The future of third-generation synthetic turf is now in the hands of the politicians. Following the closing of ECHA’s public consultation window, the final group to consider whether there is still a place for polymeric infill in synthetic turf is the European Commission.

ECHA’s public consultation window ran from 1 July to 1 September and was the last opportunity for the market and industry to state their case. Is it possible to have third-generation synthetic turf fields without the polymeric infill posing a threat to the environment? The European Chemicals Agency (ECHA) thinks this is impossible and has proposed to ban the placing on the market of these materials. Although microplastics appear in a wide range of products, including toothpaste, paint, detergents, and cosmetics, ECHA believes that a giant leap can be taken in reducing microplastics pollution by 400,000 tonnes in the coming 20 years, when use of polymeric infill in third-generation synthetic turf fields ultimately will come to an end. According to ECHA, there are enough alternative solutions available that are more sustainable. This is a belief that is highly disputed by some suppliers, as well as sectors of the market. Nevertheless, ECHA’s Risk Assessment Committee (RAC), one of two committees that make up ECHA, adopted this view earlier this year, though they advised adopting a transition period of six years before the ban becomes active. However, the other committee, the Socio-Economic Analysis Committee (SEAC), decided to refrain from expressing a firm opinion. They opted to await the input from supporters and opponents of the ban which could be submitted during a compulsory public consultation process.

Derogation based on mitigating measures

It is unclear at present how many individuals, companies and organisations have used the public consultation process to respond to ECHA. From publicly available information, it is evident that the Czech and Dutch FA, amongst others, have argued a derogation whereby third-generation synthetic turf with polymeric infill can be used, providing a field is fitted with mitigating measures. This is in line with international best practices in the field of “health and safety,” where a ban is viewed as a last resort. First, one has to attempt to mitigate the identified risk by pursuing a behavioural change in all stakeholders. Should this option not be practical or be deemed unsuccessful, the next step is the implementation of mitigating measures. Only once this appears to yield insufficient results, can a ban be considered.

As the duty of care to prevent environmental pollution from microplastics resides in most countries with the local authorities, it is easy to understand how difficult it is to achieve a behavioural change in members, parents, operators and maintenance crews of a club using a third-generation field. To them, adopting mitigating measures is the easiest way to become compliant. Bjarne Christensen, the sustainability manager at the football association of Denmark (DBU) explains it as follows: “In Denmark, we are leading the way when it comes to the green transition. This also applies on the football pitch, where artificial grass pitches have been built in recent years with simple and innovative environmental solutions to prevent the spread of rubber granules.” The DBU assures Danish clubs and municipalities that they can continue investing in synthetic turf that is fitted with mitigating measures. “Both clubs and municipalities can confidently continue the work of renovating their current artificial turf pitches or building new ones so that the football can roll all year.”

Christensen points out that the vast majority of artificial turf pitches today are built with rubber granules. “It would therefore be a great surprise if the European Union were to make a total ban. However, we expect that future EU regulation will have clear objectives to reduce the permitted granules loss to the environment,” he adds. Knowing how close the Nordic FAs work together, it is likely that the views of the DBU are also those of the FAs in Iceland, Norway, Sweden and Finland.

CEN/TR 17519 Surfaces for sports areas

The EU regulations the DBU is anticipating are, in fact, already present. Earlier this year, the European Standards Committee (CEN) adopted CEN/TR 17519 Surfaces for sports areas – Synthetic turf sports facilities – Guidance on how to minimize infill dispersion into the environment. Reference to this document surfaced in several of the responses to ECHA seen by Sportsfields.info. The document discusses various solutions that can be considered to prevent infill migrating outside the field perimeter, and defines the technical specifications for these solutions. Solutions that can be considered include containment barriers, decontamination grates, and boot cleaning stations, as well as a snow storage area. Filters for the existing drainage system, as well as a filter ribbon around the field, can also be considered to trap polymeric infill before it leaves the field perimeter.

Thanks to lobby work by the EMEA Synthetic Turf Council (ESTC), an industry body for the synthetic turf industry in Europe, the Middle East and Africa, FIFA has integrated elements of CEN/TR 17519 into the latest issue of its ‘Handbook of test methods.’ The same handbook is used by World Rugby to ensure synthetic turf surfaces for rugby are also fully compliant.

Uphill battle

Although there is a consensus that ECHA intentions do serve the environment and society at large, many disagree with ECHA’s views that there are sufficient viable alternatives available to immediately start replacing polymeric infill. Yet, they fight an uphill battle. In the absence of sufficient scientific evidence to counter the claim that polymeric infill disperses into the environment, ECHA resorted to accepting the results of a study in which polymeric infill for third-generation synthetic turf fields was only one of many things being covered. Based on their conclusions, ECHA claims that each third-generation synthetic turf field sheds between 380 and 2,000 tonnes of polymeric infill per annum. It is a claim that has been widely disputed. The German FA (DFB) even called it “incorrect.” They pointed out that ECHA bases its claim on fields that use SBR as polymeric infill. In Germany, national construction standards stipulate the use of an elayer or shockpad, hence third-generation synthetic turf fields in this country only use a small layer of performance infill. Therefore, fields in Germany use an infill volume that doesn’t even come close to the approximately 120,000 kg of SBR infill that is required. Furthermore, it was established that ECHA settled on 380 to 2,000 tonnes per field by simply asking maintenance companies how much infill they add per field per annum. In doing so, ECHA failed to recognise that the infill layer compacts.

Since ECHA voiced its intention of a ban, various studies have been conducted to establish if it is possible to prevent infill migration. Recently, a study commissioned by the ESTC was added. ESTC asked Swedish consultancy firm Ecoloop to establish what the migration of polymeric infill would be once mitigating measures have been implemented. The Swedish consultant concluded that, “Infill migration into uncontrolled zones on fields in common use in the EU can be controlled by up to 97%. This means that uncontrolled infill migration can be limited to about 15kg (2g/m2) with relatively easy measures such as appropriate field design, good maintenance routines and improving player hygiene.” All are discussed in CEN/TR 17519. According to Ecoloop, “Uncontrolled infill transport will then be below the 7g/m2 proposed by ECHA’s SEAC committee.”

Up to the politicians

The input SEAC received during the public consultation window is currently being reviewed before the committee will vote and present a final opinion. ECHA will then take the final opinions of both RAC and SEAC to the European Commission for scrutiny. This will happen before the end of this year, as the commission has the intention to vote sometime next year. For the proposal to pass, it is required that 55% of the EU member countries vote in favour. This 55% majority should also represent 65% of the population in the European Union. If the EC adopts the proposal to ban the placement onto the market of polymeric infill after a transitional period of six years, this means that from 2028, it will no longer be allowed to sell these infills. In that case, third-generation synthetic turf fields can continue being used until such time that the infill stock available at the premises of the field owner has been depleted or a field is replaced.

The politicians are now facing a Herculean task. A third-generation synthetic turf field that is used to facilitate training sessions and games for players and officials delivers approximately 37,500 hours of people exercising (2×11+3 officials/substitutes x 1,500 hours per annum). Depending on who you listen to, the 17,000 third-generation synthetic turf ESTC claims Europe has, or the 42,000 the DBU appears to have identified, multiplied by the number of exercising hours a field offers per annum, concludes that third-generation synthetic turf fields deliver 637,500,000 hours (ESTC) to 1,575,000,000 hours (DBU) of exercise. That’s a serious number of hours of people working on their health, something that can’t go unnoticed at a time when COVID-19 confronts us with the consequences of poor health.