Lead Hazard in Children's Toys:
The nature of the problem and what can be done (August 15, 2007)
Turnertoys disclaims responsibility for and is not liable for typographical errors or errors of omission.
March, 2010: CPSIA update: Politics, hysteria, economics, and unintended
October, 2008 Update:
New CPSC rule tightens limits on lead in toys
March, 2008 Update:
Identifying safe toys and toys that may be hazardous
August 2007: Made in China - an issue of health and safety
Use of Lead in PVC (Vinyl) for toys and other products
(from our original reference on PVC)
Complete list of Turnertoys products & country of origin
List of Turnertoys products that are made in USA
*The nature of the problem - Imports from China
*Why is lead a problem?
*Where is lead found? Where is it not found?
*Turnertoys products: where they are made and
which ones are
potential lead hazards
*Turnertoys testing of toys that might contain lead
- what the test
results indicate (and what they do not)
*Information from our dropship vendors
*What can be done - what should be done
The nature of the problem
By now you have certainly heard about the disturbing news of hazardous foods, pharmaceuticals, toys, and tires exported by Chinese manufacturers.
Read our first article at
You can read our extensive articles on PVC, lead, and juvenile product safety at
and more background on the hazards of imported products
I had thought that, at least in regard to toys, Chinese manufacturers had by the late 1990's largely eliminated safety hazards such as lead and cadmium in painted finishes and in PVC. I am annoyed and embarassed to say I was wrong about that. It seems that as soon as no one is looking too closely,
Chinese producers will try to cut corners. The most spectacular recent results of this sort of business
ethic have been the recall of thousands of Thomas the Tank Engine toy trains
and almost one million Mattell toys, including Sesame Street and Nickelodeon characters such as Elmo Tub Sub, the Dora the Explorer Backpack, and the Giggle Gabber
because of lead in the paint finishes.
And now again, Mattell has had to recall nearly
19 million toys, many for lead in the paint finishes of
"Sarge" toy jeeps. We read, also, that thousands of baby bibs
made from lead-stabilized or lead-pigmented PVC are on the shelves
at Toys-R-Us, or have already been purchased for use with infants, and,
astoundingly, no recall has been issued!
Mattell and RC2 Corporation, the toy importers, had provided specifications for the finishes, but at some point their Chinese
factories made unannounced change in the paint formula. It is to the credit
of both companies that they identified the problem quickly and initiated prompt recalls on their own.
An August 9 article in the Wall Street
examines the value of lead test kits, and cites a Consumer Product
Safety Commision (CPSC) spokesperson as suggesting they may be
inaccurate and misleading. The article seems to suggest that there is
not much parents can do about the problem except discard all children's
products made in China. I think that is a needlessly expensive gesture
based on a lack of understanding of exactly what is a hazard and what is
Moreover, the article seems to discourage
parents from taking reasonable steps to identify toy hazards and
concentrate on getting rid of only those toys that are actually
dangerous. Available lead test kits can yield useful results if the kits
are used properly and interpreted with knowledge of their limits.
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Lead in Children's Products: Why is it such a problem? Where is it
most likely to be found?
Arguments about "safe" levels of lead
in children's products are specious, based on an entirely outdated
understanding of the biology, especially the neurobiology, of growing
young children. I think that when these arguments come from official sources, such
as the CPSC, they are disingenuous and ultimately politically driven,
with a view to protecting potentially affected economic interests.
Lead accumulates in the body, both in nerve
tissue and bone. Ingested lead is only partially excreted in urine,
feces, and sweat. It can replace Calcium in both tissues, thus
compromising nerve conduction and response and adding to a "savings bank"
of accumulated lead in bone. The affinity of lead for nerve tissue is a
significant problem for growing children; the younger they are, the more
vulnerable. The consequences of low levels of lead in the nervous system may include
behavioral problems and cognitive impairment. High blood levels
can be fatal.
The accumulation of lead in bone makes lead
ingestion especially worrisome for females. During periods of high
demand for available calcium, such as lactation after pregnancy, or in
the context of bone loss associated with osteoporosis, lead is
released into the blood along with calcium. In the case of nursing
mothers with high blood lead levels, the lead can end up in the milk
supply. It has also been speculated that high blood lead content
in elderly women may contribute to symptoms of dementia.
Although there may a safe blood level for
children, now accepted by many scientists as below 10µ (microgram) per
deciliter (1/10 liter -dl) of blood, there is really no safe level of
content for a product. This is because lead in the bloodstream is in a
dynamic equilibrium with lead stored in body tissue, predominantly bone.
