Written Communications (Updated 03-08-2024)
PRC Meeting
March 7, 2024
Written Communications
From:Andrea Wald
To:City of Cupertino Parks and Recreation Commission
Subject:upgrades to Jollyman and Memorial Park
Date:Wednesday, March 6, 2024 7:28:33 PM
Attachments:TURI Report 2018-003. Playground+Surfacing.pdf
PIP+playgrounds+Too+hot+and+toxic+for+Child’s+play+kmm+7-24+-2017b.pdf
Andrea"s speech to Cupertino City Council 3-5-24.docx
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.
Dear P&R Commission Members,
I've just recently been made aware that plans are already complete for the upgrades of Jollyman Park. I'm not sure about
the grassy areas but do understand that the All Inclusive Playground will have some Artificial Turf and also PIP. These are
both very harmful materials. I hope there is time to figure out how to complete the playground project without using toxic
materials. Please see the two attached documents.
I attended the City Council meeting last night and made a short, 3 minute comment regarding Artificial Turf and its harmful
effects. I've attached a copy of that speech. I'm hopeful that the grassy areas at Jollyman will remain as grass and not be
changed over to Artificial Turf.
As for Artificial Turf, I'd be very curious to know where you are getting that small piece of AT from for the slide area at
Jollyman. There is a lawsuit in the works against Lowes and Home Depot for the AT they are selling consumers and not
advising them of the toxic chemicals in that turf (although ALL Artificial Turf contains PFAS which are toxic - research
showing a link to many health issues):
https://ceh.org/latest/press-releases/new-testing-reveals-high-levels-of-toxic-pfas-in-artificial-turf/
I'm also very curious as to the plans for the upgrades at Memorial Park. In reading through the very lengthy plan documentI did not see any mention of specific materials that are planned to be used - except for one reference to rubberized playarea. Wondering if that is what is known as PIP - toxic material.
I would hope, based upon Cupertino's Climate Action Plan goals, that any materials that are counter to achieving those goalswould be avoided. Artificial Turf and PIP surfaces both are detrimental to the city's goals.
I would be happy to meet up with any commission member and provide additional insight and materials to help thecommission make the best choices for presenting to City Council. I'm sure everyone would want to do what's best for theenvironment and for the health and safety of those using the parks and their amenities.
Sincerely,
Andrea Wald
waldmba@gmail.com
C: 408-431-3774
PS - Please take a look at this very important document (link below) prepared by Santa Clara County Medical Association regarding their views on Artificial
Turf based on extensive research.
https://www.sccma.org/programs/environmental-
health.aspx#:~:text=Recommendation%20to%20replace%20artificial%20turf%20with%20natural%20turf%20for%20Saratoga%20High%20School%20(2023)
Playground Surfacing
Choosing Safer Materials for Children's Health and the Environment
TURI Report #2018-003
December 2018
Acknowledgments
This report was prepared by Lindsey Pollard and Rachel Massey from the Toxics Use Reduction Institute, with input from Molly
Jacobs and Polly Hoppin from the Lowell Center for Sustainable Production; Elizabeth Harriman, Joy Onasch, and Heather
Tenney from the Toxics Use Reduction Institute; Rebekah Thomson from the Field Fund; Kara Rubio from Women for a Healthy
Environment; and Katherine Butler from Recycling Works Massachusetts. Work on this report was supported by a grant from
The Heinz Endowments.
Cover photo: A school playground in Westford, Massachusetts, with engineered wood fiber surfacing.
Playground Surfacing: Choosing Safer Materials for Children’s Health and the Environment ǀ 1
Playground Surfacing:
Choosing Safer Materials for Children's Health and the Environment
Introduction
Playground surfacing helps to protect children as
they walk, run, jump, fall, and interact with their
surroundings in the course of play. A range of
materials are sold as playground surfacing. Some of
these materials contain chemicals of concern for
human health and the environment. In response to
requests from communities, TURI has compiled
information on a range of playground surfacing
options, with a particular focus on chemicals that
may be found in these materials, and how they
may affect playground users.
Vulnerable populations, such as pregnant women
and children, may be especially sensitive to hazards
posed by chemicals found in synthetic playground
materials. Children are uniquely vulnerable to the
effects of toxic chemicals because their organ
systems are developing rapidly and their
detoxification mechanisms are immature. Children
are also more likely to have hand-to-mouth
exposure to environmental contaminants than
adults.1 For these reasons, it is particularly
important to make careful choices about children’s
exposures.
Based on TURI’s research on chemical contents of
playground surfacing materials, wood products—
especially engineered wood fiber (EWF) tested and
verified to be free of chromated copper arsenate
(CCA)—are safer choices for health and the
environment. Synthetic products pose potential
chemical hazards that can be avoided by using
alternative materials.
Playground Surfacing Materials: Overview
Playground surfacing materials are installed
underneath play equipment to cushion falls. They
can be made from natural or synthetic materials
including sand, pea gravel, wood, and rubber.
These materials come in a variety of forms; for
example, wood options include wood chips or bark
mulch, EWF, or bonded EWF (EWF bound with
adhesive). Rubber materials are used in products
such as shredded waste tires (also referred to as
rubber mulch), rubber tiles and pour-in-place (PIP)
surfacing. The U.S. Consumer Product Safety
Commission (CPSC) states that grass, dirt, concrete,
asphalt, or other hard surfaces are not considered
protective surfacing options for playgrounds.2
Protective fall materials are typically installed on
top of a prepared sub-base of gravel, soil,
geotextile, or an impervious concrete slab.
Surfacing materials fall into two broad categories:
loose-fill surfacing materials and unitary surfacing
materials. Table 1 provides an overview of these
material categories.
