Comments for Annex XV restriction report

Substance name: Polycyclic-aromatic hydrocarbons (PAH)

EC Number: -

CAS Number: -

Scope: Restricting placing on the market of plastic, rubber and other granules containing PAHs above a set concentration limit for use as infill material on synthetic turf pitches or for use as loose granules or mulch on playgrounds and sport applications.

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  GENERAL COMMENTS
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SPECIFIC INFORMATION REQUESTS
  1: Do you have information on the PAH content of infill material not derived from ELT?
  * COMPULSORY FIELDS

  2: Do you have information on analytical methods and/or costs of testing for PAHs in ELT granules and/or infill material not derived from ELT?
  * COMPULSORY FIELDS

  3: Do you have any information on the current practices and measures used to control worker exposure during the installation and maintenance of synthetic turf pitches, playgrounds, or in other applications?
  * COMPULSORY FIELDS

  4: Do you have any information on the typical duration and frequency of exposure of professional football players and/or other athletes to synthetic turf pitches/sporting areas containing rubber granules in your Member States?
  * COMPULSORY FIELDS

  5: Section 1.5.3 of the report contains information on the measured PAH concentrations from 1 234 ELT infill samples mainly taken in the Netherlands. Do you consider the presented measurement data to be representative of the EU as a whole? If you have any additional information on measured PAH concentrations from infill used in synthetic turf pitches that has not yet been taken into consideration, please submit.
  * COMPULSORY FIELDS

  6: Apart from the proposed restriction described above, the report also details a second restriction option (RO2). RO2 would envisage a lower concentration limit of 6.5 mg/kg. What are the impacts (positive and negative) on your industry/organisation (manufacturer, distributor, importer, sports club/community owning the field) of a 6.5 mg/kg concentration limit? What are the impacts of a 17 mg/kg concentration limit?
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