Scientific Response to the Greenpeace "Exposé" Lead and Cadmium in Vinyl Children's Products

In October 1997, Greenpeace published an "exposé" on lead and cadmium in certain children's products made with polyvinyl chloride (PVC). Greenpeace has utilized this report to campaign against the dangers of "toxic toys." In response, the Vinyl Institute commissioned ENVIRON Corporation, an independent scientific consultant, to review the Greenpeace findings. That report concludes:

"There are clear shortcomings with regard to the utility or the appropriateness of the methods employed by Greenpeace in their assessment of lead and cadmium in vinyl children's products. This includes numerous instances where Greenpeace has misinterpreted or misrepresented their own data. Because of the inappropriate use of that test data, the conclusions and implications drawn from these misinterpretations are not scientifically sound." Duncan Turnbull, D. Phil., D.A.B.T., ENVIRON Corporation.

Other conclusions from the ENVIRON analysis include:

Greenpeace Finding: Lead and cadmium are widely present in vinyl consumer products including those designed for children.

ENVIRON Conclusion: A finding that lead or cadmium is present at low levels in a group of consumer products, even if true, is not at all useful in assessing the safety of those consumer products. There must be a potential for exposure to these substances; the substance must be released from the product before any harm can occur.

Greenpeace Finding: The amount of lead present in many vinyl consumer products exceeds current Consumer Product Safety Commission (CPSC) regulations as well as the formal staff-recommended limit for lead in vinyl.

ENVIRON Conclusion: This allegation is incorrect when the data for the various products are compared on an apples-to-apples basis. Greenpeace reported the total amount of lead rather than expressing the levels on a standardized (per square inch) basis, the standard procedure for reporting or describing surface lead levels. When the data is standardized, a child would have to come into contact with a much larger surface area of a product to be exposed to hazardous levels of lead. Under these conditions, the "dust levels" of lead as calculated by Greenpeace, are actually ten times below the exposure limits established by CPSC and the US Enviromental Protection Agency.

Greenpeace Finding: Lead and cadmium in vinyl consumer products represents a health hazard since both are inevitably released as toxic dust when the product deteriorates.

ENVIRON Conclusion: This statement is based on the findings of an accelerated aging study. The study itself was inappropriate for the products that were tested. None of these products would be exposed to the extreme testing conditions (i.e., excessive exposure to sunlight, or heat) during customary or reasonable use that the aging study was intended to mimic. Furthermore, even under these extreme testing conditions, the amount of lead or cadmium released did not exceed established exposure limits.

Greenpeace Finding: The amount of lead and cadmium released by a representative sample of vinyl consumer products violates California's Safe Drinking Water and Toxic Enforcement Act of 1986.

ENVIRON Conclusion: Because the data reported by Greenpeace are not based on reasonably anticipated exposure scenarios or sound scientific principles, an estimate of the amount of lead and cadmium released by various vinyl products would require further thorough evaluation. In addition, there is no indication that the selection of products for testing was a "representative" sampling of available vinyl children's products.

Greenpeace Finding: Both lead and cadmium are readily available for ingestion by children. Lead and cadmium were released to the surface of products as they aged. Lead also became available under conditions that mimic accidental swallowing.

ENVIRON Conclusion:

• The amount of lead or cadmium that a child would have to ingest to exceed the established exposure limits, particularly on a chronic basis, is highly implausible or physically impossible.
• The assumption that children eat (i.e., chew off and swallow) significant amounts of these toys and accessories is unsupported, particularly the amount children would have to ingest over an extended period of time for any toxic effects to arise.

Additionally:

• In contrast to statements made by Greenpeace, the lead and cadmium content of consumer products is regulated. CPSC has a long history of action when safe levels of lead in products are exceeded.
• The conclusions presented by Greenpeace are in direct opposition to the conclusions reached by federal regulatory authorities in both the US (the Consumer Product Safety Commission) and Canada (the Product Safety Bureau of Health Canada). Both of these agencies concluded that lead and cadmium were not released in harmful amounts from the vinyl products after looking at the issues Greenpeace raised.

To order a copy of the ENVIRON report, call the Vinyl Institute at (973) 898-6699.