| PVC HOMEPAGE
|"This is of interest to us. We'll
certainly look into it."
California Deputy Attorney General Susan Fiering
Specialist in Proposition 65 cases
Quoted in the San Francisco Examiner, story written by Jane Kay
October 9, 1997, Page 1
"As a parent, I
would try to reduce exposure to my children from these products."
"We don't manufacture these products but they do
have our images on them, so we do feel responsible."
"It clearly calls for attention. It's an important
"... it is highly imprudent to dismiss these
children's products as significant sources of lead and cadmium exposure ..."
"I think the (Consumer Product Safety Commission)
should wake up and pay more attention to this."
"I am concerned that CPSC's hurried
response and the testing of only 11 products is inadequate to judge the potential
hazard from these vinyl products ... If the [Greenpeace] results are independently
substantiated, a recall of these vinyl products as well as older vinyl miniblinds may be
"I view the Greenpeace findings as a warning
clearly calling for further study and confirmation by other investigators ... If the CPSC [Consumer Product Safety Commission] actions were simply an effort
to discredit the Greenpeace report I am diappointed."
"[The CPSC is] ... a public health agency, not a
public reassurance agency. I'm afraid that this was not CPSC's shining hour."
"No heavy metal stabilizers, including lead, are
used in toys. None."
"The voluntary standard established in the United States under ASTM F-963 and the European standard under EN-71 for soluble lead in toys (lead which may migrate from the toy and be ingested by the child) is 90 parts-per-million. At that level, any intentional use of lead in paints or other surface coatings containing lead would immediately put the toy over the permitted limit.
"Under federal law, The US Consumer Product Safety Commission (CPSC) enforces a standard for total lead of 600 ppm. Recently, the CPSC refused to lower the lead limit in paint and other similar surface coating materials to 100 ppm after finding that most paints sold in the United States were already at or below that level and therefore these materials did not present an unreasonable risk of injury warranting further government regulation.
"The Global Toy Safety Standard now being drafted by the International Standardization Organization (ISO-TCI 181) adopts the standards in force in the United States and in Europe.
"Finally, the US Customs Service and the Consumer Product Safety Commission initiated an inspection project dubbed Operation Toyland.; Trained Customs and CSPC specialists carry out inspections to make sure that all toys brought into the United States conform to CPSC regulations with special focus on lead in paints.
"No one disputes the toxic effects of lead. It is poison. It is unthinkable that
toy manufacturers, the very people whose mission in life is to provide safe playthings for
children, would not be in the forefront of efforts to see that those children come to no
harm. Rest assured. They are."
CPSC Releases Lead and Cadmium Test Results on Vinyl Products
"Washington, D.C. - Greenpeace released a study today alleging that hazardous levels of lead and cadmium are present in many popular vinyl children's products. Testing by the U.S. Consumer Product Safety Commission (CPSC) does not support this conclusion.
"CPSC takes action when it learns that products contain hazardous levels of lead. However, CPSC testing found that seven of the 11 vinyl products in which Greenpeace found high levels of lead had no or only trace levels of lead. CPSC conducted further analysis on the four other vinyl products and found two are not hazardous because exposure is not likely, and testing on two is incomplete. Children's health is at risk when they are exposed to hazardous levels of lead. This exposure occurs through ingestion or inhalation.
"Of the 11 products, CPSC found eight had no or only trace levels of cadmium and one was not hazardous because exposure is not likely. Testing on two of the products is incomplete.
"Using CPSC's experience with vinyl miniblinds, Greenpeace asserts that toxic dust will inevitably be released when vinyl products deteriorate. CPSC staff found that vinyl miniblinds do deteriorate when continuously exposed to sunlight and heat. However, CPSC experts do not believe that the vinyl products tested by Greenpeace will deteriorate because they are not exposed to the same extent of sunlight and heats the vinyl miniblinds.
"CPSC has most recently identified and taken actions to reduce or eliminate the risk of lead poisoning from a number of children's products and consumer products in which lead was accessible to children. These included imported crayons, imported non-glossy miniblinds, playground equipment and children's jewelry.
