Synthetic Turf

2024-04 Submission from The Committee, West Pennant Hills Valley Progress Association Inc.

Synthetic Turf in Public Open Space - Guidelines for Decision-Makers

Background

The West Pennant Hills Valley Progress Association (WPHVPA) represents about 4,000 households and more than 10,000 residents located in the area bounded by Castle Hill Rd in the north, Pennant Hills Rd in the east, the M2 & Darling Mills Creek in the south and Excelsior Creek in the west.  The Association has been in existence for more than 30 years.  We have received strong support from Valley residents for the views expressed in this submission.

Summary

In the view of our committee, the guidelines highlight many of the very serious drawbacks of synthetic turf, but fail to reach the logical conclusion that best practice natural grass should always be the preferred solution, and that in some locations, it is the only solution.  The document appears biased towards the use of synthetic turf, and the high performance of best practice natural grass is often overlooked.  Synthetic turf manufacturers have successfully run an aggressive marketing campaign to promote their product and these guidelines do little to encourage natural grass fields.

We request amendments to the draft guidelines and regulation of the synthetic turf industry.

·        The guidelines must be strong and decisive, and rule out the use of synthetic turf in some locations. 

·        Data on surface temperature and amount of plastic typically used over the lifetime of a synthetic field must be included. 

·        The guidelines must be expanded to include Information on installing best practice natural turf, and any bias towards the use of synthetic turf must be omitted.

·        The synthetic turf industry must be regulated, including materials used, annual inspections, funding and location of new installations. 

The NSW Government needs to act quickly and decisively. This product is known to pollute the environment and is likely to affect people’s health.  We only need to look at the emerging situations with PFAS chemicals, asbestos in mulch and engineered stone, to realise that there should be a moratorium on new installations of synthetic turf, while we gather more health data.  The long-term health impacts of synthetic turf are unknown and we should adopt the precautionary principle instead of encouraging a ‘business as usual’ attitude.  The government must act now before more damage is done.

1. Requested amendments to the draft guidelines

A.     The guidelines are too weak

 i.           The guidelines must start with a clear decision-making flowchart that rules out the use of synthetic turf in some locations.

Initial questions should be of the type:

a.      Is the site located in a bush fire zone?

b.      Is the site located in a flood prone area?

c.      Is the site located in a drinking water catchment?

d.      Is the site located close to natural waterways or waterbodies?

If the answer to any of these four questions is ‘yes’, the guidelines must be decisive and rule out a synthetic turf option for this site.  It is far too weak to suggest ‘reconsidering’ the use of synthetic turf.  It must not be installed in these areas.

e.      Is the field to be used during the day by young children or the elderly?

If the answer is ‘yes’, synthetic turf must not be used because it can cause dangerous heat stress in vulnerable members of the population.

 f.       Will the field be used during the day on weekdays?

If the answer is ‘no’, a natural turf surface will suffice.  As stated in the guidelines, ‘Unless synthetic fields are used much during the day on weekdays, they are unlikely to be in use for more than 30 hours a week, as sport training sessions typically happens in afternoons and evenings and matches are held at weekends.’

B.     The guidelines lack important data

 i.          The guidelines must include data showing specific surface temperatures of synthetic grass on sunny days when the ambient temperature is between, say, 15°-35°C.  It is too vague to simply describe it as ‘significantly hotter’ than natural grass. 

Decision-makers must be made aware that ‘hot’ can mean over 80°C.  Recently, our committee members measured the surface temperature of synthetic turf on a sunny day.  At the following community meeting, we challenged residents to guess the temperature of the synthetic turf.  We told them that the ambient temperature had been around 35°C and that the synthetic turf had been ‘very hot’.  Most residents guessed a surface temperature of 40°-55°C, and were shocked to learn that the correct answer was around 81°C. 