Loose-fill surfacing material consists of loose
particles such as sand, pea gravel, EWF, or
rubber mulch/shredded tires.2
Unitary surfacing materials consist of rubber
tiles, rubber mats, or other materials (e.g.,
rubber granule, plastic, or EWF) held in place
with a binder. These materials may be poured
in place and cured at the playground site to
form a unitary surface.2 Unitary surfacing
installation designs vary between companies,
but typically include a base layer beneath a
“decorative” top layer of bonded materials.
The base layer is usually composed of either
2 ǀ Playground Surfacing: Choosing Safer Materials for Children’s Health and the Environment
gravel, concrete or asphalt.3, 4 For PIP and
artificial grass installation, a cushioning layer
made of either loose or bonded shredded
waste tire is usually installed between the base
and top layer.
Table 1. Playground surfacing materials: Loose-fill and unitary options
Category Material
Loose-fill
Engineered wood fibers (EWF)*
Wood chips or bark mulch
Sand
Pea gravel
Rubber mulch
Unitary
Bonded EWF*
Pour-in-place (PIP) rubber surfacing*
Rubber tiles and mats*
Artificial grass*
* Americans with Disabilities Act (ADA) compliant
Health and Environmental Hazards
Chemicals of concern
Some materials used in playground surfacing
contain toxic chemicals, creating potential hazards
for manufacturers, installers, playground users,
and the environment. This section provides a brief
overview of chemical hazards that may be relevant
when choosing a playground surfacing material.
Synthetic surfacing materials. A variety of rubbers
or plastics can be used in playground surfacing.
Loose-fill rubber products are generally made with
shredded waste tires. Unitary rubber, including
tiles and PIP surfacing, is made with granulated
particles processed from materials such as waste
tires, thermoplastic elastomer (TPE), or ethylene
propylene diene terpolymer rubber (EPDM), and
held together with chemical binders and adhesives.
An additional material sometimes used is
thermoplastic vulcanizate (TPV). In TPV, a
vulcanized product such as EPDM is combined or
coated with a thermoplastic, such as
polypropylene. Chemicals of concern are found in
both loose-fill recycled tire rubber and unitary
products.5, 6 Pigments added to tire materials may
also be a source of concern.
Tires are primarily composed of styrene butadiene
rubber (SBR). They also contain a wide variety of
intentionally added chemicals, such as stabilizers,
fillers, and vulcanization (curing) agents. Additional
substances can adhere to tires during use.5 Some
of these ingredients are chemicals known to be
hazardous to human health, such as polyaromatic
hydrocarbons (PAHs), volatile organic compounds
(VOCs), and heavy metals, such as lead.
A number of PAHs have been identified as known
or suspected human carcinogens by the
International Agency for Research on Cancer.7
Many of these PAHs (e.g. benz(a)anthracene,
benzo(a)pyrene, benzo(k)fluoranthene,
benzo(b)fluoranthene, indeno(1,2,3-c,d)pyrene,
chrysene, and dibenz(a,h)anthracene) have been
found in waste tire rubber, in the air around the
rubber, or in leachate from the rubber according to
an EPA literature review.8 Acute VOC exposure can
cause eye, nose, and throat irritation, headaches,
Playground Surfacing: Choosing Safer Materials for Children’s Health and the Environment ǀ 3
and nausea; longer-term exposure can cause
damage to internal organs.9
Several VOCs that are known or suspected
carcinogens, such as benzene and hexane, have
been measured in recycled tire materials.8 Metals
found in recycled tires, such as lead, pose concerns
as well. For example, even low levels of lead in a
child’s blood can result in behavior and learning
problems, slowed growth, and anemia.10 Concerns
associated with some other chemicals found in
tires (e.g., phthalates) include endocrine
disruption.8
TPE and EPDM are often marketed as alternatives
to recycled tires in unitary surfacing. These
materials may potentially pose a lower level of
concern than recycled tires, but they can contain
hazardous chemicals as well. In addition, both TPE
and EPDM can include a variety of polymers and
additives. For this reason, it is difficult or
impossible to make broad statements about the
safety of a given product unless one has access to
more detailed information.
TURI reviewed a safety data sheet for a brand of
artificial turf infill material made with TPE. The TPE
was composed of styrene block copolymer,
paraffin oil, calcium carbonate (chalk), carbon
black, polyethylene, and unspecified stabilizers and
antioxidants.11 TPE used in playgrounds could have
a similar composition, or could contain other
chemicals not noted here. In general, EPDM rubber
can contain PAHs, VOCs and a range of additives
including carbon black, oils, and minerals.12
Recycled waste tire material in playgrounds: A study by the Consumer Product Safety Commission
(CPSC)
The “Federal Research Action Plan: Crumb Rubber” is a multi-agency study including the CPSC,
Environmental Protection Agency and the Centers for Disease Control, created to investigate the
potential health and environmental effects of chemicals found in recreational surfacing made from
recycled tires. As one element of this study, the CPSC used a combination of focus groups, field
observations, and a survey of parents and child-care providers to collect information on children’s
behavior when playing on loose-fill and unitary surfacing made from recycled tires. The study shows that
children frequently pick up or pick at, mouth, chew, or fall on surfaces.a The CPSC found that the study
findings raise exposure concerns that deserve further investigation. The CPSC offers the following
precautions for limiting exposure to materials made from recycled tires.
1. “Avoid mouth contact with playground surfacing materials, including mouthing, chewing, or
swallowing playground rubber. This may pose a choking hazard, regardless of chemical exposure.
2. Avoid eating food or drinking beverages while directly on playground surfaces, and wash hands
before handling food.
