December 5, 2016
Tracey Crouch
MP
Minister for Sport
4th 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 28th
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
