ECHA

In July 2018, the Netherlands submitted a proposal to ECHA recommending to lower the legal concentration limits under REACH for eight polycyclic aromatic hydrocarbons (PAHs) found in granules and mulches. These granules and mulches are commonly used on sports pitches and in playgrounds, but there is a concern that they contain chemicals (such as PAHs) that may cause health risks. Let’s take a deeper look at what is being proposed and the implications of restricting the PAHs.

A short recap

ECHA first looked at this topic back in 2017 and, at that point, found that the health concerns of the granules used on pitches were very low due to the small concentrations of concerning chemicals measured, including metals, plasticisers and PAHs.

However, our report also mentioned some uncertainties. For instance, there was a general concern over whether the studies used were representative for the whole of Europe given that samples were not taken from all Member States.

Due to these reservations, we suggested a number of actions that could be taken, including whether a restriction should be considered under REACH so that the granules could only be supplied with very low concentrations of PAHs and other relevant hazardous substances. These findings were sent to the European Commission on 28 February 2017.

What is being done to address the uncertainties?

At the same time, the Dutch National Institute for Public Health and Environment (RIVM) also published a study on the health risks of rubber granules in use in the Netherlands. RIVM’s findings echoed those of ECHA’s report, stating that playing sports on these pitches was safe.

However, the Dutch study also reiterated the uncertainties mentioned in ECHA’s report and recommended to lower the concentration limits of PAHs in granules to protect the health of those who come into contact with them.

On 30 June 2017, RIVM followed this suggestion up by announcing its intention to prepare a proposal to restrict eight PAHs used in granules and mulches in synthetic turf pitches, at sports facilities and on playgrounds. The proposal was submitted to ECHA on 20 July 2018 and was made publicly available on 16 August 2018.

What does the restriction propose?

The Netherlands’ proposal looks at the health risks for footballers (including goalkeepers), children playing on the pitches or at playgrounds, and workers installing and maintaining such surfaces.

The eight PAHs restricted in granules and mulches are known or presumed to cause cancer in humans. They have a harmonised classification as carcinogenic (category 1B) under the CLP Regulation. The proposal outlines that the currently permitted concentration levels – 100 mg/kg for two PAHs (BaP and DBAhA) and 1 000 mg/kg for the other six – in entry 28 of Annex XVII of REACH makes it difficult to ensure that health risks are controlled.

These limits are seen as not protective enough, as the excess cancer risk following lifelong exposure to the granules would be too high.

Therefore, RIVM is proposing to restrict the placing on the market and use of granules or mulches that contain a combined concentration for the eight carcinogenic PAHs of more than 17 mg/kg.

Why is this restriction being proposed?

In the Netherland’s view, reducing the concentration limit for the eight PAHs will be an affordable and proportionate measure for society as it will ensure that:

• too high PAH concentrations and their risks will be avoided for those who come into contact with the granules during sport or play;
• societal concern related to human health effects may reduce over a 10-year period as high PAH concentrations are avoided;
• no major administrative burdens on public authorities in terms of cost for implementation, monitoring, inspection and enforcement are expected; and
• costs to society will be affordable and relatively limited.

What are the next steps?

ECHA's committees are checking the conformity of RIVM’s proposal and a public consultation is expected to begin later in September 2018.

If you are an interested party, you will have six months from that date to comment on the proposed restriction and its anticipated impacts. Have your say!

ECHA committees will evaluate the dossier and formulate their opinions. ECHA’s Committee for Risk Assessment (RAC) will adopt its opinion in July 2019.

The Committee for Socio-economic Analysis (SEAC) will give its expert opinion on the proposal by September 2019, taking into account the submitted information.

The opinions of both committees will be submitted to the European Commission. The final decision is to be taken in a comitology procedure with scrutiny involving the Member States and the European Parliament.

ECHA will continue to look at the health impacts of other substances contained in the granules and mulches derived from end-of-life tyres (ELTs). There may also be further investigations into environmental effects, too.

This is expected to lead to the publication of an intention to restrict other substances in ELTs in early 2019.

Did you know?    Granules (often made from rubber) used as infill material for sports pitches are mainly made from scrap end-of-life tyres. These are broken up and ground down to form the granules. The granules are used on synthetic sports pitches to make them more durable, weather-proof and last longer. They also add shock absorption and traction.   Rubber mulches are also predominantly produced from end-of-life tyre buffings and nuggets and have a wide range of uses in the EU. It is believed that about 60 % of rubber mulch ends up being used in playgrounds, but it is also used in landscaping, gardens, golf courses, horse arena footings and athletic arenas. Playground surfaces often use loose granules and mulches underneath swings, slides and other playground equipment to cushion the ground if a child falls.

Further information:

Are artificial football pitches safe?, Chemicals in our Life

Hot topics: granules and mulches on sports pitches and playgrounds

Text by Paul Trouth

Published on: 13 September 2018
Updated on: 20 September 2018 to change the date of the expected publication of an intention to restrict other substances in ELTs.

Top image: istock.com/nycshooter

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