3. Limit the time at a playground on extremely hot days.
4. Clean hands and other areas of exposed skin after visiting the playground, and consider changing
clothes if evidence of tire materials (e.g., black marks or dust) is visible on fabrics.
5. Clean any toys that were used on a playground after the visit.”b
a Harsanyi, S. 2018. Summary of Playground Surfacing Focus Groups. United States Consumer Product Safety Commission. Retrieved
from https://www.cpsc.gov/s3fs-public/Playground_Surfacing_Focus_Group_Report_2018.pdf?
b U.S. Consumer Product Safety Commission. 2018. Federal research action plan: crumb rubber. Retrieved from Crumb Rubber
Information Center: https://www.cpsc.gov/Safety-Education/Safety-Education-Centers/Crumb-Rubber-Safety-Information-Center
4 ǀ Toxics Use Reduction and Resource Conservation: Competitive Impacts for Massachusetts Businesses
Another synthetic surfacing option on the market is
artificial grass, generally composed of plastic grass
fibers and nylon or plastic backing atop a
polyurethane cushioning layer, fabric liner, and/or
shredded waste tires.13 Many brands use waste tire
granules or sand as an infill to hold the artificial
grass in place. The chemical constituents of the
waste tire materials pose health and
environmental concerns. Ingredients found in the
fibers and/or cushioning may also be of concern.14
Ingredients used in synthetic playground materials
vary between brands. It is important for
playground decision-makers to be aware of what
chemical constituents are present in material
options under consideration by asking vendors or
manufacturers directly for detailed safety data
sheets, test data, and catalogs.
Binders and adhesives. Rubber, artificial grass, and
bonded wood unitary surfacing materials contain
binder and adhesive chemicals. The binder
ingredients used to make and bind unitary rubber
tiles, pour-in-place (PIP), and bonded EWF vary
depending on brand. Urethanes are typically used
to bind rubber and/ or TPE granules together, and
to glue rubber tiles or artificial grass pieces
together, according to manufacturer safety data
sheets reviewed by TURI. Urethanes are made
using chemicals in the diisocyanate family, such as
methylene diphenyl diisocyanate (MDI). In general,
diisocyanates are asthmagens and dermal and lung
sensitizers.15, 16 Hazardous chemicals found in
binders mainly pose an occupational inhalation
hazard during manufacturing and installation.
However, if the cured binder contains any
unreacted monomer, this could potentially create
exposures for playground users as well.16
Sand and pea gravel. Playground sand may contain
trace amounts of crystalline silica (quartz) dust.
Airborne crystalline silica dust exposure is known
to cause pulmonary diseases, including cancer, in
an occupational setting.17 There are several brands
of sand on the market that advertise to be free of
crystalline silica dust. According to manufacturer
safety data sheets. Pea gravel is primarily made
from quartz, which does not pose chemical
concerns when in stable, solid form.
Wood. Loose-fill wood chips, bark mulch and EWF
are all made from raw wood. Wood chips are made
from ground fresh trees, and bark mulch is a
byproduct of the industrial paper and lumber
industries. EWF looks similar to wood chips and is
manufactured similarly to bark mulch, but is
designed specifically for use as playground safety
surface material.2 Wood products can only be
labeled EWF if they meet the specific particle size,
EWF colored green and bonded together with
chemical adhesive.
PIP consists of EPDM, TPE, or waste tire granules,
held in place with adhesives.
Playground Surfacing: Choosing Safer Materials for Children’s Health and the Environment ǀ 5
consistency, purity, and drainage standards
described in American Society for Testing and
Materials (ASTM) 2075: Standard specification for
engineered wood fiber.2 EWF is also tested for
levels of soluble hazardous elements such as lead,
chromium, cadmium, and arsenic.18
The CPSC states in the Public Playground Safety
Handbook that treated wood must not be used in
playground surfacing, as it may contain CCA.2 CCA
is an insecticide and wood preservative composed
of arsenic, chromium, and copper.19 The CPSC also
states that wood playground surfacing
manufacturers must provide test data on material
toxicity to ensure that no CCA-treated wood has
been mixed in with playground materials. The CPSC
suggests avoiding use of any wooden playground
surfacing products where the CCA content is
unknown. Therefore, it is important for decision-
makers to request and review test data before
installing.
With regard to chemicals only, the least hazardous
choices for playground handlers and users are:
loose-fill wood products tested for absence of CCA;
pea gravel; and sand tested for absence of
crystalline silica dust. A summary of health and
environmental hazard information for all materials
is presented in Table 4.
Environmental concerns
The primary environmental concern associated
with playground surfacing is the potential for
synthetic surfacing to produce contaminated
runoff water. Numerous studies show that metals
such as zinc, and toxic chemicals such as PAHs and
phthalates, can leach from shredded rubber into
natural environments.8 This means that the
leached hazardous substances can be carried into
natural systems by stormwater or irrigation runoff.
Even small amounts of these toxicants can create
negative effects on aquatic life.5 Any of the
synthetic material options can also cause general
pollution issues since the synthetic pieces can
migrate outside of intended play areas.
Unitary surfacing installation may also lead to loss
of water-permeable surface area. Overall,
playground surfacing installation designs and
material porosity vary between companies,
allowing for different drainage capabilities. If the
sub-base is an impervious material, such as
concrete, or the fall protection material allows for
only minimal water filtration to the sub-base, the
playground area may disrupt rainwater infiltration.
Loss of stormwater filtration through soil leads to
lowered water quality and a higher quantity of
stormwater runoff into natural water systems, like
rivers and wetlands.20
A playground in Lowell, MA, with wood chip surfacing.
