Chemical Compliance - Amazon Web Services · developing, exposure to toxic chemicals during childhood can have particularly harmful and lasting effects on their health. Examples of

Chemical Compliance:

Testing for Toxics in Children’s Products

Chemical Compliance: Testing for Toxics in Children’s Products

Brian Imus Kate Lehman

October 2009

2 Chemical Compliance: Testing for Toxics in Children’s Products

Acknowledgments The authors wish to thank Jeff Gearhart at the Ecology Center, Elizabeth Hitchcock, Public Health Advocate for the US Public Interest Research Group Education Fund, and STAT Analysis Corporation for all their help in the extensive testing process. The authors bear responsibility for any factual errors. The recommendations are those of Illinois Education Fund. The views expressed in this report are those of the authors and do not necessarily reflect the views of our funders or those who provided review. © 2009 Illinois PIRG Education Fund With public debate around important issues often dominated by special interests pursuing their own narrow agendas, Illinois PIRG Education Fund offers an independent voice that works on behalf of the public interest. Illinois PIRG Education Fund, a 501 (c) (3) organization, works to protect consumers and promote good government. We investigate problems, craft solutions, educate the public, and offer Americans meaningful opportunities for civic participation. For more information about Illinois PIRG Education Fund or for additional copies of this report, please visit www.illinoispirg.org.

http://www.illinoispirg.org/


Table of Contents

I. Introduction………………………………………………………………3-4

II. Toxic Chemical Threats Found in Children’s Products…………………5

a. Lead………………………………………………………...............5-6

b. Phthalates……………………………………………………….....7-9

c. Bromine and Cadmium…………………………………………......9

III. Testing Results…………………………………………………………10

a. Testing Methodology…………………………………….................10

b. Testing

Results…………………………………………………………...10-11

IV. Conclusion and Recommendations……………………………….12-14

V. Endnotes………………………………………………………..…..15-16

VI. Attachments

__________________________________________

I. Introduction

As their minds and bodies grow and develop, children are particularly vulnerable to chemicals

that could affect proper development. Because children have a natural tendency to touch and

mouth objects as a way of exploring the world around them, harmful chemicals can leach out of

these products and enter their bodies.

The recall of millions of lead tainted toys in 2007 brought this concern into sharp focus. More

than 45 million toys and other children‘s products were recalled from consumers‘ homes and

store shelves because of lead and other violations of safety standards. Specifically, the wave of

recalls focused attention on the agency charged with protecting Americans from unsafe

products—the Consumer Product Safety Commission (CPSC) — revealing that it had neither the

resources nor the authority to do its job effectively.


By passing the landmark Consumer Product Safety Improvement Act (CPSIA) in August 2008,

Congress responded with the first major overhaul of the CPSC since it was established during the

Nixon Administration in 1972. In addition to expanding the agency‘s budget, Congress gave the

CPSC more authority to hold corporate wrongdoers accountable and speed recalls, moved

toward banning toxic lead and phthalates except in trace amounts and greatly improved import

surveillance.

Before passage of the CPSIA, the allowable level of lead paint on a child‘s product was 600 parts

per million (ppm). Effective August 2009, toys and children‘s products are prohibited from

having more than 90 ppm of lead in their surface paint, and prohibited from having more than

300 ppm of total lead content in the product itself. Over the next three years, the new law will

phase in new standards that will lower the allowable level of total lead in a product to 100 ppm

by 2011.

With the passage of the CPSIA, six types of phthalates were banned in concentrations of 0.1%

(1,000 ppm). Childcare products and children‘s toys containing the phthalates DEHP, DBP, and

BBP in concentrations higher than 0.1% per phthalate (1,000 ppm), and on childcare products

and children‘s toys that can be put in a child's mouth containing the phthalates DINP, DnOP, and

DIDP in concentrations higher than 0.1% per phthalate (1,000 ppm). The ban on DINP, DnOP

and DIDP is in effect pending a Chronic Hazard Advisory Panel‘s report on the health effects of

the chemicals.

However, lead and phthalates are not the only toxic chemical threats that can be found in

children‘s products. Cadmium, brominated flame retardants and Bisphenol-A all pose a threat to

the growth and development of children. Yet these chemicals and others are being used in toys,

baby bottles and other children‘s products

In an effort to monitor compliance with the new lead and phthalate standards and bring

awareness to other toxic threats, Illinois PIRG Education Fund purchased 87 toys and children‘s

products found on Illinois store shelves and tested these products for lead, bromine and other

toxic chemicals. For likely products that contained high levels of chlorine, we also tested for

phthalates. The children‘s products tested were purchased in September 2009, after the new

CPSIA lead standard of 300 ppm was implemented in August 2009.

Chemical Compliance: Testing for Toxics in Children’s Products provides a summary of our

testing as well as recommendations for regulators, policy makers and parents to improve the

safety of children‘s products.


__________________________________________

II. Toxic Chemical Threats Found in

Children’s Products

Chemicals linked to cancer, developmental problems and reproductive disorders routinely show

up in our children‘s toys and products intended for children, even though safer alternatives are

available.

A growing body of scientific research suggests that because children‘s bodies are still

developing, exposure to toxic chemicals during childhood can have particularly harmful and

lasting effects on their health.

Examples of these threats include lead, a chemical whose hazards have long been known, and

more recently discovered health hazards like phthalates and bromine.

A. Lead

Health officials and children‘s health advocates have long sought to reduce children‘s daily

exposure to lead, which can impair mental and physical development. Lead-based paint is a

common and long-term concern that needs diligent and constant watch. After the major recalls in

2007-2008, the public has never been more aware of the possibility of lead in their children‘s

toys and more aware of the health concerns caused by the presence of lead.

The Dangers of Lead Exposure: Exposure to lead can affect almost every organ and system in

the human body, especially the central nervous system. Lead is especially toxic to the brains of

young children. A child exposed to a single high dose of lead—such as by swallowing a piece of

metal jewelry containing lead—can suffer permanent neurological and behavioral damage, blood

poisoning, and life-threatening encephalopathy. Exposure to low doses of lead can cause IQ

deficits, attention deficit hyperactivity disorder, and deficits in vocabulary, fine motor skills,

reaction time, and hand-eye coordination.1

Children are more vulnerable to lead exposure than adults, since young children often put their

hands and other objects in their mouths; their growing bodies absorb more lead; and children‘s

developing brains and nervous systems are more sensitive to the damaging effects of lead.

Scientists have not identified a ―safe‖ level of lead exposure for children.2

Research published in the New England Journal of Medicine in 2003 showed that children can

lose IQ points with lead levels in their blood below the ―official‖ level of concern (10 µg/dL) as

defined by the Centers for Disease Control.3


Violations Have Been a Problem in the Past: An interim CPSC enforcement policy did not

prevent jewelry with dangerous levels of lead from falling through the cracks. In March 2006,

CPSC recalled 300,000 Reebok heart-shaped charm bracelets. A four year-old child from

Minneapolis died in February 2007 of acute lead poisoning after he swallowed a piece from the

Reebok heart-shaped bracelets.4

During autopsy, doctors removed the Reebok charm from the boy‘s stomach and learned that it

contained 99% lead by weight.5

Since the February 2005 enforcement policy went into effect, CPSC has issued numerous

additional recalls and other actions affecting millions of pieces of jewelry. In May 2006, for

example, CPSC recalled 730,000 metal charms included as a free giveaway in certain Shirley

Temple movie DVDs.6

In 2007, CPSC issued innumerable recalls for excessive lead in paint on children‘s toys and other

products, including: 1.5 million Thomas the Tank Engine toys,7 967,000 Sesame Street, Dora the

Explorer,8 and 250,000 SpongeBob SquarePants toys

9. Recalls for lead and lead paint continued

in 2008. Through November 5, the CPSC had announced 64 excessive lead recalls in 2008

totaling over 6.3 million units. Forty-seven recalls (47) were lead paint violations; 17 recalls

were children‘s jewelry or trinkets. Typical recalls included 67,000 Claire‘s necklaces, 57,000

Benjamin pendants, and 18,500 RR Donnelley miscellaneous learning toys. 10

In July 2009, CPSC fined 9 major companies more than $500,000 for recalls made in 2007-2008,

including Dollar General, Hobby Lobby, First Learning Company, and Michael‘s.11

New Lead Safety Standards: Regulations under the Consumer Product Safety Improvement

Act passed in 2008 banned paint containing lead in a concentration of greater than 600 parts per

million (0.06% by weight) with a phase out process beginning in 2009.12

The Consumer Product Safety Improvement Act of 2008 banned lead in toys and children‘s

products on a phase-out schedule outlined below. After the effective dates, these products cannot

be manufactured or sold.

