Is it Safe? Identifying Hazards in Toys and other products for children; 
Finding Safe Toys - updated February 11, 2010
© 2008-2010  Edward Loewenton; Revised 2/11/2010   Please read copyright notice.
You should also read:
*Original article in this series (Aug. 15, 2007)    
*A detailed article on lead toxicity, especially in PVC Plastics 
Update March 2010: CPSIA update: Politics, hysteria, and unintended consequences
*Update October 2008: CPSC publishes stronger limits on lead

          Mechanical hazards include small parts that may result in choking or swallowing, sharp edges, fragile materials or flimsy construction with risk of collapse or breakage resulting in small parts or sharp edges, toys intended to get hot, or large toys too unstable or fragile for children at the age level for which the product is intended. Soft fabric (sewn) toys such as stuffed animals for infants and toddlers may have weak stitching or glued attachments, with resulting choke hazards. 
     Toys that involve launching a projectile or the toy itself (slingshot action) are hazardous by design, and should be reserved for older children who understand risks and precautions, and have sufficient motor skills to use them safely.  Such toys should be inspected before use to ensure they at least work reliably as intended, without introducing unforeseeable hazards not part of the design. 
     Mechanical hazard is especially age-dependent.  The impulsivity and lack of coordination and experience in younger children puts them at risk in using toys and other products that are safe for older people. For example, small parts are usually only a hazard for children who are still putting things in their mouths, even if the small parts are generated by a mechanical failure or mishandling of the product. It mostly comes down to adult supervision, guidance, and teaching. In fact, misleading age designation and inadequate product directions could be considered a fifth kind of hazard that may result in considerable harm.
   
     I would regard risk from heat injury (burns) as a kind of mechanical hazard when they occur in toys or tools that are intended to get hot, like toy bake ovens and soldering irons used to assemble kits. This, again, is a matter of age, supervision, teaching, and the child's experience.  However, some toys such as bake ovens are explicitly sold for children likely to be too young to observe necessary precautions, and are probably fundamentally defective in concept, i.e., a bad idea to start with.   
     A recent example is the recall of the Hasbro Easy-Bake Oven; 249 children caught their hands in the doors, with 77 reports of severe burns. This incident may be as much an example of bad design or concept as poor quality manufacture.  (Wouldn't it be better for even young toddlers to participate with Mom or Dad in simple baking in a real oven, along with whatever else is being baked "for real"?)

      There are also toys that malfunction and generate temperatures not intended by the designer, or actually catch fire. Parents should inspect heat-generating toys regularly and take them away if they are worn or damaged, or getting dangerously hot. 

     The new high-energy batteries such as Lithium Polymer (LiPo) have been known to overheat and catch fire. If rechargeable batteries are involved, parents must either be certain children learn to use them correctly and that all product warnings are heeded, or do the charging and installation themselves.  There have been a number of toy recalls in the past year due to batteries overheating while being charged. Parents should observe the toy the first time the battery is charged for signs of overheating; a recharging battery should never be left unattended, especially if it is charged while still installed in the toy, which can trap and concentrate heat. If the battery or toy starts getting too hot to touch, disconnect the charger.
   
     Serious electrical hazards are mostly absent in toys, since electronic toys use low voltage-low current batteries. Use of anything that plugs into house current should be closely supervised in younger children until parents are certain that children fully understand the hazards involved.  An exception: riding toys powered by 12-volt batteries.  There was a recent recall of such vehicles due to defective or undersize wiring causing short circuits and fires. Consumers should inspect such toys critically for signs of poor quality before buying, especially since these are designed for use by toddlers. Wiring that is exposed to friction, pulling, any potential movement or other mechanical stress during play is hazardous. Do not use a toy that has wire that is frayed or of too small gauge, or has loose connections. Larger batteries capable of powering a riding toy should be securely held in place and inaccessible to the child, even after a tip-over or crash. 
          
