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lengthy reply to Bill Carroll on toys

  Another reply to Bill Carroll:
  You say:
  "1)  What are toys?  Well, wires are not toys.  Raincoats are not
  toys.  Toys R Us also sells candy, and batteries which are not toys. 
  I think we, as parents, have some sense of what might reasonably be
  repeatedly sucked, which is the issue."
  Bill:  Look at our two reports - the one on lead and cadmium is called
  "Lead and Cadmium in Vinyl Children's Products."  Toys are not
  mentioned in the title, though some toys - like Kentucky Fried
  Chicken's play food - obviously designed with the expectation that
  kids will stick them in their mouths - are among the list of  products
  we tested.
  Also, as has been stated by others (parents who know more than I about
  everyday life with kids), many things not designed to be put in the
  mouth (including cables) get sucked on by kids.  Our report even
  references one case where an adult's lead poisoning was traced back to
  the fact that he chewed on  his phone cord. In addition to the fact
  that small kids suck on everything (one lead nurse told me that a lead
  poisoned kid she was studying sucked on the dogs play toys!) they run
  their hands over everything and then stick them in their mouths - hand
  to mouth behaviour is a common source of lead poisoning.  Doesn't
  matter whether they are labeled as toys or not.  If they will be used
  by children and provide for exposure either dermally or orally than
  they pose a hazard.
  In the earlier report on phthalates we did test toys designed to be
  sucked on or chewed - like teething rings.   
  You say--
  "2)  Phthalates.  "Admitting" that phthalates are largely used in
  vinyl is a little like "admitting" that most PVC goes to rigid,
  durable applications.
   It's a look-up exercise and not a secret.  On the other hand, it is
  true that phthalates are used with some other plastics and in
  Nonetheless,  the principal plasticizer application in conjunction
  with polymers is, by far, the plasticization of PVC resins.
  You say--
  "The toxicity of phthalates is low, period."  
  No, the acute toxicity is low.  
  I don't want to bore everyone else with an endless toxicological
  debate, but perhaps you're glossing over the fact that the US
  Department of Health's 7th Annual Report on Carcinogens does label
  DEHP a probable human carcinogen.  This is consistent with the U.S.
  EPA's classification of the chemical.  The U.S. Consumer Product
  Safety Commission Chronic Hazard Advisory Panel came up with the same
  conclusion in 1985. Finally, IARC finds animal evidence on DEHP
  sufficient to label it a probable human carcinogen. 
  Second, we are not focusing only on cancer or on DEHP.  Other
  phthalates are not on these lists most likely because to get them on
  the list requires a complicated listing and scientific review
  procedure which takes a long time.  Thus, only a small percentage of
  the 70,000 or so chemicals on the market have been tested for
  carcinogenicity.  This does not mean that they do not cause cancer. 
  Indeed, DINP in laboratory experiments does cause tumors in animal
  species.  DINP is the phthalate used in most of the toys we tested.
  The phthalates are well-known for their reproductive and 
  developmental toxicity, especially DEHP, BBP, DBP.  This 
  developmental/reproductive toxicity may or may not be endocrine 
  system mediated - perhaps another, more important mechanism is at work
  here, no one knows for sure.  Should we wait to define how a chemical
  causes these effects before taking action?  Industry's arguments that
  they are only "weakly" estrogenic is a nice attempt to narrow the
  terms of discussion -- it doesn't mean they can't be powerful
  reproductive toxicants through another means.  
  In laboratory experiments, the phthalates also cause liver and kidney
  lesions.  While the impact of such lesions could  vary, the results
  could be cancer (by mutating DNA or wreaking havoc on cell growth
  cycles) or reduced organ function.  There are numerous submissions to
  the EPA's database of substantial risk notifications about the
  phthalates, which is indicative of their toxicity. 
  Also, the phthalates may act synergistically with other common 
  chemicals.  For example, DEHP and trichloroethylene and heptachlor
  demonstrated synergistic reproductive effects when fed to rats.