August 2008: CPSIA rules that the maximum allowable amount of lead in paint shall decrease from

600 ppm to 90 ppm over the next three years.

February 2009: Toys and children‘s products containing lead in excess of 600 parts per million

(ppm) become banned hazardous substances.

August 2009: Toys and children‘s products containing lead in excess of 300 parts per million

(ppm) become banned hazardous substances.

August 2011: Toys and children‘s products containing lead in excess of 100 parts per million

(ppm) become banned hazardous substances. This final limit may be altered by the CPSC if it is

determined to be technologically infeasible.


B. Phthalates

Phthalates are a family of chemicals, including diethyl phthalate (DEP), diethylhexyl phthalate

(DEHP), dibutyl phthalate (DBP), butyl benzyl phthalate (BBP), diisodecyl phthalate (DIDP),

diisononyl phthalate (DINP), di-n-octyl phthalate (DNOP), and many other distinct types. The

polyvinyl chloride (PVC) plastic industry uses large amounts of phthalates as additives to

improve the flexibility of its products, including home siding, flooring, furniture, food

packaging, toys, clothing, car interiors, and medical equipment, including IV bags. In addition,

other manufacturers use phthalates in personal care products such as soap, shampoo, deodorant,

hand lotion, nail polish, cosmetics, and perfume, as well as industrial products like solvents,

lubricants, glue, paint, sealants, insecticides, detergent, and ink.13

Health Effects of Phthalates on the Human Body: Phthalates are pervasive in the environment

and in human bodies. In 2000, the Centers for Disease Control (CDC) found high levels of

phthalates and their transformation products (known as metabolites) in every one of 289 adult

Americans tested, including women of childbearing age.14

A larger CDC study in 2003 again

found high levels of phthalates in almost every person tested.15

U.S. EPA studies show that the cumulative impact of different phthalates leads to an exponential

increase in associated harm. According to data from the U.S. Centers for Disease Control and

Prevention (CDC), levels of phthalates found in humans are higher than levels shown to cause

adverse health effects. The data also show phthalate levels are highest in children. Numerous

scientists have documented the potential health effects of exposure to phthalates in the womb or

at crucial stages of development, including (but not limited to):

• Reproductive Defects. Scientists have demonstrated links between exposure to phthalates in the

womb with abnormal genital development in baby boys and disruption in sexual development.16

In October 2005, an independent panel of scientists convened by the National Institute of

Environmental Health Sciences and the National Toxicology Program released its review of one

type of phthalate, diethylhexyl phthalate (DEHP). The panel confirmed that DEHP poses a risk

to reproductive and developmental health.17

• Premature Delivery. A study published in November 2003 suggests a link between exposure to

phthalates and pre-term birth. The scientists found phthalates and their breakdown products in

the blood of newborn infants, with higher levels leading to a higher incidence of premature

delivery.18

• Early Onset Puberty. One study of girls suggests that phthalates may be playing a role in trends

toward earlier sexual maturity.19

Scientists found that levels of DEHP were seven times higher in

girls with premature breast development than levels in normal girls. Early onset puberty has been

linked to breast cancer later in life.

• Lower Sperm Counts. In 2003, Drs. Susan Duty and Russ Hauser of the Harvard School of

Public Health published one of the first studies linking phthalate exposure with harm to human


reproductive health.20

Men who had monobutyl or monobenzyl phthalate in their urine tended to

have lower sperm counts, with the highest concentrations leading to the lowest sperm counts.

Sounding the Alarm on the Dangers of Phthalates: In 1998, the state PIRGs and several other

environmental and consumer groups petitioned the CPSC, asking the agency to ban polyvinyl

chloride (PVC) plastic in all toys intended for children under the age of five because of the

potential health hazards posed by diisononyl phthalates (DINP). The CPSC stated its position

that ―few if any children are at risk from the chemical.‖21

Regardless, in 1998, the body still

asked the toy and baby products industry to voluntarily remove DINP from soft rattles and

teethers.

About 90 percent of manufacturers indicated at that time that they had or would remove DINP

from soft rattles and teethers by early 1999. CPSC staff also asked the industry to find a

substitute for phthalates in other products intended for children under three years old that are

likely to be mouthed or chewed.22

The CPSC then convened a Chronic Hazard Advisory Panel to examine the existing scientific

data concerning the potential risks of phthalates to humans. In June 2001, the panel concluded

that while the majority of children would not be adversely affected by diisononyl phthalate,

―there may be a DINP risk for any young children who routinely mouth DINP-plasticized toys

for seventy-five minutes per day or more.‖23

Unfortunately, in February 2003, CPSC denied the state PIRGs‘ petition to ban PVC plastic in

toys for young children.24

However, other countries have taken action to protect children‘s health. In September 2004, the

European Union (EU) agreed to impose wide restrictions on the use of six phthalates in toys and

childcare products.25

The EU banned three phthalates classified as reproductive toxicants –

diethylhexyl phthalate (DEHP), butyl benzyl phthalate (BBP), and dibutyl phthalate (DBP) – in

all toys and childcare articles. The EU banned three other phthalates – DINP, diisodecyl

phthalate (DIDP) and di-n-octyl phthalate (DNOP) – in toys and childcare articles intended for

children under three years of age and that can be put in the mouth.26

As countries abroad banned phthalates, the efforts were renewed at the state level. In 2007,

following a campaign by Environment California and health affected groups including the Breast

Cancer Fund, the state enacted legislation banning phthalates in children‘s products.27

In 2008, bills were introduced in eight state legislatures that included bans on phthalates in

children‘s products; Washington State and Vermont both passed legislation that was enacted in

2008.

New Federal Standards on Phthalates: In March 2008, Senator Dianne Feinstein (CA)

successfully offered an amendment to the U.S. Senate‘s Consumer Product Safety Improvement

Act that banned phthalates in children‘s products. In July, the House/Senate Conference

Committee sent a final conference report to the House and Senate floors that became law.


The new law includes a ban on childcare products and children‘s toys containing the phthalates

DEHP, DBP, and BBP in concentrations higher than 0.1% per phthalate (1,000 ppm), and on

childcare products and children‘s toys that can be put in a child's mouth containing the phthalates

DINP, DnOP, and DIDP in concentrations higher than 0.1% per phthalate (1,000 ppm). The ban

on DINP, DnOP and DIDP is in effect pending a Chronic Hazard Advisory Panel‘s (CHAP)

report on the health effects of the chemicals. The CHAP has eighteen months to report its

findings and make a recommendation on whether to make the ban permanent. Both bans are

effective February 2009. The interim ban will only be rescinded if the CHAP recommends doing

so.

C. Unregulated Dangers: Bromine and Cadmium

Bromine has become a major player in the chemical industry for its function in fire prevention.

