ETRA is pleased to acknowledge the Opinions published on June 19th 2019 by Risk Assessment Committee (RAC) and by the Socio-economic Analysis Commitee (SEAC) in whch they proposed to fix the limit of concentration of 8 PAHs in rubber granulate used as infill material at 20 mg / Kg by weight.
We think that the limt of 20 mg / kg. isreasonable and can be handled by Tyre Recyclers as it is in line with the limit of PAH contained in rubber granulate.
We arrived to this result after a few years of intensive work carried on by ETRA and other Stakeholders. ETRA, ECHA, FIFA and Sports Committees reviewed key points and potential actions during all the steps of the revision process – clarifying many points that were raised during various events and discussed at ETRA Conference in 2017, 2018 and 2019.
Here below is a summary of the process and we note that are still a few steps until the procedure is completed and before the new limit is adopted by the Commission.
Brief Summary
For more than threeyears SBR has been a major focus of debate for a broad range of stakeholders involved in the tyre recycling industries.
In June 2016, the European Commission asked ECHA to assess whether the presence of such substances in recycled rubber granulates in synthetic pitches could pose a health risk to the general population, including children, professional players and workers installing or maintaining the pitches. This was driven by claims of increased cancer risk to children playing on these pitches, which in recent years have appeared in the media of several EU Member States.
ECHA assessed the health risks, looking at exposure through skin contact, ingestion and inhalation. The findings were published in February 2017, with ECHA concluding that there was, at most,a very low level of concern from exposure to the granules.
The risk of getting cancer after a lifetime of exposure to the rubber granulates was judged to be very low, given the concentrations of PAHs measured at the European sports grounds where samples were taken. The concentrations were seen to be well below the legal limits applicable.
The level of concern about the presence of heavy metals was considered negligible, as the levels are below the limits currently allowed in toys in the EU.
There were also no concerns identified in relation to the concentration levels of phthalates, benzothiazole and methyl isobutyl ketone as they were also below the levels that would lead to health problems.
The report also highlighted some uncertainties that would warrant further investigation. For instance, there was a concern over how representative the studies carried out were for the whole of Europe (given that samples were not taken from all Member States).
As such, ECHA suggested a number of actions to be taken to counteract these uncertainties and to reflect good practice, among which: "Consider a restriction under the REACH Regulation so that rubber granules are only supplied with very low concentrations of PAHs and any other relevant hazardous substances."
ECHA sent its evaluation to the European Commission on 28 February 2017.
The Netherlands, in cooperation with the European Chemicals Agency (ECHA), submitted an Annex XV dossier under REACH proposing a restriction on eight polycyclic aromatic hydrocarbons (PAHs) in granules and “mulches” used as infill material in synthetic turf pitches or in loose forms on playgrounds and in sports applications
This dossier was received by ECHA on 20 July 2018.
The proposal suggests restricting the placing on the market of granules and “mulches” for use as infill material in synthetic turf pitches or in loose form on playgrounds and in sports applications if these materials contain more than 17 mg/kg of the sum of the eight PAHs in the scope of Annex XVII entry 50:
- a) Benzo[a]pyrene (BaP) CAS No 50-32-8
- b) Benzo[e]pyrene (BeP) CAS No 192-97-2
- c) Benzo[a]anthracene (BaA) CAS No 56-55-3
- d) Chrysen (CHR) CAS No 218-01-9
- e) Benzo[b]fluoranthene (BbFA) CAS No 205-99-2
- f) Benzo[j]fluoranthene (BjFA) CAS No 205-82-3
- g) Benzo[k]fluoranthene (BkFA) CAS No 207-08-9
- h) Dibenzo[a,h]anthracene (DBAhA) CAS No 53-70-3
On September 19th 2018, a 6 month consultation was opened to respond to the RIVM proposal on the revised PAH concentration in SBR granulate, to which the main stakeholders responded. The consultation closed on 19 March 2019.
The ETRA Sport Working Groupreviewed in depth Annex XV Restriction Report prepared by RIVM that has become the base for the procedure handled by ECHA. They explained many critical points concerning the PAH parameters and the impacts that these will have over time on all of those directly involved including : installers, players and maintenance crews, in order to make proper reflections during the six month consultation period.
The most critical and significant points reflect the lack of evidence of an actual risk to players, or, a definition of the assumed level of risk according to the content of the PAHs instead of the actual release and substance intake by players. Further, they pointed out the nominal, limited human benefits that could be gained if the proposed limits become permanent do not appear to be warranted on the basis of the high environmental and economic costs.
The report itself shows three problems connected to enforceability:
- · The Differences between and among member states
- · Common understandings across the EU
- · An absence of an EU harmonised methodology for PAH extraction and analyses
It would appear that an eventual adoption of the new parameters would increase confusion and incertitude instead of contributing to safer conditions for players, as noted above.
We identify many reasons why the proposed restriction will create lot of problems without contributing to more clarity or to a reduction of risk to health, that, however, until today has not yet been demonstrated.
On 19th June 2019RAC (Risk Assessment Committee) published its opinion based on the restriction dossier and comments received during the public consultation. The RAC analyzed whether the proposed restriction on manufacture, placing on the market or use of a substance is appropriate in reducing the risk to human health and the environment. RAC proposed a concentration limit of 20 mg / kg.
The opinion stated:
RAC therefore agreesa practical risk reduction approach, similar to the Dossier Submitter RO1, but instead recommends a 95% reduction to the currently permited (387 mg/kg) limit in entry 28 of Annex XVII of REACH i.e. 20 mg/kg. This would equate to a theoretical risk of 2.9 x 10-5 for workers and 2.8 x 10-6 for consumers. RAC reiterates that 20 mg/kg is not a risk-based limit but a measure aimed solely at avoiding very high PAH concentrations.
On 19th June 2019SEAC published its opinion supporting the concentration limit proposed by RAC. The opinon took into account the socio-economic impacts, and the comments and socio-economic information received during the public consultation.
Unitl 19th August 2019 it was possible to make comments on RAC and SEAC Opinions. However the limt of 20 mg / kg.seems reasonable and in line with the limit of PAH contained in rubber granulate, so probably there will not be comments. RAC and SEAC will prepares and adopt the final opinion taking into account the comments on its draft opinion.
The adopted RAC and SEAC opinions are sentby ECHA to the European Commission
Within three months from the receipt of the opinions, the European Commission prepares a draft amendment of the list of restrictions of Annex XVII REACH
If the Council of the European Union or the European Parliament do not oppose to the amendment (comitology rules), this is finally adopted
For more information:
https://echa.europa.eu/registry-of-restriction-intentions/-/dislist/details/0b0236e181d5746d