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Fwd: Review of Reports on the Safety of Crumb Rubber Artificial Turf Fields in Menlo Park

From: domainremoved <Safe>
Date: Wed, 15 Nov 2017 12:26:09 -0800

Dear Menlo Park City Council,

A couple weeks ago a report was submitted to Parks & Recreation about the
safety of the crumb rubber turf fields at Hillview Middle School and Kelly
Park. As a group of concerned parents, we shared our concerns with those
reports with the Menlo Park City School Board at last night's meeting and
in writing. As these are both City managed fields, we wanted to share our
analysis below with you as well. This will come as a series of emails with
various experts' opinions.

It is with considerable discomfort that we raise significant concerns about
the reports commissioned and completed from Millennium on the artificial
turf fields. We know that Millennium was hired in good faith and out of
sincere concern for the health and well-being of the children in the
district and community, and for this we are deeply grateful. However, we
are compelled to share our heavily researched concerns about the report.

*Fundamental concerns about the integrity of the Millennium Reports:*

*Parent Concern #1: The Millennium Report fails to address inhalation as a
pathway for exposure to hazardous chemicals found in crumb rubber infill.*

*Millennium quotes old studies that the State of California formally
documents as obsolete to justify exclusion of inhalation concerns*

Millennium argues that inhalation risks have already been studied, and
those studies proved that inhalation is a not an issue with crumb rubber
infill. The studies to which Millennium refers to make this point are the
*old studies*, the ones that the state of California (OEHHA) has publicly
written are now obsolete, thereby justifying its expenditure of almost $3m
in public funds to release an expanded scope study of crumb rubber turf
(that *includes* inhalation analyses) in 2019. OEHHA has formally admitted
in its publications that the old studies, including their analyses of
inhalation risks, were too limited in scope (and based on much larger crumb
rubber sizes, like 1/2 to 1 inch in diameter). The smaller the crumb size,
the more surface area of the tires are exposed, meaning the larger the off
gassing and particle-born inhalation risks. Indeed, the crumb sizes of the
Hillview and Kelly Park fields are approx. 1/8 inch in diameter.

The School Board understandably didn't want to wait until 2019 to read the
new OEHHA report and risk additional exposures on its Menlo Park children. The
school district therefore paid Millennium to provide some data and
assessments in the meantime. Yet, Millennium excluded a big piece of the
consideration set, one that OEHHA itself insists is a big piece of the
puzzle. Our intention was to pay Millennium to do a new study, not justify
exclusion of a big piece of the equation by referring to obsolete studies
that are in the process of being redone by the state of California.

In fact, a major part of OEHHA’s new study involves taking air samples
above the crumb rubber fields to test for particulate matter and chemical
gasses that can be inhaled. Millennium did not do this. (
synthetic-turf. See the very first point under, “What is OEHHA studying?”).

https://www.menlopark.org/documentcenter/view/12728 (See. P. 17. This is a
link to the 2016 EPA’s status report on why crumb rubber infill must be
further studied. P. 17 discusses emission (inhalation) data gaps in prior

Millennium’s rationale for excluding inhalation is counterintuitive and
simply does not make sense.

*Millennium states that it looks at total extractable levels of VOCs/SVOCs
to negate a need for an inhalation workup, but this rationale does not make
mathematical or scientific sense. *

Unless air samples were also taken directly above the turf at the point of
extraction, amounts of chemicals removed from the crumb rubber do not
include those VOCs that are present in the air above it in the form of gas
or inhalable particulate matter.

Note that the “V” in VOCs and SVOCs stands for “volatile”. These are
chemicals that, by their definition and nomenclature itself, volatize or
off gas from the solid material in the form of gas into the air.

PAHs, many of which are carcinogenic to humans, also offgas and can enter
the air as fine particulate matter or dust; this is not taken into
consideration in this argument or in the report, despite the fact that PAHs
were identified in both fields. (https://www.atsdr.cdc.gov/

*Millennium also says in its report that it doesn’t look at inhalation
exposure because the fields are outside, and this makes no sense*

The state of California has formally acknowledged that inhalation exposure
on outside crumb rubber fields is something that must be studied and is
doing so in its forthcoming OEHHA turf report.

