10/01/2008: "Letters About Crumb Rubber"
To the Editor:
Recent letters to the editor and an article in the Journal have not accurately described the School District and Board of Director’s position and decisions regarding the “crumb rubber” underlayment for the new playground equipment at the elementary school. Shared by everyone is the commitment and care to provide safe and healthy environments for children.
The crumb rubber underlayment was selected by the PTA and former Principal Jody Metzger due to its highly rated properties of “fall protection” for our students. Crumb rubber has been used widely for many years in the U.S. and throughout the world in artificial turf fields and playgrounds. Studies of playground injuries indicate that 80% of injuries result from falls causing bruises and fractures, and infrequently brain injury and death. Studies of the “fall protection” properties of underlayment conclude that crumb rubber provides twice the safety of the other commonly used underlayment, engineered wood fibers. Crumb rubber was selected because it provided superior safety at slightly higher cost than other options. And, as one parent noted, “the kids now bounce when they fall.”
Surprising to all was the odor coming from the playground after the crumb rubber was installed which some called offensive. Though the smell has dissipated a few have claimed it causes respiratory irritation, and this has led to concerns about possible toxicity of the recycled tire material. Toxicity studies reviewed by the District stated that there was no proof of harmful health effects. The New Jersey Department of Health reports, “available evidence suggests that there are no acute health risks, and that risks due to chronic and repeated exposure are unlikely.” Washington State and San Juan County Health Departments, as well as the District’s insurance carrier, report no ill health effects associated with crumb rubber, and continue to recommend its use. However, most studies recommend additional research to determine any potential for long term health effects including effects of trace level elements for which little data are available.
On September 24th, the school board was faced with a challenging dilemma. Would it make sense to replace the crumb rubber which is known to provide superior “fall protection” with the next best product that provides half of the safety? Would it be responsible to knowingly reduce the margin of safety for children by 50%, due to the currently unknown and “unlikely” potential for health risks which require further study? Recognizing that any underlayment product has potential disadvantages, and considering the guidance given above, the Board voted unanimously to retain the crumb rubber as the best known protection for our students. Further, the Board directed the administration to ensure that the depth of the underlayment is properly maintained, and to add access for disabled students to meet ADA compliance.
At this point the Board has found no compelling evidence or reasons to replace the “crumb rubber” with a product providing significantly less “fall protection.” However, the Board remains open to receiving additional input and research that could inform new decisions in the future, and will review its decision at the end of the school year.
We are grateful for the service and the commitment of the PTA to provide this wonderful structure for our children. We all have the welfare of our students as the highest priority. Our strength as a community is demonstrated by our ability to work cooperatively together in service to our children. Our opportunity is to demonstrate respectful and thoughtful dialog as we work through complex issues together.
Boyd Pratt, School Board Chair
Michael Soltman, Superintendent
To the Editor:
Recently, the San Juan Island School District released a press statement indicating that the Crumb Rubber would remain on the FHES Playground. In that statement, the district said "the District's legal counsel's opinion is that "there is no basis to conclude the new installation violates specific ADA accessibility standards."'.
I find this surprising, because, on September 10th, I called Cascade Rec, and spoke with Jill Thorsen. I asked Jill Thorsen "is the crumb rubber ADA compliant?" Ms. Thorsen said she would have to get back to me. A few hours later, Ms. Thorsen called to say that the Manufacturer of the Crumb Rubber, Northwest Rubber, said it is NOT ADA compliant, and that all further questions should go through Rod Turbull's office.
The manufacturer admitted it was not ADA compliant, what about that statement means it is not violating ADA law? I called the ADA's Information & Technical Assistance line, and asked, what is an ADA compliant playground cover? The person on the phone said that an ADA compliant playground cover has to be "stable and slip resistant". Perhaps the school's legal council would like to call this information line and visit the school playground. One can easily see that the crumb rubber moves, easily.
I am not an irrational person. I am not living under a misguided assumption that if the playground had a stable surface, children with physical disabilities would be cured of those disabilities. The ADA law clearly states that any facility, that receives federal funds, built after 1990 must meed ADA standards, and all areas must be accessible to all children. If you still don't understand the point I am trying to make, let me simplify. Say the school installs two water fountains - one that says "colored", and one that says "white". Would we stand for that? Why are we so accepting of this act of discrimination? The school district, and school board saying "you kids can play on here, but the "other" kids can't come with in 15 feet of this play structure and be with your friends" is an act of discrimination, plain and simple.
I admire that the school board is so concerned about the safety of our children, but I am ashamed to send my child to a school who does not know anything about ADA compliancy, and doesn't seem to care if some children can access a specific area of the school that others cannot. You would think that before someone goes and spends $50,000 they would thoroughly research the product they are buying.
