BRUSSELS—A European proposal to restrict polycyclic aromatic hydrocarbons in crumb rubber synthetic turf needs several major changes to be effective, the European Tyre and Rubber Manufacturers' Association has told the European Chemicals Agency.
"There is not, at this stage, a reliable and replicable standard method to measure PAH content in rubber matrices," ETRMA said in July 2019 comments to the ECHA on its PAH restriction proposal.
The ECHA's Committee for Socio-Economic Analysis urged adoption of a proposal from the Netherlands, covering eight PAHs found in rubber granules and mulches used in synthetic turf fields, playgrounds and other sports facilities.
"SEAC concluded that the proposed restriction is the most appropriate (European Union)-wide measure to address the identified risks," the ECHA's Committee for Risk Assessment (RAC) said in a June 18 news release, noting that it had adopted the draft opinion.
On June 19, the RAC gave the public 60 days to comment on adoption of the draft opinion.
In answering the RAC, ETRMA quoted its own study, "European Risk Assessment Study on Synthetic Rubber Turf Infill." ETRMA co-sponsored the study with the Crumb Rubber Industry Platform, whose members include the European Synthetic Turf Field Organization, as well as other stakeholders in the synthetic turf and crumb rubber industries.
Of the 67 samples of rubber granules taken in the study, all but one were below the proposed PAH threshold of 20 milligrams per kilogram, the ETRMA said in its comments.
Besides the lack of reliable testing, the cost also is a problem, according to the ETRMA.
While the specific cost of sampling and analysis depends largely on the arrangement between the recycler and the service provider, the cost of the samples in the study ranged from 500 to 1,000 euros apiece, the association said.
Members of CRIP, however, said that cost, with the right agreements with laboratories, could be reduced to 60 euros.
"The restriction proposal should indicate the PAH test method to be used for the measurement of the PAH content," ETRMA said. "In parallel, authorities should work toward introducing an internationally harmonized standard for measuring PAH."
Rubber granules derived from end-of-life tires also do not have homogeneous chemical composition, according to the ETRMA.
"Collection of samples from infill facilities also requires a standardized way to collect a homogeneous and representative samples (sic)," it said.