The guidelines must specify expected surface temperatures of synthetic grass on a sunny day so that decision-makers can be fully informed.

ii.          The guidelines should quantify the amount of plastic typically used in a synthetic turf field, initially and throughout the lifecycle.  If we were talking about using a large amount of water, we would compare it to a number of Olympic swimming pools so that decision-makers could imagine the volume.  The same reasoning should apply here.  All areas of government are trying to reduce the use of plastic, so it is essential to specify exactly how much plastic is contained in a synthetic turf field, including the infill typically lost and replaced each year, and the amount going to landfill after 8-10 years.

C.     The guidelines appear biased toward synthetic grass and appear to ignore the strong evidence against its use.

 i.          The guidelines must address the imbalance between the aggressive and expensive marketing campaigns run by synthetic turf manufacturers, and the more modest marketing techniques of natural grass suppliers.  The guidelines have been ‘Developed in partnership with local government, sporting bodies and industry experts’.  However, many councils and sporting bodies rely on being ‘informed’ and ‘trained’ by synthetic turf suppliers who have run a very aggressive marketing campaign.  This can result in the input from local government and sporting bodies being biased towards synthetic turf.  The relative performance of synthetic turf compared to natural grass is grossly overstated in marketing materials and these guidelines do nothing to correct the imbalance. 

ii.          The guidelines must be expanded to include details of installing best practice natural grass fields and should always recommend natural grass as the preferred option.  The guidelines refer to the many serious drawbacks of synthetic turf.  Some examples cited in the guidelines are:

a.      ‘Polymers used in synthetic turf are classified as easily flammable and can be ignited in bushfire settings’

b.      Polymers ‘may cause additional risks due to toxic gasses and noxious emissions being released once ignited’

c.      ‘Synthetic turf with loose infill may pose a risk through ingestion, lodgement, inhalation and skin contact’

d.      ‘Synthetic turf absorbs, radiates and reflects heat, impacting users’ thermal comfort’

e.      ‘Extreme rainfall events and flooding in NSW during 2022 caused significant damage to some synthetic fields and disintegration of old fields into unfiltered drains, resulting in water pollution’

f.       ‘Synthetic turf has a lifecycle of approximately 8-10 years……It is purposefully designed to not break down quickly, and has the potential to stay in landfill for a significant amount of time after disposal’

g.      ‘Sterilisation of soil beneath the synthetic turf has an impact on ecosystems.  Synthetic surfaces inhibit living systems’

h.  ‘Replacing natural turf with synthetic turf results in a loss of freely accessible public open space and is a disincentive to informal sport and recreation.’

These are just some of the serious drawbacks listed in the guidelines.  Having guidelines with the title ‘Synthetic turf in public open space’ appears to give synthetic turf legitimacy, regardless of the obvious drawbacks.  Considering point ‘h’ above, the existing title is ironic because synthetic turf reduces public open space! 

iii.           The high performance of natural grass fields built to current best practice must be emphasised in these guidelines.  For instance, Penrith Council has acted on advice from natural grass experts and is achieving at least 50 hours play per week on natural grass fields. 

iv.          The NSW government is developing in parallel a best practice irrigation guideline for natural grass.  The irrigation guidelines must be made available at the same time as the synthetic turf guidelines. 

D.     The guidelines must be applied to existing synthetic fields when due for renewal and must include advice on converting existing synthetic fields back to natural grass.

 i.          We already have many synthetic turf fields in unsuitable locations.  There are synthetic fields in bushfire zones, on floodplains and too close to water courses. The guidelines must be used to reassess all synthetic fields when they are due for renewal. 

2. Requested Regulation of the Industry in NSW

The synthetic turf industry in Australia is currently unregulated.  We request the following changes:

a)  Synthetic turf should only be provided and installed in NSW by suppliers approved by the NSW government.

b)     The materials used in synthetic turf manufacture must have Material Safety Data Sheets (MSDS) so that decision makers can make an informed decision.  This is particularly important because synthetic turf often contains ‘forever’ chemicals.  Decision makers cannot make a proper judgement if the composition of synthetic turf is unknown.

