06 October 2023
Your request
I would like to know about the precise materials used for the polymer surfacing of the new wet play on Clapham common.
To this end, please show me any invoices, or correspondence, or specifications, or methodologies, relating to the wet play and any
- SBR rubber granules
- EPDM rubber granules
- other polymer surfacing materials
- adhesives
- other materials required for this part of the construction
Our response
In March 2023 Friends of Clapham Common enquired about the materials used at the splashpad area of the Clapham Common Waterplay, before the construction commenced. Following the query, we sought further clarifications and a detailed response to all points made from the lead contractor and through them from the supplier of the wetpour material. The response was sent on 12 April 2023. The query and our response is attached.
Please see attachments*:
- RE_ Clapham Common Waterplay - materials used on the splashpad.pdf - original query dated 22.03.23 and LB Lambeth response dated 12.04.23
- Chemicals in -artificial turf SBR Infill Committee.pdf – an industry report referred to in the above response dated 12.04.23 and sent as an attachment.
- FW Clapham Common Waterplay - on site & publicity.pdf – a query sent by Gareth James to CCMAC and London Borough of Lambeth officer, which was included in the query to the lead contractor and the manufacturer of the wetpour.
Below is the full response from the manufacturer which we received on 22 March 2023:
“Yes we will be using TPV [Thermoplastic vulcanizate] and not EPDM [Ethylene Propylene Diene Monomer], however the extracted information they have provided you relates to recycled (black) rubber and when it is used in 3G grass pitches with a loose rubber infill.
Most of the studies regarding leachates and micro-plastic pollution relate to SBR infill as used in artificial turf. Much of the research is flawed or biased, but regardless the EU has proposed a ban on SBR, and other polymers, as an infill material due to the risk of microplastic contamination of water courses. Unfortunately, this is really a solution to a problem that barely exists. The industry has found a solution and that is retention and recycling solutions so that most of the SBR that comes off an artificial turf pitch is captured and returned.
If SBR rubber granules and the potential leachates were a significant issue, the EU and other authorities would be actively pushing for rubber vehicle tyres to be banned as the micro plastics created by tyre wear are thousands of times higher than even the most flawed calculation of infill migration.
I have attached a report complied for the ETRA (European Tyre Recycling Association) that details many of the studies conducted.
The question posed by is potentially due to a misunderstanding of what has been read. Micro plastic migration concerns relate to the release of rubber granules into water courses etc. Leaching typically relates to the release of chemicals from within granules. In both cases, good housekeeping on site during installation and the fact that the granules are bound together with a PU coating means that there are no known issues.
The customer has probably seen information about levels of PAH (polycyclic aromatic hydrocarbon) in the recycled rubber crumb which are carcinogenic. The issue was directly related to reports about ‘loose fill’ black rubber crumb in artificial sports surfaces and the possibility of ingestion by users. The recycled black rubber we use in play areas is bound by polyurethane binders and as such renders the product inert. However the PAH levels are extremely low if evident at all.
This is only related to black rubber crumb, coloured wetpour will not contain any trace of PAH. Any base material (when used) would be covered and bound so completely harmless (although levels of PAH have been tested in those and are also hardly traceable). Note there is no base rubber or recycled material planned for the Clapham site.
A long while back a statement was been issued by SAPCA about this issue:
‘A few years ago SAPCA became aware of concerns being voiced in some countries over the use of recycled rubber from vehicle tyres in sports and play surfaces. In response SAPCA convened a working group of UK experts to investigate the situation, and carried out a substantial review of previous national and international studies undertaken by scientists on the risks from rubber aggregates in sporting contexts. The consensus from those studies was that the rubber crumb poses no significant health risk.
Chief Executive, SAPCA’
Lambeth Council cannot comment on the report or where the materials used in any report would have been sourced but our materials are always sourced here in the UK and from reputable industry members of SAPCA and the API.
*Please note that personal data has been removed from the attached documents, as all FOI/EIR responses are published publicly and therefore we consider disclosure would breach the Data Protection Act 2018 and therefore engage Regulation 13 to this request.
The definition of personal data is set out in provision 3 of the Data Protection Act 2018 as follows:-
(2)“Personal data” means any information relating to an identified or identifiable living individual
(3)“Identifiable living individual” means a living individual who can be identified, directly or indirectly, in particular by reference to—
(a)an identifier such as a name, an identification number, location data or an online identifier, or
(b)one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of the individual.
We note this request asks for information which would allow an individual(s) to be identified.
I have considered whether it would be fair to disclose the information including whether disclosure would cause any unnecessary or unjustified damage or distress to the individual concerned; the individual’s reasonable expectations of what would happen to their information; and balancing the rights and freedoms of the data subject with legitimate interests.