Item E-1 Agenda Report — Beverly Hills City Council, July 15, 2025 (part 1 of 2)

AGENDA REPORT
Meeting Date: July 15, 2025
Item Number:

To: Honorable Mayor & City Council
From: Patrick Achis, Associate Planner
Chloe Chen, Principal Planner
Masa Alkire, AICP, Assistant Director of Community
Development/City Planner
Subject: AN ORDINANCE OF THE CITY OF BEVERLY HILLS AMENDING THE

BEVERLY HILLS MUNICIPAL CODE TO REPEAL RESIDENTIAL
FRONT YARD SYNTHETIC TURF ALLOWANCES, ADOPT A 15-YEAR

PHASE-OUT (AMORTIZATION) PERIOD FOR THE REMOVAL OF

EXISTING PERMITTED FRONT YARD SYNTHETIC TURF

INSTALLATIONS AND FIND THE ORDINANCE EXEMPT FROM THE

CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA)
Attachments: 1. Draft Ordinance

2. Planning Commission Resolution No. 2087

3. Summary of Synthetic Turf Regulations

4. Redline BHMC – Proposed Changes to Existing Residential Synthetic Turf Regulations

5. Staff Reports from the May 22, January 30 & 14, 2025 Planning Commission Meetings (without Attachments)

6. General Plan Goals and Policies

7. Public Correspondence

RECOMMENDATION
Staff recommends that the City Council waive the full reading and introduce by title only the ordinance entitled: “AN ORDINANCE OF THE CITY OF BEVERLY HILLS AMENDING

THE BEVERLY HILLS MUNICIPAL CODE TO REPEAL RESIDENTIAL FRONT YARD SYNTHETIC TURF ALLOWANCES, ADOPT A 15-YEAR PHASE-OUT
(AMORTIZATION) PERIOD FOR THE REMOVAL OF EXISTING PERMITTED FRONT

YARD SYNTHETIC TURF INSTALLATIONS AND FIND THE ORDINANCE EXEMPT FROM THE CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA)” (Attachment 1).

Meeting Date: July 15, 2025

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INTRODUCTION
The proposed amendments to the Beverly Hills Municipal Code (BHMC):

1. Prohibit new installations of synthetic turf in required residential front yards (in both single- and multi-family residential zones), consistent with Senate Bill 676 (Allen, effective 2024), which restores local authority to regulate or ban synthetic turf; and

2. Require the removal of existing permitted synthetic turf in required residential front yards within 15 years of the ordinance’s effective date.

These changes do not affect synthetic turf installations in residential side, street side, or rear yards and maintain the existing prohibition on synthetic turf within public rights-of-way and parkways.

BACKGROUND
Legislative Context
Historically, Beverly Hills has prohibited the use of synthetic turf in residential front yards and allowed its use only in areas not visible from the public right-of-way (e.g., side and rear yards).1In 2015, amid statewide drought conditions, the City Council adopted Ordinance No. 15-O-2691 permitting synthetic turf installations in residential front yards as a water conservation measure. That same year, Assembly Bill 1164 (Gatto, 2015) was enacted requiring cities to allow synthetic turf. However, Senate Bill 676 (Allen, 2023), effective January 1, 2024, restored local authority to regulate or ban synthetic turf. This provides an opportunity for the City to reconsider its synthetic turf regulations.

Existing Synthetic Turf Regulations
The BHMC currently requires residential front yards to be landscaped primarily with live plants for areas that are not hardscaped as paths of travel or driveways. Synthetic turf is not classified as live landscaping. However, during Stage D drought conditions, a property owner may submit an over-the-counter permit to cover up to 40% of a front yard with synthetic turf, subject to installation, material, and maintenance standards. Additionally, synthetic turf cannot exceed 70% of the required live landscape area. Observations indicate synthetic turf is typically used as an accent rather than a full landscape replacement, and Code Enforcement records show few maintenance or blight complaints.

Attachment 3 provides a summary of the City’s existing synthetic turf regulations.

Planning Commission Recommendation
On May 22, 2025, the Planning Commission considered the proposed amendments and adopted PC Resolution No. 2087 (Attachment 2), recommending that the City Council adopt the draft ordinance. The Commission cited multiple benefits of the proposed ban on synthetic turf such as encouraging water conservation with natural planting and landscaping, preserving the garden quality of the residential areas, , and supporting the City’s sustainability goals. Redline changes to the City’s existing residential synthetic turf regulations are in Attachment 4. Additional background, including recent state law, local installation trends, and comparisons between synthetic turf and natural landscaping alternatives can be found in Attachment 5.

1 The BHMC defines Synthetic Turf as “synthetic manmade material that simulates the appearance of live sod, grass or lawn.” Front yard means “that portion of a site area located between the front setback line and the front lot line.”
Meeting Date: July 15, 2025

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Public Comment
The Planning Commission received several written and oral comments both in support of and opposition to a potential prohibition on synthetic turf in residential front yards. A representative from a synthetic turf company stated that newer or proprietary turf materials may address certain environmental and public health concerns associated with older products. Staff has also received supplemental reports from the above-mentioned turf company representative opposing the ordinance, and a non-profit organization in support of the ordinance supporting it regarding environmental and health considerations.

Previous public correspondence, which address similar themes, is included in Attachment

7. DISCUSSION
The draft ordinance prohibits new synthetic turf installations in required residential front yards to maintain Beverly Hills’ garden-like residential character. From 2015 - 2023, the City issued 43 Artificial Turf Permits. No synthetic turf permits have been issued since SB 676 took effect on January 1, 2024, since new synthetic turf installations are only allowed during Stage D drought conditions. The draft ordinance repeals the prior allowances for synthetic turf regardless of drought condition. Importantly, the ordinance does not regulate side, street side, or rear yards, so property owners may continue to install synthetic turf in non-front yard areas. The City’s existing prohibition on synthetic turf in the public right-ofway and in City parkways also remains unchanged.

Existing Synthetic Turf Installations
For residential properties that already have permitted synthetic turf in a front yard, the ordinance provides a 15-year sunset period for its removal. During this amortization period, the synthetic turf may remain as long as it is properly maintained. The draft ordinance carries forward the requirement that synthetic turf be kept in an attractive and clean condition, and free from holes, tears, stains, discoloration, seam separations, uplifted surfaces, heat degradation, or excessive wear. A 15-year phase-out period aligns with typical eight- to 20-year product warranties. It also balances considerations of property owner investment and the City’s aesthetic and sustainability goals. Property owners may appeal to the City Council within 14 days of the sunset date to request an extension if they can demonstrate that replacing the turf would be economically unreasonable in their case.

Repair Provision
Under the draft ordinance’s phase-out provision, only minor repairs to existing turf are allowed. Repairs may cover up to 10 square feet or five percent of the front yard synthetic turf area (whichever is less). If the synthetic turf in a front yard is removed or damaged in excess of these thresholds, the ordinance requires that all the synthetic turf be removed from the front yard and that the area be re-landscaped with natural landscaping in compliance with BHMC requirements.

Clarification for Multi-Family Landscaping
BHMC §10-3-2813 currently requires landscaping in multi-family front yards indirectly through restricting paved surfaces, but does not state it outright. The draft ordinance clarifies that multi-family front yards must be landscaped with live plants, which matches single-family standards. Landscaping means live plants (trees, shrubs, lawns, and groundcover), supplemented by non-living elements like decorative rocks and fences. This definition provides a reference on what should replace synthetic turf when an existing installation is removed.

Meeting Date: July 15, 2025

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Alternatives to Synthetic Turf
Residents seeking alternatives to synthetic turf have numerous options for Californiafriendly and water-efficient plants suitable for residential front yards. These plants—which include both native and well-adapted non-native species—need minimal irrigation, support biodiversity, and complement various landscaping styles. With appropriate selection, live plantings reliably perform in deep shade, mixed exposure, and full sun. This demonstrates that synthetic turf is not the only viable option for different micro-climates. The Beverly Hills Garden Handbook (2015)2is a comprehensive landscape guide containing over 125 plant recommendations, four landscaping styles suited to prevalent architectural themes in Beverly Hills, and practical tips for selecting and placing water-saving plants.

Financial incentives and rebates are available for residents transitioning to water-efficient landscaping. Programs such as SoCal Water$mart (socalwatersmart.com) offer rebates starting at $2.00 per square foot for turf replacement. Further funding support may be available for water-efficient irrigation systems and equipment.

GENERAL PLAN POLICIES3 AND ZONE TEXT AMENDMENT FINDINGS The General Plan contains various goals and policies intended to help guide development in the City. Policies relevant to the City Council’s review of the draft ordinance and the zone text amendment findings are included as Attachment 6.

PUBLIC OUTREACH AND NOTIFICATION
Notice for this item, summarized in Table 1, was provided pursuant to the requirements set forth in BHMC §10-3-2.5, et seq. A courtesy notice was also sent to the interested parties for the topic of synthetic turf regulations and Long Range Planning topics. Two public comments received prior to agenda publication are provided in Attachment 7.

TABLE 1. PUBLIC NOTIFICATION TABLE
Notice of Public Hearing and Summary Ordinance
 Mailed Notice (500’ radius + block face; via first class mail)  On-Site Posted Notice
 Newspaper Notice
Beverly Hills Courier
Beverly Press
Not Required
Not Required
6/27/2025
7/3/2025

2 Access the Beverly Hills Garden Handbook online at: beverlyhills.org/gardenhandbook.

Additional useful landscaping resources include:
 City of Beverly Hills Water Efficient Landscaping Webpage – beverlyhills.org/welo  Be Water Wise Landscape Guide – bewaterwise.com/toolkit.html  The Drought Tolerant Garden Handbook (Los Angeles County) – https://dpw.lacounty.gov/wwd/web/Documents/DroughtTolerantGarden.pdf  California Native Plant Society – cnps.org/gardening
3 Available online at beverlyhills.org/generalplan
Meeting Date: July 15, 2025

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impact and is exempt from CEQA pursuant to Section 15305 of Title 14 of the California Code of Regulations because the Amendments represent minor alterations in land use limitations and do not result in any changes in land use or density. Further, the residential areas of the City to which the Amendments apply have an average slope of not more than 20%.

FISCAL IMPACT
There is no anticipated direct fiscal impact related to the adoption of this ordinance, which creates additional landscaping regulations. Property owners transitioning from synthetic turf to natural landscaping will go through plan check review and permitting, with fees applied per the City’s Comprehensive Schedule of Taxes, Fees, and Charges.

NEXT STEPS
If the draft ordinance is adopted as proposed, the staff will conduct outreach informing Artificial Turf Permit holders of the new regulations through mail, emails, and the City website. Notifications will explain the 15-year amortization period and identify available resources and financial incentives to support the transition to natural landscaping.

If the City Council approves substantial changes to the proposed ordinance, staff would incorporate those revisions and, if necessary, return with an updated ordinance for further consideration at a subsequent meeting.

Michael Forbes, AICP,
Director of Community Development
Approved By
Attachment 1
Draft Ordinance
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ORDINANCE NO. 25-O-_______

AN ORDINANCE OF THE CITY OF BEVERLY HILLS

AMENDING THE BEVERLY HILLS MUNICIPAL CODE TO

REPEAL RESIDENTIAL FRONT YARD SYNTHETIC TURF
ALLOWANCES, ADOPT A 15-YEAR PHASE-OUT
(AMORTIZATION) PERIOD FOR THE REMOVAL OF

EXISTING PERMITTED FRONT YARD SYNTHETIC TURF

INSTALLATIONS, AND FIND THE ORDINANCE EXEMPT

FROM THE CALIFORNIA ENVIRONMENTAL QUALITY ACT
(CEQA)
WHEREAS, in response to statewide drought conditions declared by the Governor in 2014, the City of Beverly Hills (“City”) allowed synthetic turf installations in residential front yards pursuant to Ordinance No. 15-O-2691 to promote water conservation; WHEREAS, Senate Bill 676 (Allen, 2023), effective January 1, 2024, amended California Government Code Section 53087.7, restoring local authority to regulate or prohibit synthetic turf installations, thereby enabling the City to reconsider its synthetic turf regulations;
WHEREAS, the City Council has considered repealing allowances for synthetic turf in the Beverly Hills Municipal Code (“BHMC”), consistent with General Plan goals and policies encouraging water conservation, to preserve the garden quality of the residential areas of the City, promote the use of natural planting and landscaping, and support sustainability efforts;
WHEREAS, numerous natural, native, and drought-tolerant alternatives to synthetic turf for front yard landscaping are widely available, including those documented -2-
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in the Beverly Hills Garden Handbook, which features four distinct planting style guides for prevalent architectural themes in Beverly Hills and practical tips for selecting and arranging water-saving and drought-tolerant plants;
WHEREAS, it is in the best interest of residents to establish a 15-year amortization period for removal of synthetic turf in the front yard to balance property owners’ interests by allowing a reasonable time to recover investments and transition to natural landscaping materials;
WHEREAS, the Planning Commission held duly noticed study sessions, as prescribed by law, on January 14, 2025, and January 30, 2025, at which time City staff and interested persons had an opportunity to, and did testify either in support or against this matter. At the conclusion of the January 30, 2025, Planning Commission hearing, and after due consideration of the testimony, the Planning Commission provided direction on the amendments to be included in this ordinance, including a recommendation to repeal synthetic turf allowances in residential front yards and to establish an amortization period for removing existing, permitted synthetic turf installations; WHEREAS, the Planning Commission considered this Ordinance on May 22, 2025, at a duly noticed public hearing, as prescribed by law, at which time City staff and interested persons had an opportunity to and did testify either in support or against this matter. At the conclusion of the Planning Commission hearing and after due consideration of the testimony, the Planning Commission adopted Resolution No. 2087, recommending -3-
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approval of the Ordinance by the City Council and that the City Council find the Ordinance exempt from the CEQA; and
WHEREAS, the City Council considered the Ordinance on July 15, 2025, at a duly noticed public hearing, as prescribed by law, at which time City staff and interested persons had an opportunity to and did testify either in support or against this matter. Following the public hearing, the City Council considered the entire record of information received at the public hearings before the Planning Commission and City Council.

THE CITY COUNCIL OF THE CITY OF BEVERLY HILLS HEREBY ORDAINS AS FOLLOWS:

Section 1. The City Council finds that the adoption of this Ordinance is consistent with the General Plan because it fulfills the following General Plan Goals and Policies:

1.a. Conservation (CON) Element
i. Policies CON 2.5 and CON 3.9 (Water Efficient Landscaping) encourage the installation of drought tolerant landscaping or water-efficient irrigation systems for all private and city landscaping and parkways. The amendments prioritize natural, drought-tolerant landscaping as an alternative to synthetic turf, thereby advancing the City’s long-term water conservation and sustainability objectives.

1.b. Land Use (LU) Element
i. Goal LU 2 (Community Character and Quality) calls for a built environment that is distinguished by its high level of site planning, architecture, landscape design, and sensitivity to its natural setting and history. The amendments help advance this -4-
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goal by transitioning residential front yards toward natural landscaping to preserve Beverly Hills’ garden-like residential character.
ii. Policy LU 5.1 (Neighborhood Conservation) directs for the maintenance of the uses, densities, character, amenities, and quality of the City’s residential neighborhoods, recognizing their contribution to the City’s identity, economic value, and quality of life. Removing allowances for synthetic turf reinforces neighborhood identity and character consistent with this policy.

Section 2. Section 10-3-2423.5 of Article 24 (Single-Family Residential Development Standards for the Central Area of the City) in Chapter 3 (Zoning) of Title 10 (Planning and Zoning) of the BHMC is hereby amended to read as follows:
“10-3-2423.5: PROHIBITION OF SYNTHETIC TURF IN FRONT YARDS:

A. General Prohibition: Synthetic turf is prohibited in all front yards and the public right-of-way, inclusive of the parkway.

B. Existing Synthetic Turf:

1. Synthetic turf in a front yard lawfully installed or approved under an Artificial Turf Permit and deemed complete before the effective date of this Ordinance may remain until a sunset date of September 5, 2040 if properly maintained per subsection C of this section. Any synthetic turf in a front yard not maintained in accordance with subsection C shall be subject to enforcement under title 1, chapter 3 of this code.
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2. Upon the sunset date, any remaining synthetic turf in the front yard shall be replaced with landscaping consistent with section 10-3-2423 of this chapter.

A property owner subject to the replacement obligation may appeal the replacement obligation pursuant to the provisions of Article 1 of Chapter 4 of Title 1 of the municipal code, with the 14-day appeal period commencing upon the sunset date for that property. Any such appeal shall include evidence to show that application of the replacement obligation is economically unreasonable as applied to the specific property in question. If the City Council determines that the replacement obligation is economically unreasonable as applied to the specific property based on evidence in the record, the City Council shall have the authority to grant an additional period of time before the synthetic turf must be replaced. The City shall enforce the replacement requirement pursuant to title 1, chapter 3 of this code.

C. Maintenance: Synthetic turf in a front yard shall be maintained in an attractive and clean condition pursuant to title 5, chapter 7 of this code and shall not contain holes, tears, stains, discoloration, seam separations, uplifted surfaces, heat degradation, or excessive wear.

A. General Prohibition: Synthetic turf is prohibited in all front yards and the public right-of-way, inclusive of the parkway.

B. Existing Synthetic Turf:

1. Synthetic turf in a front yard lawfully installed or approved under an Artificial Turf Permit and deemed complete before the effective date of this Ordinance may remain until a sunset date of September 5, 2040, if properly maintained per subsection C of this section. Any synthetic turf in a front yard not maintained in accordance with subsection C shall be subject to enforcement under title 1, chapter 3 of this code.

2. Upon the sunset date, any remaining synthetic turf in the front yard shall be replaced with landscaping consistent with section 10-3-2519. A property owner subject to the replacement obligation may appeal the replacement obligation pursuant to the provisions of Article 1 of Chapter 4 of Title 1 of the municipal code, with the 14-day appeal period commencing upon the sunset date for that property. Any such appeal shall -7-
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include evidence to show that application of the replacement obligation is economically unreasonable as applied to the specific property in question.

If the City Council determines that the replacement obligation is economically unreasonable as applied to the specific property based on evidence in the record, the City Council shall have the authority to grant an additional period of time before the synthetic turf must be replaced.

The City shall enforce the replacement requirement pursuant to title 1, chapter 3 of this code.

A. General Prohibition: Synthetic turf is prohibited in all front yards and the public right-of-way, inclusive of the parkway.

B. Existing Synthetic Turf:

1. Synthetic turf in a front yard lawfully installed or approved under an Artificial Turf Permit and deemed complete before the effective date of this Ordinance may remain until a sunset date of September 5, 2040 , if properly maintained per subsection C of this section. Any synthetic turf in a front yard not maintained in accordance with subsection C shall be subject to enforcement under title 1, chapter 3 of this code.

2. Upon the sunset date, any remaining synthetic turf in the front yard shall be replaced with landscaping consistent with section 10-3-2619. A property owner subject to the replacement obligation may appeal the replacement obligation pursuant to the provisions of Article 1 of Chapter 4 of Title 1 of the municipal code, with the 14-day appeal period commencing upon the sunset date for that property. Any such appeal shall include evidence to show that application of the replacement obligation is economically unreasonable as applied to the specific property in question. -9-
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If the City Council determines that the replacement obligation is economically unreasonable as applied to the specific property based on evidence in the record, the City Council shall have the authority to grant an additional period of time before the synthetic turf must be replaced.

The City shall enforce the replacement requirement pursuant to title 1, chapter 3 of this code.

D. No Reinstallation: Existing lawfully permitted synthetic turf in a front yard removed or damaged to an extent that requires repair or replacement exceeding ten (10) square feet or five percent of the total synthetic turf area, whichever is less, may not be replaced or reinstalled with synthetic turf, and all of the permitted synthetic turf shall be removed and replaced with landscaping consistent with section 10-3-2619.”
Section 5. Subsection A of Section 10-3-2813 of Article 28 (Paving of Setbacks; Multiple-Family Residential Zones) in Chapter 3 (Zoning) of Title 10 (Planning and Zoning) of the BHMC is hereby amended to read as follows, with all other provisions of Section 10-3-2813 unchanged:
“A. Except as otherwise provided in this section, all portions of a front yard within a multiple-family residential zone must be landscaped, and no portion of the front yard -10-
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shall be paved, except for not more than one walkway not exceeding five feet (5') in width and one driveway not exceeding the width of its curb cut.

For the purposes of this section, "landscaping" shall mean the development of the open space on a property with plantings, such as trees, bushes, shrubs, hedges, lawns, other live ground cover, or greenery. Landscaping may include nonliving decorative treatment, such as walls, fences, curbs, groupings of rock, or similar accent material, interspersed with plantings, but shall not include paving.”
Section 6. Section 10-3-2813.5 of Article 28 (Multiple-Family Residential Development Standards) in Chapter 3 (Zoning) of Title 10 (Planning and Zoning) of the BHMC is hereby amended to read as follows:
“10-3-2813.5: PROHIBITION OF SYNTHETIC TURF IN FRONT YARDS:

A. General Prohibition: Synthetic turf is prohibited in all front yards and the public right-of-way, inclusive of the parkway.

B. Existing Synthetic Turf:

1. Synthetic turf in a front yard lawfully installed or approved under an Artificial Turf Permit and deemed complete before the effective date of this Ordinance may remain until a sunset date of September 5. 2040, if properly maintained per subsection C of this section. Any synthetic turf in a front yard not maintained in accordance with subsection C shall be subject to enforcement under title 1, chapter 3 of this code. -11-
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The City shall enforce the replacement requirement pursuant to title 1, chapter 3 of this code.

D. No Reinstallation: Existing lawfully permitted synthetic turf in a front yard removed or damaged to an extent that requires repair or replacement exceeding ten (10) square feet or five percent of the total synthetic turf area, whichever is less, may not be replaced or reinstalled with synthetic turf, and all of the permitted -12-
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synthetic turf shall be removed and replaced with landscaping consistent with section 10-3-2813.”
Section 7. CEQA. This Ordinance and the Amendments were assessed in accordance with the authority and criteria contained in the California Environmental Quality Act (CEQA), the State CEQA Guidelines, and the environmental regulations of the City. The City Council finds that adoption of the Amendments will not have a significant environmental impact and is exempt from CEQA pursuant to Section 15305 of Title 14 of the California Code of Regulations because the Amendments represent minor alterations in land use limitations and do not result in any changes in land use or density. Further, the residential areas of the City to which the Amendments apply have an average slope of not more than 20%.

Section 8. Severability. If any section, subsection, subdivision, sentence, clause, phrase, or portion of this Ordinance or the application thereof to any person or place, is for any reason held to be invalid or unconstitutional by the final decision of any court of competent jurisdiction, the remainder of this Ordinance shall be and remain in full force and effect.

Section 9. Publication. The City Clerk shall cause this Ordinance to be published at least once in a newspaper of general circulation published and circulated in the City within fifteen (15) days after its passage in accordance with Section 36933 of the Government Code, shall certify to the adoption of this Ordinance, and shall cause this Ordinance and her certification, together with proof of publication, to be entered in the Book of Ordinances of the Council of this City.

Section 10. Effective Date. This Ordinance shall go into effect and be in full force and effect at 12:01 a.m. on the thirty-first (31st) day after its passage. The City Clerk is directed to -13-
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certify to the enactment of this Ordinance and to cause this Ordinance to be published and/or posted as required by law.

Adopted:

Effective:
____________________________
SHARONA R. NAZARIAN, PSYD
Mayor of the City of Beverly Hills,
California
ATTEST:
_____________________________(SEAL)

HUMA AHMED
City Clerk
APPROVED AS TO FORM: APPROVED AS TO CONTENT:
___________________________ _____________________________ LAURENCE S. WIENER NANCY HUNT-COFFEY
City Attorney City Manager
Attachment 2
Planning Commission
Resolution No. 2087
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RESOLUTION NO. 2087

A RESOLUTION OF THE PLANNING COMMISSION OF THE

CITY OF BEVERLY HILLS RECOMMENDING ADOPTION OF

AN ORDINANCE OF THE CITY OF BEVERLY HILLS

AMENDING THE BEVERLY HILLS MUNICIPAL CODE TO

REPEAL RESIDENTIAL FRONT YARD SYNTHETIC TURF
ALLOWANCES, ADOPT A 15-YEAR PHASE-OUT
(AMORTIZATION) PERIOD FOR THE REMOVAL OF

EXISTING PERMITTED FRONT YARD SYNTHETIC TURF

INSTALLATIONS, AND FIND THE ORDINANCE EXEMPT

FROM THE CALIFORNIA ENVIRONMENTAL QUALITY ACT
(CEQA)
WHEREAS, the Planning Commission has considered the proposed Amendments to the City of Beverly Hills Municipal Code (“BHMC”), as set forth and attached hereto as Exhibit A (the “Amendments”); and
WHEREAS, the Planning Commission conducted study sessions on January 14 and January 30, 2025, and a duly noticed public hearing on May 22, 2025, at which times it received oral and documentary evidence relative to the proposed Amendments; and WHEREAS, the Planning Commission finds that the proposed Amendments are required for the public health, safety, and general welfare, and that the Amendments are consistent with the general objectives, principles, and standards of the General Plan, including those related to encouraging water conservation, preserving the garden quality of the residential areas of the City, promoting the use of natural planting and landscaping, and supporting sustainability efforts; Docusign Envelope ID: 5F4291EC-E5C9-43C5-AB76-3F68CBCCFCE8 -2-
WHEREAS, in response to statewide drought conditions declared by the Governor in 2014, the City of Beverly Hills (“City”) allowed synthetic turf installations in residential front yards pursuant to Ordinance No. 15-O-2691 to promote water conservation; WHEREAS, Senate Bill 676 (Allen, 2023), effective January 1, 2024, amended California Government Code Section 53087.7, restoring local authority to regulate or prohibit synthetic turf installations, thereby enabling the City to reconsider its synthetic turf regulations; WHEREAS, the Planning Commission has considered the repeal of allowances for synthetic turf in the Beverly Hills Municipal Code (“BHMC”), consistent with General Plan goals and policies encouraging water conservation, preserving the garden quality of the residential areas of the City, promoting the use of natural planting and landscaping, and supporting sustainability efforts;
WHEREAS, numerous natural, native, and drought-tolerant alternatives to synthetic turf for front yard landscaping are widely available, including those documented in the Beverly Hills Garden Handbook, which features four distinct planting style guides for prevalent architectural themes in Beverly Hills and practical tips for selecting and arranging water-saving and drought tolerant plants;
WHEREAS, it is in the best interest of residents to establish a 15-year amortization period for removal of synthetic turf in the front yard to balance property owners’ interests by allowing a reasonable time to recover investments and transition to natural landscaping materials; Docusign Envelope ID: 5F4291EC-E5C9-43C5-AB76-3F68CBCCFCE8 -3-
NOW, THEREFORE, the Planning Commission of the City of Beverly Hills hereby finds, resolves, and determines as follows:

Section 1. The Planning Commission finds that the adoption of this Ordinance is consistent with the City’s General Plan because it fulfills the following Goals and Policies:

1.b. Land Use (LU) Element
i. Goal LU 2 (Community Character and Quality) calls for a built environment that is distinguished by its high level of site planning, architecture, landscape design, and sensitivity to its natural setting and history. The amendments support this goal by transitioning residential front yards toward natural landscaping to preserve Beverly Hills’ garden-like residential character.
ii. Policy LU 5.1 (Neighborhood Conservation) directs for the maintenance of the uses, densities, character, amenities, and quality of the City’s residential neighborhoods, recognizing their contribution to the City’s identity, economic value, and quality of life. Removing allowances for synthetic turf reinforces neighborhood identity and character consistent with this policy.

Docusign Envelope ID: 5F4291EC-E5C9-43C5-AB76-3F68CBCCFCE8 -4-
Section 2. The Amendments were assessed in accordance with the authority and criteria contained in the California Environmental Quality Act (CEQA), the State CEQA Guidelines, and the environmental regulations of the City. The Planning Commission recommends that the City Council find that this Ordinance will not have a significant environmental impact and is exempt from CEQA pursuant to Section 15305 of Title 14 of the California Code of Regulations because the Amendments represent minor alterations in land use limitations and do not result in any changes in land use or density. Further, the residential areas of the City to which the Amendments apply have an average slope of not more than 20%.

Section 3. The Planning Commission hereby recommends to the City Council review the ordinance approving and enacting the proposed Amendments substantially as set forth in Exhibit A, which is attached hereto and incorporated herein by reference. \\
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Section 4. The Secretary of the Planning Commission shall certify to the passage, approval, and adoption of this resolution, and shall cause this resolution and his/her Certification to be entered in the Book of Resolutions of the Planning Commission of the City.

Adopted: May 22, 2025
Jeff Wolfe
Vice Chair of the Planning Commission of
the City of Beverly Hills
Attest:

Masa Alkire, AICP
Secretary of the Planning Commission
Approved as to form: Approved as to content:

David M. Snow Masa Alkire, AICP
Assistant City Attorney Assistant Director / City Planner Community Development Department
EXHIBIT A: Draft Ordinance
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EXHIBIT A
Docusign Envelope ID: 5F4291EC-E5C9-43C5-AB76-3F68CBCCFCE8 -7-
[DRAFT] ORDINANCE NO. 25-O-_______

AN ORDINANCE OF THE CITY OF BEVERLY HILLS

AMENDING THE BEVERLY HILLS MUNICIPAL CODE TO

REPEAL RESIDENTIAL FRONT YARD SYNTHETIC TURF
ALLOWANCES, ADOPT A 15-YEAR PHASE-OUT
(AMORTIZATION) PERIOD FOR THE REMOVAL OF

EXISTING PERMITTED FRONT YARD SYNTHETIC TURF

INSTALLATIONS, AND FIND THE ORDINANCE EXEMPT

FROM THE CALIFORNIA ENVIRONMENTAL QUALITY ACT
(CEQA)
WHEREAS, in response to statewide drought conditions declared by the Governor in 2014, the City of Beverly Hills (“City”) allowed synthetic turf installations in residential front yards pursuant to Ordinance No. 15-O-2691 to promote water conservation; WHEREAS, Senate Bill 676 (Allen, 2023), effective January 1, 2024, amended California Government Code Section 53087.7, restoring local authority to regulate or prohibit synthetic turf installations, thereby enabling the City to reconsider its synthetic turf regulations;
WHEREAS, the City Council has considered repealing allowances for synthetic turf in the Beverly Hills Municipal Code (“BHMC”), consistent with General Plan goals and policies encouraging water conservation, to preserve the garden quality of the residential areas of the City, promote the use of natural planting and landscaping, and support sustainability efforts;
WHEREAS, numerous natural, native, and drought-tolerant alternatives to synthetic turf for front yard landscaping are widely available, including those documented Docusign Envelope ID: 5F4291EC-E5C9-43C5-AB76-3F68CBCCFCE8 -8-
in the Beverly Hills Garden Handbook, which features four distinct planting style guides for prevalent architectural themes in Beverly Hills and practical tips for selecting and arranging water-saving and drought-tolerant plants;
WHEREAS, it is in the best interest of residents to establish a 15-year amortization period for removal of synthetic turf in the front yard to balance property owners’ interests by allowing a reasonable time to recover investments and transition to natural landscaping materials;
WHEREAS, the Planning Commission held duly noticed study sessions, as prescribed by law, on January 14, 2025, and January 30, 2025, at which time City staff and interested persons had an opportunity to, and did testify either in support or against this matter. At the conclusion of the January 30, 2025, Planning Commission hearing, and after due consideration of the testimony, the Planning Commission provided direction on the amendments to be included in this ordinance, including a recommendation to repeal synthetic turf allowances in residential front yards and to establish an amortization period for removing existing, permitted synthetic turf installations; WHEREAS, the Planning Commission considered this Ordinance on May 22, 2025, at a duly noticed public hearing, as prescribed by law, at which time City staff and interested persons had an opportunity to and did testify either in support or against this matter. At the conclusion of the Planning Commission hearing and after due consideration of the testimony, the Planning Commission adopted Resolution No. 2087, recommending Docusign Envelope ID: 5F4291EC-E5C9-43C5-AB76-3F68CBCCFCE8 -9-
approval of the Ordinance by the City Council and that the City Council find the Ordinance exempt from the CEQA; and
WHEREAS, the City Council considered the Ordinance on _____________, 2025, at a duly noticed public hearing, as prescribed by law, at which time City staff and interested persons had an opportunity to and did testify either in support or against this matter. Following the public hearing, the City Council considered the entire record of information received at the public hearings before the Planning Commission and City Council.

THE CITY COUNCIL OF THE CITY OF BEVERLY HILLS HEREBY ORDAINS AS FOLLOWS:

Section 1. The City Council finds that the adoption of this Ordinance is consistent with the General Plan because it fulfills the following General Plan Goals and Policies:

1.b. Land Use (LU) Element
i. Goal LU 2 (Community Character and Quality) calls for a built environment that is distinguished by its high level of site planning, architecture, landscape design, Docusign Envelope ID: 5F4291EC-E5C9-43C5-AB76-3F68CBCCFCE8 -10-
and sensitivity to its natural setting and history. The amendments help advance this goal by transitioning residential front yards toward natural landscaping to preserve Beverly Hills’ garden-like residential character.
ii. Policy LU 5.1 (Neighborhood Conservation) directs for the maintenance of the uses, densities, character, amenities, and quality of the City’s residential neighborhoods, recognizing their contribution to the City’s identity, economic value, and quality of life. Removing allowances for synthetic turf reinforces neighborhood identity and character consistent with this policy.

A. General Prohibition: Synthetic turf is prohibited in all front yards and the public right-of-way, inclusive of the parkway.

B. Existing Synthetic Turf:

1. Synthetic turf in a front yard lawfully installed or approved under an Artificial Turf Permit and deemed complete before the effective date of Ordinance No. 25-O-_______ may remain until a sunset date of [15 years from the effective date of this ordinance], if properly maintained per subsection C of this section. Any synthetic turf in a front yard not maintained Docusign Envelope ID: 5F4291EC-E5C9-43C5-AB76-3F68CBCCFCE8 -11-
in accordance with subsection C shall be subject to enforcement under title 1, chapter 3 of this code.

2. Upon the sunset date, any remaining synthetic turf in the front yard shall be replaced with landscaping consistent with section 10-3-2423 of this chapter.

D. No Reinstallation: Existing lawfully permitted synthetic turf in a front yard removed or damaged to an extent that requires repair or replacement exceeding ten (10) square feet or five percent of the total synthetic turf area, whichever is Docusign Envelope ID: 5F4291EC-E5C9-43C5-AB76-3F68CBCCFCE8 -12-
less, may not be replaced or reinstalled with synthetic turf, and all of the permitted synthetic turf shall be removed and replaced with landscaping consistent with section 10-3-2423.”
Section 3. Section 10-3-2519.5 of Article 25 (Single-Family Residential Development Standards for the Hillside Area of the City) in Chapter 3 (Zoning) of Title 10 (Planning and Zoning) of the BHMC is hereby amended to read as follows:
“10-3-2519.5: PROHIBITION OF SYNTHETIC TURF IN FRONT YARDS:

A. General Prohibition: Synthetic turf is prohibited in all front yards and the public right-of-way, inclusive of the parkway.

B. Existing Synthetic Turf:

1. Synthetic turf in a front yard lawfully installed or approved under an Artificial Turf Permit and deemed complete before the effective date of Ordinance No. 25-O-_______ may remain until a sunset date of [15 years from the effective date of this ordinance], if properly maintained per subsection C of this section. Any synthetic turf in a front yard not maintained in accordance with subsection C shall be subject to enforcement under title 1, chapter 3 of this code.

2. Upon the sunset date, any remaining synthetic turf in the front yard shall be replaced with landscaping consistent with section 10-3-2519. A property owner subject to the replacement obligation may appeal the replacement obligation pursuant to the provisions of Article 1 of Chapter 4 Docusign Envelope ID: 5F4291EC-E5C9-43C5-AB76-3F68CBCCFCE8 -13-
of Title 1 of the municipal code, with the 14-day appeal period commencing upon the sunset date for that property. Any such appeal shall include evidence to show that application of the replacement obligation is economically unreasonable as applied to the specific property in question.

The City shall enforce the replacement requirement pursuant to title 1, chapter 3 of this code.

A. General Prohibition: Synthetic turf is prohibited in all front yards and the public right-of-way, inclusive of the parkway.

B. Existing Synthetic Turf:

1. Synthetic turf in a front yard lawfully installed or approved under an Artificial Turf Permit and deemed complete before the effective date of Ordinance No. 25-O-_______ may remain until a sunset date of [15 years from the effective date of this ordinance], if properly maintained per subsection C of this section. Any synthetic turf in a front yard not maintained in accordance with subsection C shall be subject to enforcement under title 1, chapter 3 of this code.

The City shall enforce the replacement requirement pursuant to title 1, chapter 3 of this code.

Docusign Envelope ID: 5F4291EC-E5C9-43C5-AB76-3F68CBCCFCE8 -16-
“A. Except as otherwise provided in this section, all portions of a front yard within a multiple-family residential zone must be landscaped, and no portion of the front yard shall be paved, except for not more than one walkway not exceeding five feet (5') in width and one driveway not exceeding the width of its curb cut.

A. General Prohibition: Synthetic turf is prohibited in all front yards and the public right-of-way, inclusive of the parkway.

B. Existing Synthetic Turf:

1. Synthetic turf in a front yard lawfully installed or approved under an Artificial Turf Permit and deemed complete before the effective date of Ordinance No. 25-O-_______ may remain until a sunset date of [15 years from the effective date of this ordinance], if properly maintained per subsection C of this section. Any synthetic turf in a front yard not Docusign Envelope ID: 5F4291EC-E5C9-43C5-AB76-3F68CBCCFCE8 -17-
maintained in accordance with subsection C shall be subject to enforcement under title 1, chapter 3 of this code.

The City shall enforce the replacement requirement pursuant to title 1, chapter 3 of this code.

D. No Reinstallation: Existing lawfully permitted synthetic turf in a front yard removed or damaged to an extent that requires repair or replacement exceeding Docusign Envelope ID: 5F4291EC-E5C9-43C5-AB76-3F68CBCCFCE8 -18-
ten (10) square feet or five percent of the total synthetic turf area, whichever is less, may not be replaced or reinstalled with synthetic turf, and all of the permitted synthetic turf shall be removed and replaced with landscaping consistent with section 10-3-2813.”
Section 7. CEQA. This Ordinance and the Amendments were assessed in accordance with the authority and criteria contained in the California Environmental Quality Act (CEQA), the State CEQA Guidelines, and the environmental regulations of the City. The City Council finds that adoption of the Amendments will not have a significant environmental impact and is exempt from CEQA pursuant to Section 15305 of Title 14 of the California Code of Regulations because the Amendments represent minor alterations in land use limitations and do not result in any changes in land use or density. Further, the residential areas of the City to which the Amendments apply have an average slope of not more than 20%.

Docusign Envelope ID: 5F4291EC-E5C9-43C5-AB76-3F68CBCCFCE8 -19-
Section 10. Effective Date. This Ordinance shall go into effect and be in full force and effect at 12:01 a.m. on the thirty-first (31st) day after its passage. The City Clerk is directed to certify to the enactment of this Ordinance and to cause this Ordinance to be published and/or posted as required by law.

Adopted:

Effective:
____________________________
SHARONA R. NAZARIAN, PSYD
Mayor of the City of Beverly Hills,
California
ATTEST:
_____________________________(SEAL)

HUMA AHMED
City Clerk
APPROVED AS TO FORM: APPROVED AS TO CONTENT:
___________________________ _____________________________ LAURENCE S. WIENER NANCY HUNT-COFFEY
City Attorney City Manager
Docusign Envelope ID: 5F4291EC-E5C9-43C5-AB76-3F68CBCCFCE8

STATE OF CALIFORNIA )
COUNTY OF LOS ANGELES ) SS.

CITY OF BEVERLY HILLS )
I, KAREN MYRON, Recording Secretary of the Planning Commission of the City of Beverly Hills, California, do hereby certify that the foregoing is a true and correct copy of Resolution No. 2087 duly passed, approved and adopted by the Planning Commission of said City at a meeting of said Commission on May 22, 2025, and thereafter duly signed by the Secretary of the Planning Commission, as indicated; and that the Planning Commission of the City consists of five (5) members and said Resolution was passed by the following vote of said Commission, to wit:

AYES: Commissioners Milkowski, Ross, Vice Chair Wolfe
NOES: None
ABSTAIN: None
ABSENT: Commissioner Demeter, Chair Kaplan
________________________________

KAREN MYRON
Recording Secretary of the
Planning Commission
City of Beverly Hills, California
Docusign Envelope ID: 5F4291EC-E5C9-43C5-AB76-3F68CBCCFCE8 Certificate Of Completion
Envelope Id: 5F4291EC-E5C9-43C5-AB76-3F68CBCCFCE8 Status: Completed Subject: Complete with Docusign: PC Reso 2087 - Draft Ordinance - Synthetic Turf Reg.pdf Source Envelope:

Document Pages: 20 Signatures: 5 Envelope Originator:

Certificate Pages: 2 Initials: 0 Karen Myron
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Time Zone: (UTC-08:00) Pacific Time (US & Canada)
455 N. Rexford Drive
Beverly Hills, CA 90210
[email protected]
IP Address: 198.245.189.166
Record Tracking
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5/29/2025 7:12:49 PM
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Jeff Wolfe
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Karen Myron
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COMM DEV COMMISSION SPECIALIST,

CD-PLANNING
City of Beverly Hills
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Attachment 3
Summary of Synthetic Turf
Regulations
Attachment 3 – Prohibition on Synthetic Turf Ordinance
City Council Regular Meeting
July 15, 2025

SUMMARY OF EXISTING SYNTHETIC TURF REGULATIONS
(BHMC §§10-3-2423.5, -2519.5, -2619.5, -2813.5; Ord. 15-O-2691) Applicability  Applies to Single- and multi-family residential zones  Permitted only during Stage D Water conservation
Coverage and
Location
 Limited to 40% of the front yard and 70% of required
landscape area
 Buffer of 18-inch from front/street property lines; 3-foot buffer from residential buildings
 Prohibited in public rights-of-way or within the dripline of any native or heritage tree
Installation  Requires professional installation
 3-inch compacted aggregate base
 Seamless and anchored turf
 Existing irrigation systems must be removed or capped Materials  No rubber infill or toxic materials
 Blades must be cut-pile infill with polyethylene or
polypropylene
 Use of at least two colors
 Blades Size - 1-¾ to 2-½ inches with a beige or tan thatch  Resistant to stain weather, rot, mildew, and fungus
 Meets federal and state safety standards
 Tuft bind – at least 8 pounds
 drainage rate - 30 inches per hour,
 durability features – tear grab strength of 200 pounds Maintenance  Free from holes
 No tears or stains
 No excessive wear
 No discoloration
 No seam separation
 No heat damage
Attachment 4
Redline BHMC - Proposed Changes
to Existing Residential Synthetic Turf
Regulations
Attachment 4 – Redline Version of BHMC (Showing Proposed Changes) City Council Regular Meeting
July 15, 2025

Page 1 of 15 ends

Added Text: Underlined in blue
Removed Text: Strikethrough in red
Unchanged Text: Black, regular font
Post-Adoption Text: Green (no underline)

AMENDMENTS TO CENTRAL AREA
- SINGLE-FAMILY DEVELOPMENT
(Article 24 of the Zoning Code)
10-3-2423.5: PROHIBITION OF SYNTHETIC TURF IN FRONT YARDS:

A. General Prohibition: Synthetic turf is prohibited in all front yards and the public rightof-way, inclusive of the parkway.

B. Existing Synthetic Turf:

1. Synthetic turf in a front yard lawfully installed or approved under an Artificial Turf Permit and deemed complete before the effective date of Ordinance No. 25-O-[ ] may remain until a sunset date of [15 years from the effective date of this ordinance], if properly maintained per subsection C of this section. Any synthetic turf in a front yard not maintained in accordance with subsection C shall be subject to enforcement under title 1, chapter 3 of this code.

2. Upon the sunset date, any remaining synthetic turf in the front yard shall be replaced with landscaping consistent with section 10-3-2423 of this chapter. A property owner subject to the replacement obligation may appeal the replacement obligation pursuant to the provisions of Article 1 of Chapter 4 of Title 1 of the municipal code, with the 14-day appeal period commencing upon the sunset date for that property. Any such appeal shall include evidence to show that application of the replacement obligation is economically unreasonable as applied to the specific property in question. If the City Council determines that the replacement obligation is economically unreasonable as applied to the specific property based on evidence in the record, the City Council shall have the authority to grant an additional period of time before the synthetic turf must be replaced. The City shall enforce the replacement requirement pursuant to title 1, chapter 3 of this code.

Page 2 of 15 ends

reinstalled with synthetic turf, and all of the permitted synthetic turf shall be removed and replaced with landscaping consistent with section 10-3-2423.

Synthetic turf shall be allowed as landscaping for the purposes of this article provided that the following provisions are satisfied for synthetic turf placed in front yards:

A. Stage D Required: Applications for the use of synthetic turf may only be approved, and permits for installation may only be issued when the City Council has declared and implemented stage D water conservation measures. Synthetic turf that is legally installed during stage D declared periods may be retained thereafter, even if the City Council withdraws the stage D declaration, provided the synthetic turf is maintained in accordance with all applicable standards.

B. Permit Required: A building permit must be obtained prior to the installation of any synthetic turf in the front yard. Upon application for a building permit the following shall be submitted to the Community Development Department:

1. A landscape plan that includes:
a. Dimensions and details of the landscaped area including the synthetic turf and other landscaping materials.
b. Drawings that include scaled cross sections of the proposed landscaping materials and details showing the methods of installation and attachment of the synthetic turf as well as drainage information.

2. Material description including manufacturer's product data, specifications and installation instructions, installer information and qualifications, and warranty information.

3. A sample of the proposed synthetic turf material that is at least twelve inches by twelve inches (12" x 12").

4. Maintenance information for the synthetic turf.

C. Coverage: Synthetic turf located in the front yard may be used for up to seventy percent (70%) of the landscaped area but no more than forty percent (40%) of the entire front yard area. Synthetic turf shall not be located:

1. Within the public right of way/parkway.

2. Within the dripline of any native or "heritage tree" as defined in section 10-3- 2900 of this chapter. Further, the installation of turf shall not disturb the area within the dripline of any native or heritage tree.

3. Within eighteen inches (18") of a front lot line. The eighteen inch (18") buffer between the front lot line and synthetic turf shall be landscaped with living plant material.

4. Within three feet (3') of a single-family residence.

Attachment 4 – Redline Version of BHMC (Showing Proposed Changes) City Council Regular Meeting
July 15, 2025

Page 3 of 15 ends

5. In any area that is used for the parking or driving of motor vehicles.

D. Material: Synthetic turf in a front yard must simulate the appearance of natural live grass and shall:

1. Be of a type known as cut-pile infill with parallel long slit blades. The long slit blades shall be manufactured from polyethylene or polypropylene. The minimum pile length shall be one and three-fourths inches (13/4") and the maximum pile length shall be two and one-half inches (21/2"). The turf shall contain a beige or tan thatch layer. The synthetic turf blades (not including the thatch layer) shall be required to contain at least two (2) colors. The synthetic turf shall comply with all federal and state standards related to lead and heavy metal content. Turf that is made from recycled materials is encouraged.

The use of indoor or outdoor plastic or nylon carpeting is prohibited.

2. Be constructed to maximize dimensional stability, resist damage during normal use and to minimize UV degradation. Further, the synthetic turf shall be resistant to staining, weather, insects, rot, mildew and fungus growth, and shall be nonallergenic and nontoxic.

3. Contain an infill material of clean silica sand or zeolite material that is brushed into the synthetic turf to keep the blades upright and achieve a natural grass look. Any replacement infill shall be silica sand or zeolite material. Rubber infill is prohibited.

4. Be affixed to a permeable triple layer primary backing with a tuft bind strength of at least eight (8) pounds. The backing shall allow water to percolate through the synthetic turf at a drain rate of at least thirty inches (30") per hour. The synthetic turf system shall allow for the free movement and drainage of water through the system to prevent runoff, pooling, and flooding.

5. Have a manufacturer's warranty lasting at least eight (8) years.

6. Have spacing between tufting rows (gauge) of no more than three-eighths inch (
3 /8") as defined by the manufacturer.

7. Have a face weight of at least sixty (60). The "face weight" is defined as the weight in ounces of the synthetic turf fibers found in one square yard of synthetic turf as defined by the manufacturer.

8. Have tear grab strength of at least two hundred (200) pounds.

9. Pass the pill burn test for flammability (ASTM D2859).

E. Installation: Synthetic turf shall be installed pursuant to manufacturer's requirements by licensed professionals who are experienced and trained by the manufacturer in the installation of the synthetic turf. In addition:

1. The synthetic turf shall be installed over at least three inches (3") of a compacted aggregate base that provides adequate drainage. The base material shall be installed over Attachment 4 – Redline Version of BHMC (Showing Proposed Changes) City Council Regular Meeting
July 15, 2025

Page 4 of 15 ends

subgrade that is compacted to a firm condition to ensure stability and maintain adequate drainage.

2. Seams shall not be visible and shall be fastened in a manner that ensures they are firm, tight and permanent. Seams shall be sewn and fibers shall be brushed to provide full coverage of the fibers over the seams.

3. The synthetic turf shall be anchored over the entire coverage area and shall be installed with a nailer board or any such substitute recommended by the manufacturer intended to conceal edges and ensure proper anchoring of turf.

4. All existing irrigation infrastructure in the synthetic turf area including piping and sprinkler heads that are no longer used must be capped or removed and shall not be visible.

5. All reasonable efforts shall be made to protect existing trees and tree roots from damage during installation.

F. Maintenance: Synthetic turf shall be maintained in an attractive and clean condition pursuant to title 5, chapter 7 of this code and shall not contain holes, tears, stains, discoloration, seam separations, uplifted surfaces, heat degradation, or excessive wear.

AMENDMENTS TO THE HILLSIDE AREA
- SINGLE-FAMILY DEVELOPMENT
(Article 25 of the Zoning Code)
10-3-2519.5: PROHIBITION OF SYNTHETIC TURF IN FRONT YARDS:

A. General Prohibition: Synthetic turf is prohibited in all front yards and the public rightof-way, inclusive of the parkway.

B. Existing Synthetic Turf:

1. Synthetic turf in a front yard lawfully installed or approved under an Artificial Turf Permit and deemed complete before the effective date of Ordinance No. 25- O-[ ] may remain until a sunset date of [15 years from the effective date of this ordinance], if properly maintained per subsection C of this section. Any synthetic turf in a front yard not maintained in accordance with subsection C shall be subject to enforcement under title 1, chapter 3 of this code.

2. Upon the sunset date, any remaining synthetic turf in the front yard shall be replaced with landscaping consistent with section 10-3-2519. A property owner subject to the replacement obligation may appeal the replacement obligation Attachment 4 – Redline Version of BHMC (Showing Proposed Changes) City Council Regular Meeting
July 15, 2025

Page 5 of 15 ends

pursuant to the provisions of Article 1 of Chapter 4 of Title 1 of the municipal code, with the 14-day appeal period commencing upon the sunset date for that property. Any such appeal shall include evidence to show that application of the replacement obligation is economically unreasonable as applied to the specific property in question. If the City Council determines that the replacement obligation is economically unreasonable as applied to the specific property based on evidence in the record, the City Council shall have the authority to grant an additional period of time before the synthetic turf must be replaced. The City shall enforce the replacement requirement pursuant to title 1, chapter 3 of this code.

Synthetic turf shall be allowed as landscaping for the purposes of this article provided that the following provisions are satisfied for synthetic turf in front yards:

B. Permit Required: A building permit must be obtained prior to the installation of any synthetic turf in the front yard of a residentially zoned property. Upon application for a building permit the following shall be submitted to the Community Development Department:

Attachment 4 – Redline Version of BHMC (Showing Proposed Changes) City Council Regular Meeting
July 15, 2025

Page 6 of 15 ends

2. Material description including manufacturer's product data, specifications and installation instructions, installer information and qualifications, and warranty information.

3. A sample of the proposed synthetic turf material that is at least twelve inches by twelve inches (12" x 12").

4. Maintenance information for the synthetic turf.

1. Within the public right-of-way/parkway.

3. Within eighteen inches (18") of a front lot line. The eighteen inch (18") buffer between the front lot line and synthetic turf shall be landscaped with living plant material.

4. Within three feet (3') of a single-family residence.

5. In any area that is used for the parking or driving of motor vehicles.

D. Material: Synthetic turf in a front yard must simulate the appearance of natural live grass and shall:

1. Be of a type known as cut-pile infill with parallel long slit blades. The long slit blades shall be manufactured from polyethylene or polypropylene. The minimum pile length shall be one and three-fourths inches (13/4") and the maximum pile length shall be two and one-half inches (21/2"). The turf shall contain a beige or tan thatch layer. The synthetic turf blades (not including the thatch layer) shall be required to contain at least two (2) colors. The synthetic turf shall comply with all Federal and State standards related to lead and heavy metal content. Turf that is made from recycled materials is encouraged. The use of indoor or outdoor plastic or nylon carpeting is prohibited.

4. Be affixed to a permeable triple layer primary backing with a tuft bind strength of at least eight (8) pounds. The backing shall allow water to percolate through the synthetic Attachment 4 – Redline Version of BHMC (Showing Proposed Changes) City Council Regular Meeting
July 15, 2025

Page 7 of 15 ends

turf at a drain rate of at least thirty inches (30") per hour. The synthetic turf system shall allow for the free movement and drainage of water through the system to prevent runoff, pooling, and flooding.

5. Have a manufacturer's warranty lasting at least eight (8) years.

6. Have spacing between tufting rows (gauge) of no more than three-eighths inch (3/8") as defined by the manufacturer.

8. Have tear grab strength of at least two hundred (200) pounds.

9. Pass the pill burn test for flammability (ASTM D2859).

1. The synthetic turf shall be installed over at least three inches (3") of a compacted aggregate base that provides adequate drainage. The base material shall be installed over subgrade that is compacted to a firm condition to ensure stability and maintain adequate drainage.

4. All existing irrigation infrastructure in the synthetic turf area including piping and sprinkler heads that are no longer used must be capped or removed and shall not be visible.

5. All reasonable efforts shall be made to protect existing trees and tree roots from damage during installation.

F. Maintenance: Synthetic turf shall be maintained in an attractive and clean condition pursuant to title 5, chapter 7 of this Code and shall not contain holes, tears, stains, discoloration, seam separations, uplifted surfaces, heat degradation, or excessive wear.

Attachment 4 – Redline Version of BHMC (Showing Proposed Changes) City Council Regular Meeting
July 15, 2025

Page 8 of 15 ends

AMENDMENTS TO TROUSDALE ESTATES
- SINGLE-FAMILY DEVELOPMENT
(Article 26 of the Zoning Code)
10-3-2619.5: PROHIBITION OF SYNTHETIC TURF IN FRONT YARDS:

A. General Prohibition: Synthetic turf is prohibited in all front yards and the public rightof-way, inclusive of the parkway.

B. Existing Synthetic Turf:

1. Synthetic turf in a front yard lawfully installed or approved under an Artificial Turf Permit and deemed complete before the effective date of Ordinance No. 25- O-[ ] may remain until a sunset date of [15 years from the effective date of this ordinance], if properly maintained per subsection C of this section. Any synthetic turf in a front yard not maintained in accordance with subsection C shall be subject to enforcement under title 1, chapter 3 of this code.

2. Upon the sunset date, any remaining synthetic turf in the front yard shall be replaced with landscaping consistent with section 10-3-2619. A property owner subject to the replacement obligation may appeal the replacement obligation pursuant to the provisions of Article 1 of Chapter 4 of Title 1 of the municipal code, with the 14-day appeal period commencing upon the sunset date for that property. Any such appeal shall include evidence to show that application of the replacement obligation is economically unreasonable as applied to the specific property in question. If the City Council determines that the replacement obligation is economically unreasonable as applied to the specific property based on evidence in the record, the City Council shall have the authority to grant an additional period of time before the synthetic turf must be replaced. The City shall enforce the replacement requirement pursuant to title 1, chapter 3 of this code.

Synthetic turf shall be allowed as landscaping for the purposes of this article provided that the following provisions are satisfied for synthetic turf in front yards:

Attachment 4 – Redline Version of BHMC (Showing Proposed Changes) City Council Regular Meeting
July 15, 2025

Page 9 of 15 ends

A. Stage D Required: Applications for the use of synthetic turf may only be approved, and permits for installation may only be issued when the city council has declared and implemented stage D water conservation measures. Synthetic turf that is legally installed during stage D declared periods may be retained thereafter, even if the city council withdraws the stage D declaration, provided the synthetic turf is maintained in accordance with all applicable standards.

2. Material description including manufacturer's product data, specifications and installation instructions, installer information and qualifications, and warranty information.

3. A sample of the proposed synthetic turf material that is at least twelve inches by twelve inches (12" x 12").

4. Maintenance information for the synthetic turf.

1. Within the public right of way/parkway.

3. Within eighteen inches (18") of a front lot line. The eighteen inch (18") buffer between the front lot line and synthetic turf shall be landscaped with living plant material.

4. Within three feet (3') of a single-family residence.

5. In any area that is used for the parking or driving of motor vehicles.

D. Material: Synthetic turf in a front yard must simulate the appearance of natural live grass and shall:

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The use of indoor or outdoor plastic or nylon carpeting is prohibited.

5. Have a manufacturer's warranty lasting at least eight (8) years.

6. Have spacing between tufting rows (gauge) of no more than three-eighths inch (
3 /8") as defined by the manufacturer.

8. Have tear grab strength of at least two hundred (200) pounds.

9. Pass the pill burn test for flammability (ASTM D2859).

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4. All existing irrigation infrastructure in the synthetic turf area including piping and sprinkler heads that are no longer used must be capped or removed and shall not be visible.

5. All reasonable efforts shall be made to protect existing trees and tree roots from damage during installation.

AMENDMENTS TO MULTI-FAMILY DEVELOPMENT
(Article 28 of the Zoning Code)
10-3-2813: PAVING OF SETBACKS; MULTIPLE-FAMILY RESIDENTIAL ZONES:

A. Except as otherwise provided in this section, all portions of a front yard within a multiple-family residential zone must be landscaped, and no portion of any front yard within a multiple-family residential zone shall be paved, except for not more than one walkway not exceeding five feet (5') in width and one driveway not exceeding the width of its curb cut.

B. Notwithstanding subsection A of this section, more than one walkway of up to five feet (5') in width may be paved in a front yard to provide equivalent access to a building in accordance with the requirements of local, state, and federal handicapped accessibility laws provided that such additional walkways are necessary because handicapped accessibility requirements cannot reasonably be met without the provision of such additional walkways.

C. Notwithstanding subsection A of this section, a reviewing authority may permit more than one walkway of up to five feet (5') in width to be paved within a front yard Attachment 4 – Redline Version of BHMC (Showing Proposed Changes) City Council Regular Meeting
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pursuant to an R-4 permit as provided in article 28.5 of this chapter if: 1) the walkway provides direct access to the primary entryway of an individual unit within a building, and 2) the reviewing authority finds that the proposal would not significantly and adversely affect the streetscape, including opportunities for landscaping.

D. Notwithstanding subsection A of this section, a reviewing authority may grant the equivalent of one five foot (5') wide walkway in the front yard per fifty feet (50') of frontage along the front lot line of the subject site pursuant to an R-4 permit as provided in article 28.5 of this chapter if the reviewing authority finds that the proposal is compatible with the nearby streetscape and the scale of the surrounding development. For the purposes of this subsection, any fraction in excess of a multiple of fifty feet (50') of frontage shall be rounded down. Not more than one walkway shall exceed a width of five feet (5'), and such walkway shall not exceed a width of fifteen feet (15').

