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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SECTION III. Non-confidential comments

It is possible to provide both general comments on the Annex XV restriction report subject to this Public Consultation and answers to the specific questions posed. In both cases, it is necessary to provide supporting evidence to allow ECHA’s Committees to take your comments into account. It is important not to leave the submission of any socio-economic information until the public consultation on SEACs opinion but already submit relevant comments at this stage.

  Select the relevant boxes that cover the content of your comments and provide your non-confidential comments below, (maximum 9 000 characters)

  Please provide your general comments in the box below
  1: Do you have information on the PAH content of infill material not derived from ELT?

  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?

  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?

  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?

  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.

  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?

  7: Did you know about this consultation via ResearchGate? Please select “I have information on this topic” and answer YES or NO in the box below.

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