*Millennium also deflects the issue about air quality risks*

Millennium states that it "doubts" there will be any incremental risk from
any off gassing of VOCs from the fields since the air quality in the Bay
Area is so bad already. This argument deflects us from our real work
here. First of all, there is no scientific basis for this statement;
Millennium didn't even take air samples above the fields or integrate
inhalation into its human health analyses. Second of all, the air quality
in the Bay Area is not uniformly poor; in fact, we are grateful to report
that the Peninsula has historically had much higher air quality with
respect to ozone and particulate matter than other parts of the Bay Area
(see “Bay Area Spare the Air Days” data over the last few years to view
this trend). We have local topography to thank for this.

But here’s how we think about these issues as they relate to our current
circumstances in the Bay Area: scientists have reported the obvious
conclusions that air quality in the Bay Area and throughout the United
States will likely see a repeat of the smoky air/dangerous air quality
conditions experienced just weeks ago during the North Bay fires.
Increased temperatures mean more dry biomass in our forests, meaning higher
fire risks. As parents and educators, we must contemplate a near-term
future where local air quality standards may be breached significantly,
time and time again. It is therefore pertinent that we examine the tools
we *do* have to improve the air quality our children breathe, especially
when inhaling large amounts of that air while exercising on sports fields.
One step in that direction is removing the hazardous waste, also known as
shredded recycled tires, from the fields on which our children play.

*Parent Concern #2 The Millennium report fails to examine a key chemical
(and known carcinogen) 1,3 Butadiene in its analysis.*

*Millennium falsely claims that 1,3 Butadiene is “used up” in the tire
manufacturing process and therefore there is no need to test for it. *

Many weeks ago, we called on school district staff to include 1,3 Butadiene
in measurements taken. 1,3 Butadiene is a major chemical of concern in
crumb rubber artificial turf off gassing and a known carcinogen:

Millennium claims that 1,3 Butadiene is "used up" in the tire manufacturing
process, making it negligible. Our research indicates that this is false:

1. Here is a link to a public comment on the development of the 2019
OEHHA State of California artificial turf study that insists that 1,3
Butadiene needs to be included. It’s written by Dr. Larry Rose, former
head of the medical unit for Cal/OSHA for 28 years. Note that Dr. Larry
Rose has also reviewed the Millennium report in its entirety as pro bono
favor to us in this process, and his comments are being sent to you
separately. Here is what Dr. Rose writes about the need to include this
chemical in analyses of artificial turf:

*“The synthetic crumb rubber fill used in artificial turf would expose
children and pets to1-3 butadiene both in fine inhaled particulates that
would be airborne and in gassing off with heat. The exposures that would
occur would be due to inhalation and ingestion of the finer particles, and
contamination of clothing worn by students and children roaming on this
dangerous surface would undoubtedly be brought into their homes and
classrooms. The synthetic rubber used in synthetic turf should be disposed
of as a dangerous health hazardous chemical and should immediately be
labeled with warning signs prominently posted for any one walking or
running on installed artificial turf that contains 1-3 butadiene. The
installed surfaces of this type of turf should be immediately tested for
wipe sampling concentrations and for airborne breathing zone concentrations
of 1-3 butadiene.” (Source:

2. In its own studies, EHHI.org (Environment and Human Health, Inc.),
found 1,3 Butadiene in the crumb infill in artificial turf tested. EHHI’s
board is comprised of physicians and policy experts. Their latest press
release is also being sent to you by email.

http://www.ehhi.org/NewTurf_Final.pdf (See p. 78 for 1,3 Butadiene mention)


Most importantly, new studies show that 1,3 Butadiene is so troublesome for
human health that any cocktail of chemicals including it will have toxicity
concerns much larger than the sum of its parts. Dr. Larry Rose writes, in
an email we will forward to you:

*“Any exposure to multiple substances at any concentration regardless of
what regulatory agencies allow would affect the cancer, reproductive, and
endocrine health of people exposed. Any trace amount of 1,3 butadiene, plus
volatile organic compounds, plus carcinogenic metals, plus endocrine
disruptors creates a toxic brew of concurring substances that could well be
not just additive but multiplicative in increasing these health risks.
Addressing each individual substance's allowable level of exposure would be
very misleading. This is true of a number of chemicals and health impacting
physical substances. Recent scientific information regarding endocrine
disrupting chemicals has set traditional toxicology on its head and
frequently goes unaddressed in any health risk analysis. The age groups and
health status of at risk members of exposed populations is of upmost
importance in drawing any conclusions regarding overall probable health
risks.” (Source: Dr. Larry Rose, former medical head for Cal/OSHA for 28
years, in email to Angela Evans and Jennifer Sweeney sent November 2017,
and then forwarded to the School Board)*