E. Notwithstanding subsection A of this section, the planning commission may grant the equivalent of one 5-foot wide walkway in the front yard per fifty feet (50') of frontage along the front lot line of the subject site, in any configuration, pursuant to an R-4 permit as provided in article 28.5 of this chapter, if the planning commission finds that the proposal is compatible with the nearby streetscape and the scale of the surrounding development. For the purposes of this subsection, any fraction in excess of a multiple of fifty feet (50') of frontage shall be rounded down.
10-3-2813.5: PROHIBITION OF SYNTHETIC TURF IN FRONT YARDS:

A. General Prohibition: Synthetic turf is prohibited in all front yards and the public rightof-way, inclusive of the parkway.

B. Existing Synthetic Turf:

1. Synthetic turf in a front yard lawfully installed or approved under an Artificial Turf Permit and deemed complete before the effective date of Ordinance No. 25- O-[ ] may remain until a sunset date of [15 years from the effective date of this ordinance], if properly maintained per subsection C of this section. Any synthetic turf in a front yard not maintained in accordance with subsection C shall be subject to enforcement under title 1, chapter 3 of this code.

2. Upon the sunset date, any remaining synthetic turf in the front yard shall be replaced with landscaping consistent with section 10-3-2813. A property owner subject to the replacement obligation may appeal the replacement obligation pursuant to the provisions of Article 1 of Chapter 4 of Title 1 of the municipal code, with the 14-day appeal period commencing upon the sunset date for that property. Any such appeal shall include evidence to show that application of the replacement obligation is economically unreasonable as applied to the specific property in question. If the City Council determines that the replacement obligation is economically unreasonable as applied to the specific property based on evidence in the record, the City Council shall have the authority to grant an Attachment 4 – Redline Version of BHMC (Showing Proposed Changes) City Council Regular Meeting
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additional period of time before the synthetic turf must be replaced. The City shall enforce the replacement requirement pursuant to title 1, chapter 3 of this code.

Synthetic turf shall be allowed as landscaping for the purposes of this article provided that the following provisions are satisfied for synthetic turf placed in front yards:

B. Permit Required: A building permit must be obtained prior to the installation of any synthetic turf in the front yard visible from the public right of way of a residentially zoned property. Upon application for a building permit the following shall be submitted to the community development department:

2. Material description including manufacturer's product data, specifications and installation instructions, installer information and qualifications, and warranty information.

3. A sample of the proposed synthetic turf material that is at least twelve inches by twelve inches (12" x 12").

4. Maintenance information for the synthetic turf.

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1. Within the public right of way/parkway.

3. Within eighteen inches (18") of a front lot line. The eighteen inch (18") buffer between the front lot line and synthetic turf shall be landscaped with living plant material.

4. Within three feet (3') of a multiple-family dwelling.

5. In any area that is used for the parking or driving of motor vehicles.

D. Material: Synthetic turf in a front yard must simulate the appearance of natural live grass and shall:

The use of indoor or outdoor plastic or nylon carpeting is prohibited.

5. Have a manufacturer's warranty lasting at least eight (8) years.

6. Have spacing between tufting rows (gauge) of no more than three-eighths inch (
3 /8") as defined by the manufacturer.

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8. Have tear grab strength of at least two hundred (200) pounds.

9. Pass the pill burn test for flammability (ASTM D2859).

4. All existing irrigation infrastructure in the synthetic turf area including piping and sprinkler heads that are no longer used must be capped or removed and shall not be visible.

5. All reasonable efforts shall be made to protect existing trees and tree roots from damage during installation.

Attachment 5
Staff Reports from the May 22,
January 30 & 14, 2025 Planning
Commission Meetings
(Without Attachments)
City of Beverly Hills
Planning Division
455 N. Rexford Drive Beverly Hills, CA 90210
TEL. (310) 285-1141 FAX. (310) 858-5966
Planning Commission Report
Attachments:

A. Draft Resolution (Exhibit A: Draft Ordinance)
B.

Required Zone Text Amendment Findings
Staff Reports from the January 14 and 30, 2025, Planning Commission Study Session (without Attachments)
D. Redline BHMC – Proposed Changes to Existing Residential Synthetic Turf Regulations
E. General Plan Goals and Policies
F. Public Correspondence
G. Previous Public Correspondence
(January 14 & January 30 Study Sessions)
Report Author and Contact Information:

Patrick Achis, Associate Planner
(310) 285-1129
[email protected]
Meeting Date: May 22, 2025
Subject: A DRAFT ORDINANCE OF THE CITY OF BEVERLY HILLS

AMENDING THE BEVERLY HILLS MUNICIPAL CODE TO

REPEAL RESIDENTIAL FRONT YARD SYNTHETIC TURF
ALLOWANCES, ADOPT A 15-YEAR PHASE-OUT
(AMORTIZATION) PERIOD FOR THE REMOVAL OF EXISTING

PERMITTED FRONT YARD SYNTHETIC TURF INSTALLATIONS,

AND FIND THE ORDINANCE EXEMPT FROM THE CALIFORNIA

ENVIRONMENTAL QUALITY ACT (CEQA)
The Planning Commission will consider a draft ordinance to amend the City’s regulations to prohibit synthetic turf in required residential front yard areas. The ordinance would phase out existing permitted synthetic turf installations over a 15-year period and encourage drought-tolerant planting alternatives.

Project Applicant: City-Initiated
Recommendation: Conduct a public hearing and adopt a resolution recommending the adoption of the draft ordinance to the City Council; and finding the project exempt from further review under CEQA.

REPORT SUMMARY
This report presents proposed amendments to the Beverly Hills Municipal Code (BHMC) regarding synthetic turf installations in residential front yards. The amendments reflect Planning Commission direction and include:

1. A prohibition on new installations of synthetic turf in required residential front yards (including both single- and multi-family residential zones), consistent with Senate Bill 676 (Allen, effective 2024), which restores local authority to regulate or ban synthetic turf; and

2. A requirement to remove existing permitted synthetic turf in required residential front yards within 15 years of the ordinance’s effective date.

These changes do not affect synthetic turf installations in residential side or rear yards and maintain existing prohibitions on synthetic turf in public rights-of-way and parkways.

Following the Planning Commission’s review and recommendation, the draft ordinance will be considered for adoption by the City Council.
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BACKGROUND
The BHMC defines Synthetic Turf as “synthetic manmade material that simulates the appearance of live sod, grass or lawn.” Front yard means “that portion of a site area located between the front setback line and the front lot line.”
Historically, Beverly Hills prohibited synthetic turf in residential front yards and allowed it only in areas not visible from the public right-of-way (e.g., side and rear yards). In 2015, responding to statewide drought conditions, the City Council adopted Ordinance No. 15-O-2691 permitting synthetic turf installations in residential front yards to promote water conservation. Assembly Bill 1164 (Gatto, 2015) further required cities to allow synthetic turf as a drought response measure.

However, Senate Bill 676 (Allen, 2023), effective January 1, 2024, restores local authority to regulate or prohibit synthetic turf installations and allows the City to reconsider its synthetic turf regulations.

Planning Commission Recommendation
At its January 30, 2025, study session, the Planning Commission considered the staff report and public testimony and directed staff to draft an ordinance to repeal residential front yard synthetic turf allowances and implement an amortization period for removing existing, permitted installations (Attachment A, Exhibit A). The purpose of the draft ordinance is to encourage water conservation, preserve the garden quality of the residential areas, promote natural planting and landscaping, and support the City’s sustainability goals.

Additional background, including recent state law, local installation trends, and comparisons between synthetic turf and natural landscaping alternatives can be found in Attachment C (Staff Reports from the January 14 and 30, 2025, Planning Commission Study Session). Redline changes to the City’s existing residential synthetic turf regulations are in Attachment D.

Public Comment
During study sessions on January 14 and January 30, 2025, the Planning Commission received several written and oral comments both in support of and opposition to a potential prohibition on synthetic turf in residential front yards. At the January 30 session, a representative from a synthetic turf company stated that newer or patented turf materials may address certain environmental and public health concerns. Although scientific studies have raised questions about potential environmental and health impacts associated with synthetic turf, research into these topics remains ongoing. Staff has also received reports and other information regarding environmental and health considerations from the same synthetic turf company representative (opposing the ordinance) and a non-profit organization (supporting it), included as public correspondence in Attachment F.

DISCUSSION
Overall, the draft ordinance advances the City’s sustainability goals and water conservation objectives. It is also in accordance with Beverly Hills Municipal Code (BHMC) requirements for maintaining the garden quality character of the City’s residential neighborhoods. If the ordinance is adopted, staff will periodically notify Artificial Turf Permit holders about the regulation changes, 15-year sunset date, and the available resources to aid in transitioning to drought-tolerant plants.

Permitted synthetic turf remaining on residential front yards after the sunset date would be subject to code enforcement.
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Proposed Regulations
Prohibition on Residential Front Yard Synthetic Turf
The draft ordinance prohibits new synthetic turf installations in required residential front yards to maintain Beverly Hills’ garden-like residential character. The current regulations, established as a drought measure in 2015, allowed synthetic turf for a portion of a residential front yard only during a Stage D water conservation event. Since 2015, the City has approved a total of 43 Artificial Turf Permits, five of which were issued in 2023. As of 2024, consistent with Senate Bill 676 (Allen) and the City’s Stage C water conservation status, no new Artificial Turf Permits have been issued. The draft ordinance repeals allowances for synthetic turf regardless of drought condition but does not regulate side or rear yards (synthetic turf may still be installed in these areas). The City’s existing prohibition regarding synthetic turf placement in the public right-of-way and in City parkways remains unchanged by the proposed ordinance.

Existing Synthetic Turf Installations
Existing permitted synthetic turf installations on residential front yards may be retained until a sunset date set 15 years from the ordinance’s effective date, provided they are properly maintained.1 The draft ordinance maintains requirements that synthetic turf be kept in an attractive and clean condition; and free from holes, tears, stains, discoloration, seam separations, uplifted surfaces, heat degradation, or excessive wear. Since synthetic turf generally carries an 8- to 20- year warranty, a 15-year phase-out (“amortization”) period is proposed to balance considerations of property owner investment and the City’s aesthetic and sustainability goals. Property owners may appeal to the City Council within 14 days after the sunset date to request an extension by demonstrating that replacement is economically unreasonable for their property. During the phase-out period, repairs up to 10 square feet or five (5) percent of the front yard synthetic turf area (whichever is less) may be made. Synthetic turf removed or damaged in excess of these thresholds triggers removal of all the synthetic turf in the front yard and replacement with natural landscaping consistent with the BHMC requirements.

Clarification for Multi-Family Landscaping
BHMC 10-3-2813 currently requires landscaping in multi-family front yards indirectly through restricting paved surfaces. The draft ordinance includes a cleanup item to explicitly state that all portions of a front yard must be landscaped and adds a definition for landscaping. Landscaping means live plants (trees, shrubs, lawns, and groundcover), supplemented by non-living elements like decorative rocks and fences. This amendment matches the existing BHMC landscaping definition for single-family zones and provides a reference for replacement when synthetic turf is removed.

Ordinance Implementation
Outreach to Artificial Turf Permit Holders
If the draft ordinance is adopted, the Planning Division Staff and the Sustainability Team from the Public Works Department will conduct outreach informing Artificial Turf Permit holders of the new regulations through mailed letters and emails. Notifications will explain the 15-year amortization period and identify available resources and financial incentives to support the transition to natural landscaping. Given the length of the amortization period, staff intends to provide periodic 1 Artificial Turf Permits deemed complete and pending issuance may proceed with installation, but are subject to removal at the end of the 15-year amortization period. 4-3
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reminders, especially more frequently leading up to the sunset date. More information will be accessible through the City’s webpage and the Permit Center.

Alternatives to Synthetic Turf
Residents seeking alternatives to synthetic turf have many options for California-friendly and water-efficient plants suitable for residential front yards. These plants—which include both native and well-adapted non-native species—need minimal irrigation, support biodiversity, and complement various landscaping styles. The Beverly Hills Garden Handbook (2015)2is a comprehensive landscape guide containing over 125 plant recommendations, four landscaping styles suited to prevalent architectural themes in Beverly Hills, and practical tips for selecting and placing water-saving plants.

Additional helpful landscaping resources include:
 The City’s Water Efficient Landscaping Webpage – beverlyhills.org/welo  Be Water Wise – bewaterwise.com/toolkit.html
 The Drought Tolerant Garden (Los Angeles County Handbook) – https://dpw.lacounty.gov/wwd/web/Documents/DroughtTolerantGarden.pdf  California Native Plant Society – cnps.org/gardening
Financial incentives and rebates are available for residents transitioning to water-efficient landscaping. Programs such as SoCal Water$mart (socalwatersmart.com) offer rebates starting at $2.00 per square foot for turf replacement. Further funding support may be available for waterefficient irrigation systems and equipment.

GENERAL PLAN POLICIES3 AND ZONE TEXT AMENDMENT FINDINGS The General Plan contains various goals and policies intended to help guide development in the City. Policies relevant to the Planning Commission’s review of the draft ordinance are included as Attachment E. Criteria the Planning Commission considers when evaluating the proposed amendments are in Attachment B.

PUBLIC OUTREACH AND NOTIFICATION
Notice for this project, summarized in Table 1, was provided pursuant to the requirements set forth in BHMC §10-3-2.5, et seq. A courtesy notice was also sent to the interested parties for Synthetic Turf and Long Range Planning. Three public comments received prior to agenda publication—one from a member of the public, one from a synthetic turf company, and one from a non-profit organization—are provided in Attachment F. Previous public correspondence on this topic is included in Attachment G.
2 Access the Beverly Hills Garden Handbook online at: beverlyhills.org/gardenhandbook 3 The General Plan is available online at beverlyhills.org/generalplan-document. 4-4
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TABLE 1. PUBLIC NOTIFICATION TABLE
Notice Type Notice Date
Notice of Public Hearing
 Mailed Notice (500’ radius + block face;
via first class mail)
 On-Site Posted Notice
 Newspaper Notice
o Beverly Hills Courier
o Beverly Hills Weekly
o Beverly Press
Not required
Not required
5/2/2025
Not required
5/8/2025

ENVIRONMENTAL ASSESSMENT
This Ordinance and the Amendments were assessed in accordance with the authority and criteria contained in the California Environmental Quality Act (CEQA), the State CEQA Guidelines, and the environmental regulations of the City. Staff recommends the Planning Commission find that adoption of the Amendments will not have a significant environmental impact and is exempt from CEQA pursuant to Section 15305 of Title 14 of the California Code of Regulations because the Amendments represent minor alterations in land use limitations and do not result in any changes in land use or density. Further, the residential areas of the City to which the Amendments apply have an average slope of not more than 20%.

NEXT STEPS
Staff recommends that the Planning Commission:

1. Conduct a public hearing;

2. Adopt the attached resolution, recommending the City Council adopt the proposed Zone Text Amendment amending synthetic turf regulations; and

3. Find the project exempt from CEQA.

Alternatively, the Planning Commission may recommend revisions to the draft ordinance, provided the revisions are consistent with the City’s landscaping and water conservation goals.

Report Reviewed By:

Masa Alkire, AICP
Assistant Director / City Planner
Community Development Department
4-5
Meeting Date:

Subject:

Project Applicant:

City of Beverly Hills
Planning Division
455 N. Rexford Drive Beverly Hills, CA 90210
TEL. (310) 285-1141 FAX. (310) 858-5966
Planning Commission Report
January 30, 2025

SYNTHETIC TURF IN RESIDENTIAL FRONT YARDS - STUDY

SESSION
Staff requests the Planning Commission's feedback and direction on potential changes to synthetic turf regulations for residential front yards following recent state law updates.

This item was continued from the January 14, 2025 Planning Commission meeting.

City-Initiated
Recommendation: 1. Conduct a study session; and

2. Provide input and direction to staff regarding whether to prepare a draft ordinance to be presented to the Planning Commission at a future meeting.

REPORT SUMMARY
The Planning Commission will continue its study session on synthetic turf in residential front yards. In response to the Commission's request, staff identified resources with examples of decorative and recreational groundcover alternatives to synthetic turf:
• Be Water Wise - https://www.bewaterwise.com/toolkit.html • The Drought Tolerant Garden - Los Angeles County Handbook - https://dpw.lacounty.gov/wwd/web/Documents/DroughtTolerantGarden.pdf • California Native Plant Society - https://www.cnps.org/gardening Attachment A includes the staff report from the January 14, 2025 meeting for reference.

Attachment:

A. Staff Report from the January 14, 2025 Planning
Commission Meeting
Report Author and Contact Information:

Patrick Achis, Associate Planner
(310) 285-1129
[email protected]
Report Reviewed By:

Masa Alkire, AICP
Assistant Director / City Planner
Community Development Department
4-29
City of Beverly Hills
Planning Division
455 N. Rexford Drive Beverly Hills, CA 90210
TEL. (310) 285-1141 FAX. (310) 858-5966
Planning Commission Report
Attachment(s):

A. Ordinance No. 15-O-2691
B. Applicable General Plan Goals and Policies
C. Public Comments Received for the December 12,
2024, Planning Commission Meeting
Report Author and Contact Information:

Patrick Achis, Associate Planner
(310) 285-1129
[email protected]
Meeting Date: January 14, 2025
Subject: SYNTHETIC TURF IN RESIDENTIAL FRONT YARDS - STUDY

SESSION
Staff requests the Planning Commission's feedback and direction on potential changes to synthetic turf regulations for residential front yards following recent state law updates.

This item was continued from the December 12, 2024, Planning Commission meeting.

Project Applicant: City-Initiated
Recommendation: 1. Conduct a study session; and

2. Provide input and direction to staff regarding whether to prepare a draft ordinance to be presented to the Planning Commission at a future meeting.

REPORT SUMMARY
This report evaluates potential changes to the regulations governing synthetic turf in residential front yards (both single-family and multi-family residential zones) following recent legislative updates. In 2015, the City Council adopted Ordinance No. 15-O-2691 to permit synthetic turf in residential front yards as part of state-mandated drought-response efforts. Until recently, state law prohibited cities from banning or excessively restricting synthetic turf. However, effective in 2024, Senate Bill 676 (Allen) restores local control and allows cities to regulate or ban synthetic turf to address environmental concerns and public health. This study session provides an opportunity for the Planning Commission to discuss maintaining, revising, or prohibiting the existing allowance for synthetic turf installations. This study session is intended for discussion only, and no new regulations will be adopted at this time.

BACKGROUND
What is Synthetic Turf?
Synthetic turf, also known as artificial turf or artificial grass, is a manufactured groundcover resembling natural grass. It typically involves synthetic “grass” blades made of plastic or nylon, supported by a base of crumb rubber (from recycled tires), plastic pellets, or sand.

Drought Response and Conservation Efforts
In 2014, during severe drought conditions, Governor Jerry Brown declared a statewide emergency in California and directed the State Water Resources Control Board to implement emergency water conservation measures. The following year, new legislation was enacted to 4-30
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require cities to adopt low-water-use landscaping alternatives. In response, the City escalated water conservation efforts from a “Stage B” event in 2014 to a “Stage D” in 20151. To meet state mandates, the City adopted Ordinance No. 15-O-2691 (Attachment A), which designated synthetic turf as a permitted form of groundcover, for a portion of residential front yards under specific conditions. The ordinance addressed the future enactment of Assembly Bill (AB) 1164 (Gatto)
2 that limited the City’s ability to prohibit or set overly restrictive regulations on synthetic turf.

BHMC Landscape Requirements and Existing Synthetic Turf Regulations The Beverly Hills Municipal Code (BHMC) requires that all unpaved portions of a residential front yard be landscaped. This landscaping must include living plantings, such as trees, bushes, shrubs, hedges, lawns, and other live groundcover. Non-living features, such as rocks, curbs, walls, fences, and other decorative treatments, are also permitted. However, synthetic turf is not classified as landscaping under the BHMC.

The existing synthetic turf regulations establish high environmental and quality standards, specifically for front yard and street-side yards. During a Stage D water conservation event, synthetic turf may cover up to 40% of a front yard, provided it meets certain criteria for coverage, installation, materials, and maintenance. Since the City is currently in a Stage C event, synthetic turf permits are not being issued. If the City returns to Stage D, the synthetic turf permitting process would resume.

The existing regulations prohibit synthetic turf in the public right-of-way, such as parkways and medians. It also bans materials like rubber infill and nylon-based rubber due to environmental and health risks, including chemical runoff and microplastic pollution. Synthetic turf raises soil temperatures, which damages tree roots and prevents the breakdown of organic material in the soil, which reduces nutrients available to trees. Synthetic turf installations in side or rear yards are not regulated by the ordinance.

Applications that comply with the ordinance standards are approved through a streamlined overthe-counter process by Planning Division staff. For an overview of the City’s existing synthetic turf regulations, see Table 1 on the next page.

Legislative Context and Current Challenges
Recent legislative developments have raised concerns about the environmental and health issues of synthetic turf3—such as microplastic pollution and chemical runoff, including per- and polyfluoroalkyl substances. These concerns led to the enactment of Senate Bill (SB) 676 (Allen), which repealed previous restrictions and reinstated local control4. SB 676 reinstates local authority 1 Each stage of water conservation, as detailed in BHMC § 9-4-304, specifies required water reduction targets and enforces penalty surcharges for noncompliance.
2The full text of AB 1164 (Gatto) is available on the California State Legislature website:
https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=201520160AB1164 3 A comprehensive collection of scientific articles on the health impacts of synthetic turf is compiled by the Pennsylvania State College of Agricultural Sciences: https://plantscience.psu.edu/research/centers/ssrc/research/synthetic-turfhealth. 4 SB 676 (Allen) specifically restores the authority of local agencies to regulate synthetic grass and artificial turf installations by amending the constraints of Government Code §53087.7, previously established by AB 1164 (Gatto). 4-31
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to ban or regulate synthetic turf to address these environmental and waste concerns. This study session reevaluates the City’s stance on synthetic turf and considers whether the City should maintain, revise, or prohibit its use in light of the legislative changes. See the Timeline on Page 4 for relevant state and City measures to address drought conditions.

TABLE 1. SUMMARY OF CITY’S EXISTING SYNTHETIC TURF REGULATIONS (BHMC §§10-3-2423.5, -2519.5, -2619.5, -2813.5)
Applicability  Applies to single- and multi-family residential zones  Permitted only during Stage D Water conservation
Coverage and
Location
 Limited to 40% of the front/street side yard and 70% of required landscape area
 Buffer of 18-inches from front/street property lines; 3-foot buffer from residential buildings
 Prohibited within the dripline of any native or heritage tree  Prohibited in public rights-of-way
Installation  Requires professional installation
 3-inch compacted aggregate base
 Seamless and anchored turf
 Existing irrigation systems must be removed or capped Materials  No rubber infill or toxic materials
 Blades must be cut-pile infill with polyethylene or polypropylene  Use of at least two colors
 Blades Size - 1-¾ to 2-½ inches with a beige or tan thatch  Resistant to stain weather, rot, mildew, and fungus
 Meets federal and state safety standards
 Tuft bind – at least 8 pounds
 Drainage rate - 30 inches per hour,
 Durability features – tear grab strength of 200 pounds Maintenance  Free from holes
 No tears or stains
 No excessive wear
 No discoloration
 No seam separation
 No heat damage
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Timeline of water conservation efforts by the City and State.

DISCUSSION
Existing Synthetic Turf Conditions and Trends
The City is not currently issuing new synthetic turf permits since entering Stage C for water conservation. Since 2015, the City has issued a total of 43 synthetic turf permits. Of these, 24 installations have been finalized, 12 are currently being installed, and seven are pending permit issuance. Recent years have seen a noticeable decline in permit activity as only five permits were issued in 2023.

In residential neighborhoods, synthetic turf is typically used as an accent to complement—rather than replace—living plants in front yards. While the City does not have data on the use of synthetic turf in non-front yard areas of properties, observations suggest that front yards are the most common location for synthetic turf installations. Enforcement actions by the Community Preservation Division have identified few property maintenance or blight issues related to synthetic turf. Figures 1 to 3 on the following pages illustrate the varied applications of synthetic turf in residential settings throughout Beverly Hills.
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Figure 1. In a Trousdale yard, driveway pavers are thinly framed by synthetic turf alongside a water-efficient garden.

Figure 2. A background of synthetic turf contrasts with drought-tolerant plants and gravel in the foreground of a Central Area multi-family yard.
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Synthetic Turf in the Public Right-of-Way
Over the years, some residents have expressed concerns about the inability to install synthetic turf in public rights-of-way, which is prohibited under the existing ordinance. Allowing synthetic turf in these areas could interfere with natural drainage, harm City trees, detract from streetscape character, and conflict with the broader discussions in this study session about the potential prohibition of synthetic turf in front yards.

The Sustainability Team within the Public Works Department supports considering any regulatory changes the Commission deems necessary to address environmental and public health concerns, including the possibility of prohibiting or limiting the use of synthetic turf, as the application of synthetic turf does not align with the City’s sustainability goals and should be discouraged to the extent possible.

Alternatives to Synthetic Turf
California-friendly and water-efficient plants serve as viable alternatives for synthetic turf in residential front yards by offering a sustainable option that aligns with the City’s water conservation goals. These plants, which include both native and non-native species, require minimal irrigation and can be adapted to various landscaping styles. Additionally, they promote biodiversity and improve soil quality.

Financial incentives and rebates are available for residents transitioning to water-efficient landscaping. Programs such as SoCal Water$mart (socalwatersmart.com) provide funding to offset costs, with rebates starting at $2.00 per square foot for turf replacement. Additional funding may be available for water-efficient irrigation systems and equipment.

Figure 3. Diamond-shaped panels of synthetic turf are interspersed within the driveway of a Hillside residence.

Source: Google StreetView
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Table 2 below compares the characteristics of synthetic turf and water-efficient plants to show the environmental, maintenance, and aesthetic considerations. Figure 4 on the next page shows the visual possibilities of a California-friendly garden.

TABLE 2.

SYNTHETIC TURF VS. WATER-EFFICIENT PLANTS
Criteria Synthetic Turf Water-Efficient Plants
Water Usage  Low but does not retain
soil moisture
 Minimal water use
 Positively impacts water cycle
through groundwater recharge
if runoff is directed to
landscape areas
Aesthetic  Consistently green, but
may look artificial
 May detract from the
garden quality of the city
 Offers natural aesthetic
variability; diverse textures and
colors
Cost  High initial costs
 Not eligible for rebates
 Replacement costs at
end of lifespan
 Requires more upfront
investment; but generally low
long-term costs
 Costs may be offset with turf
replacement and efficient
irrigation system rebates
Maintenance  Low; requires occasional
cleaning
 Low; requires seasonal care
and occasional pruning
Environmental  No pesticides or
fertilizers
 Contributes to heat
island effect
 Potential drainage issues
 Harmful to trees
 Supports biodiversity and
pollination
 Reduces heat island effect
Health & Safety  Concerns over
microplastic pollution,
increased stormwater
pollution runoff, and
recyclability issues
 Improves air quality
 Attracts wildlife
 Reduces storm water runoff
pollution
4-36
Planning Commission Report
Synthetic Turf Regulations – Study Session
January 14, 2025

Page 8 of 9 ends

Figure 4. A garden in the Central Area home uses California-friendly plants to create a diverse and low-water front yard.

Source: Google StreetView

GENERAL PLAN CONSISTENCY
The General Plan contains various goals and policies intended to help guide sustainable development in Beverly Hills. Attachment B lists General Plan policies relevant to synthetic turf regulations.

OPTIONS AND QUESTIONS FOR CONSIDERATION
Staff recommends the Planning Commission consider the following options and questions to specifically address the regulations for synthetic turf in light of the new state legislation and existing synthetic turf regulations.
 Option 1 - Maintain Existing Code Standards for Synthetic Turf o Should synthetic turf continue to be allowed during a Stage D water conservation event?
o Are current regulations pertaining to turf coverage limits (40% of the front yard), materials, and maintenance sufficient to balance water conservation with environmental concerns?
 Option 2 - Revise Existing Code Standards for Synthetic Turf o Which specific parts of the existing regulations should be updated to improve environmental outcomes and maintain the garden quality of residential neighborhoods?
o Should synthetic turf coverage be reduced (e.g., from 40% to [X]%) or restricted to decorative accents (e.g., driveway borders)?
4-37
Planning Commission Report
Synthetic Turf Regulations – Study Session
January 14, 2025

Page 9 of 9 ends

 Option 3 - Prohibit Synthetic Turf in Front Yards
o Should the City prohibit the use of synthetic turf in front yards altogether, regardless of the stage of drought?
o If prohibited, how should existing, permitted installations be addressed?  Should existing installations be removed after an amortization period or remain as legally nonconforming? Should ongoing maintenance and replacement be allowed?
 Additional Consideration
o Should the prohibition on synthetic turf in the public right-of-way be maintained or is there interest in modifying this standard?

ENVIRONMENTAL ASSESSMENT
The California Environmental Quality Act (CEQA) does not apply to the study session because it is not considered a “project” under Section 15378 of the CEQA Guidelines. The review of possible changes to synthetic turf regulations does not result in any physical changes to the environment, directly or indirectly. The study session is exempt from environmental review pursuant to the “common sense exemption” under Section 15061(b)(3) of the CEQA Guidelines. This exemption applies because the study session has no possibility of causing a significant effect on the environment. Any changes to synthetic turf regulations would be subject to future and separate CEQA review.

NEXT STEPS
Staff recommends the Planning Commission:

1. Conduct a study session; and

2. Provide input and direction to staff regarding whether to prepare a draft ordinance to be presented to the Planning Commission at a future meeting. A zone text amendment would require formal review by the Planning Commission and adoption by the City Council.

Report Reviewed By:

Masa Alkire, AICP
Assistant Director / City Planner
Community Development Department
4-38
Attachment 6
General Plan Goals and Policies
Attachment 6 – General Plan Goals and Policies
Prohibition on Synthetic Turf Ordinance
City Council Report
July 15, 2025
GENERAL PLAN GOALS AND POLICIES1
The General Plan includes numerous goals and policies intended to help guide sustainable development in the City. Some of the policies relevant to the City Council’s review of the proposed prohibition on synthetic turf regulations include the following:

Land Use (LU) Element – Goals and Policies
 Goal LU 2 - Community Character and Quality. A built environment that is distinguished by its high level of site planning, architecture, landscape design, and sensitivity to its natural setting and history.
 Policy LU 2.2 Public Streetscapes and Landscape. Maintain and enhance the quality and health of the “green infrastructure” that contributes to the City's identity and quality of life, including its street trees, landscaped medians and parkways, parks, and open spaces, while seeking to conserve water resources.
 Policy LU 5.1 - Neighborhood Conservation. Maintain the uses, densities, character, amenities, and quality of the City’s residential neighborhoods, recognizing their contribution to the City’s identity, economic value, and quality of life.  Goal LU 6 - Single-Family Residential Neighborhoods. Maintenance of the identity, scale, and character of the distinct single-family residential neighborhoods.  Policy LU 6.2 - Housing Character and Design. Require that new, renovated, and additions to housing to be located and designed to maintain the distinguishing characteristics and qualities of the neighborhoods in which they are located, including prevailing lot sizes, building form, scale, massing, relationship to street frontages, architectural design, landscaping, property setbacks, and other comparable elements.

Conservation Element – Goals and Policies
 Policy CON 2.5 Water Efficient Landscaping. Where feasible, encourage installation of drought tolerant landscaping or water-efficient irrigation systems for all private and city landscaping and parkways. Identify and implement minimum design and installation efficiency criteria for landscape irrigation systems.
 Goal CON 3 Water Conservation through Reduced Consumption. Conservation programs that limit water consumption through site design, the use of water conservation systems and other techniques.
 Policy CON 3.9 Water-Efficient Landscaping. Encourage and promote drought-tolerant landscaping or water-efficient irrigation systems for all private and city landscaping and parkways.
 Policy CON 11.2 Pollution Loading. Reduce pollutant loading through passive treatment systems such as vegetated filter strips, grass swales, and infiltration/sedimentation areas in suitable open space areas, overland flow channels and landscaping adjacent to parking lots and streets.
 Policy CON 11.4 Drainage Technology. Require that new developments employ the most efficient drainage technology to control drainage and minimize damage to environmentally sensitive areas.

1 The General Plan is available at beverlyhills.org/generalplan.

Attachment 7
Public Correspondence
From: Jennifer Lee <[email protected]>
Sent: Thursday, June 5, 2025 3:43 PM
To: City Clerk <[email protected]>
Cc: [email protected]
Subject: Public Comment on Behalf of the Synthetic Turf Council (STC) Good afternoon,
I'm submitting a public comment on behalf of Melanie Taylor, President and CEO of the Synthetic Turf Council (STC), attached and pasted below regarding a potential ban on synthetic turf on private front yards in Beverly HIlls.

Please let us know if you have any questions.

Best,
Jennifer
--
June 5, 2025
Beverly Hills City Councilmembers
455 North Rexford Drive
Beverly Hills, CA 90210
RE: Expressing concern over potential ban on synthetic turf on private front yards in Beverly Hills, CA
Submitted by:

Melanie Taylor, CAE
President and CEO
Synthetic Turf Council (STC)
2331 Rock Spring Road, Forest Hill, MD 21050

We have concerns over these efforts to ban synthetic turf on front yards in Beverly Hills and what it would mean for residents across the region if implemented. STC wants to ensure that policies in Beverly Hills do not jeopardize local residents' ability to utilize the water conservation, environmental, and community benefits that synthetic turf offers.

Communities, schools, businesses, and families across the country choose synthetic turf because of its significant benefits, including being accessible and available yearround, being more affordable to maintain, and protecting the environment through reduced water and chemical use. The synthetic turf industry is proud to deliver quality products that make a positive difference and are used by thousands of communities nationwide. Indeed, Santa Clara County rejected moving forward with proposed bans on synthetic turf earlier this year.

About STC and our membership
As a 501(c)(6) trade association, STC has represented the synthetic turf industry for more than 20 years. In particular, we serve as a resource for current, credible, and independent research on the safety and environmental impact of synthetic turf, as well as technical guidance on the selection, installation, maintenance, and environmentally responsible disposal of synthetic turf. Our membership includes representatives from every stage of synthetic turf production, installation and maintenance, including builders, design professionals, civil engineers, testing labs, maintenance providers, manufacturers, suppliers, installation contractors, infill and shock pad suppliers, and specialty service companies.

Environmental benefits of synthetic turf
There are many significant environmental benefits to using synthetic turf. First, synthetic turf greatly reduces water use and water pollution compared to what's needed to support grass systems. The EPA states that of "the estimated 29 billion gallons of water used daily by households in the U.S., nearly 9 billion gallons, or 30 percent, is devoted to outdoor water use. In the hot summer months, or in dry climates, a household's outdoor water use can be as high as 70 percent." In states where water conservation is vital, like California, one full-size synthetic turf sports field can save millions of gallons of water each year, depending on local climate and usage. Based on a 2024 report by the Vancouver Board of Parks and Recreation, a multi-field synthetic turf sports field uses 0 gallons of water per year as compared to up to 2.7 million gallons of water used for a grass field. Additionally, valley high schools in Henderson, NV estimate about 2 million gallons of water saved for each grass field converted to synthetic turf and "that's just going to further contribute to the water efficiency that we have seen in our communities," stated Bronson Mack from the Southern Nevada Water Authority.

Secondly, the use of synthetic turf reduces the need for chemicals. Synthetic turf eliminates the need for fertilizers, pesticides, and herbicides, which means less harmful chemicals in the environment. Additionally, the EPA estimates that using a gas-powered lawn mower produces the same amount of emissions as 11 new cars running for an hour.

Synthetic turf is safe and does not pose significant health risks STC is committed to ensuring the safety of infills for synthetic turf. Crumb rubber, a commonly used infill material to provide cushioning and support in synthetic turf, helps improve durability, drainage, and shock absorption while reusing waste rubber from old tires. Just last year, the EPA and CDC reaffirmed the safety of synthetic turf sports fields that use crumb rubber infill, publishing a study that found no significant difference in the exposure from certain chemicals found between players who played on synthetic turf fields that use crumb rubber infill and those who played on grass fields.

Additionally, the California Office of Environmental Health Hazard Assessment (OEHHA) recently published its own draft study on synthetic turf, finding no significant health risks to players, coaches, referees, and spectators from on-field or off-field exposure to chemicals in crumb rubber infill from synthetic turf fields.

Today, in addition to recycled rubber, owners and buyers can choose from a variety of infill types, including coated sand, TPE, virgin rubber, or natural and organic materials.

The synthetic turf industry's approach on PFAS
STC members are committed to maintaining the highest quality standards for synthetic turf systems. Our member manufacturers proactively engage with their component and raw material suppliers to ensure that their products contain no PFASbased ingredients, including polymeric PFAS processing aids. Additionally, our members self-audit through voluntary testing processes that rely on EPA-approved methods for individual PFAS analytes and/or a total organic fluorine test to verify the absence of intentionally-added PFAS. These tests are widely used and provide verifiable, consistent data across different projects and regions. While PFAS are unfortunately present in our environment, STC members are committed to do our part to ensure the absence of intentionally-added PFAS in our products.

Innovations in turf recycling and microplastics mitigation Regarding recycling, the synthetic turf industry continues to find innovative solutions for fields at the end of their life. There are numerous examples of the work STC members are doing to reuse or recycle synthetic turf and avoid landfilling, including:

Shaw
Sports Turf
recycles old synthetic
turf into performance shock pads for new synthetic turf fields.

BestPLUS's
GreenBoard, a
plastic lumber product, is made with 98% recycled plastic, and at least 40% is from recycled synthetic turf.

TenCate
converts used synthetic
turf into a liquid feedstock, which can then be reused to create new synthetic turf and other valuable products.

Finally,
AstroTurf
forged a strategic
alliance with the Turf Recycling Plant (TRP) in Calhoun, Georgia, to pioneer a sustainable solution for the recycling of end-of-life synthetic turf systems.

As a consumer-driven industry, synthetic turf companies are constantly innovating to help designers, contractors, owners, and users mitigate microplastic pollution.

Mitigation measures include containment barriers, cleaning stations, drainage filters, maintenance control zones, and field construction best practices. The turf industry is continuing to develop guidelines and stewardship programs to ensure synthetic turf fields are properly managed before, during, and after their useful life.

Our industry takes seriously our commitment to sustainable practices and continues to innovate more recycling and responsible end-of-life solutions. Our industry is working together with regulators and lawmakers in states nationwide to align on the best practices for end-of-life processes. We are committed to inspiring and connecting healthier communities through safe and sustainable spaces.

Long-term community benefits of turf in California
Synthetic turf is a lasting investment that enhances public spaces for years to come.

Synthetic turf transforms high-maintenance areas into clean, usable spaces with minimal upkeep, maintaining its vibrant appearance year-round to provide an aesthetically pleasing landscape. The money saved from using turf can be redirected to support critical initiatives related to economic growth, infrastructure improvements, and expanded educational opportunities.

In various communities across California, synthetic turf fields have proven to provide substantial benefits, particularly in terms of increased safety for young athletes, their extended longevity, and the sense of unity they bring to communities. These fields have not only enhanced recreational facilities but have also become central hubs for fostering community engagement and promoting healthy lifestyles.

In Moreno Valley, the installation of a new synthetic turf field at March Field Park has been a significant boon for the community. Mayor Ulises Cabrera remarked, "This beautiful soccer arena will continue to serve as a hub for our youth to learn important life skills such as teamwork, sportsmanship, and healthy competition." This sentiment underscores how synthetic turf can transform local recreational spaces into valuable assets for community development and youth engagement.

Similarly, in Visalia, the transition from a problematic grass field to a synthetic turf one has markedly improved player safety. The previous grass field was often muddy and difficult to play on, posing risks to young athletes. The new synthetic turf field, equipped with a cooling system, allows children to play safely in various weather conditions year-round. As Juan Castellanos, a parent in Visalia, pointed out, "This new field is actually a matter of student safety," highlighting the crucial role that synthetic turf plays in ensuring a safe playing environment.

Moreover, the durability and sustainability of synthetic turf fields make them ideal for long-lasting recreational spaces. Kirk Shrum, superintendent of schools in Visalia, emphasized the long-term benefits, stating, "This space is an incredible asset to our Highland community, and this field will be used for years to come." This durability not only supports ongoing community activities but also ensures that the investment in synthetic turf yields long-term returns for communities across the country.

Finally, take the City of Irvine, where their sports complex hosts over 5 million visitors annually. Last year, the city chose to expand the use of synthetic turf in the complex specifically because of the benefits it provides in increased access and more manageable maintenance. The City stated: "Synthetic turf is available for use all day, withstands diverse, heavy sports traffic, and can be used in the rain. These advantages mean a synthetic turf field will provide almost four times more use hours over its life cycle than a comparable, well-maintained, natural grass field." STC welcomes the opportunity to work with policymakers and community members
In addition to promoting safety and accessibility, synthetic turf saves water, enables increased access, and provides cost savings to communities across the country.

Efforts to ban synthetic turf hinder communities' ability to access these benefits and should be reconsidered.

Thank you for your time and attention. On behalf of STC and our members, we want to continue to be a partner to you and City staff and to provide any resources, information, or assistance we can as we work together to ensure the most beneficial policies for all. We look forward to continued discussions on this matter.

Best,
Melanie Taylor, CAE
President and CEO
Synthetic Turf Council (STC)
www.syntheticturfcouncil.org
--
Jennifer Lee
Associate, Advisory
C: +1 (415) 680-8656
[email protected]
455 Market Street, Suite 1670
San Francisco, CA 94105
This e-mail and any accompanying attachments may contain confidential information meant only for the intended recipient. If you are not the intended recipient or have otherwise received this e-mail in error, please promptly notify the sender by return email and delete all copies of this transmission.

1 Subject: RE: SYNTHETIC TURF
From: Candice Tahour
Sent: Thursday, May 1, 2025 8:52 PM
To: CommentPC <[email protected]>
Every home owner should be able to decide what They want on the property.

You want to save water, promote turf.
e n e r g e t I c a l l y y o u r s:

Candice Tahour
REALTOR® |
DRE# 01889765
4-59
4-286
From: Jennifer Nourafshan
To: CommentPC
Subject: I support artificial turf in Beverly Hills
Date: Wednesday, January 29, 2025 4:08:05 PM
[Some people who received this message don't often get email from . Learn why this is important at https://aka.ms/LearnAboutSenderIdentification ] CAUTION: EXTERNAL SENDER
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Thank you,
Jennifer Pourtavosi
N hillcrest rd, Beverly Hills, ca 90210
4-287
4-288
From: Sandra Afshani
To: CommentPC
Subject: Turf in bh
Date: Wednesday, January 29, 2025 7:11:32 PM
[Some people who received this message don't often get email from . Learn why this is important at https://aka.ms/LearnAboutSenderIdentification ] CAUTION: EXTERNAL SENDER
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Please refrain to put artificial turf in our city- please only use natural materials.

Thank you,
Sandra Afshani=
4-289
From: Soraya Afra
To: CommentPC
Subject: Truf for front lawn
Date: Thursday, January 30, 2025 11:58:51 AM
[Some people who received this message don't often get email from s . Learn why this is important at https://aka.ms/LearnAboutSenderIdentification ] CAUTION: EXTERNAL SENDER
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My name is Soraya Afra ,resident of North Rexford Drive Beverly Hills 90210 ,our family is strongly oppose to city of Beverly Hills denying our right to it artificial grass in our front lawn to save water and beautiful our city please let us save WATER . S Afra
Sent from my iPhone=
4-290
4-291
Dear Members of the Beverly Hills Planning Commission,
I am writing to respectfully advocate for the approval of synthetic turf installations on parkways and frontyards within our city. As a resident who values both the beauty and sustainability of our community, I believe that permitting synthetic turf provides numerous benefits that align with our city’s environmental and aesthetic goals.

First and foremost, synthetic turf is an effective solution for addressing California’s ongoing drought concerns. Traditional grass lawns require significant water resources to maintain their appearance and green-look, placing unnecessary strain on our water supply. By contrast, synthetic turf eliminates the need for irrigation, helping residents conserve water and contributing to the city’s water-saving initiatives. This shift would demonstrate Beverly Hills’ commitment to environmental stewardship and serve as a model for other communities.

In addition to its water-saving benefits, synthetic turf offers a consistently manicured and vibrant appearance that enhances the overall aesthetic of our neighborhoods. Unlike seeded grass, which can become patchy or brown due to weather conditions or uneven maintenance, synthetic turf remains green and uniform year-round. This not only increases curb appeal but also complements the high standards of beauty and cleanliness that Beverly Hills deserves.

Furthermore, synthetic turf is a low-maintenance alternative to traditional landscaping. It eliminates the need for mowing, fertilizing, and pesticide application, reducing the time and cost burden on residents while also minimizing chemical runoff into our local environment. For residents with limited mobility or time constraints, synthetic turf provides an accessible and sustainable option. It also eliminates the horrible smell of manure in the neighborhood and irritating noise caused from grass-cutting and edging machines.

Finally, synthetic turf is durable and long-lasting, making it a cost-effective investment over time. Its resilience to wear and tear ensures that it maintains its aesthetic value even in high-traffic areas.

In light of these considerations, I urge the Planning Commission to permit synthetic turf installations on parkways and frontyards. Doing so will support our shared goals of water conservation, environmental sustainability, and neighborhood beautification.

Thank you for your time and thoughtful consideration.

Sincerely,
Daniel Nourafshan
4-292
From:

To:

Cc:

Subject:

Date:

Attachments:

Dianne Woelke
CommentPC; WebCBH MAYORANDCTTYCOUNCIL
Patrick Achis
For the public record. Planning Commission meeting, 10 Apr 2025. Open Public Comments: Proposed Ordinance, Artificial grass/Synthetic Turf
Monday, April 7, 2025 9:11:49 PM
image.png
BeverlyHills.pelf
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I
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Good evening:

Attached please find our letter in suppo1i of modified ordinance on artificial grass/synthetic turf. Kindly share this infonnation electronically so that hyperlinks to sources cited may be accessed for those who wish to avail themselves of the science and additional infonnation provided.

Please do not hesitate to reach out with questions or comments.

Thank you for unde1iaking this impo1iant endeavor and not kicking the can down the road for future generations to suffer the consequences of negative human and environmental health impacts from this wholly un necessaiy consumer product.

Best regai·ds,
Dianne Woelke MSN, Board Member
Safe Healthy Playing Fields, Inc.
https://www.safehealthyplayingfields.org
SHPFI is an all-volunteer nonprofit 501-c-3

SAFE HEALTHY

PLAYING FIELDS
_,..�

BEYOND PLASTICS
/>►FILlb,lt
4-60
Safe Healthy Playing Fields Inc.
www.safehealthyplayingfields.org
Beverly Hills Planning Commission
10 April 2025
Proposed Artificial Grass/Synthetic Turf Ordinance
Chair Kaplan, Vice Chair Wolfe, Commissioners Ross, Demeter and Milkowski:

Thank you for the opportunity to submit comments on this item today on behalf of Safe Healthy Playing Fields, Inc. (SHPFI). SHPFI is an all-volunteer 501-c-3 non-profit organization. We are committed to educating communities, policymakers and elected officials about the health, safety and financial realities of plastic fields versus grass fields and other synthetic surfaces for their parks and schools, homes and businesses. Our constituency ranges from concerned individuals to community and civic organizations, legal, healthcare and science professionals, municipal leaders and state legislators.

We are sending this letter in advance of the planned May 2025 meeting in the hopes of providing substantial information to guide your plans. We urge the city of Beverly Hills to ban the use of synthetic turf/artificial grass for all residential use as well as on city owned and leased land.

The science on the human health and environmental impacts of plastics and synthetic turf have progressed well beyond what was known when the city created its ordinance in 2015. Allowing its use in back and side yards does not prevent it from polluting neighboring yards, surface and groundwater, storm drains, and the ocean. It does not prevent microplastics created from synthetic turf blades from lofting into the air, carrying for miles and relofting over and over. 4-61
A ban is consistent with the State’s Microplastic Strategy of 2018,1 the 2021 report by the San
Francisco Estuary Institute (SFEI)2 to the Ocean Protection Council (OPC), and the solutions developed by the OPC in 2022.3
● Pollution Prevention: Eliminate plastic waste at the source (products or materials from which microplastics originate).
● Pathway Interventions: Intervene within specific pathways (ex: stormwater runoff, wastewater, aerial deposition) that mobilize microplastics into California waters. ● Outreach & Education: Engage and inform the public and industries of microplastic sources, impacts, and solutions.

In addition, the California Department of Toxic Substances Control, an arm of the California Environmental Protection Agency (CA EPA), is in the process of bringing this fossil fuel-based petrochemical plastic product under regulation4 and has announced its intent to bring microplastics5 and per- and polyfluoroalkyl substances (PFAS), known as “Forever Chemicals” under regulation.6
The science behind plastics, consumer awareness, climate change, loss of biodiversity and the tsunami of plastic pollution demand a wake up call and a return to nature based solutions. The science shows that synthetic turf does not live up to what is found on flashy websites that target not only decision makers, but home and business owners, and blatantly target their marketing towards children and families.
6 Balan, S, Mathrani, VC, Guo, D, Algazi, A (17 Feb 2021). “The P-Sufficient Approach: a Strategy for Regulating PFAS as a Chemical Class under the California Safer Consumer Products Program.” Environmental Health Perspectives; Volume 129, Issue 2
https://ehp.niehs.nih.gov/doi/full/10.1289/EHP7431
5 Safer Consumer Product Program (2023). “Proposed Addition to the Candidate Chemicals List:

Microplastics.” California Department of Toxic Substances Control. CA EPA. https://dtsc.ca.gov/scp/candidate-chemical-list_microplastics/ 4 Safer Consumer Product Program. (27 Aug 2024). “Background Document on Candidate Chemicals in Artificial Turf.” California Department of Toxic Substances Control. CA EPA.

Background Document
3 CA Ocean Protection Council (2022). “Microplastic Strategy, Track 1: Solutions.” https://opc.ca.gov/water-quality/plastics/
2 Moran, K, Miller, E, Mendez, M et al (2021). “A Synthesis of Microplastic Sources and Pathways to Urban Runoff.” SFEI Technical Report: SFEI Contribution #1049. San Francisco Estuary Institute, Richmond, CA.
https://www.sfei.org/sites/default/files/biblio_files/Final_OPC_MP_Stormwater_Conceptual_Models_Repo rt.pdf
1 Senate Bill No. 1263 (2018). “CHAPTER 609: An act to add Chapter 3.2 (commencing with Section 35635) to Division 26.5 of the Public Resources Code, relating to pollution. State of California. https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill id=201720180SB1263 4-62
Research shows that synthetic turf/artificial grass:
● Harms human health via inhalation, ingestion and dermal absorption of toxic chemicals. ● Off-gasses methane and ethylene, adding to the climate crisis. ● Creates heat islands that impact the surrounding vegetation, neighbors and community. ● Releases massive amounts of microplastics and toxic runoff. ● Negatively impacts biodiversity, wild, avian and aquatic life as well as pets. ● Is unrecyclable.
● Increases injuries, risk for thermal and friction burns, and infections. ● Does not save water.

Chemicals of Concern in Synthetic Turf:
(not comprehensive)
● PFAS
● Phthalates
● Latex
● Polyvinyl chloride
● Naptha
● Siloxanes
● Talc
● Di/Isocyanates
● Formaldehyde
● Fungicides
● Flame retardants
● Coal fly ash
● 1,2-cyclohexane
dicarbonic acid
● Dibutyltin
● Ethylene glycol
● Triclosan
● Colorants
● UV stabilizers
● Anti-static
treatments
Per- and Polyfluoroalkyl Substances - PFAS:

NO ONE NEEDS MORE PFAS
From the foremost researcher on PFAS in consumer products, professor emeritus Dr. Graham Peaslee, University of Notre Dame:7
“PFAS is probably the worst environmental pollutant that the United States has ever faced. It makes all the rest” — including PCBs and asbestos — “pale in comparison to what the cost of this cleanup will be…and it will affect more people than all known pollutants combined.”
All synthetic turf tested by academic institutions and independent third party laboratories using proper methods, techniques and reporting limits have found PFAS in synthetic turf.8,9 9 Pollard, L, Massey, R (Aug 2024). “Per- and Poly-fluoroalkyl Substances (PFAS) in Artificial Turf:

Academic, municipal, and other testing efforts.” Lowell Center for Sustainability, University of Massachusetts, Lowell.
8 Whitehead, H. D. (2023). “Development of Analytical Methods for Highly Selective and Sensitive Analytical Analysis of Compounds Relevant to Human Health and the Environment.” Version 1. University of Notre Dame.
https://doi.org/10.7274/bg257d30j3m
7 Notre Dame Magazine (Summer 2023). “Having Coffee With…Graham Peaslee:Tackling the challenge of ‘forever chemicals’.”
https://magazine.nd.edu/stories/having-coffee-with-graham-peaslee/ 4-63
PFOS was found on the hands of young soccer players who played on synthetic turf in a small pilot study in San Diego in the summer of 2023.10 That study is currently being replicated by the Kassotis Lab, Wayne State University, with 50 student athletes and multiple playing fields.

Of high significance, a study done by the Kassotis Lab, in conjunction with The Ecology Center (Ann Arbor, MI), “In vitro endocrine and cardiometabolic toxicity associated with artificial turf materials” published in the October 2024 edition of Environmental Toxicology and Pharmacology, demonstrates the cytotoxic effects of chemicals in synthetic turf to endocrine organs and cardiac development and function. This study also demonstrates the importance of looking at combined chemical exposures associated with a given product.11 No one is ever exposed to one chemical- certainly not with plastics and definitely not with synthetic turf.

Allowing use of this toxic product has implications beyond wild and aquatic life. It is harmful to pets as well.12 With higher metabolisms and shorter life expectancies, dogs have shorter latency periods than humans for development of diseases and cancers. In dogs, endocrine disrupting chemicals have been associated with higher occurrences of low birth weight, birth defects, developmental delays, certain cancers, renal failure and newborn pup deaths.

The California Department of Toxic Substances Control has determined it will be bringing synthetic turf under regulation for PFAS that have been found in 100% of synthetic turf tested by academic, non-profit organizations and independent testing in commercial laboratories to date.13,14 They are also reviewing information on flame retardants, endocrine disrupting and neurotoxic phthalates, antimicrobials, colorants, and more, and will make additional 14 Pollard, L, Massey, R (Aug 2024). “Per- and Poly-fluoroalkyl Substances (PFAS) in Artificial Turf: Academic, municipal, and other testing efforts.” Lowell Center for Sustainability, University of Massachusetts, Lowell.
https://www.uml.edu/docs/PFAS%20in%20Artificial%20Turf%20-%20Academic%20Municipal%20%26%2 0Other%20Tests%20Aug%202024_tcm18-386957.pdf
13 Whitehead, H. D. (2023). “Development of Analytical Methods for Highly Selective and Sensitive Analytical Analysis of Compounds Relevant to Human Health and the Environment.” Version 1. University of Notre Dame.
https://doi.org/10.7274/bg257d30j3m
12 Pocar, P, Grieco, V, Aidos, L, Borromeo, V (Jan 2023). “Endocrine-Disrupting Chemicals and Their Effects in Pet Dogs and Cats: An Overview.” MDPI, Animals; (13). https://www.ncbi.nlm.nih.gov/pmc/articles/PMC9913107/
11 Siegela, KR, Murraya, BR, Gearhart, J, Kassotis, CD (2024). “In vitro endocrine and cardiometabolic toxicity associated with artificial turf materials.” Environmental Toxicology and Pharmacology; (111), 104562. https://doi.org/10.1016/j.etap.2024.104562
,
10 Amenabar, T (Mar 2024). “Study eyes safety of turf fields for kids: Scientists team up with San Diego Surf soccer club to discover if ‘forever chemicals’ pose risk.” San Diego Union Tribune, originally published in the Washington Post.
https://enewspaper.sandiegouniontribune.com/infinity/article_popover_share.aspx?guid=7f93edcb-cd5b-4 f9d-b8e4-ed57343daefc&share=true
https://www.uml.edu/docs/PFAS%20in%20Artificial%20Turf%20-%20Academic%20Municipal%20%26%2 0Other%20Tests%20Aug%202024 tcm18-386957.pdf
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announcements at a future date.15,16,17,18,19 Regulation will have major implications regarding disposal of these fossil fuel-based petrochemical products as well as the ability to replace these plastic yards in the future.

CA DTSC PFAS fact sheet
Early chemgrass, made without PFAS, was brittle. Even if the industry were able to eliminate PFAS from its products some day, it would still be plastic, with myriad toxic, carcinogenic and hazardous chemicals. The synthetic turf industry has had 60 years to self-regulate. Were it capable of doing so, it would not be under review for regulation by DTSC at this time.

Based on the current state of science, installation of synthetic turf is knowingly and willfully choosing to expose children, adults, bystanders, maintenance workers, vulnerable populations, wild and aquatic life to an increased risk of disease, disability, and even death due to the toxic and carcinogenic chemicals found in, and leaching to air, water and soil from synthetic turf.

The City of Los Angeles is working on a highly supported ordinance that would ultimately ban synthetic turf.20 The cities of Millbrae, San Marino and Carmel have enacted ordinances banning synthetic turf under SB676- Allen (2023)21 and additional cities are currently considering taking action.
“No one should be inadvertently exposed to toxic chemicals. Our lawns are places in our homes where we should be able to play and relax, safely. They should not be spaces where we worry about exposing ourselves to harm. Touching artificial turf lawns can 21 Allen, B (8 Oct 2023). “Allen. Local ordinances and regulations: drought-tolerant landscaping An act to amend Section 53087.7 of the Government Code, relating to local government. https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202320240SB676

20 City of Los Angeles (2024-present). “Synthetic Grass / Artificial Turf / Polyflouroalkyl Substances (PFAS) / Forever Chemicals / Health and Environmental Risks / Drought-Friendly Landscaping.” https://cityclerk.lacity.org/lacityclerkconnect/index.cfm?fa=ccfi.viewrecord&cfnumber=24-0602 19 DTSC (27 Aug 2024). CalSAFER website
18 DTSC (27 Aug 2024). Presentation Slides
17 DTSC (27 Aug 2024). Meeting Agenda
16 DTSC (27 Aug 2024). Background Document
15 DTSC (27 Aug 2024). “Virtual Workshop on Candidate Chemicals in Artificial Turf” Meeting Recording 4-65
expose us to PFAS chemicals when transferred from the turf to our hands and then our mouth.” Kizzy Charles-Guzman, CEO, Center for Environmental Health22 Microplastics:

Synthetic turf is most often made from low density polyethylene, the same material as straws and plastic bags. It is the most globally produced and discarded fossil fuel-based petrochemical plastic.

A 2017 study found that a single synthetic turf field loses 0.5 to 0.8% of its blades annually. This estimate is ten times lower than a previous Danish study (0.8 kg/m2). This equates to 2,000 to 3,000 pounds of microplastic blade loss per year per field.23,24 The newest generation of synthetic turf does not require infill poured on top of the synthetic carpet. They are more densely woven, may have double backing,25 and have the potential for significantly greater microplastic blade and carpet backing loss to the environment.

Microplastic synthetic turf blades have been found in Lake Tahoe, where researchers found high levels of polyethylene and polypropylene in the lake and “…recorded plastics concentrations 25 TenCate Pivot (2024). Face weight of 120 ounces per yard2 , double backing, total weight 147.5 ounces
per yard2.
https://geosurfaces.com/wp-content/uploads/2024/05/PIVOT_1.5_Spec-1.pdf 24 CA DTSC (27 Aug 2024). Slide deck, presentation on Candidate Chemicals in Artificial Turf. CA EPA. https://dtsc.ca.gov/wp-content/uploads/sites/31/2024/09/Artificial-Turf-Workshop-Slides_DTSC_Accessibl e.pdf
23 Hann, S et al (2018). “Investigating Options for Reducing Releases in the Aquatic Environment of Microplastics Emitted by (but not Intentionally Added in) Products.” Eunomia, United Kingdom. https://www.eunomia.co.uk/case_study/measuring-impacts-of-microplastics/ 22 Nevins, M (4 Mar 2024). Press Release: “New Testing Reveals High Levels of Toxic PFAS in Artificial Turf.” Center for Environmental Health, Berkeley, CA
https://ceh.org/latest/press-releases/new-testing-reveals-high-levels-of-toxic-pfas-in-artificial-turf/ 4-66
more than three times higher than those sampled using a similar method in the North Atlantic subtropical gyre.”
26,27,28
Synthetic turf fibers have been found in the world’s oceans, ranging from 12 to over 15 percent of the microplastics found, as reported by researchers in Spain, China, Japan, Australia and Canada. Synthetic turf blades represent as much as 25% of microplastics in surface waters.29 This research lead to the California Coastal Commission's decision to not allow synthetic turf at UC Santa Barbara (13 Dec 2023) and stating synthetic turf is not superior to natural grass and is not sustainable.
“Section 21080.5(d)(2)(A) of CEQA prohibits the Commission from approving a proposed development if there are feasible alternatives or feasible mitigation measures available that would substantially lessen any significant adverse effect which the activity may have on the environment. For the reasons discussed in this report, the Commission has conditioned the NOID to require design and implementation of Final Revised Project Plans that do not include the installation of artificial turf.”30
Microplastics both leach and adsorb toxic chemicals and bacteria in the environment, putting the food chain at risk.

