer reviewed scientific journals (Science of the Total Environment, March 2020).

ESTC will continue to liaise with all relevant parties in the various user and supply chains and try to ensure any new restrictions are based on the latest scientific studies and are proportional to the risks identified, taking into account the many social and health benefits that playing sport on synthetic turf fields bring to many hundreds of thousands of citizens of Europe each year.

Colin Young named 2020 Personality of the synthetic turf industry

ESTC members vote for individual who has made a positive difference to ESTC and the industry

Colin Young of the TenCate Grass Group is the winner of the inaugural ESTC Personality Award,voted for by members of the ESTC. The ESTC Personality Award recognises an individual who has made a positive difference to ESTC and the synthetic turf industry.

Colin Young has been in the synthetic turf industry since 2010, when he joined sports flooring testing company Labosport before he moved on to TenCate Grass Group in 2018, where he is the present Research and Development Director for Turf Systems. He is heavily involved in the development and improvement of the synthetic turf industry at large and takes a keen interest in improving synthetic turf for the benefit of the environment and the industry. Apart from being a board member and Vice-Chair of the EMEA Synthetic Turf Council (ESTC), he is actively involved in the PEF CR project, a programme initiated by the European Commission which aims to establish an official life-cycle assessment. In addition, Young chairs the Non-filled Working Group at the FIFA Technical Advisory Group.

ESTC Director General, Stefan Diderich, is full of praise. “We are very pleased with having Colin Young setting the bar for the ESTC Personality Award. With hundreds of people working on improving synthetic turf every day, it is important to recognise those taking the lead or making extraordinary sacrifices. Colin is an enthusiastic, driven and passionate advocate of synthetic turf and an instigator of ESTC’s environmental agenda. As he has been voted for by his peers, the recognition will certainly have a special meaning to him. More importantly, it shows how the synthetic turf industry joins him in embracing environmental focus and the roadmap he helps to shape.”

The winner was announced during the virtual annual ESTC congress, which took place on April 20.