The CLF testimony on artificial turf and PFAS that the Burrillville Town Council did not make public

Council President Donald Fox carefully curated public comment to ensure his narrative prevailed.

The Conservation Law Foundation (CLF) sent carefully researched comments on the Town of Burrillville’s plan to install artificial turf at the Burrillville High School athletic field. Some residents were worried about the presence of PFAS, known as forever chemicals, in the artificial turf and the possibility that the chemicals might leach into the town’s aquifers. At a recent Special Town Council meeting, these worries were dismissed by the Town Council President, Donald Fox and the Council decided to move ahead with the project.

The following comments were received by the Town Council, but as of the special meeting, were not included on the portion of the Town’s website dedicated to informing Burrillville residents about the Artificial Turf project. Furthermore, Council President Fox was adamant about preventing people who did not live in Burrillville from speaking at the special meeting, preventing the CLF from presenting their research during public comment. Council President Fox read only one piece of public comment at the special meeting, a public comment that supported the artifical turf project.

See previous coverage here:

• Burrillville residents battling Town Council over forever chemicals in artificial turf

• Burrillville Town Council rolling the dice on artificial turf and PFAS, gambling the town's water, health, and future

Here’s the letter:

Conservation Law Foundation (CLF) appreciates the opportunity to submit the following comments regarding the proposed artificial turf field at Burrillville High School. 

Founded in 1966, CLF is a nonprofit, member-supported, regional environmental organization working to conserve natural resources, protect public health, and promote thriving communities for all in the New England region. CLF protects New England’s environment for the benefit of all people. We use the law, science, and markets to create solutions that preserve our natural resources, build healthy communities, and sustain a vibrant economy. CLF has been a leading advocate for clean, safe drinking water in Rhode Island and throughout New England and is engaged in numerous efforts to address the threat of emerging contaminants, including PFAS, throughout New England.

Overview

On April 12, 2023, the Burrillville Town Council adopted a Capital Improvement Plan that includes an artificial turf field at Burrillville High School (Artificial Turf Project). On December 4, 2023, the Town of Burrillville entered into a 14-page (including schedules) Sales Agreement with FieldTurf USA, Inc. for FieldTurf to sell to the Town and install at Burrillville High School an artificial in-filled playing surface identified as FieldTurfFTVTP-1, 2.5 inches thick outdoor all green artificial grass in-filled playing surface measuring approximately 88,000 square feet (Artificial Turf Field). According to the Sales Agreement, the purchase price of the “fully installed” Artificial Turf Field is $3,167,235.00. According to Schedule B of the Sales Agreement, the infill of FieldTurfFTVTP-1 includes 3.0 pounds of cryogenic rubber per square foot. In the time since the adoption of the Capital Improvement Plan, a number of Burrillville residents have expressed concerns about the project, including risks posed by the chemicals contained in the Artificial Turf Field.

Over the last two months, CLF has reviewed materials posted on-line by the Town about the Artificial Turf Project, the correspondence from the Rhode Island Department of Health and the Rhode Island Department of Environmental Management to the Town of Burrillville, comment letters from other advocacy organizations, and various news stories reporting on the Artificial Turf Project. Most of the discussion and data have been focused on PFAS chemicals contained in FieldTurfFTVTP-1 and their potential to contaminate the surrounding environment and local water supply. Testimony from Elizabeth Denly, Vice President, PFAS Leader & Chemistry Director for TRC (the environmental consultant hired by the Town of Burrillville), is primarily focused on issues related to PFAS. In her testimony, Ms. Denly notes that “there were no statements made about the environmental benefits of this product.”¹ In fact, Ms. Denly doesn’t make any statements about any other environmental issues related to the product in her testimony. CLF will address the issue of PFAS as well as the other health and environmental issues related to this product in this comment letter.

Per- and Polyfluoroalkyl Substances (PFAS)

PFAS are a dangerous and ubiquitous class of chemicals that includes thousands of related compounds. PFAS have been described as a public health “perfect storm.” They are a class of chemicals that are extremely persistent in the environment and in our bloodstreams, highly mobile in water, and toxic in tiny amounts. They are also pervasive. First developed in the 1950s, today PFAS can be found in everyday products including nonstick cookware, water-repellent clothing, stain-resistant fabrics and carpets, firefighting foam, food packaging, and artificial turf.