At a low level of blood lead, lead may continue to accumulate in bone
and other tissues, so that under conditions where the stored lead is
released, there may a much higher level in blood.
Further, it is not correct to state that a
level of lead available for ingestion from a single source may be
acceptable, since there are usually multiple,
individually insignificant sources of lead in a young child's
environment, that taken together can result in a sigificant cumulative
Thus, the CPSC's statement that PVC bibs
containing lead were safe to use as long as they were not torn or
scratched is extremely unhelpful misinformation. It is simply incorrect.
The chances are that the lead
is being used as a stabilizer in the PVC, in which case lead dust
will continuously migrate to the surface and become available for
ingestion under any circumstances, albeit faster if the PVC is exposed
to mechanical stress, UV light, or heat.
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Materials that are likely or unlikely to contain lead
With the understanding that lead is always a
hazard, it is important also to realize that not all products from China
contain lead. In some cases, the decision is easy to make without
the need for testing or regulation.
If it is not painted or colored, not made of
PVC, and not made of metal, it is very unlikely that a product can
contain any lead. Clear PVC does not contain lead, although it
must necessarily contain phthalates. Unfinished wooden toys, such as
blocks, do not contain lead no matter where they are made. It is very
unlikely that polyethylene, polypropylene, polyester, or nylon will
contain lead, whether colored or not. Likewise, clear lacquer finishes
on wooden toys or furniture will not contain lead. However, we are aware
of a recent discovery that a styrene plastic part used in a wooden toy and
made in the U.S. used lead pigment for its red coloring.
Brass is almost always alloyed with small
amounts of lead to allow easier machining. There are also alloys of
aluminum that contain a few percent lead, and that may be used for the
same reason in cheap bicycles and other structural applications. These
alloys are much less of a hazard than lead-stabilized PVC, which
continually emits lead dust, or cheap lead-bearing jewelry which may be
swallowed and release biologically available lead because of exposure to
So our watchlist of products that may
present a lead hazard to children include cheap metal jewelry and
castings, painted metal, plastic, and wooden
toys and furniture, and all colored PVC. A lesser hazard is
presented by brass and lower-priced aluminum parts,
There are many toys on the market that fit these
descriptions, and are also made in China. However, regardless of where
they are made, these are the materials that may possibly contain lead. These are the ones on which we
want to focus our attention; these are the ones we need to test for
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Where our toys are made; how we know that they are safe
Complete list of Turnertoys products: country of
origin and safety assessment
List of Turnertoys products that are made in USA
At Turnertoys, we are taking what steps we can to assure the safety of everything we sell. We have never carried products that, for reasons of design or manufacturing quality, we believed might pose a safety hazard of any sort. We have made the hard decision not to carry products that were carried by many of our competitors, and that we knew we could sell, because we did not feel they met our standards of safety and quality.
For this reason, and because of the immediacy of the hazard suggested by the Thomas toy trains
and Mattell incidents, we are concentrating on establishing the absence of lead toxicity in the paints of the toys we sell. Lacquer or varnish (clear finish on natural wood) is less of a concern
because these finishes have no pigments, which is where metals such as lead are found. Likewise,
completely unfinished wooden products such as unit
blocks, Haba Architectural
and Action Blocks, and My Very Own® Rattle
cannot present a lead hazard or any similar toxicity problem.
Only one category of toy that we sell is a candidate for heavy metal
toxicity: painted toys. The
other likely loci of lead content are cheap cast metal products, such as
jewelry; and PVC (vinyl), in which lead may be
found either as pigment to provide bright color (usually red or yellow) or as
stabilizer (see What is PVC (vinyl)? Use of Lead and other stabilizers).
We sell no toys that fit either of those descriptions. A few of our toys are packaged in clear PVC, which
cannot contain lead.
We keep in inventory most of the toys we sell
(everything but the large items, such as furniture and riding or rocking toys).
Relatively few of the toys we carry in inventory are painted.
Most of our toys are not made in China
Our primary concern is with toys manufactured in China.
Only some of our toys are made there. Most of our
toys decorated with paint are made either in Germany, or in the USA. These
include the colorful wooden block sets in our Block
Shoppe. Most of the Haba Architectural Blocks are made in China of
European Hardwoods such as beechwood, but have no finish, and so
cannot constitute a lead hazard, and are also CE certified.
All of our wooden toy trains
and accessories were made in the U.S. Many of the Haba or T.C. Timber products
(Storybook World and Action block sets
in The Block Shoppe ) are made in
Germany and are CE certified (EN71 - a rigorous standard required for toys sold in the European Union, that includes destructive testing and chemical
analysis of both product and package). The alphabet blocks are made in
USA, and are also CE certified.