Brominated Flame Retardants (BFRs) are a favorite among manufacturers because of their cheap

cost and effective performance. There are more than 75 different types of BFRs in the market

today. The top 5 in production are tetrabromobisphenol A (TBBPA), hexabromocyclododecane

(HBCD), and three other types of polybrominated diphenyl ethers (PBDEs). With such a

proliferation of the chemical, including in our children‘s toys, there is very little known about the

impact of Bromine on our health. However, research suggests that there is cause for concern.28

What is known about the health impacts of BFRs: With the widespread use of BFRs, with the

U.S ranking second in the world; the lack of knowledge around this family of chemicals is

disturbing. Studies have shown disturbance in the endocrine system caused by the Brominated

Flame Retardant, TBBPA. The thyroid is the most impacted in these studies and most vulnerable

during development years for children, and a cause of concern for pregnant women. Other

studies suggest that BFRs can negatively affect motor skills, impact learning and memory

development, and are also traced to neurological and brain damage.

Cadmium: Cadmium is a known carcinogen and developmental and reproductive toxin that

bioaccumulates in the body. At low doses the chemical is known to cause nausea, vomiting and

diarrhea. It has been linked to kidney damage and lung cancer. Despite these dangers, Cadmium

is not regulated in children‘s products by the Consumer Product Safety Commission.


__________________________________________

III. Testing Results

Testing Methodology:

Illinois PIRG Education Fund staff purchased 87 toys and children‘s products at four retail stores

around the Chicago area. These stores were Target, Toys R Us, Claire‘s Boutique and Dollar

Tree.

To determine the presence of various toxic chemicals like lead and bromine, we used an X-Ray

Fluorescence (XRF) analyzer to test the products purchased and conducted a total of 178 tests on

various components of the purchased products. Our staff followed the standard testing protocol

when using the XRF analyzer. That standard protocol is attached as Attachment C.

We also had 9 products tested for lead and 7 products tested for the presence of phthalates using

STAT Analysis, a laboratory accredited by the Illinois Environmental Protection Agency in

accordance with the National Environmental Laboratory Accreditation Program. The

methodology on the testing conducted by STAT Analysis is attached as Attachment B.

Testing Results:

Lead: Of the 178 screening tests conducted by our staff using the XRF analyzer, 18 components

tested contained some trace amounts of lead. Six of the 87 children‘s products tested exceeded

the current 300 parts per million standard set by federal statute. While the current permissible

level of lead in products is 300 ppm, scientists have not identified a ―safe‖ level of lead exposure

for children.

Of the 8 products tested by STAT Analysis, 5 contained lead. Of those testing positive for lead, 3

products contained more lead than legally permissible under current law. These were a Cell

Phone Charm purchased at Claire‘s (710000 ppm), a toy duck purchased at Dollar Tree (34000

ppm) and a cloth children‘s book (1900 ppm).

Phthalates: Based on 7 tests conducted by STAT Analysis, 2 contained actionable levels of

phthalates in violation of the new federal law. The Little Princess handbag purchased at Claire‘s

had the phthalate chemical DEHP at 54000 ppm and DINP at 2200 ppm. Elmo‘s Lunch Box

contained 730 ppm of the phthalate chemical DEHP and 72000 ppm of the phthalate DIDP.

Bromine and Cadmium: Currently bromine and cadmium are unregulated toxic chemicals. In 32

products tested using the XRF Analyzer, bromine was detected at some level. Bromine was

detected in levels ranging from 672 ppm to just a few parts per million. Bromine tainted products

does not mean there are brominated flame retard chemicals contained in the product and it is

unknown what chemicals are associated with low levels (<500 ppm) of bromine in products.


However, when antimony is detected in the presence of bromine, there is the likelihood that

BFR‘s were used in the manufacture of the product and should be of concern. Of the 32 products

that tested positive for bromine, 4 also contained antimony as some level and one contained high

enough levels to warrant concern the product may contain BFRs.

Only two products tested positive for Cadmium. The toy alligator cell phone charm contained

714 ppm of cadmium and the Cupcake clip watch contained 214 ppm of cadmium.

A complete table of the testing of each product is provided as Attachment A.


__________________________________________

IV. Conclusion and Recommendations

The testing conducted is but a small sample of the toys and other children‘s products currently on

the market. However, based on this small sample, it is good to see the vast majority of products

meeting current safety regulations. The vast majority of products seem to be meeting current

standards. But, there should be no products available on store shelves that violate current lead

and phthalate standards.

While the CSPIA‘s tough new limits on two toxic chemicals --lead and phthalates—represent a

big step forward in protecting America‘s children from toxic chemicals, these are just two of the

many chemicals that affect our children‘s future that are present in a child‘s world.

Toxic chemicals found in children’s blood at birth

In a 2005 study by the Environmental Working Group (EWG) in collaboration with

Commonweal29

, researchers at two major laboratories found an average of 200 industrial

chemicals and pollutants in umbilical cord blood from 10 babies born in August and September

of 2004 in U.S. hospitals. Tests revealed a total of 287 chemicals in the group. The umbilical

cord blood of these 10 newborns, collected by the Red Cross after the cord was cut, contained

pesticides, consumer product ingredients, and wastes from burning coal, gasoline, and garbage.

Of the 287 chemicals that were detected in the study, 180 were known carcinogens, 217 were

toxic to the brain and nervous system, and 208 cause birth defects or abnormal development in

animal tests.

Many people think, incorrectly, that the government would not allow chemicals to enter the

market if they were not safe. In truth, the regulatory process has failed to work the way

the public believes it should.

U.S. Toxics policy is in need of reform

In 1976, Congress passed the primary law regulating toxic chemicals in the United States, the

Toxic Substances Control Act (TSCA), which grandfathered all existing chemicals on the market

into use without health-effects testing or analysis. Most of these chemicals emerged in the 1940s

and 1950s when few laws governed chemical safety. Today, U.S. EPA reviews new chemicals

that come onto the market but does not require full health effects testing for approval. With an

estimated 2,000 chemicals introduced each year, EPA approves an average of seven

new chemicals each day.30

Current Law Leaves U.S. EPA with Little Power to Protect Public Health

The U.S. government‘s regulation of chemicals is based on the premise that chemicals

are presumed innocent until they are proven to harm human health.


Throughout its nearly 30-year history, TSCA has rarely been amended, but clearly fails

to effectively regulate toxic chemicals. Since the law‘s inception, U.S. EPA has never used

its authority to ban a chemical and has only offered regulations on five different chemicals,

including PCBs, which Congress ordered regulated. U.S. EPA‘s lax regulation can be attributed

to the unreasonably high burden of proof the law places on the agency to show that a chemical

poses an unreasonable risk to human health and the environment.

TSCA divides all the chemicals on the market into two categories: existing chemicals and

new chemicals. Existing chemicals are chemicals already on the market before 1980. These

make up approximately 99 percent by volume of the chemicals on the market today.

Existing chemicals are considered safe until U.S. EPA can establish that they pose an

unreasonable risk to people‘s health or the environment, that the benefits of action outweigh the

risks of inaction, and that U.S. EPA is employing the least burdensome method when taking

action.31

Companies that wish to introduce new chemicals to the U.S. market must notify U.S. EPA at

least 90 days before producing or importing a new chemical. The new chemicals program,

however, should be improved by increasing the testing requirements of the chemicals.

U.S. EPA should have the authority and means to guarantee chemicals on the market are safe

for human health and the environment. In its 1998 review of high production volume

chemicals, U.S. EPA estimated the cost for a full round of basic screening tests, including tests

for reproductive and developmental toxicity, at about $205,000 per chemical.32

The

chemical industry, with profits of $13.5 billion in 2004, should pay this price to protect both

health and the environment.33

Recommendations for Policy Makers

The state and federal government must ensure the safety of all products on the market for

children.