With virtually all plastic ever made still in existence, the impact on the environment, ecosystems and biodiversity loss from the chemical leachate and microplastics is immense. From zooplankton, krill, whales, bees, and terrestrial animals of the Americas, macro-, micro- and nanoplastics are impacting aquatic and wildlife, and even our pets. Synthetic turf and microplastics have caused a decrease in bird populations, accumulation of microplastics on bees, and negatively impacts ocean habitats and biodiversity both above and below ground.

Research from 2021 estimated that >1500 species have ingested microplastics.31 Found from 31 Santos, RG, Machovsky-Capuska, GE, Andrades, R (2021). “Plastic Ingestion as an Evolutionary Trap:

Toward a Holistic Understanding.” Science: 373, 56–60. https://pubmed.ncbi.nlm.nih.gov/34210877/ 30 California Coastal Commission (13 Dec 2023). “Notice of Impending Development UCS-NOID-0002-23 (Baseball Stadium Turf).”
https://documents.coastal.ca.gov/reports/2023/12/W13.1a/W13.1a-12-2023-report.pdf 29 De Haan, WP, Quintana, R, Vilas, C, Cózar, A et al (1 Oct 2023).“The dark side of artificial greening:

Plastic turfs as widespread pollutants of aquatic environments.” Environmental Pollution; 334, 122094. https://www.sciencedirect.com/science/article/pii/S0269749123010965?via%3Dihub 28 Personal email communication from research staff at Tahoe Environmental Research Center. Lake Tahoe Email

27 Spencer, C (2023). “Lake Tahoe has higher concentration of microplastics than ocean trash heap.” LA Times.
https://www.latimes.com/california/story/2023-07-14/lake-tahoe-troubling-concentration-microplastics 26 Schultz, Madison. 2022. “UC Davis Environmental Research Center fundamental at Lake Tahoe.” Sierra Sun. Accessed 26 Oct 2023.
https://www.sierrasun.com/news/uc-davis-environmental-research-center-fundamental-at-lake-tahoe/ 4-67
the peak of Mount Everest to the depths of the Mariana trench, microplastics have now been found in high levels in air exhaled by dolphins via their blowholes.32 It is estimated that roughly one million seabirds and 100,000 marine mammals are killed annually from plastic in our oceans.

In its 2024 Report, the World Wildlife Fund reports a loss of 73% of wildlife populations in the period from 1970 to 2020.33 From cradle to grave, fossil fuel extraction to production, manufacturing, use and disposal, plastics impact healthy soil, water, ecosystems, human health and wildlife.

Impervious surfacing:
“Grass doesn’t waste water. People do!”
Dr. James Baird, UC Riverside Turfgrass Management Program

Plastic turf does not save water: Synthetic turf requires approximately 989 gallons of water to produce 1 square meter of turf,34 estimated to be the equivalent of watering a square meter of natural grass for 18 years. Additional water is required for cooling to a safe temperature for 34 Waterwise UK. “How to save water: Artificial Grass’s Footprint.” https://www.waterwise.org.uk/save-water/
33 World Wildlife Federation (2024). “Living Planet Report: 2024. Nature is Disappearing: The Average Size of Wildlife Populations Has Fallen By a Staggering 73%.” https://livingplanet.panda.org/en-US/ 32 Dziobak, MK, Fahlman, A, Wells, RS (16 Oct 2024). “First evidence of microplastic inhalation among free-ranging small cetaceans.” PlosOne.
https://journals.plos.org/plosone/article?id=10.1371/journal.pone.0309377 4-68
playing as well as for cleaning pollution, bodily fluids (like blood and vomit), animal waste, mold, bacteria and more from plastic turf and is often a condition of warranty.

Per various maintenance manuals, cleaning of synthetic turf requires the use of toxic chemicals, including synthetic herbicides and fungicides,35,36 which will be added to the toxic run-off that leaches from the plastic to soil, air and water.

Synthetic turf is an impervious, or impermeable, surface, despite manufacturer claims of exhorbitant rainfall their products are rated for. The US EPA and the State of California are clear on this issue:37
“...areas such as gravel roads...that will be compacted through design or use to reduce their impermeability.” It further has defined impervious surfaces as…[a]ny surface that prevents or significantly impedes the infiltration of water into the underlying soil. This can include but is not limited to: roads, driveways, parking areas and other areas created using non porous material; buildings, rooftops, structures, artificial turf and compacted gravel or soil.”
“Pollutants from aerial and terrestrial sources accumulate on impervious surfaces until runoff from a precipitation event carries sediment, nutrients, metals, and pesticides into stormwater drains and directly to local water bodies. As impervious surfaces increase, stormwater runoff increases in quantity, speed, temperature, and pollutant load. When impervious surfaces reach 10–20% of local watershed area, surface runoff doubles and continues to increase until, at 100% impervious surface coverage, runoff is five times that of a forested watershed. Excessive stormwater runoff also increases the potential for flooding.” US EPA Impervious Surface Fact Sheet38
As impervious surfaces increase, so does accumulation of particulate matter from traffic and wildfires, jet and leaded AVgas fuel from the multiple flight paths over Beverly Hills, bringing even more need for concern.
38 US EPA (2020). “EnviroAtlas: Fact Sheet, Percent Impervious Area.” https://enviroatlas.epa.gov/enviroatlas/DataFactSheets/pdf/ESN/PercentImperviousArea.pdf 37 US EPA, MS4 General Permit Appendix A, Definitions, Abbreviations and Acronyms, https://www3.epa.gov/region1/npdes/stormwater/ma/2016fpd/appendix-a-2016-ma-sms4-gp.pdf 36 Safety Data Sheet: Spectracide
https://s7cdn.spectrumbrands.com/~/media/HomeAndGarden/Spectracide/Files/SDS/SpectracideWeedGr assKillerConcentrate296882658845SDSJun23.pdf
35 Product label: RoundUp
https://www3.epa.gov/pesticides/chem_search/ppls/071995-00029-20220406.pdf 4-69

Toxic runoff from synthetic turf contributes 27,000 gallons per one inch of rain per acre of plastic.39 Plastic lawns are not are not exempt from this runoff.40 Beverly Hills has had 77.78 inches of rainfall since 2022.41 The amount of PFAS alone that has run off from Beverly Hills plastic lawns just since 2022 is enormous.
41 LA Almanac. Season Rainfall (Precipitation): Beverly Hills. Accessed 1 Apr 2025. https://www.laalmanac.com/weather/we143b.php
40 Simpson, TJ, Francis, RA (Aug 2021). “Artificial lawns exhibit increased runoff and decreased water retention compared to living lawns following controlled rainfall experiments.” Urban Forestry & Urban Greening; (63), 127232
https://www.sciencedirect.com/science/article/abs/pii/S1618866721002570 39 Cotrone, V (undated). “The Role of Trees and Forests in Healthy Watersheds: Managing stormwater, reducing flooding, and improving water quality.” Penn State Extension. https://extension.psu.edu/the-role-of-trees-and-forests-in-healthy-watersheds 4-70
Visible from Google Earth, Beverly Hills has many homes with synthetic turf in both front and backyards as well as on balconies. Together with features such as tennis courts, swimming pools, concrete driveways and patios, there is often little pervious land. Additionally, many of these homes are also found on hillsides, making them more susceptible to flooding and landslides.42,43 Even on a good day, traffic in Beverly Hills and the surrounding area is a challenge to negotiate. Add wildfire, flooding or landslides, and it becomes a death trap.

Heat & Heat Island effect:

Plastics get extremely hot and pose a risk for thermal burns, sometimes significant enough to require hospitalization. Synthetic turf can readily become much hotter than asphalt, reaching temperatures of 1600F to 1800F (regardless of infill type) and have even reached well in excess of 222.8oF (106oC). At a surface temperature of 118°F, a first-degree thermal burn occurs in 15 minutes, becoming a 3rd degree burn (full skin-thickness) in 20 minutes; at a temperature of 140°F, 1st degree burns occur in 3 seconds, and 3rd degree burns in 5 seconds.44 44 Moritz AR, Henriques FC Jr (1947). Original source. “Studies of thermal injury II: The relative importance of time and surface temperature in the causation of cutaneous burns.” Am J Pathol.; 23:
915-941. http://www.antiscald.com/index.php?route=information/information&information_id=15 43 Vogt, E (26 Oct 2021). “NJ prep school’s turf field blamed for rockslide that displaced 45 families.” NJ 1015.
https://nj1015.com/nj-prep-schools-turf-field-blamed-for-rockslide-that-displaced-45-families/ 42 Strunsky, Steve. 2021. “400-Year-Old N.J. Forest Cut Down for Fake Turf Field May Be to Blame for Rock Slide After Ida.” NJ.com. Accessed 23 Oct 2023.
https://www.nj.com/news/2021/10/400-year-old-nj-forest-cut-down-for-fake-turf-field-may-be-to-blame-for-r ock-slide-after-ida.html?outputType=amp
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Natural grass Adjacent plastic Plastic turf; plant infill Same plastic field; 84F ambient air turf (GeoFill)109F ambient air different color Plastic turf with crumb rubber infill
105F ambient temperature
Los Gatos, CA
July 2024
The Lawrence Berkeley National Laboratory released a report in April 2024 finding that the greenhouse emissions from plastics are four times those emitted by the aviation industry.45
45 Nihan, K, Khanna, N, Shah, N (Apr 2024). “Climate Impact of Primary Plastic Production.” Lawrence Berkeley National Laboratory. https://energyanalysis.lbl.gov/publications/climate-impact-primary-plastic 4-72
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Synthetic turf off gasses methane and ethylene46 in ever increasing amounts:
● Methane traps 90% more heat than carbon dioxide.47
● Methane is 21 times more potent than carbon dioxide.
● Land based plastics produce 2 times more methane and 76 times more ethylene than plastics in waterways and oceans.41
● GHG emissions of 527 tons of CO2e per ten-year use period per 7881m2 plastic field.48 ● Heat islands extend beyond the footprint of the field, impacting the surrounding community; are visible from satellites in space.

The resulting impact on climate change from plastics and synthetic turf are contributing factors to increased flood risk and toxic runoff49; toxic exposures during wildfires50,51; and escalating insurance costs due to both.52,53,54
54 Capani, C (7 May 2024). “Aviva issues flood risk warning as residents turn to artificial lawns.” Insurance Times; United Kingdom.
https://www.insurancetimes.co.uk/news/aviva-issues-flood-risk-warning-as-residents-turn-to-artificial-lawn s/1451833.article
53 Sherriff, L (18 Mar 2024). “Climate change is fuelling the US insurance problem.” British Broadcasting Corp.
https://www.bbc.com/future/article/20240311-why-climate-change-is-making-the-us-uninsurable

52 Mandel, A, Battiston, S, Monasterolo, I. (5 Feb 2025). “Mapping global financial risks under climate change. Nature, Climate Change.
https://doi.org/10.1038/s41558-025-02244-x
51 Staff writer (17 Jan 2025). “Plastic Chemicals in Wildfire Smoke and How to Protect Yourself.” Plastic Soup Coalition.
https://www.plasticpollutioncoalition.org/blog/2025/1/17/plastic-chemicals-in-wildfire-smoke-and-how-to-pr otect-yourself
50 Schlanger, Z (15 Jan 2025). “What Happens When a Plastic City Burns.” The Atlantic. https://www.theatlantic.com/science/archive/2025/01/los-angeles-fire-smoke-plastic-toxic/681318/ 49 Simpson, TJ, Francis, RA (Aug 2021). “Artificial lawns exhibit increased runoff and decreased water retention compared to living lawns following controlled rainfall experiments.” Urban Forestry & Urban Greening; (63), 127232
https://www.sciencedirect.com/science/article/abs/pii/S1618866721002570 48 Magnusson, Simon, Mácsik, Josef (July 2017). “Analysis of Energy Use and Emissions of Greenhouse Gases, Metals and Organic Substances from Construction Materials Used for Artificial Turf.” Resources, Conservation and Recycling: (122), Pages 362-372. https://doi.org/10.1016/j.resconrec.2017.03. 47 Climate Reality Project (2020). “REPOWER AMERICA®: Methane Stinks: Why Natural Gas is Bad News For The Planet.”
https://www.climaterealityproject.org/blog/methane-stinks-why-natural-gas-bad-news-planet? ga=2.52526 049.897177029.1647384251-251106713.1647384251
46 Royer, SJ, Ferrón, S, Wilson, ST, Karl, DM (2018). “Production of Methane and Ethylene from Plastic in the Environment.” PlosOne 13(8): e0200574.
https://journals.plos.org/plosone/article/file?id=10.1371/journal.pone.0200574&type=printable 4-74
NOT recyclable:

Less than 6% of plastics are recycled.55 Made of mixed plastics, synthetic turf is not recyclable,not sustainable and is a linear, not a circular product. The synthetic turf industry misrepresents its products with claims related to sustainability and environmental friendliness. It does not meet any definition of sustainability, nor is it environmentally friendly. It is not enough to use the vernacular of the day.

Under SB54-Allen (2022),56 “recycle” or “recycling” does not include any of the following:
● Combustion
● Incineration
● Energy generation
● Other forms of disposal
● Fuel production (except for anaerobic digestion of source separated organic materials) To be considered recycled, covered material shall be sent to a responsible end market.

The reality is, many landfills will not accept the massive amounts of plastic waste synthetic turf fields consist of. Removal of each regulation-sized field would result in approximately 200 rolls weighing 2,000 pounds each, then transported 18 rolls per flatbed semi-truck to their disposal site. They are most often dumped on agricultural land or stored in warehouses and listed for resale to unsuspecting customers on Craigslist, Facebook Marketplace and other internet outlets. This is not recycling, but rather kicking the can down the road, leaving future generations to contend with the multiple long term human and environmental health effects from massive quantities of plastic waste.

We cannot stress strongly enough that there is NO independently verifiable “recycling” of synthetic turf anywhere. Again, claims are claims and do not constitute proof. 56 Senate Bill No. 54: CHAPTER 75: An act to amend Section 41821.5 of, to add Chapter 3 (commencing with Section 42040) to Part 3 of Division 30 of, and to repeal Section 42064 of, the Public Resources Code, relating to solid waste.
https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=202120220SB54 55 Dell, J, Enck, J (May 2022). “The Real Truth about the US Plastic Recycling Rate.” Beyond Plastics. https://static1.squarespace.com/static/5eda91260bbb7e7a4bf528d8/t/62b2238152acae761414d698/1655 841666913/The-Real-Truth-about-the-US-Plastic-Recycling-Rate-2021-Facts-and-Figures-_5-4-22.pdf 4-75

San Martin, CA New Jersey Warehouse Pescadero, CA

Hesperia, CA Sacramento, CA
Old plastic playing fields and used tire crumb piling up The city of Los Angeles Sanitation Department is recommending disposal of synthetic turf in hazardous waste landfills.
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Viable alternatives:

The Beverly Hills Planning Commission already has identified native plants as viable natural, living options to synthetic turf.
57 Natural grass actively sequesters carbon dioxide and provides a cooling function that is especially dramatic when compared to the heat generated by synthetic turf. Grass naturally filters toxins, performs important eco-services for the soil beneath, and provides widely dispersed rainwater infiltration allowing absorption and recharging of the water table.

Additionally:58
● Research suggests that grasses can accumulate and deposit carbon into the soil by approximately one-half ton of carbon per acre per year for 30 to 40 years. ● Organic management and zero emission maintenance equipment mitigate emissions, reduce costs over time, and increase carbon sequestration. ● Electric mowers for playing fields and chalk markers are commercially available. 58 The Lawn Institute. “Carbon Sequestration.” Accessed 2 Feb 2025. https://www.thelawninstitute.org/environmental-benefits/carbon-sequestration/ 57 Braun, RC, Mandai, P, Nwachukwu, E, Stanton, A (17 Oct 2024). “The role of turfgrasses in environmental protection and their benefits to humans: Thirty years later.” Crop Science; (64)2, pp2909-3618.
https://doi.org/10.1002/csc2.21383
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● Drought59 and desert tolerant60,61 varieties of natural grass appropriate for lawns, parks and high use playing fields are available.
● Grass fields support biodiversity, both above and below the ground. ● 5,000 ft.2 of natural grass can provide enough daily oxygen for 34 Angelenos.62 SHPFI urges Beverly Hills to join the growing list of communities in CA and across the country opting to make the responsible choice for both people and planet by banning this highly toxic product, both for today’s residents and for generations to come, who will otherwise be left with the multiple burdens to human and environmental health from this fossil fuel-based petrochemical plastic product.

Respectfully submitted,
Diana Conway, President
Dianne Woelke MSN, Board Member
Safe Healthy Playing Fields, Inc.
https://www.safehealthyplayingfields.org
SHPFI is an all-volunteer nonprofit 501-c-3
62 The Lawn Institute. “Fresh Oxygen Production by Natural Grass Lawns in the United States.” https://www.thelawninstitute.org/wp-content/uploads/2021/02/TLI-FreshO2production_US-Final.pdf 61 University of Nevada, Reno. “Turfgrasses for Urban Mojave Desert Landscapes.” UNR Extension, College of Agriculture, Biotechnology & Natural Resources. https://extension.unr.edu/publication.aspx?PubID=3320
60 Baird, J (25 Nov 2024). “Drought-friendly UCR turfgrass is now on the market:The newly commercialized Coachella™ cultivar uses up to 65% less water than California's go-to choice for lawns.” University of California, Riverside; UCR News.
https://news.ucr.edu/articles/2024/11/25/drought-friendly-ucr-turfgrass-now-market 59 Los Angeles Times (9 Sep 2022). “Column: Has a UC Riverside researcher created the Holy Grail of drought-tolerant lawns?”
https://www.latimes.com/california/story/2022-09-09/uc-riverside-turfgrass-research-jim-baird 4-78
1 Subject: Clarification on Public Comment for Synthetic Turf (5/22/25 Planning Commission) From: Samantha Martinez <[email protected]>
Sent: Tuesday, May 13, 2025 6:08 PM
To: Patrick Achis <[email protected]>; [email protected]; [email protected] Cc: Chloe Chen <[email protected]>
Subject: RE: Clarification on Public Comment for Synthetic Turf (5/22/25 Planning Commission) I’ve attached a bit of material for your review as discussed  The first document is a brief slide presentation on the facts about turf.  The second is a one-pager on some key questions we discussed along with some links to brief videos and studies Joe mentioned. (The Rice video shows the technology and though around protecting athletes)  Lastly, below, is a summary and link to a study on Synthetic Turf that was just released by the California Office of Environmental Health Hazard Assessment (OEHHA) (study is attached) TenCate’s Pivot turf does not include crumb rubber, no PFAS are used in the manufacturing process, is recyclable and cooler than old school turf. There is a new Pivot field at DaVInci School 201 N Douglas Street 90254. Included in the material is a video about their field.

Hope this information finds you well and don’t hesitate to reach out on any follow up.

Best, Sam
The California Office of Environmental Health Hazard Assessment (OEHHA) released its draft study on synthetic turf. OEHHA conducted this study to assess potential health risks associated with the use of synthetic turf fields containing crumb rubber. Overall, this study found no significant health risks to players, coaches, referees, and spectators from on-field or off-field exposure to chemicals in crumb rubber infill from synthetic turf fields based on the assessment method and available data.

Additional takeaways include:
 There are no chemical exposures associated with the turf fields that would pose immediate health hazards.
 The use of synthetic turf fields does not pose hazardous levels of exposure to chemicals that can cause irritation of the eyes or airways.  The study found that, on average, people using the fields were not exposed to levels of chemicals that can cause harm to childhood development or the male or female reproductive systems.
 On average, long-term use of the fields does not result in exposures to chemicals that pose significant non-cancer health hazards.
 Cancer risks from the crumb rubber infill used in the artificial turf fields, on average, are insignificant for athletes, coaches and referees (i.e., less than one additional 4-79
2 cancer case in a population of 1 million people playing or spending time on the fields during a 70-year lifetime).
 This study completed a non-targeted chemical analysis of the crumb rubber and did not detect PFAS. However, the study noted that the suspected source of PFAS chemicals is not crumb rubber infill or air, but the artificial turf blades.

The study investigated 35 synthetic turf fields of various ages and in areas of different climate across California. OEHHA consulted with federal agencies, researchers, players, parents, and coaches to design the study. OEHHA also formed a Scientific Advisory Panel of seven scientific experts in exposure, laboratory work, and biomedical sciences. The Panel held annual public meetings to provide input.

Based on the OEHHA's consultations, literature reviews, and work with research partners, this synthetic turf study includes unique features, including:
 The bioaccessibility measurements of chemicals in crumb rubber samples using dynamic extraction systems to enhance the accessibility of chemicals with low water solubility and to mimic the physiological conditions on the skin surfaces and at the gut linings.
 Time-activity studies of soccer players in California and the development of soccerspecific exposure parameters to provide California-specific activity data and more accurate exposure data for risk assessment.
 The development of toxicity criteria of tire-related chemicals to enhance the assessment of human health risks from exposure to chemicals from crumb rubber on the fields.
 The assessment of health risks of four receptor categories of synthetic turf field users – players, coaches, referees, spectators – in order to provide a comprehensive understanding of the risks of exposure for each field user category and in various age groups.

Additionally, the study's appendices can be found here.

Samantha Martinez
Kindel Gagan
523 W 6th Street, Suite 516
Los Angeles, CA 90014
[email protected]
213‐624‐1550 office
213‐280‐8537 cell
The City keeps a copy of all E-mails sent and received for a minimum of 2 years. All retained E-mails will be treated as a Public Record per the California Public Records Act, and may be subject to disclosure pursuant to the terms, and subject to the exemptions, of that Act.
4-80
1131 Broadway Street
Dayton, TN 37321-1802
Tel (423) 775-0792
Tel (800) 251-1033
Fax (423) 775-5813
www.tencategrass.com
North America
May 13, 2025
Beverly Hills Planning Commission
Beverly Hills City Hall
455 North Rexford Drive
Beverly Hills, CA 90210
Dear Commissioners,
Thank you for the opportunity to share this information about artificial turf – recent studies, factual data, independent studies and the industry’s efforts to address concerns raised by environmental groups about the impacts of artificial turf of the environment, public health and safety. We believe that the City’s current regulations on installing turf are thoughtful and balanced. We are concerned that the recommendation to prohibit synthetic turf installations in residential front yards and to phase out existing installations over 15 years is unnecessary and not based on current product advances or scientific data.

We appreciate the staff including the latest, up to date turf research and information that TenCate shared in the public comment material. This research and some of the new solutions provide compelling evidence that modern turf products are both safe and sustainable. The City of Beverly Hills can be a leader in mandating high standards for turf installation moving forward – while allowing your residents the ability to choose what is best for their needs on their property. The City already requires that artificial turf products do not include infill, but it can go farther mandating recycling, PFAS-Free products and lower heat levels. We believe that turf is a good option for some uses as it reduces water use, chemicals and provides more play space. These are important factors that we hope the Commission will consider when developing your policy.

TenCate’s Leadership and Commitment to Safety and Sustainability

1. Established Track Record
TenCate Grass is the largest manufacturer, distributor, installer, and recycler of artificial turf in the United States—and a global industry leader. We recognize and respect the concerns surrounding artificial turf, and in response, we have devoted significant resources to develop more sustainable turf systems. Numerous independent studies and comprehensive research reviews have repeatedly demonstrated the safety of artificial turf. Our continued work reinforces these findings and ensures that our products meet or exceed health, safety, and environmental standards.

2. Advanced Turf Solutions & Research
Our latest innovations exemplify our dedication to safer and more environmentally friendly turf systems. Below are some key updates:
4-81
1131 Broadway Street
Dayton, TN 37321-1802
Tel (423) 775-0792
Tel (800) 251-1033
Fax (423) 775-5813
www.tencategrass.com
North America
• PFAS-Free Since October 2023: We proactively eliminated the use of PFAS in our turf products to address public health concerns.
• No Performance Infill Required – Pivot™: By removing traditional infill formulations, primary microplastics pollution is eliminated and the surface can be 30–50 degrees cooler than turf systems using rubber and/or conventional abrasive materials. • Equivalent Injury Rates: Independent studies by the NFL and NCAA demonstrate no difference in injury rates when comparing artificial turf to premier-quality natural grass stadium fields. Indeed, research evidence identified that turf can be significantly safer than regularly used grass fields, such as those used by high schools and community parks. • Recyclability: Turf systems can be recycled. TenCate has a turf recycling center in Louisiana and a leased facility in Hesperia, California, to collect and process turf for recycling—including a field recently removed from Stanford University. TenCate also led the way in the Netherlands in 2019 which now has over 95 % of turf fields recycled. • Water Conservation: Artificial turf saves significantly more water than natural grass fields—an important factor in water-sensitive regions.
• Chemicals: Unlike natural grass fields, artificial turf fields “do not” require the use of any pesticides, fertilizers or herbicides (many of which contain PFAS or are classified as PFAS) – all of which contaminate the soil in and around natural grass fields and that can find their way into our water.
• Increased Playability & Equity: Artificial turf dramatically increases playing availability compared to natural grass fields, enhancing community access.

Supporting Regulation and Collaboration
We value the feedback from environmental and community groups and acknowledge the importance of ongoing engagement with all stakeholders. As we mentioned to County staff, the turf industry supports robust regulation that addresses community concerns. Our current collaboration with the City of Los Angeles on a comprehensive turf regulation ordinance is an example of how regulation, rather than a ban, can protect public health, reduce environmental impacts, and still provide the many benefits of artificial turf. Originally, Los Angeles proposed a ban; however, upon further evaluation, the City recognized that thorough regulation is a more effective path forward.

Accordingly, we invite the City of Beverly Hills to consider the possibility of a “full regulation” of artificial turf rather than a ban. Such an approach would allow for continued innovation, ongoing improvements, and critical benefits—like water conservation, expanded recreational opportunities, and verified safety metrics—while ensuring that health and environmental standards are rigorously maintained.

With these considerations in mind, we respectfully request that the Commission work with staff to develop thoughtful and strong minimum standards which will allow your residents the right to choose what is best for them while upholding strong standards for the City. 4-82
1131 Broadway Street
Dayton, TN 37321-1802
Tel (423) 775-0792
Tel (800) 251-1033
Fax (423) 775-5813
www.tencategrass.com
North America
Conclusion
Thank you for your consideration and for the thoughtful approach the City of Beverly Hills has taken thus far. TenCate remains committed to working with you, your staff, and all stakeholders to ensure that residents benefit from the proven advantages of artificial turf while safeguarding public health and the environment.

Should you have any questions or wish to discuss our recommended approach further, please feel free to contact us. We look forward to the opportunity for continued collaboration.

Thank you for your consideration.

Very sincerely,
Joe Fields
CEO
4-83
Information on Turf
Issues to consider
 Water saving for turf vs. well maintained natural grass fields.  Equity (equal and open play for all) & health benefits  Chemicals involved in maintenance of grass fields (pesticides, diesel or gas powered mowers)
 Number of turf fields in parks, schools and homes and cost to remove/replace  Cost to install/maintain grass versus turf
Material or studies
 Video featuring Joe Fields, CEO TenCate Grass Americas  Video featuring Rice University staff
 The Facts on Turf
 University of Zurich study
 Study of non-extractable Fluorine in Artificial Turfs from Stockholm, Sweden  https://youtu.be/TYhoghW3Xgs - Pivot installation at DaVinci High School in El Segundo Is turf recyclable – and up-cyclable?
 Yes, turf fields are currently being recycled
 We are moving towards a circular model for turf recycling, where materials remain in play.
 TenCate has constructed its first dedicated turf recycling facility in Baton Rouge, LA.  TenCate has a 5-year recycling history in Amsterdam, providing the Baton Rouge team with an existing process knowledge base and recommendations for best practices.  The process separates materials - sand, rubber, cork, other components plastic – and removes any contaminants.
 Plastic is shredded and densified. Sand and rubber are sold for reuse in other applications.
 Finally, the densified material is advanced recycled where the material is turned into new products, which can be used to create food-grade products.  The Baton Rouge facility is currently online and has processed more than 60 fields to date.

Safety, are PFAS removable, children and worker safety.  TenCate has removed PFAS from our manufacturing process. 4-84
 TecCate has removed rubber infill from turf which eliminates infill migration to waterways as well as reduces the heat impact
 PFAS levels in heritage turf are much lower than those in everyday products like medicines, oral care and beauty products, and shampoos.

Information and studies on PFAS
 Study of non-extractable Fluorine in Artificial Turfs from Stockholm, Sweden 4-85
The facts
about turf.
4-86
2 Build healthier, more beautiful communities.

Our Vision
Turf is facing opposition and fear from many
environmental groups based on false or outdated
information.

We Understand
The Turf we manufacture complies with all
US (EPA/CDC), EU (REACH) and California Prop 65
quality and safety standards.

Safety First
Our vision: to build healthier, more beautiful communities. 4-87
Used in footwear to replace leather, creating
lightweight sports shoes, safety shoes, and recycled
soles.

Polyurethane Commonly used in water bottles.

Polyethylene
Used in items like face masks, yoga pants, yogurt
containers, children’s toys and food packaging.

Polypropylene
Frequently used in food packaging, medical
equipment, jerseys and athletic wear.

Polyester
Myth: turf is made from dangerous chemicals.

Fact: turf is made from the same materials we use everyday. 4-88
4 No heavy metals
EN71-3 | ASTM F963
CA Prop 65
Compliant
Compliant with toy
standards including no
lead or other toxic
materials.

Heavy
Metals
Myth: turf is made from dangerous chemicals.

Fact: turf is compliant with CA Prop 65 and toy standards. https://www.trade.gov/eu-reach https://www.p65warnings.ca.gov/ 4-89
• PFAS was removed from our
manufacturing process beginning
October 2023.
• PFAS levels in heritage turf are
much lower than those in everyday
products like medicines, oral care
and beauty products, and
shampoos.

Myth: artificial turf contains PFAS.

Fact: TenCate turf
contains no PFAS1
.
1Manufactured without PFAS
4-90
Myth: runoff from turf is polluting our water.
• Synthetic turf does not
require pesticides and
fertilizers that can harm soil
health.
• Harmful chemicals can leach
into local watersheds,
negatively impacting potable
water sources or aquarian
ecosystems.

Fact: grass field maintenance
is more harmful to local
water systems than turf.
4-91
Myth: turf is more difficult to clean.

Fact: Turf can be cleaned with
the same dish washing
detergent used at home.
• No toxic chemicals necessary
• Prop 65 compliant
4-92
Myth: more injuries occur on turf than natural grass .

Fact: There is no statistical difference between
injury occurrence on turf and well-maintained grass.
• Extensive research by the NFL, NCAA1
and academic
institutions2 have found no difference in overall
injury rates.
• Challenges with early turf3 – like increased injury
rates, turf toe and player discomfort have been
addressed through continuous advancements in
turf research and innovation.
1 Incidence of Knee Injuries on Artificial Turf Versus Natural Grass in National Collegiate Athletic Association American Football: 2004-2005 Through 2013- 2014 Seasons (2019) Authors: Loughran et al. 2Comparison of Injuries Sustained on Artificial Turf and Grass by Male and Female Elite Football Players (2010) Authors: Ekstrand et al. 3https://pmc.ncbi.nlm.nih.gov/articles/PMC2577464/ 4-93
Myth: turf is impermeable and does not drain.
1 ASTM F2898 - Standard Test Method for Permeability of Synthetic Turf Sports Field Base Stone and Surface System by Non-confined Field Testing. 2 Hurricanes Katrina (2005) Harvey (2017).

Fact: most turf systems are
designed to drain 10-20 inches
of rain per hour 1.
• Turf is commonly designed to
store large volumes of water in
the base system to help
prevent flooding.

Some of the worst hurricanes in
history 2 dumped 2-3 inches of
rain per hour.
4-94
Fact: TenCate pioneered turf
recycling in the Netherlands in
2018.
• Now, more than 95% of turf
fields are recycled in the
Netherlands.
• Over 90% of components of a
field can be recycled, including
infill, turf and pads.

A dedicated turf recycling plant has
been constructed in Baton Rouge,
Louisiana.
• More than 60 turf fields from
Massachusetts to California
have been recycled with more
capacity online everyday.

Myth: turf is not recyclable.

Turf removal Separation and Shredding
Bale for storage Densify for
advanced recycling
New recycled
material created
Shredded material
4-95
Artificial turf brings play to communities who need it
most. Whether it’s limited water, greenspace or
difficult weather conditions, turf makes play inclusive and equitable – exactly the way it should be.

Solutions for Your Community
Maintaining safe and usable natural grass fields
requires significant resources, posing challenges for
many schools and communities.

Maintaining Safe Surfaces
No matter the weather or season, one artificial turf
field provides more annual playing hours than four
natural grass fields, with far less resource-intensive
maintenance.

Unlimited Playing Time
Turf solutions promote equity, health and community.
4-96
12 Toolkit includes:
- Video featuring Joe Fields, CEO TenCate Grass Americas - Video featuring Rice University staff
- The Facts on Turf
- University of Zurich study
- Study of non-extractable Fluorine in Artificial Turfs from Stockholm, Sweden - TenCate contacts
Click to access toolkit
4-97
Backup slides
13 4-98
Perfluoroalkyl and polyfluoroalkyl
substances (PFAS) are a large family
of fluorocarbon chemicals.

Chemicals used in the manufacture of a host of
everyday products due to their lubricating
properties.

Since their introduction in the 1940s, they have
been used widely. The abundance of their use
combined with their slow breakdown means
they are ubiquitous in the environment all
over the world.

PFAS
Study of non-extractable Fluorine in Artificial Turfs from Stockholm, Sweden Myth: PFAS from turf pollutes our water What are PFAS?
4-99
15 PRODUCT PFAS PPM1
(NON-BANNED)
Prozac, Lipitor, Flonase >5% (50,000)
Women's makeup
(L’oreal) 2,000
Shaving cream 1,000
Dental Floss 250,000 - 10,000
Body Lotion 300
TenCate Slit Film Turf < 1
TenCate Mono Turf < 1
PRODUCT** PPM PFOA, PFOS
(banned)
Fire suppression foam 15,000
Scotchgard 5,000
**Stain/fire protection on
pillowcases, clothing 300
**Fire resistant carpeting,
flooring 100-300
Coated Cookware 100-300
**Carpet, Flooring, Clothing, houseware items use PFAS mostly as fire resistance to meet compliance for FFA and 16 CFR standards. 1 PPM parts per million
PFAS levels in everyday life.

Non-Soluble long Chain Soluble Short Chain
PFOS/PFHxA/PFHxs (banned PFAS chemicals)
4-100
PFAS
The Unexpected
Ingredient
PFAS hangs out in some pretty unexpected places.

In fact, you can see it in things like makeup, prescription medications and even dental floss.

Dental Floss up to
248,900ppm
Prescription Medication
More than
50,000ppm
100ppm
Typical Artificial Turf less than
And TenCate has removed
intentionally added PFAS from our
manufacturing process completely.

Makeup up to
6,000ppm
16 4-101
OEHHA Synthetic Turf Study
March 2025
Public Review Draft
Prepared by
Pesticide and Environmental Toxicology Branch
Office of Environmental Health Hazard Assessment
California Environmental Protection Agency
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Office of Environmental Health Hazard Assessment
California Environmental Protection Agency
OEHHA Synthetic Turf Study i
March 2025

LIST OF CONTRIBUTORS AND ACKNOWLEDGEMENTS
Project Leads (in alphabetical order)
Jocelyn Claude, Ph.D.

Patty Wong, Ph.D.

Contributors (in alphabetical order)
Rebecca Belloso, M.P.H.

Lori Lim, Ph.D.

David Siegel, Ph.D.

Reviewers (in alphabetical order)
Vincent Cogliano, Ph.D.

Kannan Krishnan, Ph.D.

Lauren Zeise, Ph.D.

Acting Director
David Edwards, Ph.D.

Acknowledgements
This study is the product of an interagency collaboration between the Office of Environmental Health Hazard Assessment and CalRecycle (Department of Resources Recycling and Recovery). We acknowledge the efforts of our collaborators for this study.

We thank the Lawrence Berkeley National Laboratory for their contributions in developing study protocols, and collecting and analyzing field samples. We thank the University of California, Berkeley and the University of Arizona for their collaborations in collecting, analyzing, and providing the exposure survey and videotape footage data. We thank the field owners, field managers and exposure study participants without whom the study would not have been possible. We thank the Scientific Advisory Panel for their advice and guidance in the design and implementation of our study methods. We acknowledge the contributions of the United States Environmental Protection Agency, the National Toxicology Program, the Agency for Toxic Substances and Disease Registry, the Consumer Product Safety Commission, the European Chemicals Agency, U.S. Rubber Manufacturers Association, and the International Carbon Black Association. 4-104
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OEHHA Synthetic Turf Study ii
March 2025
Table of Contents
Executive Summary ................................................................................................ ES-1 Chapter 1. Introduction.............................................................................................. 1-1

1.1. Purpose of Study .............................................................................................. 1-1

1.2. Composition of Synthetic Turf Fields and Crumb Rubber ................................. 1-1

1.3. Design of the OEHHA Synthetic Turf Study ...................................................... 1-3

1.3.1. Approach to Identifying Chemicals of Concern........................................ 1-3

1.3.2. General approach to study design........................................................... 1-4

1.4. Components of Study and Organization of the Report...................................... 1-6

1.4.1. Collection of Crumb Rubber Infill and Air Samples from Fields Across California ........................................................................................................... 1-6

1.4.2. Analysis of Air, Crumb Rubber and Environmental Samples................... 1-7

1.4.3. Compilation and Development of Toxicity Criteria for Tire-Related Chemicals.......................................................................................................... 1-7

1.4.4. Determination of Activity Patterns and Parameters for Estimating Exposure .......................................................................................................................... 1-8

1.4.5. Risk Characterization .............................................................................. 1-8

1.4.6. Discussion ............................................................................................... 1-8

1.4.7. Appendices.............................................................................................. 1-9

1.5. References........................................................................................................ 1-9 Chapter 2. Collecting Samples from Synthetic Turf Fields Across California...... 2-1

2.1. Introduction ....................................................................................................... 2-1

2.2. Sampling for Protocol Development.................................................................. 2-1

2.2.1. Sampling Freshly Manufactured and Field Aged Crumb Rubber (Phase 1) .......................................................................................................................... 2-1

2.2.2. Testing of Field Sampling Protocols on Pilot Fields (Phase 2) ................ 2-2

2.3. Sampling of Fields Across California (Phase 3)................................................ 2-4

2.3.1. Selecting Fields: Stratified Random Sampling Technique ....................... 2-4

2.3.2. Conduct of the Statewide Sampling....................................................... 2-12

2.4. Summary: Types and Number of Samples Collected in the Statewide Field Work ............................................................................................................................... 2-17

2.5. References...................................................................................................... 2-18 4-105
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Chapter 3. Laboratory Analyses and Resulting Chemical Concentrations........... 3-1

3.1. Introduction ....................................................................................................... 3-1

3.2. Analysis of Crumb Rubber – Organic Chemicals in GI and Dermal Biofluid Extracts.................................................................................................................... 3-2

3.2.1. Identifying Chemicals for Analysis ........................................................... 3-2

3.2.2. Sample Extraction and Analysis .............................................................. 3-4

3.2.3. Results of Analyses of Artificial GI Fluids ................................................ 3-7

3.2.4. Results of Analyses of Artificial Sweat Extracts..................................... 3-10

3.2.5. Chemicals Found in GI vs Dermal Extracts ........................................... 3-13

3.3. Analysis of Crumb Rubber - Metals and Metalloids in Acid Extracts............... 3-14

3.3.1. Selection of Metals and Metalloids for Study and Analytical Method..... 3-14

3.3.2. Preparation, Extraction and Analysis of Field Samples ......................... 3-15

3.3.3. Results of Analysis of GI Extracts for Metals and Metalloids ................. 3-16

3.4. Analysis of Air Samples – for Evaluating Inhalation Exposures ...................... 3-19

3.4.1. Identifying Chemicals to Analyze in Air Samples................................... 3-19

3.4.2. VOCs Analyzed ..................................................................................... 3-20

3.4.3. Low Molecular Weight Carbonyls .......................................................... 3-22

3.4.4. SVOCs analyzed (SVOC sample trains)................................................ 3-23

3.4.5. Particle Monitoring................................................................................. 3-24

3.4.6. Results of Analyses of Air Samples....................................................... 3-25

3.5. Distinguishing Field-Related Chemicals from Non-Field Related Chemicals .. 3-31

3.5.1. Chemicals Detected in Biofluid Extracts and SVOCs in Air Samples .... 3-31

3.5.2. VOCs in Air Samples............................................................................. 3-31

3.5.3. Low Molecular Weight Carbonyls .......................................................... 3-34

3.5.4. Field Related Chemical Determinations................................................. 3-36

3.6. Analysis of Environmental Data ...................................................................... 3-37

3.6.1. Temperature.......................................................................................... 3-37

3.6.2. Ozone.................................................................................................... 3-38

3.6.3. Particles................................................................................................. 3-38

3.7. References...................................................................................................... 3-39 Chapter 4. Toxicity Evaluation and Criteria ............................................................. 4-1 4-106
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4.1. Introduction ....................................................................................................... 4-1

4.1.1. What is Toxicity? ..................................................................................... 4-1

4.1.2. What is a Toxicity Criterion?.................................................................... 4-2

4.2. Toxicity Criteria Compilation ............................................................................. 4-3

4.2.1. Chemicals with Established Toxicity Criteria ........................................... 4-5

4.2.2. Chemicals without Established Toxicity Criteria ...................................... 4-6

4.3. Grouping of Toxicity Criteria for Risk Assessment ............................................ 4-9

4.4. Toxicity Criteria for Inhalation Exposure to Organic Chemicals ...................... 4-10

4.4.1. Acute One-Hour Inhalation Exposure .................................................... 4-10

4.4.2. One-Day Inhalation Exposure: DART.................................................... 4-11

4.4.3. Chronic Inhalation Exposure: Sensory Irritation..................................... 4-13

4.4.4. Chronic Inhalation Exposure.................................................................. 4-13

4.4.5. Lifetime Inhalation Exposure: Carcinogens ........................................... 4-18

4.5. Toxicity Criteria for Oral or Dermal Exposure to Organic Chemicals .............. 4-19

4.5.1. One-Day Oral and Dermal Exposures: DART ....................................... 4-20

4.5.2. Chronic Oral and Dermal Exposures: General Toxicity Criteria............. 4-21

4.5.3. Lifetime Oral or Dermal Exposure to Carcinogens ................................ 4-24

4.6. Toxicity Criteria for Oral Exposure to Metals and Metalloids........................... 4-25

4.6.1. One-Day Oral Exposure to Metal or Metalloids: DART.......................... 4-26

4.6.2. Chronic Oral Exposure to Metals and Metalloids: General Toxicity ....... 4-26

4.6.3. Lifetime Oral Exposure to Carcinogenic Metals and Metalloids............. 4-27

4.7. Summary......................................................................................................... 4-28

4.8. References...................................................................................................... 4-28 Chapter 5. Exposure Characterization ..................................................................... 5-1

5.1. Background....................................................................................................... 5-1

5.2. Synthetic Turf Exposure Model: Exposure Scenarios ....................................... 5-2

5.2.1. Exposure Sources ................................................................................... 5-2

5.2.2. Receptor Categories................................................................................ 5-3

5.2.3. Exposure Pathways................................................................................. 5-4

5.3. Development of Exposure Parameters ............................................................. 5-9 4-107
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5.3.1. Time-Activity Studies (TAS) to Estimate Exposure Parameters .............. 5-9

5.3.2. Information from the Literature to Estimate Exposure Parameters ........ 5-12

5.3.3. Exposure Parameters Estimated ........................................................... 5-13

5.4. Exposure Assessment .................................................................................... 5-14

5.4.1. One-Hour Acute Exposures................................................................... 5-15

5.4.2. One-Day Exposures to DART................................................................ 5-16

5.4.3. Chronic Exposure to Sensory Irritants ................................................... 5-20

5.4.4. Chronic Exposures to General Chemicals............................................. 5-21

5.4.5. Carcinogens – Lifetime Average Daily Dose ......................................... 5-26

5.5. References...................................................................................................... 5-32 Chapter 6. Risk Characterization.............................................................................. 6-1

6.1. Background....................................................................................................... 6-1

6.2. Non-Cancer Hazards: Acute Toxicity ................................................................ 6-3

6.2.1. Inhalation Exposure................................................................................. 6-3

6.2.2. Dermal and Ingestion Exposures............................................................. 6-4

6.3. Non-Cancer Hazards: DART............................................................................. 6-4

6.3.1. Inhalation Exposure................................................................................. 6-4

6.3.2. Dermal and Oral Exposures .................................................................... 6-6

6.3.3. Hazard Index for DART ........................................................................... 6-7

6.4. Noncancer Hazards: Sensory Irritation ............................................................. 6-8

6.5. Noncancer Hazards: Chronic Effects ................................................................ 6-9

6.5.1. Inhalation Exposure................................................................................. 6-9

6.5.2. Dermal and Ingestion Exposures........................................................... 6-14

6.5.3. Hazard Index ......................................................................................... 6-15

6.6. Cancer Risk .................................................................................................... 6-18

6.6.1. Inhalation Exposure............................................................................... 6-18

6.6.2. Dermal and Oral Exposures .................................................................. 6-20

6.6.3. Multiple Routes of Exposure.................................................................. 6-21

6.7. References...................................................................................................... 6-23 Chapter 7. Discussion................................................................................................ 7-1 4-108
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7.1. Introduction ....................................................................................................... 7-1

7.2. Study Design and Unique Features .................................................................. 7-1

7.3. Study Boundaries and Limitations..................................................................... 7-2

7.4. Variability .......................................................................................................... 7-3

7.4.1. Sample Heterogeneity ............................................................................. 7-3

7.4.2. Time-Activity and Exposure Parameters.................................................. 7-3

7.4.3. Athlete Player Position............................................................................. 7-4

7.4.4. Combined Receptor Scenarios................................................................ 7-4

7.5. Uncertainty........................................................................................................ 7-4

7.5.1. Chemical Characterization and Source Designations.............................. 7-4

7.5.2. Exposure assessment ............................................................................. 7-5

7.5.3. Dose-Response Assessment .................................................................. 7-6

7.6. Cancer and Non-Cancer Risk Characterizations for Artificial Turf Field Users . 7-8

7.7. Conclusions .................................................................................................... 7-10

7.8. References...................................................................................................... 7-11 4-109
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List Of Abbreviations
ABR Average daily breathing rate
AD(inh or der or ing)-DARTfield
Average one-day exposure dose for a DART (for inhalation, dermal, or ingestion exposure) for an individual field
ADD(inh or der or ing) Average daily exposure dose for a general chemical or carcinogen (for inhalation, dermal, or ingestion exposure) AET Annual event time
AFinh (inh-DART or inhsensory)Adjustment factor for inhalation exposure or a general chemical (or a DART or sensory irritant)
ALD Aldehyde
ANOVA Analysis of variance
ASF Age sensitivity factor
ASTM American Society for Testing and Materials
AT Averaging time
ATSDR Agency for Toxic Substances and Disease Registry
BaP Benzo[a]pyrene
BRTW One-hour time weighted breathing rate
BW Bodyweight
CA California
CalRecycle California Department of Resources Recycling and Recovery Cair-avg Average concentration of a chemical in air across 35 fields Cair-field Average concentration of a chemical in air for an individual field
Cair-max Maximum one-hour concentration of a chemical in air CASRN Chemical Abstracts Service Registry Number
C(der or GI)-crumb rubber Average dermal or GI bioaccessible concentration in crumb rubber across 35 fields of a general chemical
C(der or GI)-crumb rubber-field Average dermal or GI bioaccessible concentration in crumb rubber for an individual field of a DART
CEC California Energy Commission
CERCH Center for Environmental Research and Children’s Health CF Conversion factor
Cinh (inh-DART-field or inhsensory)
Exposure concentration for a general chemical (or a DART or a sensory irritant)
CPSC Consumer Product Safety Commission
CSFanimal (or human) Cancer slope factor for animal (or human) CSFinh (or oral) Cancer slope factor for inhalation or (oral) exposure DART Developmental and reproductive toxicant
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DL Dermal load
DNPH 2,4-dinitrophenylhydrazine
DPPD N,N’-diphenyl-1,4-benzenediamine
ED Exposure duration
EG Ethylene glycol
EPDM Ethylene propylene diene monomer
ESI Electrospray ionization
EV(DART) Event frequency (for DARTS)
GC-MS Gas chromatography mass spectrometry
GF Glass fiber
GI Gastrointestinal
HES-GC-MS High efficiency source gas chromatography mass spectrometry
HI High impact area
HI(DART or sensory) Hazard index for general chemicals (or for DARTs or sensory irritants)
HPLC High performance liquid chromatography
HQder (or ing or inh) Hazard quotient for a general chemical for dermal (or ingestion or inhalation) exposure
HQder (or ing of inh)-DART Hazard quotient for dermal (or ingestion or inhalation) exposure for a DART
HQinh-sensory Hazard quotient for inhalation exposure to a sensory irritant HQder (or ing or inh)-sum Hazard quotient for the dermal (or ingestion or inhalation) route for all chemicals
HQder (or ing or inh)-DARTsum
Hazard quotient for the dermal (or ingestion or inhalation) route for all DARTs
HQinh-sensory-sum Hazard quotient for the inhalation exposure route for all sensory irritants
HRAM LC-MS High resolution accurate mass liquid chromatography mass spectrometry
HTM Hand-to-mouth
HTOTM Hand-to-object-to-mouth
IARC International Agency for Research on Cancer
ICP-MS Inductively coupled plasma mass spectrometry
IRdaily Daily crumb rubber ingestion rate for a general chemical IRDART One-day crumb rubber ingestion rate for a DART
IRIS Integrated Risk Information System
IUR Inhalation unit risk
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LADDder (or ing or inh) Lifetime average daily exposure dose of a chemical for dermal ( or ingestion or inhalation) exposure)
LBNL Lawrence Berkeley National Laboratory
LC-MS Liquid chromatography mass spectrometry
LOQ Limit of quantification
MADL Maximum Allowable Dose Level
MATES Multiple Air Toxics Exposure Study
MDL(b or s) Method detection limit (derived from blank sample or from spike sample)
MLATS Micro-level activity time series
MRL Minimal risk level
NTP National Toxicology Program
OEHHA Office of Environmental Health Hazard Assessment
OTM Object-to-mouth
PAH Polycyclic aromatic hydrocarbon
PDMS Polydimethylsiloxane
PEF Potency equivalent factor
PM2.5 Particulate matter of or less than 2.5 micrometers in diameter POD Point of departure
PPRTV Provisional Peer-Reviewed Toxicity Value
PUF Polyurethane foam
REL Reference exposure level
RfC Reference concentration
RfD Reference dose
ROF Rest of field
SAP Scientific Advisory Panel
SBSE Stir bar sorptive extraction
SOP Standard operation procedure
South Coast AQMD South Coast Air Quality Management District SVOC Semi-volatile organic chemical
TAS Time Activity Study
TCder (or ing or inh) Toxicity criteria for dermal ( or ingestion or inhalation) toxicity TD ThermoDesorption
TMBs Trimethylbenzenes
TPE Thermoplastic elastomer
TXIB 2,2,4-trimethyl-1,3-pentanediol diisobutyrate
UA University of Arizona
UCB University of California Berkeley
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USEPA United States Environmental Protection Agency
VOC Volatile organic chemical
VSC Volatile sulfur chemical
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Executive Summary ES-1
OEHHA Synthetic Turf Study
March 2025
Executive Summary
Introduction
CalEPA’s Office of Environmental Health Hazard Assessment (OEHHA) conducted this study of potential health risks associated with the use of synthetic turf fields containing crumb rubber by athletes, referees, coaches and spectators. The California Department of Resources Recycling and Recovery (CalRecycle) contracted with OEHHA in 2015 to conduct this study.

Concerns about possible health risks from exposure to chemicals in crumb rubber infills made of waste tires used in synthetic turf fields prompted this study. There were more than 320,000 active players on affiliated soccer teams and clubs in California in 2013- 14, the last year prior to the initiation of this study for which data were available. The California Legislature between 2014 and 2016 considered but did not enact a ban on synthetic turf fields containing crumb rubber. These fields were popular because they reduce the use of water and maintenance otherwise needed for natural grass fields. The use of crumb rubber also reduces injuries from slips and falls and allows for productive reuse of crumb rubber from used motor vehicle tires.

In 2015, CalRecycle compiled a database of 907 synthetic turf fields of various ages in California. A single field can contain more than 200,000 pounds of crumb rubber infill produced from automotive tires made in the United States as well as other countries.

The specific chemical content of crumb rubber varies greatly, and this variation is reflected not only in crumb rubber used across different fields, but also within a field.

OEHHA planned this study beginning in 2015 by engaging in extensive consultation with scientific experts from federal agencies and entities in other states. OEHHA conducted three public workshops in Northern and Southern California in late 2015 to seek input from the public and stakeholders. OEHHA formed a Scientific Advisory Panel consisting of seven experts in exposure and biomedical sciences that held annual public meetings between 2016 and 2019 to provide input.

Based on the comments and suggestions from these meetings, OEHHA’s turf study consists of the following:
• Investigating 35 synthetic turf fields of various ages and in areas of different climate across California, by collecting data on environmental conditions of each field.
• Conducting “non-targeted analyses” to identify the different kinds of chemicals that are present in crumb rubber, and measuring the extent to which users of the synthetic turf fields could be exposed to these chemicals. • Conducting “time-activity” studies of youth soccer players to obtain data on the contact with the crumb rubber that users of the fields typically incur. 4-114
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• Refining models that OEHHA has used to assess potential exposure and health risks.

Field Characterization
A key task in the study was to characterize the release of chemicals from crumb rubber infill on synthetic turf fields. OEHHA accomplished this task by recording environmental conditions and examining chemicals in samples collected at selected fields in California.

OEHHA contracted with Lawrence Berkeley National Laboratory (LBNL) to provide technical assistance in this effort.

OEHHA first narrowed down its database of 907 California synthetic turf fields to obtain a representative sampling of the fields across California that could feasibly be monitored and sampled. Fields were categorized by their locations in five climate regions (Southern Coastal Areas, Northern and Central Coastal Areas, Southern California Interior Valleys and Northern California’s Central Valley, Southern California High and Low Deserts, and Mountainous Area), and by their age (fields less than nine years old and fields nine years old or greater) based on communications with field owners indicating that warranties for the fields generally expired after eight years. OEHHA selected 35 fields covering these categories. After securing consent from owners of the fields, OEHHA conducted field work at these locations in 2016 and 2017.

Field work consisted of monitoring the 35 fields for environmental conditions and concentrations of airborne volatile organic compounds (VOCs), semi-volatile organic compounds (SVOCs), and fine particulate (PM2.5) during times when the fields were idle and when soccer activities on the fields were occurring. Off-field air samples were also taken for comparison to on-field samples. OEHHA also collected crumb rubber samples from 6 to 10 locations at each field. LBNL analyzed the air samples to identify the organic chemicals that were present for inhalation and used the crumb rubber samples to calculate the gastrointestinal (GI) and dermal bioaccessible concentrations of organic, metal, and metalloid chemicals in the crumb rubber.

The study detected 119 organic chemicals in the air at on-field locations. LBNL’s crumbrubber analyses involved the use of artificial sweat and gastric juices to evaluate the potential for these bodily fluids to take up the chemicals. The study detected 75 organic chemicals in artificial sweat extracts and 76 organic chemicals in artificial gastrointestinal extracts as well as 35 metals and metalloids potentially accessible to uptake through dermal contact and oral ingestion.

The chemicals detected were then assessed for their toxicity and exposure, to characterize the health risks to the turf field users and spectators, as explained in the next three subsections.

Toxicity Evaluation
Toxicity is defined as the degree to which a chemical or mixture of chemicals can impair 4-115
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function or cause damage to a tissue or organ system. Toxicity information for a chemical comes from studies of laboratory animals, studies of the effects of chemicals on workers and other human populations, and studies using tissues, cells or cell components from humans or animals.

A chemical’s toxic effects depend on how much is taken up into the body, also referred to as the dose. For purposes of this study, the intake of a chemical depends on the level of the chemical in the air or crumb rubber; the amount of chemical absorbed into the body from the air, through the skin, or through the gut in case of ingestion; and the frequency or duration of exposure, such as once, several times a month, or daily. For instance, a particular chemical can be a respiratory irritant after inhalation of a high concentration in the air for a few hours. The same chemical may also pose a significant cancer risk through inhalation at much lower concentration in the air after many years of exposure.

OEHHA compiled toxicity criteria for the various chemicals identified in the study.

Toxicity criteria for a specific chemical typically identifies a level of long-term exposure above which there may be a risk of cancer, or a level of short- or long-term exposure above which there may be a possibility of a health effect other than cancer (“non-cancer effect”). OEHHA used toxicity criteria it has developed for its other programs, as well as criteria developed by other entities such as the US Environmental Protection Agency, the US Agency for Toxic Substances and Disease Registry, and the International Agency for Research on Cancer.

Toxicity criteria covered health effects ranging from cancer to sensory irritation, reproductive and/or developmental toxicity, and other effects, including effects on the nervous system, respiratory system, kidneys and blood.

Exposure Characterization
The study focused on examining the exposure of soccer players (athletes) and other soccer-related participants (e.g., coaches, referees, and spectators), due to the popularity of soccer in California among all genders, and close and frequent contacts of players with the field surfaces. Since soccer can be a life-long sport for some participants, exposure duration of players on synthetic turf fields can span from a few years to decades. In fact, one-half of the respondents from the survey indicated playing more than eight years. Taken together, OEHHA determined soccer to be an appropriate surrogate for athletic activities on synthetic turf fields.

Synthetic turf fields often contain three major structural parts: synthetic grass blades, backing materials, and crumb rubber infill. Inhalation exposures can occur when chemicals (of various volatility) evaporate from the synthetic turf parts or adsorb to airborne fine particles in the air above the field. This study also accounted for dermal and oral exposures that can arise from the crumb rubber infill.

Athletes, coaches, referees, and spectators are the primary categories of individuals 4-116
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who may experience chemical exposures from synthetic turf fields. OEHHA adopted the following age groups to represent the individuals in these categories: third trimester fetus in pregnant women, newborns to children under age 2, children age 2 to under 6, children age 6 to under 11, children age 11 to under 16, teenagers age 16 to young adults under 30, adults age 30 to under 40, adults age 40 to under 50, and adults age 50 to under 70 years. We chose these age groupings based on the rapidly changing physiology of young children, differences in activity and behavior patterns between children and adults, and the lifestyle patterns of individuals. These factors may affect an individual’s exposure level on a field.

In this study, athletes are soccer players, from ages 2 to 70 years, who take part in soccer practices and games in a seasonal or year-round schedule. There are different activity characteristics among these soccer positions, leading to different levels of exposure. Coaches are late teen and adult (16+ years of age) soccer team leaders and trainers. They share similar exposure parameters with the athletes. Referees are late teen and adult (16+ years of age) game officials, who are present on fields during soccer games. Spectators are the family or friends of athletes, who observe soccer activities from near or off the field, including pregnant people, newborns and adults aged up to 70 years.

