Washington, DC —The Consumer Product Safety Commission (CPSC) should require artificial turf sold for use in playgrounds and day-care centers to be lead-free, a standard which would outlaw the commonly used fill of shredded tires or mulch rubber, according to a formal rule-making petition filed today by Public Employees for Environmental Responsibility (PEER). The petition asks CPSC to regulate these synthetic turf products as “children’s products” which carry legally mandated strict lead exposure limits.
In response to an earlier request by PEER, CPSC General Counsel Cheryl Falvey issued an advisory opinion on treating recycled tire products as a children’s product. That opinion cited other possible uses, such as landscaping and equestrian arenas, which do not primarily target children but concluded that –
“Rubber mulch manufactured by a company that markets, advertises and promotes its product as principally for use in surfacing playgrounds would, in most instances, be considered a children’s product…”
In its petition, PEER details evidence that several companies market their tire crumb turf products specifically and primarily for use by children, including –
- Come-On Pitches, with promotional claims such as “Offer your children that extra margin of safety”, “softer on little knees”, “protecting children from playground bumps and bruises”, “Makes playgrounds safe and fun”, “ Invest in the safety of your playground today!” “designed for high-impact areas such as swings and slides” “keep kids safe no matter what the activity” and “unique rubber granule designed specifically to make playgrounds safer for children of all ages”;
- Product Names such as “Play Tuff Tiles”, “PlayBound TurfTop”, “Swing Mats”, “Playground Rubber Mulch” “PlaySafer” and “playground safety surfacing”; and
- Company Names like TotTurf and KidWise Outdoor Products, as well as subsidiaries dedicated to reaching playground, day-care and school markets.
“How can something called TotTurf not be a children’s product?” asked PEER Executive Director Jeff Ruch, pointing out another company claims its shredded tire pellets are safe for children even when “swallowed.” “It did not require much digging to amass ample unmistakable proof that these companies are pushing these products mainly for use by kids.”
PEER is also pressing CPSC to withdraw its own safety endorsement for synthetic turf due to a growing body of studies documenting chemical exposure and other risks. PEER’s complaint that this official endorsement violated a federal law requiring reliance on best available science is still pending.
“Used tires are nasty disposal nightmares but shredding them does not make them any less nasty, in fact it makes the mix of metals and chemicals they contain more accessible to the environment and the people who come into contact with them,” Ruch added, noting that a synthetic turf field may contain as many as 120 tons of crumb rubber from more than 25,000 shredded tires. “The Commission already considers playground equipment, such as slides, to be children’s products and should regulate the synthetic material the child lands in at the bottom of the slide in the same way.”