• Phase Out Dangerous Chemicals.

The federal government must act based on the overwhelming weight of evidence showing that

some chemicals might harm human health. Manufacturers should be required to remove

chemicals that may pose a particular threat to fetuses, infants, and children, particularly when the

chemical is not necessary for the product to function according to design.

• Reform Chemicals Policy.

Currently, manufacturers can put chemicals on the market without proving they are

safe. Manufacturers should be required to provide all hazard and health-impact information

to the state and federal government so agencies can begin to assess the thousands of

chemicals currently on the market for which little or inadequate data are available.

Next, manufacturers of chemicals should be required to conduct an alternatives analysis, in order

to determine if they really are using the least hazardous chemical for each application.

• Inform Consumers about the Presence of Dangerous Chemicals.


The state and federal government must inform consumers about the presence of dangerous

chemicals in products. Manufacturers should be required to label products with the names of

these chemicals in order to allow parents to choose less toxic products.

• Fully fund the CPSC.

Subject to Congressional appropriations, the CSPIA reauthorizes the CPSC for 5 fiscal years,

with annual increases in funding authorizations to $136 million in 2014, with additional targeted

funding to refurbish its decrepit labs. The new law also dramatically increases staffing levels,

especially for front-line inspection and import safety staff. Congress should fully fund this

important agency so that it may utilize the new authority and responsibility that it was given in

the Consumer Product Safety Improvement Act.

__________________________________________


__________________________________________

V. Endnotes

1 ATSDR, Case Studies in Environmental Medicine: Lead Toxicity, October 2000; American Academy of Pediatrics, ―Lead

Exposure in Children: Prevention, Detection and Management,‖ Pediatrics, 1036-1048 (October 2005). 2 Centers for Disease Control and Prevention, Preventing Lead Poisoning in Young Children, August 2005. 3 Richard L. Canfield, Ph.D., Charles R. Henderson, Jr., M.A., Deborah A. Cory-Slechta, Ph.D., Christopher Cox, Ph.D.,

Todd A. Jusko, B.S., and Bruce P. Lanphear, M.D., M.P.H., ―Intellectual Impairment in Children with Blood Lead

Concentrations below 10 μg per Deciliter,‖ New England Journal of Medicine, April 17, 2003, Volume 348:1517-1526. 4 CPSC, ―Reebok Recalls Bracelet Linked to Child‘s Lead Poisoning Death,‖ press release, March 23, 2006. Accessed October

30, 2006 at http://www.cpsc.gov/cpscpub/prerel/prhtml06/06119.html. 5 Centers for Disease Control, ―Death of a Child After Ingestion of a Metallic Charm --- Minnesota, 2006,‖ Morbidity and

Mortality Weekly Report, March 23, 2006. 6 CPSC, ―Metal Charms Sold with Twentieth Century Fox DVDs Recalled for Toxic Lead Hazard,‖ press release, May 5,

2006. 7 CPSC release of June 13, 2007, ―RC2 Corp. Recalls Various Thomas & Friends™ Wooden Railway Toys Due to Lead

Poisoning Hazard,‖ accessed on November 7, 2007 at http://www.cpsc.gov/CPSCPUB/PREREL/prhtml07/07212.html. 8 CPSC release of August 2, 2007, ―Fisher-Price Recalls Licensed Character Toys Due To Lead Poisoning Hazard,‖

(http://www.cpsc.gov/cpscpub/prerel/prhtml07/07257.html last accessed on November 7, 2007). 9 CPSC release, August 22, 2007, ―Martin Designs Inc. Recalls SpongeBob SquarePants Character Address Books and Journals

Due to Violation of Lead Paint Standard,‖ Accessed November 7, 2007 at

http://www.cpsc.gov/cpscpub/prerel/prhtml07/07283.html. 10 U.S. PIRG analysis of CPSC recall announcements. 11 CPSC Release, July 7, 2009, ―Nine Companies Penalized for Selling Children‘s Products that Violated the Federal Lead Paint

Ban,‖

(http://www.cpsc.gov/cpscpub/prerel/prhtml09/09264.html last accessed on October 14, 2009). 12CPSC, ―Section 101. Children‘s Products Containing Lead; Lead Paint Rule,‖ (http://www.cpsc.gov/about/cpsia/sect101.html

last accessed on October 14, 2009). 13 Phthalate Esters Panel of the American Chemistry Council, What are Phthalates?, downloaded from www.phthalates.org on 14

April 2004; Catherine Dorey, Greenpeace, Chemical Legacy: Contamination of the Child, October 2003. 14 BC Blount et al, ―Levels of Seven Urinary Phthalate Metabolites in a Human Reference Population,‖ Environmental Health

Perspectives 108: 979-982, 2000. 15 Manori J Silva et al, ―Urinary Levels of Seven Phthalate Metabolites in the U.S. Population from the National Health and

Nutrition Examination Survey (NHANES) 1999-2000,‖ Environmental Health Perspectives 112: 331-338, March 2004. 16 Shanna H. Swan et al, ―Decrease in anogenital distance among male infants with prenatal phthalate exposure,‖ Environmental

Health Perspectives 113; 1056-1061, August 2005; LE Gray et al, ―Perinatal Exposure to the Phthalates DEHP, BBP, and DINP,

but not DEP, DMP, or DOTP, Alters Sexual Differentiation of the Male Rat,‖ Toxicological Science 58: 350-365, December

2000; Vickie Wilson et al, ―Phthalate Ester-Induced Gubernacular Lesions are Associated with Reduced Insl3 Gene Expression

in the Fetal Rat Testis,‖ Toxicology Letters 146: 207-215, 2 February 2004; JS Fisher et al, ―Human ‗Testicular Dysgenesis

Syndrome‘: A Possible Model Using in-utero Exposure of the Rat to Dibutyl Phthalate,‖ Human Reproduction 18: 1383-1394,

2003. 17 NIEHS, ―Independent Panel to Evaluate a Chemical Used in Some Plastics (Di (2-ethylhexyl) phthalate) for Hazards to Human

Development or Reproduction,‖ press release, October 5, 2005. 18 G Latini et al, ―In-Utero Exposure to Di-(2-ethylhexyl)-phthalate and Human Pregnancy Duration,‖ Environmental Health

Perspectives 111:1783-1785, 2003. 19 I. Colón, D Caro, CJ Bourdony and O Rosario, ―Identification of Phthalate Esters in the Serum of Young Puerto Rican Girls

with Premature Breast Development,‖ Environmental Health Perspectives 108: 895-900, 2000. 20 SM Duty et al, ―Phthalate Exposure and Human Semen Parameters,‖ Epidemiology 14: 269-277, 2003; SM Duty et al, ―The

Relationship Between Environmental Exposures to Phthalates and DNA Damage in Human Sperm Using the Neutral Comet

Assay,‖ Environmental Health Perspectives 111: 1164-1169, 2003. 21 CPSC, ―CPSC Releases Study on Phthalates in Teethers, Rattles and Other Children‘s Products,‖ press release, December 2,

1998, accessed November 7, 2007 at www.cpsc.gov/CPSCPUB/PREREL/PRHTML99/99031.html. 22 CPSC, ―CPSC Releases Study on Phthalates in Teethers, Rattles and Other Children‘s Products,‖ press release, December 2,

1998, accessed November 7, 2006 at www.cpsc.gov/CPSCPUB/PREREL/PRHTML99/99031.html. 23 Report to the U.S. Consumer Product Safety Commission by the Chronic Hazard Advisory Panel on Diisononyl Phthalate,

