Playing with the Health of our Children and the Environment
Hidden dangers and a hidden process in Amesbury, Massachusetts. Examining the issue of playground surfacing within the broader context of a toxic societal approach.
Image: Natural mulch surfacing replaced by poured-in-place rubber, Sept 2024
Last month, the community of Amesbury, MA had a poured-in-place (PIP) rubber surface installed at its main town playground, replacing the standard mulch surfacing. It can be argued the new surfacing increases accessibility, but what are the alternatives and, at what cost? In addition, how much of an obligation does a local government have to engage the public regarding a project such as this before critical decisions are made, especially given the growing concerns over potential toxicity and health and environmental harm from everyday products, including and especially outdoor rubber-related surfaces at playgrounds and athletic fields? This report aims to explore these thoughts, with battle lines appearing to grow on the issue in states such as Massachusetts.
More specifically, the purpose of this investigation is to touch upon these general questions.
How much is in the public domain about these “poured-in-place” (PIP) rubber materials? Do we know for sure they are safe from a toxic chemical exposure angle? Has the government done any safety studies on them?
Investigating whether my community had done due diligence with regard to toxicity questions and examining how open the process was with the community at large.
Help raise awareness in the general public about these types of issues with the goal of getting more citizens involved.
Massachusetts is fortunate in that it has a number of highly-regarded entities with expertise in the areas of toxicity and chemical impacts on society. One such highly regarded entity is the Toxic Use Reduction Institute (TURI), which is an independent Massachusetts government agency with a mandate to help protect workers, communities and the environment from toxic chemicals and pollution. Hosted by the University of Massachusetts Lowell since 1989, which is a relatively short drive down the highway from Amesbury, TURI has a plethora of related information on its website and is “mandated to help protect workers, communities and the environment from toxic chemicals and pollution and works in close collaboration with businesses of all sizes, as well as government agencies, local communities and international organizations.”
https://www.uml.edu/docs/Playground_surfacing_report_Dec2023_tcm18-377890.pdf
According to a readily available and highly cited and referenced report on the TURI website first published in 2018 and updated in 2023 called: “Playground Surfacing: Choosing Safer Materials for Children's Health and the Environment,” the report ultimately concludes after going in depth on various material types that:
“From an environmental and health standpoint, wood products, especially EWF (engineered wood fiber) that is free of pigments and tested and verified to be free of CCA (Chromated copper arsenate), are safer choices for playground surfacing material based on chemical content. Both wood chips and EWF also offer high fall protection and EWF offers ADA accessibility when correct material depth and evenness are maintained. Cork products can also be a safer option for communities or schools that wish to install a unitary surface. Synthetic products, made with or without waste tires, pose potential chemical hazards that can be avoided by using alternative materials.”
At a national level, one of many organizations looking into the issue of chemical toxicity is the National Center for Health Research (NCHR). Diana Zuckerman, Ph.D., is President of NCHR, and, according to a piece written in the Kingston Wire in October 2023, Dr. Zuckerman has “testified about these products (rubber playground surfaces) to local, state and federal agencies and legislators and met with parents and community leaders from coast to coast. Our (NCHR) nonprofit think tank includes scientists, physicians and health experts who conduct studies and scrutinize research conducted by others. We explain scientific and medical information that can be used to improve policies, programs, services and products.”
According to the NCHR website, “Dr. Zuckerman is the author of five books, several book chapters, dozens of articles in medical and academic journals, and in newspapers across the country. Her policy work has resulted in news coverage on all the major TV networks.”
A specific area that Dr. Zuckerman has focused on is rubber playground surfaces. Dr. Zuckerman provided feedback to Reclaim Party on the subject. Here is a cut and paste of the principal questions asked and the complete answers given:
Reclaim Party Substack: How much is in the public domain about these “poured-in-place” rubber materials? Do we know for sure they are safe from a toxic chemical exposure angle?
Dr. Zuckerman: “In our experience, PIP always has a layer of recycled tire crumb underneath the top "poured" layer. Sometimes the top layer is also recycled tire crumb, but sometimes it is "virgin rubber" and companies claim that the top layer keeps the playground surface safe. But PIP playgrounds often develop a thin layer of dust that contains lead, and when schools or communities wash away that lead dust, it has to go somewhere -- either on nearby grass, sidewalks, or streams. Also, the top PIP layer wears down completely in spots (such as the bottom of a slide) and it also cracks over time. When that happens, the pieces of tire crumb are on the surface, and small children like to put them in their mouths, noses, etc. They get dust from them on their hands, and then their hands go in their mouths too. In addition to the lead in recycled tire crumb, there are other heavy metals in tire crumb as well as toxic chemicals that disrupt the hormones of children playing on them. Many of these are PFAS chemicals. Repeated exposures can result in early puberty, obesity, asthma, and ADHD. And unfortunately, even "virgin rubber" has these same hormone-disrupting chemicals. Many people think that rubber is natural, coming from a rubber plant, but most rubber in the U.S. is synthetic, containing some natural rubber but primarily made from petroleum. In other words, the oil industry is defending these products, not just the companies that install PIP.
