ESTC Issues Statement on the European Chemical Agency's Recommended Limit for PAH

The European Chemical Agency’s committees for Risk Assessment (RAC) and Socio-economic Analysis (SEAC) have recently published their recommended limit for PAH content of infill materials used within synthetic turf sports fields.   ESTC are pleased to be able to advise that they are proposing a limit of 20 mg/kg (0.0020 % by weight of this component) of the sum of the listed eight PAHs. This is good news in that it means that infill sourced from (EU compliant) end of life tyres can continue to be used as an infill material.  Copies of the RAC & SEAC report and supporting information can be downloaded from https://echa.europa.eu/registry-of-restriction-intentions/-/dislist/details/0b0236e181d5746d

ECHA are currently holding the statutory consultation period on the RAC & SEAC report.  ESTC are advised that even though the proposals are in line with what we advocated it is always good to make positive and supportive comments to counter any differing views registered.  Comments can be made on-line at https://comments.echa.europa.eu/comments_cms/SEACDraftOpinion.aspx?RObjectId=0b0236e182b0b6d2.  ESTC has commented as follows and you are welcome to cut and paste or endorse our comments:

The European Synthetic Turf Council (ESTC) is a non-profit trade association representing European based companies manufacturing synthetic turf surfaces and the components used to form the surfaces and companies that install and maintain synthetic turf surfaces.  Members also include sports federations that use synthetic turf surfaces.   At present ESTO has 80 members and further details may be found at https://www.estc.info

ESTC welcomes and supports the proposal of the Committee for Risk Assessment (RAC) and Committee for Socio-economic Analysis (SEAC), as detailed in their Opinion Report dated 14 June 2019, that granules (or mulches) shall not be placed on the market for use as infill material in synthetic turf pitches or in loose form on playgrounds and in sport applications if these materials contain more than 20 mg/kg (0.0020 % by weight of this component) of the sum of the listed PAHs.

Based on all of the scientific data we have seen, including the very comprehensive study recently completed by the European Risk Assessment Study on Synthetic Turf Rubber Infill (ERASSTRI ) project, ESTC believes the proposed restriction is appropriate and proportional in terms of protecting and reassuring the users of synthetic turf fields, whilst at the same time, not causing unnecessary concerns and problems to the operators of the many thousands of synthetic turf fields across Europe, that could occur if a restriction was introduced that excluded end of life tyre infill from the European market.   The data available from our members and from the ERASSTRI study shows that vast majority of European producers of synthetic turf infill materials are already supplying materials that are achieving the proposed restriction limit, which is due to them taking a proactively responsible approach and only using REACH compliant tyres as their feedstock.   The proposed restriction will therefore allow the sustainable disposal of European produced tyres to continue in a way that provides a cost effective and durable infill material. 

We would like to restate that in our opinion, ensuring there is a reliable test method with proven reproducibility and repeatability is essential for any REACH restriction to achieve its objective of keeping unacceptable materials out of the supply chain.  At present different laboratories or national restrictions are using a variety of test methods to determine the PAH content of infills and experience is showing that different test methods give different results and the reproducibility of some methods is unacceptably poor. At present we believe the German test method AFPS GS2014:01 PAK2 is most commonly being used.  

We also note the report mentions sampling of infill and we agree with the need for this to be undertaken in a consistent and representative way.   ELT derived infills do not have a homogeneous chemical composition as the feedstock from which they are produced are not homogenous tyre to tyre, or even across a single tyre as each layer has a specific technical function This means a sample lot of granulate could have a variety of different chemical compositions and as the sample specimen required for chemical analysis is very small, ensuing the sample is statically representative of the sample lot is very important.  Recognising the need for an internationally harmonized protocol for the collection of infill samples from production or from site during the construction of a sports field or from existing fields, a Code of Practice  for the sampling and preparation of infill for chemical analysis is being prepared by CEN TC 217 WG6, TG1.    The draft is currently available for public comment and it is hoped the European Standard will be published in early 2020.  We encourage REACH to refer to this document in the new Restriction.

Whilst the news on the PAH restriction is currently good, the industry is still faced with the potentially much bigger issue of REACH classifying polymeric infills as microplastics and their use being banned from 2021. The first, and most important public consultation on this topic is still open (till mid-September).  ESTC is of the view that this ban will adversely affect all members one way or another (infill this week – fibre and yarns next?).  Therefore, we re-emphasise the request that all members companies find time to study the proposed restriction, comment and answer the questions specifically asked of industry.   ESTC has already responded and will be providing further information. 

Regards

Alastair Cox
ESTC Technical Director

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ESTC – EMEA Synthetic Turf Council
40, rue Belliard - 1040 Brussels
Tel. +0044 7985 286787
Web : www.estc.info