November 2010

The 25th Annual Survey of Toy Safety

Trouble in Toyland

The 25th Annual Survey of Toy Safety

ConnPIRG Education Fund

November 2010
 Acknowledgements
Written by Elizabeth Hitchcock, Public Health Advocate with the U.S. PIRG Education Fund,
Brian Imus, Executive Director of Illinois PIRG and Celeste Meiffren Field Director of Illinois
PIRG.

ConnPIRG Education Fund issues this report under a Creative Commons “some
rights reserved” license. You are free to copy, distribute or display the work for non-
commercial purposes, with attribution. For more information about this Creative
Commons license, visit http://creativecommons.org/licenses/by-nc-nd/2.5/.

Cover design by: Erica Rosset, Public Interest GRFX

Cover photos by: Jack Qi, under license from Shutterstock.com, Brian Walker

The authors would like to thank Jeff Gearhart, Research Director for HealthyStuff.org, Ed
Mierzwinski and Brian Walker of U.S. PIRG for their help with the research and production of
this report. Special thanks to the Colston Warne program of Consumers Union for supporting
our work on consumer protection issues. Additional thanks to the Beldon Fund and individual
contributors for their generous support of our work on environmental health and toxics issues.

ConnPIRG Education Fund, a member of the state Public Interest Research Groups (PIRGs),
takes on powerful interests on behalf of the American public, working to win concrete results for
our health and our well-being. The state PIRGs are a nationwide network of nonprofit,
nonpartisan, state-based public interest advocacy organizations. The state PIRGs’ mission is to
deliver persistent, result-oriented activism that protects the environment, encourages a fair
marketplace for consumers, and fosters responsive, democratic government.

For a copy of this report, visit our website or send a check for $30 made payable to CoPIRG
Foundation at the following address:

ConnPIRG Education Fund

198 Park Rd, 2nd Fl.
West Hartford, CT 06119
860-233-7554
www.connpirg.org

PIRG’s Trouble in Toyland Page 2

 Table of Contents
Acknowledgements ......................................................................................................... 2
Table of Contents ............................................................................................................ 3
Executive Summary ........................................................................................................ 4
Introduction ..................................................................................................................... 8
Lead in Toys and Children’s Products ............................................................................. 9
Findings: Lead ........................................................................................................... 10
Recommendations: Lead ........................................................................................... 10
Toxic Phthalates in Children’s Products ........................................................................ 10
Findings: Phthalates .................................................................................................. 13
Recommendations: Phthalates - ................................................................................ 13
Other Toxic Hazards ..................................................................................................... 13
Findings: Other Toxics ............................................................................................... 14
Recommendations: Other Toxics............................................................................... 14
Choking Hazards ........................................................................................................... 14
Findings: Choking Hazards ........................................................................................ 17
Strangulation Hazards ................................................................................................... 19
Drawstring Clothing ................................................................................................... 19
Methodology .................................................................................................................. 19
Attachment A. 2010 Summary of Toy Hazards and Examples of Potentially Dangerous
Toys and Children’s Product ......................................................................................... 21
Attachment B. Toy-Related Deaths, 1990-2009 ............................................................ 26
End Notes ..................................................................................................................... 27

PIRG’s Trouble in Toyland Page 3

 Executive Summary
The 2010 Trouble in Toyland report is the American children today grow up
25th annual Public Interest Research Group surrounded by synthetic chemicals. Their
(PIRG) survey of toy safety. In this report, food containers are made with plastic. Their
U.S. PIRG provides safety guidelines for homes and yards are treated with pesticides.
consumers when purchasing toys for small Their families use cosmetics and personal-
children and provides examples of toys care products that contain hundreds of
currently on store shelves that may pose manufactured additives. The furniture and
potential safety hazards. electronics in their homes contain flame
retardant chemicals.
Over the past twenty five years, the PIRG
report has identified hazards in toys and As their minds and bodies grow and develop,
children‘s products that could cause an acute children are particularly vulnerable to
injury from small parts that pose a choking chemicals that could affect proper
hazard, to strangulation hazards from cords development. Because children have a
on pull toys, to laceration hazards from edges natural tendency to touch and mouth objects
that are too sharp. Our report has led to at as a way of exploring the world around them,
least 150 recalls and other regulatory actions harmful chemicals can leach out of these
over the years, and has helped us to advocate products, enter their bodies and cause health
for stronger federal laws to protect children problems. Chemicals have become such a
from unsafe products. close part of our lives that scientists can find
more than 100 industrial chemicals and
While most product safety regulations pollutants in the bodies of every mother and
address mechanical hazards, the 2008 child.2
Consumer Product Safety Improvement Act
began to address certain toxic chemicals in There are now more than 83,000 industrial
toys and children‘s products that represent chemicals on the market in the United
chronic hazards, such as lead and phthalates. States.3 But very little is known about most of
the chemicals in commerce. The health
In April 2010, the President‘s Cancer Panel – effects of almost half of the major industrial
a group of three distinguished experts chemicals have not been studied at all.4
appointed by President Bush to evaluate the
nation‘s cancer program – raised the alarm In 2008, Congress responded to an
about our ubiquitous exposure to toxic unprecedented wave of recalls of toys and
chemicals. ―The American people – even other children‘s products by passing the first
before they are born – are bombarded major overhaul of the Consumer Product
continually,‖ the panel wrote.1 In effect, our Safety Commission since it was established
lives have become a giant, uncontrolled during the Nixon Administration. By
experiment on the relationship between toxic passing the landmark Consumer Product
chemicals and our health. Safety Improvement Act (CPSIA) in August
2008,5 Congress not only expanded the
agency‘s budget, it also gave the CPSC more