Many companies claim that their PIP does not contain PFAS, but there are thousands of PFAS chemicals and the companies only test for a few (usually 5 or 6) and then claim their product has no PFAS.”
Reclaim Party Substack: Has the government done any safety studies on them?
Dr. Zuckerman: “The US government has not. For several years, we have asked the U.S. Consumer Product Safety Commission to do such studies, but so far they haven't. We're still trying to make that happen. However, there have been a few independent studies of the tire crumb used in PIP and of the surface dust etc. The results have shown that some of the pieces of tire crumb used in PIP have very dangerous levels of lead and other pieces of tire crumb have no lead or very little. When that is averaged, it doesn't seem worrisome. But for any child who eats pieces high in lead, it is very dangerous. And there is no way to tell from looking at the tire crumb which pieces are high in lead and which ones aren't.”
Image: example of Poured-in-Place rubber wear and tear (courtesy of National Center for Health Research (NCHR)
The broader general area of synthetic surfaces and playing fields is rapidly gaining more scrutiny. There is overlap here with the ground rubber artificial athletic fields that are popping up everywhere. In fact, Dr. Zuckerman also happened to provide testimony in Massachusetts in 2023 in support of H 3948, which is “An Act prohibiting state and municipal contracts for the purchase and installation of artificial turf fields.”
https://malegislature.gov/Bills/193/HD958
https://www.center4research.org/massachusetts-bill-h3948-artificial-turf/
Perhaps something to consider when your town athletic boosters come to the next town meeting looking to keep up with neighboring school districts by installing those supposedly pretty looking artificial sports playing surfaces. This issue is rapidly coming to a head.
A deep dive into the Amesbury government website did not produce any information, not a single word related to this project that was seen by this researcher. An official social media post from the City after the project had been completed was found on Facebook. Various outreaches via multiple emails and phone calls were made over a week and a half period to the Mayor’s Office and City Council members. None were acknowledged (please see Addendum below for email sent).
One city entity that did respond to outreaches was the Office of Community Development. Via phone call, a Department representative simply confirmed what appeared clear to this reporter in that no city entities outside of the Mayor’s office, such as the DPW or Community Development Department, had any involvement in the project. The representative stated there was no coordination with the Planning Office and that I should reach out to the Mayor’s Office, as that is where everything was handled and coordinated.
A visit to the project installer’s website did not provide any details regarding the material in use beyond generic language about their “safety surfacing.” Reaching out via phone, one representative provided a general statement that the product used in this case in Amesbury is used in playgrounds throughout the country, including others in Massachusetts and that any further inquiries or questions would be best handled by the Mayor’s Office, where all forms related to the project were submitted and maintained.
Additional online research was done and more specifics were found on some installer websites. The typical language seen includes talk about PIP rubber surfaces being “considered generally safe.”
There is a of lot of language on pro PIP rubber surface websites and installer sites about accessibility and safety from a fall perspective but little in the way of confirming with absolute certainty safety from a toxicity and environmental perspective.
What are the details of the specific PIP rubber material used for this particular playground project in Amesbury? For example, is it virgin rubber or recycled rubber? Again, the Mayor’s office has not provided any feedback via either providing it easily to the public via the city website, or via individual phone call and email request; however, as Dr. Zuckerman clarified via follow-up, “Recycled tire crumb has lead and may have some other metals or chemicals that aren’t in virgin rubber. But they all have harmful endocrine disrupting chemicals, though they may not all have the same ones.” In other words, virgin is still problematic.
The popularity of these types of surfaces has exploded in recent years; still, more aggressive pushback is being seen in many communities, as more information about the potential dangers of these materials becomes widely known.
One such recent project case is in Amherst, Massachusetts, where an open and robust debate did occur before final decisions were made involving citizen public comments, local newspaper coverage, and multiple Commissions and Committees.
The Conservation Commission played a key role. An official memo from March 2024 states:
“The Commission determines that there is sufficient evidence of toxicity to water resources resulting from the leaching and runoff from recycled tire poured in place playground surfacing, including ecological impacts and ground water contamination, to prohibit the use of this surfacing at the Fort River playground site. The Commission will not approve the use of recycled tire poured in place surfacing.