"CPSC is continuing to evaluate the information provided by Greenpeace and will
take action as appropriate."
ENVIRONMENTAL QUALITY INSTITUTE
Review of U.S. Consumer Product Safety Commission October 9, 1997, News Release
by Dr. Richard P. Maas and Dr. Steven C. Patch
University of North Carolina at Asheville, Environmental Quality Institute
As experienced and nationally-recognized researchers
on lead exposure potential from various consumer products, and having recently completed
testing for lead and cadmium exposure potential in various children's vinyl products, we
offer the following observations and comments related to today's news release by the CPSC.
a: The children's backpacks, raingear, tent poles, and beach gear we tested were
intended for outdoor use without the benefit of a glass barrier which absorbs most UV
light as in the case of miniblind exposure. b. We found relatively large amounts of lead released, in some of the products tested,
after simulated ultraviolet light exposure. c. In at least one of the products tested, levels of lead and/or cadmium were available
on the product surface even before we began the simulated sunlight exposure tests. Given the previous experience with vinyl miniblinds, where lead was not released until
after sunlight exposure, but then released in very large amounts, it would appear highly
imprudent to dismiss these children's products as significant sources of lead and cadmium
exposure without at first at least conducting sunlight exposure tests similar to the
miniblind tests, particularly in the face of independent laboratory sunlight tests by the
EQI indicating a significant exposure problem. In summary, it appears that the CPSC has gone to extraordinary lengths to draw negative
conclusions from a very small study that itself appears to indicate the presence of
significant lead and cadmium exposure potential.
a: The children's backpacks, raingear, tent poles, and beach gear we tested were intended for outdoor use without the benefit of a glass barrier which absorbs most UV light as in the case of miniblind exposure.
b. We found relatively large amounts of lead released, in some of the products tested, after simulated ultraviolet light exposure.
c. In at least one of the products tested, levels of lead and/or cadmium were available on the product surface even before we began the simulated sunlight exposure tests.
Given the previous experience with vinyl miniblinds, where lead was not released until after sunlight exposure, but then released in very large amounts, it would appear highly imprudent to dismiss these children's products as significant sources of lead and cadmium exposure without at first at least conducting sunlight exposure tests similar to the miniblind tests, particularly in the face of independent laboratory sunlight tests by the EQI indicating a significant exposure problem.
In summary, it appears that the CPSC has gone to extraordinary lengths to draw negative conclusions from a very small study that itself appears to indicate the presence of significant lead and cadmium exposure potential.
Greenpeace Rebuttal to U.S. Consumer Product Safety Commission Test ResultsWashington, D.C. -- The Consumer Product Safety Commission (CPSC) hurriedly issued a press release (#98-008) describing a few test results of vinyl products for lead and cadmium. The CPSC action was timed to occur the night before the release of a seven month Greenpeace investigation that reveals hazardous levels of both metals in vinyl children's products throughout the U.S.
The CPSC incompletely described the results of 11 tests. Neither the products nor the actual quantities of lead or cadmium were revealed by the agency.
The Greenpeace report, "Lead and Cadmium in Vinyl Children's Products", fully discloses the results of 131 product tests followed by testing in 10 major U.S. cities along with experiments that demonstrate that both metals are available for ingestion by children. All testing was conducted by independent laboratories according to established government protocols used by the CPSC.
The CPSC also concluded, without data, that vinyl products tested by Greenpeace will not deteriorate since they are exposed to less sunlight than vinyl miniblinds. In contrast, Greenpeace actually performed the scientific experiment. The University of North Carolina tested the deterioration of vinyl products using CPSC protocols and found that dangerous levels of both lead and cadmium were released by the products.
The Greenpeace investigation carefully, and comprehensively tested products throughout the U.S. and subjected the results to peer review by a distinguished panel of physicians and scientists. The CPSC press release attempts to allay Greenpeace and public concerns regarding children's vinyl products by stating conclusions without providing data for only 11 tests.
The CPSC appears to offer false reassurance to parents that vinyl products containing lead and cadmium are not widespread. This conclusion is not supported by their findings and is inconsistent with their mandate to protect the nation's children.
