Submitted via Electronic Mail to: townclerk@burrillville.org
September 3, 2024
Burrillville Town Council
105 Harrisville Main Street
Harrisville, Rhode Island 02830
Burrillville Town Council
105 Harrisville Main Street
Harrisville, Rhode Island 02830
Re: Comments on Proposed Artificial Turf Field at Burrillville High School
To the members of the Burrillville Town Council:
Conservation Law Foundation (“CLF”) appreciates the opportunity to submit the following
comments regarding the proposed artificial turf field at Burrillville High School (“BHS”).
Founded in 1966, CLF is a nonprofit, member-supported, regional environmental organization
working to conserve natural resources, protect public health, and promote thriving communities
for all in the New England region. CLF protects New England’s environment for the benefit of
all people. We use the law, science, and markets to create solutions that preserve our natural
resources, build healthy communities, and sustain a vibrant economy. CLF has been a leading
advocate for clean, safe drinking water in Rhode Island and throughout New England and is
engaged in numerous efforts to address the threat of emerging contaminants, including PFAS,
throughout New England.
Overview
On April 12, 2023, the Burrillville Town Council adopted a Capital Improvement Plan (“CIP”)
that includes an artificial turf field at BHS (“Artificial Turf Project”). On December 4, 2023, the
Town of Burrillville (“Town”) entered into a 14-page (including schedules) Sales Agreement
(“Sales Agreement”) with FieldTurf USA, Inc. (“FieldTurf”) for FieldTurf to sell to the Town
and install at BHS an artificial in-filled playing surface identified as FieldTurfFTVTP-1, 2.5
inches thick outdoor all green artificial grass in-filled playing surface measuring approximately
88,000 square feet (“Artificial Turf Field”). According to the Sales Agreement, the purchase
price of the “fully installed” Artificial Turf Field is $3,167,235.00. According to Schedule B of
the Sales Agreement, the infill of FieldTurfFTVTP-1 includes 3.0 pounds of cryogenic rubber
per square foot. In the time since the adoption of CIP, a number of Burrillville residents have
expressed concerns about the project, including risks posed by the chemicals contained in the
Artificial Turf Field.
Over the last two months, CLF has reviewed materials posted on-line by the Town about the
Artificial Turf Project, the correspondence from the Rhode Island Department of Health and the
Rhode Island Department of Environmental Management to the Town of Burrillville, comment
letters from other advocacy organizations, and various news stories reporting on the Artificial
Turf Project. Most of the discussion and data has been focused on PFAS chemicals contained in
FieldTurfFTVTP-1 and their potential to contaminate the surrounding environment and local
water supply. Testimony from Elizabeth Denly, Vice President, PFAS Leader & Chemistry
Director for TRC (the environmental consultant hired by the Town of Burrillville), is primarily
focused on issues related to PFAS. In her testimony, Ms. Denly notes that “there were no
statements made about the environmental benefits of this product”. 1 In fact, Ms. Denly doesn’t
make any statements about any other environmental issues related to the product in her
testimony. CLF will address the issue of PFAS as well as the other health and environmental
issues related to this product in this comment letter.
Per- and Polyfluoroalkyl Substances (PFAS)
PFAS are a dangerous and ubiquitous class of chemicals that includes thousands of related
compounds. PFAS have been described as a public health “perfect storm.” They are a class of
chemicals that are extremely persistent in the environment and in our bloodstreams, highly
mobile in water, and toxic in tiny amounts. They are also pervasive. First developed in the 1950s,
today PFAS can be found in everyday products including nonstick cookware, water-repellent
clothing, stain-resistant fabrics and carpets, firefighting foam, food packaging, and artificial turf.
PFAS are toxic to humans in very small concentrations and pose a wide range of health threats.
They are suspected of causing cancer and have been linked to growth, learning, and behavioral
problems in infants and children. They can also cause problems with fertility and pregnancy;
compromise immune systems; and interfere with natural hormones and with liver, thyroid, and
pancreatic function. Developing fetuses and newborn babies are particularly vulnerable to PFAS.