*Failure to acknowledge toxicology's admission that cocktails of chemicals
can pose hazards different then chemicals studied individually.*

The quote above on 1,3 Butadiene speaks to the larger issues raised in the
expert opinions by EHHI.org and Dr. Larry Rose, being sent to you
separately. Toxicology has evolved in recent years, and we realize now
that we must not only look at chemical exposures in a vacuum when making
human health assessments. Instead, we must study the risks of* cocktails
of chemicals *involved in exposures. It is now formally acknowledged that
the heath impacts of a cocktail of chemicals can far outweigh and be more
intensely toxic than a mere sum of its parts. In the simpler terms, 1+1
may very well equal more than 2, when it comes to toxicology. To better
understand this recent paradigm shift in toxicology, see the link below and
Oxford’s *Carcinogenesis, published 2015.*

*“**This Halifax Project task force focused on **‘**Assessing the
Carcinogenic Potential of Low Dose Exposures to Chemical Mixtures in the
Environment**’**. 174 scientists from prominent institutions in 28
countries were formed into 12 teams (see below) and they focused on the
possibility that complex mixtures of commonly encountered chemicals in the
environment may be capable of carcinogenic effects that have yet to be
fully appreciated.**”* (Source: http://www.gettingtoknowcancer.org/

Nowhere in its report (or on its presentation page labeled, “Toxicology
101”) does Millennium acknowledge this fundamental and crucial
toxicological premise in its conclusions about human health risks. We
believe that it is impossible to conclude that our fields are safe if a
report fails to acknowledge that chemicals mixed together may present a
different toxicological profile than those reported individually. Even if
Millennium doesn't have budget to quantify these combined risks, it should
at least qualitatively admit this possibility, ideally with some specific
examples. One noteworthy example of chemicals found both in the Hillview
and Kelly Park fields: PAHs + Bis (2-ethylhexyl) phthalate (otherwise
known as DEHP), when combined, have been well-documented to intensify
breast cancer risks *(**Our Stolen Future* by Theo Cloborne).

*Concern #3: The proposal from Millennium does NOT include the expertise of
a toxicologist in drawing conclusions about implications for human health.
Other consultants we have spoken to stress that this is absolutely

We have yet to get a response from district staff on this concern. It’s
also worth noting that once we involved a public health professional, Dr.
Larry Rose, in our review of this report, he reached a markedly different
conclusion than that of Millennium. As you will see in a forth coming
email from Dr. Rose, “The report by Millennium is deficient in a number of

*Our conclusion*

We believe the Millennium report to be flawed or, at best, an unreliable
source of conclusions upon which to base the health and safety of the
children in our district and community. Dr. Larry Rose, former head of the
medical unit of Cal/OSHA, agrees with us after a detailed review of the
Millennium report (see forthcoming email). New reports from EEHI do so as
well in principle (also sent by email).

If nothing else, we urge the School Board and the City of Menlo Park to
exercise the Precautionary Principal. You tried in good faith to obtain
additional information from Millennium, and we are *very* grateful for your
positive intentions to do the right thing. We know that you care about
these issues deeply. However, we have found the Millennium reports to be

*At this point, unfortunately we feel that further analysis is needed.
First to examine inhalation has a pathway of exposure. Second, we believe
a toxicologist should be involved to review the sampling done by Millennium
and complete their own human health assessment.*

It cannot be ignored in this conversation that there are financial
implications for each decision. We have no intention of seeking more and
more testing of the fields. We are simply asking that an accurate,
complete and scientifically sound analysis be completed before any
decisions are made.

We can’t make these decisions for you, but we do think that the health and
safety of children warrants paramount consideration.


Committee for Safe Fields for Menlo Park (leadership team below)

 *“**We believe that** the safety of the fields of play for our children is
of paramount importance**. Together, our backgrounds span degrees in
environmental science, economics, biology, and computer science with
graduate degrees in business, law, and science.**”*

Angela Evans

Jennifer Sweeney

Tori Picket

Corey Binns

Justin Evans

Kristi Cannon

Jenny Sullivan
Received on Wed Nov 15 2017 - 12:30:50 PST

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