PIRG’s Trouble in Toyland Page 4

tools to hold corporate wrongdoers Lead has no business in children‘s products,
accountable and speed recalls, moved toward whether in paint or coatings or in metal toys,
limiting toxic lead and phthalates in certain jewelry or other children‘s products (vinyl
toys and children‘s products, and greatly bibs, lunchboxes, etc). The Consumer
improved import surveillance. Product Safety Improvement Act bans lead
except at trace amounts in paint or coatings
The Consumer Product Safety Improvement (90 ppm limit as of August 2009), and in any
Act, together with stronger enforcement toys, jewelry or other products for use by
from the CPSC, has made good steps in the children under 12 years (300 ppm limit as of
right direction toward reducing mechanical August 2009, and 100ppm by August 2011).
toy hazards like choking, and chemical
hazards from lead and phthalates in certain  According to our analysis of CPSC recalls
products. However, there are tens of over the past twelve months, CPSC has
thousands of toxic chemicals that are still not recalled more than half a million toys or
regulated for the many uses in our children‘s other children‘s products for violations of the
lives. lead paint standard. The CPSC has recalled
an additional 392,000 toys and other
In researching the report, we visited children‘s products for violation of the 300
numerous national chain toy stores and other ppm lead standard.
retailers in September and October 2010 to
identify potentially dangerous toys. We  Some children‘s toys and jewelry may
analyzed CPSC notices of recalls and other contain unacceptable levels of lead. We
regulatory actions to identify trends in toy found toys and other children‘s products that
safety. This year, we focused our may exceed the CPSIA‘s lead paint standards.
investigation on hazards from toys and other
children‘s products that contain the toxic PHTHALATES IN CHILDREN’S PRODUCTS-
chemicals lead and phthalates, and other
metals restricted by the CPSIA. Because Numerous scientists have documented the
choking continues to be the leading cause of potential health effects of exposure to
death related to toys, we have also identified phthalates in the womb or at crucial stages of
toys that may pose a choking hazard to development. U.S. EPA studies show that the
children. cumulative impact of different phthalates
leads to an exponential increase in associated
Our key findings include: Findings: harm. According to data from the U.S.
Centers for Disease Control and Prevention
- LEAD IN TOYS - (CDC), levels of phthalates found in humans
are higher than levels shown to cause adverse
Exposure to lead can affect almost every health effects. The data also show phthalate
organ and system in the human body, levels are highest in children.
especially the central nervous system. Lead is
especially toxic to the brains of young Section 108 of the CPSIA bans toys
children. containing three classes of phthalates for all
children, and bans toys containing three
more phthalates if they can be put in younger

PIRG’s Trouble in Toyland Page 5

children‘s mouths. This provision went into three. CPSC also should consider special
effect in February 2009. labeling for toys shaped like corks or toy
nails, which pose special suffocation risks
 This year, we found two products that because of their shape.
laboratory testing showed to contain levels of
phthalates that may exceed limits allowed by This year, we were alerted by parents who
the CPSIA. had to administer the Heimlich maneuver on
their one year old child to prevent him from
- CHOKING HAZARDS - choking on one such small part, a small peg
in a train set labeled for children over one
Choking on small parts, small balls and year old that was about an eighth of an inch
balloons remains a leading cause of toy- longer than the small part test.
related deaths and injuries. Between 1990
and 2009, at least 198 children died after
choking or asphyxiating on a toy or toy part; - RECOMMENDATIONS -
two children died in 2009 alone.
FOR POLICY MAKERS
The law bans small parts in toys for children
under three and requires an explicit,  Congress must ensure that the CPSC‘s
prominent warning label on toys with small increased budget authorizations for the next
parts for children between the ages of three five fiscal years are fully funded in
and six. In addition, balls with a diameter appropriations, and continue vigorous
smaller than 1.75 inches are banned for oversight of implementation and
children under three years old.6 enforcement of the new law.

Although most toys on store shelves are safe,  Manufacturers should be required to
there are still some toys that may pose provide all hazard and health-impact
choking hazards. Specifically: information to the state and federal
government so agencies can begin to assess
 Our analysis of recalls and other actions the thousands of chemicals currently on the
taken by the CPSC7 from October 1, 2009- market for which little or inadequate data are
October 30, 2010 revealed that choking available.
hazards were the leading cause of such
actions. In the past year, 5.8 million toys and  The federal government must act based on
other children‘s products have been recalled the overwhelming weight of evidence
in the U.S and Canada due to choking showing that some chemicals might harm
hazards. human health, and phase out dangerous
chemicals.
 Some toys may pose a choking or
suffocation hazard even if they meet the letter  Manufacturers should be required to
of the law. We continue to find toys with label products with the names of these
small parts that just barely met the CPSC chemicals in order to allow parents to choose
standard. We recommend making the test for less toxic products.
small parts more protective of children under

PIRG’s Trouble in Toyland Page 6

FOR THE CPSC must make sure that it provides the
information consumers need to make
 CPSC should review and where necessary, informed choices in the marketplace.
expand its definition of a ―small part‖ or
―small toy‖ to include parts and toys that are
larger than the current standard but have FOR CONSUMERS
been shown to pose a choking hazard to
children. Be vigilant this holiday season, and
remember:
 CPSC should continue its work to
 The CPSC does not test all toys, and not all
implement and enforce the Consumer
toys on store shelves meet CPSC standards.
Product Safety Improvement Act‘s
provisions.
 There is no comprehensive list of
 CPSC should vigorously enforce the CPSIA potentially hazardous toys. Examine toys
bans on toxic chemicals in all toys and carefully for potential dangers before you
products for children. make a purchase. Shop with U.S. PIRG‘s
Toy Safety tips available at www.
 CPSC must continue to implement all toysafety.mobi
rules required under the new law and must
ensure that new third-party testing programs  Report unsafe toys or toy-related injuries to
meet the new law‘s standards. As the CPSC the CPSC at www.cpsc.gov.
implements the CPSIA- mandated publicly-
accessible hazards database requirement, it

PIRG’s Trouble in Toyland Page 7

 Introduction

T oys should entertain and educate children, but poorly designed and constructed toys can cause
injury and even death. According to data from the Consumer Product Safety Commission
(CPSC), at least 12 children, none older than 15 years old, died in 2009 from toy-related injuries.
Two of the children died from choking or asphyxiating on a toy or toy part. More than 250,000
children were treated in emergency rooms for injuries related to toys in 2009.8

In August 2008, The Consumer Product Safety Improvement Act of 2008 was signed into law.
The CPSIA was the first major overhaul of the Consumer Product Safety Commission since the
early 1970‘s. In addition to giving the agency much needed increases in its budget and authority,
the new law established tough new testing standards for toys and other children‘s products, and
banned toxic lead and phthalates in children‘s products.

U.S. PIRG and other organizations had long sought to strengthen the CPSC through rulemaking
petitions, lawsuits and Congressional efforts. Yet, except for the 1994 passage of the Child Safety
Protection Act, our efforts had largely been in vain.

Over the past two years, provisions of the Consumer Product Safety Improvement Act have begun
to take effect. The law‘s restrictions on the toxic chemicals lead and phthalates began to take effect
in February 2009. Similarly, the new third party testing and certification regime established by the
CPSIA took effect in September 2009 for products manufactured after that date.