In its master list of PFAS substances, the US Environmental Protection Agency’s (“EPA”) states
that: “PFAS represent a growing, increasingly diverse inventory of chemicals of interest to the
general public, scientific researchers, and regulatory agencies world-wide” noting that “[t]his
PFAS Master List will continue to expand as component lists grow. 2 In fact, the list of PFAS
compounds has grown so much that the EPA retired the PFAS Master List and replaced it with
two separate lists. 3 Together, these two lists now include 16,650 separate chemicals. It wasn’t
until April 10, 2024, that EPA finally set Maximum Contaminant Levels (“MCL”) for six PFAS
compounds. The EPA also set Maximum Contaminant Level Goals (“MCLG”) for these six
PFAS compounds. MCLG is defined as “[t]he level of a contaminant in drinking water below
which there is no known or expected risk to health and allows for an adequate margin of safety.” 4
Two of these six [PFOA and PFOS] have a MCLG of zero. 5 However, the MCL for PFOA and
PFOS is set at 4.0 ppt. Since the EPA treats the MCL as the “enforceable standard,” this is the
standard FieldTurf bases its scientific analysis on. Because PFOA and PFOS are only two of the
best known of thousands of PFAS compounds, it is deceptively simple for a company such as
FieldTurf to claim that its products are technically “PFOA and PFOS Free” without addressing
the broader class of compounds. Moreover, since less than 1% of PFAS are typically analyzed,
never mind regulated, FieldTurf can and does make the argument that based on available data, its
product is PFAS “safe.”
The real question is - what is an acceptable level? Some states, including Rhode Island, have
now enacted outright bans on PFAS in many products. Of course, the devil is in the details. 6
Importantly, “many experts argue for approaching PFAS as a class of chemicals — as in
assuming that less studied members of the chemical family may have health and environmental
impacts akin to those that have been better researched and making decisions around their use
accordingly.” 7 The cumulative effects of all PFAS substances in a product should guide our
assessment of the product’s dangers.
A review of toxic tort litigation in the United States reveals a sinister patten. From asbestos and
lead tainted paint to DDT and PCB – “too good to be true” chemicals and substances have been
introduced to American consumers over the years and have made some companies and
individuals extremely wealthy. Years after these chemicals and substances have been widely
adopted and become common place, disturbing reports of terrible health problems associated
with the use of these chemicals and substances begin to emerge. At first, these reports are easily
refuted (and financial liability deflected) by “experts” pointing out inconsistencies in testing
methods, faulty data, compromised samples, inability to link an adverse health impact to a
particular product, etc. Eventually, the rapid growth in the number of reports and amount of
validated scientific research providing clear causal links prove overwhelming to the legal
barricades that were constructed and the floodgates holding back financial liability come
crashing down. Of course, any financial recovery obtained does very little to repair the damage
done and does nothing to restore the lives lost. Sadly, the claims about these products weren’t
true and the end results from their use weren’t good.
The rise and ubiquitous use of PFAS fits this patten all too well. The Town of Burrillville has
received the latest reports about the numerous health problems associated with PFAS and knows
about the gaping void in research and understanding that needs to be filled 8 . Furthermore, some
Burrillville residents have already been exposed to PFAS contamination. 9 The residents of Burrillville should have the final say about how this story ends.