PFAS are toxic to humans in very small concentrations and pose a wide range of health threats. They are suspected of causing cancer and have been linked to growth, learning, and behavioral problems in infants and children. They can also cause problems with fertility and pregnancy; compromise immune systems; and interfere with natural hormones and with liver, thyroid, and pancreatic function. Developing fetuses and newborn babies are particularly vulnerable to PFAS.

In its master list of PFAS substances, the United States Environmental Protection Agency (EPA) states that: “PFAS represent a growing, increasingly diverse inventory of chemicals of interest to the general public, scientific researchers, and regulatory agencies worldwide” noting that “[t]his PFAS Master List will continue to expand as component lists grow.² In fact, the list of PFAS compounds has grown so much that the EPA retired the PFAS Master List and replaced it with two separate lists.³ Together, these two lists now include 16,650 separate chemicals. It wasn’t until April 10, 2024, that the EPA finally set Maximum Contaminant Levels (MCL) for six PFAS compounds. The EPA also set Maximum Contaminant Level Goals (MCLG) for these six PFAS compounds. MCLG is defined as “[t]he level of a contaminant in drinking water below which there is no known or expected risk to health and allows for an adequate margin of safety.”⁴

Two of these six [PFOA and PFOS] have an MCLG of zero.⁵ However, the MCL for PFOA and PFOS is set at 4.0 ppt. Since the EPA treats the MCL as the “enforceable standard,” this is the standard FieldTurf bases its scientific analysis. Because PFOA and PFOS are only two of the best-known of thousands of PFAS compounds, it is deceptively simple for a company such as FieldTurf to claim that its products are technically “PFOA and PFOS Free” without addressing the broader class of compounds. Moreover, since less than 1% of PFAS are typically analyzed, never mind regulated, FieldTurf can and does make the argument that based on available data, its product is PFAS “safe.”

The real question is - what is an acceptable level? Some states, including Rhode Island, have now enacted outright bans on PFAS in many products. Of course, the devil is in the details.⁶ Importantly, “many experts argue for approaching PFAS as a class of chemicals — as in assuming that less studied members of the chemical family may have health and environmental impacts akin to those that have been better researched and making decisions around their use accordingly.”⁷ The cumulative effects of all PFAS substances in a product should guide our assessment of the product’s dangers.

A review of toxic tort litigation in the United States reveals a sinister pattern. From asbestos and lead tainted paint to DDT and PCB – “too good to be true” chemicals and substances have been introduced to American consumers over the years and have made some companies and individuals extremely wealthy. Years after these chemicals and substances have been widely adopted and become common place, disturbing reports of terrible health problems associated with the use of these chemicals and substances begin to emerge. At first, these reports are easily refuted (and financial liability deflected) by “experts” pointing out inconsistencies in testing methods, faulty data, compromised samples, inability to link an adverse health impact to a particular product, etc. Eventually, the rapid growth in the number of reports and amount of validated scientific research providing clear causal links prove overwhelming to the legal barricades that were constructed and the floodgates holding back financial liability come crashing down. Of course, any financial recovery obtained does very little to repair the damage done and does nothing to restore the lives lost. Sadly, the claims about these products weren’t true and the end results from their use weren’t good.

The rise and ubiquitous use of PFAS fits this patten all too well. The Town of Burrillville has received the latest reports about the numerous health problems associated with PFAS and knows about the gaping void in research and understanding that needs to be filled.⁸ Furthermore, some Burrillville residents have already been exposed to PFAS contamination.⁹ The residents of Burrillville should have the final say about how this story ends.