     A review of the CPSC's list of recalls of toys for the twelve months prior to writing this article (http://www.cpsc.gov/cpscpub/prerel/category/toy.html)  reveals many that were recalled for mechanical hazards such as loose or small parts, including insecurely attached magnets that are especially dangerous. Other defects include tip hazard (poorly balanced), fragile parts that broke leaving sharp edges, and overheating batteries. Most of these toys were made in China, although mechanical hazards, some quite serious, were found in toys manufactured in the U.S., Taiwan,  Mexico, South Africa, and other nations. 
    It is not clear in regard to any of the imported recalled toys whether the mechanical defects were the responsibility of the Chinese factory that made them or the American importer who specified the design or materials, or simply demanded a price so low that the use of better quality components was impossible.  Among the mostly wooden toys I have personally inspected, loose parts are typically caused by the wrong choice of glue. Some of these were made in the U. S., by the way.
     Almost all the hazards in the CPSC recalls were found in toys intended for children younger than 3 years old, or likely to be attractive to them.  Play can be made much safer if we make sure that an older child's toys are not accessible to his or her younger siblings. A few recalls were issued for toys that were neither defective nor dangerous for the intended age stated on the label, but had fallen into the hands of children below that age. This seems like a supervision failure.
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Avoiding Mechanical, Heat, and Electrical Hazards
     A parent or other adult caregiver should assemble, inspect, and possibly test toys before allowing younger children to use them if there is any possible question about safety. With children older than 7 or 8, it may be sufficient to ensure that the child has developed a realistic awareness of hazards and a proper sense of precaution. For high performance toys or those intended to bear weight, including athletic gear, the best course may to be for a parent to inspect and test the new toy with the child in a collaborative manner. Requirements should be age appropriate.  For example, small parts are not usually dangerous for children older than three years, but a riding toy for a 10-year-old must support more weight and rougher handling than for a toddler.
*Inspect for sharp edges, both with the eyes and hands.
*Tug on glued or stitched parts to test for separation due to weak stitching or fasteners, poor glue joints, etc. This may reveal a tendency to expose small parts or sharp edges or points.
*Apply impact comparable to what is anticipated in normal use to test for fragility, especially tendency to break or come apart and expose sharp points or small parts. 
*Test for sturdiness, balance and weight-bearing capacity of toys or furniture that children will sit, stand, or ride on. Such a toy should support a brief static load of at least double the advertised working load. Play furniture should not tip over even if a toddler bumps it or yanks a door open. We used to carry a wooden balance bike rated at 50 lbs working load; we tested it with a weight of 150 lbs. 
*With older children, parents should at least be aware of what toys their children are playing with and how these toys are performing.
*Inspect periodically for wear or breakage that may cause hazards.
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Chemical Hazards
     Toxicity hazards cannot be identified by visual inspection. Identifying a chemical hazard requires chemically testing the product, a process not easily available to most consumers. (We will discuss the value of inexpensive swab-type testing kits later in this article.)  For this reason, it is helpful to know what kinds of materials are most likely to present a toxicity hazard and avoid them.
     Chemical hazards in toys are most often due to lead content, although there are isolated examples of poisoning by other substances in toys intended for older children that are swallowed by infants and toddlers. A majority of the toys recalled by the U.S. CPSC during the past 18 months were taken off the market because of high lead content, and all but two of these were made in China. One each came from Taiwan and South Korea. In developing economies, where the ethical and political regulatory environment is still catching up to that of the developed Western nations, lead is probably still in widespread use as an inexpensive and easy-to-use industrial feedstock. 
     Lead is poisonous to the nervous system, especially while it is  developing throughout gestation, childhood and into the teens.  Despite the limits set by the CPSC and other authorities, there is no safe lower rate of exposure, since lead accumulates in the nervous system and in bone. More detail about the dangers of lead poisoning may be read at 
 http://www.turnertoys.com/lead-hazard/default.htm#Lead-hazard 
and 
 http://www.turnertoys.com/pvc3Stabilizers.htm .
     In a previous article, I provided links to some of the many news articles reporting discoveries of lead in Chinese toys, as well as other chemical contaminants in a variety of products including drugs, pet foods, and farm-raised fish. This probably came about due to the difficulty of detecting these hazards without lab testing and enforced regulation, which until very recently have been effectively nonexistent in Chinese industry. This has been compounded by complacency and greed among importers and lack of adequate inspection in the U. S. and elsewhere. 
     It is important to keep in mind the distinction between defective materials and poor quality manufacture, due not only to greed but also to ignorance of correct industrial methods, and hazards designed into the product. The former is mostly the fault of the overseas factory, although unrealistic demands for low cost by American importers contribute to it.  The latter is largely the fault of the American importer, who is responsible for designing and specifying safe, functional, and age-appropriate products. 