Cryogenic Rubber (“Crumb Rubber”)
How Much Crumb Rubber and What’s It Made Of? “A typical football field utilizes crumb
rubber infill from as many as 40,000 recycled tires (100-120 tons). Tires are made from some
very toxic chemicals, including the known carcinogens arsenic, benzene, carbon black (which
makes up to 40% of a tire), 1,3 butadiene, TCE, and cadmium, as well as neurotoxins, lead and
mercury. Crumb rubber dust and small pieces are easily inhaled or swallowed as they become
disturbed during gameplay.” 10
Increased Injuries? “Statistics show that injuries are more common on synthetic turf surfaces,
especially those that are not constantly maintained for resiliency. The G-max rating - the ability
to absorb impact - changes as the materials are compacted, often leaving an unsafe, harder
surface that makes injuries more likely and more severe. Common injuries include joint trauma
(especially ankles and knees), concussions, “turf toe,” and unusually large skin abrasions which
are more prone to infection. These are some of the reasons that the majority of professional
athletes prefer natural grass.” 11
Heat Island? “Studies from Brigham Young University showed that synthetic turf averaged 37
degrees hotter than asphalt and 86.5 degrees hotter that natural grass. On a hot sunny day,
synthetic fields can reach a temperature of 180-200 degrees. Dehydration, heat stroke and other
serious heat-related illnesses and second degree burns occurring on the soles of the feet of
athletes have spurred turf manufacturers to sell water cannons for cooling the fields, even though
the water only reduces the temperature for about 20 minutes, at which time the process has to be
repeated. Heat also increases the outgassing of volatile chemicals, which makes them more
problematic as an inhalation exposure.” 12
Health Effects on Young Children? “Young children are especially vulnerable to toxic exposures
from synthetic turf due to their play habits close to the ground and typical hand-to-mouth
behaviors. Due to their small size, they receive proportionally greater doses of chemical
contaminants than adults and their immature organs and developing bodies make it more
challenging for them to detoxify or eliminate certain toxins. Toxic substances in the crumb
rubber can be inhaled, absorbed through the skin or accidentally ingested.” 13
Antidotal Reports of High Incidences of Cancer? “[T]here are a growing number of reports of
higher than usual cases of lymphoma and leukemia among athletes playing on synthetic turf,
especially soccer goalies, who regularly dive onto the turf, releasing dust and infill particles. To
date, no studies have been conducted to confirm a link, but common sense tells us that chemicals
in tires that are linked to cancer should be avoided.” 14 In this regard, “the evidence collected to-
date indicates a basis for concern and an urgent need for closer scrutiny. Most notable is that the
ratio of lymphomas and leukemia is the reverse of that expected in the general population for that
age group. Such a reverse in the pattern of cancers present is considered a signal that an active
chemical carcinogen is present. Given the high stakes, it is prudent to take action to protect
children from this known hazard rather than wait for definitive evidence of harm.” 15
Artificial Turf’s Plastic Problem
“The term “turf” is misleading. This material has no relationship to actual turf or grass. It is
basically a scrap chemical product.” 16
“Several parts of an artificial turf system generate plastic pollution as the product degrades over
time. Rubber or plastic particles migrate off the artificial turf area and into surrounding areas;
parents and residents living near artificial turf fields have collected photographic evidence of
waste tire particles dispersed in wetlands and filling storm drains. As plastics continue to break
down in the environment, they can contribute to microplastic pollution.
Microplastics are a source of growing concern in the scientific community, with evidence of
their presence in babies’ feces and even in breastmilk. A recent review of the scientific literature
by the California State Policy Evidence Consortium concluded ‘microplastics are suspected to
promote deleterious human health effects in the reproductive and digestive systems,’ among
other human health concerns.
Plastic grass blades pollute water resources and gradually break down into increasingly small
pieces. A recent study examined the sources of plastic debris found in sea water off the coast of
Barcelona. Artificial grass fibers ‘accounted for 15 percent of plastic pieces larger than 5
millimetres in the samples from within 1 kilometre of the shore,’ according to a summary of the
study in New Scientist. ‘The authors identify artificial turf as “a major source of plastic pollution
in the aquatic environment.’” 17
Artificial turf fields generally last for about a decade. After this point the turf – tens of thousands
of pounds of material per field – must to be disposed of and replaced. Artificial turf cannot be
recycled therefore it must be disposed of in a landfill.
Conclusion
Based upon the research conducted and the findings presented in this comment letter, CLF
believes that there are a number of serious potential health and environmental harms associated
with the Artificial Turf Project.
CLF understands that Burrillville has already spent, and may be liable for, a considerable amount
of money that will not be recoverable. However, throwing good money after bad is never a
sound fiscal decision.
CLF respectfully recommends that the residents of Burrillville require Burrillville to change
course and invest in an organically managed natural grass field at BHS. 18
Sincerely,
Richard Stang
Senior Attorney
Conservation Law Foundation
CC: Councilperson Donald A. Fox
Councilperson Stephen N. Rawson
Councilperson Dennis M. Anderson
Councilperson Jeremy P. Bailey
Councilperson Justin Batalon
Councilperson David Houle
Councilperson Raymond J. Trinque
Darrèll Brown, CLF, Vice President, Rhode Island