  (Michael G. Narotsky, et al, "Nonadditive Developnmental Toxicity in
  Mixtures of Trichloroethylene, Di(2-ethylhexyl) Phthalate, and
  Heptachlor in a 5 X 5 X 5 Design,"  Fundamental and Applied
  Toxicology,  27, 203-216, 1995)  
  The fact that  phthalates are ubiquitous in the environment (the
  Danish EPA says they are the "most abundant man-made environmental
  pollutants, and human intake per day via various routes, especially
  via the diet, is measured in tens of milligrams") makes the issue of
  synergism a cause for concern, since virtually no one (including the
  unborn) can avoid exposure.
  In sum, the simple message about phthalate toxicity is shown in the
  DINP bottle and accompanying warning statements.  No further arguing
  is needed. The Swedish government has done extensive research on the
  phthalates and has found that DINP (the phthalate most used in toys)
  is equally toxic or just slightly less toxic than DEHP.  Furthermore
  they are finding that peroxisome proliferation (industry has argued
  that this mechanism is the way in which phthalates cause cancer and
  that this is a mechanism found only in animals) is not the mechanism
  of carcinogenisis for DEHP, rendering industry arguments of DEHP's
  safety null and void. Besides, DEHP is a known reproductive toxicant.
  You say:
  "Any material with a "no effect level" for daily feeding of 500 mg/kg
  (nearly 1% of the diet) is low in  toxicity.  
  What study are you referring to?  Did they expose pregnant females and
  check the effects on offspring, or developing organisms?  Did they
  expose the animals to multiple phthalates which is almost always the
  case due to batch contamination in the PVC compounding and product
  production processes.
  In sum, the simple message about phthalate toxicity is shown in the
  DINP bottle and accompanying warning statements.  No further arguing
  is needed.
  The common-sense, practical approach to all of this is to avoid any
  unnecessary exposure where the chemical can be toxic at higher doses. 
  Especially with chemicals that can act synergistically (as the
  Narotsky study demonstrates) and  especially with chemicals that we
  get exposed  to through various means.  For instance, kids who chew on
  phthalate-emitting teethers also get them in their infant formula, as
  was discovered in the UK last year.  It's easier to reduce exposure to
  these universal contaminants by taking vinyl teethers out of their
  mouths than by tracking them down through the food chain, so that's
  should be one of the first measures of preventive business.
  The bottom line is also one of common sense.  While no one can prove
  that any specific child has been hurt by exposure to the phthalates
  (which is the case for almost all chemical exposures), it is common
  sense to not expose children to a potential risk when alternatives
  exist.  There are other plastics that do not require plasticizers to
  obtain their qualities.  No one disputes the fact that the phthalates
  leach.  Why would anyone want to take a risk of exposing a young
  developing child to an unnecessary and completely preventable risk?
  Clearly if consumers (mothers) knew that the teether they bought
  contains up to 50% by weight of a toxic substance that can leach out
  during use, they would not be giving it to their child.  The industry
  has been disingenuous in not labelling their products as such - why
  should a laboratory bottle require warnings while a toy doesn't.  Risk
  then becomes a different issue when consumers can make informed
  You say:
  "I guess this comes down to our individual readings of precaution. 
  Yours, I believe, is "avoid all unnecessary risks."  Mine is "avoid
  all significant unnecessary risks."  
  Well then, since PVC is not necessary to make toys, then you should
  agree that it'd be better to use a resin that doesn't require all
  these toxic additives to be stabilized or made flexible?
  You say:
  3)  "Lead in PVC at levels of thousands of ppm may be there as a
  Thanks for pointing that  out - that means they may be using lead as a
  stabilizer in many of the products we tested, despite the toy
  industry's own statements:
  "No heavy  metal stabilizers, including lead, are used in toys. 
  None."  (International Council of Toy  Industries Statement in
  Response to Greenpeace's September 17, 1997 Press Conferences and
  Claims Concerning Toys Made With Polyvinyl Chloride-Background
  Information on Greenpeace's Claims)
  That's about as close to a lie as it gets. 
  You say:
  "Levels of hundreds of ppm are probably pigments; in the low hundreds
  may be lead from the environment on the article, possibly modulated by
  its point of origin."
  No matter how it got there, it can get out because it is not
  chemically bonded to the resin. 
  Just what does that mean, anyway, "from the environment." ?