Loose synthetic PIP granules can migrate into the
environment. These particles were found in an area
adjacent to a playground located in Somerville, MA.
6 ǀ Toxics Use Reduction and Resource Conservation: Competitive Impacts for Massachusetts Businesses
TURI consulted Recycle Works Massachusetts on
disposal options available for different surfacing
materials. End of life disposal options are limited
for synthetic materials used on playgrounds.
Rubber mulch can only be recycled at specialized
facilities for a fee. In general, unitary synthetic
products are not recyclable because of their
adhesives, and they may not be reused because
the materials are usually well worn by the end of
their life. Synthetic materials that cannot be
recycled or reused are disposed in a landfill for a
fee, and do not biodegrade. In contrast, wood
materials can be composted onsite, or through a
company. Many composting facilities in
Massachusetts will pick up or receive these
materials for no charge. Used sand and pea gravel
may be sifted and reused on other playgrounds, or
in different applications, such as landscaping.
Heat hazards
Rubber has a higher potential to cause contact
burns as it can heat up and transfer heat quickly to
skin.21 Thermal burns on playgrounds can
occasionally result in serious injuries.22 CPSC
reported 29 thermal burns associated with
playgrounds (mostly second- and third-degree
burns) between 2001 and 2008. Of these, 14
involved playground surfacing.23
There are few published studies focused directly on
playground surfacing temperatures and burns.
However, one study in a hot climate found that
unshaded rubber surfacing reached temperatures
at or above the CPSC temperature threshold for
thermal burn injury.21
Dangerously hot temperatures on playgrounds,
created by heat absorbing materials, can also
create a microscale “heat island."21 A parents’
group in Massachusetts provided TURI with
temperature data. For example, on a day when the
air temperature measured 75o F, the parents’
group documented a temperature of 171o F on a
PIP playground surface.24 Research led by the
Center for Sports Surface Research at the
University of Pennsylvania indicates that all
artificial turf reaches higher temperatures than
natural grass.25
A parents' group in West Tisbury, MA, recorded a PIP
surface temperature of 171.1° F with an air
temperature of 75° F.
As unitary synthetic surfacing begins to age, it may
deteriorate and expose the loose-fill cushioning layer
underneath. This layer is typically made with
shredded waste tires.
Playground Surfacing: Choosing Safer Materials for Children’s Health and the Environment ǀ 7
Other potential hazards
Loose-fill materials, in general, have the potential
to hide foreign objects, and are more likely to be
used by children as “play material” (i.e., throwing
or putting in mouth). Wood and pea gravel
surfacing have the potential to grow mold, though
mold growth can be avoided by ensuring adequate
drainage on and around the play area. Drainage
planning is recommended for all loose-fill products
in order to minimize decomposition, mold growth,
and particle migration.2
Performance Criteria
Critical fall height ratings
The CPSC requires that playground surfacing
materials be tested for critical height, or “an
approximation of the fall height below which a life-
threatening head injury would not be expected to
occur.”2 Because playground materials may
degrade or be displaced over time, the CPSC
suggests testing the impact performance of
playground materials annually. Communities can
ask their chosen playground installation company
about annual field tests for impact performance.
Communities may also choose to install play
equipment that requires lower fall height
protection.
Loose-fill surfaces have standard fill depths that
offer protection for fall injury prevention. Table 2
shows the minimum required depth of each
compressed loose-fill material, and the maximum
fall height at which injuries will be prevented,
according to CPSC. It is important to note that EWF,
wood chips, and rubber mulch all offer the same
amount of fall protection. Loose-fill material
compresses by at least 25% due to use and
weathering, which must be taken into account
during installation and when planning long-term
maintenance.2 Loose-fill material depths will also
decrease over time due to displacement of
materials outside of the play area. Critical height
depths must be maintained over time by “topping-
off” materials in order to preserve performance.
Unitary surface materials have varied quality and
shock-absorption properties, and therefore do not
have standard fill depths for fall heights.2
Manufacturers must supply critical fall height test
data for all playground surfacing, including
specifications for unitary rubber tiles or pour-in-
place materials.2
Table 2. Minimum surfacing depths for compressed loose-fill materials
Compressed surfacing depth
(inches)
Loose-fill material Maximum protected fall
height (feet)
6 Rubber mulch 10
9 Wood chips, EWF 10
9 Bark mulch (non-CCA) 7
9 Pea gravel 5
9 Sand 4
Source: U.S. Consumer Product Safety Commission, 2015
8 ǀ Playground Surfacing: Choosing Safer Materials for Children’s Health and the Environment
Accessibility
Playground accessibility for persons with
disabilities is an important aspect of playground
planning. In order for a surfacing material to be
labeled as compliant with regulations within the
Americans with Disabilities Act (ADA), it must fulfill
wheelchair accessibility specifications described in
ASTM 1951: Standard specification for
determination of accessibility of surface systems
under and around playground equipment.2
EWF and unitary surfacing options are designed to
be ADA compliant.2 The wood pieces in EWF are
sized to “knit” together when compacted, causing
the pieces to remain in place, creating an even,
accessible surface. EWF must be raked to maintain
evenness, especially under swings and slides, in
order to maintain performance. Provided that they
are in good condition, unitary rubber and bonded
wood are inherently stable due to the chemical
adhesives holding the base cushioning material in
place.
Costs
We contacted several suppliers and installers of
playground surfacing materials to provide some
general, preliminary information on costs
associated with material discussed in this fact
sheet. Table 3 summarizes these findings. This
information is provided for general reference only;
costs are likely to be variable, and this overview
does not necessarily cover all the factors that may
be relevant for an individual community.