The main pathways of human exposure to chemicals from synthetic turf fields are:
• The inhalation pathway: inhaling chemical vapors and airborne fine particulate matter (e.g., PM2.5) while on the field.
• The dermal pathway: direct skin contact with synthetic turf components. • The ingestion pathways: direct intentional and unintentional (“incidental”) ingestion of synthetic turf components or indirect ingestion through hand-tomouth, hand-to-object-to-mouth, or object-to-mouth behaviors.

Breathing of air on the field that contains chemical vapors or airborne fine particulate matter released from the field results in inhalation exposure and athletes are expected to have the highest exposure through this pathway. Running on the field may stir up particles into the air and cause athletes, who have elevated breathing rates, to inhale increased amount of chemical vapor and particulates. Falling or sliding of athletes on the field may also re-suspend particles into the air in the breathing zone of the athletes.

Goalkeepers may have high exposures through constant diving onto the field surface, especially during practices, as they inhale particles and chemical vapor in the air just above the field surface.

Due to their higher activity levels on the field, athletes, coaches, and referees can have correspondingly higher inhalation rates and thus higher inhalation exposures than spectators. Spectators have low- to moderate-activity levels associated with sitting, standing, and cheering.

Direct dermal exposure refers to the scenario when there is direct skin contact with the 4-117
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field surface. Crumb rubber particles may adhere to the skin during contact. Chemicals can migrate from the adhered particles onto the skin, where they become available for dermal uptake. Moisture or personal care products on the skin surface, like sweat and sun block, respectively, may enhance adhesion of crumb rubber particles onto the skin and facilitate transfer of chemicals across the skin.

While coaches routinely spend time on the field, they have less skin contact with the field compared to athletes. Similarly, referees have less direct dermal contact with the field surface. However, some levels of dermal exposure occur in the coaches and referees, as crumb rubber can get into the shoes and under the socks during walking or running on the field.

Spectators may sit directly on the field surface to watch the practices or games.

Toddlers and young children may play, crawl around, or roll on the field. They may also play with the crumb rubber. As a result, the spectators’ hands, legs, and other body parts can be in frequent or continual contact with the field surface during a soccer event.

Ingestion exposure occurs when particles of any size get in the mouth and are swallowed. Ingestion of particles while engaging in activities on synthetic turf fields can happen either by direct or indirect pathways. OEHHA did not anticipate ingestion behaviors to be a significant exposure pathway for adult spectators, athletes, coaches, and referees. However, toddlers and young child spectators may crawl around on and play with the crumb rubber on the sidelines of the field during sport events. Some young children may ingest varied amounts of crumb rubber in a sport event.

Incidental ingestion of crumb rubber occurs for athletes when particles accidently enter the mouth and are swallowed. Falling onto the field or diving onto the field surface while playing soccer agitates the field and disperses particles of various sizes into the air.

Athletes may incidentally ingest these airborne particles. This may be an especially important exposure pathway for goalkeepers, who often lunge across the goal to block the ball and frequently land face-down onto the field surface.

Indirect incidental ingestion occurs when chemicals or particles move from the field into the mouth. Hands or fingers may come into direct contact with the field, or indirectly via objects that have contacted with the field, and then the hands or fingers touch the mouth. To take their gloves off, some goalkeepers grab their gloves with their teeth.

Athletes use their clothes to wipe away sweat on their face. Athletes or spectators leave their water bottles on the field and drink through the drinking spouts that have come into contact with the field. Toddlers or young children may touch the field or crumb rubber and use their unwashed hands to pick up an object, such as a pacifier or a toy, and ultimately put the objects into their mouth.

OEHHA, in collaboration with the University of California, Berkeley (UCB) and the University of Arizona (UA), conducted three Time-Activity Studies (TAS) to characterize the activities and exposure patterns of soccer players on synthetic turf fields in California.
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In the first TAS, OEHHA and UCB conducted a survey of soccer players in California.

Each participant (aged 7 through 71) responded to a questionnaire during an in-person interview or through an on-line platform. We gathered information on soccer activities of players engaged in during practices and games, and the types of direct contact they had with the field. Activities of interest included on- and off-field activities such as soccer drills, dive or fall on the field, snacking or drinking, and other activities on the sidelines that might result in exposure. In addition, UCB researchers recruited soccer players for in-person interviews through contacting soccer coaches and team managers in the Sacramento and San Francisco Bay areas. Additionally, they solicited players and parents of players to participate in the online survey through contacting coaches and team managers of soccer clubs in California. Overall, we received 40 completed inperson questionnaires and 1,029 on-line questionnaires.

In the second TAS, OEHHA and the collaborators videotaped soccer events to obtain data on events occurring on and off the fields. OEHHA and UCB videotaped 40 consenting soccer players (who also participated in the in-person interviews described above) during five practices and five games. On average, we videotaped four participants per event, one for each of the four soccer positions: forward, defender, midfielder, and goalkeeper. For each event, we continuously videotaped the participants from the time they entered the field until they left the field at the conclusion of a soccer event. In the third TAS, UA reviewed and obtained data from video footages from previous studies.

OEHHA estimated the potential levels of exposure on the fields by incorporating data from the TAS and the chemical results from the field characterization study.

Risk Characterization
This study characterized health risks to artificial turf field users, by focusing on the following health outcomes: acute inhalation toxicity, developmental and reproductive toxicity, sensory irritation, general chronic toxicity, and lifetime cancer risk.

The non-cancer hazards and cancer risks from inhalation exposure to organic chemicals in air over synthetic turf fields were assessed based on the airborne concentrations of measured chemicals. Concentrations exceeding the non-cancer toxicity criteria demonstrate some level of hazard, while concentrations below the toxicity criteria demonstrate the lack of a non-cancer health hazard.

To estimate non-cancer hazards and cancer risks from oral and dermal exposures to chemicals from crumb rubber samples, OEHHA calculated the average daily dose based on concentrations of chemicals measured in artificial sweat and gastrointestinal fluids. OEHHA then compared these doses of chemicals with their toxicity criteria for non-cancer health effects. Doses exceeding the toxicity criteria demonstrate some level of hazard, while doses below the toxicity criteria demonstrate the lack of a significant non-cancer hazard.
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For cancer risk assessment, the lifetime average daily dose for each chemical was calculated for each route of exposure (inhalation, dermal and oral), and multiplied with the cancer toxicity criteria, with adjustment for age sensitivity to account for the greater sensitivity of children to carcinogens.

OEHHA derived total non-cancer hazards and total lifetime cancer risks for each chemical for all three routes of exposure (inhalation, dermal and oral). The non-cancer hazards and cancer risks for individual chemicals were then summed to calculate hazard and risk posed by exposure to all the chemicals in the crumb rubber used on the artificial turf.

Results and Findings
Overall, this study found no significant health risks to players, coaches, referees and spectators from on-field or off-field exposure to chemicals in crumb rubber infill from synthetic turf fields based on the assessment method and available data. More specifically:
• The study did not find any chemical exposures associated with the turf fields that would pose immediate (acute) health hazards.
• The study found that use of synthetic turf fields does not pose hazardous levels of exposure to sensory irritants (chemicals that can cause irritation of the eyes or airways). Most exposure to sensory irritants while on the fields comes from chemicals in the ambient air that originate elsewhere.
• The study found that, on average, people using the fields were not exposed to levels of chemicals that can cause harm to childhood development or the male or female reproductive systems. The highest of the 35 fields was associated with moderately elevated exposures to athletes of 11-70 years old under a “worst case” scenario. The likelihood of exposures actually occurring at that level is low and therefore of low concern.
• On average, long-term use of the fields does not result in exposures to chemicals that pose significant non-cancer health hazards. The maximum of the individual field values was associated with slightly elevated exposures, of low concern, for spectators 0-2 years old. For children less than two years old, the exposure is primarily via ingestion of crumb rubber which was assumed to be 153 mg per day of event during 161 games and practices per year in this study.

The odds of such exposures actually occurring is low. As the actual amount of crumb rubber ingested by the infant spectators decreases, the associated hazards also decrease and would be of low to no concern. • Cancer risks from the crumb rubber infill used in the artificial turf fields, on average, are insignificant for athletes, coaches and referees, ie., less than one additional cancer case in a population of 1 million people playing or spending 4-120
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time on the fields during a 70-year lifetime. Average cancer risks for infant spectators 0-2 years were just above this level, at 1.1 additional cancer case in one million during lifetime. The individual fields posing the highest lifetime risks to athletes and infant spectators ranged up to 1.2 and 2.7 in a million, respectively, with the high-end values being slightly about the benchmark of 1 in a million lifetime risk. As with the non-cancer assessment, the cancer assessment for athletes and infant spectators was based on “worst-case” combination of exposure assumptions and parameters, and the odds of these exposures actually occurring is low. For infant spectators, the lower the actual exposure via ingestion of crumb rubber infill, the lower the corresponding health risk.
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Chapter 1. Introduction

1.1. Purpose of Study
The use of synthetic turf on outdoor sport fields has become popular because of their lower maintenance, lower cost and to conserve water use compared to traditional grass playing fields. In California over 900 synthetic turf fields have been installed in the state.

However, concerns have been raised about the potential adverse health effects and risks for athletes and children playing on synthetic turf fields that use crumb rubber infill made from recycled waste tires. In response to this concern, the Department of Resources Recycling and Recovery (CalRecycle), which regulates the uses of waste tires in California, contracted with the Office of Environmental Health Hazard Assessment (OEHHA) to perform a risk assessment addressing the health risks for players and other users exposed to crumb rubber infill from synthetic turf fields.

The OEHHA study provides a comprehensive and detailed evaluation of these human health risks. It does not however address ecological risk, for example associated with zinc from leachate reaching aquatic environments where it affects wildlife. Nor does it evaluate the risks of the other components of synthetic turf described below. It does however use state-of-the-art science in accomplishing its tasks of determining whether crumb rubber infill poses significant health risks.

1.2. Composition of Synthetic Turf Fields and Crumb Rubber Compared to natural grass, synthetic turf provides the benefits of low maintenance, reduced water usage, improved water drainage, improved playability (requires no field resting between events), and customizable appearance (multiple-colored blades allows built-in designs like team logos). With such advantages, the use of synthetic turf on indoor and outdoor sport fields for football, soccer, and baseball has become common.

First used in 1964 when it was installed on a recreational area at the Moses Brown School (Providence, Rhode Island) and in 1966 when it was installed in the Astrodome (Houston, Texas), synthetic turf (e.g., artificial turf, ChemGrass, or AstroTurf) describes a surface of synthetic fibers designed to resemble natural grass. The first-generation synthetic turf fields were comprised only of turf carpeting and backing without any infill material. To reduce the field hardness and injuries from slips and falls, starting in the 1990s turf systems were redesigned with longer blades and to contain infill materials.

Currently, synthetic turf systems generally consist of the following components (NYDOH, 2018; STC):
• Carpet backing and synthetic grass blades: A carpet backing, usually weaved polyester fabric, is a structure that holds the synthetic turf blades. The multiple colored synthetic grass blades are made of nylon, polypropylene, or polyethylene. These blades do not just serve the aesthetics purposes of the fields, but also provide structure to keep the infill materials in place. 4-122
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• Shock pad: Depending on the types of sports to be played on a field, a shock pad (made of layers of polyethylene) may be placed underneath the turf carpet to absorb the energy from physical impacts during sport activities and reduce or prevent injuries of athletes.
• Infill: Crumb rubber (uncoated or coated), virgin rubbers (synthetic and nonrecycled such as ethylene propylene diene monomer (EPDM), polymer elastomer and thermoplastic elastomer (TPE)), or organic materials (cork and coconut husk), used as a single material or as a mixture with sand, are marketed as infill materials. The infill is used to weigh down the synthetic turf carpet and level the field surface for stability, keep the blades up, improve water drainage of the fields, and absorb impacts and provide traction during sport activities. The infill can also prevent or reduce injuries.

This study focuses on the risks from crumb rubber, the most commonly used infill on synthetic turf sport fields. A single field can contain over 200,000 pounds of crumb rubber infill (NYDOH, 2018). Particles sized between one-sixteenth and one-quarter inch in diameter are used as infill on turf fields (NYDOH, 2018). In California, crumb rubber particles are made from waste passenger and light truck tires. The main raw materials used in the manufacturing of tires, and the function they serve in tires, are given below (ICBA, 2016; USTMA, 2020):
• Natural rubber and synthetic rubber (butadiene rubber, and styrene-butadiene rubber): The use of natural rubber and synthetic rubber polymers in combination improves tire performance.
• Antioxidants and antiozonants: These additives prevent degradation of the tires.

Antioxidants reduce or prevent the oxidation that breaks down the rubber polymers and crosslinks. Antiozonants, which bloom at the tire surface, prevent cracking of the tire by the ozone in ambient air.
• Accelerators or vulcanizing agents: The rubber undergoes high temperature and pressure curing process, which is called vulcanization. The vulcanization process permanently links the hydrocarbon chains of the rubber to strengthen and solidify the tires. Accelerators are added to reduce the vulcanization time and control the length and number of crosslinks between the hydrocarbon chains. • Steel wires and textiles (fabric cords): Steel wires reinforce the rubber to improve tire performance and anchor the tires onto the wheels. Fabric cords made of various materials reinforce the tire casing and maintain the shape of tires. During the recycling processes, steel and fabric fibers are separated from the rubber and recycled.
• Fillers: Carbon black and silica are added to the tires to strengthen and improve the longevity of the tires. Silica is covalently coupled to the rubber polymer to reduce the rolling resistance of the tires. Carbon black, acting as a reinforcing and coloring agent, is mixed with the tire rubber. The substance enhances the 4-123
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tear strength and improves the modulus of elasticity (resistance from deformation upon exertion of force) and wear characteristics of tires. • Extender oils: Extender oils are added during the tire manufacturing process to improve the processability and performance characteristics of tires (Gomes et al., 2021; STRO, 2004).

Tires are made to different specifications and differ in composition due to varying proprietary chemicals and bulk raw material used to manufacture them. Also, manufacturing processes change over time.

The crumb rubber infill is produced from recycled automotive tires made in the United States and imported from other countries. The variety of tires this covers results in the heterogeneity of the infill both within a field, and across different fields. Chemical composition of crumb rubber infill is also affected by the age of the used tires being recycled, aging of crumb rubber on synthetic turf fields, and environmental deposition of pollutants (e.g., PAHs) onto synthetic turf fields.

The next section discusses our approach to designing a study that captures the range of potential chemicals that may result in potentially harmful exposure for users of synthetic turf fields in California.

1.3. Design of the OEHHA Synthetic Turf Study
In this discussion of study design, we first describe our approach to identifying chemicals of concern in crumb rubber, and then our general approach to the design of the study.

1.3.1. Approach to Identifying Chemicals of Concern
OEHHA took a multipronged approach to identify potential chemicals that might be released from crumb rubber - into the air and inhaled, inadvertently consumed by field users, or penetrating the skin with direct skin contact. • Literature search: OEHHA searched the literature to identify tire-related chemicals, including studies of synthetic fields and crumb rubber. • Outreach: OEHHA received information of the chemicals used in the tire manufacturing processes from the U.S. Rubber Manufacturers Association and the International Carbon Black Association, as well as in its consultations with agencies and academics (see below).
• Laboratory experiments: Lawrence Berkeley National Laboratory (LBNL), in collaboration with OEHHA, analyzed samples of crumb rubber both before it was installed on the field (“pre-installed”) and from actual fields. LBNL performed chamber emission studies to simulate the release of volatile organic chemicals to the air on synthetic turf fields. LBNL also extracted the pre-installed and composited field crumb rubber samples with solvents of various polarities. They 4-124
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conducted non-targeted chemical analyses of these extracts to identify other chemicals not previously identified in the literature or from our outreach efforts.

Based on these sources, we compiled a list of tentatively identified tire-related chemicals (“Tire-Related Chemical Database”). OEHHA selected and verified chemical targets from this list using high purity reference standards. The targets were prioritized for confirmation based on potential toxicity and the commercial availability of standards.

These analyses provided lists of chemicals to be characterized in crumb rubber samples.

1.3.2. General approach to study design
The study design emerged from extensive consultations, literature reviews and work with our research partners, as described here.

Outreach. OEHHA has sought advice from entities that had or were in the process of conducting assessments of synthetic turf fields or were involved in assessing health effects in players or evaluating the toxicity of synthetic turf chemicals. This included several states (Connecticut, New Jersey, New York, and Washington); federal agencies (National Institute for Occupational Safety and Health, US Environmental Protection Agency (USEPA), the National Toxicology Program (NTP), the Agency for Toxic Substances and Disease Registry, and the Consumer Product Safety Commission (CPSC); and the European Chemicals Agency. Academics at the University of California, Davis and the Pennsylvania State University were also consulted early in the study.

OEHHA sought advice from players, parents, coaches, and others that had direct experience with exposures to crumb rubber and heard input on concerns most important to them. The general public was also engaged and at an early stage. In 2015 OEHHA held three public workshops using a world café format in communities in Northern and Southern California and convened a statewide virtual workshop to seek input on study design.

Research Partners. OEHHA designed and performed the work in collaboration with researchers at the following institutions:
• Lawrence Berkeley National Laboratory (LBNL): sample collection, emission testing, biofluid extractions, laboratory analysis of air and crumb rubber samples. • California Institute of Quantitative Sciences at the University of California Berkeley (UCB): analysis of sample extracts with LC/MS and identification of unknown chemical peaks advanced software.
• UCB Center for Environmental Research and Children’s Health (CERCH):
activity studies to assess the exposure patterns soccer players and other field users.
• University of Arizona: transcription of video data from UCB CERCH and coding 4-125
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for assessment of parameters for use in the exposure assessment.

Scientific Peer Review and Advice. The academic community was also formally engaged and advised OEHHA in the design and conduct of this complex, and necessarily groundbreaking scientific effort. OEHHA formed a Scientific Advisory Panel (“Panel”) of seven scientific experts in exposure, laboratory work and the biomedical sciences. In open public meetings, the Panel advised OEHHA on study plans, data analysis, and methodologies of exposure and risk assessment. At these meeting, the public provided comments and suggestions on the design of the study.

Literature Search. In 2015, OEHHA searched the literature for studies on the chemical composition of automotive tires and crumb rubber, and on studies of synthetic turf fields.

We identified 30 studies and reports published by researchers in the United States and 15 by international researchers Appendix Section A.1 highlights the designs and results of these studies. In addition OEHHA had earlier conducted two pilot studies of recycled waste tires (OEHHA, 2007; OEHHA, 2010).

OEHHA used the learnings and insights from all these efforts to guide our study design1. We focused on enhancing the knowledge of identification of chemicals in rubber, approaches to understanding bioaccessibility and other components of assessing exposure to crumb rubber-related chemicals. This was for the purpose of evaluating the human health risks from the multiple routes and exposure pathways to players and spectators.

Special Design Features. Based on our literature review, and the consultation and advice from the players described above, the synthetic turf study includes unique features to enhance our understanding of chemical exposures resulting from use of crumb rubber infill on turf fields:
• the collection of chemical vapors and airborne particles on active fields to simulate the environment of exposures for athletes during soccer activities, • non-targeted chemical analyses using advanced instruments and cheminformatic algorithms to better characterize the chemical composition (both known and unknown chemicals) of crumb rubber and to overcome the limitation of standard analytical methods which are tailored for common environmental chemicals, • the bioaccessibility measurements of chemicals in crumb rubber samples using dynamic extraction systems to enhance the accessibility of chemicals with low water solubility and to mimic the physiological conditions on the skin surfaces and at the gut 1 Since the completion of the literature search in 2015, several entities have conducted field investigations, risk assessments, and a cancer cluster investigation on the use of synthetic turf fields for sport activities. A chemical study on tire-derived consumer products and crumb rubber used for field installation was also published. (Benoit and Demars, 2018). The designs and findings of these studies are relevant to the OEHHA Synthetic Turf Study. We summarized these studies in Appendix Section A.2.
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linings,
• time-activity studies of soccer players in California and the development of soccer-specific exposure parameters to provide California-specific activity data and more accurate exposure data for risk assessment, instead of using default assumptions to estimate exposures, the literature showed a lack of a comprehensive study on the activity of athletes and children playing on synthetic turf fields. • the development of toxicity criteria of tire-related chemicals to enhance the assessment of human health risks from exposure to chemicals from crumb rubber on the fields, and
• the assessment of health risks of four receptor categories of synthetic turf field users – players, coaches, referees, spectators - in order to provide a comprehensive understanding of the risks of exposure for each field user category and in various age groups.
• the investigation of 35 synthetic turf fields of various ages and in different climate zones across California

1.4. Components of Study and Organization of the Report The OEHHA Synthetic Turf Study focuses on assessing the human exposures and health risks from the use of synthetic turf fields constructed with crumb rubber infill. The study consisted of several inter-related components, summarized below.

1.4.1. Collection of Crumb Rubber Infill and Air Samples from Fields Across California
Chapter 2 describes the statewide sampling effort and protocols. Briefly, OEHHA and LBNL collected crumb rubber samples from 35 synthetic turf fields across California and monitored the air during sport or simulated sport activities at these fields. The 35 fields ranged widely in age (years since field was installed) and were in areas of different climate at locations across California. Crumb rubber samples were collected at 7 to 10 locations on each field, which were generally composited into four samples per field.

Since the agitation of field materials by soccer activities might enhance the release of chemicals and particulates, LBNL collected air samples over time at multiple locations adjacent to and during soccer activities. In addition, samples were collected at a single location off each field, and at four different heights at a single location on each field (“vertical chemical data”). For certain air pollutants, the vertical chemical data provided spatial information that could be used to differentiate between chemicals being released into the air from crumb rubber infill and ambient air pollutants being released from sources such as traffic and industrial facilities. Finally, because synthetic turf fields can absorb heat and this can affect health, temperature data for the fields was also collected.
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1.4.2. Analysis of Air, Crumb Rubber and Environmental Samples Chapter 3 presents the approach for the laboratory analyses to determine the presence and concentrations of chemicals in the collected crumb and air samples.

A considerable effort by LBNL in collaboration with OEHHA went into the development of standard operating procedures (“SOPs”) for the laboratory analysis samples. SOPs were developed for:
• handling and preparing the samples for chemical analyses, • conducting the emission chamber study on the pre-installed samples obtained from tire recyclers,
• conducting targeted and non-targeted chemical analyses to determine chemical presence and concentration,
• measuring bioaccessibility, and
• establishing quality assurance and quality control of approaches for handling samples and data.

The SOPs developed are provided in Appendix D.

As noted above (Section 1.3.1) pilot studies were performed using targeted and nontargeted methods to determine chemicals for analysis. This involved chamber emission studies and extracting chemicals from crumb rubber in biological fluid simulants and analyzing the extracts. Chapter 3 covers these studies. It also covers the subsequent analyses of samples and analytical results from the statewide sample collection effort.

Using the composite samples of crumb rubber collected on the 35 fields, LBNL conducted bioaccessibility measurements using dynamic extraction systems that mimicked the physiological conditions on skin and in the gastrointestinal tract. The fluids were artificial sweat, artificial gastric fluid, and a set of artificial gastrointestinal biofluids.

The artificial gastric bioaccessibility data is used to estimate the amount of chemical released into the body when crumb rubber in inadvertently eaten. The data for the artificial sweat is used to estimate the amount of exposure from skin contact with the field crumb during play and practice.

Chapter 3 also discusses the approaches used to characterize chemicals detected as field-related (synthetic turf field is the assumed source) or non-field related (assumed to come from other environmental sources) for the purposes of assessing non-cancer hazards and cancer risks in the study.

Results from the analysis of temperature, ozone and particle data are also briefly discussed in Chapter 3.

1.4.3. Compilation and Development of Toxicity Criteria for Tire-Related Chemicals
Chapter 4 describes approaches to evaluate toxicity data and derive toxicity criteria 4-128
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(TC), numerical values which quantitatively characterizes the potential for a chemical to cause toxicity in humans. Criteria are presented for different exposures routes and durations. It provides values for 1-hour, 1-day and chronic exposures and cover general types of toxicity (e.g., effects on liver), developmental and reproductive effects, sensory irritation, and cancer. Values are compiled from established sources such as OEHHA and EPA. It also presents new screening values developed by OEHHA for this study.

1.4.4. Determination of Activity Patterns and Parameters for Estimating Exposure Chapter 5 details the methods, studies and approaches used to characterize exposure.

The mild climate in most parts of the California allows year-round outdoor sport activities like soccer. Since there are no time-activity data for soccer in the literature, OEHHA contracted with the University of California, Berkeley and the University of Arizona to collect time-activity data of soccer players in California. Two studies were performed:
• a field observational study that videotaped activities of soccer players on and off synthetic turf fields. The UA researchers translated the video footage into microlevel activity time series (MLATS) data— type and frequency of activities and behaviors occurring on and off the soccer fields.
• a survey study (in-person or on-line) to collect self-reported personal information, soccer activity data, soccer playing history, and personal hygiene of athletes in California.

OEHHA developed parameters and equations to calculate for four different types of users of soccer fields: athletes, coaches, referees, and spectators (see Appendix B).

For each of these groups, OEHHA estimated exposure parameters such as the frequency of play, the amount of time spent on the field during a practice session, breathing rates, and body weights. We applied these exposure parameters and established exposure models to evaluate exposures via inhalation, dermal, and ingestion pathways. For players and spectators different age groups were also characterized.

1.4.5. Risk Characterization
Chapter 6 presents a health risk assessment associated with exposure to chemicals in crumb rubber from using synthetic turf fields. The presented hazard and risk estimates represent information for users who confine their play to a local field.

1.4.6. Discussion
Chapter 7 discusses the unique features and limitations of the study. This section also characterizes specific areas within the chemical, toxicity, and exposure characterization aspects of the study that introduce variability and uncertainty into our health assessment and how they may affect our final hazard and risk estimates. 4-129
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1.4.7. Appendices
The report also includes several appendices that the reader can use to reference details on different aspects of the study, as follows:
• Appendix A contains the results of OEHHA’s 2015 literature search to identify chemicals that may be released from crumb rubber. It also presents summaries of synthetic turf and crumb rubber assessments published after 2015. • Appendix B contains the OEHHA Synthetic Turf Technical Support Document (TSD). The TSD defines and describes the development of exposure parameters and outlines the methodologies used to estimate and assess the exposure, noncancer hazard, and cancer risk of chemicals detected on synthetic turfs field in California.
• Appendix C contains the field recruitment protocols, including the telephone script to contact field owners and managers, and the questionnaire and consent form for participating field owners to complete.
• Appendix D contains the standard operating procedures (SOPs) for sample collection and analysis (including instrument descriptions), and the resulting chemical concentrations from that analysis. An analysis of heterogeneity within sample, within field, and between fields is discussed and the justification for the use of composite samples in this study. The analysis for the source designation of VOCs is also presented in this appendix.
• Appendix E provides detailed information about the derivation of the toxicity criterion (TC) for chemicals detected on synthetic turf fields. • Appendix F contains the results of the collaborative exposure studies between OEHHA, University of California Berkeley, and University of Arizona. It also contains the calculated exposure doses for all the chemicals that were detected on synthetic turf fields.
• Appendix G provides example non-cancer hazard and cancer risk calculations for selected chemicals. It also contains the hazard quotient, hazard indexes and risk of all detected chemicals on synthetic turf fields for the inhalation, dermal, and ingestions routes of exposure.

Throughout the report chapters, OEHHA has included in-text references to the appendices, where appropriate, to provide more detailed information on methods, analyses, and data.

1.5. References
Benoit G and Demars S (2018). Evaluation of Organic and Inorganic Compounds Extractable by Multiple Methods from Commercially Available Crumb Rubber Mulch.

Water Air Soil Pollut 229(3): 64.

Gomes FO, Rocha MR, Alves A, et al. (2021). A review of potentially harmful chemicals 4-130
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in crumb rubber used in synthetic football pitches. J Hazard Mater 409: 124998.

ICBA (2016). Carbon Black User's Guide. Safety, Health, and Environmental Information.

NYDOH (2018). "Information About Crumb-Rubber Infilled Synthetic Turf Athletic Fields." 2022, from
https://www.health.ny.gov/environmental/outdoors/synthetic_turf/crumbrubber_infilled/fact_sheet.htm.

OEHHA (2007). Evaluation of Health Effects of Recycled Waste Tires in Playground and Track Products, Office of Environmental Health Hazard Assessment,.

OEHHA (2010). Safety Study of Artificial Turf Containing Crumb Rubber Infill Made From Recycled Tires: Measurements of Chemicals and Particulates in the Air, Bacteria in the Turf, and Skin Abrasions Caused by Contact with the Surface, Office of Environmental Health Hazard Assessment.

STC. "About Synthetic Turf." 2022, from
https://www.syntheticturfcouncil.org/page/synthetic_turf.

STRO (2004). Replacement of Highly Aromatic Oils in Tyre, Frequently Asked Questions.

USTMA (2020). "What's in a Tire." 2022, from https://www.ustires.org/whats-tire-0. 4-131
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Chapter 2. Collecting Samples from Synthetic Turf Fields Across California

2.1. Introduction
One of the Synthetic Turf Study (the study) tasks is to characterize the release of chemicals from crumb rubber infill from fields in California. OEHHA accomplished this task by visiting synthetic turf fields, collecting samples, recording environmental conditions and examining in the laboratory, chemicals in the samples collected. OEHHA contracted with Lawrence Berkeley National Laboratory (LBNL or the Laboratory) to provide technical assistance in this effort. The Field Team consisted of scientists from OEHHA and LBNL.

There were two major parts to the synthetic turf field characterization study: field work and laboratory work. The laboratory work is covered in Chapter 3. This chapter describes the field work that was done. It included soliciting field owners’ or managers’ participation for the study, collecting field samples, and recording environmental conditions on and near the fields.

The field work proceeded in three phases.

Phase 1: Samples of freshly manufactured crumb rubber were collected from tire recycling facilities; samples were also collected from six fields of different ages.

These samples were used to develop standard operation protocols (SOPs) for sample preparation and to optimize methods for analyzing chemicals in the laboratory. These crumb samples were also used in experiments with nontargeted analysis to identify chemicals to analyze in the statewide study. Phase 1 sample collection is discussed in Section 2.2.1.

Phase 2: Field work during Phase 2 tested the sampling SOPs on two pilot fields and provided preliminary information to improve or modify the Field Sampling Plan to be used in the statewide sampling. Phase 2 data collection is discussed in Section 2.2.2.

Phase 3: The statewide field sampling in Phase 3 generated field samples for laboratory analyses that were used to characterize chemical exposures on and off the synthetic turf fields across California. Phase 3 data collection is discussed in Section 2.3.

2.2. Sampling for Protocol Development

2.2.1. Sampling Freshly Manufactured and Field Aged Crumb Rubber (Phase 1) OEHHA collected crumb rubber samples from waste tire recycling facilities (pre-installed samples) and from selected fields of various ages. The goal was to develop SOPs for preparation and chemical analysis of the field samples collected in the main study. 4-132
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Fields were selected to provide crumb rubber samples of different ages and weathered under different environmental conditions for non-targeted chemical analyses.

Between February and July 2016, OEHHA collected pre-installed crumb rubber samples from four waste tire recycling facilities located in Northern and Southern California.

Between September and November 2016, OEHHA also sampled crumb rubber from six synthetic turf fields, half of the fields were in Northern California (aged 3, 7, and 14 years) and half were in Southern California (aged 4, 5, and 10 years).

The pre-installed crumb rubber samples and six field samples were used to develop Field Sampling Protocols for testing in Phase 2 and protocols for analyses of field samples collected in Phase 3. Chapter 3 describes in detail the uses of these samples in the chemical analytical work.

2.2.2. Testing of Field Sampling Protocols on Pilot Fields (Phase 2) LBNL developed draft Field Sampling Protocols to collect air and crumb rubber samples on synthetic turf fields. The protocol was based on chemical data obtained from samples collected in the Phase 1 and literature search results from previous studies (details in Chapter 1 and Appendix A). In February and April 2017, the Field Team of LBNL and OEHHA staff tested the draft protocols on two pilot fields in Northern California and collected samples for chemical analyses. Based on preliminary data from laboratory analyses of the pilot field samples, the Field Team finalized the Field Sampling Protocols (Appendix section D.1). This covered set up of sampling equipment, collecting locations of samples, types of samples collected, and number of samples collected.

The Field Team collected air samples of volatile organic chemicals (VOCs) vapor, carbonyls of low molecular weight (aldehydes and ketones, ALDs), and volatile sulfur chemicals (VSCs) on the two pilot fields. At nearby locations, but off the two pilot fields (off-field), samples for VOCs were collected.

The Field Team collected hourly VOC and VSC samples using multibed glass thermal desorption (TD) tubes (Supelco, P/N 28286-U, see Appendix section D.2.1 for more specifics). We used computer-controlled air pumps and SKC air pumps to control the rate of airflow through the VOC sampling tubes and the VSC sampling tubes, respectively. We sampled the VOC vapor at two locations adjacent to the monitoring unit (goal box) on-field and at a nearby location off-field for each field (Positions A and C in Figure 2-1). We mounted the VSC samplers on a tripod located behind the net (Position B in Figure 2-1 and set up on Figure 2-2).

For ALD samples, we used special cartridges (2,4-dinitrophenylhydrazine coated silica gel) to capture the low molecular weight and reactive carbonyls, such as formaldehyde and acetaldehyde, in the air. We collected a three-hour ALD sample at each of the two VOC sampling locations on each field by using SKC air pumps to control the rate of airflow.
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Figure 2-1. Volatile
Compound Sampling
Packages A: Cart 1,
on field at the right
side of the monitoring
unit (white goal box).

B: Cart 2, on field at
the back of the
monitoring unit. C:

Cart 3, on field at the
left side of the
monitoring unit. Each
package was
positioned 1 meter
above the field
surface.

Figure 2-2. A Photograph of the Stratification
Sampling Tower Located Behind the Monitoring
Unit. VOC or VSC samplers mounted on the
tower at designated heights (0.1, 0.5, 1.07, and

1.63 meters above field surface) were connected
to SKC air pumps to control the rate of airflow.

LBNL analyzed the VSC samples from the pilot fields using a gas chromatography (GC) coupled with a TD injector and a sulfur chemiluminescence detector. They detected only one VSC, benzothiazole. This chemical was also detected in the VOC samples with an instrument that had higher sensitivity - a TD coupled gas chromatography mass spectrometry (TD-GC-MS). Analyses of the ALD samples, using a high-performance 4-134
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liquid chromatography (HPLC), revealed the presence of only formaldehyde and acetaldehyde.

Given the preliminary analytical results of the VSC and ALD samples collected on the pilot fields, the Field Team determined that collection of VSCs in the air from on- and off-field locations, and ALD in the air from off-field locations were unnecessary in the Phase 3 Field Work. We modified the Field Sampling Protocols accordingly.

2.3. Sampling of Fields Across California (Phase 3)
The Field Team applied the Field Sampling Protocols (Appendix section D.1) to collect samples and monitor environmental conditions on selected synthetic turf fields across California. The primary goal in field selection was to collect a representative sample of fields in California. OEHHA selected these fields by adopting a stratified random sampling method that was reviewed and approved by the OEHHA’s Synthetic Turf Scientific Advisory Panel (SAP). The following subsections describe the field selection method in detail.

2.3.1. Selecting Fields: Stratified Random Sampling Technique OEHHA used installation information furnished by field installers to the California Department of Resources Recycling and Recovery (CalRecycle) to compile a database of synthetic turf fields in California (OEHHA Field Database or Field Database). The Field Database contains 907 fields, of which 688 have installation date or year recorded. We estimated the age of fields based on the time differences between the reported installation dates and January 1, 2017. The full range of field age in the Field Database was 1 to less than 19 years old; over 90 percent were between greater than 3 and less than 14 years old. More than 80 percent of the fields in California are located in three metropolitan areas—the San Francisco Bay Area, the Greater Los Angeles Area, and San Diego County.

A simple random sampling technique with a limited sampling size to select from the 907 fields would probably lead to a collection of fields mainly located within these metropolitan areas. OEHHA therefore used a stratified random sampling method to select the study fields. This sampling technique is particularly effective in collecting random and representative samples from a skewed dataset, even with a limited sampling size. We performed the method as follows: First, we identified and selected the most critical factors (stratification factors) that might affect the release of chemicals or determine the environmental conditions of fields. Second, we divided the fields in the Field Database into strata or subgroups according to the stratification factors. Finally, we randomly selected a pre-determined number of fields from each subgroup. By adopting this sampling technique, the Field Team collected samples from the randomly selected fields in each subgroup, which also were representative of synthetic turf field conditions across California.
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OEHHA initially considered three stratification factors--local climate, age of a field, and ozone level in the ambient air--that might affect degradation of crumb rubber in synthetic turf fields. These factors in turn might influence the chemical and environmental exposures on the fields. After discussing these factors at the SAP Meeting on March 10, 2017, OEHHA followed the recommendations from the SAP and chose the local climate at a field’s location and the age of a field as the stratification factors in the field selection process.

2.3.1.1. Stratification Factor: Local Climate
The local climate (e.g., rainfall, humidity, temperature range, and solar insolation) at a field likely affects the weathering or aging of crumb rubber. California has the most diverse climate among all the states in the United States (CEC, 1995). The California Energy Commission (CEC) divides California into 16 distinct climate zones based on the mean temperatures in the summers and winters (CEC, 1995; CEC, 2015). Figure 2-3 outlines the boundary of the 16 climate zones and Table 2-1 lists the California counties covered by each of these climate zones. Some counties fall within multiple climate zones.

Figure 2-3. Map Showing the 16
Climate Zones Designated by
the California Energy
Commission (CEC, 2015)
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Table 2-1. List of Counties Covered in the 16 Climate Zones (CEC, 2015) OEHHA consolidated the 16 climate zones into 5 climate regions based on the mean temperatures in the warm seasons (defined as the months from May to October, using the data for 2011-2015 from Weather Underground, https://www.wunderground.com) and other climate considerations described below:

Region 1: Southern Coastal Areas (Climate Zones 6 to 9). This region consists of the Southern California coast. The warm ocean water keeps the climate mild throughout the year. Rain occurs mostly in the winters. During the warm seasons, the mean of the average temperatures ranged from 69 to 72°F and the mean of the maximum temperatures ranged from 84 to 89°F.

Climate
Zone Counties Covered by Climate Zone
1 Del Norte, Humboldt, Mendocino
2 Humboldt, Lake, Marin, Mendocino, Napa, Sonoma, Trinity 3 Contra Costa, Marin, Monterey, Mendocino, Santa Cruz, San Francisco, San Mateo, Solano, Sonoma
4 Monterey, San Benito, San Luis Obispo, Santa Barbara, Santa Clara 5 San Luis Obispo, Santa Barbara
6 Los Angeles, Orange, Santa Barbara, Ventura
7 San Diego
8 Los Angeles, Orange
9 Los Angeles, Ventura
10 Riverside, San Bernardino, San Diego
11 Butte, Colusa, Glenn, Nevada, Placer, Shasta, Sutter, Tehama, Trinity, Yuba
12 Alameda, Amador, Calaveras, Contra Costa, El Dorado, Mariposa, Merced, Sacramento, San Joaquin, Solano, Stanislaus, Tuolumne, Yolo 13 Fresno, Kern, Kings, Madera, Tulare
14 Imperial, Kern, Los Angeles, Riverside, San Diego, San Bernardino 15 Imperial, Inyo, Riverside, San Diego, San Bernardino 16 Alpine, Amador, Butte, Calaveras, Del Norte, El Dorado, Fresno, Glenn, Inyo, Kern, Lassen, Los Angeles, Madera, Mariposa, Mendocino, Modoc, Mono, Nevada, Placer, Riverside, San Bernardino, Shasta, Sierra, Plumas, Siskiyou, Tehama, Trinity, Tulare, Tuolumne, Ventura, Yuba 4-137
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Region 2: Northern and Central Coastal Areas (Climate Zones 1 to 5). This region is situated along the Northern and Central California coast, where the weather is greatly influenced by the Pacific Ocean. Generally, the summers are cool and winters are mild and wet. Strong wind and fog are common. During the warm seasons, the mean of the average temperatures ranged from 57 to 67°F and the mean of the maximum temperatures ranged from 64 to 80°F.

Region 3: Southern California Interior Valleys (Climate Zone 10) and Northern California Central Valley (Climate Zones 11 to 13). These valleys are surrounded by mountain ranges. In these valleys, the summers are dry and hot, while the winters are wet and relatively cold. During the warm seasons, the mean of the average temperatures ranged from 72 to 78°F and the mean of the maximum temperatures ranged from 88 to 93°F.

Region 4: Southern California High and Low Deserts (Climate Zones 14 and 15). This region is the desert area located at the southeastern border of California. Extremely hot and dry summers but moderately cold winters are the characteristics of this region. During the warm seasons, the mean of the average temperatures ranged from 82 to 86°F and the mean of the maximum temperatures ranged from 97 to 102°F.

Region 5: Mountainous Area (Climate Zone 16). This region contains California’s high-altitude and mountainous areas. Climate in the region is mild in the summers but cold and snowy in the winters. The mean of the average temperatures was 69°F and the mean of the maximum temperatures was 85°F in the warm seasons.

Figure 2-4 displays the five climate regions on a California map and approximate locations of synthetic turf fields. Table 2-2 summarizes the number of synthetic turf fields in each climate region. As shown in this figure and table, there are more fields in or near metropolitan areas (e.g., the San Francisco Bay Area, the Greater Los Angeles Area, and the City of San Diego).
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Figure 2-4. California Map Illustrating the Five
Climate Regions and the Approximate Location
of Synthetic Turf Fields (the black dots on the
map represent the 907 synthetic turf fields)
Table 2-2. The Climate Regions in California and Number of Fields in Each Region

2.3.1.2. Stratification Factor: Age of a Field
Aging is another important factor effecting the degradation of crumb rubber on synthetic turf fields. Figure 2-5 shows the cumulative frequency of age for 688 fields, of which OEHHA determined the field ages based on their installation dates available in the Field Database. Figure 2-6 shows the cumulative frequency of field age in each climate region. Overall, the median field age was 8.4 years and 54 percent of the fields (371 fields) were less than 9 years old. Communications with several field owners or managers suggested that warranties of synthetic turf fields usually expired after eight years of field installation. Some of the field owners or managers stated that they reduced field maintenance efforts after the warranties expired.

For field selection purposes, OEHHA chose nine years as the age cut-off to Climate Region Climate Zones Covered Number of Fields
1 Zones 6 – 9: southern coastal areas 376
2 Zones 1 – 5: northern and central coastal
areas
272
3 Zones 10 – 13: southern interior valleys and
northern Central Valley 233
4 Zones 14 – 15: southern high and low deserts 16
5 Zone 16: mountainous area 10
All Zones 1 – 16 907
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subcategorize fields into two age groups for each region: fewer than nine years old (new fields) and nine years old or older (old fields).

Figure 2-5. Cumulative
Frequency of the Age for 688
California Synthetic Turf Fields
(as of January 1, 2017) in the
OEHHA Field Database

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Figure 2-6 (A to E). Cumulative
Frequency of Field Age (as of January 1,
2017) in Each Climate Region of
California, According to the OEHHA Field
Database

E. Climate Region 5

D. Climate Region 4

0 25
50 75
100
0 10
20 30
40 50
60 70
Cumulative Age Frequency, %
No. of Fields
Field Age, Year
C. Climate Region 3
No. of Fields Cumulative Frequency of Age

No. of Fields

A. Climate Region 1

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Table 2-3 summarizes the number of fields in each climate region and field age subcategory. The Climate Regions 1 to 3, which contain the major metropolitan areas in California, have higher numbers of fields compared to the Climate Regions 4 and 5. The Climate Regions 4 and 5, respectively, cover the desert and mountainous areas in California. There are small numbers of fields in these two climate regions, especially when these two climate regions are further divided into the two field age subgroups.

OEHHA, therefore, consolidated the Climate Regions 4 and 5 into a Combined Climate Region 4/5 for the field selection purposes.

Table 2-3. Stratification of Fields into Climate Regions and Field Age Subgroups Climate
Region
Number of New Fields
(0 to <9 years old)
Number of Old Fields
(≥9 years old) Total
1 145 106 251
2 118 111 229
3 100 88 188
4/5 8 12 20
Total 371 317 688

2.3.1.3. Field Selection Process Steps
Applying the stratified random sampling method, OEHHA categorized the 688 fields into 8 subgroups: four climate regions and two field age groups per climate region.

Initially, OEHHA planned to randomly select five fields from each subcategory of the Climate Regions 1 to 3 (a total of 30 fields) and two to three fields per field age group in the combined 4/5 Climate Region (a total of five fields). The total number would be 35 fields. However, the plan regarding the number of fields per climate region had to be modified as discussed in Section 2.3.2.1.

OEHHA selected 35 synthetic turf fields in the Phase 3 Field Work. In the field selection process, OEHHA performed the following steps:

1. Randomly ordered fields in each subcategory

2. Searched the internet to gather field owners’ or managers’ contact information

3. Contacted field owners or managers following the randomly assigned order and used a developed phone script (Appendix section C.1) to solicit their participation in the study

4. Interviewed each participating field owner or manager to complete a field questionnaire (Appendix section C.2) and a consent to participating form (Appendix section C.3)

5. Visited each participating field to confirm that it met the study criteria (e.g., 4-142
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age, region, and field materials)

6. Updated field information in the Field Database, if needed

7. Followed the Field Sampling Protocols (Appendix section D.1) to sample the fields and document the procedures and findings

2.3.2. Conduct of the Statewide Sampling
In early 2016, the Field Team began to contact field owners and managers to secure their consent to participate in the study. By the end of 2017, we completed the field work. The following subsections summarize the field work that was done.

2.3.2.1. Fields Sampled Statewide
From June to December 2017, the Field Team sampled 35 selected synthetic turf fields across California. Thirty-three were crumb rubber infilled fields and 2 were new synthetic turf fields containing a mixture of crumb rubber and cork infill.

Although OEHHA planned to sample 10 fields in each of the Climate Regions 1 to 3 and 5 fields in the Combined Climate Region 4/5, several issues necessitated modifications to this sampling plan:
• Inadequate responses in the Climate Regions 4/5: After contacting all 26 field owners or managers in this region, OEHHA was able to sample only two fields. • Field age discrepancies: Two fields in the Climate Region 1 originally were identified as old (according to the OEHHA Field Database). Upon interviewing the owners or managers, we discovered discrepancies between the installation dates provided by the owners or managers and the dates recorded in our database. OEHHA recategorized these fields as new fields (details in Section

2.3.2.2).
• New infill materials used: In Climate Region 1, OEHHA found that two synthetic turf fields originally labelled as crumb rubber only were recently replaced with cork and crumb rubber mixed infill. According to the field owners or managers, field manufacturers developed the new infill mixture to reduce the heat exposures on the synthetic turf fields. OEHHA decided to sample these fields.

To address the low number of fields participating in the Combined Climate Region 4/5, OEHHA added an extra old field in the hot and dry Climate Region 3 and an extra new field in the Climate Region 1 at a location bordering the Combined Climate Region 4/5.

In addition, we oversampled new fields in the Climate Region 1 because of field age discrepancies and use of new infill materials in field replacements described above. To keep the total number of fields at 35, we reduced the number of new fields in the Climate Region 2 to four fields.

Overall, the 35 fields investigated in the study covered approximately four percent of the 4-143
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California fields on the OEHHA Field Database (35 out of 907 fields). The final sampling percentages of fields in Climate Regions 1 to 3 ranged from three to five percent.

Despite the low number of fields sampled in the Combined Climate Region 4/5, they represented eight percent of the fields in this region. Table 2-4 shows the number of fields sampled in each region by general age category.

Table 2-4. Number of Fields Sampled by Climate Region and Age, in Statewide Field Work (Phase 3)
a Age of fields as of January 1, 2017, according to the updated OEHHA Field Database and supplemented with information provided by participating field owners or managers

2.3.2.2. Age of Fields Sampled
OEHHA interviewed the participating field owners or managers to collect detailed field information. We noticed discrepancies between the owner- or manager-reported field installation dates and the corresponding data in the OEHHA Field Database for some fields, especially those in the Climate Region 1. For example, the ages of some fields in the database were older if the fields had been replaced more recently. For other fields, some field owners or managers indicated that their fields were older than the ages determined by OEHHA (according to data in the OEHHA Field Database). We suspected that this might be due to the lengthy field installation planning processes, long delays in field installation, or memory bias of field owners or managers. We did not have additional information to reconcile these discrepancies. For these fields, OEHHA decided to agree with the field age data provided by the owners or managers. Upon reconfirming the age of these fields with the owners or managers, OEHHA updated the Field Database and re-categorized the corresponding fields as needed.

Figure 2-7 shows cumulative frequency data for the age of fields sampled in the Phase 3 Field Work and the field ages according to the updated OEHHA Field Database.

Category of Fields
Sampleda Region 1 Region 2 Region 3 Combined Region 4/5 Total Cork/Crumb Rubber
Mixed Fields
(≤1 year-old)
2 0 0 0 2
New Crumb Rubber
Fields
(0 to <9 year-old)
8 4 5 1 18
Old Crumb Rubber
Fields (≥9 year-old) 3 5 6 1 15
Number of Fields
Sampled (percentage
of total fields in
region)
13 (3.5%)
9 (3.3%)
11 (4.7%)
2 (7.7%)
35 (3.9%)
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Overall, there is a slight left shift of the age data for the sampled fields (i.e., younger in field age) compared to the curve for all fields in the database. Despite the shift, these data and the curve share a similar shape. OEHHA was unable to verify the field age data of the entire database and therefore could not affirm that the pool of fields sampled in this study was actually younger than the overall field population in California.

Figure 2-7. Cumulative Frequencies of Field Age of the 35 Fields Sampled in the Phase 3 Compared to the 688 Fields in the Updated OEHHA Field Database (updated with information furnished by the participating field owners or managers) Among the fields sampled in the Phase 3 Field Work, only a cork and crumb rubber mixed field was less than one year old (Figure 2-7). The age distribution of fields sampled in the New Field Group spread evenly between one to eight years old, whereas most of the fields sampled in the Old Field Group were between 9 and 11 years old. The median age of all the fields sampled was 7 years old, with 57 percent of the fields (20 out of 35) being less than 9 years old. The oldest field sampled was 14 years old.

Communications with some of the field owners or managers revealed that facilities often initiated field replacement plans when fields were approximately 10 years old, and the planning process might take a few years to complete. Field replacements then occurred 0 25
50 75
100
0 3 6 9 12 15 18
Cumulative Frequency of Field Age, %
Field Age, Year
Fields in CA Sampled Fields
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when the fields became close to 14 years old. As a result, less than eight percent of the fields in the OEHHA Field Database were 14 years or older (53 out of the 688 fields).

2.3.2.3. Air Samples Collected and Sampling Methods and Conditions VOCs and Carbonyls. The Field Team collected vapor samples from the air under static (without soccer activity) and active conditions (with soccer activities). To simulate the active field conditions, we recruited volunteer soccer players from local communities to agitate the surface within the monitoring unit (around a goal box set up in the middle of a field, see Figure 2-1) on the field. They conducted vigorous soccer drills (e.g., catching, dribbling, kicking, and diving) by responding to balls released by an automatic ball-kicking machine, which set the pace of the activities.

To measure the VOCs and ALDs in the air on the 35 selected fields, the Field Team followed the Field Sampling Protocols (Appendix section D.1) to set up the instrument packages at several locations of each field, as follows (see also Table 2-5):
• VOC sampling packages on three carts and one tripod. Two carts were located on the field locations next to the monitoring unit and one was located off-field.

The samplers were positioned one meter above the field surface to represent the breathing zone of a child. The tripod was a stratification sampling tower located on-field behind the monitoring unit. Samplers were positioned on the tripod at heights of 0.1, 0.5, 1.07, and 1.63 meters above field surface. • ALD samplers on carts. Two carts were located on-field next to the monitoring unit. The sampler was positioned at a height of one meter above the field surface.

Integrated VOC and ALD samples were collected. In integrated sampling, the air is continuously sampled over the sampling period; the hourly integrated samples absorb chemicals from the air as it is pumped through the samplers. Air concentration can then be determined by:
• The amount of a chemical (e.g., nanograms) collected over a sampling period, determined in the laboratory analysis described in Chapter 3. • Flow rates of air passing through a sampling device (cubic meter per hour) monitored during the sampling period.
• Period of time over which the sample was collected.
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Table 2-5. VOCs and Carbonyls Sampling Instrument Packages for Phase 3 Statewide Field Work
Targeted
Chemicals Instrument, Method, or Device Location(refer to Figure 2-1) VOCs
Hourly integrated samples
collected on thermal desorption
sorbent tubes
on field: right and left of the monitoring
unit – Carts 1 and 3
off field; Cart 4 (not shown on Figure
2-1)
Stratified
VOCs
One-hour integrated samples
collected at four levels above
field surface using thermal
desorption sorbent tubes
on field: back of the monitoring unit -
Cart 2
Carbonyls
Three hour integrated samples
collected using 2,4-
dinitrophenylhydrazinecartiridges
on field: right and left of the monitoring
unit - Carts 1 and 3
The Field Team used a computer-controlled air pump to collect one VOC sample per hour for five consecutive hours. Each sample was separately analyzed. The first and fifth hours under static field condition on the fields and the second to fourth hours under active field conditions on the fields. Simultaneously, we collected five consecutive hourly VOC samples at an off-field location, where no simulated soccer activity occurred.

On the sampling tower on the tripod, we collected four VOC samples at various vertical levels (0.1 meter, 0.5 meter, 1.07 meter, and 1.63 meter above the field surface, stratified VOC samples) using SKC pumps to regulate the rate of airflow. These samples enabled us to examine the vertical concentration profile of VOCs in the air and in some cases distinguish field related chemicals from non-field related chemicals (See Chapter 3, section 3.5).

Additionally, the Field Team collected a three-hour ALD sample under active field conditions at each of the two on-field locations for each field (see Table 2-5 and Figure 2-1) for the sampling locations on the fields).

At the end of each field sampling day, we shipped the VOC and ALD samples overnight to LBNL for analyses upon arrival.

Semi-Volatile Organic Chemicals in Air. The Field Team followed the Field Sampling Protocols (Appendix section D.1) to collect semi-volatile organic chemicals (SVOCs) in the air (vapor and particulate matters with diameters 2.5 µm and below, PM2.5) at the 35 selected synthetic turf fields. The SVOC sample train, in the order of airflow, consisted of a 47mm glass fiber (GF) filter connected to a PM2.5 cyclone (opening at a height of 1 meter above the field surface), a polyurethane foam (PUF) sampler, and an XAD®-2 4-147
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cartridge1. Briefly, we placed three SVOC sample trains at the same locations as the VOC samplers (details in Table 2-5 and Figure 2-1)—two on-field and one off-field locations at each field. At each of the on-field locations, we collected a three-hour highvolume SVOC sample from the air under active field conditions. Simultaneously, we collected a three-hour high-volume SVOC sample at the off-field location.

At the end of each field sampling day, we shipped the SVOC samples overnight to LBNL for archiving and storing in refrigerators until they were analyzed. OEHHA applied the analytical results to calculate the SVOC concentrations in the air on and off the fields.

2.3.2.4. Crumb Rubber Samples Collected and Sampling Methods and Conditions For metals and metalloids analysis, OEHHA followed the Field Sampling Protocols (Appendix section D.1) to collect crumb rubber samples at 6 to 10 pre-selected locations on each synthetic turf field using single-use plastic sampling scoops and stored in high-density polyethylene bottles. The number and location of samples collected on field depended on the field orientation and uses (see field sample location map in the Appendix section D.1.7.4). Samples were shipped to LBNL overnight for storage at room temperature.

For organic chemicals analyses, OEHHA collected the crumb rubber samples using clean metal scoops and stored in airtight amber glass jars. The samples were shipped to LBNL overnight for storing in refrigerators.

2.3.2.5. Other Data Collected
The Field Team monitored the following environmental conditions at the on-field and offfield locations of each field: ambient and field surface temperatures, relative humidity, solar insolation, wind speed and direction, and airborne particle size distribution and counts in the air.

2.4. Summary: Types and Number of Samples Collected in the Statewide Field Work
Unexpected incidents occurring during the Phase 3 Field Work included instrument failure, insufficient power supply at the field, power failure during sample collection, and loss of samples during shipment. This resulted in one or two fields having fewer samples than planned. For example, we had VOC samples off-field for 34 instead of 35 fields. Table 2-6 and Table 2-7 summarizes the numbers and types of field samples collected in the Phase 3 Field Work.
1 XAD is a sorbent material registered by the Dow Chemical Company or an affiliated company of Dow 4-148
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Table 2-6. Samples Resulting from the Statewide Field Work Type of
Sample
Number of Fields
Captured
Number of Samples for
Analysis Blank Samplesa
On Field Off Field On
Field
Off
Field Total
VOC
vapor
35 34 481 170 651 68
Carbonyl
vapor
34 0 68 0 68 14
SVOC
trainb 34 33 64 33 97 11
a Refer to Appendix section D.1.6 for the types of blank samples and the use of analytical data from blank samples
b For collection of SVOC vapor and particulate matter with diameter 2.5 µm and below (PM2.5) Table 2-7. Number of Infill Samples Collected During the Statewide Sampling Infill Type Fields
Sampled
Number of Samples Collected
Organic Inorganic Total
Crumb 33 308 308 618
Cork and
crumb mix 2 20 20 40

2.5. References
CEC (1995). California Climate Zone Descriptions for New Buildings, California Energy Commission.

CEC (2015). California Buildling Climate Zones, California Energy Commission. 4-149
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Chapter 3. Laboratory Analyses and Resulting Chemical
Concentrations

3.1. Introduction
This chapter describes the laboratory work conducted over the course of the Synthetic Turf Study (the study) and provides an overview of the results of that work. The chapter is divided into sections covering the analyses and results of:
• Organic chemicals in artificial gastrointestinal (GI) fluids and artificial sweat extracts of crumb rubber
• Metals and metalloids in acid extracts of crumb rubber simulating gastric conditions
• Organic chemical in air samples and airborne particulate matter samples Each of the sections begins by summarizing the experiments and analyses conducted to identify and select chemicals for study. This generally involved conducting studies to release chemicals from crumb rubber samples obtained from recycling facilities (e.g., through extractions or chamber emission studies), and performing non-targeted analyses3 on the chemicals released. The section describes how this work was enriched by the literature research, findings from prior studies (see Appendix A), and discussions with government and academic experts. Each section presents the resulting list of “targeted chemicals” for analysis of samples collected from the 35 fields.

Each section then gives an overview of the approach to the extraction of samples and analysis conducted to measure “targeted chemicals”, and refers to where the details on these methods can be found in Appendix D. The sections conclude with an overview of the results for each of the “targeted chemicals”. This includes indicating the number of fields the chemicals were detected in, and the average and upper bound concentrations detected across the fields sampled.

The sections also provide tabulations of mean, minimum and maximum values for the concentrations measured in air and crumb rubber infill samples. Further statistics are provided in Appendix Sections D.4.1 and D.4.2. For cases where there was not a detection at or above the method detection limit (MDL) the concentration was assumed to be zero. If a chemical was detected, that is it was above MDL, but its concentration could not be reliability quantified because it fell below the limit of quantification (LOQ), its concentration was set to half of the LOQ. Concentrations measured above the LOQ are assumed to correct and are used without modification. 3 In non-targeted analyses, the data streams from high resolution mass spectrometry (HRMS) are analyzed to identify known and suspected chemicals present. The suspected chemicals are later confirmed with highly pure standards (Place et al., 2021). 4-150
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Regarding the results of the analyses of artificial biofluids, we define the bioaccessible concentration of a chemical as the releasable amount (e.g., in micrograms per gram of crumb rubber) from crumb rubber into artificial biofluid and available for absorption via the GI tract or skin.

The synthetic turf field environment is subject to sources of pollution, such as from industrial facilities and traffic, so that not all measured levels are directly attributable to the field, especially for chemicals in air. The Chapter concludes with a section on how OEHHA made the determination that a chemical in an air sample or crumb rubber extract was field related.

