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ECHA publishes SEAC draft opinion

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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.

Genan proactively leads the way to stop rubber infill from spreading from pitches

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As a responsible manufacturer of high-performance ELT infill, continuously striving for a sustainable future, Genan has made a short, informative video explaining how we can all contribute to keeping granules on the pitch. Even simple measures make a huge difference, and we can all do something!

This inspirational, new video can be watched at the Genan website, where stakeholders at all levels may also download Genan’s 3 simple guides to the installation and maintenance of – as well as behaviour around – artificial turf pitches.

“In terms of performance and natural ball behaviour, ELT granulate is unarguably the number one infill solution,” says Group CEO at Genan, Poul Steen Rasmussen. “And keeping granules on the pitch is indeed both possible and doable, if pitches are constructed and maintained in the right way. Users must act responsibly and follow simple brush-off routines before they leave the pitch.”

For the sake of the environment – and to keep the need for granulate refill at a minimum – artificial turf pitches should be both constructed and maintained in a way to ensure that rubber granules stay on the pitch.

Genan welcomes all initiatives to protect the environment, and on the Genan website and YouTube channel, you can also find a short film (subtitled in different languages) about a recent Swedish research project, where different stakeholders joined forces to construct a reference pitch (Bergaviks IP). At this pitch, made as a closed system with preventive measures, filters etc., the loss of microplastics to the aquatic environment was successfully reduced to as little as 100 grams a year – of which only approximately 1 gram was rubber granulate!

“The recycling of end-of-life tyres helps solving a huge, global waste problem. Worn-down tyres are turned into a valuable resource with exceptional product properties – and vast amounts of CO2 are saved,” says Poul Steen Rasmussen. “But we must take sustainability even further and ensure that infill material then stays on the pitch. It really isn’t that difficult…”

With adequate containment measures and responsible behaviour, we can all help take good care of our artificial turf pitches – and their surroundings. For the benefit of public health – and the environment that we all share.

ECHA opinion delayed by 3 months

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The European Chemical Agency (ECHA) has decided to take an extra three months to finalize its opinion on the proposed restriction on intentionally added microplastics. The consolidated opinion of ECHA’s Committees for Risk Assessment (RAC) and Socio-economic Analysis (SEAC) is now expected in June this year.

The standard 12 months reserved for the committees’ opinion formation has been extended due to the high number of comments received through the public consultation. ECHA also acknowledges the complexity of the issues to be evaluated.

The public consultation on the proposal to restrict the use of intentionally added microplastic particles closed on 20 September 2019. By that time ECHA had received 477 individual comments.

ESTC welcomes EU and UEFA statements in microplastics debate

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The EMEA Synthetic Turf Council (ESTC) is pleased to have noted the statements made by the European Commission (EU) and the European Football Association (UEFA) to clarify the position of synthetic turf in the current debate about microplastics.

An official statement by the EU released on 25 July, states: ‘The European Commission does not plan to ban artificial turf pitches and does not work on such a proposal.’ The statement goes on to say that: ‘The truth is: The Commission’s plastic strategy is looking at ways to reduce the amount of environmentally harmful microplastics in our environment. In this context, among other things, the European Chemicals Agency (ECHA) is currently conducting a public consultation on the possible effects of a possible restriction on the use of microplastic granules, which is used, among other things, as filling material for artificial turf.’

The EU statement follows that of an UEFA official issued to the German Press Agency (DPA): ‘There is currently insufficient evidence of the dangers of these substances to the environment.’ The official also pointed out that ‘the existing alternatives lead to high costs and are neither feasible nor sustainable.’

ESTC Director General Stefan Diderich is happy with the public announcements made by the EU and UEFA. “The public concern and debate about the environment are understandable but the way arguments have wrongfully been linked to the synthetic turf lately, doesn’t serve any purpose. It is good to see that the European Commission is arresting this situation.”

The ESTC’s position on infill and microplastics is clear. “Infill is an essential component for third-generation synthetic turf systems. Providing it is kept within the system it is not a pollutant. There are many systems and solutions available to keep the infill within the field. All that is lacking at the moment is for owners, users and maintenance crews to actively participate in ensuring the infill remains in the field. The ESTC and its members are working hard to create such awareness.”

European Chemical Agency

While welcoming the statements from the EU and UEFA, a statement released by ECHA shows that there is still work to be done regarding the education on synthetic turf systems. “We are very disappointed to note that ECHA still relays on unvalidated data when motivating why it is still investigating infill for synthetic turf pitches. Over the past few months the ESTC, and many other organisations, have answered ECHA’s call to participate in the public consultation process regarding a ban on the intentionally use of microplastics. We have submitted extensive and substantiated information on the 5 questions ECHA asked. It appears that this information has largely been ignored as ECHA still uses data which has been proven to be incorrect.”