Greenpeace Letter of protest to U.S. Consumer Product Safety Commission Chair Ann BrownOctober 14, 1997
We believe it is essential that the Consumer Product Safety Commission (CPSC) issue a statement of clarification regarding vinyl children's products and warn the public that reputable scientists and experts in the field of childhood lead exposure believe that heavy metal exposure from these products presents an avoidable risk that ought to be of concern to parents.
On Wednesday, October 8, 1997, the Consumer Product Safety Commission (CPSC) issued press release #98-008. The press release stated that testing of 11 vinyl products by the CPSC "does not support" the findings of the Greenpeace report, "Lead and Cadmium in Vinyl Consumer Products." CPSC staff repeatedly emphasized this point in press interviews.
The circumstances surrounding the release of the CPSC statement are troubling. Greenpeace had provided senior CPSC staff with an embargoed copy of the Greenpeace report in advance to enable appropriate comment. However, CPSC staff chose instead to release testing information without the actual data from an incomplete investigation that was hurriedly initiated upon receipt of a leaked copy of the Greenpeace report. The press statement was characterized in a way which tended to dismiss the Greenpeace findings, rather than acknowledge their significance.
We have now learned that the CPSC incorrectly measured lead and cadmium levels in vinyl plastic and then distorted the reporting of its own data. It is thus unconscionable that you let the Commission's initial response stand.
The CPSC measured lead in vinyl with a procedure that was designed to measure lead in paint. The independent labs commissioned by Greenpeace used a procedure designed for determining lead in vinyl. The Environmental Quality Institute (EQI) and Stat Analysis have documented that paint procedures underestimate the lead content of vinyl due to the physical differences between paint and vinyl. The CPSC probably underestimated lead and cadmium levels in several vinyl samples because it used the wrong measurement procedure.
The CPSC press release referred to data without giving any numbers. Greenpeace has learned why. The CPSC data shows four vinyl products that exceed the agency's own legal recall level for lead of 600 ppm. No reference was made to these products in the CPSC press release even though the agency measured lead levels from 810 ppm to 6,300 ppm. The products include a Gemini modular phone cord cable, a Barbie Slumber Tent Pole, a Looney Tunes Hackey Sack, and a Looney Tunes umbrella. In addition, the CPSC failed to report that their results for these hazardous products closely matched those reported by Greenpeace. The Commission ignored their own data which indicated that hazardous levels of lead are present in vinyl products.
The CPSC data also showed that cadmium was undetected in the few products that the agency tested. Unfortunately, a relatively high no-detect threshold of 50 ppm cadmium was used by the agency. If this is taken into account, the CPSC and Greenpeace data appear to match quite closely.
Finally, the CPSC press release dismissed the hazard posed by release of lead and cadmium from vinyl children's products during degradation in the light. The CPSC asserted that vinyl children's products would get less sunlight than vinyl miniblinds. In contrast to asserting an opinion, Greenpeace commissioned the EQI to conduct a thorough scientific study of products intended for outdoor use. The EQI used the CPSC's own protocol to demonstrate that hazardous amounts of lead and cadmium were released during deterioration of vinyl children's products.
For example, a Barbie backpack purchased at Kmart in nine cities contained 236 ppm - 627 ppm lead and released more than 35 µg of lead and 23 µg of cadmium to its surface during deterioration in the light. These levels are two times higher than the CPSC's own lead exposure standard of 15 µg/day. In California where the backpack was purchased, the lead and cadmium amounts released by the backpack are 70 and 460 times higher than the maximum permissible exposure levels under Proposition 65. This product, along with many others, remains on the shelves of retail stores today. This is simply unconscionable.
The Greenpeace report differs significantly from the CPSC press release. The Greenpeace report discloses the results of a seven month investigation that included 131 product tests followed by testing in 10 major U.S. cities along with experiments conducted by two independent laboratories. The data demonstrates that lead and cadmium are available for ingestion by children. The results were submitted to peer review by a distinguished panel of scientists and physicians. The Greenpeace findings on lead and cadmium further support proposals for moving away from using vinyl in children's products.