While the CPSIA and stronger enforcement by the CPSC have taken major steps forward in
limiting toy hazards, there is much more to be done. The CPSIA only regulates fourteen
chemicals in certain toys and other children‘s products. There are more than 80,000 industrial
chemicals on the market today, most with little or no testing for their effects on human health.

This report is a progress report on the implementation of the new law and an examination of the
marketplace for common hazards. Our researchers went to national chain discount stores and
larger stores to identify potential hazards. Our research focused on hazards from toxic chemicals
including lead and phthalates, as well as choking. We readily found examples on store shelves.

PIRG’s Trouble in Toyland Page 8

 Lead in Toys and Children’s Products
Health officials and children‘s health lose IQ points at levels of lead in blood below
advocates have long sought to reduce the ―official‖ level of concern as defined by
children‘s daily exposure to lead, which can the Centers for Disease Control.11
stunt mental and physical development.
Lead-based paint is a common and long-term An interim CPSC lead policy did not prevent
concern reiterated in recent years by the jewelry with dangerous levels of lead from
massive recalls of popular toys including falling through the cracks. In March 2006,
Curious George, Thomas the Tank Engine, CPSC recalled 300,000 Reebok heart-shaped
Dora the Explorer, other Sesame Street charm bracelets. A four year-old child from
characters, and SpongeBob Squarepants, to Minneapolis died in February 2007 of acute
name some of the iconic toys subject to recall lead poisoning after he swallowed a piece
in 2007 and 2008. from one of these bracelets.12 During
autopsy, doctors removed the Reebok charm
The Dangers of Lead from the boy‘s stomach and learned that it
Exposure to lead can affect almost every contained 99% lead by weight.13
organ and system in the human body,
especially the central nervous system. Lead is In 2007, CPSC issued virtually innumerable
especially toxic to the brains of young recalls for excessive lead paint, including, for
children. A child exposed to a single high example, 1.5 million Thomas the Tank
dose of lead—such as by swallowing a piece of Engine toys and parts,14 967,000 Sesame
metal jewelry containing lead—can suffer Street, Dora the Explorer, and other
permanent neurological and behavioral children's toys,15 and 250,000 SpongeBob
damage, blood poisoning, and life- SquarePants toys,16 among others. Recalls for
threatening encephalopathy. Exposure to lead and lead paint continued in 2008. In
low doses of lead can cause IQ deficits, 2008, the CPSC announced at least 64
attention deficit hyperactivity disorder, and excessive lead recalls totaling over 6.3 million
deficits in vocabulary, fine motor skills, units. Forty-seven recalls (47) were lead paint
reaction time, and hand-eye coordination.9 violations; 17 recalls were children‘s jewelry
or trinkets. Typical recalls included 67,000
Children are more vulnerable to lead Claire‘s necklaces, 57,000 Benjamin
exposure than adults, since young children pendants, and 18.500 RR Donnelley
often put their hands and other objects in miscellaneous learning toys. 17
their mouths. Their growing bodies absorb
more lead and children‘s developing brains Federal Standards for Lead
and nervous systems are more sensitive to the Under the Consumer Product Safety Act,
damaging effects of lead. regulations banned paint containing lead in a
concentration of greater than 600 parts per
Scientists have not identified a ―safe‖ level of million (0.06% by weight).18 Under the
lead exposure for children.10 Research Federal Hazardous Substances Act, CPSC
published in the New England Journal of could deem other products, such as articles
Medicine in 2003 showed that children can of metal jewelry, as ―hazardous substances‖ if

PIRG’s Trouble in Toyland Page 9

they contain toxic quantities of lead
sufficient to cause substantial illness as a This final limit may be altered by the CPSC
result of reasonably foreseeable handling or if it is determined to be technologically
use, including ingestion.19 If such jewelry is infeasible.
intended for use by children and the toxic
lead content is accessible by a child, it then Findings: Lead
constitutes a banned hazardous substance
under the law.20
 U.S. PIRG‘s analysis of recalls and other
The Consumer Product Safety Improvement regulatory actions between October 2009 and
Act of 2008 bans lead in toys and children‘s October 2010 showed that nearly 1.3 million
products on a phase-out schedule outlined toys and other children‘s products have been
below. After the effective dates, these subject to such action due to potential
products cannot be manufactured, imported violation of the CPSIA lead paint standard,
for sale or sold. with another 102,700 units recalled because
 February 2009: Toys and children‘s of violation of the lead standard.
products containing lead in excess of
600 parts per million (ppm) became  Some children‘s toys and jewelry may
banned hazardous substances. contain high levels of lead. In one case, we
 August 2009: The maximum found a stuffed animal that contained
allowable amount of lead in paint 97ppm lead in the surface coating.
and surface coatings decreased from
600 ppm to 90 ppm. Recommendations: Lead
 August 2009: Toys and children‘s
products containing lead in excess of Lead-tainted children‘s products should
300 ppm became banned hazardous never end up on store shelves or in the
substances. home. The CPSC should continue to
 August 2011: Toys and children‘s vigorously enforce the CPSIA‘s bans on lead
products containing lead in excess of and lead paint in any toys, jewelry or other
100 parts per million (ppm) will products for children under 12 years.
become banned hazardous
substances.

Toxic Phthalates in Children’s Products

Effective February 10, 2009, Section 108 of (BBP), diisodecyl phthalate (DIDP),
the Consumer Product Safety Improvement diisononyl phthalate (DINP), di-n-octyl
Act banned six phthalates in children‘s phthalate (DNOP), and many other distinct
products. types. The polyvinyl chloride (PVC) plastic
industry uses large amounts of phthalates as
Phthalates are a family of chemicals, additives to improve the flexibility of its
including diethyl phthalate (DEP), products, including home siding, flooring,
diethylhexyl phthalate (DEHP), dibutyl furniture, food packaging, toys, clothing, car
phthalate (DBP), butyl benzyl phthalate interiors, and medical equipment, including