Table 3. Cost estimates for initial installation, regular maintenance, and disposal of playground s urfacing
materials for a 2500 square-foot areaa
Material Initial cost Maintenance activities/cost Disposalb
EWF,
woodchips,
bark mulch
Raw materials: $2,600
Materials and installation
with drainage: $7,500
Raking back into play area, top-off every 3-5
years
Cost of raw materials for 10% top-off: $300
Compost, many
companies offer free
drop-off or pick up
Sand Raw materials: $3,000 Raking and leveling, top-off every 2-3 years.
Cost of raw materials for 10% top-off: $300
Reused (e.g., surfacing
in community areas) or
repurposed at a facility
Pea gravel Raw materials: $5,000 Raking back into play area, top-off every 1-2
years
Cost of raw materials for 10% top-off: $500
Reused (e.g., other
playgrounds or
landscaping)
Artificial grass Materials, installation of
sub-base, and surfacing
materials: $38,000
Sweeping, blowing or vacuuming, inspection
for damage
Patching heavily worn areas
Landfill, recycling or
reuse may be possible
Unitary rubber
(PIP)
Materials, excavation,
installation of sub-base
and PIP materials: $50,000
Sweeping, blowing or vacuuming, inspection
for damage
Patching cracks and heavily worn areas
Landfill drop-off for a
fee
Rubber mulch Raw materials: $8,000
Materials and installation:
$15,000
Raking back into play area, top-off every 1-2
years
Cost of raw materials for 10% top-off: $800
Recycled at specialized
facilities for a fee
a Fill volumes were estimated using minimum fill depths in Table 2. Cost figures were provided by several suppliers in October 2018. Costs
are likely to vary by time, location, brand, and functional requirements.
b For all options except artificial grass, disposal information was provided by personal correspondence with Recycle Works Massachusetts.
TURI did not obtain detailed information on options for disposing of artificial grass.
Playground Surfacing: Choosing Safer Materials for Children’s Health and the Environment ǀ 9
Questions to Consider when Choosing a Playground Surfacing Material
In researching this topic, TURI found variability in
chemical contents, physical characteristics, and/or
installation techniques between brands of unitary
surfacing products. Below are a number of
questions that decision-makers may want to ask
manufacturers and vendors in order to gain a more
complete understanding of topics such as material
contents, installation design, and disposal options.
What are the chemical constituents of all layers
of material?
What tests have been conducted to check for
chemicals in the material?
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 critical fall height protection can be
achieved with the material?
Can the installation company test fall
protection performance annually?
What is the surface temperature of the
material located in the sun with air
temperature above 80o F?
What is the lifespan of the materials and cost
of maintenance?
Summary
From an environmental and health standpoint,
wood products, especially EWF tested and verified
free of CCA, are safer choices for playground
surfacing material based on chemical content. EWF
also offers high fall protection and ADA
accessibility when correct material depth and
evenness are maintained. Synthetic products,
made with or without recycled tires, pose potential
chemical hazards that can be avoided by using
alternative materials. Table 4 summarizes the
overall characteristics for each material reviewed
in this document. Playground planners are
encouraged to request and carefully review data
on contents and toxicity. Planners are also
encouraged to read installation instructions from
manufacturers on their specific materials in order
to make the safest and most informed choices.
Table 4. Summary of health, environmental, and performance criteria
Materials are listed in order of least concern (green) to greatest concern (orange) to playground users based on chemical hazard criteria only. TURI has attempted to identify the key
concerns for each material.
Health & Environmental Hazard Criteria Performance Criteria
Material (color coding based
on chemical hazards) Possible chemicals of concern Health effects associated with
chemicals of concern
Other human
health
concernsa
Environmental concerns Fall
protection
ADA
compliant
EWF, wood chips, bark mulch
Tested for absence of CCA —e —e Mold growth
possibleb —e High Yes
(EWF only)
Sand
Tested for absence of
crystalline silica dust
—e —e —e —e Low No
Pea gravel —e —e —e —e Low No
EWF, wood chips, bark mulch
Not tested for absence of CCA Traces of CCA possible.2 Arsenic exposure can increase risk of
certain types of cancer.19
Mold growth
possibleb
Possible runoff
contamination High Yes
(EWF only)
Sand
Not tested for absence of
crystalline silica dust
Traces of crystalline silica
dust.26
Inhalation of crystalline silica dust can
cause respiratory disease, including
lung cancer.17
—e —e Low No
Bonded EWF
Binding substances can contain
hazardous chemicals (such as
MDI) before they have been
cured.27
Respiratory issues, skin sensitization,
development of asthma and possible
carcinogenicity. (Primarily an
occupational exposure concern.)16
—e Possibility of impervious
surfaced
Depends on
installation
design
Yes
Artificial grass
PAHs, VOCs, heavy metals,
phthalates, and others found in
some infills; binding substances
can contain hazardous
chemicals (such as MDI) before
they have been cured; grass
blades can pose concerns as
well.5, 6, 8, 11, 12,14
Carcinogenicity, endocrine disruption,
respiratory irritation or skin
irritation.7, 9, 10
Heat hazard
Possible runoff
contamination, migration
of synthetic materials
offsite
Depends on
installation
design
Yes
Rubber tiles, PIP
PAHs, VOCs, heavy metals,
phthalates; binding substances
can contain hazardous
chemicals (such as MDI) before
they have been cured.5, 6, 8, 11, 12
Carcinogenicity, respiratory irritation
or skin irritation. (Substances in
binder primarily present occupational
exposure concerns.)7, 9, 10
Heat hazard
Possible runoff
contamination, possibility
of impervious surface,
migration of synthetic
materials offsited
Depends on
installation
design
Yes
Loose-fill rubber
PAHs, VOCs, heavy metals,
phthalates, and others.c, 5, 8
Carcinogenicity, endocrine disruption,
respiratory irritation or skin irritation.
