NCHR Comments on CPSC Agenda and Priorities for FY2018-2019

Diana Zuckerman, PhD, National Center for Health Research: July 26, 2017


Diana Zuckerman, PhD, President of National Center for Health Research 
Comments on the U.S. Consumer Product Safety Commission 
Agenda and Priorities for FY2018/2019

The National Center for Health Research is a nonprofit research center staffed by scientists, medical professionals, and health experts who analyze and review research on a range of health issues. Thank you for the opportunity to share our views concerning the Consumer Product Safety Commission’s (CPSC) priorities for fiscal year 2018 and 2019. We respect the essential role of the CPSC, as well as the challenges you face in selecting the most important priorities.

Two priorities that are clearly consistent with CPSC priorities are the safety of children’s products. We are very concerned about exposures to phthalates in children’s toys and other products as well as endocrine-disrupting chemicals and other safety concerns related to recycled tire crumb rubber and other artificial turf (including “poured in place” surfaces).

The CPSC has been a champion for children with its careful analysis of phthalates in toys and products for children under 3 years of age. As you know, products specifically for children under 3 are not the only ones that pose risks: we need to also be concerned about phthalates in many products used by pregnant women and children. Through dust and other means, phthalates migrate from many products into our environment and bodies. Phthalate metabolites are detectable in nearly all people in this room and in the U.S.[1] Many phthalates are endocrine disruptors that can have long-term effects on our health and children’s development, including their ability to learn.

Our Center was instrumental in shaping the law resulting in permanent and temporary bans on six phthalates in children’s toys and child care articles.[2] However, these bans need to be expanded. Over 2 years ago, CPSC proposed the rule “Prohibition of Children’s Toys and Child Care Articles Containing Specified Phthalates” following the Chronic Hazard Advisory Panel (CHAP).[3][4] This rule is absolutely essential in providing additional protections for children.

We support the permanent bans on four additional phthalates (DIBP, DPENP, DHEXP, and DCHP) and making permanent the interim ban on DINP.[3] However, the CHAP report also recommended an interim ban on DIOP, which should also be included in the rule. We strongly disagree with the proposal to lift the interim bans on DNOP and DIDP. While they may not affect male hormones, they are associated with organ toxicity and altered development.

The CHAP report also recommended additional studies on three other phthalates (DMP, DPHP, and DEP) and six phthalate alternatives.[4] The final rule should include a timeline for the completion of these studies that reflects the potential damage these phthalates can cause.

It is also important for CPSC to expand its work on phthalates to include products that can cause prenatal exposures as well as those that can harm older children and other vulnerable adults. Phthalate exposure has been found to increase risk for early puberty and problems with reproduction.[5][6][7] This is especially important because a new meta-analysis of 185 studies shows that male sperm counts are less than half what they were just a generation ago.[8]  Phthalate exposure also affects pregnant and breastfeeding women and thus their children, which can affect brain and reproductive system.[4][9] Phthalates in household dust can be extremely harmful regardless of what products it comes from.

Artificial turf made with recycled tire crumb rubber and other products raises similar issues because it is widely used and can release chemicals that affect the health of children of all ages, pregnant women, and other adults. Artificial turf is currently used on more than 12,000 athletic fields and numerous playgrounds in the U.S. and most parents are unaware of the risks it poses.[10]

Scientific evidence suggests that crumb rubber, “poured in place” (PIP) rubber and other artificial turf pose potential safety hazards when used on playground and playing field surfaces. Rubber from recycled tires and even from “virgin tires” and “virgin rubber products” is not comprised only of rubber from a rubber plant.  Instead it includes phthalates, polycyclic aromatic hydrocarbons (PAHs), volatile organic compounds (VOCs), heavy metals, and other chemicals known or suspected to harm human health.[11][12][13][14] In addition to disrupting hormones, some PAHs may increase a person’s chance of developing cancer.[15][16] While one time or sporadic exposures are unlikely to cause long-term harm, repeated exposures over years, especially during critical developmental periods clearly raise the likelihood of harm.

Artificial turf made with crumb rubber and poured rubber products can also cause short-term harms. For example, crumb rubber generates dust which may exacerbate asthma for children.[17][18] These products heat up much more than ambient temperature, which can cause heat stress and burns.[19][20][21]
In addition, some studies have indicated increased risk for joint injuries and mild traumatic brain injury.[22][23] In other words, we can conclude that grass is a relatively safe alternative. We can’t say that of artificial turf, whether crumb rubber or other products.

As is often the case when researchers are paid by those with conflicts of interest, some studies suggest that the risk is minimal. However, the studies that are more reassuring do not comprehensively evaluate health risks from exposure to recycled tire crumb material. In addition, many studies of air quality pertaining to crumb rubber and similar products use stationary measures, while particulate matter becomes airborne during activity, so these measurements may not accurately reflect exposures during play activities.[24] Our conclusion from the research is that definitive studies of the harm caused by crumb rubber and other rubber products are difficult to conduct, but there are clear reasons to be concerned about children being harmed by them.

We are encouraged that the CPSC is working with other federal agencies to investigate the safety of crumb rubber on playgrounds and playing fields.[8][25][26]

However, we strongly urge you to broaden your investigation to include other synthetic rubber products and to provide warnings to families and athletes as soon as possible. The public has limited access to information about the chemicals that make up these products, which can affect our health and that of our children. All Americans rely on the CPSC to protect us and our children from unsafe products.

