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Lead Hazard in Children's Toys:
The nature of the problem and what can be done (August 15, 2007)
Turnertoys disclaims responsibility for and is not liable for typographical errors or errors of omission.
March, 2010: CPSIA update: Politics, hysteria, economics, and unintended consequences
October, 2008 Update: New CPSC rule tightens limits on lead in toys
March, 2008 Update: Identifying safe toys and toys that may be hazardous
August 2007: Made in China - an issue of health and safety
Use of Lead in PVC (Vinyl) for toys and other products (from our original reference on PVC)
Complete list of Turnertoys products & country of origin
List of Turnertoys products that are made in USA
*The nature of the problem - Imports from China
*Why is lead a problem?
*Where is lead found? Where is it not found?
*Turnertoys products: where they are made and which ones are
potential lead hazards
*Turnertoys testing of toys that might contain lead - what the test
results indicate (and what they do not)
*Information from our dropship vendors
*What can be done - what should be done
The nature of the problem
By now you have certainly heard about the disturbing news of hazardous foods, pharmaceuticals, toys, and tires exported by Chinese manufacturers. I had thought that, at least in regard to toys, Chinese manufacturers had by the late 1990's largely eliminated safety hazards such as lead and cadmium in painted finishes and in PVC. I am annoyed and embarassed to say I was wrong about that. It seems that as soon as no one is looking too closely, Chinese producers will try to cut corners. The most spectacular recent results of this sort of business ethic have been the recall of thousands of Thomas the Tank Engine toy trains and almost one million Mattell toys, including Sesame Street and Nickelodeon characters such as Elmo Tub Sub, the Dora the Explorer Backpack, and the Giggle Gabber because of lead in the paint finishes.
And now again, Mattell has had to recall nearly 19 million toys, many for lead in the paint finishes of "Sarge" toy jeeps. We read, also, that thousands of baby bibs made from lead-stabilized or lead-pigmented PVC are on the shelves at Toys-R-Us, or have already been purchased for use with infants, and, astoundingly, no recall has been issued!
Mattell and RC2 Corporation, the toy importers, had provided specifications for the finishes, but at some point their Chinese factories made unannounced change in the paint formula. It is to the credit of both companies that they identified the problem quickly and initiated prompt recalls on their own.
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Lead in Children's Products: Why is it such a problem? Where is it most likely to be found?
Arguments about "safe" levels of lead in children's products are specious, based on an entirely outdated understanding of the biology, especially the neurobiology, of growing young children. I think that when these arguments come from official sources, such as the CPSC, they are disingenuous and ultimately politically driven, with a view to protecting potentially affected economic interests.
Lead accumulates in the body, both in nerve tissue and bone. Ingested lead is only partially excreted in urine, feces, and sweat. It can replace Calcium in both tissues, thus compromising nerve conduction and response and adding to a "savings bank" of accumulated lead in bone. The affinity of lead for nerve tissue is a significant problem for growing children; the younger they are, the more vulnerable. The consequences of low levels of lead in the nervous system may include behavioral problems and cognitive impairment. High blood levels can be fatal.
The accumulation of lead in bone makes lead ingestion especially worrisome for females. During periods of high demand for available calcium, such as lactation after pregnancy, or in the context of bone loss associated with osteoporosis, lead is released into the blood along with calcium. In the case of nursing mothers with high blood lead levels, the lead can end up in the milk supply. It has also been speculated that high blood lead content in elderly women may contribute to symptoms of dementia.
Although there may a safe blood level for children, now accepted by many scientists as below 10µ (microgram) per deciliter (1/10 liter -dl) of blood, there is really no safe level of content for a product. This is because lead in the bloodstream is in a dynamic equilibrium with lead stored in body tissue, predominantly bone. At a low level of blood lead, lead may continue to accumulate in bone and other tissues, so that under conditions where the stored lead is released, there may a much higher level in blood.
Further, it is not correct to state that a level of lead available for ingestion from a single source may be acceptable, since there are usually multiple, individually insignificant sources of lead in a young child's environment, that taken together can result in a sigificant cumulative hazard.
Thus, the CPSC's statement that PVC bibs containing lead were safe to use as long as they were not torn or scratched is extremely unhelpful misinformation. It is simply incorrect. The chances are that the lead is being used as a stabilizer in the PVC, in which case lead dust will continuously migrate to the surface and become available for ingestion under any circumstances, albeit faster if the PVC is exposed to mechanical stress, UV light, or heat.