c)  Any proposal to install synthetic turf must be accompanied by an Environmental Impact Statement (EIS)

d) Synthetic turf installations must be subject to an annual inspection to ensure that proper maintenance is carried out.  The risk to our environment of a poorly installed or maintained synthetic field is too great.

e)     Public funding must ensure equal access to funds for synthetic and natural grass.  Decision makers must not be ‘encouraged’ to install synthetic grass simply because funding is only available for that purpose.

f)       The precautionary principle must be applied, leading to a moratorium on new synthetic turf installations while more data is collected on health and environmental impacts, and until the industry is properly regulated.  Loose infill material can pose a risk through ingestion, lodgement, inhalation and skin contact. Existing synthetic turf fields are already releasing tonnes of micro and nano- plastics into our waterways, which find their way into our food chain and have a cumulative effect.  The long-term health impacts of synthetic turf are unknown.

Conclusion

The NSW Government needs to act quickly and decisively. This product is known to pollute the environment and is likely to affect people’s health.  We only need to look at the emerging situations with PFAS chemicals, asbestos in mulch and engineered stone, to realise that there should be a moratorium on new installations of synthetic turf, while we gather more health data.  The long-term health impacts of synthetic turf are unknown, and we should not be encouraging a ‘business as usual’ attitude.  The government must act before more damage is done. 

Our committee requests that the guidelines are amended in line with our recommendations and that the synthetic turf industry is regulated by the NSW Government.

Cc: Ms Tracy Mackey

CEO NSW Environment Protection Authority

Dear Minister Kean,

We are writing to you regarding our ongoing concerns about the continued use and apparent expansion of the use of synthetic turf on NSW playing fields.

We first raised our concerns with our local government authority, The Hills Shire Council, in March 2019 in relation to a synthetic turf playing field proposed for the West Pennant Hills Valley. We believe that like many NSW councils, the Hills Shire Council continues to see a benefit in using synthetic turf and that we are likely to see more plastic playing fields in our local area.

Much is made of the inability of natural turf to cope with the pressure of the increasing demand for the use of playing fields. It is also suggested that there is a cost benefit in changing to plastic. We are aware of studies and comments by experts in this area that if designed and maintained properly, fields with natural turf can generally support significantly higher usage than the proponents of synthetic turf fields would have us believe and that the real cost benefit is to be found in keeping natural turf.

We agree that prioritising participation in active and passive recreation has enormous benefits for us all and understand that there is an increasing demand for recreational spaces placing pressure on our existing natural grass fields.

However, we have serious environmental and public health concerns about achieving this goal through replacing natural grass with plastic grass. Given the real possibility of negative outcomes arising from the use of synthetic turf and the lack of scientific data about its long-term effects, we believe that we should embrace the precautionary principle and stop its use in NSW.

We recently made an on-line submission to The Department of Planning, Industry and Environment’s Synthetic Turf Study. Whilst we commend Minister Stokes for his actions in initiating this study, we believe that this discussion needs to include both your office and the NSW EPA as the state’s primary environmental regulator.

The recent release of the NSW Waste and Sustainable Materials Strategy 2041 and its associated NSW Plastics Plan clearly support the need to use less plastic and improve the way we manage plastic waste and pollution. They suggest that we do understand the inappropriateness of the continued use of plastic grass.

We have calculated, using data from a study by the Federation Internationale de Football (FIFA), that, on average, a single synthetic playing field will lose the equivalent of half a million single-use plastic bags into the environment every year. In addition, at the end of its life we will need to dispose of the equivalent of an average 30 million single-use plastic bags.  The end-of-life figure is based on disposal of the blades, backing and infill and does not include an allowance for any plastic in the shockpad and underlay which may also require disposal.

Plastic playing fields are often located in positions where there is significant run-off into our waterways. We question how the use of synthetic turf and especially synthetic turf using plastic or recycled rubber infill, could possibly comply with the NSW Protection of the Environment Operations (POEO) Act 1997 in terms of materials being washed off-site, and especially the Protection of the Environment (Waste) Regulation 2014 in the case of fields using re-cycled tyre waste as infill?

