Industry reaction to proposals for new limits on the PAH-content of sports- and play-surface materials
Industry groups have reacted with a mix of caution and positivity to the joint Dutch RIVM/European Chemical Agency (ECHA) proposals for tighter limits on the content of polycyclic aromatic hydrocarbons (PAHs) in rubber granulate.
The issue is a critical one for both tire manufacturers and recyclers, not least because synthetic turf and other playing surfaces represent about half of the market for recycled tire rubber.
And crucially, new restrictions could raise undue public concern about the safety of these products – even though the background science rates the health-risk posed by PAH migration as negligible.
Understandably so, the European Tyre & Rubber Manufacturers’ Association (ETRMA) said the industry needs proper time for assessment before issuing comments on the proposals.
“ETRMA will prepare itself for the consultation that will be launched later in September,” the association’s secretary general Fazilet Cinaralp commented in a written statement to ERJ.
On behalf of the Tyre Recovery Association, Peter Taylor said: ‘’ The UK industry generally welcomes these proposals and has taken a lead in initiating its own voluntary quality standards and wider testing programme which further limit PAH volumes.’’
Representing end-product suppliers, the Synthetic Turf Council (STC) said it supported “all additional scientific-based testing to ensure the safety of those who play on our products.”
“We are carefully reviewing the RIVM proposal and will be providing comments via the public comment process,” STC added in a written statement to ERJ.
“Our members provide a beneficial way to reuse existing tires to create synthetic turf fields that promote healthy, active lifestyles,” STC further commented.
There was also support from recycler Genan Holding A/S, which has an in-take capacity of 275 kilotonnes per annum across four European plants – 75% of output is rubber.
“Genan welcomes the initiative for a pan-European set of rules applying to rubber infill and mulches for artificial turf,” said group CEO, Poul Steen Rasmussen.
“Tires manufactured or imported into Europe must comply with strict limit values for PAH content,” the Genan boss said. “Ensuring that rubber infill for artificial turf is made from end-of-life tires only is thus key.”
And, emphasised Rasmussen: “It is paramount that well-defined, pan-European rules are laid down, defining how product samples should be extracted, and how tests should be performed. If sampling is random and unrepresentative, test results will be “equally random and misleading.”
The European Tyre Recycling Association (ETRA) also intends “to actively take part [in the consultation] with the aim of contributing to the process to bring clarity and certainty,” president Ettore Musacchi said in a statement to ERJ.
“ETRA and its team will continue to work in close cooperation with scientific bodies and other organisations on this dossier and will follow closely all the steps of the procedure of revision,” he added.
Reviewing the background to the proposals, Musacchi noted that the RIVM report acknowledges that the content of PAH in tires was limited since 2010 by a European directive adopted by tire producers as the use of plasticising oil was prohibited.
“This, more than anything else, brought a reduction in the PAH concentration also in recycled materials, that, as assessed by the report, in 95% of the fields investigated by RIVM, would already comply with the proposed limitation,” he said.
Similar restrictions, Musacchi observed, do not seem to exist for other sectors or products that could be the source of waste streams from which other infill materials have been produced, or could be in future.
The ETRA president added that the process of defining new PAHs limits was not started as a scheduled activity to fill a legislative gap, but “as result of an unjustified emotional attack on recycled tire materials.”
While the latest revision procedure will conclude in 2020, Musacchi suggested that it could be more effective, to use this period to further define the limitations on PAH-content in tire production.
“Indeed, a high PAH concentration may create more actual health risk situations in various contexts – tire production, use of tires and dispersion of micro-powders – prior to recycling, rather than the use, in a shape of granulates, in artificial turf,” he said.