An Absence of Evidence is not Evidence of Absence: UK efforts to raise awareness continue

December 5, 2016

Tracey Crouch MP

Minister for Sport

4^th Floor

100 Parliament Street

London SW1 2BQ

Dear Tracey,

Re: 3G Crumb Rubber Artificial Pitches

Thank you for your response to Jenny Chapman MP (letters dated25/3/16 and 21/11/16) which I received on 28^th November regarding my concerns over potential links between 3G Crumb Rubber Artificial Pitches and Cancer.

In these letters, you clearly state that the pitches ‘are safe’ and that ‘this is based on the numerous scientific studies conducted by government agencies around the world, and undertaken by independent experts, who have all validated the human and environmental safety of 3G pitches and crumb rubber.’ I believe that such a strongly worded statement defending the safety of these surfaces is at best ill-advised.

I fully understand that you do not have sufficient time to read the literature on the safety of 3G in detail but I would expect you to ensure your civil servants do; given the potential gravity of the concerns and complete lack of answers to the questions of long term exposure. I would hope however, that in the light of the recent Dutch TV documentary by Zembla ( with English subtitles http://zembla.vara.nl/dossier/uitzending/dangerous-play ) and the response by the Dutch Government and Football Clubs, you may take the opportunity to acquaint yourself with these concerns and ask some questions of your department, the FA and indeed Sport England etc.

A subsequent random analysis of 60 3G pitches in Holland, showed high levels of carcinogens and toxins, up to six times higher than would be allowed if it were classified as a consumer product. more than 100 clubs have now decided to ban youth teams from playing on them.  

I have listed below several interesting articles and research into possible links between Crumb Rubber and Cancer. I have also included a paper from WHOs International Agency for Research on Cancer (IARC) into the increased cancer rates (in particular Lymphoma and Leukaemia) of workers in the rubber tyre industry. Here they conclude: 'Occupational exposures in the rubber-manufacturing industry are carcinogenic to humans.' Given this link I do not think it is such a great leap of faith to think that long term exposure to car tyres in the form of Crumb Rubber could be linked in some way to ill health in children who play on this day in and day out.

WHO IARC report into Rubber Industry:

http://monographs.iarc.fr/ENG/Monographs/vol100F/mono100F-36.pdf

Occupational Exposures in the Rubber Manufacturing Industry

36.pd f http://www.ncbi.nlm.nih.gov/pmc/articles/PMC1757501/

Crumb Rubber studies and reports that raise concern by South Lakes Turf. Listed here are several studies that raise concern of the links with the compounds in Crumb Rubber and ill health.

http://southlakesturf.org/?page_id=86

School of Public Health at the University of California identifies a direct link between exposure to Benzene and Lymphoma and concludes there is no safe limit - especially for children.

http://www.lymphomahelp.org/SolventsReportEditedSJO.pdf

Occupational Cancer. Helpful summary of associations between chemicals/industries and cancer:

http://www.haz-map.com/cancer.htm

Mount Sinai, Children's Environmental Health Center. Artificial Turf. A health based consumer guide (Attached).

Center for Environmental Health paper ’A cocktail of artificial chemicals in artificial turf.'

http://www.ceh.org/get-involved/take-action/a-cocktail-of-harmful-chemicals-in-artificial-turf-infill/

US Environment Protection Agency Literature Review 2015:

https://www.epa.gov/chemical-research/tire-crumb-and-synthetic-turf-field-literature-and-report-list-nov-2015

US Paediatricians expressing concern over Crumb Rubber and health risks to children:

http://www.turfgrasssod.org/publisher/hot-topics/2012/12/20/children-and-synthetic-turf-health-experts-discuss-childrens-health-and-artificial-playing-surfaces

Letizia Marseli 2014. Siena University. Release of PAHs and heavy metals in synthetic turf:

https://www.researchgate.net/profile/Letizia_Marsili/publication/275581397_Release_of_Polycyclic_Aromatic_Hydrocarbons_and_Heavy_Metals_from_Rubber_Crump_in_Synthetic_Turf_Fields_Preliminary_Assessment_for_Athletes/links/553fa17b0cf2320416eacd2b.pdf

Extensive research database on synthetic turf with numerous articles/research expressing concerns:

http://www.synturf.org/home.html

Maria Llompart et al. Chemosphere. ‘Hazardous organic chemicals in rubber recycled tire playgrounds and pavers.'

http://www.sciencedirect.com/science/article/pii/S0045653512009848?via%3Dihub

O Ecotextiles article with extensive literature references:

https://oecotextiles.wordpress.com/2014/11/19/another-concern-for-vigilant-parents/

Pitchcare article referencing concerning research into nano particles/carbon black:

https://www.pitchcare.com/magazine/is-artificial-turf-hiding-an-800-pound-gorilla.html

