ASGi recommends that each company in the artificial turf and synthetic grass supply chain - from grass surfaces component manufacturers to consumable job materials suppliers and product brand owners, their distributors and installers - develop a quality assurance system that addresses specific federal and state restrictions on the use of heavy metals and other chemicals and integrates these requirements into existing quality assurance and control (QA/QC) programs.
What due diligence steps can your company take to ensure the quality of your materials and supplies are compliant with federal and state laws?
Don't assume that suppliers have read and adhere to the specifications, or know about federal and state restrictions on the use of heavy metals in artificial turf system job materials.
Discuss specifications and requirements directly with your suppliers.
Incorporate specifications of maximum level requirements into your purchase orders and product specifications.
Require suppliers to submit a Certificate of Compliance with supporting documentation. Ask suppliers to provide the analytical data on which they base their compliance claim. Require suppliers to submit new Certificates of Compliance with supporting documentation whenever their suppliers, formulation or raw materials change.
Test the incoming finished goods and job materials components of all new suppliers prior to issuing a purchasing contract, using x-ray fluorescence analysis or conventional laboratory testing.
Select laboratory sample preparation and test methods that result in full dissolution of the sample and analyze for total concentration of lead [and other heavy metals and chemicals]. Test methods that only measure leachable metals are not appropriate (example - TCLP Total Characteristic Leachette Protocol)
Adopt an on-going program for monitoring or doing a "spot-check" on incoming stock, job materials or other components to make sure that heavy metals are not subsequently introduced into your workplace or inventory and supplies.
A Special Note Regarding California's Proposition 65
Proposition 65 doesn't BAN any products, nor does it set limits of the amount of a chemical or heavy metal a product is allowed to have it simply requires appropriate and proper warnings on products containing controlled chemicals - specifically if the amount exceeds the SHN defined under OEHHA maximums.
Anyone doing business in the State of California ought to know what is required to insure that you do not risk receiving a 60 Day Notice of Violation.