ESTC’s Technical Director, Alastair Cox, has reached out to ECHA and offered assistance from the ESTC to help ECHA understand how infill is managed in a synthetic turf system.  

Predicting at this point whether there is a future for granular infills in synthetic turf pitches, is premature. “The ESTC is continuously updating ECHA on new developments and trends in the industry that can help in reducing or preventing a possible microplastics problem as well as explaining why a ban on synthetic turf would be counterproductive. Our participation has been acknowledged and is appreciated. Understandingly, ECHA sets the bar very high in stimulating the industry. It’s a challenge that the ESTC and the synthetic turf industry are very eager to meet. A good example was the debate on the amount of polycyclic aromatic hydrocarbon that crumb rubber was allowed to contain. After ECHA initially planned to pursue a very low limit, the industry reviewed its products and procedures to determine whether this could be achieved and proposed a maximum limit of 17mg/kg. It has now been announced that ECHA wants to introduce a limit of 20 mg/kg (0.0020 % by weight of this component) of the sum of the listed eight PAHs. We are confident that, by continuing showing our willingness to participate and assist in the debate, innovate and by continuously advocating best practices, the synthetic turf industry under the leadership of the ESTC and ECHA will once again establish benchmarks that will be acceptable to the market, the industry and the environment collectively.

ESTC DG Stefan Diderich with Eric O'Donnell - Sports Labs

Taking the lead

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Scotland is tackling microplastics pollution head-on and has invited the ESTC to join them in finding solutions to deal with this issue. They couldn’t have wished for a better partner.

Pollution from microplastics affects everybody and everything but has a complicated nature that needs to be treated delicately in order to be solved correctly. According to Scientists at Oxford University, close to 5 billion microplastic particles pollute the world’s oceans’ surface making coastal countries in particular vulnerable to pollution. With a coastline measuring 11,000 kilometres in length, Scotland has been on the receiving end of (plastic) waste transported in currents and drifts for decades. A recent clean-up for research purposes at 16 coastal spots saw over 20,000 pieces of plastic being retrieved, an incredible number considering the mere 48m2 that was cleaned. However, sewage related debris like wet wipes, cotton or bud stems that are found in the Scottish ecosystem all come from people flushing plastic down the toilet. It made the Scottish government realise that the issued needed to be addressed urgently, hence its decision to assemble a forum in late June to help them to draft a framework for implementing adequate measures.

ESTC’s Director General, Stefan Diderich represented the synthetic turf industry from the European, Middle Eastern and African region. ‘Participating in such a debate is the best way to prevent the whole microplastics issue becoming of Loch Ness Monster-sized proportion,’ he says while referring to a monster that has never really been identified nor measured. ‘Plastics and microplastics without any real purpose are a major concern. However, the rubber or plastic infill used in synthetic turf fields form an integral part of the synthetic turf system. They are vital to ensuring a lasting, safe and quality surface for sports and leisure activities. As long as these materials remain within the system they cannot be considered a concern in terms of microplastics pollution. The issue that needs to be dealt with is ensuring that those granules don’t leave the field and enter the environment.’

Numerous solutions

There are numerous solutions to ensuring that the rubber or plastic remains in the field. ‘Buyers of synthetic turf fields have options like kick-boards or other barriers that will prevent the granules from leaving the field while options like brushes, walk-off mats and extended paving around the field can also prevent the granules from going AWOL. Many of these solutions have already proven to be very effective. All it takes is for buyers of a synthetic turf field to accept that these solutions require an increased budget,’ Diderich continues. He points out that the ESTC is actively assisting the European Technical Committee on sports surfaces in drafting a document to create awareness amongst field designers, venue owners, installation companies and those maintaining long pile synthetic turf sports fields about measure to keep the infill inside the field. Budget for these measures doesn’t necessarily have to be excessive. Proper planning and oversight can help to keep it limited. ‘Nowadays, Dutch municipalities expect installing companies to first explain how they will remove and recycle the synthetic turf field as part of the tender process for an installation project. This to ensure that, in the process, no infill will be able to get out of the system. For the city of Amsterdam it has become the norm to wrap the old field in biodegradable plastic before it is loaded onto trucks that remove the old field off-site before they ship it to the recycling company.’ Utrecht municipality even encourages installing companies to recycle old synthetic turf carpets to produce kickboards that can be used to keep infill inside newly installed fields.

One of the partners the ESTC closely works together with in sharing its knowledge is the British Trade Association, the Sports and Play Construction Association (SAPCA). ‘We promote collaboration and innovation to help ensure successful projects for sports and leisure use,’ says SAPCA Project Manager Colin Corline. The organisation’s goal in ‘Building an Active Nation’ is to ensure that every project meets the customer’s expectations, and is designed, built and maintained to last, whilst delivering excellent value for money. SAPCA and the ESTC have joined hands to assist the Scottish government in an ocean pollution initiative. ‘With the debate in Scotland directly affecting our members it is important for us to explain what can be done to tackle the issue locally and to explain to our members what it is the Scottish government intends to do.’