(CPSC notes that children frequently
pick up or pick at, mouth, chew, or fall
on loose-fill surfacing.)7, 9, 10, 28
Heat hazard
Possible runoff
contamination, migration
of synthetic materials
offsite
High No
a. Information on abrasion hazards associated with playground surfacing was not included in this report. d. Some installation designs include the addition of an impervious concrete sub-base.
b. Mold growth is unlikely provided that drainage is adequate. e. TURI did not identify any priority concerns for hazards covered in this report.
c. Exposure is likely to be greater with loose-fill rubber as children may handle and play with the material.
Playground Surfacing: Choosing Safer Materials for Children’s Health and the Environment ǀ 11
Glossary of Acronyms
ADA Americans with Disabilities Act
ASTM American Society for Testing and Materials
CCA Chromated copper arsenate
CPSC The U.S. Consumer Product Safety Comission
EPA The U.S. Environmental Protection Agency
EPDM Ethylene propylene diene terpolymer
EWF Engineered wood fiber
MDI Methylene diphenyl diisocyanate
PAH Polyaromatic hydrocarbon
PIP Pour-in-place
SRB Styrene butadiene rubber
TPE Thermoplastic elastomer
TPV Thermoplastic vulcanizate
VOC Volatile organic compound
References
1. Landrigan, P. 1998. Environmental Hazards for Children in USA. International Journal of Occupational Medicine and Environmental
Health, 11(2), 189–94.
2. U.S Consumer Product Safety Commission. 2015. Public Playground Safety Handbook. Bethesda, MD.
3. Surface America. (n.d.). Recreational and Athletic Surfacing. Retrieved November 14, 2018, from
https://www.surfaceamerica.com/product/playbound-poured-in-place/
4. Game Time. 2018. Poured in place rubber. Retrieved November 14, 2018, from https://www.gametime.com/playground -
surfacing/poured-in-place-rubber
5. Toxics Use Reduction Institute. 2017. Sports turf alternatives assessment: preliminary results, infill made from recycled tires.
Retrieved from https://www.turi.org/Our_Work/Community/Artificial_Turf/Infills_Recycled_Tires
6. Llompart, M., Sanchez-Prado, L., Pablo Lamas, J., Garcia-Jares, C., Roca, E., & Dagnac, T. 2013. Hazardous organic chemicals in rubber
recycled tire playgrounds and pavers. Chemosphere, 90(2), 423–431.
7. International Agency for Research on Cancer. 2018. Agents classified by the IARC monographs, Volumes 1-123. Retrieved from
https://monographs.iarc.fr/agents-classified-by-the-iarc/
8. U.S. Environmental Protection Agency. 2016. Federal Research Action Plan on Recycled Tire Crumb Used on Playing Fields and
Playgrounds, Status Report. Retrieved from https://www.epa.gov/sites/production/files/2016-
12/documents/federal_research_action_plan_on_recycled_tire_crumb_used_on_playing_fields_and_playgrounds_status_report.pdf
9. U.S. Environmental Protection Agency. 2017. Volatile organic compounds’ impact on indoor air quality. Retrieved November 11,
2018, from https://www.epa.gov/indoor-air-quality-iaq/volatile-organic-compounds-impact-indoor-air-quality
10. U.S. Environmental Protection Agency. 2018. Learn about lead. Retrieved from https://www.epa.gov/lead/learn-about-lead
11. Toxics Use Reduction Institute. 2017. Sports turf alternatives assessment: preliminary results, chemicals in alternative synthetic
infills: thermoplastics elastomer (TPE). Retrieved from https://www.turi.org/Our_Work/Community/Artificial_Turf/Infills_TPE
12. Toxics Use Reduction Institute. 2017. Sports turf alternatives assessment: preliminary results, chemicals in alternative sythetic infills:
EPDM. Retrieved from https://www.turi.org/Our_Work/Community/Artificial_Turf/Infills_EPDM
13. Zeager Bros, Inc. 2009. Recreation surface catalog. Retrieved from https://www.zeager.com/content/uploads/2018/09/Zeager-
Recreation-Surfaces-Brochure-2019.pdf
12 ǀ Playground Surfacing: Choosing Safer Materials for Children’s Health and the Environment
14. Pavilonis, B. T., Weisel, C. P., Buckley, B., & Lioy, P. J. 2014. Bioaccessibility and risk of exposure to metals and SVOCs in artificial turf
field fill materials and fibers. Risk analysis : an official publication of the Society for Risk Analysis, 34(1), 44–55.
15. Toxics Use Reduction Institute. 1999. Massachusetts Chemical Fact Sheet: 4,4-Methylene Diphenyl Isocyanate. Retrieved from
https://www.turi.org/content/download/182/1439/file/Fact Sheet Methylene Diphenyl Isocyanate 2000.pdf
16. U.S. Environmental Protection Agency. 2011. Methylene diphenyl diisocyanate (MDI) and related compounds action plan [RIN 2070-
ZA15]. Retrieved from https://www.epa.gov/sites/production/files/2015-09/documents/mdi.pdf
17. National Institute for Occupational Safety and Health. 2002. Health effects of occupational exposure to respirable crystalline silica.
18. American Society for Testing and Materials. 2015. Standard specification for engineered wood fiber for use as a playground safety
surface under and around playground equipment, active standard ASTM F2075.
