Remove & ban shredded tire mulch from Poolesville playgrounds & replace w/ safer material

 As community members and concerned parents, we urge Commissioners to remove the shredded tire mulch in all playgrounds in the town of Poolesville and replace it with safer, sustainable, certified ADA-compliant engineered wood fiber tested and verified to be free of chromated copper arsenate (CCA). We also urge town Commissioners to permanently ban any further installation of shredded tire mulch in the future due to its many potential health and environmental hazards.

Our youngest, most vulnerable populations have a right to a healthy, safe environment where they play. Children should not be exposed knowingly to materials containing contaminants like lead when safer, inexpensive, readily available alternatives like engineered wood fiber exist. Children are much more biologically and developmentally susceptible to harmful chemicals even at low exposure levels since their organs are still developing and behaviors such as increased hand-to-mouth contact and crawling put them at greater risk of harmful exposures. They also breathe more air and drink more water per body weight than adults, putting them at risk of exposure to higher concentrations of toxins in their environments. 

Below are some important reasons for taking a proactive, preventative, evidence-based approach to better protect our children and community from known hazards that shredded rubber tires present. 

• Well known hazardous chemicals found in shredded tire mulch: 
  • The science on the known hazards found in shredded tires is well documented in many studies and reports including the EPA FRAP literature review, a Yale report, UMASS Lowell Toxics Reduction Institute Playground Surfacing report, and an Environment and Human Health report. This research provides evidence of the many carcinogenic and hormone disrupting chemicals, in addition to skin, eye, and respiratory irritants that can exacerbate asthma. These chemicals found in shredded tire mulch include but are not limited to heavy metals including lead, volatile organic compounds (VOCs), polyaromatic hydrocarbons (PAH), phthalates, and PFAS.
  • Lead alone is linked to many harmful health effects including permanent neurological, behavioral, and developmental problems and cancer. There is no safe level of lead, especially for young children.
  • Other contaminants found in this material raise additional cummulative health and environmental concerns. For example, according to the EPA skin contact and breathing in PAH’s increases the risk of developing cancer and birth defects.
• Hotter temperatures means less playtime:
  • The Consumer Product Safety Commission (CPSC), Environmental Protection Agency (EPA), and Centers for Disease Control and Prevention (CDC) recommend limiting time on playgrounds with shredded tire mulch as a result of hotter surface temperatures.
• Reliance on groundwater for our town’s primary drinking water source and soil quality in the agricultural reserve:
  • There is potential for hazardous chemicals mentioned above to leach into Poolesville’s aquifers and soil, contaminating our drinking water and food in the agricultural reserve. PFAS, also known as the “forever chemical” due to its high persistence in our environment, is posing an additional health and environmental risk to our community. On August 23, 2022, two months after the Poolesville playground fire, water testing results found PFAS in well two, the same well that was nearest to the site where the playground fire took place. Banning sources of PFAS contamination such as shredded tire mulch is critical as they are very costly and difficult to remove from our drinking water.
• Relevant, common sense federal and local laws that are intended to protect communities and young children from the hazards found in tire waste:
  • There is a scrap tire law in Montgomery County that includes provisions to safely dispose of tires properly, as they contain hazardous chemicals and are a fire hazard. The unfortunate fire that took place in Poolesville playground on Fisher Avenue in June of 2022 is a good example of the potential hazards from burning such material, which could have been avoided had safer materials been in use.
  • In 2015 the Montgomery County Council unanimously passed a resolution to ban tire crumb rubber used in synthetic turf and both Montgomery County Public Schools and Montgomery Parks do not use shredded tire mulch in their playgrounds, especially since it isn’t ADA approved.
  • The Consumer Product Safety Commission has set strict limits for lead content in accessible parts of all children's products including playground equipment. Shredded tire mulch is highly accessible to children as it is loose and they often play with it. The CPSC documents the many instances of young children playing with the material and putting it in their mouths. All routes of exposure (skin and eye contact, ingestion, and inhalation) are a concern in this case.
• Benefits of removal far outweigh the costs associated with exposure to shredded tire mulch:
  • Per a study looking at Economic gains resulting from the reduction in children's exposure to lead in the United States by NIH and CDC researchers, estimated costs associated with reducing a 2-year-old child’s blood lead levels to the point where their IQ improves by just one point increases their lifetime productivity somewhere between 1.76-2.38%. Applying the lowest estimate, this translates to a present value of $22,375 (2022 dollars) of lifetime earnings for one child that otherwise would have been lost. Multiply that by the number of just 2-year-olds currently living in Poolesville today and it is clear that the resulting benefits far exceed the costs of shredded tire mulch removal. Note that this does not even factor in other healthcare costs associated with lead or other contaminant exposure.
  • Engineered wood fiber and wood chips are also less expensive than shredded tire mulch!

In light of all of this, we strongly urge the Commission to take a preventative approach to better protect and prioritize the health and well-being of our children and community.

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