PIRG’s Trouble in Toyland Page 10

IV bags. In addition, other manufacturers National Toxicology Program released its
use phthalates in personal care products such review of one type of phthalate, diethylhexyl
as soap, shampoo, deodorant, hand lotion, phthalate (DEHP). The panel confirmed
nail polish, cosmetics, and perfume, as well that DEHP poses a risk to reproductive and
as industrial products like solvents, developmental health.25
lubricants, glue, paint, sealants, insecticides,
detergent, and ink.21 • Premature Delivery. A study published in
November 2003 suggests a link between
Phthalates are pervasive in the environment exposure to phthalates and pre-term birth.
and in human bodies. In 2000, the Centers The scientists found phthalates and their
for Disease Control (CDC) found high levels breakdown products in the blood of
of phthalates and their transformation newborn infants, with higher levels leading
products (known as metabolites) in every one to a higher incidence of premature delivery.26
of 289 adult Americans tested, including
women of childbearing age.22 A larger CDC • Early Onset Puberty. One study of Puerto
study in 2003 again found high levels of Rican girls suggests that phthalates may be
phthalates in almost every person tested.23 playing a role in trends toward earlier sexual
maturity.27 Scientists found that levels of
- PHTHALATE EXPOSURE LINKED TO DEHP were seven times higher in girls with
HEALTH EFFECTS - premature breast development than levels in
normal girls.
U.S. EPA studies show the cumulative
impact of different phthalates leads to an • Lower Sperm Counts. In 2003, Drs.
exponential increase in associated harm. Susan Duty and Russ Hauser of the Harvard
According to data from the U.S. Centers for School of Public Health published one of the
Disease Control and Prevention (CDC), first studies linking phthalate exposure with
levels of phthalates found in humans are harm to human reproductive health.28 Men
higher than levels shown to cause adverse who had monobutyl or monobenzyl
health effects. The data also show phthalate phthalate in their urine tended to have lower
levels are highest in children. sperm counts, with the highest
concentrations leading to the lowest sperm
Numerous scientists have documented the counts.
potential health effects of exposure to
phthalates in the womb or at crucial stages of - U.S. FAILS TO TAKE ACTION ON
development, including (but not limited to): PHTHALATES -

• Reproductive Defects. Scientists have In 1998, the state PIRGs and several other
demonstrated links between exposure to environmental and consumer groups
phthalates in the womb with abnormal petitioned the CPSC, asking the agency to
genital development in baby boys and ban polyvinyl chloride (PVC) plastic in all
disruption in sexual development.24 In toys intended for children under the age of
October 2005, an independent panel of five because of the potential health hazards
scientists convened by the National Institute posed by diisononyl phthalates (DINP).
of Environmental Health Sciences and the While noting its position that ―few if any

PIRG’s Trouble in Toyland Page 11

children are at risk from the chemical,‖29 in intended for children under three years of
December 1998 CPSC asked the toy and age and that can be put in the mouth.34
baby products industry to remove DINP from
soft rattles and teethers. About 90 percent of In 2007, following a campaign by
manufacturers indicated at that time that Environment California, the new home of
they had or would remove DINP from soft CALPIRG‘s environmental work, California
rattles and teethers by early 1999. CPSC staff enacted legislation banning phthalates in
also asked the industry to find a substitute children‘s products.35 In 2008, bills were
for phthalates in other products intended for introduced in eight state legislatures that
children under three years old that are likely included bans on phthalates in children‘s
to be mouthed or chewed.30 products; Washington State and Vermont
both passed legislation in 2008.
CPSC also convened a Chronic Hazard
Advisory Panel to examine the existing - CONGRESS TAKES ACTION ON
scientific data concerning the potential risks PHTHALATES -
of phthalates to humans. In June 2001, the
panel concluded that while the majority of In March 2008, Senator Dianne Feinstein
children would not be adversely affected by (CA) successfully offered an amendment to
diisononyl phthalate, ―there may be a DINP the Senate‘s Consumer Product Safety
risk for any young children who routinely Improvement Act that banned phthalates in
mouth DINP-plasticized toys for seventy-five children‘s products.
minutes per day or more.‖31
After a lengthy House/Senate conference,
Unfortunately, in February 2003, CPSC the CPSIA was signed into law with a ban on
denied the state PIRGs‘ petition to ban PVC childcare products and children‘s toys
plastic in toys for young children.32 containing the phthalates DEHP, DBP, and
BBP in concentrations higher than 0.1% per
- EUROPEAN UNION AND THE phthalate (1,000 ppm), and on childcare
STATES LEAD THE WAY - products and children‘s toys that can be put
in a child's mouth containing the phthalates
Other countries have taken action, however, DINP, DnOP, and DIDP in concentrations
to protect children‘s health. In September higher than 0.1% per phthalate (1,000 ppm).
2004, the European Union (EU) agreed to
impose wide restrictions on the use of six The ban on DINP, DnOP and DIDP is in
phthalates in toys and childcare products.33 effect pending a Chronic Hazard Advisory
The EU banned three phthalates classified as Panel‘s report on the health effects of the
reproductive toxicants – diethylhexyl chemicals. The CHAP commenced its
phthalate (DEHP), butyl benzyl phthalate consideration of the provisional ban in 2010,
(BBP), and dibutyl phthalate (DBP) – in all and has eighteen months to report its
toys and childcare articles. The EU banned findings and make a recommendation on
three other phthalates – DINP, diisodecyl whether to make the ban permanent. Both
phthalate (DIDP) and di-n-octyl phthalate bans were effective February 2009. The
(DNOP) – in toys and childcare articles interim ban will be rescinded only if the
CHAP recommends doing so.

PIRG’s Trouble in Toyland Page 12

Findings: Phthalates Recommendations:
This year, we found two children‘s products Phthalates -
that contain phthalates. One baby doll
contained 53,000 ppm DIDP and 300,000 CPSC should vigorously enforce the CPSIA‘s
ppm DIIP in the baby‘s face. Another ban on the use of phthalates in all toys and
cartoon character backpack contained children‘s products, and should make the
measured 150,000 ppm Bis(2-ethylhexyl) interim ban on DINP, DnOP and DIDP
phthalate on the mouth. permanent.