19. U.S. Environmental Protection Agency. (n.d.). Chromated Arsenicals (CCA). November 2016. Retrieved from
https://www.epa.gov/ingredients-used-pesticide-products/chromated-arsenicals-cca
20. Brabec, E., Shulte, S., & Richards, P. L. 2002. Impervious surfaces and water quality: a review of current literature and its implications
for watershed planning. Journal of Planning Literature, 16(4), 499–514.
21. Vanos, J. K., Middel, A., McKercher, G. R., Kuras, E. R., & Ruddell, B. L. 2016. Hot playgrounds and children’s health: A mul tiscale
analysis of surface temperatures in Arizona, USA. Landscape and Urban Planning, 146, 29–42.
22. Ford, G., Moriarty, A., Riches, D., & Walker, S. 2011. Playground Equipment: Classification & Burn Analysis. Retrieved from
https://web.wpi.edu/Pubs/E-project/Available/E-project-122111-202154/unrestricted/WPI_Final_Report_IQP-CPSC.pdf
23. O’Brien, C. W. 2009. Injuies and investigated deaths associated with playground equipment, 2001-2008.
24. Data provided by Rebekah Thomson, personal communication. (n.d.).
25. Center for Sports Surface Research. 2012. Synthetic turf heat evaluation: progress report. Pennsylvania State University, University
Park, PA.
26. Quikrete. 2011. Playsand Safety Data Sheet. Atlanta, GA. Retrieved from https://www.quikrete.com/pdfs/msds-b4-playsand.pdf
27. Advanced Polymer Technology. 2017. Woodcarpet binder safety data sheet. Harmony, PA.
28. U.S Consumer Product Safety Commission. 2018. Federal research action plan: crumb rubber. Retrieved from
https://www.cpsc.gov/Safety-Education/Safety-Education-Centers/Crumb-Rubber-Safety-Information-Center
Playground Surfacing
Choosing Safer Materials for Children's Health and the Environment
The Toxics Use Reduction Institute is a multi-disciplinary research, education, and policy
center established by the Massachusetts Toxics Use Reduction Act of 1989. The Institute
sponsors and conducts research, organizes education and training programs, and provides
technical support to help Massachusetts companies and communities reduce the use of
toxic chemicals.
Toxics Use Reduction Institute
University of Massachusetts Lowell
126 John Street, Suite 14
Lowell, Massachusetts 01852
(978) 934-3275
www.turi.org
Too hot for Child’s play
- Rubber’s Pretty Poisons
History
https://www.playgroundprofessionals.com/magazine/issues/2014/12/evolution-playground-surfacing112
..."Rubber nuggets or chips derived from tire recycling had been
offered as playground surfaces since the 1970s- {pushed by a
collaboration between the EPA and industry}. However, these
black, …dirty products found limited acceptance among
playground operators. Then, in the late 1990s, a Ohio chemist
found a way to coat the rubber particles with colored
pigments and, voilà, colored loose-fill rubber playground
surfacing (aka rubber mulch) was born. The coloration
technique spread rapidly and a number of rubber recyclers
soon were supplying the product."...
PIP RUBBER HEAT!
Kemp Mill Park July 15
PIP
154
AIR
and
GRASS
95
Asphalt
128
Wood
Fiber
103
Manufacturer Maintenance Instructions-
Fibar Poured‐In‐Place Rubber
• h"p://fibar.com/Playgrounds/pip/FibarPIP-‐%20Maintenance-‐Instruc@on2017.pdf
Debris
in
the
EPDM
Top
Surface
• Keeping
the
surface
clean
of
debris
is
cri@cal
in
maintaining
the
product.
Sand,
dirt,
organic
material
(leaves,
twigs)
gum
etc
must
be
cleaned
from
the
surface.
If
not
removed,
these
par1cles
can
work
their
way
into
the
EPDM
surface
layer,
to
severely
reduce
or
eliminate
the
impact
a=enua1on
proper1es
….
serious
injury
or
death
can
occur,
and
the
playground
should
not
be
used
un1l
the
surface
is
cleaned
and
the
par1cles
removed.
• drainage
can
also
be
affected.
PIP- breaking down exposing tire
waste
Fairland
Park
Playground
Plastic Synturf & Rubber Playgrounds
BURN
Blair
HS
PlasLc
Synturf
field
WITHOUT
rubber
BURNS
from
Rubber
playgrounds
and
PlasLc
synturf
Fields
IMPACT PROTECTION PROBLEMS
:
http://center4research.org/child-teen-health/early-childhood-development/caution-children-at-play-on-potentially-toxic-surfaces/
California State Study
• 1/3 of the rubber / tire waste playgrounds did NOT pass head
impact safety criteria (and the impact safety decreased with
rising temperature)
• ALL of the wood fiber mulch playgrounds passed .
TOXIC SUBSTANCE EXPOSURE
Many but one example: A study on rubber mulch (and solid rubber
mats) found harmful chemicals in all sampled, often at high levels
(Llompart et al 2012).
Most contained high concentrations of several carcinogenic PAHs.
Several of the identified PAHs can be released into the air by heat,
and when that happens children are likely to inhale them. The heat
needed to do this (140 degrees Fahrenheit/ 60 ºC) is common on
these surfaces but many of the chemicals also became airborne at a
much lower temperature of 77 ºF (25 ºC).
The authors concluded that the use of rubber recycled tires on
playgrounds “should be restricted or even prohibited ,,,"
CONCLUSIONS?
• STOP!
