Lead in Children's Products
Lead Exposure

Although it is currently recognized that the most common source of lead exposure among children in the United States is by ingestion of dust from lead-based paint, it is also recognized that a significant percentage of children aged < 6 years are exposed to items containing lead that have been brought into the home. These items include painted and unpainted metal and non-metal toys and jewelry items, antique items, ceramic dinnerware, folk and traditional medications, and cosmetic items. According to recent CDC estimates, about 900,000 children (ages 1-5) living in the United States have elevated blood lead levels. Exposures to some of these items can result in life-threatening blood lead levels (BLLs; >100 μg/dL).

Items containing lead are to be considered health hazards, and parents and children should avoid handling such items. Sadly, children may put jewelry and small toys in their mouths to suck or teethe on them and accidently swallow these items. For example, in mid-February, 2006, a four year old boy died from acute lead poisoning caused by lead encephalopathy after ingestion of a heart-shaped metallic charm (see photo at right) containing lead; the charm had been attached to a metal bracelet provided as a free gift with the purchase of shoes manufactured by Reebok International Ltd. On March 23, 2006, a voluntary recall of 300,000 heart-shaped charm bracelets was announced by Reebok and the by CPSC.

In a recent survey performed by Microecologies®, a variety children's jewelry, accessory, and toy items were purchased from retail outlets and tested (using a hand-held X-ray Fluorescence instrument; see section on lead testing below) for lead content to determine if these items may pose a lead exposure risk to children. Many of the jewelry and accessory items contained concentration levels of lead that are many times higher than the current Consumer Product Safety Commission's (CPSC) allowable limit of 90 parts per million (ppm) and 300 ppm (see below section on applicable lead-based paint regulations and lead regulations related to children’s products) , and present a potentially serious health hazard to kids. For example, levels of lead in multicolored coated bobby pins (see photo at lower left), which are the type of item both kids and their moms may put in their mouths, were found to range from 9,740 ppm (green) to 106,000 ppm (orange). Levels of lead in other children’s jewelry items and many of the toys were also found to substantially exceed regulatory limits (see photos below).



Applicable Lead-based Paint Regulations and Lead Regulations Related to Children’s Products

On August 14, 2009, the Consumer Product Safety Commission (CPSC) reduced the limit for lead in paint and similar surface coatings from 600 parts per million (ppm) to 90 ppm, as mandated by section 101(f )(1) of the Consumer Product Safety Improvement Act of 2008(CPSIA). The new lower limit applies to paint on toys or other articles for children, paint sold to consumers (for example, a gallon of paint sold at a hardware store), and paint on certain household furniture items (not limited to children’s furniture).

On August 14, 2009, the CPSC also reduced the limit for lead in any unpainted accessible part of a children’s product from 600 ppm to 300 ppm, as required by section 101(a)(2)(B) of the CPSIA. The term "children’s product" means any consumer product that is designed or intended primarily for children 12 years of age or younger. The CPSIA requires that the lead limit be further reduced to 100 ppm on August 14, 2011.

Under section 102(a) of the CPSIA, any painted children’s product that is manufactured after August 14, 2009 must be certified as being lead compliant with the 90 ppm lead-based paint limit. Children’s unpainted metal jewelry items that are manufactured after August 14, 2009 must be certified as lead compliant with the 300 ppm limit in any accessible metal part. Accessible parts of other children’s products (i.e., unpainted children’s products and non-metal jewelry items) must be lead compliant with the 300 ppm lead content limit if they are manufactured after February 10, 2011. These certifications must be based on testing by a third-party.

Under section 101(a)(1) of the CPSIA, the CPSC classifies any product that fails to comply with the new lead limits, regardless of when the product was made, as a banned hazardous substance under the Federal Hazardous Substances Act, which states that it is unlawful for any person to sell, offer for sale, import or distribute a banned hazardous substance. Therefore, beginning on August 14, 2009, it became unlawful to sell, offer for sale, manufacture for sale, distribute in commerce or import into the United States any children’s product containing lead above the regulatory limits.

Lead Testing

X-Ray Fluorescence (XRF) is a quick, reliable, non-destructive method for testing items such as children’s toys and jewelry, furniture, dinnerware/foodservice and other items for lead.

Using our state of the art, handheld, direct reading XRF instrument, Microecologies’ New York State licensed, EPA certified, experienced, lead-based paint inspectors can measure (in parts per million) levels of lead in items of concern to determine if they are in compliance with applicable regulations and if your children are unnecessarily at risk of being exposed to lead hazards. If you are a manufacturer, distributor, and/or seller of products intended to be used by children and would like your products tested for compliance with applicable regulations, or if you are a school or concerned parent and would like your children’s toys and/or household items tested for lead/lead-based paint, Microecologies® can help.

Please call if you would like further information about lead in consumer and children’s products, the health hazards associated with lead exposure, or if you would like to schedule a comprehensive survey of manufactured/retail merchandise or household and/or children’s items using XRF to determine the lead content of these items.

Microecologies®, Inc. • 1829 Madison Ave, NY, NY 10035 • 212-755-3265 • info@microecologies.com