  You say--
  "Lead and cadmium can and are used as pigments in lots of things.  If
  Greenpeace were interested in lead exposure it would also look for it
  in places other than PVC.  Since that hasn't been done, I question
  whether the issue is protecting the public from lead or furthering a
  political goal."
  No, the issue is protecting the public from PVC.  This has been our
  clear goal all along.  I assume that agenda is anything but hidden,
  which is why you (who represent the PVC industry and not the lead
  industry, though your arguments sound like those of any industry under
  attack, including PVC, tobacco, lead or asbestos.) are here to defend
  Unlike most other resins, PVC will decompose rapidly when exposed to
  typical plastics processing temperatures.  Also, the loose chlorine
  atoms that occur will also degrade the polymer, which is why you also
  use stabilizers.  Chlorine-free polymers don't have the same problem. 
  Just one of many reasons to single out PVC.
  "That said, let's look at your examples.  Will children continually
  suck on the Robin tent pole?  The Tweety purse?  The Minnie Mouse
  umbrella?  These are not teething rings, Charlie."
  Did anyone say the miniblinds had to be sucked to pose a hazard?  They
  also had lead dust on their surfaces at the time they were taken out
  of the packages, which shows you were wrong in asserting that kids
  would have to suck on the products to be exposed.
  As I said above, we never claimed kids suck on those items.  The lead
  can still come out over time, though, as the studies conducted at  U.
  of North Carolina demonstrated.  Kids can touch the products with
  their hands, and then put their hands in their mouth.
  You say:
  "Finally, you applaud governments that agree with you and blast those
  that don't.  I think the CPSC, which happens to be a pretty aggressive
  agency by most standards, has done a pretty fair job on the issue
  despite pressure visits from Greenpeace."
  Do you call the CPSC's failure to recall vinyl miniblinds, despite
  knowing that they posed a lead hazard risk to children "a pretty fair
  job"?    Here's what Ed Norman  of the Division of Environmental
  Health, North Carolina Department of Environment,  Health, and Natural
  Resources, Raleigh writes:  "Although new formulations with no lead
  added are available, millions  of children may still be at risk
  because a product recall has not been issued (ie lead-contaminated
  vinyl miniblinds are still in general use).  In addition, the risk
  assessment evaluations proposed in lieu of universal blood lead
  screening for low-risk communities could overlook children with
  exposure to this source." (Edward H. Norman, et al., "Childhood Lead
  Poisoning and Vinyl Miniblind Exposure," Arch. Peiatr. Adolesc. Med/
  Vol 151, Oct 1997).
  The CPSC said in their Oct. 9 press release (issued when they got a
  leaked copy of our lead and cadmium report) that testing they
  conducted does not support our conclusions.  This "aggressive agency"
  attacked the bearers of the message, not the people who caused the
  problem.  I guess that's aggressive, yes.  Not particularly
  responsible, however, by standards of public health policy.  They
  didn't conduct the aging studies, so they didn't do that kind of test
  to back up their opinion of exposure scenarios.  Worse, the tests they
  did for lead and cadmium content (leaked to us later) showed levels in
  half the items tested that were as high as our levels - levels that
  would have prompted a recall had they applied the same standard as
  they apply to lead in paint.  
  The CPSC is not supposed to prove things as safe, only that they are
  not hazardous.  However, to prove non-hazard, the agency has to be
  rigorous about its testing and methods.  For example, the agency did
  not ash (burn) samples which is necessary when testing for lead in
  vinyl. The agency is even clear that no level of lead is safe for a
  child. Their testing, over a period of a few days, in no way matched 
  the depth and peer review of the Greenpeace testing, which was
  reviewed by some of the leading scientists and public health
  practicioners in the country.
  One of our colleagues went to a seminar organized by Swedish
  environment ministry on chemicals, human health and environment. The
  Deputy Director General of Swedish Chemicals Industry Association said
   in a plenary in front of ca. 60 industry people (incl. Eurochlor,
  CEFIC) that she cannot defend the use of soft PVC in baby toys and
  that she does not think that a full risk assessment is necessary.
  PS For those interested, the American Journal of Public Health
  published an article titled "Lead and Other Metals in Play Kit and
  Craft Items Composed of Vinyl and Leather,"  October 1997pp 1724-1727.
  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