Cryogenic Rubber (Crumb Rubber)

How Much Crumb Rubber and What’s It Made Of? “A typical football field utilizes crumb rubber infill from as many as 40,000 recycled tires (100-120 tons). Tires are made from some very toxic chemicals, including the known carcinogens arsenic, benzene, carbon black (which makes up to 40% of a tire), 1,3 butadiene, TCE, and cadmium, as well as neurotoxins, lead and mercury. Crumb rubber dust and small pieces are easily inhaled or swallowed as they become disturbed during gameplay.”¹⁰

Increased Injuries? “Statistics show that injuries are more common on synthetic turf surfaces, especially those that are not constantly maintained for resiliency. The G-max rating - the ability to absorb impact - changes as the materials are compacted, often leaving an unsafe, harder surface that makes injuries more likely and more severe. Common injuries include joint trauma (especially ankles and knees), concussions, “turf toe,” and unusually large skin abrasions which are more prone to infection. These are some of the reasons that the majority of professional athletes prefer natural grass.”¹¹

Heat Island? “Studies from Brigham Young University showed that synthetic turf averaged 37 degrees hotter than asphalt and 86.5 degrees hotter that natural grass. On a hot sunny day, synthetic fields can reach a temperature of 180-200 degrees. Dehydration, heat stroke and other serious heat-related illnesses and second degree burns occurring on the soles of the feet of athletes have spurred turf manufacturers to sell water cannons for cooling the fields, even though the water only reduces the temperature for about 20 minutes, at which time the process has to be repeated. Heat also increases the outgassing of volatile chemicals, which makes them more problematic as an inhalation exposure.”¹²

Health Effects on Young Children? “Young children are especially vulnerable to toxic exposures from synthetic turf due to their play habits close to the ground and typical hand-to-mouth behaviors. Due to their small size, they receive proportionally greater doses of chemical contaminants than adults, and their immature organs and developing bodies make it more challenging for them to detoxify or eliminate certain toxins. Toxic substances in the crumb rubber can be inhaled, absorbed through the skin, or accidentally ingested.”¹³

Antidotal Reports of High Incidences of Cancer? “[T]here is a growing number of reports of higher than usual cases of lymphoma and leukemia among athletes playing on synthetic turf, especially soccer goalies, who regularly dive onto the turf, releasing dust and infill particles. To date, no studies have been conducted to confirm a link, but common sense tells us that chemicals in tires that are linked to cancer should be avoided.”¹⁴ In this regard, “the evidence collected to date indicates a basis for concern and an urgent need for closer scrutiny. Most notable is that the ratio of lymphomas and leukemia is the reverse of that expected in the general population for that age group. Such a reverse in the pattern of cancers present is considered a signal that an active chemical carcinogen is present. Given the high stakes, it is prudent to take action to protect children from this known hazard rather than wait for definitive evidence of harm.”¹⁵

Artificial Turf’s Plastic Problem

“The term “turf” is misleading. This material has no relationship to actual turf or grass. It is basically a scrap chemical product.”¹⁶

“Several parts of an artificial turf system generate plastic pollution as the product degrades over time. Rubber or plastic particles migrate off the artificial turf area and into surrounding areas; parents and residents living near artificial turf fields have collected photographic evidence of waste tire particles dispersed in wetlands and filling storm drains. As plastics continue to break down in the environment, they can contribute to microplastic pollution.

Microplastics are a source of growing concern in the scientific community, with evidence of their presence in babies’ feces and even in breast milk. A recent review of the scientific literature by the California State Policy Evidence Consortium concluded that ‘microplastics are suspected to promote deleterious human health effects in the reproductive and digestive systems,’ among other human health concerns. 

Plastic grass blades pollute water resources and gradually break down into increasingly small pieces. A recent study examined the sources of plastic debris found in seawater off the coast of Barcelona. Artificial grass fibers ‘accounted for 15 percent of plastic pieces larger than 5 millimeters in the samples from within 1 kilometer of the shore,’ according to a summary of the study in New Scientist. ‘The authors identify artificial turf as “a major source of plastic pollution in the aquatic environment.’”¹⁷

Artificial turf fields generally last for about a decade. After this point the turf – tens of thousands of pounds of material per field – must to be disposed of and replaced. Artificial turf cannot be recycled therefore it must be disposed of in a landfill.

Conclusion

Based upon the research conducted and the findings presented in this comment letter, CLF believes that there are a number of serious potential health and environmental harms associated with the Artificial Turf Project.