Some of the significant problems that cause us to object to the use of synthetic turf are summarised below.

TEMPERATURE - we have measured local synthetic turf playing fields at temperatures exceeding 80 degrees C, and 20 to 50 degrees C above adjacent natural grass in hot weather. Users, particularly children, can suffer from heat stress and injury.

Water can be used to cool the field but it will reheat quickly as it lacks the cooling transpiration of natural grass.

MICROPLASTIC POLLUTION - Plastic particles from 5mm down to microscopic levels are seen as one of the greatest environmental burdens and threats today. These particles, found throughout our environment, especially oceans, are now in our food chain and have been reported in human stool samples.

Globally governments and industry are working to dramatically remove plastic from the environment. Plastic playing fields shed microplastics into the environment from both the plastic turf fibres and its infill, usually artificial rubber or plastic. These microplastics pollute water catchments and the ocean.

Pollutants in the marine environment will adhere to microplastic particles increasing the potential for damage to the environment and the planet’s food chains.

Some studies have shown that microscopic particles generated from plastic playing fields can form a respirable dust ready to be inhaled by children using the field.

CHEMICAL POLLUTION - The plastics used in the fibres and the usually synthetic in-fills are created from petrochemicals and contain many toxic chemicals including known carcinogens which will be leached, outgassed and physically broken off and swept into the environment.

The plastics used in playing fields have been shown at times to contain PFAS and lead. Given our global concerns about the environmental and health effects of these contaminants we need to understand how plastic fields may or may not contribute to this environmental burden.

END OF LIFE DISPOSAL - Depending on the level of usage and maintenance, synthetic turf will need replacing after 8 to 15 years. There is no infrastructure in place to recycle the plastic.

The plastic will be too dirty to recycle without some significant cleaning. Any cleaning solutions used are likely to become heavily contaminated with microplastics and will become a significant environmental issue in themselves. Landfill is still looking as the most likely end for a plastic field where it will continue to shed microplastics and chemicals into the environment.

It has been suggested that the disposal problem may be managed by burning the waste for energy which may not be approved and also raises additional environmental concerns.

INJURIES - Synthetic turf can be a harder and more abrasive surface than natural grass and many sports health professionals and players believe that it contributes to greater sports injuries.

We believe that there is a real opportunity for NSW to become a national and international leader by embracing the creation of well-designed and maintained, sustainable playing fields using natural grass.

We would welcome your comments and the opportunity to discuss our concerns with you in greater detail.

Peter Ernst, President & Joan Rowley, Vice President

on behalf of

The Committee, West Pennant Hills Valley Progress Association

Email: wphvpa@gmail.com

Website: wphvpa.org

2021-06-04 WPHVPA Submission to the DPIE Synthetic Turf Study

(limited to a maximum of 500 words)

We agree that prioritising participation in active and passive recreation has enormous benefits for us all and understand that there is an increasing demand for recreational spaces placing pressure on our existing natural fields.

However, we have serious environmental and public health concerns about achieving this goal through replacing natural grass with synthetic turf. Given the real possibility of negative outcomes arising from the use of synthetic turf and the lack of facts about its long-term effects, we believe that we should embrace the precautionary principle and stop its use in NSW.

Some of the significant problems that cause us to object to the use of synthetic turf are summarised below.

TEMPERATURE– we have measured local synthetic turf playing fields exceeding 80 degrees C, and 20 to 50 degrees C above natural grass in hot weather. Users, particularly children, can suffer from heat stress.

MICROPLASTIC POLLUTION - Plastic particles from 5mm down to microscopic levels are seen as one of the greatest environmental burdens and threats today. These particles, found throughout our environment, especially oceans, are now in our food chain and have been reported in human stool samples.

Globally governments and industry are working to dramatically remove plastic from the environment. Plastic playing fields shed microplastics into the environment from both the plastic turf fibres and its infill, usually artificial rubber or plastic. These microplastics pollute water catchments and the ocean.

Pollutants in the marine environment will adhere to microplastic particles increasing the potential for damage to the environment and the planet’s food chains.