3.2. Analysis of Crumb Rubber – Organic Chemicals in GI and Dermal Biofluid Extracts

3.2.1. Identifying Chemicals for Analysis
LBNL conducted solvent extractions and analyzed the composite samples of crumb rubber samples collected from tire recycling facilities (Phase 1) and 35 fields using nontargeted chemical analyses to identify chemicals of potential concern (or suspected chemicals):
• Organic solvent comprised of a one-to-one volume ratio of acetone and hexanes was used to extract chemicals for the analysis using high efficiency source gas chromatography mass spectrometry (HES-GC-MS) (see Appendix Section D.3.3).

The algorithms and procedures used to analyze the GC-MS data and confirm chemical identities are described in Appendix Section D.3.3.4. • A polar solvent, made up of 10 percent methanol in water, was used to extract polar organic chemicals for analysis with high resolution accurate mass liquid chromatography mass spectrometry (HRAM LC-MS) (see Appendix Section D.3.4).

The algorithms and procedures used to analyze the LC-MS data and confirm chemical identities are described in Appendix Section D.3.4.4. This included matching LC-MS data to that for chemicals on OEHHA’s Tire-Related Chemical List, among other information sources, computer software search to available chemical databases (e.g., ChemSpider and mzVault), and application of cheminformatic algorithms to deduce the unknown chemical structures. • Suspected chemicals from the GC-MS and LC-MS analyses were then confirmed against commercially available high purity reference chemicals.

The resulting compiled list of chemicals to be targeted in the analysis of organic extracts from crumb rubber is shown in Table 3-1. LBNL looked for the presence of and quantified these chemicals in the artificial GI biofluids and artificial sweat extracts. 4-151
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These are referred to as the “bioaccessibility measurements”. These were done for the crumb rubber samples collected from the 35 fields in the Phase 3 Field Work described in Section 2.3.2.4.

Table 3-1. Targeted Organic Chemicals for Gastrointestinal and Dermal Bioaccessibility Measurements Targeted Chemical CASRN Analysisa
Acenaphthylene 208-96-8 GC
Aniline 62-53-3 GC
Anthracene 120-12-7 GC
Anthracene, 2-methyl- 613-12-7 GC
Anthracene, 9,10-dimethyl 781-43-1 GC
Anthracene, 9,10-diphenyl- 1499-10-1 GC
Anthracene, 9-phenyl 602-55-1 GC
2-Azacyclotridecanone 947-04-6 LC
Benzene, n-butyl- 104-51-8 GC
1,4-Benzenediamine, N-(1,3-
dimethylbutyl)-N’-phenyl- 793-24-8 GC
1,4-Benzenediamine, N,N’-
diphenyl- 74-31-7 GC and LC
1,4-Benzenediol, 2,5-bis(1,1-
dimethylethyl)- 88-58-4 GC
Benz[a]anthracene 56-55-3 GC
Benzo[a]pyrene 50-32-8 GC
Benzo[b]fluoranthene 205-99-2 GC
7H-Benzo[c]fluorene 205-12-9 GC
Benzo[e]pyrene 192-97-2 GC
Benzo[g,h,i]perylene 191-24-2 GC
Benzo[k]fluoranthene 207-08-9 GC
Benzothiazole 95-16-9 GC and
LC
Benzothiazole, 2-phenyl- 883-93-2 GC
1,3-Benzothiazole-2-thiol 149-30-4 LC
2-Benzothiazolone 934-34-9 GC and
LC
Benzyl butyl phthalate 85-68-7 GC
Bis(2-Ethylhexyl)adipate 103-23-1 GC
Bis(2,2,6,6-tetramethyl-4-
piperidyl)sebacate 52829-07-9 GC
Butylated Hydroxytoluene 128-37-0 GC
n-Caproic acid vinyl ester 3050-69-9 GC
Chrysene 218-01-9 GC
Coronene 191-07-1 GC
Cyclohexylamine 108-91-8 GC
Cyclohexyl isothiocyanate 1122-82-3 GC
Targeted Chemical CASRN Analysisa
Cyclopenta[cd]pyrene 27208-37-3 GC
Demecolcine 477-30-5 GC
Dibenz[a,h]anthracene 53-70-3 GC
Dibenzothiophene 132-65-0 GC
Dibutyl phthalate 84-74-2 GC
Cyclohexanamine, Ncyclohexyl- 101-83-7 GC and
LC
N,N-Dicyclohexyl-methylamine 7560-83-0 GC and
LC
N,N’-Dicyclohexylurea 2387-23-7 LC
Diethyl Phthalate 84-66-2 GC
Diisobutyl Phthalate 84-69-5 GC
Diisooctylphthalate 27554-26-3 GC
Dimethyl phthalate 131-11-3 GC
Di-n-octyl phthalate 117-84-0 GC
1,3-Diphenylguanidine 102-06-7 LC
Diphenylurea 102-07-8 LC
2,5-di-tert-Butyl-1,4-
benzoquinone 2460-77-7 GC
3,5-di-tert-Butyl-4-
hydroxybenzaldehyde 1620-98-0 GC and LC
Fluoranthene 206-44-0 GC
Fluorene 86-73-7 GC
Hexadecane 544-76-3 GC
2,5-Hexanedione 110-13-4 GC
Hexanoic Acid, 2-ethyl 149-57-5 GC
1-Hydroxypyrene 5315-79-7 GC
Indeno[1,2,3-cd]pyrene 193-39-5 GC
Limonene 138-86-3 GC
Linoleic acid 60-33-3 LC
Methyl stearate 112-61-8 GC
2-(Methylthio)benzothiazole 615-22-5 LC
Naphthalene 91-20-3 GC
Naphthalene, 1-methyl- 90-12-0 GC
Naphthalene, 1,2-dimethyl- 573-98-8 GC
Naphthalene, 1,6-dimethyl- 575-43-9 GC
Naphthalene, 2-(bromomethyl)- 939-26-4 GC
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Targeted Chemical CASRN Analysisa
Naphthalene, 2,3-dimethyl- 581-40-8 GC
Naphthalene, 2-methyl 91-57-6 GC
1-Octadecene 112-88-9 GC
4-tert-Octylphenol 140-66-9 GC
Oleic acid 112-80-1 LC
17-Pentatriacontene 6971-40-0 GC
Phenanthrene 85-01-8 GC
Phenanthrene, 1-methyl 832-69-9 GC
Phenanthrene, 2-methyl- 2531-84-2 GC
Phenanthrene, 3-methyl 832-71-3 GC
Phenol, 2,4-bis(1-methyl-1-
phenylethyl)- 2772-45-4 GC
Targeted Chemical CASRN Analysisa
Phenol, 4-(1-phenylethyl)- 1988-89-2 GC
Phenoxazine 135-67-1 LC
N-Phenylbenzamide 93-98-1 GC
Phthalimide 85-41-6 GC
Pyrene 129-00-0 GC
Pyridine, 2-(4-methylphenyl)- 4467-06-5 GC
Resorcinol 108-46-3 GC
Ricinoleic acid 141-22-0 LC
Triethylene glycol monobutyl
ether 143-22-6 LC
5,9-Undecadien-2-one, 6,10-
dimethyl- 689-67-8 GC
aGC: gas chromatography; LC: liquid chromatography

3.2.2. Sample Extraction and Analysis
LBNL extracted chemicals from crumb rubber into artificial sweat to simulate conditions leading to dermal exposure. The artificial sweat preparation is described in Appendix Section D.4.1.3.1.

Similarly, three different types of artificial GI fluids were used during chemical extraction to simulate conditions leading to oral exposure: saliva, gastric, and intestinal biofluids.

These three artificial GI fluid preparations are described in Appendix Section D.4.1.4.1.

The extraction systems used specially coated stir bars to enhance the accessibility or solubility of chemicals from crumb rubber into the artificial fluids. When coupled with GC-MS or LC-MS analyses, this stir bar sorptive extraction (SBSE) method provides a simple sample preparation that supports simultaneous, trace analyses of a large number of chemicals (Telgheder et al., 2018) without the need of an extensive cleanup.

The conventional approach to simulating dermal and GI physiological conditions is to include lipids and milk in the artificial biofluids to model the skin surface and GI linings, respectively. Milk is often included in GI biofluids to simulate the fed state. Lipids or milk enhance the extractability of lipophilic chemicals from samples. However, the resulting extracts require extensive cleanup prior to instrumental analyses. This would not be practical and feasible for analyzing the large number of organic chemicals, which have a wide range of physical properties (e.g., polarity and solubility) and ranges of concentrations in our study. Loss of chemicals during the cleanup processes would be hard to control.

Nonetheless, LBNL tested feasibility of the SBSE extraction system for GI bioaccessibility measurements under different conditions, which included the addition of milk. They used commercially available artificial gastric and intestinal biofluids (See Appendix Section D.4.1.4.1 for artificial gastric biofluid compositions). Ultra-heat treated 4-153
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milk was added to the artificial gastric fluid to simulate the presence of food in the fed state.

After extracting crumb rubber samples using the SBSE system, LBNL conducted GCMS analysis of the organic chemicals adsorbed on the polydimethylsiloxane (PDMS) stir bars. Preliminary GC-MS analytical data showed that the presence of milk reduced the GC signals. This could be due to the binding of the crumb rubber chemicals to lipids and proteins in the milk, which interfered with their adsorption onto the PDMS stir bars.

Alternatively, the adhesion of lipids and proteins could have saturated the adsorption capacity of the stir bars for crumb rubber chemicals. The Team, therefore, adopted crumb rubber extraction systems without added lipids or milk.

Below we provide an overview of the approaches used to create the artificial biofluid extracts and analyze them for the presence and levels of chemicals in the fluids. For details on the procedures and instruments used, see Appendix Section D.4.1.3 for the artificial sweat extraction and analyses and Appendix Section D.4.1.4 for the artificial GI fluids extractions and their analyses.

Lipophilic chemicals: A PDMS coated Gerstel stir bar was magnetically affixed on the wall of a test tube that contained the crumb rubber and artificial fluid mixture (Figure 3-1). LBNL incubated the mixtures at 37°C under constant stirring with an inert (Telfoncoated) stir bar at the bottom of the tube, for various time durations. At the end of the incubations, LBNL removed and gently rinsed the Gerstel stir bars.

The PDMS coated stir bar acted as a chemical sink which sequestered lipophilic chemicals from the aqueous artificial fluid and enhanced the extractability and accessibility of these chemicals from crumb rubber, simulating human physiological conditions in the gut linings or lipid layer on skin surfaces. 4-154
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Figure 3-1. Bioaccessibility Measurement Setup. A Gerstel stir bar is magnetically fixed on the side of an incubation tube. The solution in the tube is an artificial biofluid. The inert stir bar in the bottom of the tube constantly stirs the mixture.

The Laboratory analyzed the chemicals adsorbed on the stir bar using a HES-GC-MS system (Series 7890 Plus; Agilent Technologies) equipped with a thermal desorption injection system (ThermoDesorption Autosampler – Gerstel Model TDSA2 and a thermal desorption oven – Gerstel Model TDS3). See Appendix Sections D.4.1.3.2 and D.4.1.4.2.

Hydrophilic Chemicals: Hydrophilic chemicals generally dissolve or extract well into aqueous artificial biofluids. However, inorganic salts in the biofluids interfered with the analysis of organic chemicals using the HRAM LC-MS. Instead of processing the extracts for desalting and cleanup, LBNL used ethylene glycol-PDMS copolymer coated Gerstel stir bars (EG stir bars) to adsorb the accessible hydrophilic chemicals from the aqueous artificial fluids during extraction. The setup was similar to the extraction system used for lipophilic chemicals (Figure 3-1), with the EG stir bar used instead of the PDMS stir bar. At the end of the incubation, LBNL removed and gently rinsed the EG stir bars.

They reconstituted the chemicals adsorbed on the EG stir bars into acetonitrile and analyzed the acetonitrile extract using the HRAM LC-MS system: a 1200 series LC system (Agilent Technologies) connected in line with an (linear ion trap) LTQ-OrbitrapXL® mass spectrometer equipped with an electrospray ionization (ESI) source (ThermoFisher Scientific). See Appendix Section D.3.4.3 for details.

Limits of Detection: LBNL determined the MDL and LOQ of each chemical targeted in the bioaccessibility measurements using the USEPA protocols (USEPA, 2016). 4-155
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Appendix Section 3.6.1.5 details the methods and provides the limits of detection for the chemicals analyzed by HES GC-MS. LBNL was unable to determine the limits of detection using the HRAM LC-MS due to its limited availability. However, the sensitivity of this instrument has been reported to be at the sub-femtomole level4 (UWPR, 2007).

3.2.3. Results of Analyses of Artificial GI Fluids
The results of the analyses of the GI fluid extracts of the 35 sampled fields (Phase 3) are summarized in Table 3-2. As described in Appendix Section D.1.8, two composite samples were prepared in the Laboratory using crumb rubber sampled from each field, one from samples collected in areas of high impact (“HI”), such as in the two goal areas in a soccer field, the second from samples collected in the rest of the field (“ROF”). A discussion of the differences between HI and ROF samples is provided in Appendix Section D.4.1.4.3, along with a discussion of sample variation. Variations in chemical composition within a sample, within a field, and between pairs of composite samples from the 35 individual fields were found to be low, thus OEHHA found the use of composite samples to be appropriate for the study. For the presentation here, a single value was calculated for each field by averaging analytical data for the HI and ROF composite samples for each field.

The mean value shown for each chemical is the arithmetic mean of the 35 individual field average GI bioaccessible concentrations. The table also shows the minimum and maximum values of the 35 fields. Further statistics on these chemical results are presented in Appendix Section D.4.1.4.6, Table D-41.

Table 3-2. Gastrointestinal (GI) Bioaccessible Concentrations of Organic Chemicals in Crumb Rubber Sampled from 35 Synthetic Turf Fields in California* Chemical CASRN Detections
(# of fields)
GI Bioaccessibile Concentration
(nanograms per gram crumb rubber)
Minimum Mean Maximum
1,4-Benzenediamine, N-(1,3-
dimethylbutyl)-N'-phenyl- 793-24-8 20 0 48 230
1,4-Benzenediamine, N,N'-
diphenyl- 74-31-7 7 0 5.5 120
17-Pentatriacontene 6971-40-0 9 0 4 42
1-Hydroxypyrene 5315-79-7 1 0 1.1 40
1-Octadecene 112-88-9 32 0 4.7 14
2-(Methylthio)benzothiazole 615-22-5 5 0 15 300
2,5-di-tert-Butyl-1,4-
benzoquinone 2460-77-7 4 0 0.082 1.2
3,5-di-tert-Butyl-4-
hydroxybenzaldehyde 1620-98-0 35 0.049 18 180
4 For example, the molecular weight of benzothiazole is 135 grams per mole, thus, 1 femtomole of benzothiazole equals to 0.1 picogram.
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Chemical CASRN Detections
(# of fields)
GI Bioaccessibile Concentration
(nanograms per gram crumb rubber)
Minimum Mean Maximum
4-tert-Octylphenol 140-66-9 35 5.3 69 430
5,9-Undecadien-2-one, 6,10-
dimethyl- 689-67-8 35 2 3.4 6.5
7H-Benzo[c]fluorene 205-12-9 31 0 0.77 6.2
Acenaphthylene 208-96-8 35 0.041 0.32 1.2
Aniline 62-53-3 12 0 1.8 18
Anthracene 120-12-7 28 0 0.83 6.8
Anthracene, 2-methyl- 613-12-7 35 0.48 3.3 15
Anthracene, 9,10-dimethyl 781-43-1 2 0 0.027 0.88
Anthracene, 9,10-diphenyl- 1499-10-1 2 0 0.21 5.3
Anthracene, 9-phenyl 602-55-1 30 0 0.31 1.4
Benz[a]anthracene 56-55-3 35 0.19 2.9 13
Benzene, n-butyl- 104-51-8 29 0 0.18 2.7
Benzo[a]pyrene 50-32-8 35 0.47 2.4 7
Benzo[b]fluoranthene 205-99-2 35 0.81 4 12
Benzo[e]pyrene 192-97-2 35 2.1 7.1 16
Benzo[g,h,i]perylene 191-24-2 35 0.33 4.8 13
Benzo[k]fluoranthene 207-08-9 35 0.11 1.3 4.8
Benzothiazole 95-16-9 35 110 490 1200
Benzothiazole, 2-phenyl- 883-93-2 35 15 53 280
Benzothiazolone 934-34-9 35 790 1200 1700
Benzyl butyl phthalate 85-68-7 35 1.3 25 100
Bis(2,2,6,6-tetramethyl-4-
piperidyl)sebacate 52829-07-9 4 0 12 130
Bis(2-Ethylhexyl)adipate 103-23-1 33 0 16 57
Butylated Hydroxytoluene 128-37-0 19 0 0.67 5.6
Chrysene 218-01-9 35 3.2 13 35
Coronene 191-07-1 7 0 1.8 28
Cyclohexyl isothiocyanate 1122-82-3 29 0 160 410
Cyclopenta[cd]pyrene 27208-37-3 35 0.49 2.8 13
Dibenz[a,h]anthracene 53-70-3 7 0 0.17 2.1
Dibenzothiophene 132-65-0 27 0 0.67 4.1
Dibutyl phthalate 84-74-2 31 0 48 140
Dicyclohexylamine 101-83-7 25 0 41 110
Diethyl Phthalate 84-66-2 23 0 4 12
Diisobutyl Phthalate 84-69-5 32 0 4.8 73
Diisooctylphthalate 27554-26-3 33 0 100 270
Dimethyl phthalate 131-11-3 9 0 0.93 15
Di-n-octyl phthalate 117-84-0 26 0 9.9 110
Diphenylurea 102-07-8 35 5.6 130 770
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Chemical CASRN Detections
(# of fields)
GI Bioaccessibile Concentration
(nanograms per gram crumb rubber)
Minimum Mean Maximum
Fluoranthene 206-44-0 35 3.1 22 110
Fluorene 86-73-7 11 0 0.29 3.5
Hexadecane 544-76-3 28 0 2.1 8.2
Indeno[1,2,3-cd]pyrene 193-39-5 12 0 0.48 3.3
Limonene 138-86-3 34 0 4.2 76
Linoleic acid 60-33-3 35 630 1000 1300
Methyl stearate 112-61-8 35 2.5 10 47
N,N'-Dicyclohexylurea 2387-23-7 17 0 23 220
Naphthalene 91-20-3 1 0 0.053 1.8
Naphthalene, 1,2-dimethyl- 573-98-8 12 0 0.032 0.36
Naphthalene, 1,6-dimethyl- 575-43-9 35 0.083 0.21 0.59
Naphthalene, 1-methyl- 90-12-0 31 0 0.14 2.8
Naphthalene, 2-
(bromomethyl)- 939-26-4 35 0.19 5.5 12
Naphthalene, 2,3-dimethyl- 581-40-8 35 0.041 1.6 7
Naphthalene, 2-methyl 91-57-6 19 0 0.12 3
n-Caproic acid vinyl ester 3050-69-9 1 0 0.13 4.7
N-Phenylbenzamide 93-98-1 22 0 22 150
Oleic acid 112-80-1 3 0 54 760
Phenanthrene 85-01-8 35 1.7 9.8 63
Phenanthrene, 1-methyl 832-69-9 35 0.23 2.6 11
Phenanthrene, 2-methyl- 2531-84-2 35 0.071 3.4 18
Phenanthrene, 3-methyl 832-71-3 35 0.43 5.6 28
Phenol, 2,4-bis(1-methyl-1-
phenylethyl)- 2772-45-4 35 3.1 26 70
Phenol, 4-(1-phenylethyl)- 1988-89-2 34 0 14 94
Phenoxazine 135-67-1 3 0 13 250
Phthalimide 85-41-6 16 0 3.9 42
Pyrene 129-00-0 35 8.8 47 140
Pyridine, 2-(4-methylphenyl)- 4467-06-5 2 0 0.1 3.4
Ricinoleic acid 141-22-0 33 0 25 110
Triethylene glycol monobutyl
ether 143-22-6 3 0 1.2 26
*Detections: Number of fields out of 35 with concentrations above method detection limits.

Mean: Arithmetic mean of the concentrations of the individual field average concentrations. 0: A value of 0 means the chemical is not detected or is detected below the method detection limit.

Among the 86 GI bioaccessible organic chemicals targeted (Table 3-1), the study confirmed the presence of and quantified 76 chemicals as having concentrations above the method detection limits.

Two chemicals were determined invalid due to matrix interference or that the reference 4-158
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standard was not detected in calibration:
• cyclohexylamine (CASRN 108-91-8) due to matrix interference • demecolcine (CASRN 477-30-5) reference standard not detected in the calibration.

Eight chemicals were not detected in the GI extracts:
• 1,3-benzothiazole-2-thiol (CASRN 149-30-4)
• 1,3-diphenylguanidine (CASRN 102-06-7)
• resorcinol (CASRN 108-46-3)
• 2,5-bis(1,1-dimethylethyl)-1,4-benzenediol (CASRN 88-58-4) • 2-azacyclotridecanone (CASRN 947-04-6)
• 2,5-hexanedione (CASRN 110-13-4)
• hexanoic acid, 2-ethyl (CASRN 149-57-5)
• N,N-dicyclohexylmethylamine (CASRN 7560-83-0)

3.2.4. Results of Analyses of Artificial Sweat Extracts The results of the analyses of the dermal fluid extracts of the 35 sampled fields (Phase 3) are summarized in Table 3-3. For each field the average of the concentrations for the HI and ROF composite samples were calculated. The mean value in Table 3-3 is the arithmetic average of the concentrations for the 35 individual fields. The table also shows the minimum and maximum concentration values for the 35 fields. Further details on these results are provided in Appendix Section D.4.1.3.3, Table D-32.

Table 3-3. Dermal Bioaccessible Concentrations of Organic Chemicals in Crumb Rubber from 35 Synthetic Turf Fields in California*
Chemical CASRN Detections
Dermal Bioaccessibile Concentration
(nanograms per gram crumb rubber)
Minimum Mean Maximum
Acenaphthylene 208-96-8 10 0 0.0056 0.035
Aniline 62-53-3 4 0 0.18 2.7
Anthracene 120-12-7 20 0 0.062 0.41
Anthracene, 2-methyl- 613-12-7 35 0.022 0.089 0.35
Anthracene, 9,10-diphenyl- 1499-10-1 5 0 0.012 0.17
Anthracene, 9-phenyl 602-55-1 9 0 0.03 0.3
2-Azacyclotridecanone 947-04-6 2 0 0.24 6
Benzene, n-butyl- 104-51-8 1 0 0.00037 0.013
1,4-Benzenediamine, N-(1,3-dimethylbutyl)-N’-
phenyl- 793-24-8 32 0 17 140
1,4-Benzenediamine, N,N’-diphenyl- 74-31-7 9 0 3.5 86
Benz[a]anthracene 56-55-3 31 0 0.25 1.3
Benzo[a]pyrene 50-32-8 32 0 0.19 0.76
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Chemical CASRN Detections
Dermal Bioaccessibile Concentration
(nanograms per gram crumb rubber)
Minimum Mean Maximum
Benzo[b]fluoranthene 205-99-2 34 0 0.35 1.4
7H-Benzo[c]fluorene 205-12-9 26 0 0.03 0.16
Benzo[e]pyrene 192-97-2 35 0.053 0.55 1.5
Benzo[g,h,i]perylene 191-24-2 35 0.051 0.42 1.1
Benzo[k]fluoranthene 207-08-9 29 0 0.15 0.62
Benzothiazole 95-16-9 35 46 200 450
Benzothiazole, 2-phenyl- 883-93-2 35 1.4 4.8 19
1,3-Benzothiazole-2-thiol 149-30-4 1 0 1.3 46
2-Benzothiazolone 934-34-9 35 120 560 790
Benzyl butyl phthalate 85-68-7 35 0.15 2.3 6.5
Bis(2-Ethylhexyl)adipate 103-23-1 35 0.18 2.5 23
Bis(2,2,6,6-tetramethyl-4-piperidyl)sebacate 52829-07-
9 1 0 0.52 18
Chrysene 218-01-9 35 0.17 1.6 3.6
Coronene 191-07-1 1 0 0.13 4.4
Cyclohexyl isothiocyanate 1122-82-3 1 0 0.0084 0.29
Cyclopenta[cd]pyrene 27208-37-
3 35 0.029 0.28 0.65
Dibenz[a,h]anthracene 53-70-3 14 0 0.091 0.69
Dibenzothiophene 132-65-0 20 0 0.054 0.32
Cyclohexanamine, N-cyclohexyl- 101-83-7 30 0 48 480
N,N-Dicyclohexylmethylamine 7560-83-0 28 0 0.084 0.88
N,N’-Dicyclohexylurea 2387-23-7 18 0 25 360
Diethyl Phthalate 84-66-2 5 0 0.41 6.2
Diisobutyl Phthalate 84-69-5 28 0 0.35 3.4
Diisooctylphthalate 27554-26-
3 35 0.098 11 33
Dimethyl phthalate 131-11-3 3 0 0.25 3.2
Di-n-octyl phthalate 117-84-0 33 0 2.4 16
1,3-Diphenylguanidine 102-06-7 2 0 0.72 18
Diphenylurea 102-07-8 32 0 61 220
2,5-di-tert-Butyl-1,4-benzoquinone 2460-77-7 4 0 0.0021 0.028 3,5-Di-tert-butyl-4-hydroxybenzaldehyde 1620-98-0 25 0 11 160 Fluoranthene 206-44-0 35 0.31 1.9 5.2
Fluorene 86-73-7 6 0 0.008 0.14
Hexanoic Acid, 2-ethyl 149-57-5 1 0 0.0092 0.32
1-Hydroxypyrene 5315-79-7 1 0 0.53 19
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Chemical CASRN Detections
Dermal Bioaccessibile Concentration
(nanograms per gram crumb rubber)
Minimum Mean Maximum
Indeno[1,2,3-cd]pyrene 193-39-5 28 0 0.18 0.66
Limonene 138-86-3 35 0.077 0.34 1.8
Linoleic acid 60-33-3 1 0 1.1 37
Methyl stearate 112-61-8 28 0 1.1 8.1
2-(Methylthio)benzothiazole 615-22-5 9 0 7.3 73
Naphthalene 91-20-3 2 0 0.012 0.21
Naphthalene, 1-methyl- 90-12-0 1 0 0.0019 0.065
Naphthalene, 1,2-dimethyl- 573-98-8 1 0 0.00083 0.029
Naphthalene, 1,6-dimethyl- 575-43-9 6 0 0.0087 0.065
Naphthalene, 2-(bromomethyl)- 939-26-4 33 0 0.34 1.1
Naphthalene, 2,3-dimethyl- 581-40-8 33 0 0.1 0.41
Naphthalene, 2-methyl 91-57-6 1 0 0.0018 0.063
1-Octadecene 112-88-9 27 0 0.59 9.7
4-tert-Octylphenol 140-66-9 34 0 4.6 43
Oleic acid 112-80-1 3 0 5.5 110
Phenanthrene 85-01-8 29 0 0.4 2.5
Phenanthrene, 1-methyl 832-69-9 35 0.04 0.21 0.65
Phenanthrene, 2-methyl- 2531-84-2 34 0 0.26 0.96
Phenanthrene, 3-methyl 832-71-3 3 0 0.093 1.9
Phenol, 2,4-bis(1-methyl-1-phenylethyl)- 2772-45-4 35 0.11 1.4 5.2 Phenol, 4-(1-phenylethyl)- 1988-89-2 35 0.13 1.5 7.3
Phenoxazine 135-67-1 2 0 4.3 100
N-Phenylbenzamide 93-98-1 8 0 0.58 4.2
Phthalimide 85-41-6 26 0 3.8 38
Pyrene 129-00-0 35 0.94 5.1 14
Pyridine, 2-(4-methylphenyl)- 6/5/4467 14 0 0.19 1.6
Ricinoleic acid 141-22-0 3 0 3.8 67
Triethylene glycol monobutyl ether 143-22-6 7 0 0.98 11 5,9-Undecadien-2-one, 6,10-dimethyl- 689-67-8 32 0 0.13 0.63 *Detections: Number of fields out of 35 fields with concentrations above method detection limits.

Mean: Arithmetic mean of the concentrations of the individual field average concentrations. 0: A value of 0 means the chemical is not detected or is detected below the method detection limit.

Among the 86 chemicals targeted (Table 3-1), the study confirmed the presence of and quantified 75 organic chemicals with dermal bioaccessible concentrations above the method of detection limits.

The analyses of three targeted chemicals were invalidated due to matrix interference or 4-161
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reference standards not detected in the calibration:
• cyclohexylamine (CASRN 108-91-8) - matrix interference • demecolcine (CASRN 477-30-5) – reference standard not detected • resorcinol (CASRN 108-46-3) – reference standard not detected Eight chemicals were not detected in the extracts of artificial sweat:
• 2,5-bis(1,1-dimethylethyl)- 1,4-benzenediol (CASRN 88-58-4) • 2,5-hexanedione (CASRN 110-13-4)
• 17-pentatriacontene (CASRN 6971-40-0)
• 9,10-dimethylanthracene (CASRN 781-43-1)
• butylated hydroxytoluene (CASRN 128-37-0)
• dibutyl phthalate (CASRN 84-74-2)
• hexadecane (CASRN 544-76-3)
• n-caproic acid vinyl ester (CASRN 3050-69-9)

3.2.5. Chemicals Found in GI vs Dermal Extracts
Of the 81 chemicals detected in either the extracts of artificial sweat or artificial GI fluids, 70 chemicals were found in both types of fluids. The chemicals detected are of diverse structure and lipophilicity, from water soluble amines to polycyclic aromatic hydrocarbons (PAHs), and can be generally categorized as follows:
• sulfur-containing chemicals (5 in GI extracts, 6 in artificial sweat) • alkanes and alkenes (6 in GI extracts, 4 in artificial sweat) • oxygen-containing (phenols, a quinone, a polyglycol ester) (6 in GI extracts, 5 in artificial sweat)
• fatty acids and esters (7 chemicals in both types)
• phthalates (7 in GI extracts, 6 in artificial sweat)
• nitrogen-containing chemicals (amines, amides, ureas, and a pyridine) (10 in GI extracts, 13 in artificial sweat)
• PAHs and derivatives (32 in GI extracts, 31 in artificial sweat) • brominated-PAH (one in both types of extracts)
• sulfur-containing PAH (one in both types of extracts) • an aldehyde (one in both types of extracts)
Five chemicals were detected only in artificial sweat extracts:
• 1,3-benzothiazole-2-thiol (CASRN 149-30-4)
• 1,3-diphenylguanidine (CASRN 102-06-7)
• 2-azacyclotridecanone (CASRN 947-04-6)
• hexanoic acid, 2-ethyl (CASRN 149-57-5)
• N,N-dicyclohexylmethylamine (CASRN 7560-83-0)
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Six chemicals were detected only in GI biofluids extracts:
• 1,4-benzenediamine, N-(1,3-dimethylbutyl)-N'-phenyl- (CASRN 793-24-8) • anthracene, 9,10-dimethyl (CASRN 781-43-1)
• butylated hydroxytoluene (CASRN 128-37-0)
• hexadecane (CASRN 544-76-3)
• dibutyl phthalate (CASRN 84-74-2)
• n-caproic acid vinyl ester (CASRN 3050-69-9)

3.3. Analysis of Crumb Rubber - Metals and Metalloids in Acid Extracts Exposure to metals and metalloids from crumb rubber is assumed to mainly occur via the oral route. Measurements were undertaken using simulated gastrointestinal acids to evaluate the degree that metals and metalloids would be released from crumb rubber when ingested. “Bioaccessible concentrations” of metals and metalloids represents the amount of metal released in the GI tract per amount of crumb rubber consumed.

This section presents bioaccessible concentrations measured for the metals and metalloids. In addition, it reports on the full digestion of crumb rubber in acid that enabled calculations of bioaccessible fractions – expressed as the percent of metal/metalloids in crumb rubber that is released into the biofluid.

3.3.1. Selection of Metals and Metalloids for Study and Analytical Method LBNL analyzed the crumb rubber samples collected from the 35 fields (Phase 3) using inductively coupled plasma mass spectrometry (ICP-MS) for development of sample preparations and extraction SOPs. Originally, we planned to use the crumb rubber collected from manufacturers and pilot fields, as discussed in Phase 1, but were unable to do the analyses until after the Statewide fields were sampled. We therefore amended the project plan to use the statewide field samples instead.

ICP-MS allows a direct and highly sensitive quantitative measurement in a sample of almost all the elements in the periodic table5. It provides a nearly complete elemental profile of each sample run. No sample cleanup is required before analyses with the ICPMS instrument. The method detection limit is at the parts per trillion level.

We decided use this highly sensitive method to focus on a predetermined list of 31 potentially hazardous metals and metalloids for the targeted elemental analysis of the crumb rubber acid extracts. This was based on preliminary results and input received at the 2018 OEHHA SAP Meeting (OEHHA, 2018). Also, rather than trying to speciate detected metals, as a screening approach, we assumed the detected metals and 5 Hydrogen, helium, argon, nitrogen, oxygen, fluorine, and neon are the only elements that cannot be measured.
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metalloids were in their most toxic forms in assessing the hazards and risks. Had high risks been seen we could follow-up with additional analysis.

Two different acid digestion methods were used to extract metals and metalloids from the crumb rubber samples:
• American Society for Testing and Materials (ASTM) F3188-16 was used to simulate gastric fluid - to obtain extracts for the bioaccessibility measurement of metals and metalloids in the crumb rubber samples.
• USEPA 3051A (USEPA, 2007) is a microwave-assisted method that provides a full acid digestion of the sample. This enables the determination of total extractable metals and metalloids in crumb rubber samples.

The details on how the extractions were performed are presented in Appendix Sections D.4.1.1 and D.4.1.2.

The ASTM method is established for simulating gastric digestion of crumb rubber using mild acid (0.8 Molarity hydrochloric acid or 0.8 M HCl). The amounts metals and metalloids detected in this assay are applied to calculate the oral bioaccessible concentrations of crumb rubber. On the other hand, the USEPA method fully extracted crumb rubber by microwave digestion at 175 °C in a concentrated acid mixture (3:1 concentrated nitric acid and concentrated hydrochloric acid). This provides the basis estimating the amount of a given metal or metalloid in a crumb rubber sample.

A decision was made to deviate from the initially established the list of 31 metals and metalloids to be analyzed - to exclude mercury. The analysis for mercury had to be conducted separately from the other metals (see Appendix Section D.2.7). Preliminary analysis of the ASTM extracts found that the bioaccessible concentrations of mercury in most of the crumb rubber extracts were below the MDL (OEHHA, 2018). Less than 6% of samples (5 of 84) had concentrations above the MDL of 0.15 part per billion. Since mercury was uncommon, as reported in previous studies on crumb rubber and synthetic turf fields, the SAP recommended excluding mercury in the final analysis of the crumb rubber extracts (OEHHA, 2018).

3.3.2. Preparation, Extraction and Analysis of Field Samples ICP-MS measurements showed minimal variation of metal and metalloid concentrations among samples collected from a selected field. The SAP suggested the preparation of two composite samples per field. One composite sample was from the high impact area of the field - goal areas on a soccer field, end zones on a football field, and four bases on a softball field. The second composite sample was from the rest of the field areas.

The procedures for preparing the composite samples is discussed in Appendix Section D.1.8)
LBNL extracted the composite field samples from the statewide sampling using ASTM F3188-16. They quantified the concentrations of metals and metalloids in these acid 4-164
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extracts by ICP-MS, as described in Appendix Section D.4.1.1.4. OEHHA applied the results to assess the gastric bioaccessible concentrations of metals and metalloids from crumb rubber. OEHHA assumes these concentrations represent the amount of crumb rubber exposure, for example in micrograms, per gram of crumb rubber ingested. These concentrations were used to calculate exposures of field users by the oral route in Chapter 5.

The procedure LBNL used to determine the MDL and LOQ of each metal or metalloid is described in Appendix Section D.3.6.1.7.

3.3.3. Results of Analysis of GI Extracts for Metals and Metalloids The results of the analysis of the 30 metals and metalloids quantified by LBNL applying ICP-MS to the GI biofluid extracts are summarized in Table 3-4. Metals and metalloids are generally more soluble in the acidic pH in gastric fluid than the alkali pH in intestinal fluids. OEHHA therefore assumed that the concentrations measured in the artificial gastric fluid (0.8 M hydrochloric acid) represented the gastrointestinal (GI) bioaccessible concentration following the inadvertent ingestion of crumb rubber by field users.

The values shown in Table 3-4 are the arithmetic mean, minimum, and maximum of the 35 individual field averages of GI bioaccessible concentrations. In making these calculations, a single field is represented by the average of the concentration for the samples of the high impact area and of the “rest of field”. Additional statistics for this analysis are provided in Appendix Section D.4.1.1.5, Table D-27.

Table 3-4. Gastrointestinal (GI) Bioaccessible Concentrations of Metals and Metalloids in Crumb Rubber from 35 Synthetic Turf Fields in California* Metal or Metalloid Symbol Detection
(# of fields)
GI Bioaccessible Concentration
(micrograms per gram of crumb rubber)
Minimum Mean Maximum
Aluminum Al 35 7 22 52
Antimony Sb 35 0.0015 0.024 0.1
Arsenic As 35 0.0012 0.01 0.039
Barium Ba 35 0.4 1.5 5.7
Beryllium Be 11 0 0.00063 0.0035
Boron B 25 0 0.45 1.8
Cadmium Cd 34 0 0.017 0.04
Calcium Ca 35 13 460 7900
Chromium Cr 35 0.0088 0.047 0.26
Cobalt Co 35 0.2 1.1 3.8
Copper Cu 35 0.84 2.1 6.7
Iron Fe 35 8.1 23 38
Lead Pb 35 0.19 1 4.5
Lithium Li 3 0 0.0033 0.047
Magnesium Mg 35 3.2 19 130
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Metal or Metalloid Symbol Detection
(# of fields)
GI Bioaccessible Concentration
(micrograms per gram of crumb rubber)
Minimum Mean Maximum
Manganese Mn 35 0.18 0.99 3.1
Molybdenum Mo 14 0 0.0018 0.009
Nickel Ni 35 0.021 0.097 0.37
Potassium K 35 2.9 13 40
Rubidium Rb 35 0.016 0.05 0.17
Selenium Se 4 0 0.006 0.088
Silicon Si 35 5.3 16 50
Silver Ag 2 0 0.0006 0.014
Sodium Na 35 0.9 21 110
Strontium Sr 35 0.081 0.85 9.6
Thallium Tl 21 0 0.00024 0.0022
Tin Sn 30 0 0.0093 0.037
Titanium Ti 35 0.16 0.36 0.69
Vanadium V 2 0 0.0048 0.085
Zinc Zn 35 46 210 600 * A value of 0 means the chemical is not detected or is detected below the detection limit. Concentrations below the MDL are set to equal zero. Detections above MDL, but below the LOQ are set to half of the LOQ. Concentrations above the LOQ are presented without modification.

Detections: Number of fields out of 35 total with concentrations above detection limits.

Mean: Arithmetic mean of the concentrations of the individual field average concentrations.

Table 3-5 shows the results of analysis of the full digestion of the crumb rubber samples from the 35 fields - using USEPA 3051A. The values shown in Table 3-5 are the arithmetic mean, minimum, and maximum of the 35 individual field averages of the strong acid digestions. These values represent the concentration of metal in the crumb rubber sample. These values are used to calculate the bioaccessibility percent.

Table 3-5. Total Concentrations of Metals and Metalloids in Crumb Rubber from 35 Synthetic Turf Fields in Californiaa
Metal or
Metalloid Symbol Detections (# of fields)
Total Concentrationb
(micrograms per gram of crumb rubber)
Minimum Mean Maximum
Aluminum Al 35 380 860 2300
Antimony Sb 35 0.18 0.82 2.5
Arsenic As 35 0.25 0.75 2.1
Barium Ba 35 4 11 75
Beryllium Be 4 0.0046 0.018 0.045
Boron B 31 1.7 5.9 39
Cadmium Cd 35 0.22 0.96 4.5
Calcium Ca 35 920 8300 120000
Chromium Cr 35 0.72 5.2 120
Cobalt Co 35 48 150 360
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Metal or
Metalloid Symbol Detections (# of fields)
Total Concentrationb
(micrograms per gram of crumb rubber)
Minimum Mean Maximum
Copper Cu 35 8.3 21 35
Iron Fe 35 270 720 2600
Lead Pb 35 3.6 23 91
Lithium Li 35 0.76 1.7 3.1
Magnesium Mg 35 170 430 4600
Manganese Mn 35 4.5 8.8 25
Molybdenum Mo 35 0.0059 0.15 0.51
Nickel Ni 35 1.1 3.7 17
Potassium K 35 250 490 1700
Rubidium Rb 35 1 2 9.4
Selenium Se 35 1.4 2.6 4.4
Silicon Si 35 61 600 1100
Silver Ag 11 0.014 2.1 11
Sodium Na 35 140 370 650
Strontium Sr 35 1.9 6.8 49
Thallium Tl 35 0.026 0.046 0.1
Tin Sn 35 0.44 1.9 9.8
Titanium Ti 35 20 57 220
Vanadium V 35 0.51 2.3 6.9
Zinc Zn 35 7600 16000 25000 a Full digestion of crumb rubber using U.S. EPA, 2007. b Minmium, mean, and maximum are the corresponding values for the 35 individual field average concentrations.

The bioaccessibility percent of each metal or metalloid was calculated as the ratio of average GI bioaccessibility concentration for an individual field to the average total concentration of the same field multiplied by 100 percent. Table 3-6 shows the value arithmetic mean of GI bioaccessibility percent of metals and metalloids in crumb rubber for the 35 fields. The values range from 0.2 for vanadium to 18 percent for boron among the 30 metals and metalloids. Fields with no detected total concentration a metal or metalloid above the MDL are excluded in the calculation of bioaccessibility percent.

Table 3-6. Estimates of Gastric Bioaccessibility for Metals and Metalloids in Crumb Rubber from 35 Synthetic Turf Fields in California
Metal or Metalloid Number of fields with detections by Mean Gastric ASTM Method USEPA 3051A Bioaccessibility
Aluminum 35 35 2.9%
Antimony 35 35 3.6%
Arsenic 35 35 1.6%
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Metal or Metalloid Number of fields with detections by Mean Gastric ASTM Method USEPA 3051A Bioaccessibility
Aluminum 35 35 2.9%
Barium 35 35 17.4%
Beryllium 11 4 10.3%
Boron 25 31 18.3%
Cadmium 34 35 2.4%
Calcium 35 35 7.3%
Chromium 35 35 2.2%
Cobalt 35 35 0.8%
Copper 35 35 10.6%
Iron 35 35 3.9%
Lead 35 35 7.5%
Lithium 3 35 0.2%
Magnesium 35 35 5.5%
Manganese 35 35 12.0%
Molybdenum 14 35 1.3%
Nickel 35 35 2.9%
Potassium 35 35 2.8%
Rubidium 35 35 2.7%
Selenium 4 35 0.3%
Silicon 35 35 4.6%
Silver 2 11 0.5%
Sodium 35 35 5.7%
Strontium 35 35 12.9%
Thallium 21 35 0.7%
Tin 30 35 0.7%
Titanium 35 35 0.8%
Vanadium 2 35 0.2%
Zinc 35 35 1.4%

3.4. Analysis of Air Samples – for Evaluating Inhalation Exposures

3.4.1. Identifying Chemicals to Analyze in Air Samples
OEHHA also conducted literature research, outreach and consulted experts at federal 4-168
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agencies to identify chemicals for targeted analyses of air samples (see section 3.1 and

1.3.1). In addition, LBNL conducted preliminary laboratory measurements to determine chemical targets for the analysis of samples collected in the air during the statewide field sampling efforts. This included “non-targeted analysis” to look for chemicals not previously known to be released from crumb rubber, or those suspected of being present. Non-targeted analyses were also performed in the following studies:
• Chamber emission studies where the vapors emitted were analyzed. This produced volatile organic chemicals (“VOCs”) for analysis by GC-MS and low molecular weight carbonyls for analysis by high performance liquid chromatography (HPLC).
• Direct thermal desorption into the GC-MS. This was used to provide mid-range VOCs for analysis.
• The crumb rubber solvent extracts (one-to-one parts acetone and hexane) used to identify chemicals for oral and dermal routes (see Section 3.2.1) were also used to identify the semi-volatile organic chemicals (“SVOCs”) in air.

These studies were conducted by LBNL using crumb rubber obtained from waste tire recycling facilities. The chamber and thermal desorption studies are described in in the Appendix D sections, as follows:
• D.3.1 Environmental Chamber and Emissions Testing of Crumb Rubber:

Describes how the material was prepared for the emission studies, the material was tested in the chamber, the chamber air was sampled and analyzed for volatile organic chemicals and low molecular weight carbonyls, chamber emissions studies were conducted, how the samples were analyzed for VOCs and low molecular weight carbonyls.
• D.3.2 Direct Thermal Desorption Measurements of Crumb Rubber: Describes the desorption experiment
• D.3.3.4 Non-Targeted Analysis of GC-MS Data: Describes the steps taken to identify and confirm chemicals suspected from the GC-MS data stream.

This work identified chemical targets for analysis that fall in the following groups:
• VOCs: Samples were collected onto multibed glass thermal desorption tubes, hereto after referred to as “sorbent tubes”.
• Low molecular weight carbonyls (aldehydes and ketones): Samples were collected on silica gel cartridges coated with 2,4-dinitrophenylhydrazine (DNPH). • SVOCs: Samples were collected on an apparatus called a sample train.

3.4.2. VOCs Analyzed
The Team selected the 20 potential tire-related VOCs for analyses based on information 4-169
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from literature review, described in Appendix A. Data obtained in the controlled emission chamber study and the direct thermal desorption measurements of crumb rubber discussed above supported the selection of these chemicals. LBNL also selected 40 common VOC air pollutants including 4 low molecular weight carbonyls (additional discussion on carbonyls in Section 3.4.3). The result is the Table 3-7 list of VOCs targeted for analyses.

Table 3-7. VOCs Targeted in the Analyses of Air Samples from 35 Synthetic Turf Fields Targeted Chemical CASRN
Azulene 275-51-4
Benzaldehyde* 100-52-7
Benzene, 1,2,3-trimethyl- 526-73-8
Benzene, 1,2,4,5-tetramethyl- 95-93-2
Benzene, 1,2,4-trimethyl- 95-63-6
Benzene, 1,4-dichloro 106-46-7
Benzene, 1-chloro-4-
(trifluoromethyl)- 98-56-6
Benzene, 1-ethyl-2,4-dimethyl- 874-41-9
Benzene, 2-ethyl-1,4-dimethyl- 1758-88-9
Benzene, n-butyl- 104-51-8
Benzothiazole 95-16-9
Benzothiazole, 2-mercapto 149-30-4
Benzothiazole, 2-methylthio- 615-22-5
Biphenyl 92-52-4
Butanal* 123-72-8
Butylated Hydroxytoluene 128-37-0
2-Butoxyethanol 111-76-2
3-Carene 13466-78-9
Cyclohexanone 108-94-1
Cyclopentasiloxane, decamethyl- 541-02-6
Cyclotetrasiloxane, octamethyl- 556-67-2
Cyclotrisiloxane, hexamethyl- 541-05-9
Decanal 112-31-2
Decane 124-18-5
D-Limonene 5989-27-5
Dodecane 112-40-3
Ethylbenzene 100-41-4
2-Ethyl-1-Hexanol 104-76-7
Formamide, N-(1,1-dimethylethyl)- 2425-74-3
Targeted Chemical CASRN
Furan, 2-methyl 534-22-5
Heptanal 111-71-7
Heptane 142-82-5
Hexanal* 66-25-1
Indan 496-11-7
m/p-Xylene 106-42-3
Mesitylene 108-67-8
Methacrolein* 78-85-3
Methyl Isobutyl Ketone 108-10-1
Naphthalene 91-20-3
Nonanal 124-19-6
Octanal 124-13-0
Octane 111-65-9
o-Xylene 95-47-6
p-Cymene 99-87-6
Phenol 108-95-2
a-Pinene 7785-70-8
Styrene 100-42-5
g-Terpinene 99-85-4
a-Terpineol 98-55-5
Tetrachloroethylene 127-18-4
Tetradecane 629-59-4
Texanol, TXIB (mono-isomer) 25265-77-4
Toluene 108-88-3
Trichloroethylene 79-01-6
Trichloromethane 67-66-3
TXIB "Kodaflex" 6846-50-0
Undecane 1120-21-4
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The VOCs for analysis were collected in sorbent tube samples at each of the 35 selected fields. Upon arrival at the laboratory after shipping, LBNL analyzed the sorbent tube samples for VOCs by a GC-MS system—equipped with a ThermoDesorption (TD) injection system comprised of the following:
• a TD Autosampler (Model TDSA2; Gerstel),
• a TD oven (Model TDS3, Gerstel),
• a cryogenically cooled injection system (Model CIS4; Gerstel) and • a GC (Series 6890 Plus; Agilent Technologies) connected to an electron impact MS (Series 5973; Agilent Technologies)—operated in total ion current mode with target and qualifier ions specified for each targeted chemical.

LBNL quantified the response for each analyte (normalized to response of the internal standard) using multipoint calibrations prepared from high purity reference standards.

Details on the analysis and instrumentation are provided in Appendix Section D.2.1.

OEHHA used the data from the stratified VOC samples (Section 2.2.2) to evaluate whether chemicals were field related but did not employ the data to assess exposure levels for the purpose of estimating risk, since the sampling and analyses described in the paragraphs above are more accurate and better suited for that purpose.

Established procedures (USEPA, 2016) were used to determine MDL and LOQ for each VOC analyzed. The MDL value was selected to be the higher value between the MDL derived from the blank samples (MDLb) and MDL derived from the spike sample (MDLs).

For VOCs and carbonyls, we used the analytical data of the travel blanks and low-level sample spikes. Appendix Section D.3.6.1.1 details the determination of limits of detection for analyses of the VOC air samples collected.

3.4.3. Low Molecular Weight Carbonyls
LBNL also analyzed 13 carbonyls (aldehydes and ketones) that are common air pollutants, shown in Table 3-8. The samples for this analysis were captured in 2,4- DNPH cartridges. Four of these chemicals were also analyzed in the VOC sample (sorbent tube), described above (Section 3.4.2).

Table 3-8. Aldehydes and Ketones Targeted in the Analyses of Air Samples (ALD cartridges) from 35 Selected Synthetic Turf
Targeted Chemical CASRN
Acetaldehyde 75-07-0
Acetone 67-64-1
Acrolein 107-02-8
Benzaldehyde* 100-52-7
Butanal* 123-72-8
2-Butanone 78-93-3
Crotonaldehyde 123-73-9
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Targeted Chemical CASRN
Formaldehyde 50-00-0
Hexanal* 66-25-1
Methacrolein* 78-85-3
Propionaldehyde 123-38-6
m-Tolualdehyde 620-23-5
Valeraldehyde 110-62-3
* Also analyzed in the VOC sample (sorbent tube)
The Laboratory analyzed the samples for the targeted carbonyls by HPLC (1200 Series; Agilent Technologies) connected to an ultraviolet detector. LBNL quantified the targeted carbonyls by using multipoint calibration curves for the certified standard the hydrazone derivatives (CRM47651: Sigma-Aldrich). Appendix Section D.2.2 provides the details on the instrumentation and how the analysis was performed.

For a discussion of limits of detection, see Appendix Section D.3.6.1.3.

3.4.4. SVOCs analyzed (SVOC sample trains)
The Team compiled a list of 70 SVOCs detected in organic solvent extractions of crumb rubber designed to identify crumb rubber chemicals for the analysis in the study (see Section 3.2.1). These chemicals were the SVOCs targeted in the analyses of extracts from the SVOC sample trains. Table 3-9 lists the SVOCs analyzed.

Table 3-9. SVOCs Targeted in the Analyses of Air Samples from the 35 Selected Synthetic Turf Fields
Chemical CASRN
Acenaphthylene 208-96-8
Aniline 62-53-3
Anthracene 120-12-7
Anthracene, 2-methyl- 613-12-7
Anthracene, 9,10-dimethyl 781-43-1
Anthracene, 9,10-diphenyl- 1499-10-1
Anthracene, 9-phenyl 602-55-1
Benz[a]anthracene 56-55-3
Benzo[a]pyrene 50-32-8
Benzo[b]fluoranthene 205-99-2
7H-Benzo[c]fluorene 205-12-9
Benzo[e]pyrene 192-97-2
Benzo[g,h,i]perylene 191-24-2
Benzo[k]fluoranthene 207-08-9
Benzothiazole, 2-phenyl- 883-93-2
2-Benzothiazolone 934-34-9
Benzyl butyl phthalate 85-68-7
2,5-Bis(1,1-dimethylethyl)-1,4-
benzenediol 88-58-4
Bis(2,2,6,6-tetramethyl-4-
piperidyl)sebacate 52829-07-9
Bis(2-Ethylhexyl)adipate 103-23-1
Chemical CASRN
n-Caproic acid vinyl ester 3050-69-9
Chrysene 218-01-9
Coronene 191-07-1
Cyclohexanamine, N-cyclohexyl- 101-83-7
Cyclohexylamine 108-91-8
Cyclopenta[cd]pyrene 27208-37-3
Cyclohexyl isothiocyanate 1122-82-3
Demecolcine 477-30-5
Dibenz[a,h]anthracene 53-70-3
Dibenzothiophene 132-65-0
Dibutyl phthalate 84-74-2
Diethyl Phthalate 84-66-2
Diisobutyl Phthalate 84-69-5
Diisooctylphthalate 27554-26-3
N-(1,3-Dimethylbutyl)-N'-phenyl-1,4-
benzenediamine 793-24-8
Dimethyl phthalate 131-11-3
Di-n-octyl phthalate 117-84-0
N,N'-diphenyl-1,4-benzenediamine 74-31-7
2,5-di-tert-Butyl-1,4-benzoquinone 2460-77-7
3,5-di-tert-Butyl-4-
hydroxybenzaldehyde 1620-98-0
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Chemical CASRN
Fluoranthene 206-44-0
Fluorene 86-73-7
Hexadecane 544-76-3
2,5-Hexanedione 110-13-4
1-Hydroxypyrene 5315-79-7
Indeno[1,2,3-cd]pyrene 193-39-5
Limonene 138-86-3
Methyl stearate 112-61-8
Naphthalene, 1,2-dimethyl- 573-98-8
Naphthalene, 1,6-dimethyl- 575-43-9
Naphthalene, 1-methyl- 90-12-0
Naphthalene, 2-(bromomethyl)- 939-26-4
N,N-Dicyclohexylmethylamine 7560-83-0
Naphthalene, 2,3-dimethyl- 581-40-8
Naphthalene, 2-methyl 91-57-6
1-Octadecene 112-88-9
Chemical CASRN
4-tert-Octylphenol 140-66-9
17-Pentatriacontene 6971-40-0
N-Phenylbenzamide 93-98-1
Phenanthrene 85-01-8
Phenanthrene, 1-methyl 832-69-9
Phenanthrene, 2-methyl- 2531-84-2
Phenanthrene, 3-methyl 832-71-3
Phenol, 2,4-bis(1-methyl-1-
phenylethyl)- 2772-45-4
Phenol, 4-(1-phenylethyl)- 1988-89-2
Pyrene 129-00-0
Phthalimide 85-41-6
Pyridine, 2-(4-methylphenyl)- 4467-06-5
Resorcinol 108-46-3
5,9-Undecadien-2-one, 6,10-
dimethyl- 689-67-8
To analyze the samples, LBNL first followed the procedures for SVOC sample extraction and preparation (Appendix Section D.4.1.2). An accelerated solvent extraction system and two solvent systems were used—PUF filters were extracted with 1:1 hexane and acetone, while the GF filters and XAD® were extracted with dichloromethane—under elevated temperature and pressure. LBNL analyzed the extracts using a HES-GC-MS system (Series 7890 Plus; Agilent Technologies) fitted with a programmed temperature vaporizer inlet (Model CIS4; Gerstel), a septum-less sampling head. The injection system contained a deactivated glass wool injection liner (P/N 23432; Restek) connected to a 30 meter by 0.25-mm diameter DB-UI8270D column with 2.5 micron film thickness (P/N 122-9732, Agilent) (Appendix Section D.2.4).

Established procedures (USEPA, 2016) were used to determine MDL and LOQ for each SVOC. The MDL value for each chemical was selected to be the higher value between the MDL derived from the blank samples (MDLb) and MDL derived from the spike sample (MDLs). Due to high background levels of SVOCs in the PUF filters of the sample trains, the MDLb would have been higher than the MDLs for the SVOCs. LBNL therefore used analytical data of the travel blanks to determine the MDL of SVOCs.

Appendix Section D.3.6.1.2 details the determination of limits of detection for analyses of the SVOCs.

3.4.5. Particle Monitoring
The Team collected continuous particle data in air on and off the fields during the statewide field work (Phase 3). Instrument setups are described in Appendix Section D.1.2.5. These environmental particle monitoring data include:
• size resolved particle number concentration, size resolved particle mass distribution,
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• particulate matter sizes of or less than 2.5 micrometer in diameter (PM2.5) mass concentration profiles,
• particle number concentrations (0.4 to 0.5 micrometer in diameter and 1 to 2.5 micrometer in diameter) at three different heights (18, 35 and 60 inches), • particle number concentration for particle sizes 0.3, 0.4, 0.5, 0.7, 1, and 2.5 micrometer in diameters,
Overall, the results showed no difference in particle concentrations, particle size distribution between inactive field condition and active field condition, as well as between on-field and off-field locations for the 35 fields. Details of the particle data were presented in the 2018 SAP Meeting (OEHHA, 2018).

3.4.6. Results of Analyses of Air Samples
As provided in more detail in Section 2.3.2.3, the Team collected air samples as follows:
• a set of five hourly sequential VOC vapor integrated samples, at two locations on-field (Figure 2-1), one location off-field. This covered the first and fifth hour when conditions were static and the second, third, and fourth hours when there were vigorous on-field soccer drills.
• a three-hour ALD vapor integrated sample, at two locations on-field, under active field conditions.
• a three-hour high-volume SVOC integrated sample at one location on-field, under active field conditions, and one location off-field.

OEHHA followed the procedure in Appendix Section D.3.6 to validate the analytical data and calculated the chemicals in the air at on- or off-field locations of each field.

Table 3-10 summarizes the results for average air concentrations of the chemicals detected for the statewide field samples (Phase 3 Field Work). The results presented are based on the average air concentrations for the three-hour period under active field conditions. The tabulated mean is the arithmetic mean of the individual field average concentrations. The minimum and maximum values are also included in the table.

These values were used to estimate to estimate average daily dose of the chemical via inhalation exposure on the fields in Chapter 5.