Other Toxic Hazards

CPSIA LIMITS OTHER TOXIC
CHEMICALS IN SURFACE COATING Cadmium is classified as a known human
OF CHILDREN’S PRODUCTS AND carcinogen, associated with lung and prostate
TOYS cancer. Depending on the level of exposure,
cadmium exposure is associated in animal
The Consumer Product Safety Improvement studies with developmental effects, including
Act made most ASTM F963-07 standards possible decreases in birth weight, delayed
mandatory. Included among them is a ban sensory-motor development, hormonal
on antimony, arsenic, barium, cadmium, effects, and altered behavior. Cadmium can
chromium, lead, mercury, or selenium in the cause adverse effects on the kidney, lung and
surface coating or paint of any children‘s intestines.
product or toy in excess of the amounts listed
in the table below: Exposure to cadmium can result in bone loss
and increased blood pressure. Acute toxicity
Maximum Soluble Migrated Element in from ingestion of high levels of cadmium can
ppm (mg/kg) Toy Material result in abdominal pain, nausea, vomiting
and death.
Antimony, (Sb) 60
Arsenic, (As) 25 In January, 2010, in response to research
Barium, (Ba) 1000 finding high levels of cadmium in children‘s
Cadmium, (Cd) 75 jewelry, the CPSC issued a warning to
Chromium, (Cr) 60 parents advising them to keep such jewelry
Lead, (Pb) 90 away from children. Some large retailers
Mercury, (Hg) 60 reacted to the announcement and removed
Selenium, (Se) 500 the items from their inventories. In 2010,
the CPSC has recalled more than 12 million
toys and other children‘s products because of
Cadmium (Cd) is a heavy metal used as a
excess levels of cadmium.
stabilizer in PVC and in coatings and
pigments in plastic and paint.

PIRG’s Trouble in Toyland Page 13

In August 2010, the CPSC requested Higher levels of antimony have been shown
comments in response to a petition filed in to cause fertility problems and lung cancer in
May 2010 by Empire State Consumer animals. The ASTM F-963 standard for
Project, Sierra Club, Center antimony in the surface coating of a
for Environmental Health, and children‘s product is 60 ppm.
Rochesterians Against the Misuse of
Pesticides. On October 19, 2010, CPSC staff Findings: Other Toxics
sent letters to the ASTM F15.24
Our laboratory findings showed 120 ppm
Subcommittee on Children‘s Jewelry and the
antimony in the red handle of a baby book,
ASTM F15.22 Subcommittee on Toy Safety
and 1200 ppm antimony in the surface
to encourage expedited completion of safety
coating of a pair of toy handcuffs.
standards that address the potential hazard of
cadmium in children‘s jewelry and some toys
to assist in the standards development Recommendations: Other
process (including possible revisions to the Toxics
ASTM F-963 toy safety standard, which was
made a mandatory safety standard pursuant Given the clear adverse health consequences
to Section 106 of the Consumer Product of cadmium exposure, the CPSC should
Safety Improvement Act of 2008). issue clear, meaningful restrictions on
cadmium content for all children‘s products,
Antimony trioxide is classified as a in both the base of the product as well as in
carcinogen in the state of California and has the surface coating, as well as guidance to
been listed as a possible human carcinogen industry on compliance.
by the International Agency for Research on
Cancer and the European Union. In long-
term studies, animals that breathed very low CPSC should vigorously enforce limits on
levels of antimony had eye irritation, hair other toxic chemicals restricted by the
loss, lung damage, and heart problems. CPSIA.

Choking Hazards
the size of a fully expanded throat of a child
CPSC BANS SMALL PARTS FOR under three years old. If the toy or any part
CHILDREN UNDER AGE 3 of the toy – including any parts that separate
during ―use and abuse‖ testing – fits inside
In 1979, CPSC banned the sale of toys the test tube, the product is a choking hazard
containing small parts if they are intended and is banned for children under the age of
for use by children under the age of three, three. In 1994, the Child Safety Protection
regardless of age labeling. A small part is Act established a more protective standard
defined as anything that fits inside a choke for small balls in children‘s toys.
test cylinder, which has an interior diameter
of 1.25 inches and a slanted bottom with a CPSC uses three factors to determine
depth ranging from 1 to 2.25 inches (Figure whether a toy is intended for children under
A). This cylinder is designed to approximate three years old, including the manufacturer‘s

PIRG’s Trouble in Toyland Page 14

stated intent, such as the age labeling, the balloons, from any sort of warnings or
advertising and marketing of the product, regulations. It also became apparent that
and whether the toy is ―commonly small balls that passed the small parts test
recognized‖ as being intended for a child could still pose a choking hazard, as they
under three years old.36 Some items could completely block a child‘s airway.
commonly recognized for children under
three include (but are not limited to) squeeze
toys; teethers; toys or articles that are affixed
to a crib, stroller, playpen, or baby carriage;
pull and push toys; bathtub, wading pool and
sand toys; and stuffed animals.37

Some toys and products are exempt from this

small parts regulation because they cannot be
manufactured in a way that would prevent
them from breaking into small parts when
subjected to use and abuse testing. These
items include (but are not limited to)
balloons, articles made of paper, writing
materials such as crayons and chalk,
modeling clay, and finger paints, watercolors
and other paint sets. Children‘s clothing and
accessories such as shoe lace holders, diaper
Figure A. Choke Test Cylinder
pins, and barrettes also are exempt because
they need to be small to perform their Throughout the 1980s, consumer groups
intended purpose.38 lobbied Congress and the CPSC to increase
the size of the small parts test and to require
Pieces of paper, fabric, yarn, fuzz, elastic, and an explicit choke hazard warning on toys
string that fit in the choke test cylinder also intended for older children, if the toys
are exempt, as they are unlikely to pose a contained banned small parts. A 1992
choking hazard.39 campaign led by ConnPIRG and other child
safety advocates resulted in a tough choke
LABELS FOR TOYS WITH SMALL hazard warning label law that took effect in
PARTS FOR CHILDREN OVER AGE 3 Connecticut on January 1, 1993. The
Connecticut law laid the foundation for a
CPSC‘s 1979 regulations, however, were not federal standard, and in 1994, Congress
entirely effective; some manufacturers passed the Child Safety Protection Act of
attempted to circumvent the small parts ban 1994 (CSPA). President Clinton signed the
by labeling products intended for children CSPA into law on June 16, 1994.
under three for ―ages three and up.‖ This
allowed parents to misinterpret these labels
as recommendations, rather than warnings,
and to purchase such toys anyway for
children under three. The 1979 regulation
also exempted a significant choking hazard,

PIRG’s Trouble in Toyland Page 15

 - SMALL BALLS -
CHARACTERISTICS OF TOYS FOR
CHILDREN UNDER THREE The 1994 CSPA also strengthened the test
for small balls from 1.25 inches in diameter
The following are some general characteristics to 1.75 inches. Balls with a diameter smaller
that make toys appealing to children under three. than 1.75 inches are banned for children
under three years old.41 The law defines a
Size and Weight: Small and lightweight, easy to ball as ―any spherical, ovoid, or ellipsoidal
handle. object that is designed or intended to be
thrown, hit, kicked, rolled, dropped, or
Theme: Represents a common object found bounced.‖42 According to this definition,
around the home, farm, or neighborhood. toys that are spherical or have spherical parts
but are not intended for use as a ball do not
Degree of Realism: Silly or cute, some realistic
have to meet this test.
details.

