--- title: When Recycling Isn't Always So Green description: When Recycling Isn't Always So Green image: https://go.adherent.com/hubfs/Imported_Blog_Media/Blog_Pitchb-150x150.jpg --- [![](https://www.complianceandrisks.com/wp-content/themes/compliancerisk/inc/img/general/compliancelogo.svg)](https://www.complianceandrisks.com/) - Products Products - - [C2P](https://www.complianceandrisks.com/c2p-compliance-knowledge-management-platform/) - [Regulations Management](https://www.complianceandrisks.com/solutions/conquering-the-regulatory-avalanche/) - [Standards Management](https://www.complianceandrisks.com/solutions/standards/) - [Requirements Management](https://www.complianceandrisks.com/solutions/heres-the-regulation-whats-next/) - [Regulatory Topics](https://www.complianceandrisks.com/solutions/regulated-areas/) - [WFSGI Compliant Labelling Requirements Database](https://www.complianceandrisks.com/WFSGI/) - Services Services - [Market Access Service](https://www.complianceandrisks.com/solutions/grow-in-new-markets/) - [Regulatory Process Consulting](https://www.complianceandrisks.com/solutions/best-practices-in-compliance-processes/) - [Environmental, Health & Safety (EH&S)](https://www.complianceandrisks.com/solutions/ehs-and-your-legal-registers/) - [Managed Services](https://www.complianceandrisks.com/solutions/solutions-for-every-day/) - [Training and Systems Implementation](https://www.complianceandrisks.com/solutions/training-and-systems-implementation/) - [Ask Our Experts](https://www.complianceandrisks.com/solutions/your-compliance-question) - Resources News & Resources - [Blog](https://blog.complianceandrisks.com/news-resources?__hstc=67571022.c37393069837d66fdddfdab74b5ad3c6.1593078357468.1593078357468.1593078357468.1&__hssc=67571022.1.1593078357469&__hsfp=693435645) - [Commentary & Analysis](https://blog.complianceandrisks.com/commentary-analysis?__hstc=67571022.c37393069837d66fdddfdab74b5ad3c6.1593078357468.1593078357468.1593078357468.1&__hssc=67571022.1.1593078357469&__hsfp=693435645) - [COVID-19](https://www.complianceandrisks.com/covid-19/) - [Webinars](https://www.complianceandrisks.com/webinars/) - [White Papers & eBooks](https://www.complianceandrisks.com/whitepapers/) - [About](https://www.complianceandrisks.com/about/) Compliance & Risks - [About Us](https://www.complianceandrisks.com/about/) - [Industries](https://www.complianceandrisks.com/compliance-requirements-industries/) - [History](https://www.complianceandrisks.com/compliance-and-risks-history/) - [Careers](https://www.complianceandrisks.com/compliance-risks-careers/) - [Knowledge Partners](https://www.complianceandrisks.com/knowledge-partners/) - [Partners & Affiliates](https://www.complianceandrisks.com/becoming-a-compliance-risks-partner/) - [Get in touch](https://www.complianceandrisks.com/contact/) COVID-19 Regulatory Developments [Find Out More](https://www.complianceandrisks.com/covid-19/) - [Book a demo](https://www.complianceandrisks.com/book-a-demo/) - [Eng](https://complianceandrisks.com) - [日本語](http://complianceandrisks.jp/) ![](https://www.complianceandrisks.com/wp-content/themes/compliancerisk/inc/img/general/burger.svg) Search for: # When Recycling Isn't Always So Green --- ##### 16 March 2016 [![EU REACH](https://go.adherent.com/hs-fs/hubfs/Imported_Blog_Media/Blog_Pitchb-150x150.jpg?width=150&height=150&name=Blog_Pitchb-150x150.jpg)](https://go.adherent.com/hubfs/Imported_Blog_Media/Blog_Pitchb.jpg) ***The Precautionary Principle: An Ethical Guideline or Corporate Policy?*** The words ‘presently’ and ‘anticipate’ are two favorite clangers. Most agree ‘presently' is misused to mean ‘now’, ‘at present’ (as in (and incorrectly) presently I’m gainfully employed) whereas it means ‘soon’ (as in presently I’ll get down to real work instead of blogging). ‘Anticipate’ is often used to mean ‘expect’ (I anticipate the St. Patrick’s day parade will be a goose-bumpy affair, so I’ll wear my long johns). Some say it means to act now in the expectation something will happen (I anticipated my blogging holiday in the sun by buying myself a pair of shades). Personally I prefer the latter but don’t lose sleep if I hear it used the other way, like I do if someone says they are disinterested when they mean uninterested. I agree, I agree, pedant, even I wouldn’t want to spend any time with myself on a desert island. Well - certainly not without a Chambers dictionary. [**EU REACH**](http://www.complianceandrisks.com/about/regulated-areas/reach/) is happening, and needs to be anticipated with appropriate compliance and process strategies. The earlier the better. Chemistry is wonderful, but poisons are not. More and more substances are making their way to the EU SVHC (Substances of Very High Concern) list and the challenge for R&D departments is to ensure they don’t use harmful chemicals