Unexpected incidents occurring during the Phase 3 Field Work included instrument failure, insufficient power supply at the field, power failure during sample collection, and loss of samples during shipment. This resulted in one or two fields having fewer samples than planned, with the exception of VOC vapor for which samples for all 35 fields were available. In reporting “detection frequency” in Table 3-10 the number of fields for which air samples for that chemical are available for analysis is given in parenthesis.
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Table 3-10. Average Concentrations of Chemicals Detected in Air at the 35 Synthetic Turf Fields in Californiaa
Chemical CASRN
On-Field Off-Field
Detection
Concentration
nanograms per cubic meter Detection
Concentration
nanograms per cubic meter
Min Mean Max Min Mean Max
1,4-Benzenediamine, N-
(1,3-dimethylbutyl)-N'-
phenyl793-24-8 26 (34) 0 3.7 15 19 (33) 0 4.2 16
17-Pentatriacontene 6971-40-0 2 (34) 0 0.73 17 1 (33) 0 0.5 17 1-Hexanol, 2-ethyl- 104-76-7 6 (35) 0 7.8 91 7 (34) 0 18 230 1-Octadecene 112-88-9 16 (34) 0 4.4 18 14 (33) 0 4.1 19 2,5-di-tert-Butyl-1,4-
benzoquinone 2460-77-7 26 (34) 0 32 140 26 (33) 0 39 310 2,5-Hexanedione 110-13-4 5 (34) 0 27 260 3 (33) 0 35 640 2-Benzothiazolone 934-34-9 5 (34) 0 4.6 45 3 (33) 0 4.1 45 2-Butanone 78-93-3 30 (34) 0 570 1400 - - - -
2-Butoxyethanol 111-76-2 1 (35) 0 4.9 170 1 (34) 0 4.7 160 3,5-di-tert-Butyl-4-
hydroxybenzaldehyde 1620-98-0 8 (34) 0 17 110 3 (33) 0 11 190 3-Carene 13466-78-9 1 (35) 0 0.77 27 1 (34) 0 1.6 54
4-tert-Octylphenol 140-66-9 10 (34) 0 1.8 14 7 (33) 0 0.53 5.8 5,9-Undecadien-2-one,
6,10-dimethyl- 689-67-8 14 (34) 0 3.8 19 13 (33) 0 2.7 15 7H-Benzo[c]fluorene 205-12-9 13 (34) 0 0.054 0.36 6 (33) 0 0.031 0.33 Acenaphthylene 208-96-8 11 (34) 0 1 8.7 8 (33) 0 1.1 9.4 Acetaldehyde 75-07-0 34 (34) 260 2500 9600 - - - -
Acetone 67-64-1 34 (34) 1600 20000 69000 - - -
Aniline 62-53-3 10 (34) 0 6.5 44 8 (33) 0 7.2 60
Anthracene 120-12-7 12 (34) 0 0.33 2.4 4 (33) 0 0.2 2.8 Anthracene, 2-methyl- 613-12-7 15 (34) 0 0.085 0.42 11 (33) 0 0.052 0.37 Anthracene, 9,10-dimethyl 781-43-1 16 (34) 0 0.097 0.94 12 (33) 0 0.084 0.67 Anthracene, 9-phenyl 602-55-1 1 (34) 0 0.009 0.31 2 (33) 0 0.037 0.61 a-Pinene 7785-70-8 12 (35) 0 37 380 9 (34) 0 46 450
Benz[a]anthracene 56-55-3 1 (34) 0 0.0049 0.17 0 (33) 0 0 0 Benzaldehyde 100-52-7 15 (35) 0 89 540 14 (34) 0 97 580 Benzene 71-43-2 35 (35) 90 600 2500 34 (34) 180 640 2700 Benzene, 1,2,3-trimethyl- 526-73-8 6 (35) 0 13 210 6 (34) 0 17 160 Benzene, 1,2,4,5-
tetramethyl- 95-93-2 5 (35) 0 2.5 27 5 (34) 0 3.2 41
Benzene, 1,2,4-trimethyl- 95-63-6 13 (35) 0 120 970 12 (34) 0 130 890 Benzene, 1,4-dichloro 106-46-7 7 (35) 0 19 120 6 (34) 0 17 120 Benzene, 1-chloro-4-
(trifluoromethyl)- 98-56-6 34 (35) 0 570 2100 33 (34) 0 580 2000 Benzene, 1-ethyl-2,4-
dimethyl- 874-41-9 7 (35) 0 5.3 71 7 (34) 0 6 52
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Chemical CASRN
On-Field Off-Field
Detection
Concentration
nanograms per cubic meter Detection
Concentration
nanograms per cubic meter
Min Mean Max Min Mean Max
Benzene, 2-ethyl-1,4-
dimethyl- 1758-88-9 12 (35) 0 7.5 68 11 (34) 0 8.4 77
Benzene, butyl- 104-51-8 2 (35) 0 2.6 73 3 (34) 0 4.3 73 Benzo[a]pyrene 50-32-8 28 (34) 0 1.1 4.7 24 (33) 0 1.4 9.9 Benzo[b]fluoranthene 205-99-2 2 (34) 0 0.025 0.42 3 (33) 0 0.038 0.42 Benzo[e]pyrene 192-97-2 6 (34) 0 0.019 0.13 6 (33) 0 0.027 0.26 Benzo[g,h,i]perylene 191-24-2 19 (34) 0 0.13 0.76 16 (33) 0 0.13 0.99 Benzo[k]fluoranthene 207-08-9 4 (34) 0 0.031 0.35 3 (33) 0 0.032 0.35 Benzothiazole 95-16-9 19 (35) 0 37 120 2 (34) 0 4.8 82
Benzothiazole, 2-phenyl- 883-93-2 27 (34) 0 2.9 17 15 (33) 0 0.43 1.8 Benzyl butyl phthalate 85-68-7 7 (34) 0 3.4 23 5 (33) 0 4.4 51 Bis(2-Ethylhexyl)adipate 103-23-1 1 (34) 0 22 730 2 (33) 0 17 280 Butanal 123-72-8 13 (35) 0 310 3800 12 (34) 0 280 3400
Chrysene 218-01-9 13 (34) 0 0.2 1.3 7 (33) 0 0.1 0.93
Coronene 191-07-1 10 (34) 0 0.085 0.73 7 (33) 0 0.068 0.7 Cyclohexanamine, Ncyclohexyl- 101-83-7 19 (34) 0 0.34 3.1 10 (33) 0 0.2 1.2 Cyclohexylamine 108-91-8 4 (34) 0 2.3 31 1 (33) 0 0.94 31 Cyclopenta[cd]pyrene 27208-37-3 28 (34) 0 0.073 0.41 22 (33) 0 0.064 0.26 Cyclopentasiloxane,
decamethyl- 541-02-6 18 (35) 0 160 1300 14 (34) 0 150 1200 Cyclotetrasiloxane,
octamethyl- 556-67-2 13 (35) 0 58 330 13 (34) 0 52 320
Cyclotrisiloxane,
hexamethyl- 541-05-9 1 (35) 0 73 2600 3 (34) 0 77 1600
Decanal 112-31-2 7 (35) 0 28 550 1 (34) 0 17 580
Decane 124-18-5 11 (35) 0 54 310 12 (34) 0 60 350
Dibenz[a,h]anthracene 53-70-3 14 (34) 0 0.14 1.2 9 (33) 0 0.09 0.73 Dibenzothiophene 132-65-0 14 (34) 0 1.2 6.8 12 (33) 0 1.2 8.5 Dibutyl phthalate 84-74-2 7 (34) 0 380 4900 5 (33) 0 300 5800 Diethyl phthalate 84-66-2 1 (34) 0 2.6 89 2 (33) 0 11 180 Diisobutyl phthalate 84-69-5 15 (34) 0 14 150 14 (33) 0 15 91 Diisooctylphthalate 27554-26-3 9 (34) 0 49 950 6 (33) 0 15 81 Dimethyl phthalate 131-11-3 4 (34) 0 3.6 62 3 (33) 0 3.3 60 Di-n-octyl phthalate 117-84-0 5 (34) 0 0.096 1.1 3 (33) 0 0.099 1.1 D-Limonene 5989-27-5 4 (35) 0 7.7 67 5 (34) 0 9.9 67
Dodecane 112-40-3 4 (35) 0 6.7 120 3 (34) 0 8.7 120
Ethylbenzene 100-41-4 13 (35) 0 170 1200 13 (34) 0 180 1300 Fluoranthene 206-44-0 21 (34) 0 3.8 17 14 (33) 0 2.2 19 Fluorene 86-73-7 15 (34) 0 6 61 11 (33) 0 5 53
Formaldehyde 50-00-0 34 (34) 810 3800 16000 - - - -
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Chemical CASRN
On-Field Off-Field
Detection
Concentration
nanograms per cubic meter Detection
Concentration
nanograms per cubic meter
Min Mean Max Min Mean Max
Furan, 2-methyl 534-22-5 34 (35) 0 110 410 21 (34) 0 38 270 Heptanal 111-71-7 7 (35) 0 15 130 5 (34) 0 15 130
Heptane 142-82-5 20 (35) 0 230 1500 17 (34) 0 230 1700
Hexadecane 544-76-3 11 (34) 0 32 230 9 (33) 0 46 420
Hexanal 66-25-1 30 (35) 0 790 4000 27 (34) 0 870 5800
Hexane 110-54-3 26 (35) 0 670 8700 28 (34) 0 460 2000
Indan 496-11-7 12 (35) 0 14 110 12 (34) 0 13 110
Indeno[1,2,3-cd]pyrene 193-39-5 3 (34) 0 0.11 1.2 2 (33) 0 0.074 1.2 Limonene 138-86-3 14 (34) 0 29 160 10 (33) 0 22 240
m/p-Xylene 106-42-3 25 (35) 0 580 3500 24 (34) 0 610 3400 Mesitylene 108-67-8 15 (35) 0 28 230 13 (34) 0 28 200
Methacrolein 78-85-3 20(35) 0 76 430 16(34) 70 0 400
Methyl Isobutyl Ketone 108-10-1 5 (35) 0 16 180 1 (34) 0 3.6 120 Methyl stearate 112-61-8 10 (34) 0 5.5 44 8 (33) 0 5.5 44 m-Tolualdehyde 620-23-5 19 (34) 0 270 900 - - - -
N,NDicyclohexylmethylamine 7560-83-0 18 (34) 0 0.33 2 12 (33) 0 0.35 1.8 Naphthalene 91-20-3 9 (35) 0 27 260 9 (34) 0 29 260
Naphthalene, 1,2-dimethyl- 573-98-8 4 (34) 0 0.37 3.6 6 (33) 0 0.78 7.6 Naphthalene, 1,6-dimethyl- 575-43-9 14 (34) 0 2.7 15 12 (33) 0 2.8 20 Naphthalene, 1-methyl- 90-12-0 15 (34) 0 22 150 12 (33) 0 22 120 Naphthalene, 2-
(bromomethyl)- 939-26-4 11 (34) 0 0.74 2.5 8 (33) 0 0.77 7.8 Naphthalene, 2,3-dimethyl- 581-40-8 14 (34) 0 2 10 12 (33) 0 2.1 15 Naphthalene, 2-methyl- 91-57-6 10 (34) 0 33 320 12 (33) 0 35 190 n-Caproic acid vinyl ester 3050-69-9 1 (34) 0 6.8 230 3 (33) 0 13 300 Nonanal 124-19-6 2 (35) 0 7.8 140 0 (34) 0 0 0
N-Phenylbenzamide 93-98-1 6 (34) 0 9 55 4 (33) 0 8.9 130 Octanal 124-13-0 24 (35) 0 45 210 16 (34) 0 44 240
Octane 111-65-9 10 (35) 0 60 420 9 (34) 0 73 480
o-Xylene 95-47-6 13 (35) 0 190 1300 11 (34) 0 190 1400
p-Cymene 99-87-6 21 (35) 0 25 120 18 (34) 0 26 120
Phenanthrene 85-01-8 17 (34) 0 13 84 12 (33) 0 11 92
Phenanthrene, 1-methyl 832-69-9 17 (34) 0 0.82 3.4 13 (33) 0 0.49 3.4 Phenanthrene, 2-methyl- 2531-84-2 18 (34) 0 1.5 6.3 13 (33) 0 0.96 6.3 Phenanthrene, 3-methyl 832-71-3 18 (34) 0 1.8 7.5 13 (33) 0 1.1 7.7 Phenol 108-95-2 18 (35) 0 58 210 12 (34) 0 53 210
Phenol, 2,4-bis(1-methyl-1-
phenylethyl)- 2772-45-4 2 (34) 0 0.018 0.3 0 (33) 0 0 0 Phenol, 4-(1-phenylethyl)- 1988-89-2 9 (34) 0 0.44 6.3 9 (33) 0 0.64 7 4-177
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Chemical CASRN
On-Field Off-Field
Detection
Concentration
nanograms per cubic meter Detection
Concentration
nanograms per cubic meter
Min Mean Max Min Mean Max
Propionaldehyde 123-38-6 12 (34) 0 180 1800 - - - -
Pyrene 129-00-0 20 (34) 0 3.2 14 14 (33) 0 1.6 10
Pyridine, 2-(4-
methylphenyl)- 4467-06-5 2 (34) 0 0.035 1 1 (33) 0 0.0054 0.18 Resorcinol 108-46-3 18 (34) 0 19 120 18 (33) 0 32 260
Styrene 100-42-5 17 (35) 0 59 660 13 (34) 0 60 670
Tetrachloroethylene 127-18-4 7 (35) 0 48 420 7 (34) 0 49 420 Tetradecane 629-59-4 3 (35) 0 8.1 140 2 (34) 0 6.3 140
Texanol, TXIB (monoisomer) 25265-77-4 15 (35) 0 100 1600 11 (34) 0 100 2300 Toluene 108-88-3 35 (35) 200 1400 7700 34 (34) 200 1400 7100 Trichloroethylene 79-01-6 12 (35) 0 9.7 94 11 (34) 0 9.8 84 Trichloromethane 67-66-3 10 (35) 0 38 350 7 (34) 0 37 230 TXIB "Kodaflex" 6846-50-0 1 (35) 0 2 69 2 (34) 0 4.1 69 Undecane 1120-21-4 5 (35) 0 13 130 7 (34) 0 18 160
Valeraldehyde 110-62-3 11 (34) 0 930 4600 - - - -
a On-field and off-field: See Appendix Section D.4.2.3 additional statistics on measurements.

Detection: Number of fields with concentrations above method detection limit. Value in parenthesis: total number of fields tested.

Mean: Arithmetic mean of the individual fields average concentrations. Min: minimum of the individual field average concentrations; Max: maximum of the individual field average concentrations; 0: A value of 0 means the chemical is not detected or is detected below the method detection limit.

Overall, the study detected at on-field locations, 119 chemicals with levels at or above MDLs:
• 46 VOCs - out of 55 targeted,
• 11 carbonyls (9 aldehydes and 2 ketones) – out of 13 targeted, and • 62 SVOCs – out of 70 targeted
The 11 carbonyls were detected in the ALD samples with HPLC, and four of these were also detected in the GC-MS analysis of VOCs:
• benzaldehyde (CASRN 100-52-7);
• butanal (CASRN 123-72-8);
• hexanal (CASRN 66-25-1); and
• methacrolein (CASRN 78-85-3).

For these four chemicals OEHHA chose the VOC/GC-MS results over the ALD/HPLC results to calculate the air concentrations because they provided more spatial and temporal information. The VOC samples were taken from two on- and one off-field locations in five hourly consecutive samples per location whereas the ALD sample was taken at one on-field location over a three-hour period. 4-178
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For the off-field locations, 109 chemicals were detected in the air samples with levels at or above MDLs:
• 45 VOCs – out of 55 targeted
• 4 carbonyls (4 aldehydes) – out of 13 targeted, and
• 60 SVOCs – out of 70 targeted
Several chemicals previously reported as related to tires were detected in the air at onfield locations more frequently and at levels several times higher than off-field:
benzothiazole, methyl isobutyl ketone, and 2-methyl furan. This indicates that synthetic turf field was probably the source of these chemicals.
18 chemicals were not detected in air samples collected at locations either on or off the field:
• Acrolein (CASRN 107-02-8)
• Azulene (CASRN 275-51-4)
• Biphenyl (CAS: 92-52-4)
• 2,5-bis(1,1-Dimethylethyl)1,4-benzenediol (CASRN 88-58-4) • Bis(2,2,6,6-tetramethyl-4-piperidyl)sebacate (CASRN 52829-07-9) • Butylated hydroxytoluene (CASRN 128-37-0)
• Crotonaldehyde (CASRN 123-73-9)
• Cyclohexanone (CASRN 108-94-1)
• Demecolcine (CASRN 477-30-5)
• N,N'-Diphenyl 1,4-benzenediamine (CASRN 74-31-7)
• 9,10-Diphenylanthracene (CASRN 1499-10-1)
• N-(1,1-Dimethylethyl)formamide (CASRN 2425-74-3)
• 1-Hydroxypyrene (CASRN 5315-79-7)
• 5-Methyl 2-hexanone (CASRN 110-12-3)
• 2-Methylthiobenzothiazole (CASRN 615-22-5)
• 2-Mercaptobenzothiazole (CASRN 149-30-4)
• gamma-Terpinene (CASRN 99-85-4)
• alpha-Terpineol (CASRN 98-55-5)
Three chemicals were present only in air at on-field locations, but each only on one or two fields:
• benz[a]anthracene (CASRN 56-55-3, detected 1/34),
• nonanal (CASRN 124-19-6, detected 2/35), and
• 2,4-bis(1-methyl-1-phenylethyl)-phenol (CASRN 2772-45-4, detected 2/34).

This may imply synthetic turf field as a source of these chemicals. However, the low detection frequency introduces some uncertainty.

Thirty PAHs and PAH derivatives were detected in both the on- and off-field SVOC or VOC samples. Benz[a]anthracene was the only PAH that was detected on-field and not in an off-field SVOC sample, and the on-field detection was for only one field. Fourteen 4-179
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of the 30 PAHs measured had slightly elevated mean concentrations for on-field SVOC samples compared to off-field samples, and 25 were detected more frequently on-field compared to off-field, while 16 PAHs had the same or lower mean concentrations onfield compared to off-field. Taken together, these observations might suggest environmental sources besides synthetic turf may also contribute to the on-field levels of PAHs measured.

However, the off-field sample locations were in relatively close proximity to the on-field sample locations, and wind direction changed over time, so off-field samples were not always upwind of the field. Thus, the off-field samples may also be considered to represent a “near field” exposure with ultimately some of the exposure emanating from the crumb rubber in the synthetic turf field. For these reasons, the off-field samples are not considered to represent a true background that could be used to distinguish fieldrelated chemicals from other environmental sources such as industrial facilities and motor vehicles.

3.5. Distinguishing Field-Related Chemicals from Non-Field Related Chemicals This section discusses our approach to identifying the chemicals detected as synthetic field related, or non-field related and assumed to come from other environmental sources like traffic.

3.5.1. Chemicals Detected in Biofluid Extracts and SVOCs in Air Samples The targeted chemical lists for the analysis of the biofluid and metal crumb rubber extracts and the SVOC air samples were developed from non-targeted analyses of solvent or acid extractions of crumb rubber itself. We attribute the concentrations measured in the statewide field sampling (Phase 3) to synthetic turf, and not to other environmental sources like industrial facilities and traffic.

3.5.2. VOCs in Air Samples
On the sampling tower located behind the monitoring unit on each field, we collected four VOC samples at four different vertical levels – at 0.1, 0.5, 1.07 and 1.63 meters above the field surface. We call these the stratified VOC samples. For details on the instrumentation and sample collection protocols, see Section 2.2.2, and Appendix Sections D.1.2.5 and D.2.1.
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0 250
500
750
1000
1250

0.1 0.4 0.7 1 1.3 1.6
Concentration,
nanograom per cubic meter air
Height, meter
(b) Methyl Isobutyl Ketone
The stratified samples enabled us to examine the vertical concentration profile of VOCs in the air (Figure 3-2). We used these to distinguish field related VOCs from non-field related VOCs. For field-related VOCs, we expect the air concentrations to be highest closer to the field surface. As the VOCs are released from the crumb in the synthetic turf they enter the air and become less concentrated as they rise from the surface and mix with increasing volumes of air with increasing height.

Figure 3-2. Vertical Concentrations of Selected VOCs for 35 Synthetic Turf Fields in California.

Field-Related: (a) Benzothiazole and (b) Methyl Isobutyl Ketone Non-Field Related: (c) Benzene and (d) Toluene
OEHHA used the chemical concentration data from analysis of stratified VOC samples 0 250
500
750
1000
1250

0.1 0.4 0.7 1 1.3 1.6
Concentration,
nanograom per cubic meter air
Height, meter
(a) Benzothiazole
0 1000
2000
3000

0.1 0.4 0.7 1 1.3 1.6
Concentration,
nanograom per cubic meter air
Height, meter
(c) Benzene
0 1000
2000
3000
4000
5000

0.1 0.4 0.7 1 1.3 1.6
Concentration,
nanograom per cubic meter air
Height, meter
(d) Toluene
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to examine the vertical concentration profile of the 50 VOCs. Through statistical analyses we evaluated whether higher concentrations were detected at lower sampling positions, closer to field surface.

Briefly, we employed a linear mixed-effect model to analyze the air concentrations of each VOC in the tower samples using RStudio version 3.6.0 (RStudio Team, 2018) equipped with the lme4 package (Bates et al., 2015). VOCs with concentrations that significantly decreased from low to high positions on the sampling tower (i.e., an inverted concentration gradient) were determined to be field related, with the synthetic field as the predominant source. A statistical significance level of p <0.05 for the linear mixed-effect model with position number ANOVA was used, VOCs lacking this inverted concentration gradient were determined to be non-field related chemicals. Details of the analysis and the results for the 50 chemicals are provided in Appendix Section D.4.3.

Based on results of the statistical analysis, OEHHA designated 29 VOCs as field-related (see List 3-1, for simplicity, we assumed synthetic turf fields as the sources of these chemicals in air on or off the fields):

List 3-1: Field-Related VOCs
3-Carene
alpha-Pinene
Benzaldehyde
Benzene, 1,2,3-trimethylBenzene, 1,2,4,5-tetramethylBenzene, 1,2,4-trimethylBenzene, 1-ethyl-2,4-dimethylBenzene, 2-ethyl-1,4-dimethylBenzene, butylBenzothiazole Butanal
Cyclopentasiloxane, decamethylCyclotetrasiloxane, octamethylDecane D-Limonene
Dodecane
Furan, 2-methyl
Heptanal
Indan
Mesitylene
Methacrolein
Methyl Isobutyl Ketone
Naphthalene
Octanal
Octane
p-Cymene
Styrene
TXIB "Kodaflex"
Undecane
Twenty-one VOCs were determined to be non-field-related (see List 3-2, assumed environmental or other sources of these chemicals detected in air on or off fields):

List 3-2: Non-Field-Related VOCs
1-Hexanol, 2-ethyl2-Butoxyethanol
Benzene
Benzene, 1,4-dichloro
Benzene, 1-chloro-4-(trifluoromethyl)-
Cyclotrisiloxane, hexamethylDecanal
Ethylbenzene
Heptane
Hexanal
Hexane
m/p-Xylene
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Nonanal
o-Xylene
Phenol
Tetrachloroethylene
Tetradecane
Texanol, TXIB (mono-isomer)
Toluene
Trichloroethylene
Trichloromethane
For each of the field-related VOCs, we cannot determine with reasonable confidence the amounts contributed from environmental sources versus those from field-related sources. Recent studies provide evidence of the presence of tire-related chemicals in the environment (Johannessen et al., 2022; Tian et al., 2021).

3.5.3. Low Molecular Weight Carbonyls
Thirteen carbonyls were analyzed in 2,4-DNPH cartridge sampling of the statewide fields (Phase 3).

Non-Detected Carbonyls. Two aldehydes, acrolein and crotonaldehyde, were not detected in any field samples and a determination of whether these chemicals are field related is therefore unnecessary.

Carbonyls also analyzed in VOC stratified samples. Four aldehydes were analyzed in tower samples. Based on the linear mixed-effects model analysis of the tower data discussed above, OEHHA designated benzaldehyde, butanal, and methacrolein as field-related chemicals, and hexanal as non-field related (see discussion Section 3.5.2).

Other carbonyls analyzed in 2,4-DNPH cartridge samples. South Coast Air Quality Management District (South Coast AQMD) monitored seven of the carbonyls in its Multiple Air Toxics Exposure Study (MATES). The data collected are robust and can be used as a point of comparison with concentration data from our study collected from fields in the District to inform whether the carbonyls should be treated as field-related or non-field related.

The South Coast AQMD has been monitoring environmental levels of air toxics for more than three decades. Their latest MATES study, MATES V (South Coast AQMD, 2021a; South Coast AQMD, 2021b), included monitoring of the following seven carbonyls that are included in this study: 2-butanone; acetaldehyde, acetone, acrolein, benzaldehyde, formaldehyde, and propionaldehyde. Benzaldehyde was designated as a field-related chemical based on statistical analysis of results from the tower samples. Acrolein was not detected in our study.

MATES V used 24-hour integrated samples that were collected once every 6 days for 1 year from May 1, 2018, to April 30, 2019, at 10 fixed air sampling stations covering the Greater Los Angeles Area. Seven air stations collected carbonyl samples from the air using DNPH cartridges and analyzed the samples with HPLC. The carbonyls monitoring data from MATES V can be used to characterize background exposures for the six carbonyls detected in our study based on the following considerations:
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• MATES V applied the same carbonyl sampling and analytical methods as our study.
• MATES V is a comprehensive environmental monitoring study. The program has a long history of collecting periodic monitoring data of air toxics in the air within the district. Seven of the ten fixed air sampling stations provided validated and continual monitoring data of the carbonyls in air for a whole year. • MATES covered similar geographical area as the Climate Region 1 and the southern part of the Climate Region 3 of our study. OEHHA detected higher levels of carbonyls in ALD samples collected from fields located in these areas compared to the other Climate Regions. In fact, the four highest concentrations (six percent of total number of samples) for each of the four carbonyls (2- butanone, acetaldehyde, formaldehyde, and propionaldehyde) were collected from fields located within the MATES V monitored area.
• MATES V monitoring occurred between mid-2018 and mid-2019, while our field sample collections were performed August to December 2017 for Climate Region 1, which is in the MATES region. Considering the close time proximity between the sampling periods, the air monitoring data from MATES V provided suitable data to understand the ambient levels of carbonyls in the air for our study.

OEHHA compared the measured air concentrations for six carbonyls (in the ALD samples collected in the Climate Region 1 of our study to the monitoring data collected in MATES V (Table 3-11). Based on the regional mean concentrations and maximum concentrations of each carbonyl in the OEHHA study and MATES V for each carbonyl, we identified acetone, benzaldehyde, and propionaldehyde as field-related chemicals, but designated 2-butanone, acetaldehyde, and formaldehyde as non-field-related (details in Table 3-11). The MATES data support the determination of benzaldehyde as a field related chemical based on the tower samples in our study discussed above.

Table 3-11. Concentrations of Six Selected Carbonyls Detected in Climate Region 1 of the Synthetic Turf Study versus MATES V
Chemical
Concentration (nanograms per cubic meter)
mean (maximum) FieldRelated? Rationale
Turf Studya MATES Vb
Acetone 19000 (62000) 5300 (39000) Yes Turf mean and maximum are higher Propionaldehyde 390 (3600) 410 (1500) Yes
Turf mean similar to MATES V mean
but Turf maximum is 2 X higher than

MATES V
2-Butanone 750 (1400) 570 (3600) No turf mean slightly higher than MATES V, Turf maximum lower than MATES
Acetaldehyde 2700 (5100) 2600 (13000) No
Turf mean similar to MATES V mean
but Turf maximum is lower than

MATES V
Benzaldehydec 730 (4600) 260 (2500) Yes Turf mean and maximum concentrations higher than MATES V.
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Chemical
Concentration (nanograms per cubic meter)
mean (maximum) FieldRelated? Rationale
Turf Studya MATES Vb
Formaldehyde 3900 (6600) 3600 (57000) No
Turf mean similar to MATES V mean,
but turf maximum is lower than
MATES maximum. a Mean concentration of individual field average concentrations of the chemical detected in ALD samples collected in climate region 1 of the OEHHA Study. b Mean concentration of a carbonyl is the mean of the 7 individual station average concentrations of the chemical (Table IV-6 in Appendix IV SCAQMD, 2021). Concentration (ng per cubic meter) = molecular weight of a carbonyl (g per mole) × concentration (part per billion) ÷ 24.45 cubic meters per mole × 1000 ng per µg.
c Benzaldehyde is also designated as field-related based statistical analysis of vertical concentration profile (see List 3-1, and Appendix D.4.3).

To summarize 7 carbonyls were determined to be field-related (see List 3-3).

List 3-3: Field-Related Carbonyls
Acetone
Benzaldehyde
Butanal
m-Tolualdehyde
Methacrolein
Propionaldehyde
Valeraldehyde
Four ALDs were determined to be non-field related (see List 3-4).

List 3-4: Non-Field-Related Carbonyls
2-Butanone
Acetaldehyde
Formaldehyde
Hexanal

3.5.4. Field Related Chemical Determinations
As discussed above, OEHHA applied several strategies to differentiate field-related from non-field-related chemicals. All chemicals, including metals, metalloids, and organic chemicals of low volatility that were found in extracts of crumb rubber using targeted or non-targeted chemical analyses are considered to be field related. Since chemicals targeted in SVOC analysis were identified from non-targeted analyses of solvent extracts of crumb rubber, all SVOCs detected in the air are also considered field-related.

Considering environmental sources, including traffic related, for some of the VOCs and selected carbonyls, OEHHA analyzed their vertical concentration profiles to evaluate whether they should be considered field-related. Low molecular weight carbonyls (e.g., formaldehyde and acetaldehyde), from various environmental and anthropogenic sources, are commonly present in ambient air. OEHHA compared the concentrations of these carbonyls to findings from a well-established air monitoring program (MATES V) conducted by the South Coast AQMD to evaluate the field-related carbonyls in the air.

Table 3-12 summarizes these methods and results of these determinations. 4-185
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Table 3-12. Determination of Field-Related Chemical – Approach, Methods, Result Chemical Class Data Source for Determining if Field Related Field related chemical list
Metals and
Metalloids in Crumb
Rubber
Assumed to be “field-related”;
Chemicals identified from targeted analysis of
crumb rubber extracts
Table 3-5
Organic chemicals in
Crumb Rubber
Assumed to be “field-related”;
Chemicals selected for analysis from non-targeted
analysis of crumb rubber extracts
Table 3-1
VOCs in Air
Assumed to be field related if concentrations
decreased with increasing vertical height observed
for stratified on-field tower data
List 3-1 and List 3-2
Aldehydes and
Ketones in Air
• 4 chemicals: Stratified on-field tower data for 4
tested in VOC samples. (3 assumed field related).
• 6 chemicals: MATES V (3 assumed field-related)
• 2 chemicals: Assumed to be “field-related” since
no tower or MATES data available
• 2 chemicals not detected
List 3-3 and List 3-4
SVOCs in Air
Assumed to be “field-related”;
Chemicals identified from non-targeted analysis of
crumb rubber extracts
Table 3-9

3.6. Analysis of Environmental Data
Environmental data were collected on the fields during the study. These data were collected for one hour before any field activity, for three hours during field activity, and for one hour following field activity. The fields studied were distributed throughout California and placed into five climatic regions, as described in Section 2.3: Region 1:

Southern Coastal Areas; Region 2: Northern and Central Coastal Areas; Region 3:

Southern California Interior Valleys; Region 4: Southern California High and Low Deserts; and Region 5: Mountainous Area. These regions were reduced to four regions when Region 4 and Region 5 were combined into Region 4/5 because of the low number of fields in these regions. The fields were studied from June through December 2017, and divided based on age, with newer fields less than 9 years of age and older fields 9 years to about 14 years of age.

3.6.1. Temperature
Appendix sections D.1.2, D.5.2 and D.5.3 and describe the setup and collection of temperature data during sampling events. Briefly, temperature was monitored for five hours (one hour, for three hours during, and for one hour following field activity) on and off the field. Temperature data were collected at heights of 8, 24, 45, 50, and 65 inches above the field surface. Temperature probes were used to monitor the temperature of deep and shallow crumb rubber for the five-hour sampling period on and off the field.

Data were continuously collected and logged every minute at each height and then averaged over the five-hour study period for each height.

The full analysis can be found in Appendix sections D.5.2 and D.5.3. Regardless of 4-186
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location (region) and age of fields, measured air temperatures on the field generally decreased as the height of the measurement increased. Temperature over the fields generally ranged from around 70 °F to almost 100 °F, with the full range of temperatures spanning from below 40 °F to a high of almost 110 °F. No differences in the measured temperature between old and new fields could be determined.

The average surface temperature of the fields increased as the average ambient temperature above the fields increase. Average temperatures at the deep, shallow and surface levels on the fields in the four regions studied followed a similar pattern of the deeper the probe, the cooler the temperature. In general, surface temperatures were the hottest and were more than 20 degrees higher than ambient temperatures. The highest average surface temperature measured on a single field was 131 degrees Fahrenheit.

3.6.2. Ozone
Ozone occurs naturally in the stratosphere above the earth but is also formed troposphere near the ground surface from the photochemical reaction between volatile organic compounds (VOCs) and nitrogen oxides. It has been known to affect the aging and degradation of crumb rubber on synthetic turf fields. OEHHA measured ozone onand off-field with Ozone Dual Beam Monitors and sun light intensity on-field as solar energy in watts per square meter (W/m2). The dataset and results of the analysis can be found in Appendix section D.5.4. Ozone values were lowest in the morning and tended to peak around midday. Most of the measured concentrations were within the California’s ambient ozone air standard of 90 ppb for a 1-hour exposure or the California and the National ambient ozone air standard of 70 ppb for an 8-hour exposure. Only three fields exceeded the 8-hour ozone standard with the highest measured concentration at 87.0 ppb, and these were in areas of the state with higher ambient ozone concentrations.

Our data analysis show ozone levels increasing with light intensity. This suggests that the ozone concentrations measured are related to photochemical reactions to create ozone. The observed high variability in ozone values suggests there are other factors contributing to the formation of ozone, such as the levels of VOCs and oxides of nitrogen that were present in the atmosphere.

3.6.3. Particles
PM2.5 was collected on- and off-field. More details can be found in Appendix section D.5.5. Due to several samples being compromised because at least one of the three filters used on each field did not provide useable information, only PM2.5 levels from 19 fields were useable and the results of our analysis are uncertain. The calculated average on- and off-field PM2.5 concentrations, in micrograms per cubic meter of air, were 13.4 and 14.1 micrograms per cubic meter of air respectively. When the off-field filter PM2.5 weight was first subtracted from the on-field PM2.5 weight, the average 4-187
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difference seen for the 19 fields was -0.63 micrograms per cubic meter. Based on these results, OEHHA concluded that activity on the fields did not increase PM2.5 concentrations.

3.7. References
Bates D, Kliegl R, Vasishth S, et al. (2015). Parsimonious Mixed Models. arXiv 1506.

Johannessen C, Saini A, Zhang X, et al. (2022). Air monitoring of tire-derived chemicals in global megacities using passive samplers. Environmental Pollution 314: 120206.

OEHHA (2018). "OEHHA Synthetic Turf Scientific Advisory Panel Meeting Notice." from https://oehha.ca.gov/risk-assessment/events/oehha-synthetic-turf-scientific-advisorypanel-meeting-notice-0.

Place BJ, Ulrich EM, Challis JK, et al. (2021). An Introduction to the Benchmarking and Publications for Non-Targeted Analysis Working Group. Anal Chem 93(49): 16289- 16296.

RStudio Team (2018). RStudio: Integrated Development for R. Boston, MA, RStudio, Inc.

South Coast AQMD (2021a). Multiple Air Toxics Exposure Study V, MATES V: Final Appendices. Diamond Bar, CA, South Coast Air Quality Management District.

South Coast AQMD (2021b). Multiple Air Toxics Exposure Study V, MATES V: Final Report. Diamond Bar, CA, South Coast Air Quality Management District.

Telgheder U, Bader N and Alshelmani N (2018). Stir bar sorptive extraction as a sample preparation technique for chromatographic analysis: An overview. 1.

Tian Z, Zhao H, Peter KT, et al. (2021). A ubiquitous tire rubber-derived chemical induces acute mortality in coho salmon. Science 371(6525): 185-189.

USEPA (2007). SW-846 Test Method 3051A: Microwave Assisted Acid Digestion of Sediments, Sludges, Soils, and Oils. Washington, DC, U.S. Environmental Protection Agency.

USEPA (2016). Definition and Procedure for the Determination of the Method Detection Limit, Revision 2. Washington, DC, USEPA.

UWPR (2007). "LTQ-Orbitrap XL." from
https://proteomicsresource.washington.edu/instruments/ltqorbitrap.php. 4-188
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Chapter 4. Toxicity Evaluation and Criteria

4.1. Introduction
This Chapter describes how the toxicity of chemicals is evaluated in order to determine if exposure to the chemicals would result in health concerns. The toxicity criterion provide a numeric representation of toxicity, and in this chapter they are provided for most of the detected chemicals in samples of air and crumb rubber. They are presented in summary tables in this chapter. Detailed information about the values and their sources is provided in Appendix E. OEHHA applied these toxicity criteria to assess human health hazards from exposures to chemicals at synthetic turf fields for the OEHHA Synthetic Turf Study (the study).

4.1.1. What is Toxicity?
Toxicity is defined as the degree to which a chemical or mixture of chemicals can impair function or cause damage to a tissue or organ. Toxicity information for a chemical comes from the following sources:
• Human studies: Epidemiological studies of the adverse health effects (for example, in the general population or workers), case reports, and controlled human exposure studies.
• In vivo animal studies: Toxicity studies conducted in laboratory animals (for example, rat and mouse).
• In vitro studies: Toxicity studies using tissues, cells or cell components from animals or humans, as well as studies in yeast, bacteria, and plant cell cultures.

The type of toxicity, or hazard traits, associated with the exposure to a chemical, can be non-cancerous effects to specific organs such as the liver or kidneys, or to systems such as the developmental and/or reproductive systems. They may also be cancerous resulting in tumors in one or more organs, or systemic cancers such as leukemia.

The extent the toxicant causes adverse health effects depends on the chemical’s inherent toxicity and how much it is taken up into the body. Factors determining intake include:
• The concentration of the chemical in, for example, the air or crumb rubber. • The amount of chemicals absorbed into the body, for example, through inhalation of air, or through the gut for ingested crumb rubber.
• The occurrence and exposure duration, for example, acute one-hour, one-day, a few times a month, or daily for a lifetime.

For instance, a particular chemical can be a respiratory irritant after inhalation of a high concentration in the air for a few hours. The same chemical may also pose a significant cancer risk through inhalation, at much lower concentrations in the air after many years 4-189
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of exposure. Among the many possible adverse health effects a particular chemical may have, human health risk assessment typically focuses on the most sensitive health effects, which are effects that are caused at the lowest exposure levels. Protecting the public health from sensitive health effects also protects them from effects which may occur at higher levels.

4.1.2. What is a Toxicity Criterion?
A toxicity criterion (TC) is a numerical value which quantitatively characterizes the potential for a chemical to cause toxicity in humans for a specific exposure route and duration. In order to facilitate evaluation of adverse health effects posed by chemicals, toxicity criteria are developed by OEHHA, U.S. Environmental Protection Agency (USEPA) and other governmental agencies for their various programs and mandates.

The criteria are broadly grouped separately into criteria for non-cancer and cancer effects, mainly because of differences in the underlying methods to develop and apply the criteria in risk assessment.

For non-cancer effects, a toxicity criterion is the concentration in the air, intake amount, or dose, for a specified exposure route and duration, which is likely to be without an appreciable risk of deleterious effects to humans, including sensitive subgroups. The assumption is that there is a dose below which the effects are unlikely to occur. An example of a non-cancer toxicity criterion is the exposure dose which does not cause a significant reduction in bodyweight.

Non-cancer toxicity criteria are derived for different exposures routes:
• Criteria for inhalation (TCinh) exposures: These are typically expressed as concentrations in the air (e.g., parts per million in air, ppm; microgram of chemical per cubic meter of air, µg per cubic meter).
• Criteria for oral (TCoral) or dermal (TCder) exposures: These are typically expressed as doses (e.g., as milligram of chemical per kilogram of bodyweight per day, mg per kg per day).

For cancer effects, the criteria can be expressed as a cancer slope factor, or CSF. This is an estimate of increase in cancer risk per unit increase in dose. It reflects the potency of a chemical to cause cancer after a lifetime exposure. Inhalation cancer potencies are also sometimes expressed as a dose or concentration associated with a specific level of risk to the population. The typical assumption in cancer risk estimation is that any level of exposure can result in an additional risk of developing cancer above the background risk of cancer.

Estimated cancer risks ranging from one excess cancer in ten thousand people to one excess cancer in one million people are often used as a reference point in determining what is considered an acceptable exposure level to a cancer-causing chemical. For this study, a risk of one cancer in a million, above the background level of risk, is used as a 4-190
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reference point.

4.2. Toxicity Criteria Compilation
OEHHA has developed work flows to compile and select the most appropriate toxicity criterion for each detected chemical and exposure scenario for the study. A generic workflow is shown in Figure 4-1.

Figure 4-1. Generic Work Flow for Compilation of Toxicity Criteria for the Synthetic Turf Study Chemicals.

The key steps in the workflow are: (1) determine if a toxicity criterion has been established for a relevant chemical, (2) if yes, select the most appropriate value, and (3) if not, do one of three options - derive a new criterion de novo from toxicity studies, use a criterion from an analog chemical, or decline to use a value for the chemical.

Specific toxicity criteria for the following scenarios are needed:
• Inhalation exposures to organic chemicals: non-cancer effects from acute onehour, one-day, and chronic exposure durations, and cancer from lifetime exposure. These are need for chemicals detected in samples collected from the air.
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• Oral (ingestion) or dermal exposures to organic chemicals: non-cancer effects from one-day and chronic exposures and cancer from lifetime exposure. These are needed for chemicals detected in artificial gastrointestinal (GI) fluid or artificial sweat extracts of crumb rubber samples collected from fields. • Oral (ingestion) exposure to metals and metalloids: non-cancer effects from oneday and chronic oral exposures and cancer from lifetime oral exposure. These are needed for metals and metalloids detected in GI acid extracts of crumb rubber samples.

The first step common to all these cases is to survey the four sources of published toxicity criteria:
• OEHHA Chemical Database,
• USEPA Integrated Risk Information System (IRIS),
• USEPA Superfund Provisional Peer-Reviewed Toxicity Value (PPRTV) Program, and
• Toxicological Profiles from Agency for Toxic Substances and Disease Registry (ATSDR).

These sources are used because the toxicity criteria they contain have been established after a comprehensive review of available human and animal toxicity data, relevant in vitro testing results, and related information such as absorption, distribution, metabolism, and excretion. In addition, they have undergone extensive internal and external peer reviews and are generally of high quality.

Non-cancer toxicity criteria include:
• reference exposure levels (RELs) or acceptable daily doses (ADDs) by OEHHA, • reference doses (RfDs) or reference concentrations (RfCs) by USEPA, and • minimal risk levels (MRLs) by ATSDR.

Cancer toxicity criteria are expressed as cancer slope factors (CSFs), oral slope factors or inhalation unit risk values (IURs).

In this study, CSFs are compiled only for carcinogens classified:
• by the International Agency for Research on Cancer (IARC) in as known (Groups 1), probably (Group 2A), or possibly (Group 2B) carcinogenic to humans, • by USEPA as known or likely to be carcinogenic to humans, or • for the cancer endpoint on the California Proposition 65 maintained by OEHHA.

OEHHA developed approaches to select the most appropriate established values for those chemicals that have multiple values and to develop screening toxicity criteria for those chemicals that do not have established values.
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For chemicals which have not been identified by IARC, USEPA, or OEHHA as carcinogens, but belong to chemical classes with well-known carcinogens, such as the polycyclic aromatic hydrocarbons (PAHs), OEHHA investigated their potential carcinogenicity using cancer prediction models within the Virtual Models for Property Evaluation of Chemicals within a Global Architecture (VEGA). The models compared the structure of each chemical of concern with a library of known carcinogenic structure fragments. VEGA model predictions for selected chemicals are presented in Appendix E.

4.2.1. Chemicals with Established Toxicity Criteria
Among the established toxicity criteria of chemicals, there are two characteristics to consider: whether the values are chemical specific and the number of sources with established values.

4.2.1.1. Types of Established Toxicity Criteria
There are two main types of toxicity criteria: chemical-specific and chemical-equivalent.

Chemical-specific criteria are those developed using toxicity data for the specified chemical. This is the most common type. Some toxicity criteria are developed for a chemical in the mixture that is assumed to apply to other chemicals in the mixture, for a mixture that is assumed to apply to the chemicals in the mixture, or by using a criterion for a chemical with a similar structure (analogs). We call these types of toxicity criteria “chemical-equivalent”.

One example of a chemical equivalent toxicity criterion is the USEPA single chronic inhalation toxicity criterion for the trimethylbenzenes (TMBs), which covers the 1,2,4-, 1,3,5-, and 1,2,3-TMB isomers (USEPA, 2016). These chemicals typically occur as mixtures and the individual isomers are observed to have similar toxicity for the sensitive endpoint, neurotoxicity. EPA elected therefore to assign the same criterion to each of the three isomers.

A different, chemical-equivalent, approach is used for the PAHs. PAHs are structurally related chemicals and are hydrocarbons consisting of multiple conjugated aromatic ring structures. Many PAHs have been found to be carcinogens in studies in animals and one PAH, benzo(a)pyrene (BaP), has been identified as “carcinogenic to humans” by IARC. The carcinogenic potencies for several PAHs were derived from that for BaP.

BaP is used as an index chemical for PAHs because it has a relatively large cancer bioassay database. While many PAHs have sufficient toxicity information to identify them as carcinogenic, data on dose-response relationships are limited. Using comparative toxicity and carcinogenicity data, the relative potencies of these PAHs to that of BaP can be determined and expressed numerically as potency equivalent factors (PEFs). For cancer endpoints, the CSFs of these PAHs are then calculated as the product of their respective PEFs and the CSF of BaP. On that basis, OEHHA has developed human CSFs for several PAHs (OEHHA, 2004; OEHHA, 2015). 4-193
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For metals and metalloids in this study, the toxicity criteria for any oxidation state (referred to as “form”) were compiled and the value for the metal or metalloid was set at the most toxic form for the purpose of screening for toxicity concerns. The form of the metals or metalloids detected in acid extracts of crumb rubber were not examined in this study (see Section 3.3.1), but had a toxicity concern been seen, further follow up would have been undertaken.

4.2.1.2. Selection of Toxicity Criteria from Multiple Sources For any particular chemical, toxicity criteria are often available from only one source; these values were adopted for this study after a review of the supporting documentation and a determination that the value should be used.

Some chemicals have established toxicity criteria from multiple sources; they are mainly common environmental contaminants. When there are multiple sources, the values can differ because of differences in the data availability, approaches used in hazard identification, dose-response assessment, data extrapolation, or methodology to address uncertainty. In the case of metals or metalloids, the difference can in part be due to the different forms of the element encountered in human studies or administered to laboratory animals in toxicity studies.

OEHHA’s selection of toxicity criteria considered the following:
• Magnitude of the value: The lowest non-cancer toxicity criterion and highest CSF represent the most health protective values.
• Quality of the database: Criteria from more recently developed assessments, particularly from the same source (OEHHA or USEPA), are preferred when they are based on higher quality studies, more comprehensive evaluation of the database, or more current methodology.

4.2.2. Chemicals without Established Toxicity Criteria
For organic chemicals with no established non-cancer toxicity criteria, OEHHA either derived new toxicity criteria or used those from structural analogs. OEHHA first conducted a literature search for published toxicology reviews and toxicity studies. The next step was to prioritize developing values for those with greatest potential exposure concern, based on results from published synthetic turf studies and whether they were known to be in tires. OEHHA developed screening toxicity criteria to be used in this study from the published toxicity data. For chemicals without adequate toxicity data, OEHHA identified structural analogs that had toxicity criteria and adopted the TC of the structural analog.

Oral toxicity criteria were available for most of the metals and metalloids detected in the statewide study and of interest because of their toxicity profiles. For metals and metalloids with no established toxicity criteria, we did not derive new toxicity criteria. In 4-194
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addition, we could not use the structural analog approach for metals or metalloids because metals of similar ionic radius and charges can manifest very different effects (e.g., calcium ion and lead ion).

Processes used to derive toxicity values for chemicals without established toxicity criteria are outlined below.

4.2.2.1. Toxicity Criteria Derived De Novo from Published Toxicity Studies In developing new toxicity criteria, OEHHA followed its risk assessment guidelines (OEHHA, 2008; OEHHA, 2009) and documented the studies used and analysis in Appendix section E.3. OEHHA took the following steps in these de novo derivations:

1. Searched the literature for relevant studies.

2. Determined the critical study and critical toxicity endpoints by a hazard identification process using published toxicity studies or reviews.

3. Conducted a dose-response assessment. For non-cancer effects, this step establishes a point of departure. In this study, it was usually the dose at which no adverse effect is observed in an animal study. For cancer, it is to establish an upper bound on the slope of the dose response curve in the low dose region of the curve.

4. Quantified the uncertainty factor and extrapolation of the point of departure (POD), the point on the dose-response curve where below which no effect is expected or the lifetime excess cancer risk is at one in a million. • For non-cancer effects, uncertainty factors are used to account for variability in human susceptibility, uncertainty in extrapolation from animals to humans, as well as limitations of the toxicity database. The uncertainty factors are multiplied together. For screening-level non-cancer toxicity criteria, the maximum combined uncertainty factor is 10,000 was used in this study.
• For cancer, CSFs for humans (CSFhuman) are developed based on animal CSFs (CSFanimal) from chemical-specific animal cancer bioassay data and a scaling factor for animal to human extrapolation.

4.2.2.2. Toxicity Criteria Derived from Structural Analogs The ideal analog is similar in structure and biological activity in the target organ to the chemical of concern and has an established toxicity criterion for the exposure pathway.

However, the ideal case is often not met because many chemicals of concern do not have an adequate toxicity database for comparison to their analogs, or the suitable analogs do not have any established toxicity criterion.

In the interest of public health protection, the study tried to maximize the number of chemicals included in the risk assessment. OEHHA used scientific judgment to identify analogs based on similarities in chemical structure and toxicity, or structure alone. The 4-195
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USEPA CompTox Chemicals Dashboard (Dashboard, (USEPA, 2023)) was queried for structural similarity and Toxicity criteria information. Using the Dashboard, we matched each chemical of potential concern with chemicals in the database using a structural similarity score. However, many of the matched candidates did not have established toxicity criteria. For each of these chemicals, the assignment of an analog was based on qualitative evaluation of the structure alone.

An example of the structure and toxicity relationship analysis is that for 5 benzothiazoles, shown in Figure 4-2. Two of the chemicals shown have toxicity criteria - benzothiazole (Figure 4-2c) and 2-Mercaptobenzothiazole (Figure 4-2a). The remaining three chemicals do not have toxicity criteria. One important way in which these benzodiazoles differ structurally is that some have a mercapto group while others do not. (Structurally, the mercapto group is represented by R-SH or R1-S-R2, where R, R1 and R2 represent alkyl groups).
2-Mercaptobenzothiazole is the analog for 2-methythiobenzothiazole (Figure 4-2b), because they both have the mercapto group. Benzothiazole is the analog for 2- hydroxybenzothiazole (Figure 4-2d) and 2-phenylbenzothiazole (Figure 4-2e), as these chemicals do not have the mercapto group.

Figure 4-2. Chemical Structures of Five Benzothiazoles: (a) 2-mercaptobenzothiazole, CASRN 149-30-4; (b) 2-methylthiobenzothiazole, CASRN 615-22-5; (c) benzothiazole, CASRN 50-32-8; (d) 2-hydroxybenzothiazole, CASRN 934-34-9; and (e) 2- phenylbenzothiazole, CASRN 883-93-2.

4.2.2.3. Criteria Derived From Route- or Duration-Specific Toxicity Criteria for the Same Chemical
When a toxicity criterion is not available for a specific exposure route of a chemical, route-to-route extrapolation is commonly used when a value is available for a different route of exposure. For example, a toxicity criterion for oral exposure based on systemic effects is generally considered appropriate for deriving toxicity criteria for inhalation or dermal exposures. The oral toxicity criterion (TCoral) expressed, for example, as mg per kg per day would be converted to the inhalation criterion (TCinh), expressed, for example, as mg of chemical per cubic meter of air concentration. The oral criterion would be multiplied by the default bodyweight (70 kg) and divided by the inhalation rate (20 cubic meters of air per day). In this case the resulting inhalation criterion would be expressed in units mg per cubic meter. Oral toxicity criteria can be similarly calculated from inhalation toxicity criteria when expressed in these units by multiplying by (a) (b) (c) (d) (e)
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inhalation rate and dividing by the bodyweight default values. See Appendix Section E.2.3 for examples. An assumption of 100 percent absorption, in the absence of chemical-specific absorption data, is applied in these cases.

For the study, oral criteria (TCoral) are applied in assessing exposure via the dermal route by assuming 100 percent of absorption (both oral and dermal absorptions), in the absence of chemical-specific absorption data. While dermal absorption is rarely 100%, this assumption is made to screen chemicals for concern. For those chemicals that appear to be concern for dermal exposure this assumption can be examined.

When non-cancer toxicity criterion is available only for subchronic and not for chronic exposure, OEHHA adjusted the subchronic value using a standard uncertainty factor approach (OEHHA, 2008) to derive a value for chronic exposure. An example is using the intermediate-duration oral exposure level (15 to 364 days) for tin to derived a chronic oral value for the compound. The intermediate-duration value available is based on hematological effects observed in a 13-week oral study of animals (ATSDR, Toxicological Profiles). The shorter-term value was divided by an uncertainty factor of 10 to derive the chronic oral exposure toxicity value for tin (see Appendix Section E.2.3.10, Table E-17).

4.3. Grouping of Toxicity Criteria for Risk Assessment
For each general type of toxicity – after acute one-hour, one-day or chronic exposure - the Toxicity criteria are grouped by target organs or specific types of effects, according to the groupings shown in Table 4-2. This allows for the hazard assessment of multiple chemicals that act on the same target systems or produce the same effects. For example if two chemicals, A and B, both have chronic toxicity criteria based on cardiac effects they would be assessed jointly in evaluating the hazard for cardiac effects.

Similarly, chemicals that have sensory irritation as the basis of the toxicity criteria would be jointly assessed in determining the sensory hazard. This comports with the hazard index framework presented in Chapter 6 for making the assessment. The reported toxicity endpoints provided in Appendix E are used group chemicals according to the categories in Table 4-2.

Table 4-1. Groupings of Target Organs or Effects for the Physiological System Basis of the Non-Cancer Toxicity Criteria
Grouping Target Organs or Effects
Sensory Irritation
Nervous and sensory
system Brain, sensory or motor effects, ear, eye and nose irritation Developmental and/or Reproductive Toxicity (DART)
Developmental system Effects on the fetus, for example increased gestation period, teratology, and fetal mortality
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Grouping Target Organs or Effects
Reproductive system Effects on reproductive outcome and organs, for example, litter size, ovulation rate, sex organ weight
All Other Effects
Alimentary tract Oral cavity, stomach, forestomach (rodent), liver Cardiovascular system Heart, circulatory system
Endocrine system Thyroid gland, parathyroid gland, pituitary gland, adrenal gland
General toxicity
Clinical signs; change in bodyweight; change in food
consumption; effects on bones, teeth, hair, nail, or skin; mortality
Hematological system Blood cells, spleen, thymus
Immunological system Antibody levels,
Respiratory system Nasal cavity, lung
Renal system Kidney
In calculating the risks from exposures to multiple carcinogens, cancer risks are assumed to be additive, and carcinogens are treated as one large group.

4.4. Toxicity Criteria for Inhalation Exposure to Organic Chemicals In the following sections, discussion of non-cancer toxicity criteria for inhalation exposures (TCinh) are organized based on exposure duration and effects. The criteria are presented in different sections for:
• acute one-hour exposure
• one-day exposure – developmental and reproductive effects • chronic exposure – sensory irritation
• chronic exposure
• lifetime exposure – carcinogens

4.4.1. Acute One-Hour Inhalation Exposure
Chemicals with established one-hour non-cancer RELs from OEHHA are provided in Table 4-3. The one-hour RELs are given in units of µg per cubic meter and used as the non-cancer toxicity criteria to evaluate the acute inhalation exposures (Acute TCinh) to these chemicals. Respiratory and sensory are the common target organ systems. For benzene, the one-hour REL was primarily based on respiratory, sensory, and nervous system effects (see Appendix Section E.1 for more details). 4-198
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In addition to these values, USEPA’s tabulation of “Acute Dose-Response Values for Screening Risk Assessments” was an additional point of comparison of concentrations detected on synthetic turf fields to toxicity values (USEPA, 2021).

Table 4-2. Acute One-Hour Inhalation Toxicity Criteria (Acute TCinh) Based on OEHHA One-Hour Reference Exposure Levels
Chemical CASRN Acute TCinh
(µg per cubic meter) Target Organ Systems
Acetaldehyde 75-07-0 470 Eyes; Respiratory System
(sensory irritation)
Benzene 71-43-2 27
Reproductive/Developmental;
Immune and Hematologic
Systems
2-Butanone
(methyl ethyl ketone) 78-93-3 13000 Eyes; Respiratory System 2-Butoxyethanol (ethylene
glycol monobutyl ether) 111-76-2 4700 Eyes; Respiratory System Formaldehyde 50-00-0 55 Eyes (sensory irritation)
Phenol 108-95-2 5800 Eyes; Respiratory System
Styrene 100-42-5 21000 Eyes; Respiratory System;
Reproductive/Developmental
Tetrachloroethylene 127-18-4 20000 Eyes; Nervous System; Respiratory System
Toluene 108-88-3 5000
Nervous and Respiratory
Systems; Eyes; Reproductive/
Developmental
m/p-Xylene 106-42-3 22000 Eyes; Respiratory System;
Nervous System
o-Xylene 95-47-6 22000 Eyes; Respiratory System;
Nervous System

4.4.2. One-Day Inhalation Exposure: DART
The inhalation toxicity criteria for DART chemicals (DART TCinh) are:
• chemical-specific based on an existing OEHHA or USEPA assessment (6 chemicals),
• chemical-specific - newly developed by OEHHA for this study (2 chemicals), or • chemical-equivalent based on a structural analog (12 chemicals) There are six chemical specific values, and these are provided in Table 4-4.

Table 4-3. Chemical-Specific Inhalation Toxicity Criteria for DART Effects (DART TCinh) Chemical CASRN
DART TCinh
(µg per cubic
meter)
Source
2-Butanone 78-93-3 5000 USEPA IRIS
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In addition, 12 chemicals have values that are chemical-equivalent and based on structural analogy to one of the chemicals in Table 4-4. Table 4-5 summarizes the toxicity criteria for these chemicals and indicates the structural analog used as the basis of the values.

Table 4-4. Chemical-Equivalent Inhalation Toxicity Criteria for DART Effects (DART TCinh) Based on Structural Analog
Chemical CASRN
DART TCinh
(µg per cubic
meter)
Source
Benzo[a]pyrene 50-32-8

0.4 – ages < 11 OEHHA derived. See text below

0.002 – other ages USEPA IRIS
Bis(2-ethylhexyl)
adipate 103-23-1 98 OEHHA
Cyclohexylamine 108-91-8 700 USEPA IRIS
Dimethyl phthalate 131-11-3 400 USEPA PPRTV
4-tert-Octylphenol 140-66-9 140 OEHHA Derived: Appendix E.3.10
Chemical CASRN Chemical Analog
DART TCinh
(µg per cubic
meter)
Benzo[e]pyrene 192-97-2
Benzo[a]pyrene 0.4 – ages < 11

0.002 – other ages
Benzo[g,h,i]perylene 191-24-2
Chrysene 218-01-9
Coronene 191-07-1
Cyclopenta[cd]pyrene 27208-37-
3 Indeno[1,2,3-cd]pyrene 193-39-5
Methyl stearate 112-61-8 Bis(2-ethylhexyl)
adipate 98
n-Caproic acid vinyl ester 3050-69-9
N-Cyclohexyl-cyclohexanamine 101-83-7
Cyclohexylamine 700
N,N-Dicyclohexylmethylamine 7560-83-0
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Two values are given in Table 4-4 for benzo(a)pyrene and in Table 4-5 for benzo(a)pyrene analogs. One value is for ages groups <11 years, the second for all other ages. The value for those greater than 11 years of age is based on a critical study where exposure occurred during pregnancy and offspring were affected. Given the mismatch of this critical study for the young age groups (<11 years, pre-puberty age children), a value more appropriate for application to young children was derived.

No sensitive inhalation studies were available that were relevant to this age period.

However, a rat study conducted by the oral route was available where animals were exposed postnatally and neurobehavioral changes were observed, along with effects on ovarian follicles (Chen et al., 2012). The value for young children is based on this study.

OEHHA conducted route-to-route-extrapolation to develop the DART TCinh value for children of 0<11 years, shown in Table 4-4. See Appendix Section E.2.1.