Colors: Bright, contrasting colors covering large Round objects are more likely to choke
areas of the toy. children because they can completely block a
child‘s airway. Any small ball intended for
Noisemaking: Not loud or frightening. children over the age of three must include
the following warning:43
Action and Movement: May be silly, should be
easy for child to cause movement.

Type and level of skill: Lets child begin to learn

skills or practice skills such as walking, stacking,
and sorting; should be slightly beyond child‘s Any toy or game containing a small ball and
capabilities to maintain interest.
intended for children between ages three and
eight must include the following warning:
Source: Consumer Product Safety Commission

- SMALL PARTS -

The 1994 CSPA requires that toys with small

parts intended for children between the ages - BALLOONS -
of three and six years old include the
following explicit choke hazard warning:40 Balloons pose a grave choking hazard to
children, causing more choking deaths than
any other children‘s product. Almost half
(40 percent) of the choking fatalities reported
to the CPSC between 1990 and 2009
involved balloons. The 1994 law requires the
following choke hazard warning on all
balloons:44

PIRG’s Trouble in Toyland Page 16

 - MOST TOYS ARE SAFE AND
PROPERLY LABELED -
Overall, manufacturers and toy retailers are
doing a good job of marketing and labeling
small balls, balloons, small toys and toys with
small parts, ensuring either that the bin in
which the toy is sold or the toy packaging is
- MARBLES - labeled with the required choke hazard
warning.
Any marble intended for children three years
of age or older must bear the following
- SOME TOYS MAY NOT MEET CSPC
cautionary statement on its packaging:45
REQUIREMENTS -

The law bans small parts in toys for children

under three and requires a warning label on
toys with small parts for children between the
ages of three and six. PIRG researchers,
Any toy or game containing a marble and
however, still find toys for children under
intended for children between ages three and
three with small parts and toys with small
eight must include the following warning:
parts for children under six without the
statutory choke hazard warning.

- NEAR-SMALL PARTS MAY POSE

CHOKING HAZARDS -
- BINS AND VENDING MACHINES - In September 2006,
CPSC and Playskool
Finally, the CSPA requires choke hazard
voluntarily recalled about
labels on bins and vending machines. If toys
255,000 Team Talkin‘
or small balls requiring labels are sold in
Tool Bench toys following
vending machines or unpackaged in bins,
the deaths of two young
these vending machines and bins must
children. A 19-month-old West Virginia boy
display the statutory warnings.46
and a 2-year-old Texas boy suffocated when
oversized, plastic toy nails sold with the tool
bench toys became forcefully lodged in their
Findings: Choking Hazards throats.47

PIRG researchers surveying toy stores in the The toy was labeled for children three and
fall of 2010 identified the following trends: older but did not include a choke hazard
warning; the toy nails in question, measuring
three inches in height, passed the small parts
test. This tragic incident is a reminder that
some toys may pose a choking or suffocation
hazard even if they pass the small parts test.

PIRG’s Trouble in Toyland Page 17

In August 2009, the CPSC announced the children under eight. For example, we found
recall of a variety of Little Tikes Children's balloons marketed specifically for toddlers
Workshop toys totaling over 1.6 million (e.g., ―Baby‘s First Birthday‖) and balloons
units following an incident in which a little depicting characters appealing to younger
boy was hospitalized after choking on an children (e.g., ―Curious George‖ or ―Bob the
over-sized plastic nail but made a full Builder‖). Manufacturers and retailers should
recovery.48 stop producing and selling balloons aimed at
children under eight years old.
In preparing this year‘s report, we were
notified by a Washington DC parent of a toy - MANY TOYS ARE OVER-LABELED -
with a peg that a one-year old choked on.
The toy – ―Baby‘s First Train‖ was labeled for Some manufacturers are over-labeling their
ages 1 and up. The part in question extends toys, placing choke hazard warnings on toys
about 1/8 inch outside the choke tube. without small parts or small balls. This over-
labeling dilutes the weight of the warning. In
In particular, toys shaped like corks or with the words of Celestine T. Kiss, an
spherical, hemispherical, or circular flared engineering psychologist with the CPSC,
ends and attached to a shaft, like the toy nails speaking to a group of toy manufacturers:
that caused the two suffocation deaths, could
pose particular hazards, even if they pass the “It is…important that products not be over labeled.
small parts test. To ―address a potential By that we mean, toys that do not need to have a
impaction hazard,‖ the Standard Consumer label shouldn’t have a label. I know that may
Safety Specification for Toy Safety lays out sound logical, but we see toys coming in that have
requirements for toys with spherical ends the small parts label on it, when there aren’t any
that are intended for children under 18 small parts. This creates a problem for the
months.49 Under these specifications, toys of consumer, because then they don’t know when to
this design weighing less than 1.1 pounds, believe the label or not. Some companies think
and intended for children up to 18 months they are protecting themselves from lawsuits by just
of age, should not be capable of entering and slapping the label on all of their toys, but they
penetrating past the full depth of the cavity really are not helping the consumer.”50
of the supplemental test fixture, also used for
some rattles and teethers. A similar standard - RECOMMENDATIONS -
for toys intended for children over 18
months does not exist. We call on CPSC to:

• Enlarge the small parts test tube to be more

- BALLOONS ARE MARKETED TO protective of children under three.
YOUNG CHILDREN -
• Consider extending the standard for toys
The 1994 CSPA requires that all balloons with spherical ends to apply to toys intended
include a choke hazard warning alerting for children under six years old instead of
parents to the dangers of balloons and under 18 months. At minimum, consider
broken balloons for children under eight. special labeling for toys shaped like the toy
Some balloons, however, are marketed for nails that caused two children to suffocate.

PIRG’s Trouble in Toyland Page 18

• Change the small-ball rule to include small effectiveness of labels on products that
round or semi-round objects, not just ―balls‖ genuinely pose a choking hazard.
in the strictest definition.