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Chinese imports: And now for the good news
     Although there have been recalls for chemical hazards of consumer products other than toys coming from a variety of nations including China, when it comes to toys, the label "Made in China" must at this time serve as a red flag.  There have been nearly no recalls of toys coming from elsewhere in the world, including and most notably Thailand, the other Asian nation with a large and well-developed toy industry. In fact, Thailand has had a sophisticated and modern wood products manufacturing industry for many years, and makes some of the safest, sturdiest, and best-designed wooden toys in the world.  Some of our toys are made in Thailand, including the doll houses and furniture, some of our toddler furniture and play kitchen, and some of our wooden unit block sets. 
In China
     The Chinese government, aware of the potentially disastrous effect these problems may have on their export-driven economy, have started to require laboratory testing of exports before they may be shipped. The government has also closed down hundreds of smaller sub-contracting factories who have been causing much of the problem. However, they have far too few laboratories to do all the testing. The result has been the inability of many importers to get their products shipped in a timely fashion.  One we know had almost no inventory to ship from during the 2007 Holiday season.  Since October, 2007, we have had occaional problems with timely availability of products from our American suppliers who import, with no guarantee as to when we may receive them. They, in turn, are having trouble scheduling shipments from overseas.
     The results will ultimately be safer toys at higher prices. The factories in China are going to have to charge more, as they begin using only more expensive, safer materials and better processes.  I would suggest that Chinese toys be purchased with caution and awareness of potential hazards for at least another year or so while all the toys now in inventory are either sold or are identified as hazardous and destroyed. I do believe that the problems with imported toys will be much reduced by then. 
In the United States
      American importers with Chinese sources are also playing a part in reducing potential hazards in toys, or are at least claiming that they are. One of our vendors, Guidecraft, has a program in place that comes very close to my personal standards of scientific verification.  Guidecraft makes some of the furniture  and play kitchens we sell.  The design, both cosmetic and structural, is excellent, the manufacturing quality has alway been good with an occasional disappointing exception, and now they are testing their paint finishes in a manner that even I approve of.  The paint for each purchase order is specified as a separate batch and laboratory tested in China.  These results are verified by sampling the finished product as it arrives in the United States, to be certain that the tested paint was actually used to make the toys.  This is the protocol that should be followed as a minimum standard.  Guidecraft has factories in China and Thailand. 
     
Here is what you can do to avoid chemical hazard
     You cannot identify toys with high lead content or other chemicals by visual inspection, but you can identify and avoid the kinds of products where toxic chemicals might be found, and feel secure purchasing other  toys where such chemicals are not likely or cannot be present. You can also do testing at home with some degree of accuracy.
     I recommend the use of Lead Check swab test kits. (http://www.leadcheck.com). Lead in most products is added deliberately as stabilizer or pigment, and is in sufficient quantity to be detected with reasonable reliability with simple swab tests.  Note that although a false positive is very unlikely, a negative result does not guarantee the absence of lead, merely that the lead content is below approximately 600 ppm.. 
     The mass media have been very unhelpful in uncritically reporting the 2007-2008 comments of the toy industry to the effect that these tests are not valid, based on a biased reading of a flawed and altogether unscientific "experiment" conduct by the CPSC. If used correctly, swab tests can detect lead concentration as low as 600 parts per million (the CPSC maximum permitted concentration) on product surfaces.  As of February 2009, these limits will be reduced, until a level of 100 ppm becomes law in August, 2011, so swab tests cannot be used to determine if a toys is "legal".