The Commission recommends for use in the Fort River Playground, the use of following playground surfacing:
• Poured In Place unitary surface made of Cork
• Engineered Wood Fiber (EWF), Tested for absence of CCA
• Sand
• Pea gravel”
A representative from the Amherst Development Department confirmed that the Conservation Commission recommended against the use of PIP rubber and provided an alternative list. The decision ultimately rests with the Building Committee. It appears the material of choice is Corkeen, which is made from natural cork.
The statement from the Amherst Development Department representative lines up with the easily accessible and publicly available memo from the Amherst website included here.
Like many topics, the issue of playground surfacing seems to boil down to a battle over control of which version of “safe” wins out: safe from more of a traditional version of accessibility vs. safe focused more on potential impacts to our health and environment. Yet, safety from an accessibility point of view is often clouded more by desires for convenience and appearance. Still, beauty is in the eye of the beholder. There are those who believe a rubber playground surface or artificial ball field is prettier looking. Many people don’t see it that way, though, and prefer the aesthetic look of natural grass, mulch, or stone. This is especially true for those that are concerned with potential toxicity from synthetic surfacing, which makes artificial products “look” that much more unattractive.
In addition, while a rubber playground surface is perhaps simpler to maintain, it will break down eventually, increasing with time the danger level from all angles: accessibility, aesthetics, and chemical toxicity. Like all products, they likely break down quite a bit sooner than the salesmen of the industry will claim.
In terms of the issue of Americans with Disabilities Act (ADA) and accessibility, as the TURI report highlights, Engineered Wood Fibers (EWF) is considered ADA compliant when properly installed.
In the end, a proper debate about true playground safety cannot occur without complete information availability and sharing, which is the missing ingredient in this story. Those that are highly focused on making playgrounds and other areas as accessible as possible and view rubber surfacing as the only alternative likely would consider things more broadly if the true potential impacts to our health and environment were widely known, which is not currently the case. There simply is not enough transparency with how our everyday products are made and what the real cost of them is to our well-being.
One interesting case study highlighted in the TURI report states that in 2023, “the town of Poolesville, MD managed seven playgrounds surfaced with shredded tire mulch. After learning about the chemical and heat hazards related to shredded tires, town decision-makers voted to replace the shredded tire mulch with EWF in all town playgrounds.”
For something more similar to PIP rubber (a unitary surface), there is the newer surfacing product called Corkeen made from natural cork claiming to be free from all chemicals and toxins. While a pricing analysis has not been done for this report, Corkeen likely brings up the issue of additional cost. But this brings up yet another key point. What price can you put on the health of children and the environment? We as a society often like to cut cost corners when it comes to issues such as the quality of the infrastructure of our local communities. We never seem to have enough money for our roads, sidewalks, drainage systems, playgrounds, schools, etc. but we seemingly have endless money for unnecessary wars and bailing out our banking system led by our elites.
To be clear, this article is not meant to be an attack on local installers. They are small business owners just trying to make a living and this article is not accusing them of doing anything illegal. This article is meant to be critical of the broader system controlled by large unaccountable global corporations and the lack of awareness in the general public that allows for so much toxicity in general to be present in our daily lives. This is aided by government officials and agencies that too often are not looking out for the best interests of the general population. Many government officials simply are not aware of the potential issues with materials such as shredded tires, just like those in the general public. We need many more people attempting to bring to light these issues so that we can finally have honest debates about the best path forward with not only things such as playgrounds and sporting fields, but issues across the board. Unfortunately, despite all the evidence to the contrary, too many people still innocently assume that if a product or procedure is out in the marketplace, it must have been fully tested for safety from all angles, otherwise, businesses and our government would not have allowed it to be sold and used in the public realm. Unfortunately, nothing could be further from the truth.
Like many issues related to toxicity in America, the public must rely on statements such as “generally considered safe” but that does not prove they are safe. In fact, often times these statements are used because there simply is no reliable testing that has been done. Thus, entities can often conveniently say that the product in question has not been proven without a doubt to be unsafe; however, it also means they have not been proven to be safe. And this, in a nutshell, is how the system works in America: new chemicals come flooding into the marketplace and are considered innocent until proven guilty, with roadblock after roadblock put in place to prevent full testing by neutral agencies. For good measure, the supposedly neutral agencies and all the potential judges in the process are bought off and silenced by an army of industry lawyers and lobbyists. This is how it is done, whether it is material used at playgrounds, or material used in our clothing, mattresses, furniture, the food we eat, the health care industry, etc., absolutely every product class imaginable.