Scientific American article reviewing latest research concerning carbon nanotubes:

http://www.scientificamerican.com/article/carbon-nanotube-danger/

List of studies and research from Toxic Turf:

http://notoxicturf.ca/articles/

It strikes me that there are five key questions – two of which have been answered beyond reasonable doubt and three that we just do not have the answers for. The ones that have been answered are:

1. Does Crumb Rubber contain chemicals known to cause cancer or ill health? Answer Yes.

2. Does it also contain other chemicals that could cause cancer or ill health? Answer Yes.

The three key questions that I do not believe we have the full answers are:

3. Can these chemicals escape from the rubber, either into the air or through skin or ingestion? Unknown.

4. If so are they at sufficiently high levels to cause cancer? Unknown.

5. Is there an increased incidence of cancer in people exposed to crumb rubber when compared to the general population? Unknown.

As is often quoted in these circumstances: ‘An Absence of Evidence is not Evidence of Absence.’

The list of carcinogens that often appear in all components of 3G Pitches is enormous. For example, studies have demonstrated that the following compounds (including known carcinogens) have been found in and around 3G pitches: lead, benzothiazole, polycyclic aromatic hydrocarbons, carbon black, crystalline silica, cadmium, fungicides, pesticides, microbiocides, mercury to name just a few. In regards to lead, we know that there is no safe exposure level for children. Nonetheless, the industry openly admits that lead remains in its products. It should be noted that many carcinogens are known to have synergistic interactions, thereby exponentially increasing one’s risk of developing cancer, as opposed to being exposed to a single carcinogen.

 The study undertaken in Holland (Joost G.M.van Rooij et al 2010) which looked at levels of toxins in urine of football players and is the only current study that investigates actual uptake in the body and is widely used by the FA and Sport England, has been thoroughly discredited by experts.

My son Lewis (who was on trials at Leeds United at the time of first diagnosis in 2013) played two to three times a week on 3G Pitches as a goalkeeper.  Particularly during training sessions, he would be exposed to the Crumb Rubber in a number of ways. This included breathing in vapours (particularly on warmer days), swallowing the granules on a frequent basis, smaller particles getting in his eyes and exposure through cuts and grazes (which carry a high risk on these surfaces). From birth and throughout adolescents it is widely recognised that children have a higher risk from exposure to toxins and carcinogens and it is this that I am most concerned about. You may be aware of the register that Amy Griffin (former US Goalkeeper and currently coach at Washington State University) has kept for a few years. This register has in excess of 150 soccer players who were diagnosed with cancer/leukaemia and played regularly on 3G pitches. The striking observation however is that more than a hundred were goalkeepers. It is this close and regular contact with the surface that concerns me the most and at a very minimum should stop forthwith.

Sadly, what I see unfolding, here in the UK, bears striking similarities to previous health related catastrophes including tobacco, asbestos, thalidomide etc. whereby deceptive market practices, industry funded junk science  put profit and reputation before consumer health and safety. Fortunately, as I am sure you will be aware, in the US the Consumer Product Safety Commission (CPSC), Environmental Protection Agency (EPA) and Center for Disease Control (CDC) are currently investigating the toxicity of 3G pitches and are due to report preliminary finding early next year. In addition, The European Chemicals Agency (ECHI) are undertaking a research and literature review and the Dutch Minister for Health, Welfare and Sport has commissioned the Dutch National Institute for Public Health to undertake a review. Unfortunately, we may not know for several years, or indeed decades, whether there is a causal link between 3G Pitches and cancers; as this can realistically only be done through epidemiological studies.

Consequently, given what we know about the toxic chemicals and carcinogens in Crumb Rubber and the absence of hard data I would urge you as Minister for Sport to consider the precautionary principle to the growing concerns over the possible links to ill health and consider the following:

1.     Have an immediate moratorium on the building of 3G Crumb Rubber Artificial Pitches.

2.     Commission Public Health England to work closely with the Dutch authorities and undertake a review of all current research and literature and conduct a risk assessment.

3.     Issue guidelines for sports governing bodies to minimise potential risks of exposure. For example, by restricting time spent by goalkeepers training and ensuring children shower immediately after playing.

As recently quoted by James Ferraro (The Ferraro Law Firm in the US) in his letter (dated 1/12/16), to educational authorities in Martha’s Vineyard and writing in his capacity as a concerned local resident:

“Throughout my experience in mass tort litigation, I often wonder: what if the industry players (manufacturers and premise owners) could step back in time and reassess their decisions to purchase and/or use toxic substances (i.e.asbestos)? For synthetic turf industry participants that time is right now.”

 I sincerely hope that you give this matter your full consideration and take the time to at the very least watch the Dutch documentary before you respond to this letter.

Thank you for your time. I look forward to hearing from you.

Sincerely,

Nigel Maguire

cc. Jenny Chapman MP