Lead Risk Reduction Strategy

6.2.3   Group 3:   Children's Equipment, furniture, toys, and other items intended for used by a child in learning or play (Excludes Products in Groups 1 or 2)

Examples of Group 3 Products:

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

Lead Limits:
For each and every individual component of Group 3 products, total lead must not exceed 600 mg/kg and migratable lead must not exceed 90 mg/kg.

Intent:
The intent is to protect children from exposure to lead through mouthing of products which are intended for their use or for the use of those caring for them, and with which the child would reasonably be expected to be in frequent, often daily, contact. While mouthing and/or swallowing of inedible items ceases in the majority of children at or around 18 months, these behaviours, known as pica, persist beyond that age in 10% to 30% of children (62). The proposed lead limits would provide some protection against lead exposure for children exhibiting pica. The regulation would also protect young children from the effects of mouthing leadcontaminated dusts or other residues produced by children's products containing lead.

Rationale:
Group 3 products have a total lead limit which is higher than for Group 1 and Group 2 products. This reflects the fact that Group 3 products are not intended to be placed in the mouth nor intended for play by children under 36 months. As children grow older, the tendency to mouth objects is reduced. For the reasons set out for the Group 2 products, the maximum migratable lead concentration for Group 3 products is set at 90 mg/kg. The maximum total lead concentration for Group 3 products is 600 mg/kg. This standard offers manufacturers of Group 3 products a broader choice of materials, while ensuring the product is safe for children who may mouth it.

The 600 mg/kg maximum total lead standard is the same as that proposed for paints and other liquid coating materials used for furniture, household products, children's products, and exterior and interior surfaces of any building frequented by children, under the recent amendment to the Hazardous Products Act Liquid Coating Materials Regulations. It is also the same standard prescribed by the U.S. Consumer Product Safety Commission Regulation 16 CFR Part 1303, for paint and other liquid coatings for residential use, toys and furniture (97). This limit was determined by a risk assessment which calculated that 600 mg/kg of lead in paint was the threshold level, at or below which there would be no significant lead exposure if a child consumed a one square inch paint chip each day.

If a lead test demonstrates that the total lead content of a Group 3 product does not exceed 90 mg/kg, then it will not be necessary to perform a migratable lead test as, by definition, migratable lead in the product cannot exceed 90 mg/kg.

The following exclusions apply to Group 3 products:

• components of products that are required to store, generate or conduct an electrical current or to electrically insulate or shield an electrical conductor, provided that these components are not accessible to children. Such components include batteries, electrical solder and flux, wire and cable products including their insulation, and jacketing materials. This exception does not apply to toys, hobby kits and other products of a similar type which are intended for children 36 months or older and which require assembly. Examples of such toys are "build your own electrical or electronic device kits" and items requiring the use of solder.
  
  
• Solder and flux used to fuse or connect components of jewellery, crafts or artists' products. Though these products are of concern to Health Canada, no other viable substitutes are available at this time. A labelling requirement for solder, advising consumers of the lead content, is being considered.
  
  
• Artistic paints and pigments will be exempt from the requirement for total lead not to exceed 600 mg/kg, but they will be subject to a total migratable lead limit of 90 mg/kg because there is a reasonable probability that children will mouth these items. A labelling requirement for these paints, advising consumers of the lead content, is being considered. (Paints and pigments intended primarily for use by children are included under Group 1 or Group 2, depending upon whether or not they are marketed for use by children under 36 months.)

6.2.4   Group 4:   Products that are intended for use in preparing, serving, eating, containing or storing food and beverages (Excludes Products in Groups 1, 2 or 3)

Examples of Group 4 Products:

• cutlery
• cooking utensils such as beaters, spatulas, cutting boards, pots, pans, and cooking trays
• serving utensils such as serving spoons and carving knives
• tableware such as plates, bowls, drinking glasses, and mugs
• food storage materials and containers such as plastic and foil wrap, sandwich bags, plastic containers, and juice jugs
• lead crystal decanters and other crystalware

Lead Limit:
Total lead in Group 4 products must not exceed 600 mg lead/kg. For glazes on hollowware, migratable lead must not exceed the levels specified for glazed hollowware under the Glazed Ceramics and Glassware Regulations of the Hazardous Products Act. Under these Regulations, hollowware is defined as a product having an internal depth greater than 25 mm, measured vertically from the lowest interior point to a horizontal plane passing through the point of overflow. For other types of foodware, migratable lead content must not exceed 90 ppm.

The concentration of migratable lead will be evaluated by Health Canada's test method: "Determination of Leachable Lead and Cadmium from Glazed Ceramics and Glassware" (46).

Intent:
The intent is to protect the Canadian public, especially children, from lead exposure associated with use of foodware products, by preventing migration of lead from such products into foods or beverages. A maximum lead concentration of 600 mg/kg for all components of Group 4 products is proposed to allow for potential increases in lead leachability over time due to erosion of the protective coating or alteration of the physical or chemical composition of the product with use. This limit ensures that migratable lead will never exceed 600 mg/kg with wear and time.