Contributing to a greater cause

The ESTC recently approved the first set of tools and documentation regarding the microplastics issue and how the industry can help to manage it, for distribution amongst its members. The information was also shared with Fidra, a Scottish environmental charity organisation. ‘With feedback provided by ESTC members, we finalised our best practice guidelines outlining simple ways to reduce your microplastic footprint, with different versions tailored for designers and procurement, owners and maintenance staff, and users,’ says Fidra’s Madeleine Berg. She has been delighted by the proactive and open discussions she already has had with the synthetic turf industry through the ESTC. ‘Since the start of the project of addressing microplastics issues within the synthetic turf industry, we have been impressed by the willingness shown by organisations and companies to take the lead in tackling the problem, particularly within the ESTC network. Several companies took the time to review our draft guidelines, which helped to make suggestions more robust. We encourage ESTC to continue leading the way on this issue, helping to ensure best practice is put in place across new and existing pitches to reduce microplastic loss. This way we can increase access to safe play and training areas while minimising impact on the environment.’

Educating the world, informing the industry

Berg points out that Fidra is always looking for more input and feedback on their documentation. She mentions pitch architects and designers specifically as an industry group that is still ‘missing’. These are the same professionals and industries Stefan Diderich is trying to convince to join the ESTC. ‘These professionals are a vital link between buyers of synthetic turf and the synthetic turf industry yet they miss out on valid information,’ he says. ‘It is very unfortunate that is has largely gone unnoticed that the European Chemical Agency (ECHA) uses incorrect information for its proposed ban on intentionally added plastics in synthetic turf systems. This is something the ESTC is passionately trying to rectify and it requires all stakeholders to educate and remind buyers of synthetic turf fields about their role to keep the possibility of microplastics pollution at a minimum.’ According to ECHA synthetic turf fields tend to lose a large amount of infill every year. ‘I beg to differ as the latest and well-engineered third generation synthetic turf systems require much less infill to perform compared to the fields that were introduced at the turn of the century. It is incorrect to believe that if one system design has an issue, this applies to all the synthetic turf fields that are out there. As the latest synthetic turf innovations use performance infill on a performance layer, these systems require 60% less infill. The infill for these systems also has a lesser tendency to compact. That means that possible contribution to the microplastics issue by modern synthetic turf systems is very limited, if it exists at all.’

Ahead of other industries

The ESTC’s key message to the Scottish government was to invest in quality synthetic turf systems and improve the maintenance of these fields. Earlier this year Cameron Watt, the Facilities Manager at the Scottish FA, pointed out that the 350 synthetic turf fields in the country enable 9.7 hours of healthy, physical activity. Banning these fields indiscriminately will have massive implications for Scottish society.

The drafting of a report is now handled by a consultancy company. Testing institute Sports Labs is on hand to provide assistance. ‘It has become evident that the synthetic turf industry is already ahead of the guidance documents currently used to determine the position of each industry,’ Eric O’Donnell of Sports Labs claims. It’s an encouraging message that also requires to be managed correctly. ‘While most companies in Europe and North America have started to accept the debate about possible microplastic pollution from synthetic turf systems in their quest to develop new or better systems, large parts of places like Africa have never been pushed to look beyond the cheapest price when investing in a synthetic turf system. It is essential to invest in educating markets like this if one wants to address the issue of microplastics from synthetic turf systems.’ Madeleine Berg proposes that all parts of the synthetic turf community have a role to play. ‘The government has a role in helping to ensure that guidelines for minimising loss are implemented in all new builds, and that retrofitting fields happens during refurbishments of old fields. Designers can include specifications to reduce microplastic loss, while customers can demand that these specifications are included. But ultimately the industry can lead the way in preventing this issue. Whether that is ensuring that best practice measures are incorporated into design specifications, encouraging innovation in non-infill or organic infill-based systems, or providing training and knowledge-sharing, the industry can provide the expertise that is needed as awareness increases across the rest of the community.’

The ESTC is the industry association for the synthetic turf industry and has the vision to serve as the forum to promote, develop, grow and advocate for the synthetic turf industry. It is the voice of the industry and it aims to fulfil its role by means of close collaboration with all parties involved, be they members, end-users, sports governing bodies or legislators. ‘Assisting the Scottish government in closing the tap on microplastic pollution comes naturally as it serves the interests of the users and buyers as well as the industry,’ says Stefan Diderich. ‘There is an enormous amount of knowledge and experience available within the ESTC and we are certainly keen to assist where possible and to share that freely.’