In contrast, the CPSC performed a few tests and found four vinyl products that exceeded the agency's own recall level for lead in consumer products. Despite its mandate to protect public health, the CPSC chose not to report this data and the fact that it had partially confirmed Greenpeace findings. Instead, the CPSC issued a press release designed to invalidate the Greenpeace report.
We deem it inappropriate that the CPSC chose to publicly cast doubt on the validity of our work. Either the CPSC should have simply released its data and allowed that it confirmed some of the Greenpeace findings, or the agency should have stated that an investigation was ongoing and no scientific conclusions could be drawn.
It was disingenuous and dangerous to publicly cast doubt on the validity of the Greenpeace investigation. For example, Greenpeace revealed the widespread sale of a piece of vinyl Kentucky Fried Chicken designed to be placed in children's mouths which contained both lead and cadmium. Experiments conducted by Stat Analysis revealed dangerous levels of lead would be released by the chicken if only one-thousandth of an ounce was swallowed.
We have been invited to meet with your technical staff to discuss the differences in data and chemical analysis. We are eager to do so. However, we remain disappointed and concerned that the Commission's public pronouncements on the matter carelessly offered false reassurances to the public at a time when concern should be elevated.
We await your earliest response as to whether the Commission will revise its public statement to accurately convey the essence of its own investigation.
Joseph Di Gangi, PhD
This letter to Vice President Al Gore concerning phthalate additives in PVC was
signed by over 20 scientists.
July 1, 1998
The Vice President
The White House
Washington, DC 20501
Dear Mr. Vice President:
We are deeply concerned by recent reports that the Commerce
Department, at the behest of U.S. toy manufacturers, has instructed
U.S. diplomats to block efforts in Europe to control the use of a
class of chemicals called "phthalates" in children's toys, chemicals
that have been linked to a range of potentially serious health
effects. These actions run contrary to Administration policy to
"ensure that policies, programs, activities, and standards address
disproportionate risks to children that result from environmental
health risks or safety risks" (Executive Order, April 21, 1997).
Commerce officials have explained their actions by pointing to the
absence of a scientific consensus on the health risks associated with
phthalates. Even as the Consumer Product Safety Commission has
identified carcinogenic, developmental, and other physiological
effects such as liver and kidney damage associated with various
phthalates, no one disputes the need for more scientific information
on this and a range of other toxic-related health issues. But as
scientists and physicians we know all too well how science is
manipulated by lobbyists and policymakers to delay action. We do not
believe that precautionary protections for children should wait years
until science renders a final judgment, especially where potential
effects are serious and irreversible.
Recognizing that protecting children from certain risks should not
wait for scientific certainty, your Administration signed the Food
Quality Protection Act (FQPA) mandating specific protection factors
for children when full health information about a chemical is lacking.
And your Administration issued an executive order designed to protect
children from health risks not just clear and present dangers.
Several European countries, after considering conclusive studies of
health effects of phthalates in animals and proof of leaching from
various products, have mandated controls of phthalates in children's
products. These nations are merely recognizing the principle already
embodied in the FQPA and your Administration's executive order that
children deserve greater protection because their developing systems
are more vulnerable to environmental insults and because any
developmental impacts they might experience are irreversible. We hope
the U.S. Government will respect the decisions of its trading partners
when it comes to precautionary measures concerning matters of public
safety, especially child safety.
Here in the U.S., polls suggest that vast majorities of the American
people believe that products and technologies should be proven safe
before being placed in commerce. As you know, many of our regulations
controlling toxic harms reverse this burden, requiring the public to
prove that a product is harmful. With the FQPA and the children's
health executive order, your Administration has taken the very first
steps toward bringing our regulatory system more in line with the
We hope your Administration will more vigorously implement the FQPA
and the children's health executive order and take steps to ensure
that all agencies follow the spirit and letter of these critically
important policies. A good place to start would be to direct the
Department of Commerce to end its campaign to protect U.S. toy
companies at the expense of increasing a health risk to children.