Rationale:
Products of this category are used regularly, often daily, by adults and by children. Under normal use, cooking and eating utensils may be subjected to intense heat, abrasion or other mechanical stress, chemical reactions from contact with such products as oils or acidic foods and beverages, or a combination of these effects. Examples of lead exposure from glazed ceramic products are quite numerous. However, lead poisoning can occur from the use of unglazed products as well. Clay used in the manufacture of plates have been found to contain as much as 16,504 mg/kg of lead (17). Hollowware is of particular concern because it is used to store foods and beverages, often for considerable periods of time. Alcoholic beverages such as wine and brandy, may be stored for very long periods of time, providing an opportunity for significant leaching of lead. Exposure from the leaching of lead from crystal decanters and glasses is still a concern, especially for antique crystal containing a high proportion of lead (38).

Adoption of the leachable lead limits specified in the Glazed Ceramics and Glassware Regulations ensures that the same standard is in force for all manufacturers and distributers of food contact products (53). Therefore, these regulations would not present an undue constraint to most of the lead crystal industry and would allow regulation of presently unregulated food contact products. Migratable limits for lead crystal products are stipulated by the ISO Standard 7086, "Glassware and Glass Ceramic Ware in Contact with Food - Release of lead and cadmium - Part 2: Permissible limits" (54) These limits are 1.5 mg/litre for small hollowware, 0.75 mg/litre for large hollowware, and 0.5 mg/litre for storage hollowware (defined as hollowware having a capacity of 3.0 litres or more). Member of the International Crystal Federation, which includes a large number of major lead crystal manufacturers, have reduced migratable lead from their products to levels below the ISO Standard 7086 permissible limits.

Products that are already covered under other legislation are exempt from Group 4 requirements:

These include:

• products which are used for storing, preparing or serving food and which are "completely or partially covered with a coating, glaze or decoration that contains lead or cadmium." These products are covered under the Glazed Ceramics and Glassware Regulations of the Hazardous Products Act. Under these Regulations, maximum levels of leachable lead are 0.50 milligrams per litre for flatware, cups and mugs, and small hollow-ware, and 0.25 milligrams per litre for pitchers and large hollow-ware. (Small hollowware is defined as hollowware with a capacity of less than 1.1 litres, and large hollowware is defined as hollowware with a capacity of 1.1 litres or greater.)
• kettles, which are regulated under the Hazardous Products (Kettles) Regulations
• pre-packaged food items, which are regulated under the Food and Drugs Act

6.2.5   Group 5:   Consumer Products Intended to be Melted or Burned in Enclosed Spaces

Examples of Group 5 Products:

• candles, including birthday, emergency, dinner, ceremonial and aromatherapy candles
• fuel for indoor lanterns
• incense
• metal moulding kits for craft making
• candles sold in glazed pottery containing lead flux and lead frits
• chemical fire logs

Lead Limits:
Total lead, in each component of Group 5 products which is intended to be burned or melted, must not exceed 600 mg/kg.

Intent:
To minimize the exposure to lead vapours and lead dusts created when any component of a Group 5 product is burned or melted.

Rationale:
Group 5 products which contain lead and which are intended to be melted or burned, may release lead vapours during use. Elemental lead has a relatively low melting point of 328 oC. When lead is heated to melting point, the lead vapourizes. This airborne vapourized lead quickly condenses to form a fume consisting of microscopic particles of lead suspended in air. The composition and toxicity of the fumes produced by melting or burning is dependent upon such factors as the product's composition, including impurities, its melting or vaporizing temperature, and the environment in which it is being used.

Lead fumes are readily inhaled into the lungs. Inhaled particles in the 0.003 - 5.0 micron size range are most likely to be retained in the lung. Lead fume particles are typically less than 1 micron (one millionth of a metre), so that there is considerable potential for them to remain in the lung. About 80% of inhaled lead is absorbed into the bloodstream (12,101), so that inhalation of lead fumes can result in a significant increase to the body lead burden. Larger inhaled particles that have impacted onto the mucous of the trachea or bronchial walls will be transported by ciliary action to the mouth. If they are swallowed, uptake may occur from the gastrointestinal system. Particles not inhaled will settle onto room surfaces where they become mixed with household dust to form a reservoir of lead-laden dust, which acts as a secondary source of lead exposure, particularly for young children.

Candles with lead-core wicks, discussed under 3.2 above, are an example of a Group 5 product which can emit lead vapours when burned (104).

There is little data on the production of lead vapours when consumer products are burned or melted. Experiments on lead-core wick candles carried out by the U.S. Consumer Product Safety Commission found no reliable correlation between the lead content of the wicks and the amount of lead vapour released when the candles are burned. However, the Commission found that no measurable amounts of lead fumes were produced when candles with metallic wicks containing 600 ppm or less of lead were burned. (100). In the light of these results, the Commission has proposed a ban on candles with more than 600 ppm lead in their wicks. The proposed lead content standard for Group 5 products is consistent with this standard.

The following exclusions apply to Group 5 products:

• untreated firewood to which lead has not been intentionally added.
• products covered under the Explosives Act administered by Natural Resources Canada.