June 2001. Accessed November 7, 2006 at http://www.cpsc.gov/LIBRARY/FOIA/Foia01/os/dinp.pdf.

http://www.cpsc.gov/cpscpub/prerel/prhtml07/07283.html

http://www.cpsc.gov/cpscpub/prerel/prhtml09/09264.html

http://www.cpsc.gov/about/cpsia/sect101.html

http://www.phthalates.org/

http://www.cpsc.gov/LIBRARY/FOIA/Foia01/os/dinp.pdf


24 CPSC, Letter to Jeffrey Becker Wise, National Environmental Trust, February 26, 2003, accessed November 7, 2006 at

http://www.cpsc.gov/library/foia/foia03/petition/ageunder.PDF. 25 ―Results of Competitiveness Council, Brussels, 24th September 2004,‖ Memo/04/225. 26 Bette Hileman, ―EU Bans Three Phthalates from Toys, Restricts Three More,‖ Chemical and Engineering News, July 11, 2005. 27 News release, October 15, 2007, ―Governor Signs Bill to Protect Kids from Toxic Toys,‖ Accessed November 7, 2007 at

http://www.environmentcalifornia.org/newsroom/environmental-health/environmental-health-news/governor-signs-bill-toprotect-

kids-from-toxic-toys. 28 Birnbaum, Linda S., ―Brominated Flame Retardants: Cause for Concern?,‖ U.S. Environmental Protection Agency, Office of

Research and Development, National Health and Environmental Effects Research Laboratory, Experimental Toxicology

Division, Research Triangle Park, North Carolina, USA;

Staskal, Danielle F., University of North Carolina, Curriculum in Toxicology, Chapel Hill, North Carolina, USA 29 Environmental Working Group, ―Body Burden — The Pollution in Newborns‖, July 14, 2005. Accessed November 13, 2008

at http://archive.ewg.org/reports/bodyburden2/ 30 Environmental Working Group, Body Burden: The Pollution in Newborns, July 2005. 31 Lowell Center for Sustainable Production, The Promise and Limits of the United States Toxic Substances Control Act, October

10,2003. 32 U.S. Environmental Protection Agency, Office of Pollution Prevention and Toxics, Chemical Hazard Data Availability Study,

April 1998. 33 Bureau of Economic Analysis, National Economic Accounts, Corporate Profits, ―News Release: Gross Domestic Product and

Corporate Profits,‖ September 29, 2005, at http://www.bea.doc.gov/bea/newsrelarchive/2005/gdp205f.htm. Table 12

contains data on ―Corporate Profits by Industry,‖ available at http://www.bea.doc.gov/bea/newsrelarchive/2005/gdp205f.xls.

http://www.cpsc.gov/library/foia/foia03/petition/ageunder.PDF

http://archive.ewg.org/reports/bodyburden2/

http://www.bea.doc.gov/bea/newsrelarchive/2005/gdp205f.htm

http://www.bea.doc.gov/bea/newsrelarchive/2005/gdp205f.xls

VI. Attachments

1.

Product: Baby’s First Sounds SKU:379778003, Age: 6 months Retailer: Target

Parts Tested (4): Cl Br Pb

Monkey Face <LOD <LOD <LOD

Red Front <LOD <LOD <LOD

Red Page <LOD 4 <LOD

Yellow Page <LOD <LOD <LOD

2.

Product: Sponge Bob Cuddle Pillow SKU: 9231788269, Age: 6 months Retailer: Target


Yellow Body <LOD <LOD <LOD

Black Belt <LOD 156 <LOD

3.

Product: Sesame Street Insulated Sippy Cups SKU: 7146309095, Age: 9 months Retailer: Target


Yellow cup <LOD <LOD <LOD

Green top <LOD <LOD <LOD

4.

Product: Sassy "Look Book" Baby Photo Book SKU: 3797780021, Age: 3 months Retailer: Target


Ladybug <LOD 8 <LOD

Yellow Page <LOD <LOD <LOD

Handle <LOD <LOD <LOD

5.

Product: Just One Year Halloween PJ’s SKU: 6445400756, Age: 3 months Retailer: Target


Witch 52012 <LOD <LOD

Black Cat 19917 <LOD <LOD

6.

Product: Mrs. Potato Head SKU: 3224502251, Age: 2+ Retailer: Target


Lips 365544 <LOD <LOD

Body <LOD <LOD <LOD

7.

Product: 10 Squirtin' Sea Buddies SKU: 3528218004, Age: 9 months Retailer: Target

Part Tested: Cl Br Pb

Blue Penguin 267429 <LOD <LOD

8.

Product: Bubble Ducky Spout Guard SKU: 3528232501, Age: Not Specified Retailer: Target


Hat 285457 <LOD <LOD

Hatchet 251099 <LOD <LOD

Yellow Body 353284 <LOD <LOD

9.

Product: Hello Kitty Cuddle Pillow SKU: 7355861869, Age: Not Specified Retailer: Target

Parts Tested (3):

Fabric Body <LOD 24 <LOD

Pink Bow <LOD 33 <LOD

Phone <LOD 37 <LOD

10.

Product: Elmo Live! SKU: 2708454173, Age: 18 months Retailer: Target


Hands <LOD <LOD <LOD

Nose <LOD <LOD <LOD

Eyes <LOD <LOD <LOD

11.

Product: Piggy Bank SKU: 8895564625, Age: Not Specified Retailer: Target


Crown NA 0 <LOD

Body <LOD <LOD 93

12.

Product: Disney Princess Costume Set SKU: 492170213883, Age: 3+ Retailer: Target


Bodice <LOD <LOD <LOD

Skirt <LOD <LOD <LOD

13.

Product: Boppy feeding Pillow SKU: 6966227405, Age: Not Specified Retailer: Target


Back <LOD <LOD <LOD

14.

Product: Paul Frank Monkey Hat SKU: 9217030041, Age: Not Specified Retailer: Target


Ear <LOD 4 <LOD

15.

Product: Sassy Sensory Symphony SKU: 3797780032, Age: 6 months Retailer: Target


Fabric Front <LOD 7 <LOD

Plastic Fish <LOD <LOD <LOD

Body <LOD <LOD <LOD

16.

Product: Circo Wooden Bead Maze SKU: 0694363144, Age: 2+ Retailer: Target


Red Bead <LOD <LOD <LOD

Yellow Star <LOD <LOD <LOD

Metal Slide <LOD <LOD <LOD

17.

Product: 2 in 1 Harness Buddy by Eddie Bauer SKU: 7153452866, Age: Not Specified Retailer: Target


Plastic Snap <LOD 21 <LOD

Straps <LOD <LOD <LOD

Body <LOD 8 <LOD

18.

Product: Carrier Toy Bar SKU: 7445108676, Age: 0-12 months Retailer: Target


Pink bug <LOD <LOD <LOD

Sun face <LOD 8 <LOD

Pink Flower <LOD 9 <LOD

Strap <LOD <LOD <LOD

19.

Product: Mini Stacking Train SKU:0077202479, Age: 2+ Retailer: Target


Red Wheels <LOD <LOD <LOD

Yellow Block <LOD <LOD <LOD

Orange Block <LOD <LOD <LOD

20.

Product: Mommy's Melodies Bear SKU: 1291402375, Age: 0+ Retailer: Target Parts Tested (3): Cl Br Pb

Body <LOD <LOD <LOD

Ribbon <LOD <LOD <LOD

Nose <LOD 6 <LOD

21.

Product: Rhyme and Discover Book SKU: 050803608019, Age: 6+ Months Retailer: Toys R’ Us Parts Tested (4): Cl Br Pb

Cover <LOD <LOD <LOD

"Mary had a little lamb" page <LOD <LOD <LOD

Binding <LOD 17 <LOD

Red Dog Tab <LOD 131 21

22.