•
Do
NOT
INSTALL
RUBBER
or
PLASTIC
SURFACING
with
or
without
Lre
waste
• INSTALL
improved
NATURAL
surfaces
for
children
at
play
• WARN
USERS
of
the
high
heat
potenLal
• TEST
ALL
RUBBER&
PLASTIC
surfaces
for
IMPACT
ATTENUATION
REGULARLY
• SHUT
DOWN
playgrounds
and
fields
over
120
deg
surface
temperature
City Council members,
My name is Andrea Wald. I’m speaking on behalf of a group called “Community for
Natural Play Surfaces”. Our goal is to educate as many as we can to the ills of Artificial
Turf in hopes of avoiding decisions to be made for installation in our local cities and
throughout CA. We are very worried about the impact that Artificial Turf is having on
our environment and the health and safety of all.
Our first major victory was recently when, with our input and community support, the
Sunnyvale City Council unanimously voted to keep natural grass in a local park instead
of opting for Artificial Turf . They are also considering a ban.
Now for a quick Artificial Turf lesson and relation to Cupertino’s Climate Action Plan
goals.
The first main point in the Climate Action Plan is (quote) “to reduce our city’s
greenhouse gas emissions to net zero by the year 2040”. The section basically
mentions transportation: Artificial Turf is not manufactured in CA and not only are
greenhouse gases emitted during manufacture but also when its transported here on
huge flatbed trucks.
Another section talks about: Natural Systems and Biodiversity. The plan mentions
trees, how to manage and protect them and how they naturally capture and store
carbon, thereby reducing the greenhouse gas impact. There is mention of conducting
an urban heat island study in order to identify areas in Cupertino for planting trees.
The same absolutely holds true for natural grass. Covering acres of fields with
PLASTIC actually emits CO2 and methane, rather than absorbing CO2. Artificial turf
gets up to 80 degrees hotter than natural grass creating a “heat island effect”. This
and the emission of greenhouse gases is leading to an increase in Global Warming.
Artificial turf can also undermine biodiversity as it does not provide habitat for insects and
other wildlife and blocks soil from sequestering carbon dioxide.
Next on the Climate Action Plan is the call to “Reduce Waste” – specifically by “
reducing unnecessary consumption and increasing waste diversion from landfill”.
Artificial turf is plastic, lasts only 8-10 years, is not recyclable and ends up in landfill,
incinerated or even dumped in open fields, where the toxic chemicals continue to leach
into the ground. And since there is no landfill space available nearby nor factories in
CA that burn it, it is shipped off on those same flatbed trucks that brought it here to
begin with.
The toxic chemicals in Artificial Turf plus the microplastics that break off the fields and
flow into our waterways are harmful to aquatic life and end up in our drinking water.
Studies are now showing significant health and safety concerns. There is an increased
rate of injuries on Artificial Turf and studies are showing links to many serious health
issues like cancers, interference with one’s own immune system, and increase in
thyroid disease to name a few.
Artificial turf is not water-free. A lot is used in the manufacturing process and is
needed to clean the fields. As temperatures rise with Global Warming, either fields will
need to be shut down or watered down with significant amounts of water – with the
cooling effect only lasting about 20 minutes.
The Climate Action Plan notes that the community of Cupertino should do its fair share
and that by working together they can lead the way for other communities by
demonstrating effective leadership, innovative thinking and commitment to addressing
the climate crisis now.
The choice between natural and artificial turf happens within this context. This is a
climate decision. This is an environmental decision. This is a solid waste
decision. This decision and many others will shape our future atmosphere and
environment.
I hope when the time comes that City Council is asked to make decisions on landscape
for city properties that Artificial Turf is not part of those discussions. I also would hope
that you might also consider a full out ban for both city properties and residential use –
as did the City of Milbrae. Please look at the big picture when considering the
desirability of artificial turf.
PRC Meeting
March 7, 2024
Written Communications
Item #3
Review Fiscal Year 2024-
2025 Community Funding
Grant Applications and
Program Evaluation
Process
From:Jean Bedord
To:City of Cupertino Parks and Recreation Commission; Jenny Koverman
Subject:Fwd: Omniware networks
Date:Thursday, March 7, 2024 8:18:45 PM
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you
recognize the sender and know the content is safe.
Parks and Recreation Commission,
I am forwarding this to the entire commission at the request of the chair. I am President of the
Cupertino Senior Center Advisory Council, and have also been appointed to the Sourcewise
Advisory Board. Sourcewise is county funded and provides services for the aging, and works
in cooperation with our Senior Center.
Warm regards,
Jean Bedord
---------- Forwarded message ---------
From: Jean Bedord <Jean@bedord.com>
Date: Thu, Mar 7, 2024 at 4:26 PM
Subject: Omniware networks
To: Jennifer Shearin <shearin.jen@gmail.com>
Jennifer,
These are duplicated programs with the Cupertino Senior Center. Look at the 50+ insert in the
Parks and Recreation catalog. The senior center is organizing a health expo on May 10 There
are monthly movies, and a number of social activities in addition to classes and bus trips.
There is a Stay Active Fund which subsidizes membership. The Cherry Blossom festival (no
charge) utilizes the senior center. No mention of transportation to Hakone Gardens - which is
the big issue with seniors.
" For instance, we have organized outing to the bay wetlands which are beyond their normal
daily reach. We have selected recreation areas with paved roads / trails accessible to
handicapped seniors. We have hosted health fair booths to provide information and resources
of mental health. We organized senior talent shows which received tremendous positive
feedback from seniors as they enhanced their confidence, and showcased their talents. We are
also organizing group tour, such as a complimentary culture tour of Hakone Japanese Garden
where we’ll introduce Japanese culture, guide the tour the garden, provide kimono
photography opportunities, and offer Japanese souvenirs. "
The picture of the Talent Show may be Live Oak Adult Day Program - and that may be
justified. The other pictures don't look like Cupertino locations.....
Warm regards,
Jean Bedord
Cell: 408-966-6174