at all. And thankfully the EU isn’t the only regulator determined to protect our health and the environment. It can be extremely costly to make bad chemistry choices, so manufacturers are not disinterested. Opponents of synthetic grass pitches using recycled car tires in the form of rubber crumb say our kids are playing on toxic dumps. It’s in the news in Ireland because more and more are being laid down. What’s interesting is that in trying to find creative use for used tires we might be causing serious harm. It is accepted that rubber crumb contains PAH (Polycyclic Aromatic Hydrocarbons) an agreed carcinogen and believed to be an endocrine disruptor, but the question is whether via skin grazes and ingestion enough is absorbed to cause cancer. The dose makes the poison, and perhaps some children are more sensitive than others to a small dose. Parents are kicking up while those in the business of laying these pitches are on the back foot. Not for them the precautionary principle. They are in too deep, too invested. The point is that for completely different chemicals and products a growing number of companies are likely to find themselves in similar situations to those in the artificial grass and rubber crumb game. Knowledge of chemical poison investigations and anticipation of regulation is key. On March 8, 2016, the European Commission together with the Member States agreed that there is a need to assess whether rubber crumb used as infill in sports pitches poses a risk to human health. In the EU, there are several national studies conducted related to the PAH substances (and some other impurities) in rubber crumb and exposure to these impurities. ECHA expects to receive a request from the European Commission to investigate all the relevant information to determine whether a restriction of the substance(s) is needed. National helpdesks in the Member States act as a good point of contact for questions related to the REACH, CLP and Biocides Regulations. You can contact them for further questions:  [http://echa.europa.eu/web/guest/support/helpdesks/national-helpdesks/list-of-national-helpdesks](http://echa.europa.eu/web/guest/support/helpdesks/national-helpdesks/list-of-national-helpdesks) For example, the Swedish Chemical Agency (KEMI) recommends that rubber crumbs from waste tires not be used in synthetic turf. So why are these pitches being laid all over Ireland? I welcome any feedback if your organization has specifically made the precautionary principle an ethical guideline or policy. I’m also looking for examples where it has had an impact on business decisions. ### Written by [Damien McGovern](https://go.adherent.com/commentary-analysis-old/author/damien-mcgovern) - - - - ## Featured Posts --- ![Stacey Bowers to Present at ICPHSO 2022 Annual Meeting & Training Symposium](https://go.adherent.com/hubfs/icphso%202022%20(1).png) [Stacey Bowers to Present at ICPHSO 2022 Annual Meeting & Training Symposium](https://go.adherent.com/news-resources/stacey-bowers-to-present-at-icphso-2022-annual-meeting-training-symposium) 26 January 2022 ![Regulating Explosive Atmospheres in the Workplace](https://go.adherent.com/hubfs/Regulating%20Explosive%20Atmospheres%20in%20the%20Workplace.png) [Regulating Explosive Atmospheres in the Workplace](https://go.adherent.com/news-resources/regulating-explosive-atmospheres-in-the-workplace) 25 January 2022 ![What's Trending in Product Compliance?](https://go.adherent.com/hubfs/Trending%20Jan%2022.png) [What's Trending in Product Compliance?](https://go.adherent.com/news-resources/whats-trending-in-compliance-jan-22) 24 January 2022 #### Ireland Office   Unit 9 Eastgate Avenue Eastgate Business Park Little Island Cork Ireland +353 (0)21 435 1990 [info@complianceandrisks.com](mailto:info@complianceandrisks.com) #### US Offices   New York 50 Fountain Plaza Suite 1400 Buffalo NY 14202 +1 716 939 1951   California P.O.Box 309 8712 Marysville Road Oregon House, CA 95962 – 0309 +1 530 216 4455 [![Compliance Logo](https://go.adherent.com/hubfs/Compliance_and_Risks_January2018/Images/compliancelogo.svg)](http://www.complianceandrisks.com/) #### Information - [Solutions](https://www.complianceandrisks.com/c2p-platform/) - [Industries](https://www.complianceandrisks.com/industry-solutions/) - [News & Resources](https://www.complianceandrisks.com/resources/) - [About Us](https://www.complianceandrisks.com/about-us/) - [Get in touch](https://www.complianceandrisks.com/contact/) - [About Us](http://www.complianceandrisks.com/about/) - [Get in touch](http://www.complianceandrisks.com/contact/) [![Compliance Logo](https://go.adherent.com/hubfs/Compliance_and_Risks_January2018/Images/compliancelogo.svg)](http://www.complianceandrisks.com/) © 2021 Compliance and Risks Ltd. | [Privacy Policy](http://www.complianceandrisks.com/privacy-policy/)