Summary of the Lead Risk Reduction Strategy
Consumer Product Safety Bureau Health Canada
Background
Lead is an inexpensive, soft, heavy metal which has many potential uses, but which 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 body.
Current lead content regulations under the federal Hazardous Products Act & Regulations are considered inadequate to protect consumers, especially children, against exposure to lead in 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.
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 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 is recognized internationally as one of the most serious environmental threats to children's health. Health Canada, as the federal agency with primary responsibility for the health of Canadians, is committed to eliminating unnecessary lead exposure in children.
Currently only the following consumer products are regulated for lead content under the federal Hazardous Products Act & Regulations administered by Health Canada:
- Paints, enamels and other decorative coatings on pencils and artists' brushes, and on toys, children's furniture, and other articles intended for children. The current regulation stipulates that the coating on any of these products should not contain more than 5000 mg/kg total lead.
- Paints, enamels and other liquid coating materials on furniture, household products, children's products, exterior and interior surfaces of any building frequented by children may not contain more than 0.5% lead by weight. This limit will be reduced to 0.06% by weight under a regulatory amendment.
- Toys, equipment, and other products "for use by a child in learning or play" may not contain more than 5000 mg/kg lead.
- Glazes, coatings or decorations on ceramics and glassware used for storing, preparing, or serving food or beverages.
- Kettles. The regulation limits the amount of lead that may be released when water is boiled in the kettle.
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 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 effctive means of controlling this risk.
Proposed Lead Content Regulations under the Lead Risk Reduction Strategy
General Considerations
The Strategy proposes lead content standards for five categories of consumer product with which children are likely to interact. The standards for each product group reflect the relative level of risk, which is determined by the probability that child/product interactions would occur and would result in exposure to lead, and the exposed 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 subjected to the action of the digestive system. The proposed standards are in harmony with international standards.
A total prohibition on lead in a consumer product would be unrealistic because trace amounts of lead are found everywhere in the natural and human environments.
Three groups of products which may contain lead and to which children may potentially be exposed are not covered by the current Strategy. The first two groups - Household Furnishings and Fittings, such as furniture, vent coverings, wallpaper, and holiday trim, and Products Intended to be used in Public Spaces, such as nails, screws and other fasteners, exercise weights and leaded greases and caulking compounds - contain a very broad range of products and would affect a large number of industry stakeholders. Since the risk for children of lead exposure through these products is not as great, Health Canada has decided to address these product groups in a separate strategy paper. The third product group, Products used for Hunting and Fishing, such as lead shot and leaded fishing weights, presents a number of potential risks for both human health and the environment. However it is unclear whether Health Canada has the authority to regulate the sale of these products. A legal opinion is being sought on this issue. Jurisdiction over the use of these products is shared by a number of federal and provincial/territorial agencies.
Proposed Lead Content Regulations
| Group 1: |
Products Likely to be Ingested in Significant Quantities |
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| Examples: |
children's crayons, modelling clays, and paints |
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| Lead Limit: |
for each individual component of Group 1 products which is likely to be ingested, total lead must not exceed 75 ppm. Migratable lead therefore cannot exceed 75 ppm. |
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| Exemptions: |
food, beverages, medicines or other products intended for human consumption. Lead content of these products is regulated under the federal Food & Drugs Act. |
| Group 2: |
Products intended to be or Likely to be Placed in or near the Mouth (Group 1 products are excluded.) |
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| 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, and crib toys
- plastic beverage straws
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| Lead Limit: |
for each individual component of Group 2 products which is likely to be placed in or near the mouth, total lead must not exceed 90 ppm. Migratable lead therefore cannot exceed 75 ppm. |
| Group 3: |
Children's Equipment, Furniture, Toys and other Items intended for use by a child in Learning or Play (Group 1 and Group 2 products are excluded). |
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| Examples |
- baby carriers, strollers, playpens, high chairs and cribs
- children's clothing, footwear, and accessories
- interior and exterior play equipment
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| 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. |
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| Exemptions: |
- 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.
- solder and flux used to fuse or connect components of jewellery, crafts, or artists' products
- artistic paints and pigments will be exempt from the requirement for total lead not to exceed 600 ppm, but they will be subject to the migratable lead limit of 90 mg/kg.
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| Group 4: |
Products intended for use in preparing, serving, or storing food or beverages (Groups 1, 2 and 3 products are excluded.) |
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| Examples |
- cooking utensils such as beaters, spatulas, pots and pans
- serving utensils such as spoons, forks and knives
- tableware such as plates, bowls, drinking glasses and mug
- food storage materials and containers such as plastic and foil wrap, sandwich bags, and juice jugs
- lead crystal decanters and other crystalware
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| Lead Limit: |
total lead must not exceed 600 ppm. |
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| Exemptions: |
- glazes, coatings, and decorations on ceramics and glassware (lead content of these materials is already regulated under the federal Hazardous Products Act)
- kettles, which are already regulated for migratable lead content under the federal Hazardous Products Act.
- pre-packaged food items, which are regulated under the federal Food & Drugs Act
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| Group 5: |
Consumer Products intended to be or likely to be Melted or Burned in Enclosed Spaces (Groups 1,2, 3, and 4 products are excluded). |
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| Examples |
- candles
- incense
- fuel for indoor lanterns
- metal moulding kits for craft making
- chemical fire logs
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| Lead Limit: |
Total lead in each component of Group 5 products which is intended to be or likely to be burned or melted, must not exceed 600 ppm. (Group 5 products represent a double hazard, in that the lead fumes they produce, if not inhaled, settle out on household surfaces as lead-contaminated dust.) |
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| Exemptions: |
- untreated firewood to which lead has not been intentionally added
- products covered under the federal Explosives Act
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Implementation of the Lead Risk Reduction Strategy
Stakeholder consultations on the recommendations of the Strategy are being carried out. The Strategy will be revised to take into account feedback received from stakeholders. A stakeholder report will be issued. If there is sufficient stakeholder acceptance of the proposals, the process whereby the Strategy proposals are promulgated as regulations under the Hazardous Products Act will be initiated.
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