CLF understands that Burrillville has already spent, and may be liable for, a considerable amount of money that will not be recoverable. However, throwing good money after bad is never a sound fiscal decision.

CLF respectfully recommends that the residents of Burrillville require Burrillville to change course and invest in an organically managed natural grass field at BHS.¹⁸

Sincerely,

Richard Stang

Senior Attorney

Conservation Law Foundation

1. Questions with Answers from Elizabeth Denly, TRC; https://www.burrillville.org/sites/g/files/vyhlif2886/f/uploads/questions_answers.pdf.

2.  PFAS Master List of PFAS Substances (RETIRED); https://comptox.epa.gov/dashboard/chemical-lists/pfasmaster.

3. Navigation Panel to PFAS Structure Lists; https://comptox.epa.gov/dashboard/chemical-lists/PFASSTRUCT, and PFAS|EPA PFAS chemicals without explicit structures; https://comptox.epa.gov/dashboard/chemical-lists/PFASDEV.

4. PFAS National Primary Drinking Water Regulation - FAQs for Drinking Water Primacy Agencies; https://www.epa.gov/system/files/documents/2024-04/pfas-npdwr_fact-sheet_general_4.9.24v1.pdf.

5.  Id.; see also, PFAS ‘forever chemicals’: Why EPA set federal drinking water limits for these health-harming contaminants, The Conversation, April 10, 2024; https://theconversation.com/pfas-forever-chemicals-why-epa-set-federal-drinking-water-limits-for-these-health-harming-contaminants-227621.

6. States that regulate PFAS in drinking water, Safer States, May 2023; https://images.theconversation.com/files/528650/original/file-20230526-27-z9wg9e.png.

7. Why getting PFAS out of our products is so hard — and why it matters, PBS News: September 22, 2022 – Updated on March 14, 2023; https://www.pbs.org/newshour/science/pfas-are-everywhere-what-can-we-do-to-change-that.

8. Synthetic Turf – Industry’s Claims Versus the Science (A Careful Analysis of Studies that Industry Uses to Justify Safety Claims), Environment & Human Health, Inc., 2017; https://www.ehhi.org/NewTurf_Final.pdf.

9. ‘Just the Tip of the Iceberg’: New PFAS Drinking Water Standards in R.I. Go a Long Way, but Target Only One Part of Complicated Issue, EcoRI: October 10, 2022; https://ecori.org/just-the-tip-of-the-iceberg-new-pfas-drinking-water-standards-in-r-i-go-a-long-way-but-target-only-one-part-of-complicated-issue/.

10. Synthetic Turf, Grassroots Environmental Education; https://www.grassrootsinfo.org/synthetic-turf. See also: Synthetic Turf Contains Known Carcinogens; https://www.safehealthyplayingfields.org/toxicity-carcinogens; and Global evaluation of the chemical hazard of recycled tire crumb rubber employed on worldwide synthetic turf football pitches, March 22, 2022; https://www.sciencedirect.com/science/article/pii/S0048969721076208.

11. Id.

12. Id.

13. Id. See also, Emerging Health Risks of Crumb Rubber: Inhalation of Environmentally Persistent Free Radicals via Saliva During Artificial Turf Activities, December 4, 2023; https://pubs.acs.org/doi/10.1021/acs.est.3c03278.

14. Id.

15. Human Health Experiment on Children to Determine Cancer Connection to Synthetic Turf Field Use – November 19, 2015; https://www.safehealthyplayingfields.org/the-cancer-question/2016/10/19/human-health-experiment-on-children-to-determine-cancer-connection-to-synthetic-turf-field-use.

16. Playing on Plastic: Artificial Turf Hazards and Safer Alternatives, August 21, 2023; https://www.healthandenvironment.org/join-us/blog/playing-on-plastic-artificial-turf-hazards-and-safer-alternatives.

17. Id.

18. Athletic Playing Fields: Choosing Safer Options for Health and the Environment, Toxic Use Reduction Institute, December 2018 – updated April 2019; https://www.turi.org/publications/athletic-playing-fields/.