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U. S. Consumer Product Safety Commission Room 502
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to the U.S. Consumer Product Safety Commission on Petition HP 06-1
“Petition Requesting Ban on Lead Toy Jewelry”
Consumers Union (CU), publisher of Consumer Reports magazine, submits the following comments in response to the U.S. Consumer Product Safety Commission’s (CPSC or Commission) Notice, “Petition Requesting Ban on Lead Toy Jewelry (Petition)”.1 The CPSC has published this Notice soliciting comments concerning a petition filed by the Sierra Club requesting that the CPSC ban toy jewelry containing more than 0.06% lead. CU strongly supports the Petition, and urges the CPSC to establish the requested ban — and convert its voluntary guidance on lead in consumer products, issued December 22, 19982, to enforceable regulations.
The well-document effects of lead toxicity are often acute, severe and irreversible. Lead accumulates from multiple sources to generate average body burdens that continue to exceed 10 IJg/dl, the level identified by the CDC as cause for concern. Because not all sources can be easily eliminated and because no safe exposure threshold has been established for lead, it is imperative that we eliminate as many avoidable sources as possible. There is simply no reason for continued use of this chemical in paints or plastics, especially those used in products designed for children. CPSC’s current guidance threshold for lead in consumer products, lead levels that result in no more than 15 IJg of ingested lead per day, is ineffective and contributes nothing toward the federal government’s goal of eliminating childhood lead poisoning by 2010. Instituting a ban and stronger regulations for lead in consumer products is a critical step in achieving this important goal.
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