King County Parks have replaced their crumb rubber underlayments with engineered wood fiber, because it moves so readily, it's surface temperature can be 20 degrees warmer than the air temperature on a sunny day, is highly flammable, and does not meet ADA standards.
I haven't been to any playgrounds that use crumb rubber (besides FHES), and while I believe that Steve Grout, the school's insurance representative, thinks there are schools and communities that believe crumb rubber is the greatest thing ever invented, I have yet to visit those communities, or have any reason to believe they actually exist.
Here's to being better informed,
A concerned FHES Parent.
To the Editor:
There is a wonderful new playground at the elementary school. However, a controversial product called “crumb rubber” was used as the ground cover. It was purchased in good faith at the recommendation of the playground manufacturer as the safest option. It is small, black, broken chunks of used tires and has a strong chemical odor reminiscent of products that come with health warnings. The manufacturer has declared it safe and non-toxic.
Proponents of crumb rubber will point to industry funded studies showing the presence of known carcinogens and respiratory irritants at levels below legal thresholds. These studies look at only a small handful of samples and don’t consider the most troubling class of chemicals: Polycyclic Aromatic Hydrocarbons. David Brown (formally of EPA, now EHHI) who has done the only comprehensive review of all the crumb rubber studies internationally has shown that in different samples, the levels of these chemicals can vary by a magnitude of 10 or even 100. His point is that we just don’t know what exposure our children are receiving from crumb rubber.
Sweden and Norway have decided that due to these “substances of very high concern”, crumb rubber “should not be used”. Italy is removing theirs. There are students and parents at Friday Harbor Elementary school who have experienced respiratory distress and skin irritation after being on the playground this year. Groups have organized against crumb rubber in New York, Connecticut, New Jersey, California and Friday Harbor.
There is an action plan for replacement of the crumb rubber with the same legally acceptable product that is used in the playground at the fairgrounds. This plan relies on an in-hand list of volunteers and would result in no additional fundraising or expense to the district due to a commitment by the manufacturer to accept return of the crumb rubber for a refund.
If you would like more information on the studies mentioned or, more importantly, would be willing to add your name to a list requesting the School Board reconsider their decision to keep the crumb rubber, please the Playground For All Group.
Playground For All
San Juan Island
To The Editor:
Sometimes first impressions are spot on. If it looks like a duck, acts like a duck and smells like a duck, is it? Most likely. If it looks and smells like chopped up discarded old tires that nobody knows what to do with and is hazardous waste that can’t go in regular landfills, what is it? It’s crumb rubber, the new playground underlayment at the elementary school. My first and remaining impression of crumb rubber is that it’s looking like hazardous waste, smells like it, and sure seems to quack like it.
I think I’m going with my gut instincts on this one.
And our family, like many, thinks we should get it out of there. Are we going to suffer it for the lifespan of that new playground? Our previous playground was in there 20 years. Take a good whiff at the school. Take a good long look at how the children burrow into it and get it all over themselves…my three children deserve better and so do yours.
To learn more visit the local action group’s blog at: www.playgroundforall.blogspot.com
Petitions can be signed at the Fitness Club, Dr. Earnhart’s office, and soon other spots around town.
If we don’t all speak up now, then when??
Shannon Calverley and family
To the Editor:
Does our community know about crumb rubber? I am writing this letter because I feel it is necessary to communicate to the folks who may not have kids in the elementary school. A multitude of families would like to replace the existing mistake with a safer alternative.
The problem is half the people think crumb rubber is perfectly fantastic (bouncy, bouncy) and the other half are beside themselves with worry because of concern for recent (asthma, bloody noses) and future health concerns (cancer). Please take a few minutes, old and young, kids or no kids to walk by and/or play in the new elementary school playground. The school board recently voted on a discussion item to keep crumb rubber.
I believe this is a community issue and not merely a school board decision because we all pay taxes. Many of us also volunteer time or money to different organizations which support public schools.
I would like us all to consider our natural defense mechanisms. If something is too bright we shield our eyes. If we hear something too loud we cover our ears. If we smell something foul we plug our nose. In most cases we might avoid a nuisance but sometimes our natural defense mechanism may be warning us about a threat to our health. I believe crumb rubber is a threat to the most vulnerable members of our community-our precious children.
Please speak up if you agree with me that a simple mistake was made. Changing out the existing crumb rubber for something similar to the playground at the fairgrounds, or any other suggestion would be helpful. You can send a quick email to firstname.lastname@example.org if you are interested in adding your name to a petition asking the school board to listen, this time, and not to ignore the many, many, concerned families.
Thanks for reading this letter.