|Voluntary Measures Fail To Ensure Safety Of Vinyl Products:
Lead, Cadmium, and DEHP Still Present Despite Toy Makers' Promises
A December 1998 Greenpeace investigation has found DEHP, lead, and cadmium in a variety of vinyl children's products despite industry assurances that DEHP use was "negligible" and that lead would be removed. DEHP softens vinyl and makes it more pliable, while lead and cadmium can serve either as the metal stabilizer that vinyl requires or as pigment ingredients. The vinyl items used in this study were purchased during September, October and November from national chain stores and "dollar" stores. The items selected were designed for use by children, and include vinyl bibs, backpacks featuring Teletubbies and Rugrats, a 101 Dalmatians girl's purse, a vinyl Rawlings baseball mitt, a Disney rain slicker, and a promotional beach ball distributed by the chemical industry.
1.1 Lead: Voluntary measures undertaken in 1998
In January 1998, the Consumer Product Safety Commission (CPSC) issued a guidance document asking manufacturers to eliminate lead from all consumer products.  In August 1998, the Toy Manufacturers Association (TMA) agreed, pledging to eliminate lead from all products. The TMA cited all of the following consequences of lead exposure as reasons for its action: behavioral problems, learning disabilities, hearing problems and growth retardation. 
The impetus behind these actions was an October 1997, Greenpeace investigation documenting high levels of lead and cadmium in a wide variety of vinyl children's products.  A different study, performed at the University of North Carolina, demonstrated that vinyl children's products released lead and cadmium dust as the vinyl degraded in light.  The toxic dust could easily be ingested by children through inhalation, licking, or handling the vinyl products. Chewing and sucking on vinyl is also a known source of lead poisoning.  Researchers at the State University of New York, and several network television stations across the U.S. have also found high levels of lead and cadmium in vinyl consumer products. , 
In October 1997, prior to its agreement to eliminate the use of lead, the TMA responded to the Greenpeace findings by denying that lead was present.  The Vinyl Institute later admitted that both lead and cadmium are deliberately added to vinyl consumer products either as required metal stabilizers (due to vinyl's high chlorine content) or as part of pigments. 
1.2 Tests reveal that lead is still present in vinyl children's products
Despite the governmental request and the industry promise to remove it, Table 1 shows that recently purchased vinyl children's products contained from 20 parts-per-million (ppm) to over 12,000 ppm lead. Cadmium, a metal approximately ten times more toxic than lead, was found at levels up to 600 ppm. Table 2 shows that a beach ball used by the chemical industry in public relations outreach contained both lead and cadmium. Minute amounts of lead cause cumulative and irreversible nervous system damage and decreased intelligence.  Cadmium is a kidney toxin and carcinogen. 
The results shown in Tables 1 and 2 are consistent with a November 1998 investigation carried out by Greenpeace Canada, which found high levels of lead and cadmium in a variety of major brand vinyl consumer products to which children are exposed including: a watch strap, notebook, diaper bag, phone cord, soccer ball, backpacks and kitchen appliance cables.  (See Appendix 1) Many of these products are widely available in the United States.
2.1 DEHP: Voluntary measures undertaken in 1986
In 1986, the TMA agreed to limit concentrations of DEHP (di(2-ethyl hexyl) phthalate) in vinyl teethers, pacifiers and squeeze toys to levels less than 3 percent. The CPSC requested the action in a voluntary agreement with the TMA due to the carcinogenicity and reproductive toxicity of DEHP. ,  To resolve the issue, the toy industry substituted DINP, another phthalate, as a softener in vinyl toys before testing it for safety. More than a decade later, DINP was also found to be carcinogenic as well as damaging to the liver, kidneys, and reproductive organs. , , , , , ,  Currently, the chemical industry insists that "DEHP is used in negligible amounts in toys in the United States and Europe, after the United States phased out its use in the mid-1980s." 