• Discourage manufacturers from over-

labeling their products with choke hazard
warnings, as this could reduce the

Strangulation Hazards
Drawstring Clothing In May 2006, CPSC sent a letter to
Drawstrings on children‘s clothing can lead manufacturers and retailers of children‘s
to deaths and injuries when they catch on upper outerwear, urging them to make sure
such items as playground equipment, bus that all clothing sold in the U.S. complies
doors, or cribs.51 From January 1985 with the voluntary safety standard.55 The
through June 1997, CPSC received reports of letter also stated that CPSC ―considers
21 deaths and 43 incidents involving children‘s upper outerwear with drawstrings
drawstrings on children‘s upper outerwear.52 at the hood or neck area to be defective‖ and
In February 1996, CPSC issued guidelines to subject to recall.
help prevent these injuries, which ASTM
adopted as a voluntary standard in June U.S. PIRG‘s analysis of the past year‘s recalls
1997.53 In the period since, CPSC has seen a and other enforcement actions shows that
marked decrease in fatalities and incidents. more than 450,000 articles of children‘s
clothing have been recalled because of this
CPSC recommends that parents remove hazard. An August 2009 recall occurred after
drawstrings from all children‘s upper the death of a three year old child in Fresno,
outerwear sized 2T to 12 and buy clothing Calif., who was strangled when the
that has alternative closures, such as snaps, drawstring on the hooded sweatshirt that he
buttons, and Velcro.54 was wearing became stuck on a play ground
set.56
[

Methodology

Testing of toys and other children’s Corporation in Chicago, a laboratory

products for lead and other metals: We accredited by the Illinois Environmental
purchased 98 toys and children‘s jewelry Protection Agency in accordance with the
from major retailers and dollar stores and National Environmental Laboratory
used an X-Ray Fluorescence (XRF) analyzer to Accreditation Program, for additional testing.
perform 337 screens for the presence of lead STAT Analysis used EPA Method 6020
and other metals. We sent these items and (Inductively Coupled Plasma-Mass
another 162 products to STAT Analysis Spectrometry) and EPA Method 3050B (Acid

PIRG’s Trouble in Toyland Page 19

Digestion of Sediments, Sludges, and Soils)
to determine the quantity of lead and other
metals regulated by the CPSIA in each item.57

Testing of products for phthalates: STAT

Analysis performed the phthalates testing.
STAT Analysis followed standard procedures,
using EPA Method 8270C and EPA Method
3580A.58 The reporting/quantitation limits
varied based on the product tested.

Choking hazards: We categorized toys as a

potential choking hazard if: a) a toy labeled
for children under three contains small parts
or breaks easily into small parts;a b) a toy
contains small parts or small balls but is
intended for children under three, regardless
of age labeling if any; c) a toy contains small
parts or small balls, is intended for children
over three, but lacks the statutory choke
hazard warning; or d) the toy is intended for
children under six, lacks the statutory choke
hazard warning and appears to fail the ―use
and abuse‖ test, breaking easily into small
parts that fit in the choke tube, or e) contains
a ―near small part‖ that is slightly larger than
the choke test cylinder.

a
If a toy broke into small parts with little effort or
force, we assumed that the toy may not comply with
CPSC use and abuse testing procedures.

PIRG’s Trouble in Toyland Page 20

 Attachment A. 2010 Summary of Toy Hazards and
Examples of Potentially Dangerous Toys and
Children’s Product

- Potentially Toxic Toys: Lead and Other Toxic Chemicals-

Standards

The Consumer Product Safety Improvement Act of 2008 bans lead in toys and children‘s products
on a phase-out schedule outlined below. After the effective dates, these products cannot be
manufactured, imported for sale or sold.

 February 2009: Toys and children‘s products containing lead in excess of 600 parts per
million (ppm) became banned hazardous substances.
 August 2009: The maximum allowable amount of lead in paint decreased from 600 ppm
to 90 ppm.
 August 2009: Toys and children‘s products containing lead in excess of 300 parts per
million (ppm) became banned hazardous substances.
 August 2011: Toys and children‘s products containing lead in excess of 100 parts per
million (ppm) become banned hazardous substances.

The CPSIA 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 CPSIA made mandatory the previously voluntary ASTM F-963-07 standards, including limits
on eight metals in the surface coating of children‘s products, as outlined in the table below:
Maximum Soluble Migrated Element in ppm (mg/kg) Toy Material

Antimony Arsenic Barium Cadmium Chromium Lead Mercury Selenium

(Sb) (As) (Ba) (Cd) (Cr) (Pb) (Hg) (Se)
60 25 1000 75 60 90 60 500

PIRG’s Trouble in Toyland Page 21

Examples of Toys and Children’s Products Containing Potentially Toxic
Lead
Category: Toxic chemicals
Product Name: Princess Expressions Tiara and Jewelry set
Manufacturer: Almar Sales
Retailer: KMart
Item # or SKU: 2457682123
Problem: Lab measured 87 ppm lead in tiara *

** While this does NOT violate the CPSIA standard for lead in
surface coating, scientists have not identified a ―safe‖ level of lead
exposure for children.59

Category: Toxic Chemicals

Product Name: Monkey in Banana
Manufacturer: Play Pets
Retailer: Uncle Fun
Item # or SKU: stuffed monkey in banana
Problem: lab test measured 97 ppm lead in the surface of the
banana

Examples of Toys and Children’s Products Containing Phthalates

Category: may contain toxic chemicals

Product Name: baby toys Baby Doll
Manufacturer: unknown
Retailer: Uncle Fun
Item # or SKU: unknown
Problem: measured 53,000 ppm DIDP and 300,000 ppm DIIP
(phthalates) in the baby’s face

*these phthalates are only regulated in so-called “mouthing toys”

PIRG’s Trouble in Toyland Page 22

Category: toxic phthalates
Product Name: Dora the Explorer backpack
Manufacturer: Global Design Concepts
Retailer: Claire's
Item # or SKU: 6232981295
Problem: lab measured 150,000 ppm Bis(2-ethylhexyl) phthalate*
on the mouth

*This phthalate was NOT regulated by the 2008 law.

