Summary of the Lead Risk Reduction Strategy for Consumer Products

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Consumer Product Safety Bureau
Health Canada

Purpose

Health Canada currently has no authority to control the advertisement, import or sale of unregulated consumer products which may represent a lead exposure risk. The regulatory standards proposed under the Lead Risk Reduction Strategy for Consumer Products will enable Health Canada to more effectively control the risks to children associated with lead in consumer products.

Health Canada has evaluated other risk management options, including maintaining the current regulatory situation, requesting voluntary industry compliance with lead content limits in unregulated products, or a combination of regulatory and voluntary standards, but has concluded that regulatory standards are the fairest and most effective means of controlling this risk

Background

Lead is an inexpensive, soft, heavy metal which has many potential uses, but it is also highly toxic, especially to children. Lead can enter the body through the digestive system or the lungs. It accumulates in the body and can damage almost all body systems, especially the nervous system, the kidneys, and the blood-forming and reproductive systems. Even very low levels of exposure to lead can cause intellectual and behavioural deficits in children. Children's immature body systems are less able to eliminate lead from the body and at a given blood lead level, lead causes more serious effects on a child's body than on an adult's body.

Exposure to Lead

Young children are more likely to be exposed to lead because of their natural habit of mouthing objects. They can also be exposed to lead through crawling in lead-contaminated dust or mouthing surfaces contaminated with leaded dust. Lead has a sweetish taste which encourages children to continue to mouth objects containing it.

The use of leaded household paints, leaded gasoline, and lead solder in food cans, all of which were once major sources for lead exposure for Canadians, have been virtually eliminated in Canada. However, lead has potential uses in a wide variety of consumer products. For products like lead batteries and lead-containing radiation protection clothing and screens, the risk of exposure is low. However, some uses do present a significant risk of exposure to children. In the past ten years, Health Canada has recorded a number of incidents in which lead was found in children's products, such as clothing trim and fasteners, and jewellery, including a case of lead toxicity which occurred when a young child chewed on a pendant which was pure lead.

Health Canada's Lead Risk Reduction Strategy for Consumer Products

Lead content is regulated for only a few consumer products, and some of the lead content limits for these regulated products are considered too high to adequately protect consumers, especially young children.

Currently the following consumer products are regulated for lead content under the Hazardous Products Act and Regulations:

• Consumer paints, enamels and other surface coating materials. The lead content of surface coating materials is limited to 600 mg/kg total lead under the Surface Coating Materials Regulations, which came into effect in 2005.
  
  
• Paints, enamels and other surface coating materials on furniture, household products, children's products, exterior and interior surfaces of any building frequented by children. Under amendments of Schedule I to the Hazardous Products Act, which came into effect in May 2005, the lead content of paints or other surface coating on any of these products or surfaces is limited to 600 mg/kg total lead.
  
  
• Paints, enamels and other decorative coatings on pencils and artists' brushes, and on toys, children's furniture, and other articles intended for children. Under amendments of Schedule I to the Hazardous Products Act, which came into effect in May 2005, the lead content of paints or other surface coating on any of these products is limited to 600 mg/kg total lead.
  
  
• Paints and other surface coatings on toys, equipment, and other products "for use by a child in learning or play" may not contain more than 600 mg/kg total lead.

Each of the above amendments reduced the levels of lead established in the original regulatory requirements set between 1973-1976, and ensured that the 1991 voluntary levels of lead adopted by domestic manufacturers were applied fairly to all products advertised, sold or imported into Canada.

• Kettles The Kettles Regulations limit the amount of lead that may be released when water is boiled in domestic kettles. This Regulation came into force in 1974 and is currently under review to determine whether the limit should be further reduced to reflect current recommended lead levels in water quality guidelines.
  
  
• Glazes, coatings or decorations on ceramics and glassware used for storing, preparing, or serving food or beverages. The releaseable lead content of these products is regulated under the Glazed Ceramics and Glassware Regulations. An amendment to reduce the lead content limits for the lip and rim of drinking vessels (i.e. the portion which touches the mouth when in use) is expected to be finalized within a few months. The original regulatory limits were established in 1971, and previous amendments to lower the limits came into force in 1998.
  
  
• Children's jewellery. The Children's Jewellery Regulations came into force June 1, 2005 and permits the import, advertisement or sale of jewellery items intended primarily for children under 15 years of age only if the items do not contain more than 600 mg/kg total lead and 90 mg/kg migratable lead.
  
  
• Part II, Schedule I of the Hazardous Products Act contains a general prohibition on toys, equipment, and other products for use by a child in learning or play that contain a toxic substance. Lead is classified as a toxic substance for the purposes of this prohibition.

Proposed Lead Content Regulations under the Lead Risk Reduction Strategy for Consumer Products

General Considerations
The Strategy proposes lead content limits for four categories of consumer products with which children are likely to interact. The limits for each product group reflect the relative level of risk, which is determined by the probability that child/product interactions would occur which result in exposure to lead, and the likely level of exposure. For some product categories, there is a migratable or leachable lead limit, as well as a total lead limit. Migratable lead is the proportion of total lead that is released from the product when it is subject to the action of the digestive system. The proposed limits are in harmony with international standards.

The 2002 version of the Lead Risk Reduction Strategy for Consumer Products contained five categories of consumer products. Following stakeholder consultation, the number of categories was reduced to four by amalgamating Groups 1 and 2 to form a new Group 1 category.

Two groups of products which may contain lead and to which children may potentially be exposed are not covered by the current Strategy:

• Household Furnishings and Fittings, such as furniture, vent coverings, wallpaper, and holiday trim;
  
  
• Products Intended to be used in Public Spaces, such as nails, screws and other fasteners, exercise weights and leaded greases and caulking compounds.