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Materials that are likely or unlikely to contain lead
With the understanding that lead is always a hazard, it is important also to realize that not all products from China contain lead. In some cases, the decision is easy to make without the need for testing or regulation.
If it is not painted or colored, not made of PVC, and not made of metal, it is very unlikely that a product can contain any lead. Clear PVC does not contain lead, although it must necessarily contain phthalates. Unfinished wooden toys, such as blocks, do not contain lead no matter where they are made. It is very unlikely that polyethylene, polypropylene, polyester, or nylon will contain lead, whether colored or not. Likewise, clear lacquer finishes on wooden toys or furniture will not contain lead. However, we are aware of a recent discovery that a styrene plastic part used in a wooden toy and made in the U.S. used lead pigment for its red coloring.
Brass is almost always alloyed with small amounts of lead to allow easier machining. There are also alloys of aluminum that contain a few percent lead, and that may be used for the same reason in cheap bicycles and other structural applications. These alloys are much less of a hazard than lead-stabilized PVC, which continually emits lead dust, or cheap lead-bearing jewelry which may be swallowed and release biologically available lead because of exposure to digestive acids.
So our watchlist of products that may present a lead hazard to children include cheap metal jewelry and castings, painted metal, plastic, and wooden toys and furniture, and all colored PVC. A lesser hazard is presented by brass and lower-priced aluminum parts,
There are many toys on the market that fit these descriptions, and are also made in China. However, regardless of where they are made, these are the materials that may possibly contain lead. These are the ones on which we want to focus our attention; these are the ones we need to test for lead.
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Where our toys are made; how we know that they are safe
At Turnertoys, we are taking what steps we can to assure the safety of everything we sell. We have never carried products that, for reasons of design or manufacturing quality, we believed might pose a safety hazard of any sort. We have made the hard decision not to carry products that were carried by many of our competitors, and that we knew we could sell, because we did not feel they met our standards of safety and quality.
For this reason, and because of the immediacy of the hazard suggested by the Thomas toy trains and Mattell incidents, we are concentrating on establishing the absence of lead toxicity in the paints of the toys we sell. Lacquer or varnish (clear finish on natural wood) is less of a concern because these finishes have no pigments, which is where metals such as lead are found. Likewise, completely unfinished wooden products such as unit blocks, Haba Architectural and Action Blocks, and My Very Own® Rattle cannot present a lead hazard or any similar toxicity problem.
Only one category of toy that we sell is a candidate for heavy metal toxicity: painted toys. The other likely loci of lead content are cheap cast metal products, such as jewelry; and PVC (vinyl), in which lead may be found either as pigment to provide bright color (usually red or yellow) or as stabilizer (see What is PVC (vinyl)? Use of Lead and other stabilizers). We sell no toys that fit either of those descriptions. A few of our toys are packaged in clear PVC, which cannot contain lead.
We keep in inventory most of the toys we sell (everything but the large items, such as furniture and riding or rocking toys). Relatively few of the toys we carry in inventory are painted.
Most of our toys are not made in China
Our primary concern is with toys manufactured in China. Only some of our toys are made there. Most of our toys decorated with paint are made either in Germany, or in the USA. These include the colorful wooden block sets in our Block Shoppe. Most of the Haba Architectural Blocks are made in China of European Hardwoods such as beechwood, but have no finish, and so cannot constitute a lead hazard, and are also CE certified.
All of our wooden toy trains and accessories were made in the U.S. Many of the Haba or T.C. Timber products (Storybook World and Action block sets in The Block Shoppe ) are made in Germany and are CE certified (EN71 - a rigorous standard required for toys sold in the European Union, that includes destructive testing and chemical analysis of both product and package). The alphabet blocks are made in USA, and are also CE certified. The pegs for the Jumpo and Ntangle were made in USA (by us, the Elwood Turner Co) with non-toxic paints. The RoyToy Log Sets, Slinky, and Gyroscope are made in USA. My Very Own® Rattle is made in the USA. The Unit Blocks are made either in USA or China, but in any case, are not painted.