The pegs for the Jumpo and Ntangle were made in USA (by us, the Elwood Turner Co) with non-toxic paints.
Log Sets, Slinky,
and Gyroscope are
made in USA. My Very Own® Rattle is
made in the USA. The Unit Blocks are made either in USA or China, but in
any case, are not painted.
Among our "Folk
Toys", only the Old Fashioned
Top, the throwing
top, Jacobs Ladder, and the Sew'N'Sew stitching block are made in China.
The PDI 2-layer wooden puzzles and the
Haba Sunnyland puzzles are also made in
China. We have tested these for lead with negative results (see below). The Jumbo puzzles are made in
Our wooden flying toys have essentially no paint, and are not of concern.
All of the balsa planes, gliders, and
model kits are made in USA.
Our plastic flying toys
and accessories have no PVC, the only plastic with a potential for lead content.
The Tim Flying Bird is made
in China, but contains no PVC (we tested it anyway). The Titan
airplane is made in Germany. Lead would not typically be part of the formulation for
plastics other than PVC, and does not appear to be in common current use
in the pigments (Google search).
Our kites are all made in China,
but are all either nylon or Tyvek. The crayons in the Creative
Diamond kites are potential lead sources, but our lead tests were
negative (see below). A small sampling of the non-PVC plastic parts in
these toys revealed no lead in the pigments.
Rigs construction vehicles are made in China, but are not painted; and further, have CE, ASTM, and
ISO9001 certifications, indicating very high quality standards. We rely on the
fact that they are not painted, however, not on the one-time test
results leading to the various certifications.
by Real Good Toys are made in Thailand, not China. (Their dollhouse kits are
made in USA.) Thailand has had a mature, technically sophisticated wood products
industry for at least 15 years, and has not ever been found to generate the
sorts of quality problems that been have associated with Chinese-made toys.
Nonetheless, we have requested formal data from the importer. The dollhouse
furniture is imported from Asia, but is not painted, thus not a toxicity
Little Colorado Furniture is made in the USA, using
American-made paints (we understand it is Sherwin-Williams).
Some of our large items of furniture made by
Guidecraft is imported from China; however, some may be made in Thailand, not in China,
although we generally have no easy way to find this out.
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Larger Toys - our Drop-ship Vendors
Most of the larger toys are drop-shipped, that is, sent directly from the manufacturer's or importer's warehouse to the customer. However, we have been able to examine these carefully and critically at Toy Fair each year, and in the case of the
Dory, have paid several visits to the factory in Warren, Vermont.
We have not performed our own lead tests on these
drop-shipped products. At this time, we have requested formal statements from our drop-ship suppliers regarding
safety of their products, primarily with regard to paints and finishes. We are still waiting to receive
and wagons are made either in the U.S. or China. There is no paint on them. The runners are powder-coated, essentially a baked enamel finish. These sleds and wagons have been lab tested, and we
have available to us a copy of the results. Our Vermont Rocking
Dory is painted with American-made, brand-name paint, for which we have the
Our new line of Kettler®
premium wheeled toys are made in Germany, and are not painted. They have a
polyester powder-coat finish, completely non-toxic, and far less degradable with
wear than paint. The plastic parts are polyethylene, which does not present a
lead hazard (nor any other acute chemical hazard - see polymer
safety update). The Kettler® products are all CE certified.
The two greatest concentrations of painted products among
the large, drop-shipped items we carry are the
(Asia) and Little Colorado play furniture (USA) items (Kitchens, table & chair sets, craft tables, etc.) and the
Little Colorado Furniture is made in the USA, using
American-made paints (we understand it is Sherwin-Williams). We have an informal statement from Guidecraft that a staff member visits the Chinese factories monthly, and that the finishes are or have been subjected to periodic testing. We
have just been informed that there will no more formal statement made than
Most of the steel pedal cars we sell are made in China, and the importer has provided an informal statement that they believe the finishes to be lead-free, largely because they have specified the paint formula. They have notified the factory in China that they want a formal analysis, and we will have more information when they provide it.
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Testing of items kept in inventory - interpreting test results
Samples of most of the toys we keep in inventory have been opened and examined critically for defects of design or workmanship, and many have been play-tested, including all the flying toys. We have eliminated from the Turnertoys website any items that failed more than once to meet our very high standards, even if they had previously been satisfactory.
In 2007, we started testing surfaces of our painted toys for
the presence of lead, regardless of the country of origin. We are using LeadCheck® Professional Test Kits,
made by Hybrivet Systems (Natick, MA: 800-262-5323 / http://www.leadcheck.com
). These tests indicate the presence of lead in surfaces with a concentration of
more than 2µ (micrograms) per 1 cm2 surface area.