4.4.3. Chronic Inhalation Exposure: Sensory Irritation
Inhalation toxicity criteria of chemicals with sensory irritation as the basis (Sensory TCinh) were established by OEHHA as chronic RELs (Table 4-6, see Appendix E for additional details). The effects of concern were eye and respiratory system irritation. To screen for potential effects the study evaluated the average concentrations measured at each field on a single day against these toxicity benchmarks.

Table 4-5. Inhalation Toxicity Criteria for Sensory Irritants (Sensory TCinh) Using Chronic Reference Effect Levels Based on OEHHA Chronic RELs (OEHHA Chemicals Library) Chemical CASRN Chronic REL
(µg per cubic meter)
Acetaldehyde 75-07-0 140
Formaldehyde 50-00-0 9
Styrene 100-42-5 900

4.4.4. Chronic Inhalation Exposure
This section presents chemicals with chronic inhalation toxicity criteria (Chronic TCinh) based on chronic reference concentrations for effects other than sensory irritation or DART. The effects can be for general systemic toxicity such as body weight changes, or effects on target organs such as the liver, kidneys, as presented in Table 4-2. For this study, we gave chemicals the term “general chemicals” when their chronic toxicity Chemical CASRN Chemical Analog
DART TCinh
(µg per cubic
meter)
2,4-bis(1-methyl-1-
phenylethyl)phenol 2772-45-4
4-tert-Octylphenol 140
4-(1-phenylethyl)-phenol 1988-89-2
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criteria were based on endpoints other than sensory irritation or DART. Chemicals with chemical-specific inhalation toxicity criteria are listed in Table 4-7 and chemicals with inhalation toxicity criteria from structural analogs are listed in Table 4-8.

Most of the chemicals detected in samples collected from the air, had chronic noncancer TCinh were available from OEHHA, USEPA, or ATSDR, or could be assigned values using a structural analog. OEHHA newly derived screening TCinh for the following chemicals (details in Appendix Section E.3):
• 2-Methylfuran
• Benzothiazole
• Methacrolein
• Methyl isobutyl ketone
• N-(1,3-dimethylbutyl)-N'-phenyl-p-benzenediamine
• 4-tert-Octylphenol
• 2,2,4-Trimethyl-1,3-pentanediol diisobutyrate (TXIB)
The newly derived value for benzothiazole was used to assign, by structural analogy, toxicity criteria for some of the other benzothiazoles.

Four chemicals do not have established non-cancer TCinh, but were excluded in the development of toxicity criteria because they are relatively non-toxic and commonly found in plants or food: 3-carene, alpha-pinene, D-limonene, and limonene.

Table 4-6. Chemical-specific Chronic Toxicity Criteria for Inhalation (Chronic TCinh) Organic Chemicals
Chemical CASRN Chronic TCinha
(µg per cubic meter)
Target Organ
System Reference
1,4-Benzene-diamine, N-(1,3-
dimethylbutyl)-N'-phenyl- 793-24-8 10.5* General Appendix E 1-Hexanol, 2-ethyl- 104-76-7 0.4 Respiratory USEPA PPRTV 2-Butoxyethanol 111-76-2 80 Respiratory OEHHA
Acetone 67-64-1 3.15 Renal USEPA IRIS
Aniline 62-53-3 1 Hematological USEPA IRIS
Anthracene 120-12-7 1050* General USEPA IRIS
Benzaldehyde 100-52-7 350* Alimentary
tract, Renal USEPA IRIS
Benzene 71-43-2 3 Hematological OEHHA
Benzene, 1,2,3-trimethyl- 526-73-8 60 Nervous USEPA IRIS Benzene, 1,2,4-trimethyl- 95-63-6 60 Nervous USEPA IRIS Benzene, 1,3,5-trimethyl 108-67-8 60 Nervous USEPA IRIS Benzene, 1,4-dichloro 106-46-7 60 Respiratory ATSDR
Benzene, 1-chloro-4-
(trifluoromethyl)- 98-56-6 300 Alimentary tract USEPA PPRTV Benzene, n-butyl- 104-51-8 17500 Alimentary tract USEPA PPRTV 4-202
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Chemical CASRN Chronic TCinha
(µg per cubic meter)
Target Organ
System Reference
Benzothiazole 95-16-9 1.75* General Appendix E
Benzyl butyl phthalate 85-68-7 700* Alimentary tract USEPA IRIS Cyclopentasiloxane,
decamethyl- 541-02-6 700
Alimentary
tract,
Hematological
OEHHA
Dibenzothiophene 132-65-0 35* Alimentary tract USEPA PPRTV Dibutyl phthalate 84-74-2 350* General USEPA IRIS
Diethyl phthalate 84-66-2 2800* General USEPA IRIS
Di-n-octyl phthalate 117-84-0 35* Alimentary tract USEPA PPRTV Ethylbenzene 100-41-4 300 Renal ATSDR
Fluoranthene 206-44-0 140* Renal,
Hematological USEPA IRIS
Fluorene 86-73-7 140* Hematological USEPA IRIS
Furan, 2-methyl 534-22-5 0.35* Alimentary tract Appendix E Heptane 142-82-5 400 Nervous USEPA PPRTV
Hexane 110-54-3 700 Nervous USEPA IRIS
Methacrolein 78-85-3 1.4 Respiratory Appendix E
Methyl isobutyl ketone 108-10-1 160 Renal Appendix E
Naphthalene 91-20-3 3 Respiratory ATSDR
Naphthalene, 1-methyl 90-12-0 24.5* Respiratory USEPA PPRTV Naphthalene, 2-methyl- 91-57-6 14* Respiratory USEPA IRIS Phenol 108-95-2 200 Nervous OEHHA
Propionaldehyde 123-38-6 8 Respiratory USEPA IRIS
Pyrene 129-00-0 105* Renal USEPA IRIS
Tetrachloroethylene 127-18-4 40 Nervous USEPA IRIS,
ATSDR
Toluene 108-88-3 420 Nervous OEHHA
Trichloroethylene 79-01-6 2 Hematological USEPA IRIS,
ATSDR
Trichloromethane 67-66-3 300 Alimentary
tract, Renal OEHHA
TXIB, 2,2,4-Trimethyl-1,3-
pentanediol diisobutyrate 6846-50-0 10.5* Alimentary tract Appendix E Xylenes mixture: m-Xylene, pXylene, and o-Xyleneb
1330-20-7
108-38-3
106-42-3
95-47-6
100b
Impaired motor
coordination in
rats

USEPA IRIS
a Chemicals that are derived from toxicity criteria by the oral route are denoted with an asterisk (*) b There is a Sensory TCinh of 700 microgram per cubic meter for one-day exposure to xylenes (Appendix E.2.3.6), which is less to 10-fold higher than a Chronic TCinh of 100 microgram per cubic meter for other effects. Both effects are evaluated.
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Table 4-7. Chemical Equivalent Chronic Toxicity Criteria for Inhalation (Chronic TCinh) for Organic Chemicals Based on Structural Analog
Chemical CASRN Analog
Chronic TCinha
(µg per cubic
meter)
Target Organ
System
Reference
for Analog
17-Pentatriacontene 6971-40-0 Nonane 20 General USEPA
PPRTV
1-Methyl-4-(1-
methylethyl) benzene 99-87-6 Benzene, 1,2,3-trimethyl- 60 Nervous USEPA 1-Octadecene 112-88-9 Nonane 20 General USEPA
PPRTV
2,5-di-tert-Butyl-1,4-
benzoquinone 2460-77-7 Anthraquinone 7*
Alimentary
tract, Renal,
Hematological
USEPA
PPRTV
2,5-Hexanedione 110-13-4 2-Hexanone 30 Nervous USEPA
IRIS
2-Benzothiazolone 934-34-9 Benzothiazole 1.75* General Appendix E
3,5-di-tert-Butyl-4-
hydroxybenzaldehyde1620-98-0 Butylated hydroxyl
toluene 1050* General USEPA IRIS
5,9-Undecadien-2-
one, 6,10-dimethyl- 689-67-8 Methyl isobutyl ketone 160 Renal OEHHA 7H-Benzo[c]fluorene 205-12-9 Fluorene 140* Hematological USEPA IRIS
Acenaphthylene 208-96-8 Acenaphthene 210 Alimentary
tract
USEPA
IRIS
Anthracene, 2-
methyl- 613-12-7 Anthracene 1050* General USEPA IRIS
Anthracene, 9,10-
dimethyl 781-43-1 Anthracene 1050* General USEPA IRIS
Anthracene, 9-phenyl 602-55-1 Anthracene 1050* General USEPA IRIS
Benz[a]anthracene 56-55-3 Anthracene 1050* General USEPA IRIS
Benzene, 1,2,4,5-
tetramethyl- 95-93-2 Benzene, 1,2,3-trimethyl- 60 Nervous USEPA IRIS Benzene, 1-ethyl2,4-dimethyl- 874-41-9 Benzene, 1,2,3- trimethyl- 60 Nervous USEPA IRIS
Benzene, 2-ethyl1,4-dimethyl- 1758-88-9 Benzene, 1,2,3- trimethyl- 60 Nervous USEPA IRIS
Benzo[b]fluoranthene 205-99-2 Fluoranthene 140* Renal,
Hematological
USEPA
IRIS
Benzo[k]fluoranthene 207-08-9 Fluoranthene 140* Urinary, Hematological
USEPA
IRIS
Benzothiazole, 2-
phenyl- 883-93-2 Benzothiazole 1.75* General Appendix E Butanal 123-72-8 Propionaldehyde 8 Respiratory USEPA
IRIS
Cyclotrisiloxane,
hexamethyl- (D3) 541-05-9 Cyclopentasiloxane, decamethyl- 700 Alimentary
tract,
Hematological
OEHHA
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Chemical CASRN Analog
Chronic TCinha
(µg per cubic
meter)
Target Organ
System
Reference
for Analog
Cyclotetrasiloxane,
octamethyl- 556-67-2 Cyclopentasiloxane, decamethyl- 700 Alimentary
tract,
Hematological
OEHHA
Decanal 112-31-2 Propionaldehyde 8 Respiratory USEPA
IRIS
Decane 124-18-5 Nonane 20 General USEPA
PPRTV
Dibenz[a,h]-
anthracene 53-70-3 Anthracene 1050* General USEPA IRIS
Diisobutyl phthalate 84-69-5 Di-n-octyl phthalate 35* Alimentary tract
USEPA
PPRTV
Diisooctyl phthalate 27554-26-
3 Di-n-octyl phthalate 35* Alimentary tract
USEPA
PPRTV
Dodecane 112-40-3 Nonane 20 General USEPA
PPRTV
Heptanal 111-71-7 Propionaldehyde 8 Respiratory USEPA
IRIS
Hexadecane 544-76-3 Nonane 20 General USEPA
PPRTV
Hexaldehyde
(Hexanal) 66-25-1 Propionaldehyde 8 Respiratory USEPA IRIS Indan (Benzocyclopentane) 496-11-7 Styrene 900 Nervous OEHHA m-Tolualdehyde 620-23-5 Benzaldehyde 350* Alimentary
tract, Renal
USEPA
IRIS
Naphthalene, 1,2-
dimethyl- 573-98-8 Naphthalene 3 Respiratory ATSDR
Naphthalene, 1,6-
dimethyl- 575-43-9 Naphthalene 3 Respiratory ATSDR
Naphthalene, 2-
(bromomethyl)- 939-26-4 Naphthalene 3 Respiratory ATSDR Naphthalene, 2,3-
dimethyl- 581-40-8 Naphthalene 3 Respiratory ATSDR
Nonanal 124-19-6 Propionaldehyde 8 Respiratory USEPA
IRIS
N-Phenyl-benzamide 93-98-1 Aniline 1 Hematological USEPA IRIS
Octanal 124-13-0 Propionaldehyde 8 Respiratory USEPA
IRIS
Octane 111-65-9 Nonane 20 General USEPA
PPRTV
Phenanthrene 85-01-8 Anthracene 1050* General USEPA
IRIS
Phenanthrene, 1-
methyl 832-69-9 Anthracene 1050* General USEPA IRIS
Phenanthrene, 2-
methyl- 2531-84-2 Anthracene 1050* General USEPA IRIS
Phenanthrene, 3-
methyl 832-71-3 Anthracene 1050* General USEPA IRIS
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Chemical CASRN Analog
Chronic TCinha
(µg per cubic
meter)
Target Organ
System
Reference
for Analog
Pyridine, 2-(4-
methylphenyl)- 4467-06-5 Pyridine 3.5* Alimentary tract USEPA
IRIS
Resorcinol 108-46-3 Phenol 200 Nervous OEHHA
Tetradecane 629-59-4 Nonane 20 General USEPA
PPRTV
Texanol, 2,2,4-
Trimethyl-1,3-
pentanediol
monoisobutyrate
25265-77-
4 TXIB, 2,2,4-
Trimethyl-1,3-
pentanediol
diisobutyrate

10.5* Alimentary
tract
Appendix
E
Undecane 1120-21-4 Nonane 20 General USEPA
PPRTV
Valeraldehyde 110-62-3 Propionaldehyde 8 Respiratory USEPA IRIS a Chemicals that are derived from toxicity criteria by the oral route are denoted with an asterisk (*)

4.4.5. Lifetime Inhalation Exposure: Carcinogens
The cancer slope factors for evaluating inhalation exposure (CSFinh) to carcinogens detected in the study are presented in Table 4-9. They are all based on OEHHA values.

Several of them were derived earlier by OEHHA based on potency equivalency factors (PEF) applied to the CSF for benzo(a)pyrene. Two carcinogens did not have established human CSFs - cyclopenta[c,d]pyrene and methyl isobutyl ketone. OEHHA newly derived human CSFinh for these two chemicals. The CSF for methyl isobutyl ketone was chemical-specific and used an inhalation carcinogenicity study for the chemical (See Appendix Section E.3.8.5.2). The CSF for cyclopenta[c,d]pyrene used the CSFinh of BaP and a PEF that was derived by comparing the inhalation toxicity of BaP to cyclopenta[c,d]pyrene (See Appendix Section E.3.9.3).

Table 4-8. Human Cancer Slope Factors for Lifetime Inhalation Exposure to Carcinogens (CSFinh)
Chemical CASRN Basis
CSFinh
(mg per kg per
day)-1
Tumor Organ
System Reference
Acetaldehyde 75-07-0 ChemicalSpecific 0.01 Renal OEHHA Aniline 62-53-3 ChemicalSpecific 0.0057 Hematological OEHHA Benzene 71-43-2 ChemicalSpecific 0.1 Hematological OEHHA Benzene, 1,4-dichloro 106-46-7 ChemicalSpecific 0.04 Alimentary tract OEHHA Benzene, 1-chloro-4-
(trifluoromethyl)- 98-56-6 ChemicalSpecific 0.03 Alimentary tract OEHHA Benzo[a]pyrene 50-32-8 ChemicalSpecific 3.9 Respiratory OEHHA Dibenz[a,h]anthracene 53-70-3 ChemicalSpecific 4.1 Respiratory OEHHA 4-206
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Chemical CASRN Basis
CSFinh
(mg per kg per
day)-1
Tumor Organ
System Reference
Ethylbenzene 100-41-4 ChemicalSpecific 0.0087 Renal OEHHA Formaldehyde 50-00-0 ChemicalSpecific 0.021 Respiratory OEHHA Methyl isobutyl ketone 108-10-1 ChemicalSpecific 0.0039 Alimentary tract Appendix E.3.8
Naphthalene 91-20-3 ChemicalSpecific 0.12 Respiratory OEHHA Styrene 100-42-5 ChemicalSpecific 0.026 Respiratory OEHHA Tetrachloroethylene 127-18-4 ChemicalSpecific 0.02 Alimentary tract, Hematological OEHHA
Trichloroethylene 79-01-6 ChemicalSpecific 0.014
Alimentary tract,
Hematological,
Renal
OEHHA
Trichloromethane 67-66-3 ChemicalSpecific 0.014 Alimentary tract, Renal OEHHA
Benz[a]anthracene 56-55-3 PEF BaP 0.39 Respiratory OEHHA Benzo[b]fluoranthene 205-99-2 PEF BaP 0.39 Respiratory OEHHA Benzo[k]fluoranthene 207-08-9 PEF BaP 0.39 Respiratory OEHHA Chrysene 218-01-9 PEF BaP 0.039 Respiratory OEHHA
Cyclopenta[cd]pyrene 27208-37-3 PEF BaP 3.9 Respiratory Appendix E.3.9
Indeno[1,2,3-
cd]pyrene 193-39-5 PEF BaP 0.39 Respiratory OEHHA
PEF BaP: potency equivalency factor (PEF) with benzo[a]pyrene (BaP) as the index chemical.

4.5. Toxicity Criteria for Oral or Dermal Exposure to Organic Chemicals There were 81 organic chemicals detected in the artificial biofluid extracts (artificial sweat or artificial GI fluids) of crumb rubber. Four chemicals were excluded from the development of toxicity criteria because they are considered relatively non-toxic or beneficial and commonly found in foods and plants: linoleic acid (an essential fatty acid in diet), oleic acid (an omega-9 fatty acid in olive oil), ricinoleic acid (the main component of castor oil) and limonene (an oil, e.g., in dill, citrus skin and caraway). For the 77 remaining chemicals, criteria were compiled for evaluating oral and dermal exposures for evaluating one-day exposure for DART effects or chronic exposure for other chronic effects. Cancer potency factors were also compiled for the detected carcinogens.

As noted in Section 4.2.2.3, toxicity criteria were typically not available for the dermal route, so oral toxicity criteria were used for the evaluation of the dermal route for this study, using the worst case assumption that dermal absorption was 100%. 4-207
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Five chemicals did not have established oral chronic toxicity or DART criteria but had suitable toxicity data for derivation of sensitive toxicity criteria. OEHHA derived new screening values for these chemicals as follows:
• 1,3-diphenylguanidine (DART oral, see Appendix Section E.3.4) • 4-tert-octylphenol (DART oral, see Appendix Section E.3.10) • Benzothiazole (general chronic toxicity, see Appendix Section E.3.5) • N-(1,3-dimethylbutyl)-N’-phenyl-1,4-benzenediamine (“6PPD”, general chronic toxicity, see Appendix Section E.3.2)
• N,N’-diphenyl-1,4-benzenediamine (“DPPD”, DART oral, see Appendix Section E.3.3)
However, there are no toxicity data for derivation of new values, or suitable analogs for three chemicals: phenoxazine, N,N’-dicyclohexylurea, and diphenylurea. We were therefore unable to evaluate these three chemicals in the risk assessment.

4.5.1. One-Day Oral and Dermal Exposures: DART
Toxicity criteria for evaluating developmental and reproductive toxicity (DART TCoral) for oral and dermal exposures to organic chemicals in crumb rubber are presented in Table 4-10. The table also shows the applicable routes for exposure to these chemicals given the detections in biofluid extracts (Chapter 3). Appendix E provides additional details and citations for sources the DART toxicity criteria.

Table 4-9. Chemical-specific Oral Toxicity Criteria for Organic Chemicals for Developmental and Reproductive Effects (DART TCoral)
Chemical CASRN DART TCoral
mg per kg per day
Exposure Route
Applied to Reference
1,4-Benzene-diamine,
N,N'-diphenyl- 74-31-7 0.008 Dermal Appendix E.3.3
1,3-Diphenylguanidine 102-06-7 0.005 Oral, dermal Appendix E.3.4 4-tert-Octylphenol 140-66-9 0.04 Oral, dermal Appendix E.3.10 Benzo[a]pyrene 50-32-8 0.0003 Oral, dermal USEPA IRIS
Bis(2-Ethylhexyl)adipate 103-23-1 0.028 Oral, dermal OEHHA Dimethyl phthalate 131-11-3 0.1 Oral, dermal USEPA PPRTV For 14 chemicals oral toxicity criteria for the DART endpoint were based on structural analogy, as shown in Table 4-11. The analog used in the assignment of the toxicity value is provided in the table along with the exposure route that the values are being applied to. 4-208
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Table 4-10. Oral Toxicity Criteria of Organic Chemicals for Reproductive and/or Developmental Effects (DART TCoral) Based on Structural Analogs(OEHHA Chemicals Library; USEPA IRIS)
Chemical CASRN Analog
DART TCoral
mg per kg per
day
Exposure
Route
Applied to
Reference for
Analog
2-Azacyclotridecanone 947-04-6 Caprolactam 0.5 Dermal USEPA IRIS Benzo[e]pyrene 192-97-2 Benzo[a]pyrene 0.0003 Oral,
dermal USEPA IRIS
Benzo[g,h,i]perylene 191-24-2 Benzo[a]pyrene 0.0003 Oral, dermal USEPA IRIS
Bis(2,2,6,6-tetramethyl4-piperidyl)sebacate 52829-07-9 Bis(2-ethylhexyl) adipate 0.028 Oral, dermal OEHHA
Chrysene 218-01-9 Benzo[a]pyrene 0.0003 Oral,
dermal USEPA IRIS
Coronene 191-07-1 Benzo[a]pyrene 0.0003 Oral,
dermal USEPA IRIS
Cyclopenta[cd]pyrene 27208-37-3 Benzo[a]pyrene 0.0003 Oral, dermal USEPA IRIS
Cyclohexanamine, Ncyclohexyl- 101-83-7 Cyclohexylamine 0.2 Oral, dermal USEPA IRIS
Indeno[1,2,3-cd]pyrene 193-39-5 Benzo[a]pyrene 0.0003 Oral, dermal USEPA IRIS
Methyl stearate 112-61-8
Bis(2-
ethylhexyl)adipa
te

0.028 Oral,
dermal OEHHA
N,NDicyclohexylmethylami
ne
7560-83-0 Cyclohexylamin
e

0.2 Dermal USEPA IRIS
n-Caproic acid vinyl
ester 3050-69-9
Bis(2-
ethylhexyl)adipa
te

0.028 Oral OEHHA
Phenol, 2,4-bis(1-
methyl-1-phenylethyl)- 2772-45-4 4-tertoctylphenol 0.04 Oral, dermal OEHHA Phenol, 4-(1-
phenylethyl)- 1988-89-2 4-tertoctylphenol 0.04 Oral, dermal OEHHA

4.5.2. Chronic Oral and Dermal Exposures: General Toxicity Criteria Toxicity criteria for evaluating general chronic toxicity (ChronicTCoral) for oral and dermal exposures to organic chemicals deteced in crumb rubber are presented in Table 4-12.

The table also shows the applicable routes for exposure to these chemicals given the 4-209
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detections in biofluid extracts (Chapter 3).

Table 4-11. Chemical-specific Oral Chronic Toxicity Criteria for Organic Chemicals (Chronic TCoral)
Chemical CASRN
Chronic TCoral
(mg per kg per
day)
Oral Target
Organ
System
Exposure
Route
Applied to
Reference
1,4-Benzene-diamine, N-
(1,3-dimethylbutyl)-N'-
phenyl793-24-8 0.003 General Oral, dermal Appendix
E.3.3.1
1,3-Benzothiazole-2-thiol 149-30-4 0.004 Alimentary
tract Dermal USEPA PPRTV
Aniline 62-53-3 0.007 Hematological Oral, dermal USEPA
PPRTV
Anthracene 120-12-7 0.3 General Oral, dermal USEPA IRIS Benzene, n-butyl- 104-51-8 0.05 Alimentary
tract Oral, dermal USEPA PPRTV
Benzothiazole 95-16-9 0.0005 General Oral, dermal Appendix E.3.5
Benzyl butyl phthalate 85-68-7 0.2 Alimentary
tract Oral, dermal USEPA IRIS
Butylated
Hydroxytoluene 128-37-0 0.3 General Oral USEPA PPRTV
Dibenzothiophene 132-65-0 0.01 Alimentary
tract Oral, dermal USEPA PPRTV
Dibutyl phthalate 84-74-2 0.1 General Oral USEPA IRIS
Diethyl phthalate 84-66-2 0.8 General Oral, dermal USEPA IRIS Di-n-octyl phthalate 117-84-0 0.01 Alimentary
tract Oral, dermal USEPA PPRTV
Fluoranthene 206-44-0 0.04 Renal,
Hematological Oral, dermal USEPA IRIS
Fluorene 86-73-7 0.04 Hematological Oral, dermal USEPA IRIS Naphthalene 91-20-3 0.02 General Oral, dermal OEHHA
Naphthalene, 1-methyl- 90-12-0 0.007 Respiratory Oral, dermal USEPA PPRTV
Naphthalene, 2-methyl 91-57-6 0.004 Respiratory Oral, dermal USEPA IRIS Pyrene 129-00-0 0.03 Renal Oral, dermal USEPA IRIS
For 36 chemicals oral toxicity criteria for general chronic toxicity (ChronicTCoral) for oral and dermal exposures were based on structural analogy, as shown in Table 4-13. The analog used in the assignment of the toxicity value is provided in the table along with the exposure route that the values are being applied to. 4-210
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Table 4-12. Oral Chronic Toxicity Criteria (Chronic TCoral,) for Organic Chemicals Based on Structural Analogs
Chemical CASRN Analog
Chronic
TCoral
mg per kg
per day
Oral Target
Organ
System
Applicable
Exposure
Route
Reference
for Analog
17-Pentatriacontene 6971-40-0 Mineral oil 3 Alimentary tract Oral USEPA IRIS
1-Hydroxy-pyrene 5315-79-7 Pyrene 0.03 Urinary Oral,
dermal
USEPA
IRIS
1-Octadecene 112-88-9 Nonane 0.0003 Alimentary
tract
Oral,
dermal
USEPA
PPRTV
2-(Methylthio)-
benzothiazole 615-22-5
1,3-Benzothiazole-2-
thiol

0.004 Alimentary
tract
Oral,
dermal
USEPA
PPRTV
2,5-di-tert-Butyl1,4-
benzoquinone
2460-77-7 9,10-Anthraquinone 0.002
Alimentary
tract, Urinary,
Hematological
Oral,
dermal
USEPA
PPRTV
2-Benzothiazolone 934-34-9
Butylated
hydroxytoluene0.0005 General Oral,
dermal
Appendix
E.3.5
3,5-di-tert-Butyl4-hydroxybenzaldehyde
1620-98-0
Butylated
hydroxytoluene0.3 General Oral,
dermal
USEPA
IRIS
5,9-Undecadien2-one, 6,10-
dimethyl689-67-8
Methyl
isobutyl
ketone

0.017 Alimentary
tract, Urinary
Oral,
dermal OEHHA
7H-Benzo[c]-
fluorene 205-12-9 Fluorene 0.04 Hematological Oral, dermal USEPA
IRIS
Acenaphthylene 208-96-8 Acenaphthene 0.06 Alimentary
tract
Oral,
dermal
USEPA
IRIS
Anthracene, 2-
methyl- 613-12-7 Anthracene 0.3 General Oral, dermal
USEPA
IRIS
Anthracene, 9,10-
dimethyl 781-43-1 Anthracene 0.3 General Oral USEPA IRIS Anthracene, 9,10-
diphenyl- 1499-10-1 Anthracene 0.3 General Oral, dermal USEPA
IRIS
Anthracene, 9-
phenyl 602-55-1 Anthracene 0.3 General Oral, dermal
USEPA
IRIS
Benz[a]-
anthracene 56-55-3 Anthracene 0.3 General Oral, dermal
USEPA
IRIS
Benzo[b]-
fluoranthene 205-99-2 Fluoranthene 0.04 Urinary, Hematological Oral,
dermal
USEPA
IRIS
Benzo[k]-
fluoranthene 207-08-9 Fluoranthene 0.04 Urinary, Hematological Oral,
dermal
USEPA
IRIS
Benzothiazole, 2-
phenyl- 883-93-2 Benzothiazole 0.0005 General Oral, dermal Appendix
E.3.5
Cyclohexyl
isothiocyanate 1122-82-3
Phenyl
isothiocyanate0.0002 Endocrine Oral,
dermal
USEPA
PPRTV
Dibenz[a,h]-
anthracene 53-70-3 Anthracene 0.3 General Oral, dermal
USEPA
IRIS
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Chemical CASRN Analog
Chronic
TCoral
mg per kg
per day
Oral Target
Organ
System
Applicable
Exposure
Route
Reference
for Analog
Diisobutyl
phthalate 84-69-5 Di-n-octyl phthalate 0.01 Alimentary tract Oral,
dermal
USEPA
PPRTV
Diisooctyl
phthalate
27554-26-
3 Di-n-octyl
phthalate 0.01 Alimentary tract
Oral,
dermal
USEPA
PPRTV
Hexadecane 544-76-3 Nonane 0.0003 Alimentary
tract Oral USEPA PPRTV
Hexanoic Acid, 2-
ethyl 149-57-5 Hexanedioic acid 2 General Dermal USEPA PPRTV Naphthalene,
1,2-dimethyl- 573-98-8 Naphthalene 0.02 General Oral, dermal OEHHA Naphthalene,
1,6-dimethyl- 575-43-9 Naphthalene 0.02 General Oral, dermal OEHHA Naphthalene, 2-
(bromomethyl)- 939-26-4 Naphthalene 0.02 General Oral, dermal OEHHA Naphthalene,
2,3-dimethyl- 581-40-8 Naphthalene 0.02 General Oral, dermal OEHHA N-Phenylbenzamide 93-98-1 Aniline 0.007 Hematological Oral, dermal
USEPA
PPRTV
Phenanthrene 85-01-8 Anthracene 0.3 General Oral,
dermal
USEPA
IRIS
Phenanthrene, 1-
methyl 832-69-9 Anthracene 0.3 General Oral, dermal
USEPA
IRIS
Phenanthrene, 2-
methyl- 2531-84-2 Anthracene 0.3 General Oral, dermal
USEPA
IRIS
Phenanthrene, 3-
methyl 832-71-3 Anthracene 0.3 General Oral, dermal
USEPA
IRIS
Phthalimide 85-41-6 Folpet 0.1 General Oral,
dermal
USEPA
IRIS
Pyridine, 2-(4-
methylphenyl)- 4467-06-5 Pyridine 0.001 Alimentary tract Oral,
dermal
USEPA
IRIS
Triethylene glycol
monobutyl ether 143-22-6 2-butoxyethanol 0.1 Alimentary Oral, dermal USEPA
IRIS

4.5.3. Lifetime Oral or Dermal Exposure to Carcinogens
Oral cancer slope factors (CSForal) for assessing risks of organic chemicals detected in GI or dermal extracts of crumb rubber are provided in Table 4-14. OEHHA was the source of these values with one exception. The CSForal for 1,3-benzothiazole-2-thiol was an established value from USEPA IRIS. For cyclopenta[c,d]pyrene, BaP was used by OEHHA as the analog after considering the similarity of the oral toxicity data for the two chemicals (details in Appendix Section E.3.9). The Chemical-specific cancer slope factor by the inhalation route (CSFinh) for aniline is based on a systemic effect, thus the inhalation cancer potency is used to derive the values for both the oral and dermal routes for this compound.
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Table 4-13. Oral Cancer Slope Factors (CSForal) for Assessing Lifetime Oral or Dermal Exposure to Carcinogens
Chemical CASRN Chemical
Basis
CSForal
(mg per kg per
day)-1
Oral Tumor
Organ
system
Applicable
Exposure
Route
Reference
1,3-Benzothiazole-2-thiol 149-30-4 ChemicalSpecific 0.01 Endocrine Dermal USEPA IRIS
Aniline 62-53-3 ChemicalSpecific 0.0057 Hematological Oral,
dermal OEHHA
Benzo[a]pyrene 50-32-8 ChemicalSpecific 12 Alimentary
tract
Oral,
dermal OEHHA
Benzo[b]-
fluoranthene 205-99-2 ChemicalSpecific 1.2 Alimentary tract Oral,
dermal OEHHA
Benzo[k]-
fluoranthene 207-08-9 ChemicalSpecific 1.2 Alimentary tract Oral,
dermal OEHHA
Chrysene 218-01-9 ChemicalSpecific 0.12 Alimentary
tract
Oral,
dermal OEHHA
Dibenz[a,h]-
anthracene 53-70-3 ChemicalSpecific 4.1 Respiratory Oral, dermal OEHHA Naphthalene 91-20-3 ChemicalSpecific 0.12 Respiratory Oral, dermal OEHHA
Benz[a]-
anthracene 56-55-3 PEF BaP 1.2 Alimentary tract
Oral,
dermal OEHHA
Cyclopenta[cd]-
pyrene
27208-
37-3 PEF BaP 12 Alimentary tract
Oral,
dermal
Appendix
E.3.9
Indeno[1,2,3-cd]-
pyrene
193-39-5 PEF BaP 1.2 Alimentary
tract
Oral,
dermal OEHHA
PEF BaP: potency equivalency factor (PEF) with benzo[a]pyrene (BaP) as an index chemical.

4.6. Toxicity Criteria for Oral Exposure to Metals and Metalloids Oral toxicity criteria were compiled for the metals and metalloids detected in the gastric fluid extracts of crumb rubber samples. The metals were not speciated and the health protective approach we took was to select the toxicity criteria for most toxic form for which values were available as representative of toxicity the metal or metalloid in crumb rubber. For example, chromium occurs in the environment in two oxidation states, trivalent chromium (Cr III) and hexavalent chromium (Cr VI) (USEPA, 2000). Cr (III) is known to be much less toxic than Cr (VI) and unlike Cr (VI) has not been found to be carcinogenic in humans. The USEPA oral RfDs are 1.5 mg per kg per day and 0.003 mg per kg per day for Cr (III) and Cr (IV), respectively (USEPA, 1998a; USEPA, 1998b).

OEHHA chose to represent chromium with the toxicity value for Cr (VI).

Of the metals and metalloids detected in gastric fluid extracts, the following were excluded in the compilation of toxicity criteria:
• Calcium, iron, magnesium, potassium, and sodium are essential nutrients, are found commonly in food, and are relatively non-toxic.
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• Lithium, rubidium, and silver are excluded because the established TCoral are based on side effects from clinical doses, considerably higher than expected from exposures to crumb rubber.
• Silicon and titanium do not have established values and OEHHA did not derive new screening values.

4.6.1. One-Day Oral Exposure to Metal or Metalloids: DART For a few metals and metalloids the most sensitive endpoints are for DART effects. The chemical-specific DART toxicity criteria for these elements are shown in Table 4-15.

The derivation of the DART toxicity criteria for oral exposure to lead is derived by OEHHA (2009) from dose response data for IQ deficits in children vs blood lead levels in children. The dynamic of blood lead level in these children is not a simple doseresponse relationship from a one-day oral exposure to lead, but the result from continuous, ongoing exposures to lead. Therefore, despite being a DART, the noncancer DART toxicity criterion TCoral for lead for children is applied in chronic non-cancer hazard assessment (see Table 4-16). However, OEHHA’s maximum allowable dose level (MADL, 0.5 µg/day) is also compared against the one-day oral exposure dose of lead. Appendix E provides additional details and sources of the values.

Table 4-14. Oral Toxicity Criteria of Metals and Metalloids for Developmental or Reproductive Effects (DART TCoral)
Chemical Chemical
Basis
DART TCoral
(mg per kg per day)
Oral Target Organ
System Reference
Arsenic Unspecified 0.0000035 Developmental OEHHA
Boron Boric acid 2.0 Developmental USEPA
PPRTV
Lead* Unspecified (MADL = 0.0005 mg per
day) Neuro-developmental OEHHA
Nickel NiCl or NiSO4 0.011 Reproductive OEHHA
*the MADL for lead is compared against the one-day oral dose of the chemical (see text above and Chapter 6 for details).

4.6.2. Chronic Oral Exposure to Metals and Metalloids: General Toxicity Chronic toxicity criteria (Chronic TCoral) for the metals and metalloids detected in artificial GI and dermal biofluids were available from OEHHA and USEPA and are shown in Table 4-16 below. However, the Chronic TCoral for tin was derived from a subchronic toxicity criterion using a duration uncertainty factor of 10-fold according to OEHHA guidelines (OEHHA, 2008).
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Table 4-15. Oral Chronic Non-Cancer Toxicity Criteria of Metals and Metalloids (Chronic TCoral)(OEHHA Chemicals Library; USEPA IRIS; USEPA PPRTV) Chemical
(Symbol) Chemical Basis
Chronic TCoral
mg per kg per
day
Oral Target Organ
System Reference
Aluminum (Al) Al lactate 0.018 General OEHHA
Antimony (Sb) Sb potassium tartrate 0.00014 Alimentary tract OEHHA Barium (Ba) Unspecified 0.07 Hematological OEHHA
Beryllium (Be) Be sulfate tetrahydrate 0.002 Alimentary tract OEHHA Cadmium (Cd) Unspecified 0.00006 Urinary OEHHA
Chromium (Cr) Na2Cr2O7, Cr VI 0.0002 Alimentary tract OEHHA Cobalt (Co) Unspecified 0.0003 General USEPA PPRTV
Copper (Cu) Unspecified 0.14 Alimentary tract OEHHA
Lead (Pb)a Unspecified 0.0001 Neurodevelopmental OEHHA
Manganese (Mn) Unspecified 0.14 Nervous USEPA IRIS
Molybdenum (Mo) Unspecified 0.005 General USEPA IRIS
Selenium (Se) Unspecified 0.005 General, Nervous OEHHA
Strontium (Sr) SrCO3 0.6 General USEPA IRIS
Thallium (Tl) Tl2SO4 0.00001 General, Alimentary
tract OEHHA
Tin (Sn) Stannous chloride 0.03 General OEHHA
Vanadium (V) NaVO3 0.00007 Urinary USEPA PPRTV
Zinc (Zn) Unspecified 0.3 General USEPA IRIS
a See text above regarding lead toxicity criterion

4.6.3. Lifetime Oral Exposure to Carcinogenic Metals and Metalloids There were three carcinogenic metals and metalloids for consideration for the oral route: arsenic, chromium (as Cr (VI)), and lead. The oral cancer slope factors (CSForal) these chemicals were established by OEHHA and are provided below in (Table 4-17).

Appendix section E.2.3.11 provides additional details and sources of the values.

Table 4-16. Human Cancer Slope Factors for Lifetime Oral Exposure to Carcinogenic Metals and Metalloids (CSForal)
Chemical (Symbol) Chemical
Basis
CSForal
(mg per kg per day)-1 Tumor Organ System
Arsenic (As) Unspecified 9 Respiratory, Urinary
Chromium (Cr) Chromium VI 0.5 Alimentary tract
Lead (Pb) Lead 0.0057 Renal
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4.7. Summary
OEHHA used available information and health-protective approaches in compiling the toxicity criteria and cancer slope factors to be used in the risk assessment of human exposure to chemicals at synthetic turf fields. Toxicity criteria for many were chemicalspecific either established by OEHHA, USEPA, and ATSDR; or derived new as screening values for this study from dose response data in toxicity studies. However, for many chemicals, the toxicity criteria were from structural analogs. Route-to-route extrapolation to estimate inhalation toxicity criteria from oral studies and vice versa was applied in several instances for chemicals when the reference criterion was based on systemic effects.

All the cancer slope factors (CSFs) are chemical-specific, except for three PAHs. For these PAHs, information is available to establish potency equivalency factors (PEFs).

These PEFs were applied to derive the CSFs from BaP.

4.8. References
ATSDR. Toxicological Profiles. https://www.atsdr.cdc.gov/toxprofiledocs/index.html.

Chen C, Tang Y, Jiang X, et al. (2012). Early postnatal benzo(a)pyrene exposure in Sprague-Dawley rats causes persistent neurobehavioral impairments that emerge postnatally and continue into adolescence and adulthood. Toxicol Sci 125(1): 248-261.

OEHHA. Chemicals Library. https://oehha.ca.gov/chemicals.

OEHHA (2004). No Significant Risk Levels (NSRLS) for the Proposition 65 Carcinogens Benzo[b]fluoranthene, Benzo[j]fluoranthene, Chrysene, Dibenzo[a,h]pyrene, Dibenzo[a,i]pyrene, and 5-Methylchrysene by the Oral Route. Sacramento, CA, Office of Environmental Health Hazard Assessment, California Environmental Protection Agency.

OEHHA (2008). Air Toxics Hot Spots. Risk Assessment Guidelines: Technical Support Document For the Derivation of Noncancer Reference Exposure Levels Oakland, CA, Office of Environmental Health Hazard Assessment, California Environmental Protection Agency.

OEHHA (2009). Technical Support Document for Cancer Potency Factors:

Methodologies for derivation, listing of available values, and adjustments to allow for early life stage exposures. Sacramento, CA, Office of Environmental Health Hazard Assessment, California Environmental Protection Agency.

OEHHA (2015). Air Toxics Hot Spots Program Appendices G-J: Guidance Manual for Preparation of Health Risk Assessments. Sacramento, CA, Office of Environmental Health Hazard Assessment, California Environmental Protection Agency.

USEPA. Integrated Risk Information System. https://www.epa.gov/iris.

USEPA. Provisional Peer-Reviewed Toxicity Values (PPRTVs). https://www.epa.gov/pprtv.
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USEPA (1998a). Chromium (VI) ; CASRN 18540-29-9. IRIS Summary, Integrated Risk Information System. U.S. Environmental Protection Agency.

USEPA (1998b). Chromium(III), insoluble salts; CASRN 16065-83-1. IRIS Summary, Integrated Risk Information System. U.S. Environmental Protection Agency.

USEPA (2000). Chromium Compounds: Hazard Summary. Washington, DC, U.S.

Environmental Protection Agency.

USEPA (2016). Toxicological Review of Trimethylbenzenes: Executive Summary.

Washington, DC, Integrated Risk Information System, National Center for Environmental Assessment, Office of Research and Development, U.S. Environmental Protection Agency.

USEPA (2021). Dose Response Assessment Tables
USEPA (2023). "CompTox Chemicals Dashboard." from
https://comptox.epa.gov/dashboard.

VEGA. "Virtual Models for Property Evaluation of Chemicals within a Global Architecture (VEGA) models." from https://www.vegahub.eu/portfolio-item/vega-qsar/. 4-217
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Chapter 5. Exposure Characterization

5.1. Background
Across California, there are over 900 synthetic turf fields with crumb rubber infill1. These fields hold various team sport events like soccer and football. Currently, approximately more than 228,000 soccer athletes are represented by northern and southern California soccer associations2. The study focused on examining the exposure of soccer players (athletes) and other soccer-related participants (coaches, referees, and spectators), due to the popularity of soccer in California among all genders, and close and frequent contacts of players with the field surfaces. Since soccer can be a life-long sport for some participants, exposure duration of players on synthetic turf fields can span from a few years to decades. Taken together, OEHHA determined soccer to be an appropriate surrogate for athletic activities on synthetic turf fields.

In order to evaluate the exposure of soccer players and other users of synthetic turf fields, their activities and exposure patterns had to be characterized. To do this, OEHHA collaborated with the University of California, Berkeley (UCB) and the University of Arizona (UA) to conduct three Time-Activity Studies (TAS, referring to all three studies):
• TAS Survey: OEHHA surveyed soccer players’ activity patterns, histories, and behaviors at the field (Appendix Section F.2).
• TAS Observation Study: UCB and OEHHA videotaped volunteers during soccer practices or games at selected synthetic turf fields in Northern California.

Researchers at UA translated these video footages into micro-level activity time series (MLATS) data— type and frequency of activities and behaviors occurred on and off fields (Appendix Section F.3).
• TAS Archive Study: UA translated video footage into MLATS data of an archived studies of behaviors of young children during play (Appendix Section F.2).

These studies are described in Section 5.3 below.

OEHHA applied the survey and MLATS data to derive model parameters for various exposure scenarios (Appendix Sections B.2 to B.5) such as field play by athletes of various ages. An overview of how these parameters were estimated is also provided in Section 5.3 below. The parameters were used to estimate the levels of chemical exposures in this chapter. Section 5.4 provides an overview of how these parameters 1 OEHHA compiled our Synthetic Turf Field Database (last updated March 2017) with data collected by the California Department of Resources Recycling and Recovery (CalRecycle). The database does not include sports fields on federal facilities, fields not reported to CalRecycle by installers, or fields that did not receive funding from CalRecycle.
2 Estimated number of soccer athletes based on data from Cal North (https://www.calnorth.org/parentguide) and Cal South (https://calsouth.com/what-we-do/). 4-218
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were integrated with the concentration data measured in air samples and biofluids to estimate exposure to spectators and athletes of various ages, coaches and referees.

These exposures were used to assess the associated human health risks for these groups in Chapter 6.

5.2. Synthetic Turf Exposure Model: Exposure Scenarios
OEHHA developed an exposure model describing scenarios of human exposure to chemicals released from crumb rubber infill of synthetic turf fields (Figure 5-1). The model describes the potential exposure pathways by which for athletes, coaches, referees and spectators are exposed through the inhalation, dermal, and ingestion routes. For example, it illustrates how gases from synthetic turf are released into the air and breathed in by all four types of human receptors (athletes, coaches, referees and spectators).

Figure 5-1. Exposure Model: Transfer of Chemicals from Crumb Rubber, via Exposure Pathways, to Human Receptor Categories

5.2.1. Exposure Sources
Synthetic turf fields often contain three major structural parts: synthetic grass blades, backing materials, and crumb rubber infill. This study focuses on exposure people to chemicals in crumb rubber infill, for example, when chemicals, which have varying volatility, evaporate from the infill and are breathed in. 4-219
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Although, windblown dust particles, or surface water runoff from the field may lead to exposures for off-field spectators, these are expected to be significantly lower than the other exposures scenarios. The model shown in Figure 5-1 and the exposure discussions and evaluations in this report do not cover these off-field exposures. The scope of this study also does not cover ecological receptors, so did not analyze, for example, runoff to streams potentially resulting in exposure of fish to toxic metals and organic chemicals.

5.2.2. Receptor Categories
Athlete, coach, referee, and spectators are the primary receptor categories on synthetic turf fields. OEHHA adopted the following age groups to represent the individuals in the spectator category: third trimester fetus in pregnant women, 0<2, 2<6, 6<11, 11<16, 16<30, 30<40, 40<50, and 50<70 years. However, all these age group were not considered for other categories, such as athletes. Table 5-1 shows the age groups considered for each receptor category.

We chose these age groupings based on the rapidly changing physiology of young children, and differences in activity and behavior patterns among children and adults of different ages. These factors may affect a receptor’s exposure level, due for example to different breathing rates during playing the game, while watching it or hand to mouth activity. Appendix Section B.2 provides a discussion of the age groupings in the context of exposure parameter selection. Based on the results of the TAS (Appendix Sections F.2 and F.3), we developed age-specific exposure parameters for each receptor category. We also used survey information to inform our exposure framework, such as the age intervals for the assessment. Appendix Sections B.2 to Section B.5 describe the development of exposure parameters for each receptor category, age group, and exposure pathway. The following sections briefly discuss the four receptor categories.

Table 5-1. Age Groups Considered for Exposure Assessment for Each Receptor Group Age Group Exposure for age group assessed?
Athletes Coaches Referees Spectators
Third trimester fetus No
No No
Yes
0<2 years
2<6 years
Yes
6<11 years
11<16 years
16<30 years
Yes Yes 30<40 years
40<50 years
50<70 years

5.2.2.1. Athletes
Athletes are soccer players, from ages 2 to 70 years, who take part in soccer practices 4-220
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and games in a seasonal or year-round schedule. Athletes on organized soccer teams can play in one or multiple positions (forward, mid-fielder, defense or wingback, and goalkeeper). There are different activity characteristics among these soccer positions, leading to different levels of exposure. In the TAS Observation Study, scientists at the UA quantified the micro-and macro-activities among the different positions. The TAS Survey also provides self-reported physical data such as bodyweight and soccer activity data for athletes. OEHHA used these TAS results to estimate study-specific exposure parameters for athletes in various age groups (Appendix Sections B.2 through B.5).

5.2.2.2. Coaches and Referees
Coaches are late teen and adult soccer team leaders and trainers, assumed in the study to be 16 years of age or older. In addition to coaching, they often organize and lead team practices, and schedule games. They share similar exposure parameters with the athletes. Referees are game officials, also assumed to be 16 years old or older, who enforce game rules and provide arbitration on field activities. They are present during soccer games. Although the TAS did not collect coach- or referee-specific data, OEHHA used information from the athletes to estimate the values of exposure parameters for these two receptor categories.

5.2.2.3. Spectators
Spectators are typically the family or friends of athletes, who observe soccer activities from near or off the field, ranging in age from ages 0-70 years. The TAS Archive Study provides behavioral data such as hand-to-mouth activity to estimate the values of some exposure parameters for young child spectators. OEHHA used literature values to estimate the exposure parameters for adolescent and adult spectators. Additionally, we applied results from the TAS Survey, such for as the number of practices and games they observed each year, to develop soccer-specific exposure data for spectators.

5.2.3. Exposure Pathways
The main pathways of human exposure to chemicals from synthetic turf fields can be grouped by routes of exposure:
• inhalation pathways: inhaling chemical vapors and airborne fine particulate matter (e.g., PM2.5) released from crumb while participating in or watching games and practices
• dermal pathways: direct skin contact with crumb rubber or, to a lesser extent, vapors released into the air and permeating the skin and suspended particles reaching the skin and releasing chemicals.
• ingestion pathways: direct intentional and unintentional (“incidental”) ingestion of crumb rubber or its indirect ingestion through hand-to-mouth, hand-to-object-tomouth, or object-to-mouth behavior 4-221
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OEHHA incorporated the values for activity and behavioral parameters estimated from the TAS and the chemical concentrations measured in samples of crumb rubber and air taken during the statewide sampling of fields (Phase 3) to derive the exposure doses and exposure concentrations for these exposure pathways (shown in Figure 5-1).

5.2.3.1. Inhalation Exposure Pathway
Inhalation exposure to crumb rubber infill results from the breathing of air that contains chemical vapors or airborne fine particulate matter released from the infill. Among all the receptor categories, OEHHA expects athletes to have the highest exposure through this pathway. Running on the field may stir up particles into the air which athletes, who have elevated breathing rates, inhale. This increased breathing rate also increase their exposures to chemical vapors released from crumb rubber. Falling or sliding of athletes on the field may also re-suspend particles into the air in the breathing zone of the athletes. Goalkeepers may have higher exposures through constant diving onto the field surface, especially during practices, as they inhale particles and chemical vapor in the air just above the field surface. Due to their higher activity levels on the field, coaches and referees also have correspondingly higher inhalation rates and thus higher inhalation exposures than spectators. Spectators have the low- to moderate-activity levels associated with sitting, standing, and cheering.

5.2.3.2. Dermal Exposure Pathways
Dermal exposure to chemicals in crumb rubber infill occurs when the adhered chemical residues permeate the skin and enter the body. This exposure can occur indirectly when the skin comes in contact with chemicals released into the air or onto objects (carriers) and take them up. These different modes of exposure are further described below.

Direct Dermal Exposure Pathway
Direct dermal exposure pathway refers to the scenario when there is direct skin contact with the field surface. Crumb rubber particles may adhere to the skin during the contact.

Chemicals can migrate from the adhered particles onto the skin, where they become available for dermal uptake. Moisture or personal care products on the skin surface, like sweat and sun block, respectively, may enhance adhesion of crumb rubber particles onto the skin and facilitate transfer of chemicals across the skin.

Because of the moderate climate in California, athletes often dress lightly (short sleeve shirts and short pants) during outdoor practices and games. Their uncovered arms and legs can come into direct and frequent contact with the field surfaces during warm-up exercises (e.g., sit-ups and push-ups); while pushing off the field with hands to maintain balance or get up after a fall; and when lunging, jumping, and falling repeatedly on the field. Goalkeepers may be especially exposed.

While coaches routinely spend time on the field, they have less skin contact with the field compared to athletes. They seldom fall and do not dive onto the turf like athletes. 4-222
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They typically stand on the sidelines of the field during the entire game. Similarly, referees have less direct dermal contact with the field surface. However, some level of dermal exposure can occur for the coaches and referees, as crumb rubber can get into the shoes and under the socks during walking or running on the field.

Spectators may sit directly on the field surface to watch the practices or games.

Indirect Dermal Exposure Pathways
Dermal exposure may also occur indirectly through deposition of chemicals from the air to the skin. On hot days, the temperature can enhance the release of volatile organic chemicals (VOCs) and semi-volatile organic chemicals (SVOCs) from the field into the air. Dermal exposure to VOCs and SVOCs is expected to be much smaller by this pathway compared to direct inhalation exposure (OEHHA, 2000). Ball kicking, running, and tackling activities, during soccer practices and games, may also agitate the field surface and disperse crumb rubber particles into the air. The resulting airborne fine particles may also settle onto the skin of players, where the chemicals may be absorbed by the skin and eventually into the body. Athletes, coaches, referees, and spectators may have continuous indirect dermal exposure of chemicals via this mechanism as well.

However, the magnitude is expected to be minor compared to that resulting from direct dermal contact with the field. Because the indirect dermal exposure pathways for vapor and deposition of particles on skin were assumed to be minimal in comparison with other pathways, they were not further assessed.

However, indirect dermal exposure may occur through transfer of chemicals or particles to the skin by an object. Objects such as soccer balls, soccer gloves, and shoes are in constant or frequent contact with the field surface. The interactions between these objects and the field surface lead to transfer of chemicals or fine particles onto the objects. Subsequent dermal contact with these objects may transfer the adhered chemicals or particles from the objects to the skin where they can be absorbed into the body. This indirect dermal pathway can occur for all human receptor categories. Hands, lower legs, and forehead of the athletes can in frequent contact with these objects before, during, and after practices or games: athletes head the ball to score, handle or get hit by the balls, put on and take off shoes and gloves. Coaches and referees often have dermal contact as they handle balls and remove and put on their shoes.

Spectators can be exposed this way, for example, by assisting in handling soccer equipment, playing with the soccer equipment after the practices or games, or picking up their water bottles left on the field.

5.2.3.3. Ingestion Exposure Pathways
Ingestion exposure occurs when particles of any size get in the mouth and are ingested. 4-223
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Ingestion of particles while engaging in activities on synthetic turf fields can happen either by direct or indirect pathways.

Direct Ingestion Exposure Pathways
Direct ingestion exposure pathways consist of intentional ingestion and unintentional incidental ingestion. OEHHA assumed the direct ingestion exposure pathways to occur for athletes of all ages and young spectators (0 to <2 and 2 to <11 age groups), but not for coaches, referees, or adult spectators.

Intentional ingestion exposure occurs when someone knowingly or purposefully eats crumb rubber. OEHHA did not anticipate intentional ingestion behaviors to be a significant exposure pathway for adult spectators, athletes, coaches, and referees.

However, toddlers and young child spectators may crawl around on and play with the crumb rubber on the sidelines of the field during sport events. Some young children may intentionally ingest varied amounts of crumb rubber in a sport event. Uncommonly, this pathway may be important for young children, particularly those who exhibit pica behavior.

Incidental ingestion of crumb rubber occurs when particles accidently enter the mouth and are swallowed. OEHHA assumed that this pathway occurs for athletes of all ages.

Falling onto the field or diving onto the field surface while playing soccer agitates the field and disperses particles of various sizes into the air. Athletes may incidentally ingest these airborne particles. This may be an especially important exposure pathway for goalkeepers, who often lunge across the goal to block the ball and often land face-down onto the field surface. OEHHA deemed this direct ingestion pathway unimportant for coaches, referees, and adult spectators, since they seldom fall or dive onto the field.

Indirect Ingestion Exposure Pathway
Indirect incidental ingestion occurs via carriers (e.g., hands or objects): chemicals or particles transferred from the field to carriers eventually enter the mouth via the following mechanisms:
• hand-to-mouth (HTM)
• object-to-mouth (OTM)
• hand-to-object-to-mouth (HTOTM)
OEHHA considered the indirect ingestion exposure pathway to occur for all receptor categories and in all age groups. However, the exposure level may vary greatly among the age groups and individuals.

Hand-to-Mouth Behaviors. Hands or fingers may come into direct contact with the field, or indirectly via objects that have contacted with the field, and then through touching transfer material to the mouth or the peri-buccal area. Hand-to-mouth behaviors can directly or indirectly transfer fine particles and chemical residues from the field and onto the face or into the mouth.
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All receptors of all ages may engage in HTM behaviors, although the frequency can vary. Common examples of the HTM behaviors observed on the field are toddler and young child spectators crawling on the sidelines of the field or playing with crumb rubber and then sucking their fingers. Athletes or spectators may bite their fingernails, touch their mouth (e.g., braces or mouth guard) or face (or teammate’s face), or use their hands to wipe away sweat on their face. Coaches and referees may touch their face with their hands after touching the soccer ball and transfer chemical residues or fine particles to the mouth or the peri-buccal area.

Object-to-Mouth Behaviors. Objects may come into contact with the field and then be put into the mouth or they may touch the peri-buccal area. The object acts as a carrier that may transfer fine particles or chemical residues from the field into the mouth.

OEHHA considered OTM behaviors to occur for all receptor categories.

There are a number of common examples of OTM behaviors. To take their gloves off, some goalkeepers grab their gloves with their teeth. Athletes use their clothes to wipe away sweat on their face. Athletes or spectators leave their water bottles on the field and drink through the drinking spouts that have come into contact with the field.

Mouthing behaviors include touching the face or mouth with objects or putting them into the mouth, as well as licking, sucking, chewing, and biting are common in young children and adolescents (Groot et al., 1998). Coaches and referees accidentally drop their whistles on the field and may blow through the uncleaned whistles.

Hand-to-Object-to-Mouth Behaviors. Hands may come into contact with the field, which then pick up an object and the object may then be put into mouth. Hand-to-objectto-mouth activities involve indirectly transfer of fine particles or chemical residues from the field via the hand, to a carrier object and then into the mouth when the carrier touches to or near the mouth. This exposure pathway involves two carriers, the hand and then the object. OEHHA anticipated the level of exposure from each event of HTOTM to be lower than that of HTM or OTM. Similar to the HTM pathway, we considered the HTOTM exposure pathway to occur for all receptor categories.

Mouthing behaviors are common in toddlers and young children. They may touch the field or crumb rubber and use their unwashed hands to pick up an object, such as a pacifier or a toy, and ultimately put the objects into their mouth. Athletes and spectators may touch the field surface and then handle food with their unwashed hands (OEHHA, 2012), or touch the drinking spout of their water bottles and drink through it. Spectators may put arms of their sunglasses into their month while watching a practice or game.

Coaches or referees may exhibit HTOTM behaviors (e.g., blowing a whistle). Even though coaches and referees rarely have direct dermal contact with the field surface, indirect ingestion exposure may still occur through a sequence of events such as indirect dermal exposure activity (touching an object that had contact with the field surface) followed by a HTOTM activity (coach or referee holds the ball and then picks up the whistle and blows). Depending on the frequency of these event sequences, 4-225
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individuals may have various levels of exposure through the indirect ingestion pathway.

5.3. Development of Exposure Parameters

5.3.1. Time-Activity Studies (TAS) to Estimate Exposure Parameters This section describes the three Time Activity Studies (TAS) used to characterize the activity patterns and exposure of soccer players, coaches, referees and spectators – the survey of soccer players, field observational study, and study analyzing of the archived video recordings of children playing. These studies focused on soccer activities occurring on synthetic turf fields with crumb rubber infill. These studies enhanced OEHHA’s understanding of the models of exposure discussed in Section 5.2, and enabled the derivation of soccer-specific exposure parameters that were incorporated with chemical analysis results to estimate levels of chemical exposures, which in turn were used to derived human health risk for athletes, spectators, coaches and referees of various ages.

OEHHA and its UCB and UA collaborators utilized two approaches to obtain the timeactivity data of soccer players:
• a survey of players, which is reported in full in Appendix Section F.2, and • field observation of games and practices, study reported in full in Appendix Section F.3, and on archived video, study reported in full in Appendix Section F.2.

We received approval from the Institutional Review Boards of the State of California (i.e., Committee for the Protection of Human Subjects) for the UCB, and the UA to conduct these studies according to the authorized human subject protocols.