Product: Bob the Builder T-shirt by Extreme Concepts SKU: 631338121626, Age: All Ages Retailer: Toys R’ Us Parts Tests (2): Cl Br Pb

Bob the Builder (face) 55562 <LOD <LOD Glow in the Dark Parts 90069 <LOD <LOD

23.

Product: Adventures of Thomas the Tank Engine by Learning Curve SKU: 796714991290, Age: 2+ Retailer: Toys R’ Us Parts Tests (2): Cl Br Pb

Snow Thomas

<LOD <LOD <LOD Paint-splattered Thomas

<LOD <LOD <LOD

24.

Product: Imaginarium 3 Piece Wooden Train Set SKU: 717851693946, Age: 3+ Retailer: Toys R’ Us Parts Tested (1): Cl Br Pb

Red Train

<LOD <LOD <LOD

25.

Product: Molly of Thomas & Friends Talking Series by Learning Curve SKU: 796714987149, Age: 2+ Retailer: Toys R’ Us Parts Tested (2): Cl Br Pb

Train

<LOD <LOD <LOD

Yellow Wheel

<LOD 9 <LOD

26.

Product: Melissa and Doug’s Geometric Stacker SKU: 000772005678, Age: 2+ Retailer: Toys R’ Us Parts Tested (3): Cl Br Pb

Yellow Wheel

<LOD <LOD <LOD

Red Block

<LOD <LOD <LOD

Blue Block

<LOD <LOD <LOD

27.

Product: Piggy Toes Toys Touch and Feel Bedtime Book SKU: 9781581172799, Age: 2+ Retailer: Toys R’ Us Parts Tested (2): Cl Br Pb

Sheep Cover <LOD <LOD <LOD Dog Touch and Feel Page 45516 <LOD <LOD

28.

Product: Especially for Baby Bath Wind-up Toy SKU: 717851180163, Age: 2+ Retailer: Toys R’ Us Parts Tested (3): Cl Br Pb

Yellow Face

49499 4 <LOD

Blue Fin

<LOD <LOD <LOD

Orange Body

<LOD <LOD <LOD

29.

Product: Soft Play’s Twinkle Twinkle Elmo SKU:9781592922925, Age: 6+ Retailer: Toys R’ Us


Rocket ship Page <LOD 6 <LOD

Elmo Mirror Page <LOD <LOD <LOD

30.

Product: Little First Look and Find ft. Disney’s Finding Nemo Book SKU: 9781412784399, Age: Not specified Retailer: Toys R’ Us Parts Tested (2): Cl Br Pb

Foam cover <LOD <LOD <LOD

Colorful Gems Page <LOD <LOD <LOD

31.

Product: Melissa & Doug Jigsaw Puzzle SKU: 000772029377, Age: 3+ Retailer: Toys R’ Us Part Tested: Cl Br Pb Puzzle Piece <LOD <LOD <LOD

32.

Product: Melissa & Doug’s Play-time Produce Farm Fresh Fruit SKU: 000772040822, Age: 3+ Retailer: Toys R’ Us Parts Tested (5): Cl Br Pb

Strawberry

336474 <LOD <LOD

Apple

364054 <LOD <LOD

Plum

449786 <LOD <LOD

Orange

357716 <LOD <LOD

Banana

387593 <LOD <LOD

33.

Product: Super Why Action Figure by Learning Curve SKU: 796714512013, Age: 3+ Retailer: Toys R’ Us Parts Tested (4): Cl Br Pb

Masked face 323983 <LOD <LOD

Body <LOD <LOD <LOD

Cape <LOD <LOD <LOD

Red Accessory <LOD <LOD <LOD

34.

Product: Berkshire Fashions Thomas & Friends Umbrella SKU: 081715530174, Age: Not Specified Retailer: Toys R’ Us Part Tested (2): Cl Br Pb

Red Vinyl

<LOD 54 <LOD

handle

<LOD <LOD <LOD

35.

Product: Disney Baby Stack and Discover Blocks SKU: 07445190522, Age: 3 months Retailer: Toys R’ Us Parts Tested (3): Cl Br Pb

Small Green Apple <LOD <LOD <LOD

Medium Red Bird Block <LOD <LOD <LOD

Large Blue Butterfly Block <LOD <LOD <LOD

36.

Product: Strawberry Shortcake Lunch Bag SKU: 840716079477, Age: 3+ Retailer: Toys R’ Us Parts Tested (2): Cl Br Pb

Front

420652 <LOD <LOD

Back

91825 <LOD <LOD

Inside

<LOD <LOD <LOD

37.

Product: Especially for Baby Bath Time Support SKU: 717851180187, Age: Retailer: Toys R’ Us Part Tested: Cl Br Pb

Padding

<LOD <LOD <LOD

38.

Product: Elmo Lunch Bag **** SKU: 840716079446, Age: 3+ Retailer: Toys R’ Us Parts Tested (3): Cl Br Pb

Front

550000 <LOD 29

Back

103271 <LOD <LOD

Inside

<LOD <LOD <LOD

39.

Product: Just Like Home & McKids Plastic Food Set SKU: 045672904829, Age: 3+ Retailer: Toys R’ Us Parts Tested (7): Cl Br Pb

Fries

<LOD <LOD <LOD

Apple Pie Box

<LOD <LOD <LOD

Salad Bowl

<LOD <LOD <LOD

Hamburger

<LOD <LOD <LOD

Tomato

<LOD <LOD <LOD

Cheese

<LOD <LOD <LOD

Carrying Case

356048 <LOD <LOD

40.

Product: Little People Noah’s Animals SKU: 027084603996, Age:1-4 Retailer: Toys R’ Us Parts Tested (2): Cl Br Pb

Purple Hippo

204089 <LOD <LOD

Kangaroo face/ear

260164 <LOD <LOD

41.

Product: Fisher-Price Tuff Rumblin’ Vehicles SKU: 673579065017, Age: 3+ Retailer: Toys R’ Us Parts Tested (2): Cl Br Pb

Yellow Section

<LOD 16 <LOD

Orange Front

<LOD 359 <LOD

42.

Product: PEZ Pocahontas Dispenser SKU: 073621008199, Age: 3+ Retailer: Toys R’ Us Part Tested: Cl Br Pb

Dispenser Body

<LOD <LOD <LOD

43.

Product: Super Mario Bros. Backpack SKU: 843340011707, Age: 3+ Retailer: Toys R’ Us Parts Tested (2): Cl Br Pb

Mario’s Face

321044 <LOD <LOD

Back

18741 17 <LOD

44.

Product: Disney’sGoofy Driving Construction Vehicle SKU: 027084745085, Age: 2+ Retailer: Toys R’ Us Parts Tested (2): Cl Br Pb

Goofy

187603 <LOD <LOD

Car

<LOD <LOD <LOD

45.

Product: Priddy Books Touch and Feel Cloth Book SKU: 9780312492601, Age: Not Specified Retailer: Toys R’ Us Parts Tested (3): Cl Br Pb

Cover <LOD <LOD <LOD Yellow Patch on Spinosaurus Page <LOD <LOD <LOD

Red Dot on Back Page <LOD <LOD 212

46.

Product: Bratz Walking Doll SKU: 035051361275, Age: 6+ Retailer: Toys R’ Us Parts Tested (4): Cl Br Pb

Dog’s Body

<LOD <LOD <LOD

Doll's Face

385478 <LOD <LOD

Inside of Jacket

<LOD 18 <LOD

Hair

550000 <LOD <LOD

47.

Product: Barbie Princess Styling Head SKU: 027084656329, Age: 3+ Retailer: Toys R’ Us Parts Tested (4): Cl Br Pb

Face

461290 <LOD <LOD

Dress

<LOD <LOD 8

Brush

<LOD <LOD <LOD

Tiara

<LOD <LOD <LOD

48.