2.2 Tests reveal that DEHP is still present in many U.S. vinyl children's products
Despite chemical industry claims about its insignificant use, Table 1 shows that many common vinyl children's products contain DEHP at levels from 6 percent to 44 percent by weight. Table 2 shows that even a chemical industry promotional toy contained high levels of DEHP, along with lead and cadmium. A recent Greenpeace investigation of toys sold in China and an earlier Greenpeace investigation of toys from 17 countries also found significant levels of DEHP. , 
3.1 Vinyl children's products slip through a regulatory loophole
Current laws, regulations and voluntary agreements fail to ensure the safety of children's products. No law required the items in Tables 1 and 2 to pass pre-market safety approval because the addition of toxic chemicals to children's products is not prohibited. In addition, there is no mechanism for evaluating the combined effect of two or more toxic ingredients-such as lead and DEHP-in the same product. Finally, no labels are required on toys to inform parents about the presence of these or other toxic ingredients in toys.
3.2 A materials-based policy is needed
Vinyl is the only commonly used plastic that requires both a metal stabilizer and a chemical softener to make a useful pliable product. To date, voluntary measures by industry have amounted to little more than a toxic shell game. In the face of public concern about one metal or phthalate, another is simply substituted to replace it. It is then left to the public to make the case against the next metal and the next phthalate. Manufacturers have no burden of proving that these ingredients are safe before adding them to children's products. Nor are they even required to avoid toxic ingredients in the first place.
The widespread availability of alternative materials to vinyl that do not require toxic metals or plasticizers makes eliminating vinyl children's products a realistic public health goal.
1. Parents should not purchase vinyl or PVC products to which children might be exposed. Vinyl children's products should be returned to the manufacturer or retailer.
2. Retailers, distributors, and manufacturers should remove vinyl children's products from the market.
3. The Consumer Product Safety Commission should regulate vinyl as a material. Vinyl children's products containing phthalates, lead, cadmium, or other untested or toxic additives should be recalled by the agency.
4. The Federal Hazardous Substances Act (FHSA) should be amended to require pre-market approval of toy additives and materials based on safety, and permit the CPSC to take precautionary action to prevent human exposure. In addition, the law should require labeling of existing toys to indicate material and chemical ingredients so that parents can make informed choices.
5. Congress should pass HR 1636, a bill introduced last year by Rep. Henry Waxman and 150 co-sponsors. HR1636 would require manufacturers to provide information to the government regarding toxic chemicals contained in children's products.
6. Retailers and trademark licensers should not market vinyl products to which children might be exposed. This should be made explicit in future sales and licensing agreements.
7. The plastics industry and toy manufacturers, through trade associations such as the Society of Plastics Industry and the Toy Manufacturers of America, should adopt an industry-wide standard against manufacturing children's products with vinyl.
Materials and Methods
Determinations by Stat Analysis, Chicago, Illinois, AIHA-, NIST/NVLAP-accredited. Samples from phthalate analysis were prepared according to ASTMD3421, which was modified to avoid using chlorinated solvents.  Analysis using GC/MS was performed essentially according to EPA Method 8270C. The total lead and cadmium content was measured using atomic absorption spectroscopy as previously described.  All samples were tested in duplicate.
Abbreviations: ppm= parts-per-million; mfr=manufacturer; nd=not detected; DINP=diisononyl phthalate; DEHP=di(2-ethyl hexyl) phthalate; MD= Maryland; MA= Massachusetts; IL= Illinois; CA=California; NY=New York. *This sample contained DINP not DEHP. Determinations by Stat Analysis, Chicago, IL. Results shown are the averages of duplicates. The average coefficients of variation were 20%, 21%, and 38% for lead, cadmium and phthalates respectively. The U.S. Consumer Product Safety Commission (CPSC) staff-recommended limit for lead in vinyl is 200 ppm. Cadmium is not regulated by the agency. Proposition 65 in California regulates cadmium at one-tenth the level set for lead. Teethers and rattles containing DINP are currently being voluntarily removed from commerce at the request of the Consumer Product Safety Commission. DEHP in teethers and rattles was voluntarily removed from commerce at the request of the Consumer Product Safety Commission in 1986 due to its carcinogenicity and reproductive toxicity.
Table 2. Vinyl Industry Promotional Product Contains Lead, Cadmium, and DEHP
Abbreviations: see Table 1. CMA=Chemical Manufacturers Association. The following text is included on the product: "Have a Ball! Vinyl .Another Product of Chlorine Chemistry"
Products with high levels of lead
* This measurement was subject to higher than normal variation These values were above the instrument detection limit (5 ppm), but below the quantification limit (10 ppm).
