This looks almost illegal - Analysis of USCPSC study on lead in synthetic turf fields

From: Nancy Alderman
Date: July 31, 2008 1:31:31 PM PDT
To: Recipient List Suppressed:;
Subject: This looks almost illegal - Analysis of USCPSC study on lead in synthetic turf fields

David Brown, Sc.D. for Environment and Human Health, Inc. evaluation of the U.S. Consumer Product Safety Commission (USCPSC) testing for lead on synthetic turf fields.

David Brown, Sc.D, Public Health Toxicologist, looked at the USCPSC "study".

The USCPSC report sampled only 10 tests on four fields. There were three samples on three fields and one sample on one other field. How many fields are there in the United States? The answer of course is thousands.
The table is padded with other turf data (less than 10) from unspecified sources with no relevancy to the fields in actual use.
They wiped an area 50 cm long and 8 cm wide (18 inches long and 3 inches wide). Your hand is about 4 inches wide and 8 inches long.
Next they divided the amount of lead found by 5 -- because they assumed that the hand is not as efficient at picking up lead as their wipe. They then divided that number obtained again by 2 -- because they assumed that only half of the lead could be taken from on's hand and then becaome ingested.

Their determination of a safe reference exposure:

1.They compared the exposure to a blood level of 10 ug/dl as their level of concern - although current peer reviewed literature clearly demonstrate health effects in children below that level.

2.They than reference a position that chronic ingestion of lead should not exceed 15 ug/day. They then incorrectly assumed that the "not to be exceeded" level was an acceptable exposure level, which it is not.

This rationale makes no sense because of the following incorrect assumptions:

Assumption 1. The child has no other exposures to lead each day. The assumption is clearly incorrect based on population studies published by the centers for Disease Control and Prevention.

Assumption 2. During an athletic activity the child only touches the surface with one hand one time each day. This assumption is ludicrous if anyone has observed any athletic activity on any playing field.

Assumption 3. That four fields would be considered adequate to evaluate the safety of the thousands of fields in the United States and then to characterize to the American people that this is a NATIONWIDE evaluation. UNBELIEVABLE

Assumption 4. It is acceptable to ignore the key chemical reaction between the acidity in the moisture on the surface and the release of lead bound in the material. A reading in a basic high school chemistry text shows that highly soluble lead carbonate dust is formed when items containing lead are exposed to air containing carbon dioxide in humid atmosphere such as occurs every morning when dew forms on the surface of the fields

Assumption 5. Most of the lead on the surface is not released on the first pass over the surface. While there may be multiple passes over the surface there is no basis for a division by 5 or any other number, most of the lead is released by the first touch although additional lead is picked up with further wipes. If the CPSC had wiped the field 100 times would they have divided the amount obtains on their sample wipe by 100?

It should be apparent to even the most casual observer that the CPSC test report cannot support any conclusion with respect to the health risk of children to exposure to lead from artificial turf fields. Moreover, lead has never been the only or even major concern from the health scientists.

Nancy Alderman, President
Environment and Human Health, Inc.
1191 Ridge Road
North Haven, CT 06473
(phone) 203-248-6582
(fax) 203-288-7571
http://www.ehhi.org