5.3.1.1. TAS Survey of the Soccer Players
UCB in collaboration with OEHHA conducted an online or in-person survey of soccer players in California that played on synthetic turf fields with crumb rubber infill. The online survey is described at length in Appendix Section F.1.2.3, and the similar inperson survey in Appendix Section F.1.2.4. Participants were aged 4 through 71. The goal was to collect information on roughly 1,000 players to inform parameter estimates related to, for example, duration of exposure and frequency of exposure, breathing rates during play, and the potential for dermal and ingestion exposures. Parents of soccer players under the age of 18 were invited to complete the online survey for their child.

For the in-person survey, parent/guardian was asked to complete the questionnaire for participants younger than 14 years.

With these surveys, we gathered information on soccer activities of players engaged in during practices and games, and the types of direct contact they had with the field.

Activities of interest included on- and off-field activities such as soccer drills, dive or fall on the field, snacking or drinking, and other activities on the sidelines that might result in 4-226
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exposure. Also, the Survey requested information on the frequency of practices or games, types of uniforms worn, personal hygiene practices, and soccer history of the participating players.

Researchers at the UCB recruited soccer players for the in-person interviews through contacting soccer coaches and team managers in the Sacramento and San Francisco Bay Areas. Additionally, they solicited players and parents of players to participate in the online survey through contacting coaches and team managers of soccer clubs in California.

Overall, we received 1,029 on-line questionnaires and 40 completed in-person questionnaires. The participants with in-person questionnaires were also videotaped (see next section).

Figure 5-2. Heat Map of Zip Code Reported by Online Survey Participants Figure 5-2 is a heat map of the residential zip code reported in the online survey. The majority of the survey respondents were located in the San Francisco, Sacramento, Los Angeles, and San Diego metropolitan areas. These are the California regions with the greatest population, and where most of the synthetic turf field with crumb rubber infill are located. See Section 2.3.1.

Results of the online and in-person surveys are presented in Appendix Section F.1.3.

OEHHA compiled and analyzed responses to the questionnaires to estimate several of the exposure parameters. Appendix Sections B.2 to B.5 provide details of parameter development.
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5.3.1.2. TAS Field Observation Study of Players during Soccer Games and Practices
UCB and OEHHA videotaped 40 consenting soccer players during events and translated the videos into MLATS data. The players videotaped also completed the inperson surveys discussed above. Activities occurring both on and off field were recorded. Appendix Section F.1.2.4 describes the methods used.

Players were videotaped during five practices and five games. On average, we videotaped four participants per event, one for each of the four soccer positions:
forward, defender, midfielder, and goalkeeper. For each event, we continuously videotaped the participants from the time they entered the field until they left the field at the conclusion of a soccer event. Thus, on and off field activities of these players were captured. Table 5-2 summarizes players videotaped, types of event, and positions they played.

Table 5-2. Videotaping Player and Event Summary (Total Players=40) Event
Type Gender Age (Years) Positions Videotaped Number of Players Game Male 9 Defender, Goalie, Variable (2) 4
Game Female 9 Defender/Goalie, Midfielder (2) 3
Practice Female 11-12 Defender, Defender/Goalie, Forward, Midfielder 4 Practice Male 11-12 Forward, Goalie, Midfielder 4
Practice Female 14 Defender/Midfielder, Forward, Forward/Goalie, Forward/Midfielder 4
Game Male 14-15 Defender, Forward, Goalie (2), Midfielder 5 Game Female 16-17 Defender (2), Defender/Forward/Goalie, Forward 4 Game Male 16-18 Defender (2), Goalie, Midfielder 4
Practice Male 19-22 Defender, Defender/Midfielder, Goalie, Midfielder 4 Practice Female 19-21 Defender, Goalie, Midfielder (2) 4 Researchers at the UA translated the video footage using Virtual Timing DeviceTM, videotaping methodologies and video-translation software developed at Stanford University (Beamer et al., 2008; Beamer et al., 2012; Ferguson et al., 2006). In this way we obtained data on the duration and frequency of contacts occurring on and off the field. Briefly, while viewing the video footage on a player, the translator interacted with a video palette to record data (Appendix Section F.1.2.4.4). Every palette contained grids that represented different designations such as location, object, or contact type. The translator activated cells in each grid of the palette that correlated with the activity and contact that occurred in the video. Once the translator activated a cell, the software activated a timer to record the length of each activity and contact. Through this process, 4-228
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the software captured the activity data and translated video footage into contact frequencies and durations for the types of contacts examined. The translator repeated this recording step to gather data for all the body parts and the types of contact of interest.

OEHHA used the activity data to develop parameters used in the exposure assessment.

For example, the dermal contact frequencies with turf fields were used in the assessment of hand-to-mouth ingestion and to evaluate surface area estimates for dermal contact could be derived (Appendix Section B.4.1.1).

5.3.1.3. TAS Archived Video Study of Young Children
UA reviewed and translated video footage from previous studies on children in outdoor settings:
• Outdoor Residential Exposure Task Force Project: 36 children aged 1-12 years were videotaped for 2 hours in a primarily outdoor residential environment to examine mouthing frequency, contact duration, mouthing contacts with hands and non-dietary objects (AuYeung et al., 2006; AuYeung et al., 2004; Ferguson et al., 2006)
• USEPA study from the years 1998-2000: 20 children aged 1- 6 years were videotaped for 2 hours to examine contact activity of the hands and mouth in a primarily outdoor residential environment (Beamer et al., 2012; Ferguson et al., 2006)
The videotapes covering the 56 children playing were watched and footage was analyzed where children were playing on turf or a playground. The same methodologies as used for the TAS Observation Study (section 5.3.2) were used to gather MLATS data on the hand-to-mouth activity of young children playing outdoors. OEHHA used these data to develop indirect ingestion exposure parameters for child spectators on the synthetic turf field sidelines.

The UA report of this study is reproduced in full in Appendix Section F.2.

5.3.2. Information from the Literature to Estimate Exposure Parameters Some parameters such as breathing rates were constructed from survey information and values in the published literature. For example, in deriving breathing rates, survey and videotape information on exertion levels was used in concert with published OEHHA guidance values for breathing rates at different levels of exertion (OEHHA (2012), See Table 5-3). This was done to derive overall breathing rates for different receptor groups at different ages.

Table 5-3. Mean One-Hour Breathing Rates for Different Activity Levelsa 4-229
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Age Group
Breathing rate (cubic meters per hour)
Resting Activity Light Activity Moderate
Activity High Activity
0<2 years 0.23a 0.58 1.06 Not applicableb
2<6 years 0.26 0.68 1.25a 2.24a
6<11 years 0.37 1.04 1.49 3.87
11<16 years 0.46 0.96 1.26 5.37
16<70 years 0.41 1.38 2.35 8.43 a See Appendix Section B.5.3 for explanation. b Individuals 0<2 years of age were assumed not to engage in high intensity activities (OEHHA, 2012).

Another example of adoption of literature values is OEHHA’s use of direct ingestion rates for crumb rubber from assumptions in published risk assessment reports for crumb rubber from the (European Chemical Agency, 2017; National Institute for Public Health and the Environment, 2017).

See Appendix Sections B.2 to B.5 for further examples on how the literature was used to develop parameter values.

5.3.3. Exposure Parameters Estimated
OEHHA analyzed and incorporated data from the literature and the three TAS described above to develop the exposure parameters used in estimating chemical exposures from crumb rubber infill. The approach to parameter estimation is described in Appendix Section B.1.

For athletes, coaches, referees and spectators of different ages, parameter values assigned included the following:
• Bodyweight
• Event frequency: Number of events participated in annually • Event time: Amount of time spent on or near the field during an event • Annual event time: Hours per year of exposure
• Route specific factors
o Breathing rates, dependent on age and exertion level during events o Skin surface area of specific parts of the body
o Adherence factor to skin
o Absorption factor by inhalation, oral and dermal routes o Crumb rubber ingestion rate per hour for hand-to-mouth, object-to-mouth, and hand-to-object-to mouth activities
See Appendix Sections B.2 to B.5 for details.
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5.4. Exposure Assessment
The objective of the exposure assessment is to estimate the doses and concentrations resulting from crumb rubber infill that soccer players, coaches, referees and spectators experience. These estimates are then used in non-cancer and cancer risk calculations for these groups. OEHHA incorporated data from the three Time Activity Studies described above and from the literature to develop exposure parameters to use in the exposure calculations, described in Section 5.3 above. These exposure calculations take in to account the variety of pathways by exposure to chemicals from crumb rubber infill can occur to these four receptor groups, described in Section 5.2.

Measurements of chemicals in biofluids, described in Chapter 3, are combined with parameter estimates (e.g., receptor specific ingestion rates) to derive average daily doses (ADD) received by ingestion and dermal routes for receptors of different ages.

Similarly, concentrations of chemicals measured in air on the fields are appropriately adjusted using parameters of duration of exposure and other considerations to derive concentrations to represent acute, one-day, and chronic inhalation exposures for the different receptor groups.

Exposure estimates depend on the type of toxicity being assessed. For this study, OEHHA adopted the term “general chemicals” for chemicals with their most sensitive non-cancer effect being neither sensory irritation nor DART. This was necessary because different exposure assumptions (e.g., exposure frequency and exposure duration) were applied in the exposure calculations for general chemicals compared to sensory irritants and DARTs (see Sections 5.4.2 and 5.4.3). Exposures to DARTs are assessed as a one-day exposure, whereas sensory irritants and general chemicals are assessed on a chronic exposure basis (See Section 5.4.4). For each carcinogen, a lifetime average exposure dose is derived, and age sensitivity factors are used to account for enhanced susceptibility to carcinogens early in life (OEHHA, 2012).

For the study, the following groupings were employed:
• one-hour acute exposures for acute toxicity assessment • one-day exposures to developmental and reproductive toxicants (DART) • chronic exposures to sensory irritants
• chronic exposure to general chemicals (most sensitive non-cancer endpoint neither sensory irritation nor DART)
• lifetime exposures to carcinogens
This section describes the approaches used to estimate exposure concentrations and doses for each of these exposure classes, for the different pathways of exposures, receptors and age groupings.
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5.4.1. One-Hour Acute Exposures
Acute, high exposures to several of the detected chemicals in air can lead to adverse health outcomes on the respiratory and circulatory systems and eyes (See Chapter 4, Table 4-3). To assess the risks of acute inhalation exposure, OEHHA has developed reference concentrations that apply to chemical exposures for one hour on an intermittent basis (OEHHA, 1999).

In this study, we collected samples sequentially over one-hour periods for VOCs and carbonyls, and over a three-hour period for SVOCs (See Section 2.3.2.3). To represent the acute concentration (Acute Cinh) for assessing acute toxicity, we took the maximum concentration of each chemical measured in air at any of the 35 synthetic turf fields during soccer activities (Cair-max). Thus, the acute concentration, Acute Cinh, that represents an acute exposure to a chemical via inhalation pathway is simply given by:

where,
Cair-max = maximum one-hour concentration of a chemical detected in air on- or off-field, among the 35 fields in the study, micrograms per cubic meter Table 5-4 provides these concentrations (see also Appendix Section B.3.4.1). Samples were collected at on- and off-field locations. The Acute Cin in the on-field column in Table 5-4 represents the maximum concentration of the chemical detected in a single sample at any of the 35 fields at on field locations (Cair-max) during soccer activities. The off-field Acute Cinh is similarly the Cair-max at the off field locations for any of the fields.

Table 5-4. Acute Concentrations of Chemicals in Air (Acute Cinh)a at On- and Off-Field Locations
Chemicalb CASRN Acute Cinh, micrograms per cubic meter air On Field Off Fieldc
Field-Related Chemical
Styrene 100-42-5 1.6 1.4
Non-Field Related Chemicals
Acetaldehyde 75-07-0 9.7 not sampled
Benzene 71-43-2 3.7 3.5
2-Butanone 78-93-3 1.9 not sampled
2-Butoxyethanol 111-76-2 1.0 0.48
Formaldehyde 50-00-0 17 not sampled
Phenol 108-95-2 0.21 0.21
Tetrachloroethylene 127-18-4 0.42 0.42
Toluene 108-88-3 12 10
m/p-Xylene 106-42-3 5.2 5.2
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Chemicalb CASRN Acute Cinh, micrograms per cubic meter air On Field Off Fieldc
o-Xylene 95-47-6 2.1 2.0 a Acute Cinh is the maximum concentration measured in any of the 35 fields. See text for explanation. b Only chemicals assessed for acute non-cancer hazard are shown in the table. c Selected carbonyls were not sampled at off the field locations. See Section 2.3.2.3, CASRN: Chemical Abstracts Service Registry Number. Values are rounded to two significant figures.

Acute doses via ingestion and dermal routes are not presented in lieu of the one-day and chronic exposure and risk analyses. See Section 6.2.2 for further explanation.

5.4.2. One-Day Exposures to DART
As a precautionary measure, OEHHA compares one-day exposures to DART reference values in this study, even when the values are taken from chronic reference levels under the EPA IRIS or CA Toxic Hot Spots programs, as discussed in Section 4.2.4.

This was done instead of comparing an annual average concentration to the reference concentrations or reference doses. This worse case assumption was used to screen for potential DART hazard. Where hazards are identified, further analyses will be undertaken to consider their significance.

5.4.2.1. One-Day DART Inhalation Concentration: Cinh-DART-field OEHHA derived field-specific exposure concentrations for one-day inhalation exposure to a DART (Cinh-DART-field, Equation 5-2). This was done by multiplying the measured air concentration of the chemical for the field (Cair-field) by an adjustment factor (AFinh-DART) to account for the length of time for the event and other factors such as receptor breathing rates during an event:

where
Cair-field = field-specific average concentrations of a DART in air, in nanograms per cubic meter air. Concentrations on- and off- field, are provided Appendix Section D.4.2.3.

AFinh-DART = adjustment factor that accounts for breathing rate and duration of exposure during the event, for a receptor category in an age group, unitless, provided in Table 5-5.

The above provides Cinh-DART-field, in units of nanograms per cubic meter air. It can be expressed in units milligrams per kilogram bodyweight per day by dividing by 1,000,000.

For a full discussion on the derivation of the values for Cinh-DART-field for the different fields see Appendix Section B.3.4.2.
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Values for Cinh-DART-field for the various fields are given in Appendix Section F.4.4.

Table 5-5. AFinh-DART (unitless) for Different Receptors Categories at Different Ages Age Group (Years) Athletes Spectators Coaches Referees
Third trimester fetus Not applicable 0.049
Not applicable Not applicable
0<2 0.40
2<6 0.73 0.21
6<11 0.55 0.20
11<16 0.46 0.086
16<30 0.68 0.057 0.29 0.27
30<40 0.45 0.050 0.25 0.23
40<50 0.45 0.050 0.25 0.24
50<70 0.49 0.050 0.25 0.24
Values are rounded to two significant figures.

Appendix Sections B.3.4.2 and F.XX describe the calculation of AFinh-DART from the TAS data.

5.4.2.2. One-Day DART Average Dose for Dermal Pathways: ADder-DART-field The calculation of the amount of a chemical in crumb rubber that is received by dermal pathways accounts for the amount of crumb rubber adhered on the skin during an event. This is referred to as the dermal loading, or DL, and is discussed at length in Appendix Section B.4.1. Multiplying this amount by the measured concentration of the chemical in simulated sweat – that is the “bioaccessible concentration” (Cder-crumb rubberfield, Section 3.2.4) – provides an estimate of the amount of chemical in crumb rubber that is taken up by the body during the event. To express this in terms of a dose, this is then divided by the bodyweight of the receptor coming into dermal contact with the crumb rubber. A factor can also be applied to account for the fraction of the bioaccessible concentration that is absorbed into the body (see Appendix Section B.4.3). However, in this screening assessment absorption it is conservatively assumed to be 100%. Finally, it is assumed that receptors are exposed during one event on any given day.

Thus, ADder-DART-field, the average one-day dose of chemicals in crumb rubber infill resulting from dermal contact, is given by Equation 5-3. It is specific to the ages of athletes and spectators.

ADder−DART−field =
DL × Cder−crumb rubber−field
BW
Equation 5-3
where,
DL = mean total loading of crumb rubber particles on the skin in an event, in grams per event, given in Table 5-6 for the various groups Cder-crumb rubber-field = field-specific average dermal bioaccessible concentration in 4-234
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artificial sweat extracts of crumb rubber, nanograms chemical per gram crumb rubber (tabulated in Section 3.2.4)
BW = bodyweight of an age group, kilograms, given in Table 5-7.

The resulting ADder-DART-field is expressed in units nanograms per kilogram bodyweight per day. It can be expressed in units milligrams per kilogram bodyweight per day by dividing by 1,000,000. Values for ADder-DART-field are summarized in Appendix Section F.5.2.

Table 5-6. Synthetic Turf Study Mean Dermal Loading (DL), in grams Crumb Rubber per Event
Ages (years) Athletes Spectators Coaches,
Referees
Third trimester fetusa
Not applicable 0.072
Not applicable
0<2 0.048
2<6 0.077 0.077
6<11 0.11 0.11
11<16 0.14 0.14
16<30 0.17 0.078 0.083
30<40 0.18 0.084 0.089
40<50 0.18 0.083 0.089
50<70 0.18 0.083 0.089
Appendix Section B.4.1 describes the equation, TAS survey data, and assumptions used to calculate the dermal load for each group. Values are rounded to two significant figures.

Table 5-7. Mean Bodyweight (BW, kilograms)a used in the Synthetic Turf Study Age Group Mean BW
Third trimester fetusb 75.6
0<2 years 9.4
2<6 yearsc 20.5
6<11 years 32.0
11<16 years 48.7
16<30 years 65.8
30<40 years 75.3
40<50 years 74.5
50<70 years 74.3 a Appendix Section B.2.2 provides the details on the derivation of bodyweights used in this study. b To evaluate exposure to third trimester fetuses, the BW of third trimester pregnant women is used, as discussed in Appendix Section B.2.2.

5.4.2.3. One-Day DART Average Dose for Ingestion Pathways: ADing-DART-field To calculate the amount of a chemical received by ingesting crumb rubber, the measured bioaccessible concentration for the chemical (CGI-crumb rubber-field) is multiplied by the amount of crumb rubber ingested during the event. To express this in terms of a 4-235
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dose, this is then divided by the bodyweight of the receptor consuming the crumb rubber. A factor can also be applied to account for the fraction of bioaccessible concentration that is absorbed into the body (see Appendix Section B.5.2). However, in this screening assessment absorption is conservatively assumed to be 100%. Finally, it is assumed that receptors are exposed during one event on any given day.

Thus, ADing-DART-field, the average one-day dose for ingestion of chemicals in crumb rubber infill, is given by Equation 5-4, and calculated separately for receptor groups of different ages:

ADing−DART−field = CGI−crumb rubber−field × IRDART
BW Equation 5-4
where,
CGI-crumb rubber-field = field-specific average GI bioaccessible concentrations of a DART in crumb rubber, nanograms chemical per gram crumb rubber (see Appendix Section D.4.1.3.3)
IRDART = ingested amount of crumb rubber on the day of the event, in grams.

Amounts for different groups are given in Table 5-8.

BW = bodyweight of an age group, kilograms, given in Table 5-7 above The ADing-DART-field calculated as above is expressed in units nanograms per kilogram bodyweight per day. It can be converted to units milligrams per kilogram bodyweight per day by dividing by 1,000,000.

Table 5-8. Ingestion Rate (IRDART): Grams of Crumb Rubber Ingested on the Day of an Event, for Assessing Exposure to Developmental and Reproductive Toxicants Age Group Athletes Coaches, Referees Spectators
Third trimester
fetus Not applicable
Not applicable

0.042
0<2 years 0.36
2<6 years 0.30 0.37
6<11 years 0.30 0.40
11<16 years 0.29 0.049
16<30 years 0.32 0.092 0.038
30<40 years 0.31 0.099 0.041
40<50 years 0.30 0.095 0.038
50<70 years 0.30 0.095 0.038
Appendix Section B.5.4 describes the equation, exposure parameters, and assumptions used to calculate the IRDART for each receptor category and age group. Values here are rounded to two significant figures.

5.4.2.4. Example: One Day DART Exposures to Benzo(a)pyrene Table 5-9 shows the results of the exposure calculations for athletes of different ages to 4-236
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the DART benzo(a)pyrene (CASRN 50-32-8). For each age category, it shows the highest “max” and lowest “min” exposure values for the 35 fields. It also shows the mean value for the 35 fields. Exposure estimates such as these will be used in the assessment of a chemical’s potential to pose a reproductive health risk from crumb rubber infill.

Appendix Section G.1 presents further details on the calculations used in this example.

In that case doses are given in units milligram per kilogram. The values in Table 5-9 can be converted to those units by dividing by 1,000,000.

Table 5-9. Exposures of Athletes (Combined Gender) to Benzo(a)pyrene by Different Routes
Age
Group,
years
Inhalation: Cinh-DART-field,
nanograms per cubic
meter air
Dermal: ADder-DART-field,
nanograms per kilogram
Oral: ADing-DART-field,
nanograms per kilogram
Min Mean Max Min Mean Max Min Mean Max
2<6 0 0.83 3.4 0 0.7 2.8 7.0 35 1.0
6<11 0 0.63 2.6 0 0.63 2.6 4.4 22 66
11<16 0 0.52 2.2 0 0.54 0.22 2.8 14 42
16<30 0 0.77 3.2 0 0.47 1.9 2.2 11 33
30<40 0 0.52 2.1 0 0.44 1.8 1.9 9.8 29
40<50 0 0.52 2.1 0 0.45 1.8 1.9 9.6 28
50<70 0 0.56 2.3 0 0.45 1.8 1.9 9.6 28
Values are rounded to two significant figures.

5.4.3. Chronic Exposure to Sensory Irritants
For this study, chronic inhalation exposure to sensory irritants (Section 4.4.2) was done in precautionary fashion by making no adjustment for a less than 365 days per year and a less than 24 hours per day exposure in estimating the chronic sensory concentration, Chronic Cinh-sensory (Equation 5-5). For each on- and off- field calculation, two values for a chemical, two concentration values were produced to evaluate the sensory hazard: 1) The mean value for the 35 field average concentrations in air during soccer activities for the three hour period under active field conditions (Cair-avg, details in Section 3.4.6 and Appendix Section D.4.2.3); and 2) the maximum of the average concentrations of the 35 fields under active field conditions. These are provided in Table 5-10. The assumption in applying these concentrations in the chronic context is that receptors would be exposed repeatedly to the measured levels.
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Chronic Cinh−sensory = Cair−avg
Equation 5-5
where,
Cair-avg = average air concentration measured during active field conditions, in nanograms per cubic meter. See Table 3-10 for mean value and maximum values for the 35 fields, and Appendix Section D.4.2.3 for details.

Table 5-10. Chronic Concentrations of Sensory Irritants in Air (Chronic Cinh-sensory) – Detected in the Statewide Study during Active Field Conditions Chemicala CASRN
Chronic Cinh-sensory
nanograms per cubic meter
On Fieldc Off Fieldc
Mean Max Mean Max
Field-Related Chemical
Styrene 100-42-5 59 660 60 670
Non-Field Related Chemicals
Acetaldehyde 75-07-0 2500 9600
not sampled
Formaldehyde 50-00-0 3800 16000
a Only sensory irritants with available chronic toxicity criteria are shown in the table. b Mean - average of 35 field average concentrations (active field conditions). Max - maximum of 35 field (active field conditions). Values are rounded to two significant figures. Values also in Table 3-10. c Selected carbonyls, including acetaldehyde and formaldehyde, were not sampled at off the field locations. See Section 3.4 for details.

5.4.4. Chronic Exposures to General Chemicals
General chemicals are toxicants causing adverse health effects upon chronic exposure via one or more pathways. DARTs and sensory irritations are evaluated separately and not included in this group when those endpoints show greater sensitivity than the other toxicities (See Sections 5.4.2 and 5.4.3).

Chronic exposures were estimated from the concentrations measured in air and biofluid extracts in the field sampling described in Chapter 3. Before discussing the adjustments made to calculate chronic exposures, OEHHA’s approach to selecting representative field concentrations to use in those calculations is discussed.

Averaging of concentrations – individual field. One question for characterizing concentrations for was whether to average concentrations taken at different locations.

For example, results are available for GI and dermal biofluid concentrations separately 4-238
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for high impact (“HI”) areas, such as in the two goal areas in a soccer field, and in the rest of the field (“ROF”). However, on average HI to ROF sample results were quite similar (Appendix Section D.4.1.4.3). Also VOCs air samples are available for multiple field locations. One consideration is that during soccer practices, athletes conduct various sport activities, such as warm-up exercise and soccer drills, across the field.

During soccer games, the teams are required to switch sides during halftime. The TAS Survey data show that approximately one-third of participants play multiple positions, regardless of categorization based on age, gender, or soccer type. Of those who reported playing multiple positions, approximately 75 percent reported playing two positions, and 25 percent reported playing three positions. The survey was a snapshot in time and over time, players also take up different positions. OEHHA, therefore, used average concentration of a chemical for an individual field to estimate the levels of chronic exposure for athletes for that field.

Integrating concentration information from different fields. Concentration levels measured in air and crumb rubber infill varied for the 35 fields studied. School-aged soccer players conduct sport activities at home fields as they progress in education levels (from elementary to high schools). Generally, fields at neighborhood schools and local sport clubs are their home fields. Soccer players, especially those at competitive level, often attend multiple local and statewide soccer tournaments during sport seasons. Taken together, soccer players and family spectators most likely have exposures at multiple synthetic turf fields—not limited to their neighborhood fields, but also fields across the State. OEHHA therefore evaluated two different exposure scenarios. One derived average daily doses (ADDs) for ingestion and dermal pathways and concentration in air (Cair-avg) by averaging values for the 35 individual fields. Under this scenario it is assumed that levels of chemical detected in samples collected across California can be combined to properly represent the exposure levels for the chronic exposures of the various receptor categories. The second scenario assumed that the local field was dominant source of exposure, and so ADDs and air concentrations were evaluated for each individual field. This enabled the consideration of the distributions of exposure across the 35 fields, including maximum levels seen.

Thus, the mean concentrations of chemicals measured in air and in biofluids across the 35 fields, as well as those for the individual fields, unpin the estimates of chronic exposure. The chronic exposure estimates for the different field users were developed from these values by adjusting for
• duration of exposure - less than 365 days per year and a less than 24 hours per day,
• activities on- and off- field by different receptor/age categories such as dermal contact with crumb rubber infill and intentional and unintentional ingestion of the infill, and
• physiological factors such as bodyweights and breathing rates for the different 4-239
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receptor groups.

5.4.4.1. Chronic Exposures to General Chemicals by Inhalation Pathways:

Chronic Cinh
OEHHA applied a receptor- and age- specific adjustment factor (AFinh) to measured air concentrations to estimate the chronic inhalation exposure, in terms of a chronic concentration (Chronic Cinh), to general chemicals for each receptor and age group:

Chronic Cinh = Cair−avg × AFinh
Equation 5-6
where:

Cair-avg = average air concentration measured during active field conditions, in nanograms per cubic meter. See Table 3-10 for mean value and maximum values for the 35 fields, and Appendix Section D.4.2.3 for details.

AFinh = receptor-dependent adjustment factor applied to estimate chronic exposure to a chemical for a receptor category in an age group, unitless, shown in Table 5-11
Table 5-11. Adjustment Factor (AFinh, unitless) Applied to Measured Air Concentrationsa to Estimate Chronic Inhalation Exposure to General Chemicals Age Group (years) Athletes Spectators Coaches Referees
Third Trimester Fetus
Not applicable

0.021
Not applicable Not applicable
0<2 0.17
2<6 0.16 0.087
6<11 0.20 0.083
11<16 0.20 0.036
16<30 0.37 0.024 0.15 0.057
30<40 0.24 0.021 0.13 0.050
40<50 0.24 0.021 0.14 0.050
50<70 0.23 0.021 0.14 0.050 a Concentrations measured under active field conditions. Appendix Section B.3.4 describes the equation and exposure parameters used to calculate receptor and age-specific values of AFinh. Values are rounded to two significant figures.

The receptor- and age-specific AFinh addresses, among other things, the less than 365 days per year and less than 24 hours per day exposures for events played on synthetic turf fields, for each receptor category and the specific age group. It also covers other pertinent features, such as the increased breathing rates during soccer activities and Appendix B.3.4.3 provides the details and calculation of AFinh with study-specific 4-240
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exposure parameters derived from the TAS data.

Appendix F.4.6 summarizes values of Chronic Cinh for athletes, coaches, referees and spectators of different ages.

5.4.4.2. Chronic Exposures to General Chemicals by Dermal Pathways: Chronic ADDder
Chronic exposures via dermal pathways are expressed as an average daily dose (ADDder for dermal pathway). This is calculated for the general chemicals by considering the dermal loading of crumb rubber infill onto the skin, as discussed in section xx above, factors related to the length of time of exposure, and the concentration of bioaccessible chemicals. Typically absorption by the dermal route is taken into account; in the current calculations the conservative approach of assuming 100% absorption being taken.

Thus, the ADDder is calculating using the following equation:

ADDder = DL × Cder−crumb rubber × EV × CF
BW Equation 5-7
where,
DL = mean total loading of crumb rubber particles on the skin in each event, grams crumb rubber per event, shown in Table 5-6 above.

Cder-crumb rubber = the bioaccessible concentration of a general chemical in artificial sweat extracts of crumb rubber, in nanograms chemical per gram crumb rubber. See Table 3-3 for the mean value and maximum values for the 35 fields. See Appendix Section D.4.1.3 for further details.

EV = number of field events per year, shown in Table 5-12 for different receptor and age groups, and discussed in Appendix Section B.2.3.

CF = conversion factor, equal to 1 year per 365 days
BW= bodyweight of an age group, in kilograms, provided in Table 5-7 above This results in an ADDder expressed in units of nanograms per kilogram bodyweight. It can be expressed in units of milligrams per kilogram bodyweight per day by dividing by 1,000,000. Values for ADDder for the various receptors and ages are provided in Appendix Section F.5.3
Table 5-12. Practice and Game Event Frequencya (EV, Events Per Year) Age Group
(years) Athletes Spectators Coaches Referees
Third trimester
fetusa Not applicable 161 Not applicable Not applicable 0<2 2<6 139
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Age Group
(years) Athletes Spectators Coaches Referees
6<11 121
11<16 149
16<30 215
215 86 30<40 163
40<50 137
50<70 138 a Derived from TAS data. Appendix Section B.2.3 provides the details and discussion of EV. Table values are rounded to the nearest whole integer.

5.4.4.3. Chronic Exposures to General Chemicals by Ingestion Pathways: Chronic ADDing
Similarly, chronic exposure via ingestion pathways is expressed as an average daily dose (ADDing). This is calculated for general chemicals by considering the rate of intentional and incidental ingestion rate of crumb rubber infill by various groups, as discussed in section xx above, and the concentration of bioaccessible chemicals measured in GI extracts (See Sections 3.2.3 and 3.3.3). The calculations conservatively assume 100% absorption by the oral route. The ADDing , average daily dose of general chemical via the ingestion pathway, is calculated using the following equation:

ADDing = CGI−crumb rubber × IRdaily
BW Equation 5-8
where,
CGI-crumb rubber = GI bioaccessible concentrations, in nanograms per gram crumb rubber. Mean and maximum of values for 35 fields is provided in Tables 3- 2 and 3-4. Fuller reporting is in Appendix Section D.4.1.

IRdaily = daily average amount of crumb rubber ingested per day, in grams per day, shown in Table 5-13.

BW= bodyweight of an age group, in kilograms, provided in Table 5-7 above Calculations with these parameters results in an ADDing in units of nanograms per kilogram bodyweight per day. It can be expressed in units of milligrams per bodyweight per day, by dividing by 1,000,000.

Values for ADDing are summarized in Appendix Section F.5.6.

Table 5-13. Daily Average Ingestion Rate for Crumb Rubber (IRdaily), in grams crumb rubber per day
Ages (years) Athletes Spectators Coaches Referees
Third trimester
fetus Not applicable 0.018a
Not applicable Not applicable
0<2 0.15
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Ages (years) Athletes Spectators Coaches Referees
2<6 0.095 0.16
6<11 0.099 0.17
11<16 0.12 0.021
16<30 0.18 0.016 0.045 0.020
30<40 0.14 0.017 0.048 0.021
40<50 0.11 0.016 0.046 0.020
50<70 0.12 0.016 0.046 0.020 a Value is based on female spectators 16<40 year old estimate exposure to third trimester fetuses via the mother.

Appendix Section B.5.3 describes the equation, exposure parameters, and assumptions used to calculate the IRdaily for each receptor category and age group. Values are rounded to two significant figures.

5.4.4.4. Example: Chronic Exposures to Benz[a]anthracene by Different Pathways Table 5-14 shows the results of the exposure calculations for athletes of different ages to the general chemical benz[a]anthracene. For each age category, it shows the highest “maximum” value for any field and average exposure values across fields in the statewide sampling. Exposure estimates such as these will be used in the assessment of a chemical’s potential to pose a general chemical toxicity hazard from crumb rubber infill.

Table 5-14. Chronic Exposure Estimates for Athletes (Combined Genders) to Benz[a]anthracene (CASRN 56-55-3) by Inhalation, Dermal and Ingestion Pathways Ages
(Years)
Inhalation: Chronic Cinha,
nanograms per cubic
meter air
Dermal: ADDderb,
nanograms per kilogram
bodyweight per day
Ingestion: ADDingc,
nanograms per kilogram
bodyweight per day
Average maximum average maximum average maximum
2<6 0.00078 0.27 0.35 1.8 13 58
6<11 0.00098 0.34 0.28 1.5 9.0 40
11<16 0.00098 0.34 0.29 1.5 7.0 31
16<30 0.0018 0.63 0.37 1.9 7.8 35
30<40 0.0012 0.41 0.26 1.4 5.2 23
40<50 0.0012 0.41 0.22 1.1 4.4 20
50<70 0.0011 0.39 0.22 1.1 4.5 20 a The average was derived using the On-Field average across fields of 0.0049 nanograms per cubic meter air (Table 3-10). It was only detected for one of 34 fields, at a level of 1.7 nanograms per cubic meter.
b Derived using the average across 35 fields of Cder-crumb rubber of 0.25 ng per gram and a maximum field with a value of 1.3 nanograms per gram (Table 3-3). c Derived using the average across 35 fields of CGI-crumb rubber = 2.9 ng per gram and the value for the field with the maximum measurement of 13 nanograms per gram (Table 3-2).

Values are rounded to two significant figures.

5.4.5. Carcinogens – Lifetime Average Daily Dose
OEHHA assessed exposures to carcinogens for each receptor category through the three exposure routes. The approach to identifying a chemical as a carcinogen for the 4-243
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purpose of the study is discussed in Section 4.2. The goal for the exposure assessment is to the estimate lifetime average doses for each carcinogen, that adjusts for the enhanced susceptibility to carcinogens early in life, following OEHHA guidance (OEHHA, 2012). For this study, we defined a lifetime exposure as the period from thirdtrimester fetus to 70 years old. The fetal exposure was included since under OEHHA guidance there is a presumption of increased sensitivity to carcinogens during this period of pregnancy.

The LADD for carcinogens was calculated for each exposure route and receptor group in steps:
• The average daily doses to the carcinogen for different age groups are estimated by incorporating measured concentrations of chemicals in air and biofluids with exposure parameters.
• For each receptor group (e.g., spectators), the average daily dose for a given age grouping is time-weighted by an age susceptibility factor, and then averaged over a lifetime of 70 years. This produces the lifetime average daily dose, or LADD, for that receptor and age group.

Also, similar to what was done for chronic exposure to general chemicals, calculations were done to create a mean estimate of LADD for each chemical using its mean concentration across the 35 fields. In addition, calculations were done for each of the 35 fields, assuming that was the predominant field of play.

5.4.5.1. Lifetime Average Daily Doses via Inhalation: LADDinh Calculation of the average daily inhalation dose for each receptor age group. For each receptor and for each age group for that receptor, the LADD calculation starts with accounting for the breathing rates for the different receptors of different ages, especially the increased breathing rates of athletes during play. It is assumed that the higher the breathing rate, the higher the exposure to the carcinogen. Table 5-15 shows the onehour time weighted breathing rates (BRTW) for athletes and different receptors during games, practices and while observing these activities.

Table 5-15. One-Hour Time Weighted Breathing Rates (BRTW) for different activities, in cubic meters air per hour a
Ages (years)
Athletes Coaches Referees
Spectators Practice Game Practice Game Game
Third
trimester
fetusa Not
applicable
Not
applicable Not
applicable
Not
applicable
Not
applicable

0.4a
0<2 0.4
2<6 1.4 1.5 0.5
6<11 2.3 2.3 0.7
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Ages (years)
Athletes Coaches Referees
Spectators Practice Game Practice Game Game
11<16 2.8 2.9 0.5
16<30 4.2 4.4

1.9 1.6 1.6 0.4
30<40 3.6 4.0
40<50 3.9 4.0
50<70 4.1 4.4
a Appendix Section B.3.2 describes the equation and exposure parameters used to calculate the one hour breathing rates. Values are rounded to one decimal place. a Values are estimated using the breathing rates for 16<40 year old females to evaluate exposure via the mother to the third trimester fetus.

Within an age group these breathing rates for games and practices can then be multiplied by the hours each year spent in these activities each year, that is the “annual event time” (AET) to calculate the cubic meters breathed in a year in these activities.

OEHHA derived these values from the TAS survey data (see Appendix Section B.2.5).

When divided by the number of days in a year, this produces a daily average breathing rate for the year for the activity. Thus, the average soccer related daily breathing rate (for a given age group and receptor) can be represented as:

𝐴𝐴𝐴𝐴𝐴𝐴 = � ( BRTW ×
event type
AET) × CF Equation 5-9
where,
BRTW = time-weighted one-hour breathing rate for an event type, cubic meters per hour. Table 5-15 shows these values for receptor category and age groups
AET = annual event time spent on the field, hours per year. Table 5-16 provides values of AET for different receptor categories and age groups for event types, namely games and practices.

CF = conversion factor, equal to 1 year per 365 days. This converts the annual breathing rate to an average daily breathing rate, “ABR”.

The resulting average soccer related breathing rate ABR is in units cubic meters per day.

Table 5-16. Synthetic Turf Study Annual Event Time (AET) a in Hours Per Year
Ages
(years)
Athletes Coaches Referees Spectators
Practice Game Practice Game Game Practice Game
Third
trimester
fetus
Not
applicable
Not
applicable
Not
applicable
Not
applicable
Not
applicable 156 241
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Ages
(years)
Athletes Coaches Referees Spectators
Practice Game Practice Game Game Practice Game
0<2
2<6 126 104
6<11 156b 137
11<16 223 129
16<30 354c 241b
354 241 241 30<40 343 167
40<50 256 214
50<70 187 239 a Appendix Section B.2.5 describes the equation, TAS survey data, and assumptions used to calculate the annual event time for each receptor category and age group. Values are rounded to nearest whole integer.

Once the breathing rate is estimated for an age and receptor group, the average daily dose by the inhalation route for that group can be calculated. Multiplying the breathing rate by the air concentration breathed in (Cair-avg) gives amount breathed in. If the concentration is in nanograms per cubic meter the resulting amount is in nanograms.

Dividing this by the bodyweight in kilograms provides the dose estimate for that age group in nanograms per kilogram bodyweight per day. Thus, ADDinh = Cair−avg × 𝐴𝐴𝐴𝐴𝐴𝐴
BW
Equation 5-10
where,
Cair-avg = average air concentrations measured during active field condition, in nanograms per cubic meter air. Values may be used for an individual field in provided in Appendix Section 4.2.3, or the mean of 35 individual fields provided in Table 3-10 of Section 3.4.6.

ABR = daily average breathing rate for soccer related activity, as described in text above.

BW= bodyweight of an age group, in kilograms, provided in Table 5-7 above Appendix Section F.5.1 provides ADDinh, in Tables F-180 to F-184 using the mean values for the 35 fields, and in Tables F-185 to F-217 for individual fields.

Calculation of the LADD for inhalation for each receptor group. This calculation takes the ADDinh for the different age groupings for a given receptor and time-weights it by an age sensitivity factor, or ASF, to account for varying sensitivity to the effects of exposure to a carcinogen with age (OEHHA, 2012’s Appendix J). The ASF modifies a chemical’s cancer potency. This age group-dependent factor, along with the exposure duration, ED, which is also age-dependent, are included in the calculation of LADD. The equation used is:
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LADDinh = ADDinh × ASF × ED
AT Equation 5-11
where,
ADDinh = the average daily dose of a carcinogen for the inhalation pathway, for an age group within a receptor category, as discussed in the previous subsection.

ASF = the age sensitivity factor for a given age group, unitless, provided in Table 5-17.

ED = exposure duration of an age group, in years. For example, a child spends 4 years of life in the 2<6 years age group. See Table 5-17 for values.

AT = the default number of years of life used in OEHHA cancer risk assessment, 70 years (OEHHA, 2015; Appendix Section B.6.2)
When the ADDinh is expressed in nanograms per kilogram per day, the resulting LADDinh is in those units as well. To convert to milligrams per kilogram per day, the number would be divided by 1,000,000.

Table 5-17. Age Sensitivity Factors (ASF, unitless) and Exposure Duration (years) for Cancer Risk Assessment
Age Group Exposure Duration, years ASF
Third trimester fetus 0.25 10 0<2 years 2
2<6 years 4
6<11 years 5 3
11<16 years 5
16<30 years 14
1 30<40 years 10
40<50 years 10
50<70 years 20
Appendix Section B.6.2 provides the details and discussion of ASF.

For an example of this calculation see Appendix section G.1.2.

5.4.5.2. Lifetime Average Daily Doses via dermal pathways: LADDder There are differences across receptor groups and ages in dermal contact with crumb rubber infill that is explicitly accounted for in estimating the average daily dermal dose (ADDder) for these groups. Equation 5-7 above to calculate chronic exposure to general chemicals for the different age groups applies here as well, with the same input parameters, including the dermal loading (DL) values that varied across the receptor age categories. See Section 5.4.4.2. The ADDder results for these different groups are 4-247
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reported in the tables in Appendix Section F.5.4.

The calculation of the lifetime average daily dose for the dermal route LADDder for a receptor and age group takes the same form as for inhalation exposures discussed above:

LADDder = ADDder × ASF × ED
AT Equation 5-12
The parameters ASF, ED, and AT are the same and carry the same meaning as in previous section 5.4.5.1. For the LADDder calculation, however, the age and receptor specific dermal average daily dose values ADDder are used. LADDder values are compiled in tables in Appendix Section F.6.2.

5.4.5.3. Lifetime Average Daily Doses via ingestion pathways: LADDing There are substantial differences in ingestion doses of crumb rubber across the age and receptor groups and these are captured in the ADDing calculations. The ADDing calculations are the same as for chronic exposure to general chemicals, following Equation 5-8. Values for the ADDinh can be found in tables in Appendix Section F.5.7.

The calculation of the lifetime average daily dose for the ingestion route (LADDing) for a receptor and age group takes the same form as for inhalation and dermal exposures discussed above:

LADDing = ADDing × ASF × ED
AT Equation 5-13
with the identical meaning for the parameters in the equation with the exception that the ingestion average daily dose (ADDing) for receptor age groups is used instead those for the other pathways.

The ingestion LADDing values are compiled in tables in Appendix Section F.6.3.

5.4.5.4. Example of Lifetime Average Daily Dose Result for Receptors for the Three Exposure Routes
Table 5-18 shows the results of the lifetime exposure calculations for each receptor category to the carcinogen benzo[a]pyrene. For each receptor category, it shows the average LADD value for each exposure route. Exposure estimates such as these will be used in the assessment of a chemical’s potential to pose a risk from crumb rubber infill. 4-248
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Table 5-18. Lifetime Average Daily Doses to different groups to Benzo[a]pyrene (CASRN 50-32-8), in units nanogram per kilogram per day Ages
(Years)
Inhalation
LADDinh
Dermal
LADDder
Ingestion
LADDing
Average Maximum Average Maximum Average Maximum
2<6 0.0019 0.0056 0.000045 0.00019 0.0019 0.0056
6<11 0.0016 0.0046 0.000045 0.00018 0.0016 0.0046
11<16 0.0012 0.0036 0.000047 0.00019 0.0012 0.0036
16<30 0.0013 0.0037 0.000056 0.00023 0.0013 0.0037
30<40 0.00061 0.0018 0.000028 0.00012 0.00061 0.0018
40<50 0.00052 0.0015 0.000024 0.00010 0.00052 0.0015
50<70 0.0011 0.0031 0.000048 0.00020 0.0011 0.0031
Values are rounded to two significant figures.

5.5. References
AuYeung W, Canales R, Beamer P, et al. (2006). Young Children's Hand Contact Activities: An Observational Study Via Videotaping in Primarily Outdoor Residential Settings. J Expo Sci Environ Epidemiol 16: 434-446.

AuYeung W, Canales RA, Beamer P, et al. (2004). Young Children's Mouthing Behavior: An Observational Study via Videotaping in a Primarily Outdoor Residential Setting. Journal of Children's Health 2(3-4): 271-295.

Beamer P, Key ME, Ferguson AC, et al. (2008). Quantified activity pattern data from 6 to 27-month-old farmworker children for use in exposure assessment. Environ Res 108(2): 239-246.

Beamer PI, Luik CE, Canales RA, et al. (2012). Quantified outdoor micro-activity data for children aged 7-12-years old. J Expos Sci Environ Epidemiol 22(1): 82-92.

European Chemical Agency (2017). Annex XV Report: An Evaluation of the Possible Health Risks of Recycled Rubber Granules Used as Infill in Synthetic Turf Sports Fields Ferguson A, Canales R, Beamer P, et al. (2006). Video methods in the quantification of children's exposures. J Expos Sci Environ Epidemiol 16(3): 287-298.

Groot M, Lekkerkerk M and Steenbekkers L (1998). Mouthing behavior of young children: An observational study. H&C onderzoeksrrapport, Wageningen.

National Institute for Public Health and the Environment (2017). Evaluation of health risks of playing sports on synthetic turf pitches with rubber granulate - Scientific background document, Rijksinstituut voor Volksgezondheid en Milieu (RIVM), Ministry of Health, Welfare and Sport, Government of the Netherlands.

OEHHA (1999). Determination of Acute Reference Exposure Levels for Airborne Toxicants. Sacramento, CA, Office of Environmental Health Hazard Assessment, California Environmental Protection Agency.

OEHHA (2000). Air Toxic Hot Spots Program Risk Assessment Guidelines Part IV:

Technical Support Document for Exposure Assessment and Stochastic Analysis. 4-249
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Oakland, CA, Office of Environmental Health Hazard Assessment, California Environmental Protection Agency.

OEHHA (2012). Air Toxics Hot Spots Program Risk Assessment Guidelines: Technical Support Document for Exposure Assessment and Stochastic Analysis. Sacramento, CA, Office of Environmental Health Hazard Assessment, California Environmental Protection Agency.
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Chapter 6. Risk Characterization

6.1. Background
This study examined non-cancer hazards and cancer risks from exposure to chemicals from crumb rubber infill via multiple routes (inhalation, dermal, and ingestion) on the synthetic turf fields for four receptor categories (athletes, coaches, referees, and spectators) and their appropriate age groups. Off-site data for airborne chemicals was also collected. The study focused on the soccer player exposure scenario (i.e., athletes) in artificial turf fields, as soccer is a popular sport among players of all ages, and based on the nature of play, soccer players were exposed via most of the routes and hence probably had high exposures, hazards and risks. OEHHA assessed there was negligible exposure through: direct ingestion (intentional or incidental as described in Section

5.2.3.3) of crumb rubber for coaches and referees; and dermal or ingestion of airborne chemicals for all receptor categories. Therefore, these exposures were excluded from the evaluation of non-cancer hazards and cancer risks in this study.

Combining the results of the toxicity criteria presented in Chapter 4 and the exposure assessment presented in Chapter 5, OEHHA evaluated acute and chronic non-cancer hazards, as well as lifetime excess cancer risks (OEHHA, 2015; USEPA, 1989) for each receptor category.

Risk characterization was conducted for each chemical exposure in each receptor category (athletes, coaches, referees, and spectators), and for each appropriate age group within the receptor categories (third trimester, 0<2 years, 2<6 years, 6<11 years, 11<16 years, 16<30 years, 30<40 years, 40< 50 years, and 50<70 years). The noncancer hazards and cancer risk values were obtained for both on-field and off-field exposures to field-related chemicals and non-field-related chemicals.

For non-cancer hazards, a Hazard Quotient (HQ) for the chemical of interest in each category was calculated using the following general equation:

Hazard Quotient = Exposure Metric
Toxicity Criterion
where:

Exposure Metric refers to the exposure concentration or dose of the chemical.

For inhalation exposures, the exposure metric is an airborne concentration, whereas for dermal and ingestions exposures, the exposure metric is an average daily dose. These are presented in Appendix Sections F.4 and F.5
Toxicity Criterion refers to the chemical-specific numerical values that reflect the potency of the chemical, for the specific health (non-cancer) effect and route of exposure. These are available in Chapter 4 and Appendix E. 4-251
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Once the HQs for all the chemicals were calculated, they were summed together (HQsum). The minimum, mean, standard deviation of the mean, 95th percentile, and maximum of HQsum from the individual 35 fields for all receptor categories and age groups were calculated and provided in Appendix G.

The HQs of individual chemicals were then summed to calculate a Hazard Index (HI) to determine the non-cancer hazard posed by exposure to all the chemicals in the crumb rubber used on the artificial turf. To calculate the HI for each receptor category and age group, the HQ for inhalation, dermal, and ingestion routes were added as follows:

HI = HQinh−sum + HQder−sum + HQing−sum
where:

HQroute-sum = Summed chemical hazard quotients for an exposure route (inh:
inhalation, der: dermal, ing: ingestion)
A HI value up to 1 suggests that the chemical exposures do not present a health hazard. When the HI is above 1, it indicates an increasing but undefined probability of an adverse health impact, particularly in sensitive individuals.

Cancer risk is calculated for lifetime exposure to a carcinogen or multiple carcinogens, in terms of probability of developing cancer in excess of background incidence in a population. The background lifetime cancer risk rate is 0.2 (1 case of cancer out of 5 people) in California (CHPH 2017). From a public health perspective related to chemical exposures, one excess cancer in a population of one million people over a lifetime of 70 years is considered negligible risk or de minimis risk level. Regulatory decisions based on excess lifetime cancer risks generally use an action level between one in ten thousand and one in one million. Cancer Risk in the present study was calculated with the following general equation:

Cancer Risk = LADDx × CSFy
where:

LADDx = Lifetime Average Daily Dose integrating the age sensitivity factors specific to each age group x, as presented in Section F.6.

CSFy = Cancer Slope Factor for the route of exposure y. Inhalation and oral CSFs are available in Chapter 4 and Section E. The CSF for dermal exposures is the same as for the oral route.

The following sections present the results of HQ and HI calculated for:
• acute toxicity
• developmental and reproductive toxicity
• sensory irritation
• general chronic toxicity, and
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risks associated with lifetime exposures to carcinogens via multiple routes (inhalation, dermal, and ingestion) on or off the synthetic turf fields.

6.2. Non-Cancer Hazards: Acute Toxicity

6.2.1. Inhalation Exposure
The 11 chemicals detected and evaluated for acute inhalation hazard are listed in Table 6-1. Section 4.4.1 lists the acute TCinh for these chemicals. Using the maximum onehour measured concentration of a chemical among all the maximal concentrations of these chemicals detected in the air at the 35 individual fields, the acute HQinh for these chemicals were calculated (see Appendix Sections F.4.1 & G.2.1).

Table 6-1. Chemicals Evaluated for Acute Inhalation Hazard Field-Related
Chemicals
Non-Field-Related
Chemicals
Styrene Acetaldehyde
Benzene
2-Butanone
2-Butoxyethanol
Formaldehyde
Phenol
Tetrachloroethylene
Toluene
m/p-Xylene
o-Xylene
The on-field and off-field acute HQinh for styrene - the only field-related chemical - were

0.000077 and 0.000066, respectively. These values were well below the benchmark HQ of 1 and much lower than the sum of all acute HQinh for the non-field-related chemicals both on-field (0.47) and off-field (0.13). Acute HIinh, calculated as the sum of the acute HQinh for the 11 detected chemicals, are summarized in Table 6-2.

Table 6-2. Acute Inhalation Hazard Indexa for the Inhalation Route Chemical Group On-Field Acute HI Off-Field Acute HI
Field-Related Chemicals <0.01 <0.01
Non-Field-Related Chemicals 0.47 0.13
All Chemicals Acute HIinh 0.47 0.13
aThe acute hazard index (Acute HI) equals the sum of acute hazard quotients (Acute HQinh-sum) assessed.

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chronic health guidance values from other peer-reviewed sources (USEPA PPRTV, ATSDR MRL). In all cases, maximum air concentrations on-field and off-field were well below the sub-chronic health guidance values, which indicates that there would be no concern for acute health hazards.

6.2.2. Dermal and Ingestion Exposures
For acute dermal and ingestion exposures to chemicals in crumb rubber, the corresponding toxicity criteria were not available for conducting the assessment.

Therefore, single day exposures to field-related chemicals were compared with toxicity criteria developed by ATSDR and USEPA/PPRTV programs for durations ranging from 14 days (ATSDR MRL) to 90 days (USEPA/PPRTV). Even by comparison with such toxicity criteria, there were no cases of exceedance from single day exposure to fieldrelated chemicals in any of the 35 fields, indicating no reason for concern with health hazards associated with acute exposures by the oral or dermal route.

6.3. Non-Cancer Hazards: DART

6.3.1. Inhalation Exposure
Among the 18 DART chemicals detected for inhalation exposure (Table 6-3), 17 were considered field-related chemicals and one was considered non-field-related. The TCinh for these DART chemicals are presented in Section 4.4.3. To assess the reproductive and developmental hazards associated with inhalation of these chemicals, the average concentration (Cair-field) of only those chemicals that were detected in air on or off an individual field was used to calculate a field-specific exposure concentration (Cinh-DARTfield, see Appendix Section F.4.4). Subsequently, an HQinh-DART-field for the DART endpoint was calculated for each of the individual 35 fields.

Table 6-3. DART Chemicals Evaluated for One-Day Exposure Chemical Route Evaluated
Inhalation Dermal Ingestion
Non-Field Related Chemicals
2-Butanone X
Field-Related Chemicals
Arsenic X
2-Azacyclotridecanone X
1,4-Benzenediamine, N,N'-diphenyl- X X
Benzo[a]pyrene X X X
Benzo[e]pyrene X X X
Benzo[g,h,i]perylene X X X
Bis(2,2,6,6-tetramethyl-4-piperidyl)sebacate X X
Bis(2-Ethylhexyl)adipate X X X
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Boron X
n-Caproic acid vinyl ester X X
Chrysene X X X
Coronene X X X
Cyclohexylamine X
Cyclopenta[cd]pyrene X X X
Dicyclohexylamine X X X
N,N-Dicyclohexylmethylamine X X
Dimethyl phthalate X X X
1,3-Diphenylguanidine X
Indeno[1,2,3-cd]pyrene X X X
Methyl stearate X X X
Nickel X
4-tert-Octylphenol X X X
Phenol, 2,4-bis(1-methyl-1-phenylethyl)- X X X
Phenol, 4-(1-phenylethyl)- X X X
The only non-field-related DART chemical (2-Butanone) had a HQinh-DART-field of less than

0.01 for all the receptor categories and age groups, both on- and off-field exposures; so it is not discussed further. For field-related DART chemicals, most of the mean and maximum HQ values from off-field exposures and many from on-field exposures, were at or less than 0.01. Table 6-4 shows the groups with HQinh-DART-sum-field of more than

0.01 for field-related DARTs (all HQinh-DART-sum-field can be found in Appendix Section G.2.2). The HQinh-DART-sum-field for exposure on-field was above 1 for the athlete groups aged 11 – 70 years only, and it ranged between 1.2 and 1.8.

The HQinh-DART-sum-field values greater than 1 were driven by PAHs: benzo[a]pyrene (8 fields), indeno[1,2,3-cd]pyrene (3 fields), and chrysene (3 fields). B(a)P, which was the chemical accounting for 39 to 92% of the value of HQDART, has a DART TCinh value that is based on toxicological studies of much longer duration than one day.

Table 6-4. Field-Specifica Hazard Quotients for Field-Related DARTs Receptor
Category Age Group One-Day HQinh-DART-sum-field
Meanb Maximumc
Athletes
11<16 years 0.39 1.30
16<30 years 0.58 1.80
30<40 years 0.39 1.20
40<50 years 0.39 1.20
50<70 years 0.42 1.30
Coaches 16<30 years 0.25 0.78
30<40 years 0.21 0.68
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Receptor
Category Age Group One-Day HQinh-DART-sum-field
Meanb Maximumc
40<50 years 0.22 0.69
50<70 years 0.22 0.69
Referees
16<30 years 0.23 0.73
30<40 years 0.20 0.64
40<50 years 0.20 0.64
50<70 years 0.20 0.64
Spectators
on-field
11<16 years 0.07 0.23
16<30 years 0.05 0.15
30<40 years 0.04 0.13
40<50 years 0.04 0.14
50<70 years 0.04 0.14
Spectators
off-field
11<16 years 0.08 0.45
16<30 years 0.05 0.30
30<40 years 0.05 0.26
40<50 years 0.05 0.26
50<70 years 0.05 0.26 a 35 field-specific One-Day HQDART are included in this table. b The mean is the average mean HQinh-DART-sum-field of the 35 fields sampled c The maximum is the highest HQinh-DART-sum-field of the 35 fields sampled

6.3.2. Dermal and Oral Exposures
There were 19 DART chemicals evaluated for dermal exposure on-field and 20 DART chemicals evaluated for on-field oral exposure (Table 6-3). Their exposure metrics, ADDder-DART-field and ADDing-DART-field are presented in Appendix Sections F.5.2 and F.5.5.

The present study did not evaluate off-field dermal and oral exposures to chemicals from crumb rubber as they were not present off the field. The toxicity criteria for these chemicals (DART TCoral) are presented in Chapter Sections 4.5.1 for organic chemicals and 4.6.1 for metals and metalloids.

The HQder-DART-sum-field for each receptor and age group was calculated by summing the HQder-DART-field for all the chemicals within that group. A similar summation of the HQingDART-field for each receptor and age group was done to calculate the HQing-DART-sum-field.

There was no group that had a HQder-DART-sum-field that was greater than 0.01 (See Appendix Section G.2.5). All receptor categories and age groups also had mean and maximum HQing-DART-sum-field of less than 1. Table 6-5 shows only receptor groups with HQing-DART-sum-field of more than 0.01 as a mean or maximum value among the 35 individual fields (See Appendix Section G.5.7).
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Table 6-5. Field-Specifica Hazard Quotients for 1-day exposure to Field-Related DART chemicals
Receptor
Category
Age Group One-Day HQing-DART-sum-field
Mean Maximum
Athletes
2<6 years 0.05 0.17
6<11 years 0.03 0.11
11<16 years 0.02 0.07
16<30 years 0.02 0.06
30<40 years 0.01 0.05
40<50 years 0.01 0.05
50<70 years 0.01 0.05
Coaches
16<30 years <0.01 0.02
30<40 years <0.01 0.02
40<50 years <0.01 0.02
50<70 years <0.01 0.02
Referees
16<30 years <0.01 0.02
30<40 years <0.01 0.02
40<50 years <0.01 0.02
50<70 years <0.01 0.02
Spectators
0<2 years 0.12 0.43
2<6 years 0.06 0.20
6<11 years 0.04 0.14
11<16 years <0.01 0.01 a 35 field-specific One-Day HQDART are included in this table.

6.3.3. Hazard Index for DART
All the calculated HIDART for each receptor category and age group based on all DART chemicals and multiroute exposures can be found in Appendix Section G.2.9. Most of the calculated mean and maximal values of HIDART were at 0.01 and above for all the receptor categories and age groups on-field. Table 6-6 shows all groups with HIDART above 0.01, as at least the maximum value. The HIDART was greater than 1 for on field exposures of athletes groups aged 11 – 70 years, as detailed above in the section on inhalation exposure to DART chemicals (section 6.3.1).

Beverly Hills City CouncilJuly 15, 2025

Beverly Hills City Council
July 15, 2025