comments on toys

["Charlie Cray" <ccray@dialb.greenpeace.org>]

  Response to some of Bill Carroll's points:
  
  First, in his response to the initial release of our report, he said,
  "most of those products aren't toys anyway" (something to that 
  effect).  Toys R Us  told us they consider everything they sell to be 
  a toy.  If you look at hackey sacks and Kentucky Fried Chicken Play 
  Food, you have to ask  Dr. Carroll what he thinks they are, coffee 
  table conversation pieces? As for exposure scenarios, Do you really 
  think kids won't put vinyl play food in their mouth?  As Jackie said, 
  kids under three put just about everthing in their mouth.
  
  "While phthalate plasticizers are primarily used with PVC, lead and cadmium
  can and have been used in almost any plastic."  
  
  First, notice the admission that phthalates are used primarily in PVC.  
  The toxicity of phthalates is the reason why numerous countries and 
  companies have taken action by removing PVC teething rings from the 
  shelf.  In the US the companies are hiding behind scientific 
  uncertainty  because the weak-kneed CPSC does not apply the 
  precautionary principle.  (When they found lead to be a problem 
  in mini-blinds, they didn't recall them either, only required 
  them to be labeled, which meant they were sold at a discount, 
  mostly to poor people who are already disproportionately exposed to 
  lead --especially in the big cities.) While phthalates are labeled 
  with warnings like  "avoid contact" when you buy them for lab use, 
  the toys are labeled "non-toxic" though they leach these same 
  chemicals when they are sucked on by kids.  
  
  Second, other plastics don't require the stabilizers that PVC does, 
  because they aren't as brittle.  Sure they can be found in paints 
  used as colorants in other plastics, but does that justify their 
  being in PVC toys?  (It's ye olde "they do it, so why can't we" 
  argument)
  
  "Practices differ around the world as we saw when imported miniblinds
  were found to contain lead but domestic equivalents did not.  For 
  many, if not most, of the articles tested there are vinyl products 
  available that do not use either lead or cadmium as pigment or 
  stabilizer."
  
  Yet nearly all  toys are made where they still use these additives.  
  Go into a toys store and try to find a toy that's not made in China.  
  Furthermore, it's not like you get a "safe" product without the 
  metals.  There are still other dangerous additives (like the 
  phthalates), and the PVC itself, with all its problems (least 
  recycled of all resins, produces dioxin when disposed by 
  incineration, etc.)  I.e. it sounds like the vinyl industry is ready  
  to make a "safe cigarette" argument here. 
  
  "Levels of lead of about 200 ppm (0.02%) are consistent only with its use as a
  pigment, not as a stabilizer.  They might, in some situations, also be
  consistent with inadvertent contamination the product saw along the way."
  
  If it's used in the pigment, and in many instances the levels 
  we found were above 600 ppm, the level the CPSC applies to recall 
  lead in paint, then how come they don't recall these products?
  
  Lead showed up in thousands of parts per million in many cases.  It 
  also showed up in many different colored items.  What color pigments 
  use lead?  Where still used, what levels  does lead show up as a 
  stabilizer, if I may  ask?  If lead is co-mined with zinc and shows 
  up as a contaminant, then won't it show up even where it's not 
  intentionally used?
  
  Here are the levels found in Round 2 of our Chicago tests:
  
  Tweety purse (Warner Bros).  3,320 ppm lead, 84.0 ppm Cadmium
  Batman and Robin Tent Pole (Toys R Us) 5,715 ppm lead, 15 ppm Cadmium
  Minnie Mouse umbrella (Toys R Us) 1,685 ppm lead, 337 ppm Cadmium
  
  The CPSC staff-recommended limit for lead in vinyl blinds was 200 
  ppm.  The limit for lead in paint is 600 ppm.  How come they don't 
  recall these products if, as Dr. Caroll says, the lead is probably 
  in the paint, not in the resin as a stabilizer?
  
  Dr. Bill  wrote:
  "The question is whether that low level of lead or cadmium is 
  available, and whether it might reasonably be expected to be used so 
  as to extract it.  I cannot imagine the use of either in a toy 
  designed to be put in the mouth."
  
  1) What about toxic chemicals like phthalates used in teething rings?  
  
  2)  As Jackie Christensen said, kids put just about anything in their 
  mouths.  Plus, the lead can appear in dust on the surface as the 
  products degrade (or right out of the package).  Kids can handle the 
  product then stick their hands in their mouths.  So there's more than 
  one exposure route involved.
  Charlie Cray
  Greenpeace US Toxics Campaign
  847 W. Jackson Blvd., 7th floor
  Chicago, IL 60607
  Ph: (312) 563-6063
  Fax: (312) 563-6099
  Note new e-mail address: Charlie.Cray@dialb.greenpeace.org