We score the
painted surface down to the substrate to expose as much of the coating as
possible, so we are not just testing the exposed surface. This is a qualitative
test that does not rule out the presence of lead in lower concentrations. Any
positive result using this test indicates a toy clearly not suitable for
children of any age.
This test, when applied for longer than 30 seconds
and over a larger surface area, will detect lead content as low as 600
parts per million - the legal standard prior to the new
CPSIA 2008 regulations.
Admittedly, it is very difficult to translate results
in content per unit surface area into numbers relevant to known health effects
in children, which are calibrated in micrograms (µ) per deciliter (dl) of
blood. 10µ/dl is considered a very rigorous standard of safety; blood levels
below this are regarded by almost all scientists as not of concern.
However, neither the U.S. Environmental Protection
Agency (EPA) nor the Consumer Products Safety Commission (CPSC) have been
helpful in providing a translation formula from surface concentration to blood
level, and in fact, it may not be so easy. Surface lead (which our tests
detect) indicates only available lead, not ingested lead, which will necessarily
be a much smaller amount, depending on frequency, duration, and manner in which
the child handles the toy. A toy not placed in the mouth is much less of a
hazard than one that is.
Furthermore, a toy in which lead is bound in a
paint film will release it at a rate slower than our testing indicates, since we
scratch the surface in order to release as much as possible. In PVC toys, on the
other hand, lead, if present, and other substances of concern, are emitted
steadily by the plastic. Again, Turnertoys does not sell toys made with
Results of our testing
In 2007, we tested the painted surfaces of all our
Chinese-made toys, and were not able to detect any lead. We also tested
representative sample of our toys made in USA and Germany, and found no lead. We
have available to us the Material Safety Data Sheets (MSDS) for our
American-made toys; they are all decorated with USA-made coatings, of which the
composition is known. The MSDS includes, among other data, the chemical
composition of the product.
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Ongoing Program - a continued scrutiny
Unfortunately, it appears that Chinese factories will get
away with whatever they can if not constantly watched. If Mattell, who has more
influence and economic power than any other toy company on earth, and who
actually owns some of their factories in China, can have problems with lead in
paint, than any of the thousands of smaller importers are subject to the
vagaries and vices of their Chinese suppliers, unless they have a continuing,
active test program.
The only sure remedy would be to pull samples out of
each batch of product that is packed and ready for container loading, and test
them before they are shipped. If a product fails the test, that
entire batch should be rejected and destroyed in China. It would mean
that the importer would be "out of stock" of that item for a while,
which is a normal ocurrence in retail commerce, anyway. Whether or not any
importer is able to adopt such a rigorous standard remains to be seen. Mere
observation of procedures, or questioning of factory managers, is clearly
insufficient. Testing of either the paints used, or the surfaces of finished
products, is needed. Again, this should be done before the products are shipped,
and should be done on randomly selected, packed items, not "test
samples" provided by the factory. Meanwhile, Turnertoys will continue to test our
in-house inventory, and may consider having some of the drop-shipped items sent
to us, so we can test them here. We are hoping to have documentation of our
drop-ship vendors' testing at some point in the near future.
Actions reasonable and unreasonable:
Focusing on the real hazard; interpreting lead test results
Parents and child-care providers should be
concerned about lead and other hazards in toys. However, We
suggest that the available lead test kits are one tool that can be used
effectively in the effort to keep kids safe, if used according to all
manufacturer's directions, and interpreted conservatively. False
positives are unlikely; if the swab turns color, lead is present
in quantities of concern. False negatives are possible, since the test
results using the swab kits do not absolutely rule out the presence of
any lead. However, in general lead will either be present in detectable
quantities, or present only in trace amounts as contaminants, not as
intentionally added pigments or stabilizers. Thus, a negative result can
be interpreted with reasonable reliability. Furthermore, sensitivity of
the swab-type home kits can be increased by swabbing a larger surface
area, thus exposing the swab to more lead if any is present.
Throwing out all Chinese products makes no
sense to me. The toys containing the materials identified here and in our
other articles as hazardous should be discarded, or perhaps tested
and kept in use with supervision. Potentially hazardous materials as
described here should not be present in toys for children who are still
teething, and never for children under the age of 12 months.
The material presented in this article is
intended as a guideline to focus the attention of responsible adults
conerned about the safety of children on the real hazards, so that kids
can continue to enjoy the majority of toys made in China and elsewhere
that are safe and of good quality.
We have had numerous requests for information about the safety of our products, especially in regard to where they are made, and I hope this information has been helpful.