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Where lead and other toxic chemicals may be found, and where they won't be found
     Lead and other toxic chemicals, if they are present, are most likely to be found in paint and cheap cast metal products, especially jewelry, Vinyl may contain lead (alway a hazard), and always contains phthalates, which are a hazard primarily when ingested by infants and toddlers. Lead in products that are to be handled without protection is an unacceptable risk for people of any age. Other less-toxic materials may be aceptable if they add functionality to products for children old enough to know how to use them safely. 
     Toys that rely on some sort of chemical process in order to work are hazardous to young children that put things in their mouths, but generally not to older children. Examples are "science kits", glues, paints, and other craft supplies. 
     Toys that contain sealed liquids may be hazardous depending on the nature of the liquid and the sturdiness and reliability of the material containing the liquid.  There are some odd examples of inappropriate and dangerous materials used in unexpected applications. An example: in July, 2007, a "flashing eyeball" toy was recalled because the eyes were filled with kerosene, an obvious chemical hazard in case of breakage or leaks.  What were they thinking?
Cheap cast metal jewelry or other metal toys
     Lead is an inexpensive material that melts at a low temperature and is soft and easy to work.  This makes it a good choice from the standpoint of easy profit-making, but it is still a very bad choice in regard to chemical safety. Lead jewelry is likely to be found in vending machines and as prizes, as well as in the general retail toy market. I would simply suggest that you not let your children have anything like that.  Another hazard is that such items are inherently made of small parts, and are a hazard per se regardless of composition if they fall into the hands of toddlers.  One advantage you have here is that toys actually made from lead are very easy to detect with swab-type kits, as long as you test not only the surface but also the substrate, by scraping through any layers of surface material before testing.
Painted products:
     Lead compounds have been the preferred colorants in paints for centuries worldwide. It is only in recent decades that the awareness of their dangers motivated regulation and switching to other kinds of pigments in the developed world. Not until 1978 did the CPSC banned the use of lead in paint for residential use. Lead pigments were, of course, used in American toys and other products as well as housepaint until the 60's or 70's.  Thus it is not surprising that lead-pigmented paints are being used by Chinese manufacturers.  Much of the problem has been caused by small mom-&-pop subcontract operations who switch formulas on the big factories without warning.  Hundreds of them have been shut down by the Chinese government. 
     Although things are getting better, it may be wise to avoid painted toys made in China unless you can verify their safety. Turnertoys sells some of these toys, and we do take steps to verify safety and explain our reasoning to you. (See 
 http://www.turnertoys.com/made-in-USA/country-of-origin.htm 
for details.)
     Anything we keep in inventory we have tested with LeadCheck swab test kits.  High levels of lead can reliably be detected with these kits if they are used correctly. These kits are available for home use. For the larger drop-shipped items where we cannot inspect each item that goes out, we ask for descriptions of the quality control program and decide whether we can endorse it. We also obtain copies of lab test reports. 
       The only other drop-shipped toys we have that are painted in China are the steel pedal cars. 
 www.turnertoys.com/classic-steel-pedal-cars/classic-steel-pedal-cars.htm 
We had a chance to inspect our vendors' (Warehouse 36 and American Retro) products at the New York Toy Fair last month, and they have switched to polyester powder coating.  This finish is not only far more durable than paint, it is a high-tech coating that is not typically formulated with lead or other heavy metals. This is a new development since last year, and more good news.

     
Products made from vinyl (PVC) or certain other plastics
     Despite Vinyl industry claims, it appears that vinyl, or Polyvinyl Chloride (PVC) may still sometimes be stabilized with lead, at least in products made in China. One of the most spectacular infant product hazards recently reported was the vinyl feeding bibs with very high lead content. PVC among plastics is uniquely dependent upon plasticizers, i.e., phthalates, and stabilizers such as lead or other metallic compounds for its flexibility and stability. Both the plasticizers and stabilizers are emitted by PVC during use, and are available for ingestion, either when the object is placed in the mouth, or through contact with hands which are placed in the mouth. There has not been recent evidence of lead in American-formulated PVC used for children's products, although there were infant deaths due to lead-stabilized PVC in U.S.-made mini-blinds in the mid-1990's. 
(http://www.turnertoys.com/pvc3Stabilizers.htm )