Products with high levels of cadmium
* This value was above the instrument detection limit (0.2 ppm), but below the quantification limit (1 ppm)
Notes on Canadian testing
1. A total of 32 PVC products were analyzed. All analyses were conducted by Stat Analysis Corporation, 2201 West Campbell Park Drive, Chicago (NVLAP and AIHA accredited laboratory), under the supervision of Dr. Benjamin Ruth, tel. (312) 733-0551.
2. Total lead and cadmium concentrations are averages of the two results showing the least relative percent differences (in all cases less than 30%) from a maximum of three duplicate preparations for any given sample. Early public drafts of Health Canada's "Strategy for Reducing Lead in Children's and Other Consumer Products" proposed a limit of just 15 parts per million total lead in such products. Paint manufacturers in Canada have agreed to a voluntary limit of 600 parts per million total lead. Staff of the Consumer Products Safety Commission (the responsible U.S. federal government agency) recommended a limit of 200 parts per million total lead for PVC mini-blinds. The blinds, which were the subject of a Health Canada warning in June 1996, contained up to 19,000 parts per million total lead. Regulations on cadmium from several different jurisdictions typically treat it as five to ten times more toxic than lead. Since 1994, PVC products containing over 100 parts per million cadmium have been banned in the European Union.
3. Extractable lead and cadmium concentrations were evaluated according to European Norm EN71-3 ("Safety of Toys - Part 3: Migration of certain elements"), in which shredded samples are placed in conditions mimicking those of a human stomach. In draft II of Health Canada's "Strategy for Reducing Lead in Children's and Other Consumer Products" (August 1997), 90 parts per million extractable lead (measured according to EN71-3) is proposed as the level for triggering "requests for product recalls, stopping further sales, and issuing public warnings." However, it is important to realize that products with levels of extractable lead lower than 90 parts per million can also release to children significant amounts of lead and cause health damage. For example, Health Canada has stated in its 1996 risk assessment for PVC mini-blinds that "any source of lead that results in any increase over the current blood level in a child is considered to be unacceptable".
4 ibid, and Maas, R.P., Smith, R.M., Patch, S.C., Thornton, L.R., "Assessment of potential lead exposure from children's vinyl products" UNC Asheville Environmental Quality Institute Technical Report #97-043. 1997.
11 Reproductive and Cancer Hazard Assessment Division, Health Hazard Assessment Division, California Department of Health Services. "Risk-specific intake levels for the Proposition 65 carcinogen cadmium". 1990.
16 Myers, B.S. "13-week subchronic dietary oral toxicity study with di(isononyl) phthalate in Fischer 344 rats (final report) with cover letter dated 5/20/92: supplemental information. Hazelton Laboratories Washington. EPA/OTS Doc#89-920000224. 1991.
17 US EPA "Subchronic (4-week) dietary oral toxicity study of di(isononyl) phthalate in B6C3Fa mice (final report) with cover sheet dated 5/29/91. Hazelton Laboratories, Washington. EPA/OTS Doc #86-910000793. 1991.
18 US EPA. "13-week subchronic dietary oral toxicity study with di(isononyl) phthalate in mice, with cover letter dated 7/6/92 and attachments: supplement. American College of Veterinary Pathology. EPA/OTS Doc#89-020000303. 1992.
22 Toloken, S. "Vinyl toy controversy mounts worldwide" "DEHP is used in negligible amounts in toys in the United States and Europe, after the United States phased out its use in the mid-1980s, Cadogan said." David Cadogan, is the director of the European Council for Plasticizers and Intermediates. Plastics News. December 7, 1998.
24 Stringer, R., Labounskaia, I., Santillo, D., Johnston, P., Siddorn, J., Stephenson, A. "Determination of the composition and quantity of phthalate ester additives in PVC children's toys." Greenpeace Research Laboratories Technical Note 06/97. 1997.
25 Stringer, R., Labounskaia, I., Santillo, D., Johnston, P., Siddorn, J., Stephenson, A. "Determination of the composition and quantity of phthalate ester additives in PVC children's toys." Greenpeace Research Laboratories Technical Note 06/97. 1997.