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lengthy reply to Bill Carroll on toys
- To: email@example.com
- Subject: lengthy reply to Bill Carroll on toys
- From: "Charlie Cray" <firstname.lastname@example.org>
- Date: Mon, 17 Nov 1997 18:44:28 +0000
- Comments: Authenticated sender is <email@example.com>
- Organization: Greenpeace
- Priority: normal
Another reply to Bill Carroll:
"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
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.
"2) Phthalates. "Admitting" that phthalates are largely used in
vinyl is a little like "admitting" that most PVC goes to rigid,
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.
"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.
"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
In sum, the simple message about phthalate toxicity is shown in the
DINP bottle and accompanying warning statements. No further arguing
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
"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?
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.
"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." ?
"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
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.
"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.
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