Nicholas Ashford, Ph.D.
Professor of Technology and Policy
Massachusetts Institute of Technology
Devra Lee Davis, Ph.D.
Strang Cancer Prevention Center
Cornell Medical School
Peter deFur, Ph.D.
Virginia Commonwealth University
Cathey Falvo, MD, MPH
New York Medical Center
Erica Frank, MD
Emory University School of Medicine
Howard Frumkin, MD, DrPH
Rollins School of Public Health
Kenneth Geiser, Ph.D.
Director, Toxics Use Reduction Institute
University of Massachusetts, Lowell
Molly Tan Hayden, MD
Guy Lanza, Ph.D.
Professor and Director, Environmental Sciences Program
University of Massachusetts, Amherst
Michael McCally, MD, Ph.D.
Mt. Sinai School of Medicine
Peter Montague, Ph.D.
Environmental Research Foundation
Robert K. Musil, Ph.D.
Physicians for Social Responsibility
John Peterson Myers, Ph.D.
W. Alton Jones Foundation
Peter Orris, MD, MPH
Cook County Hospital
David Ozonoff, Ph.D.
Professor and Chair, Dept. of Environmental Health
Boston University School of Public Health
Ted Schettler, MD, MPH
Boston Physicians for Social Responsibility
Ellen Silbergeld, Ph.D.
Director, Program in Human Health and the Environment
University of Maryland
Allen Silverstone, Ph.D.
State University of NY Health Science Center at Syracuse
Gina M. Solomon, MD, MPH
Natural Resources Defense Council
Abbey Strauss, MD
Tim K. Takaro, MD, MPH
University of Washington, School of Medicine
David B. Wallinga, MD
Natural Resources Defense Council
Nancy and James Chuda
Children's Health Environmental Coalition/Founders
National Spokesperson for the Children's Health Environmental
Austria to ban soft PVC baby toys
ENDS Daily - 10/07/98
Austria is to ban PVC toys likely to be placed in the
mouths of small children, it has emerged. According
to government officials a decree will be issued later
this month, following the end of a consultation period
this week. The measure will come into force before
the end of the year. Imports, retailing and advertised
of affected products will be prohibited.
Austria's move follows a recommendation issued by the
European Commission less than two weeks ago, calling
on EU member states to take regulatory action on
children's PVC toys containing phthalates if they
could demonstrate a health risk (ENDS Daily 1 July).
It is the first EU country to put in place a ban.
The development removes an uncertainty generated by
the Commission decision, which left environmental
groups claiming it would open the way to widespread
national bans while the PVC and toy industries hoped
it would forestall them.
Harmonised EU rules to address potential health risks
from phthalates are to be drawn up, probably this
autumn, when a Dutch-coordinated study of phthalate
migration from toys into human saliva is to be
completed. Until then, commissioners decided this
month, there was not a firm enough scientific basis on
which to decide EU emergency action.
Greenpeace, which is campaigning both on the
phthalates issue and against PVC use more broadly, has
welcomed Austria's move. "This should send a signal
to other member states to act on the Commission's
recommendation," the group said. However, it went on,
the ban "still leaves the gates open for PVC producers
to replace phthalates with other hazardous additives.
PVC is a poisonous plastic - replacing phthalates
won't solve that problem."
Austria's ban conforms with a key requirement laid
down by the Commission that any restriction should be
supported by a scientific assessment of phthalate
migration levels. Austrian scientists have shown that
there is a risk, according to the consumer affairs
However, the ban will cover not only toys designed to
be placed in the mouths of children under three years,
but also toys "feasible to be" chewed or sucked,
according to the ministry. In this respect it will be
broader than the Commission's recommendation, which
concerned only toys "intended" to be placed in babies'
mouths, such as teething rings.
Two other EU countries - Denmark and Sweden - are also
on the way to similar bans. Sweden says it will ban
chemical softeners in toys for the under-threes if
industry does not phase them out on a voluntary basis.