     Even if poisonous lead is not present in PVC, there is now sufficient evidence that phthalates cause pathological  alterations in the sexual development of male mammals to suggest that products made from PVC not be used for objects that may end up in a child's mouth or be ingested by pregnant women. This applies most strongly to the period including gestation up to about 12 months. 
(1. Gray LE Jr, Ostby J, Furr J, Price M, Veeramachaneni DN, Parks L.
Perinatal exposure to the phthalates DEHP, BBP, and DINP, 
but not DEP, DMP, or DOTP, alters sexual differentiation of the male rat. Toxicol Sci. 2000 Dec;58(2):350-65 
2. Wade V. Welshons, Susan C. Nagel and Frederick S. vom Saal 
Large Effects from Small Exposures. III. Endocrine Mechanisms Mediating Effects of Bisphenol A at Levels of Human Exposure.
Endocrinology Vol. 147, No. 6 s56-s69
 http://endo.endojournals.org/cgi/content/full/147/6/s56  
3. Ramos JG, Varayoud J, Sonnenschein C, Soto AM, Muñoz De Toro M, Luque EH.  Prenatal exposure to low doses of bisphenol A alters the periductal stroma and glandular cell function in the rat ventral prostate.
Biology of Reproduction. 2001 Oct;65(4):1271-7
 http://www.biolreprod.org/cgi/content/full/65/4/1271  )

     Although manufacturers have resisted inquiries about the types of plastics used for infant toys, that resistance is softening.  I suggest you determine what kind of materials are used in the plastic toys you are buying for infants and very young children. Insist on knowing or do not buy it. Polyethylene and polypropylene are acceptable safe subsitutes. For teething toys, washable cloth or unfinished wood toys
 http://www.turnertoys.com/wood_rattle.htm  are acceptable, as are crackers, carrots, cold washcloths, or toast.
     Polycarbonate, the hard clear plastic often used for utensils, dishware, and bottles, is also unsuitable for very young children. The basic monomer compound used to make polycarbonate is Bisphenol-A, a synthetic estrogen, and the plastic has been shown to degrade into this compound with aging. It has been shown in mammals to interfere with sexual development.  
(Complete information at  http://www.turnertoys.com/Polymer_update20051009.htm )

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Finding subsititutes for Vinyl and Polycarbonate
 http://www.turnertoys.com/Polymer_update20051009.htm  
    Consider using stainless steel or glass for food handling,  along with silicone for bottle nipples or pacifiers.   "Silicone rubber" can have all sorts of additives, including PVC, so be sure to use medical grade silicone only! Buy only known brands that specify this. Polypropylene or polyethylene are widely used in molded plastic toys, and are inherently chemically safe, as well as strong and durable. 
     Soft (i.e., very high phthalate plasticizer content) PVC has long been used as a fabric or leather substitute in many applications, especially where ease of cleaning is desired.  This is a bad choice of materials for young children. In children's furniture coverings, bibs, crib mats, soft toys, backpacks, and so on, consider using cloth and doing a little more washing and cleaning.  Like many other things in life, it involves a tradeoff. 
     A relatively new polymer, Polyethersulfone, or PES, is now being used by a few manufacturers as a replacement for polycarbonate.  It is so chemically inert and non-toxic that it is used for laboratory-grade filters; it is clear, tough, and so heat resistant it can be sterilized repeatedly with no degradation. It requires no additives. I have found a company that makes PES  baby bottles with medical grade silicone nipples  (http://www.greentogrow.com ).   There are several other companies now making PES bottles.
     We considered selling these PES baby bottles. However, I decided that the old standby, glass baby bottles, just cannot be beat.  They are a known safe alternative, and there is a brand that is wrapped in a  shock-absorbing synthetic rubber jacket, which greatly reduces breakage problems. 

Added February 2010:
     After the CPSIA 2008 (see article CPSC publishes stronger limits on lead) was signed into law, it was the responsibility of the Consumer Product Safety Commission (CPSC) to translate the law into enforceable regulation. During the period of public comment (which continues), original enforcement dates have been postponed at least once, due to testimony by manufacturers and retailers regarding the unwarranted hardships imposed by the regulations as originally proposed. 

Ed Loewenton
March, 2008
www.turnertoys.com 

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