Some studies have shown that microscopic particles generated from plastic playing fields can form a respirable dust ready to be inhaled by children using the field.

CHEMICAL POLLUTION – The plastics used in the fibres and the usually synthetic in-fills are created from petrochemicals and contain many toxic chemicals including known carcinogens which will be leached, outgassed and physically broken off and swept into the environment.

The plastics used in playing fields have been shown at times to contain PFAS and lead. Given our global concerns about the environmental and health effects of these contaminants we need to understand how plastic fields may or may not contribute to this environmental burden.

END OF LIFE DISPOSAL – Depending on the level of usage and maintenance, synthetic turf will need replacing after 8 to 15 years. There is no infrastructure in place to recycle the plastic. The plastic will be too dirty to recycle without some significant cleaning. Any cleaning solutions used are likely to become heavily contaminated with microplastics and will become a significant environmental issue in themselves. Landfill is still looking as the most likely end for a plastic field where it will continue to shed microplastics and chemicals into the environment.

INJURIES – Synthetic turf can be a harder and more abrasive surface than natural grass and many sports health professionals and players believe that it contributes to greater sports injuries.

We need to look at how more sustainable playing fields can be created using natural grass.  

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2021-06-04 Submission to the DPIE Synthetic Turf Study

This is a personal submission from the Vice-President of West Pennant Hills Valley Progress Association.

I object to the use of artificial turf on environmental grounds.  Plastic playing fields are yet another example of how technological solutions can appear to succeed, but only at the cost of seriously polluting our environment.

Depending on usage and maintenance, most synthetic surfaces need replacing every 8-15 years, and currently there are no recycling facilities in NSW.

For every synthetic sportsfield, there are the equivalent of 30 million single-use plastic bags going to landfill every 8-15 years, plus the equivalent of another half million bags leeching into the environment every year.

In 2019, The Hills Shire Council (THSC) proposed using artificial turf for a site in my suburb.   Also in 2019, there was much discussion about banning the use of single-use plastic bags.  That prompted me to investigate the plastic bag equivalent of a synthetic playing field.

A useful resource for the calculation was a report on the FIFA website ‘ENVIRONMENTAL IMPACT STUDY ON ARTIFICIAL FOOTBALL TURF’.   See FIFA EIS on Artificial Turf 

The results of my investigations were as follows:

·        The blades, backing and infill of a new synthetic pitch are equivalent to nearly 30 million single-use plastic bags (this excludes any plastic used in shockpad or underlay);

·        The average amount of infill escaping each year from one synthetic pitch is equivalent to around half a million single-use plastic bags.  This infill pollutes the soil and our waterways, and enters the food chain.

These calculations are based on the following assumptions:

·        Pitch size of 72m x 106m (as proposed by THSC)

·        Average weight of a single-use plastic bag is 5g

·        Average amount of infill lost and replaced each year is 2.5% of total (derived from FIFA report)

·        Average combined weight of blades, backing and infill is 18.6kg/sqm (derived from FIFA report)

We don’t need more landfill and more pollution.  A natural turf playing field constructed with good drainage is the obvious choice for our sporting venues. 

FIFA EIS on Artificial Turf A report commissioned by FIFA that studies the environmental impact of synthetic turf.
https://www.safehealthyplayingfields.org/  A very complete web page from an American group that discusses all aspects of comparing grass and plastic fields including costs, maintenance, environmental and health issues as well as current law suits etc.
http://www.kimointernational.org/feature/microplastic-pollution-from-artificial-grass-a-field-guide  A very good summary of microplastic pollution from playing fields produced by KIMO a Scandinavian association for sustainable seas
https://www.illawarramercury.com.au/story/5422307/fears-uows-synthetic-football-pitch-will-be-an-environmental-disaster/  An Australian perspective regarding plans to use synthetic playing fields by the Uni of Wollongong and Wollongong council.
http://theconversation.com/why-artificial-turf-may-truly-be-bad-for-kids-72044  A short summary by an environmental scientist covering many of the concerns.