Among our "Folk Toys", only the Old Fashioned Top, the throwing top, Jacobs Ladder, and the Sew'N'Sew stitching block are made in China. The PDI 2-layer wooden puzzles and the Haba Sunnyland puzzles are also made in China. We have tested these for lead with negative results (see below). The Jumbo puzzles are made in Holland.
Our wooden flying toys have essentially no paint, and are not of concern. All of the balsa planes, gliders, and model kits are made in USA. Our plastic flying toys and accessories have no PVC, the only plastic with a potential for lead content.
The Tim Flying Bird is made in China, but contains no PVC (we tested it anyway). The Titan airplane is made in Germany. Lead would not typically be part of the formulation for plastics other than PVC, and does not appear to be in common current use in the pigments (Google search).
Our kites are all made in China, but are all either nylon or Tyvek. The crayons in the Creative Diamond kites are potential lead sources, but our lead tests were negative (see below). A small sampling of the non-PVC plastic parts in these toys revealed no lead in the pigments.
Our Working Rigs construction vehicles are made in China, but are not painted; and further, have CE, ASTM, and ISO9001 certifications, indicating very high quality standards. We rely on the fact that they are not painted, however, not on the one-time test results leading to the various certifications.
Our Dollhouses by Real Good Toys are made in Thailand, not China. (Their dollhouse kits are made in USA.) Thailand has had a mature, technically sophisticated wood products industry for at least 15 years, and has not ever been found to generate the sorts of quality problems that been have associated with Chinese-made toys. Nonetheless, we have requested formal data from the importer. The dollhouse furniture is imported from Asia, but is not painted, thus not a toxicity hazard.
Little Colorado Furniture is made in the USA, using American-made paints (we understand it is Sherwin-Williams).
Some of our large items of furniture made by Guidecraft is imported from China; however, some may be made in Thailand, not in China, although we generally have no easy way to find this out.
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Larger Toys - our Drop-ship Vendors
Most of the larger toys are drop-shipped, that is, sent directly from the manufacturer's or importer's warehouse to the customer. However, we have been able to examine these carefully and critically at Toy Fair each year, and in the case of the Vermont Rocking Dory, have paid several visits to the factory in Warren, Vermont.
We have not performed our own lead tests on these drop-shipped products. At this time, we have requested formal statements from our drop-ship suppliers regarding safety of their products, primarily with regard to paints and finishes. We are still waiting to receive these.
Our sleds and wagons are made either in the U.S. or China. There is no paint on them. The runners are powder-coated, essentially a baked enamel finish. These sleds and wagons have been lab tested, and we have available to us a copy of the results. Our Vermont Rocking Dory is painted with American-made, brand-name paint, for which we have the formula available.
Our new line of Kettler® premium wheeled toys are made in Germany, and are not painted. They have a polyester powder-coat finish, completely non-toxic, and far less degradable with wear than paint. The plastic parts are polyethylene, which does not present a lead hazard (nor any other acute chemical hazard - see polymer safety update). The Kettler® products are all CE certified.
The two greatest concentrations of painted products among the large, drop-shipped items we carry are the Guidecraft (Asia) and Little Colorado play furniture (USA) items (Kitchens, table & chair sets, craft tables, etc.) and the Steel Pedal Cars.
Little Colorado Furniture is made in the USA, using American-made paints (we understand it is Sherwin-Williams). We have an informal statement from Guidecraft that a staff member visits the Chinese factories monthly, and that the finishes are or have been subjected to periodic testing. We have just been informed that there will no more formal statement made than this.
Most of the steel pedal cars we sell are made in China, and the importer has provided an informal statement that they believe the finishes to be lead-free, largely because they have specified the paint formula. They have notified the factory in China that they want a formal analysis, and we will have more information when they provide it.
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Testing of items kept in inventory - interpreting test results
Samples of most of the toys we keep in inventory have been opened and examined critically for defects of design or workmanship, and many have been play-tested, including all the flying toys. We have eliminated from the Turnertoys website any items that failed more than once to meet our very high standards, even if they had previously been satisfactory.
In 2007, we started testing surfaces of our painted toys for the presence of lead, regardless of the country of origin. We are using LeadCheck® Professional Test Kits, made by Hybrivet Systems (Natick, MA: 800-262-5323 / http://www.leadcheck.com ). These tests indicate the presence of lead in surfaces with a concentration of more than 2µ (micrograms) per 1 cm2 surface area.