An official in the Danish government said that
environment minister Svend Auken would take a decision
next month on exactly which category of
phthalate-containing toys - whether those specifically
designed to be chewed or a wider range - should be
Contacts: Austrian consumer affairs ministry
(http://www.bmg.gv.at/bmg), tel: +43 1 53115.
Nike phases out PVC
The shoe and sports equipment manufacturers are phasing out PVC. In a
statement sent to Greenpeace Business on 10th July they state:
"Extensive scientific studies of polyvinyl chloride (PVC) have linked
both the manufacture and improper disposal to the use and by-product
generation of substances that are known to be, or suspected of being,
harmful to living systems. In keeping with Nike's corporate goal of
adopting sustainable business practices, Nike will not continue to
support the production and use of PVC and has made the following
As of August 1st, 1998 for the footwear and December 1, 1998 for all
other divisions: * No new PVC-containing materials, packaging or
processes will be allowed in any Nike category or division. * Nike
will adopt measures to phase out the existing use of PVC in all
products across all categories and divisions. * The use of approved
alternatives to PVC will be mandated across all categories and
divisions, and preferences will be given to those suppliers who
develop PVC alternatives that meet all of Nike's requirements.
Designed in conjunction with William McDonough & Partners, Nike's new
European headquarters in Hilversum, the Netherlands implements many
ecologically intelligent (TM) design features. For example Nike has
implemented a "no PVC" regime. All suppliers and subcontractors have
been asked to ensure that they do not provide Nike with or use PVC
materials or products in connection with the construction and fitting
of the site. All piping for the electricity, sewage, grey water and
heat systems is PVC free. All data cabling and the majority of
electric cabling are PVC free."
NIKE MAKES IT OFFICIAL:
August 26, 1998
Nike to Stop Using PVC in Shoes
By David S. Hilzenrath
Washington Post Staff Writer
Wednesday, August 26, 1998; Page C12
Nike, the world's largest manufacturer of athletic shoes, said it will
purge its products of the widely used plastic substance polyvinyl
chloride, which it called "a threat to humans and the environment."
Nike's plan, publicized yesterday by the environmental group
Greenpeace, was a symbolic milestone in an international campaign to
reduce the use of PVC in products as varied as toys and medical
For now, Nike's gesture is more symbolic than substantive, though.
Nike said it has "barely just begun" to look for materials to
substitute for PVC and will make the change "as supplier capacity and
viable replacements allow." The company would not predict when
products would start rolling off its assembly lines free of PVC.
The manufacture and disposal of PVC can release toxins known as
dioxins, which are linked to birth defects, cancer, decreased
fertility and other medical problems, Nike said.
"We are a sports company, and we must help protect the environment
that athletes need to participate in their sports," Nike said in a
statement prepared for use by Greenpeace.
In the statement, Nike made a point of denying that it was trying to
divert attention from criticism of its labor practices in low-wage
countries. But, in an interview, a company spokeswoman said the
elimination of PVC was a workplace-safety issue for factory employees.
The Vinyl Institute, which represents PVC producers, said the impact
of Nike's action on the industry might be insignificant. But Mark
Sofman, manager of industry affairs, took exception to Nike's
"Vinyl's been in common use for nearly 70 years. It's used safely
every day in thousands of products from food packaging to . . . PVC
pipe for potable water systems," as well as the bags used to store
blood, Sofman said.
Nike spokeswoman Dawn Leonetti said the company doesn't know how much
PVC it uses. The material is used in various parts of shoes, in the
logos that appear on Nike garments, and as a laminate in duffel bags,
among other things.
Greenpeace official Charlie Cray said lead and other hazardous
additives often used with PVC can leach out, posing another threat to
Other companies such as the furniture retailer Ikea and the toy
manufacturer Lego have taken steps to reduce PVC use, Greenpeace said.
The U.S. Consumer Product Safety Commission has tested toys singled
out by Greenpeace and found that they did not pose a hazard to
children, said Ron Medford, assistant executive director for hazard
identification and reduction. But the agency asked manufacturers to
remove lead from PVC mini-blinds after finding that the plastic was
breaking down under exposure to sunlight, releasing dust that children
c Copyright 1998 The Washington Post Company
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