There are close to 90,000 chemicals in use in our society, but only a few hundred (around 1%) have ever been tested by the EPA for safety. Still, because corporations own government agencies such as EPA, even if they tested more, it's not like we could trust the EPA to report accurately. We are basically putting our complete trust with our health into the hands of a handful of giant corporations with the hopes they are voluntarily acting ethically.
Back to Amesbury: the Mayor’s office was likely driven by issues of cost, accessibility, and limiting maintenance. Still, no information to confirm has been provided and seemingly no public meetings on the issue took place, with no information on the city website found by this writer. However, with regard to accessibility, as highlighted in this report, other avenues can and have been pursued by other communities. How much awareness of the issues brought up in this report was there with whoever was making decisions in Amesbury? Likely, there was a significant lack of simple awareness, which could and should have been greatly reduced by a fully open and transparent process that allowed the public at large to be a legitimate part of the debate.
Certainly, there is a much deeper dive that could be done on this issue, but the hope of this article via one small example of a seemingly innocent playground project is to help raise awareness and increase debate of the following critical but often overlooked issues:
Potential hidden chemical toxicities in our everyday lives
Government transparency and citizen engagement, especially at the local level where so many decisions that impact our day-to-day lives occur.
We know it is perfectly possible to live comfortably in a less toxic environment. Most other advanced countries have much greater protections in this arena and they are not only able to somehow live a fully modern lifestyle but the data clearly shows in a much healthier way. We also know there is an epidemic of skyrocketing cases of cancer, allergies, chronic disease, autism, etc. and no doubt the daily bombardment of an endless list of less than fully tested and regulated chemicals in our lives from every food and product we come in contact with is playing a role in the degradation of our health and well-being. It comes down to whether we want a society where citizens are ultimately in control, or whether unaccountable global corporations and captured government agencies are in control. Unfortunately, too often it is the latter. It starts with public attention, followed by citizen engagement and action demanding full transparency on all issues starting at the local government level.
What is the ultimate call on PIP rubber? Are there dangers hiding in the layers of material? There are certainly many growing concerns, with more and more experts and ordinary citizens asking important questions. What we do know is that PIP rubber is being used widely in modern society in towns across America and, in the case of Amesbury, MA, it just suddenly appeared with what looks to have been no public debate via a hidden process.
Addendum:
All official email addresses prominently displayed on Amesbury’s City website in a way that encourages residents to reach out via phone/email. Emails sent out individually and ignored.
Dear Mayor Gove (email sent to direct email plus general mayor’s office email on separate occasions. There was a phone call outreach as well);
Dear Council President Mandeville:
I read with intrigue the recent action to replace the town park’s mulch playground surface with Poured-In-Place Rubber Surfacing.
I am developing a report on this issue, as I believe a deeper dive would be a valuable service to the public. This is an area that greatly interests me, given my background and projects being pursued.
More specifically, I am interested in learning the process regarding the decision and the degree and breadth of safety issues and environmental impacts that were considered in the decision.
Please see here my list of questions that I have had difficulty in finding in this particular case in Amesbury:
- Where did the funding come from and what was the overall process for making the decision to switch from mulch to rubber? Which Amesbury government entities were ultimately involved?
- What were the driving forces around the decision to make the switch? Was it centered on the Americans with Disabilities Act? If yes, does the ADA require rubber type surfaces?
- When pursuing manufacturers/vendors, were any of the following questions asked?
What are the chemical constituents of all layers of material? Does it contain “tire crumb?”
What tests have been conducted to check for chemicals in the material, with the goal of confirming the safety of the product to the health and well-being of the public?
What method of disposal is used for the materials when it is time to replace them?
Are the materials permeable? What are the drainage options for the surfacing?
What is the surface temperature of the material located in the sun with air temperature above 80 degrees F?
What is the lifespan of the materials and cost of maintenance?
- Finally, were any neutral organizations or individuals with knowledge on the subject pursued for input, such as the Toxic Use Reduction Institute (TURI) in Lowell?
Thank you for your timely consideration of this outreach. I am looking to finish gathering information and reporting within the next few days.
Regards,
Ted Semesnyei
265 Lions Mouth Road
Amesbury, MA 01913
Final note: my District Councilor, to her credit, did at least respond to me right at time of final publication of this report, as I sent her the same email. However, the response from her simply stated she did not know the answers to my questions and that it would be best addressed by our DPW, with no mention whatsoever of the Mayor’s office. At this point, I was not interested in getting into an endless loop with City Hall Departments. From the little information I had been able to gather, it was clear the best source of information was the Mayor’s office and not the DPW. Thus, what my City Counselor’s response showed me was an additional layer of a lack of understanding and communication between the City Council and City Hall.