We score the painted surface down to the substrate to expose as much of the coating as possible, so we are not just testing the exposed surface. This is a qualitative test that does not rule out the presence of lead in lower concentrations. Any positive result using this test indicates a toy clearly not suitable for children of any age.
This test, when applied for longer than 30 seconds and over a larger surface area, will detect lead content as low as 600 parts per million - the legal standard prior to the new CPSIA 2008 regulations.
Admittedly, it is very difficult to translate results in content per unit surface area into numbers relevant to known health effects in children, which are calibrated in micrograms (µ) per deciliter (dl) of blood. 10µ/dl is considered a very rigorous standard of safety; blood levels below this are regarded by almost all scientists as not of concern.
However, neither the U.S. Environmental Protection Agency (EPA) nor the Consumer Products Safety Commission (CPSC) have been helpful in providing a translation formula from surface concentration to blood level, and in fact, it may not be so easy. Surface lead (which our tests detect) indicates only available lead, not ingested lead, which will necessarily be a much smaller amount, depending on frequency, duration, and manner in which the child handles the toy. A toy not placed in the mouth is much less of a hazard than one that is.
Furthermore, a toy in which lead is bound in a paint film will release it at a rate slower than our testing indicates, since we scratch the surface in order to release as much as possible. In PVC toys, on the other hand, lead, if present, and other substances of concern, are emitted steadily by the plastic. Again, Turnertoys does not sell toys made with PVC.
Results of our testing
In 2007, we tested the painted surfaces of all our Chinese-made toys, and were not able to detect any lead. We also tested representative sample of our toys made in USA and Germany, and found no lead. We have available to us the Material Safety Data Sheets (MSDS) for our American-made toys; they are all decorated with USA-made coatings, of which the composition is known. The MSDS includes, among other data, the chemical composition of the product.
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Ongoing Program - a continued scrutiny
Unfortunately, it appears that Chinese factories will get away with whatever they can if not constantly watched. If Mattell, who has more influence and economic power than any other toy company on earth, and who actually owns some of their factories in China, can have problems with lead in paint, than any of the thousands of smaller importers are subject to the vagaries and vices of their Chinese suppliers, unless they have a continuing, active test program.
The only sure remedy would be to pull samples out of each batch of product that is packed and ready for container loading, and test them before they are shipped. If a product fails the test, that entire batch should be rejected and destroyed in China. It would mean that the importer would be "out of stock" of that item for a while, which is a normal ocurrence in retail commerce, anyway. Whether or not any importer is able to adopt such a rigorous standard remains to be seen. Mere observation of procedures, or questioning of factory managers, is clearly insufficient. Testing of either the paints used, or the surfaces of finished products, is needed. Again, this should be done before the products are shipped, and should be done on randomly selected, packed items, not "test samples" provided by the factory. Meanwhile, Turnertoys will continue to test our in-house inventory, and may consider having some of the drop-shipped items sent to us, so we can test them here. We are hoping to have documentation of our drop-ship vendors' testing at some point in the near future.
Actions reasonable and unreasonable:
Focusing on the real hazard; interpreting lead test results
Parents and child-care providers should be concerned about lead and other hazards in toys. However, We suggest that the available lead test kits are one tool that can be used effectively in the effort to keep kids safe, if used according to all manufacturer's directions, and interpreted conservatively. False positives are unlikely; if the swab turns color, lead is present in quantities of concern. False negatives are possible, since the test results using the swab kits do not absolutely rule out the presence of any lead. However, in general lead will either be present in detectable quantities, or present only in trace amounts as contaminants, not as intentionally added pigments or stabilizers. Thus, a negative result can be interpreted with reasonable reliability. Furthermore, sensitivity of the swab-type home kits can be increased by swabbing a larger surface area, thus exposing the swab to more lead if any is present.
Throwing out all Chinese products makes no sense to me. The toys containing the materials identified here and in our other articles as hazardous should be discarded, or perhaps tested and kept in use with supervision. Potentially hazardous materials as described here should not be present in toys for children who are still teething, and never for children under the age of 12 months.
The material presented in this article is intended as a guideline to focus the attention of responsible adults conerned about the safety of children on the real hazards, so that kids can continue to enjoy the majority of toys made in China and elsewhere that are safe and of good quality.
We have had numerous requests for information about the safety of our products, especially in regard to where they are made, and I hope this information has been helpful.