Both groups contain a very broad range of products and regulatory lead content limits would affect a large number of industry stakeholders. Since the risk for children of lead exposure through interaction with these products is not as great, Health Canada has decided to address these product groups in a separate strategy paper.

The lead exposure risks associated with a third product group:

 Products used for Hunting and Fishing, such as lead shot and leaded fishing weights

are mainly to the environment rather than to human health. Jurisdiction over the use of these products is shared by a number of federal and provincial/territorial agencies. Environment Canada is working with the sportfishing industry to determine the optimum method to manage the risk to wildlife posed by lead-containing fishing sinkers and jigs.

"Zero-lead" content limits for consumer products are not realistic because trace amounts of lead are found everywhere in the natural and human environments.

Proposed Lead Content Regulations

The current product categories and proposed regulatory standards are:

Group 1: Products Whose Reasonably Foreseeable Pattern of Use Involves the Product being Brought into Contact with the User's Mouth

Examples:

• toys labelled by the manufacturer as being suitable for children less than three years of age, or which by their nature are likely to be used by a child less than three years of age
• mouthpieces used in sports equipment, such as snorkels and breath deflectors
• mouthpieces of musical instruments
• pacifiers, teethers, rattles, baby bottle nipples, baby bibs, and crib toys
• plastic beverage straws
• children's crayons, modelling clays, and paints

Lead Limit: for each individual component of Group 1 products which is likely to be placed in or near the mouth, total lead must not exceed 90 mg/kg. Migratable lead therefore cannot exceed 90 mg/kg.

Exemptions:

• Food, beverages, medicines or other products intended for human consumption. Lead content of these products is regulated under the Food and Drugs Act.
• Eating utensils and other foodware items, which will be covered under separate foodware legislation.

Group 2: Children's Equipment, Furniture, Toys and other Items intended for use by a child in Learning or Play

Examples

• baby carriers, strollers, playpens, high chairs and cribs
• children's clothing, footwear, and accessories
• interior and exterior play equipment

Lead Limit: for each accessible component of Group 2 products, total lead must not exceed 600 mg/kg. Migratable lead content must not exceed 90 mg/kg.

Exemptions:

• Products covered under Group 1
• Components of products that are required to store, generate, or conduct an electrical current, such as batteries, electrical solder and flux, and cables, provided that these components are not accessible to children. This exemption does not apply to toys, hobby kits, and similar products which are intended for children older than 36 months and which require assembly.

Group 3: Foodware Products (Products intended for use in preparing, serving, or storing food or beverages)

Examples

• cooking utensils such as beaters, spatulas, pots and pans
• serving and eating utensils such as spoons, forks and knives
• tableware such as plates, bowls, drinking glasses and mugs
• food storage materials and containers such as plastic and foil wrap, sandwich bags, and juice jugs

Lead Limit: for each individual component of Group 3 products, total lead must not exceed 600 ppm, and migratable lead must not exceed 90 ppm.

Exemptions:

• Products covered under Group 1
• Pre-packaged food items, which are regulated under the Food and Drugs Act

Group 4: Consumer Products intended to be or likely to be Melted or Burned in Enclosed Spaces

Examples:

• incense
• fuel for indoor lanterns
• metal moulding kits for craft making
• chemical fire logs

Lead Limit: Total lead in each component of Group 4 products which is intended to be or likely to be burned or melted, must not exceed 600 ppm. (Group 4 products represent a double hazard, in that the lead fumes they produce, if not inhaled, settle out on household surfaces as lead-contaminated dust.)

Exemptions:

1. Untreated firewood to which lead has not been intentionally added
2. Products covered under the Explosives Act

Other initiatives under the Hazardous Products Act - Vinyl Mini-blinds

In addition to the above regulatory initiatives, the proposed Corded Window Coverings Regulations currently being drafted under the Hazardous Products Act limit the lead content of any exterior component of blinds or other corded window coverings which can be touched or ingested by young children to a maximum of 200 mg total lead per 1.0 kg weight of window covering (0.02% by weight).

The above regulatory proposal will enable Health Canada to more effectively control the risks to children associated with lead in consumer products. Health Canada has evaluated other risk management options, including maintaining the current regulatory situation, requesting voluntary industry compliance with lead content limits in unregulated products, or a combination of regulatory and voluntary standards, but has concluded that regulatory standards are the fairest and most effective means of controlling this risk.

Implementation of the Lead Risk Reduction Strategy

Group 1 Products
The results of an economic cost analysis determined that the vast majority of Group 1 products on the Canadian marketplace are already in compliance with the proposed lead content limit of 90 mg/kg. It is anticipated that Group 1 Regulations will be pre-published in Canada Gazette Part I in the spring of 2007. Stakeholders will be advised of the prepublication date as soon as possible. A 75-day comment period will follow prepublication.

Group 2 Products
An economic cost analysis has been completed for Group 2 products. An economic benefits analysis will be completed by March 31, 2007. The future direction of the Group 2 Regulations will be determined once the results of the benefits analysis are available.

Group 3 Products
It has been decided to include lead content limits for foodware in a general foodware regulation, which will facilitate the regulation of foodware hazards other than lead. It is anticipated that a draft foodware regulation will be circulated for stakeholder comment during the first half of 2007.

Group 4 Products
Canadian retailers voluntarily discontinued the sale of candles which contained lead in the cores of their wicks several years ago. Health Canada has drafted the Candles Regulations which permit the import, advertisement or sale of candles only if they do not contain more than 600 mg/kg total lead in the cores of their wicks or any other part of the candle. (The draft Regulations also include requirements for safe use labelling of candles.)