In summary, we strongly urge the CPSC to consider our views as it finalizes the proposed rule on phthalates in children’s toys and child care articles, and consider how these rules could be expanded to cover other products that expose children and adults to harmful substances.


  1. National Health and Nutrition Examination Survey (NHANES). (2016) Phthalates and Plasticizers Metabolites – Urine (PHTHTE_H); years of content 2013-2014.
  2. Federal Register. (2014) Consumer Product Safety Commission. Prohibition of Children’s Toys and Child Care Articles Containing Specified Phthalates. Docket No. CPSC-2014-0033.
  3. Federal Register. (2014) Consumer Product Safety Commission. Prohibition of Children’s Toys and Child Care Articles Containing Specified Phthalates. Docket No. CPSC-2014-0033.
  4. Consumer Product Safety Commission. (2014) Chronic Hazard Advisory Panel On Phthalates and Phthalate Alternatives.
  5. Bourguignon JP, Juul A, Franssen D, Fudvoye J, Pinson A, Parent AS. (2016) Contribution of the Endocrine Perspective in the Evaluation of Endocrine Disrupting Chemical Effects: The Case Study of Pubertal Timing. Hormone Research in Paediatrics. 86(4):221-232.
  6. Wang YX, Zeng Q, Sun Y, Yang P, Wang P, Li J, Huang Z, You L, Huang YH, Wang C, Li YF, Lu WQ. (2016) Semen phthalate metabolites, semen quality parameters and serum reproductive hormones: A cross-sectional study in China. Environmental Pollution. 211:173-82.
  7. Hannon PR, Flaws JA. (2015) The effects of phthalates on the ovary. Frontiers in Endocrinology. 6:8.
  8. Levine H, Jøgensen N, Martino-Andrade A, Mediola J, Weksler-Derri D, Mindlis I, Pinotti R, Swan SH. (2017) Temporal trends in sperm count: a systematic review and meta-regression analysis. Human Reproduction Update. 1-14.
  9. Ejar Ejaredar M, Nyanza EC, Ten Eycke K, Dewey D. (2015) Phthalate exposure and childrens neurodevelopment: A systematic review. Environmental Research. 142:51-60.
  10. Synthetic Turf Council. About synthetic turf.
  11. Llompart M, Sanchez-Prado L, Lamas JP, Garcia-Jares C, Roca E, Dagnac T. (2013) Hazardous organic chemicals in rubber recycled tire playgrounds and pavers. Chemosphere. 90(2):423-431.
  12. Marsili L, Coppola D, Bianchi N, Maltese S, Bianchi M, Fossi MC. (2014) Release of polycyclic aromatic hydrocarbons and heavy metals from rubber crumb in synthetic turf fields: Preliminary hazard assessment for athletes. Journal of Environmental and Analytical Toxicology. 5:(2).
  13. California Office of Environmental Health Hazard Assessment (OEHHA). (2007) Evaluation of health effects of recycled waste wires in playground and track products. Prepared for the California Integrated Waste Management Board.
  14. Kim S, Yang J-Y, Kim H-H, Yeo I-Y, Shin D-C, Lim Y-W. (2012) health risk assessment of lead ingestion exposure by particle sizes in crumb rubber on artificial turf considering bioavailability. Environmental Health and Toxicology. 27, e2012005.
  15. U.S. National Library of Medicine, National Institutes of Health. (2017) Tox Town (Environmental health concerns and toxic chemicals where you live, work, and play): Polycyclic aromatic hydrocarbons (PAHs).
  16. Armstrong B, Hutchinson E, Unwin J, Fletcher T. (2004) Lung cancer risk after exposure to polycyclic aromatic hydrocarbons: a review and meta-analysis. Environmental Health Perspectives, 112(9), 970.
  17. Shalat SL. (2011) An evaluation of potential exposures to lead and other metals as the result of aerosolized particulate matter from artificial turf playing fields. Submitted to the New Jersey Department of Environmental Protection.
  18. Mount Sinai Children’s Environmental Health Center. (2017) Artificial turf: A health-based consumer guide.
  19. Thoms AW, Brosnana JT, Zidekb JM, Sorochana JC. (2014) Models for predicting surface temperatures on synthetic turf playing surfaces. Procedia Engineering. 72:895-900.
  20. Penn State’s Center for Sports Surface Research. (2012) Synthetic turf heat evaluation- progress report.
  21. Serensits TJ, McNitt AS, Petrunak DM. (2011) Human health issues on synthetic turf in the USA. Proceedings of the Institution of Mechanical Engineers, Part P: Journal of Sports Engineering and Technology, 225(3), 139-146.
  22. Balazs GC, Pavey GJ, Brelin AM, Pickett A, Keblish DJ, Rue JP. (2015) Risk of anterior cruciate ligament injury in athletes on synthetic playing surfaces: A systematic review. American Journal of Sports Medicine. 43(7):1798-804.
  23. Theobald P, Whitelegg L, Nokes LD, Jones MD. (2010) The predicted risk of head injury from fall-related impacts on to third-generation artificial turf and grass soccer surfaces: a comparative biomechanical analysis. Sports Biomechanics. 9(1):29-37.
  24. U.S. Environmental Protection Agency. (2017) Federal research on recycled tire crumb used on playing fields.
  25. U.S. Consumer Product Safety Commission. Crumb rubber information center.
  26. U.S. Centers for Disease Control and Prevention/Agency for Toxic Substances and Disease Registry (ATSDR). (2016) Federal research action plan on recycled tire crumb used on playing fields and playgrounds.