Product: Claire’s Best Friend Mood Rings SKU:25212-2-05-14-179, Age: Not Specified Retailer: Claire’s Part Tested: Cl Br Pb

Mood Section

<LOD 58 <LOD

49.

Product: Pretty Princess Puppy Purse **** SKU: 36699-7, Age: 3+ Retailer: Claire’s Part Tested: Cl Br Pb

Front

232139 9

<LOD

50.

Product: High School Musical I <3 Troy Hair Clip SKU: 17613-1 08-03 25, Age: 3+ Retailer: Claire’s Part Tested: Cl Br Pb

I <3 Troy

<LOD <LOD <LOD

51.

Product: Little Princess Collection Hair Tiara SKU: 62899-0 12-12 337, Age: 3+ Retailer: Claire’s Part Tested: Cl Br Pb

Front

<LOD 53 35

52.

Product: Hot Pink Chain Link Necklace SKU: 89325-5 05-06 169, Age: Not Specified Retailer: Claire’s Part Tested: Cl Br Pb

Chain

NA 0 <LOD

53.

Product: Lady Bug Beaded Necklace SKU: 67467-1 12-02 498, Age: 3+ Retailer: Claire’s Part Tested: Cl Br Pb

Bead

<LOD <LOD <LOD

54.

Product: Claire’s Beaded Necklace SKU: 46360-4 05-06 238, Age: Not Specified Retailer: Claire’s Part Tested: Cl Br Pb

Beads

<LOD <LOD <LOD

55.

Product: Electronic Accessory Case SKU: 27572-7 09-17 378, Age: Not Specified Retailer: Claire’s Part Tested: Cl Br Pb

Front

<LOD <LOD 19

56.

Product: Best Friends Necklace SKU: 45506-3 05-14 248, Age: Not Specified Retailer: Claire’s Part Tested: Cl Br Pb

Friend Section

NA 0 <LOD

57.

Product: Hello Kitty Hair Clip SKU:60155-9 12-14 159, Age: Not Specified Retailer: Claire’s Part Tested: Cl Br Pb

Clip

<LOD <LOD <LOD

58.

Product: Patriotic Necklace SKU: 62356-1 11-04 129, Age: Not Specified Retailer: Claire’s Part Tested: Cl Br Pb

Red Star

NA 0 <LOD

59.

Product: Cupcake Clip Watch SKU: 62356-1 11-04 129, Age: Not Specified Retailer: Claire’s Part Tested: Cl Br Pb Cd

Cupcake

NA 0 <LOD 214

60.

Product: Winged Necklace SKU: 84105-6 05-06 029, Age: Not Specified Retailer: Claire’s Part Tested: Cl Br Pb

Yellow wing

NA 0 <LOD

61.

Product: Candy Corn Halloween Wear SKU: 36336-6 11-05 279, Age: Not Specified Retailer: Claire’s Parts Tested (2): Cl Br Pb

Orange

<LOD <LOD <LOD

Yellow

<LOD <LOD <LOD

62.

Product: Alligator Cell Phone Charm SKU: 2556-1 09-17 147, Age: Not Specified Retailer: Claire’s Part Tested: Cl Br Pb Cd

Alligator

NA 0 282439 714

63.

Product: Clip-on Diamond Earrings SKU: 81890-6 02-25 258, Age: Not Specified Retailer: Claire’s Part Tested: Cl Br Pb

Dangles

NA 0 26932

64.

Product: Claire’s Club LOVE ring/necklace Set SKU: 82977-0 12-02 189, Age: Not Specified Retailer: Claire’s Parts Tested (2): Cl Br Pb

Painted LOVE

<LOD <LOD <LOD Painted Beads

<LOD <LOD <LOD

65.

Product: Claire’s Club Cupcake Necklace SKU: 21057-5 12-02 408, Age: Not Specified Retailer: Claire’s


Pink cupcake

195976 6 <LOD

Chain

NA 0 <LOD

66.

Product: Disney Princess Charm Necklace "E" SKU: 54562-4 12-14 169, Age: Not Specified Retailer: Claire’s Parts Tested (3): Cl Br Pb

Pink Heart

<LOD <LOD <LOD

Pk. Flower

NA 0 <LOD

Chain

NA 0 <LOD

67.

Product: LOVE Pink Cell Phone Accessory SKU: 35108-0 09-17 408, Age: Not Specified Retailer: Claire’s Part Tested: Cl Br Pb

LOVE

NA 0 7637

68.

Product: Heart Ring SKU: 48805-6 25-30 109, Age: Not Specified Retailer: Claire’s Part Tested: Cl Br Pb

Red Heart

NA 0 <LOD

69.

Product: Knight’s Axe SKU: 639277584182, Age: Not Specified Retailer: Dollar Tree


Chrome Handle

<LOD 168 153

Axe Piece

<LOD 133 105

70.

Product: Cuddly Cousin’s Brown Teddy Bear SKU: 639277752369, Age: Not Specified Retailer: Dollar Tree


White Face

<LOD 20 <LOD

Body

<LOD 11 <LOD

71.

Product: Mickey Mouse Clubhouse Slide Puzzle SKU: 639277537096, Age: Not Specified Retailer: Dollar Tree


Square front

<LOD 623 <LOD Lime Green Back

<LOD 667 <LOD

72.

Product: Magic Dough SKU: 639277541390, Age: Not Specified Retailer: Dollar Tree

Parts Tested (2): Cl Br Pb Red Dough

<LOD 20 <LOD

Yellow Top

<LOD <LOD <LOD

73.

Product: 911 Rescue Playset SKU:639277539748, Age: 3+ Retailer: Dollar Tree


Red Whistle

<LOD 51 <LOD

Axe

<LOD <LOD <LOD

74.

Product: H20 Water Blasters Water Shield Blasters SKU: 639277407146, Age: 3+ Retailer: Dollar Tree Parts Tested (2): Cl Br Pb

Green Gun

<LOD <LOD <LOD

Orange Shield

NA 0 <LOD

75.

Product: Turbo Wheels Monster Truck SKU: 639277037015, Age: 3+ Retailer: Dollar Tree Parts Tested (2): Cl Br Pb

Red Body

NA 0 <LOD

Wheels

<LOD 105 188

76.

Product: Joking Around Halloween Teeth SKU:639277752246, Age: 3+ Retailer: Dollar Tree Part Tested: Cl Br Pb

Gold Tooth

<LOD <LOD <LOD

77.

Product: Marvel Hot Rodz Spider Man Car SKU: 639277752031 , Age: 3+ Retailer: Dollar Tree


Top of Car

<LOD 380 1940

78.

Product: Grow Capsules Soft Expanding Dinosaurs SKU: 639277970916, Age: 3+ Retailer: Dollar Tree


yellow capsule <LOD <LOD <LOD

79.

Product: 1st Birthday Plates SKU: 073525863405, Age: Not Specified Retailer: Dollar Tree


Top of Plate

<LOD <LOD <LOD

80.

Product: Collector’s Series Painted Duck SKU: 639277250544, Age: Not Specified Retailer: Dollar Tree


Red Jacket

<LOD <LOD 1545 Yellow Duck Face

<LOD <LOD 2215

81.

Product: Dress Up Doll SKU:639277533043, Age: Not Specified Retailer: Dollar Tree


Head

415272 <LOD <LOD

Body

<LOD 22 <LOD

82.

Product: Wobble Fireman and Dog SKU: 639277538468, Age: 3+ Retailer: Dollar Tree


Fireman'sBody

<LOD 60 <LOD

Dog

<LOD <LOD <LOD

83.

Product: Fun with Bugs! Lady Bug SKU:639277250933, Age:4+ Retailer: Dollar Tree


Red Back

326402 <LOD <LOD

84.

Product: Knight’s Helmet SKU: 639277584236, Age:4+ Retailer: Dollar Tree


Top

<LOD 207 384

85.

Product: Stretchable Jungle Animals, Elephant SKU: 639277392671, Age: 3+ Retailer: Dollar Tree


Body

<LOD <LOD <LOD

86.

Product: Wooden Jumbo Chalkboard SKU: 639277121400, Age: 3+ Retailer: Dollar Tree


Chalk Board <LOD <LOD <LOD

Yellow Design <LOD <LOD <LOD

87.

Product: Flower Girl Jewelry Set SKU: 075656041394, Age: 3+ Retailer: Dollar Tree


Beads

<LOD 18 <LOD

**** Denotes the presence of Phthalates, Please see Attachment B

Page 1 of 19

October 26, 2009Date:STAT Analysis Corporation

Project: Phthalates and Lead TestingClient: Illinois Pirg

Lab Order: 09100323Work Order Sample Summary

Lab Sample ID Client Sample ID Collection DateTag Number Date Received

09100323-001A 2 Munchkin Fire Duck 10/8/2009 10:50:00 AM 10/9/200909100323-002A 3 Big Rex Cloth Book Red D 10/8/2009 10:50:00 AM 10/9/200909100323-003A 4 Knights Helmet 10/8/2009 10/9/200909100323-004A 5 Claire Cellphone Charm 10/8/2009 10/9/200909100323-005A 6 Duck Collector's Series 10/9/200909100323-006A 7 Hair Clip I Love Troy 10/9/200909100323-007A 8 Claire's Tiara 10/9/200909100323-008A 9 Handbag - Little Princess 10/9/200909100323-009A 10 Electronics Holder w/ Fro 10/9/200909100323-010A 11 Walking Bratz Doll (face) 10/9/200909100323-011A 12 Bath Toy wind-up fish 10/9/200909100323-012A 13 Lady Bug 10/9/200909100323-013A 14 Elmo Lunch Box 10/9/200909100323-014A 15 Super Mario Backpack 10/9/200909100323-015A 16 Bob the Builder T-shirt 10/9/2009

Page 2 of 19

Project: Phthalates and Lead Testing

Client Sample ID: 2 Munchkin Fire Duck

Collection Date: 10/8/2009 10:50:00 AMMatrix: Solid

Analyses Result Qualifier Units Date AnalyzedRL

Client: Illinois PirgLab Order: 09100323

Lab ID: 09100323-001A

DF

Print Date: October 26, 2009

Tag Number:

STAT Analysis Corporation2242 West Harrison St., Suite 200, Chicago, IL 60612-3766Tel: (312) 733-0551 Fax: (312) 733-2386 [email protected]

Report Date: October 26, 2009

Accreditation Numbers: IEPA ELAP 100445; ORELAP IL300001; AIHA 101160; NVLAP LabCode 101202-

Phthalates SW8270C (SW3580A) Analyst: HVHPrep Date: 10/19/2009Bis(2-ethoxyethyl)phthalate * 10/21/200949 mg/Kg 1ND

Bis(2-ethylhexyl)phthalate 10/21/200949 mg/Kg 1ND

Bis(2-methoxyethyl)phthalate * 10/21/200949 mg/Kg 1ND

Bis(2-n-butoxyethyl)phthalate * 10/21/200949 mg/Kg 1ND

Bis(4-methyl-2-pentyl)phthalate * 10/21/200949 mg/Kg 1ND

Butyl benzyl phthalate 10/21/200949 mg/Kg 1ND

Di-n-butyl phthalate 10/21/200949 mg/Kg 1ND

Di-n-octyl phthalate 10/21/200949 mg/Kg 1ND

Diethyl phthalate 10/21/200949 mg/Kg 1ND

Dihexyl phthalate * 10/21/200949 mg/Kg 1ND

Diisobutyl phthalate * 10/21/200949 mg/Kg 1ND

Diisodecyl phthalates * 10/21/2009490 mg/Kg 1ND

Diisoheptyl phthalates * 10/21/2009490 mg/Kg 1ND

Diisononyl phthalates * 10/21/2009490 mg/Kg 1ND

Dimethyl phthalate 10/21/200949 mg/Kg 1ND

Dinonyl phthalate * 10/21/200949 mg/Kg 1ND

Dipentyl phthalate * 10/21/200949 mg/Kg 1ND

Qualifiers: J - Analyte detected below quantitation limitsB - Analyte detected in the associated Method Blank

S - Spike Recovery outside accepted recovery limitsR - RPD outside accepted recovery limits

ND - Not Detected at the Reporting Limit

E - Value above quantitation range* - Non-accredited parameter H - Holding time exceededHT - Sample received past holding time

RL - Reporting / Quantitation Limit for the analysis

Page 3 of 19


Client Sample ID: 3 Big Rex Cloth Book Red Dot

Collection Date: 10/8/2009 10:50:00 AMMatrix: Solid



Lab ID: 09100323-002A

DF


Tag Number:




Lead by FLAA SW7420 (SW3050B) Analyst: LBPrep Date: 10/19/2009Lead 10/19/2009230 mg/Kg 11900






Page 4 of 19


Client Sample ID: 4 Knights Helmet

Collection Date: 10/8/2009Matrix: Solid



Lab ID: 09100323-003A

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Page 5 of 19


Client Sample ID: 5 Claire Cellphone Charm

Collection Date: 10/8/2009Matrix: Solid



Lab ID: 09100323-004A

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Tag Number:










Page 6 of 19


Client Sample ID: 6 Duck Collector's Series

Collection Date:Matrix: Solid



Lab ID: 09100323-005A

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Tag Number:










Page 7 of 19


Client Sample ID: 7 Hair Clip I Love Troy




Lab ID: 09100323-006A

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Lead by FLAA SW7420 (SW3050B) Analyst: LBPrep Date: 10/19/2009Lead 10/19/200947 mg/Kg 1ND






Page 8 of 19


Client Sample ID: 8 Claire's Tiara




Lab ID: 09100323-007A

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Tag Number:










Page 9 of 19


Client Sample ID: 9 Handbag - Little Princess




Lab ID: 09100323-008A

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Bis(2-ethylhexyl)phthalate 10/21/200915000 mg/Kg 50054000












Diisononyl phthalates * 10/21/20091500 mg/Kg 52200









Page 10 of 19


Client Sample ID: 10 Electronics Holder w/ Frog




Lab ID: 09100323-009A

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Page 11 of 19


Client Sample ID: 11 Walking Bratz Doll (face)




Lab ID: 09100323-010A

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Tag Number:














Diisobutyl phthalate * 10/21/200947 mg/Kg 1240












Page 12 of 19


Client Sample ID: 12 Bath Toy wind-up fish




Lab ID: 09100323-011A

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Tag Number:


























Page 13 of 19


Client Sample ID: 13 Lady Bug




Lab ID: 09100323-012A

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Tag Number:










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Client Sample ID: 14 Elmo Lunch Box




Lab ID: 09100323-013A

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Tag Number:
















Diisodecyl phthalates * 10/21/200923000 mg/Kg 5072000











Page 15 of 19


Client Sample ID: 15 Super Mario Backpack




Lab ID: 09100323-014A

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Tag Number:


























Page 16 of 19


Client Sample ID: 16 Bob the Builder T-shirt




Lab ID: 09100323-015A

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Tag Number:










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Documents

Chemical Compliance - Amazon Web Services · developing, exposure to toxic chemicals during childhood can have particularly harmful and lasting effects on their health. Examples of