Examples of Toys and Children’s Products Containing Potentially Toxic

Antimony

Category: may contain toxic chemicals

Product Name: bright stars travel book
Manufacturer:
Retailer: Toys R Us
Item # or SKU:7445108849
Problem: lab measured 120 ppm antimony in the red handle of the
book

Category: may contain toxic chemicals

Product Name: plastic handcuffs
Manufacturer:
Retailer: Toys R Us
Item # or SKU:7565602150
Problem: lab measured 1200 ppm antimony in the surface coating

Category: may contain toxic chemicals

Product Name: wild ranger toy gun
Manufacturer: POLYFECT, INC
Retailer: Family Dollar
Item # or SKU:7856511300
Problem: measured 94 ppm antimony in surface coating of the
silver part of the gun; 190 ppm antimony on the handle

-Potential Choking Hazards -

PIRG’s Trouble in Toyland Page 23

Standards

Under the Child Safety Protection Act (CSPA) and Consumer Product Safety Commission rules:

 Toys intended for children under 3 are banned if they contain small parts or easily break
into pieces that are small parts.
 Toys intended for children between the ages of three and six years old that contain small
parts must include an explicit choke hazard warning with precise statutory language.
 Any small ball or toy that contains a small ball must meet a stricter safety test and include
an explicit choke hazard warning.
 Marbles or toy with marbles must include an explicit choke hazard warning.
 All balloons must include a warning about the dangers of uninflated or broken balloons
to children younger than 8 years of age.

Examples of Toys that Pose Potential Choking Hazards

TOYS THAT CONTAIN NEAR SMALL PARTS -

Toys intended for children between the ages of three and six years old that contain small parts must include an
explicit choke hazard warning with precise statutory language. Any small ball or toy that contains a small
ball must meet a stricter safety test and include an explicit choke hazard warning. Any marble must include
an explicit choke hazard warning.

These products contain toy parts that almost fit in the choke test tube. Although these toys do not violate the
letter of the law, these parts could block a child’s airway given their shape and size. Children have died on
similarly-sized toys that pass the choke tube test.

Category: Near Small Parts

Product Name: Lokmock /Baby‘s first train
Manufacturer: Haba
Retailer: Amazon.com, Sullivan’s Toys
Item # or SKU:1197
Problem: Contains pegs that are about 1cm longer than the choke
tube. Labeled ―Age 1+‖. No choke hazard warning; CSPA does not
require a warning because the toys do not fit in the choke test
cylinder. U.S. PIRG was alerted to this toy by a consumer who had
to perform a Heimlich maneuver on her one-year-old because he
swallowed one of the pegs.

PIRG’s Trouble in Toyland Page 24

Category: Near Small Parts
Product Name: Let‘s Get Building! Construction Playset (Handy
Manny Big Construction Job)
Manufacturer: Fisher Price
Retailer: Target
Item # or SKU:2708478850
Problem: Contains a toy warning cone that is barely larger than the
choke tube. Labeled “3+” No choke hazard warning; CSPA does
not require a warning because the toys do not fit in the choke test
cylinder. Has a warning in small print on the back of the package
that ―small parts may be generated‖.

PIRG’s Trouble in Toyland Page 25

 Attachment B. Toy-Related Deaths, 1990-2009

Total
1990

1991

1992

1993

1994

1995

1996

1997

1998

1999

2000

2001

2002

2003

2004

2005

2006

2007

2008

2009
Choking/Asphyxiation
Deaths
Balloons 6 3 6 6 6 8 7 6 4 4 1 4 3 3 1 2 3 4 1 1 79
Balls 2 2 3 6 4 2 0 3 1 4 2 1 2 5 4 9 4 4 1 59
Marbles 0 2 1 0 0 1 0 0 0 0 1 0 0 0 0 0 0 0 0 1 6
Toy or Toy Part 6 6 1 4 3 1 3 2 3 1 2 4 3 2 2 2 6 2 1 54
Total 14 13 11 16 13 12 10 11 8 9 6 9 8 10 7 13 13 10 3 2 198

Riding Toys, Scooters 4 8 4 5 4 6 2 0 4 4 8 13 5 0 6 8 11 8 9 7 116

Toy Chests 4 2 2 1 0 0 0 1 0 1 1 1 0 0 0 1 0 0 1 1 16

Strangulation/ Suffocation 1 1 3 2 0 1 1 0 0 0 0 1 0 0 2 2 0 0 0 1 15

Other 0 1 2 1 1 2 0 1 2 2 2 1 0 1 1 2 5 4 6 1 35

TOTAL TOY DEATHS 23 25 22 25 18 21 13 13 14 16 17 25 13 11 16 26 29 22 19 12 380

% BY CHOKING/ASPHYXIA 61% 52% 50% 64% 72% 57% 77% 85% 57% 56% 35% 36% 62% 91% 44% 50% 45% 45% 16% 17% 52%

Source: U.S. PIRG analysis of annual CPSC Reports on "Toy-Related Deaths and Injuries". Previous years updated by new information in 2009 report released November 18, 2010

PIRG’s Trouble in Toyland Page 26

 End Notes
1
U.S. National Cancer Institute, President’s Cancer Panel, Reducing Environmental Cancer Risk: What We Can Do
Now, April 2010.
2
U.S. Centers for Disease Control and Prevention, Fourth National Study on Human Exposure to Environmental
Chemicals, December 2009; Environmental Working Group, Body Burden: The Pollution in People, January 2003.
3
U.S. Environmental Protection Agency, What is the TSCA Chemical Substance Inventory?, (factsheet), 19 August
2009; available at www.epa.gov/opptintr/newchems/pubs/invntory.htm.
4
U.S. Environmental Protection Agency, Chemical Hazard Data Availability Study, 1998. Major chemicals are
defined as those produced or imported in amounts exceeding one million pounds per year.
5
The Consumer Product Safety Improvement Act of 2008, HR 4040, became Public Law 110-314 on August 14th
when it was signed by the President.
6
16 CFR 1500.18(a)(17)
7
U.S. Consumer Product Safety Commission press releases January 2009- November 10, 2009,
http://www.cpsc.gov/cpscpub/prerel/prerel.html
8
U.S. CPSC “Toy Related Deaths And Injuries Calendar Year 2009” November 18, 2010
9
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).
10
Centers for Disease Control and Prevention, Preventing Lead Poisoning in Young Children, August 2005.
11
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.
12
CPSC, “Reebok Recalls Bracelet Linked to Child’s Lead Poisoning Death,” press release, March 23, 2006.
Accessed November 7, 2010 at http://www.cpsc.gov/cpscpub/prerel/prhtml06/06119.html.
13
Centers for Disease Control, “Death of a Child After Ingestion of a Metallic Charm --- Minnesota, 2006,”
Morbidity and Mortality Weekly Report, March 23, 2006.
14
CPSC release of June 13, 2007, “RC2 Corp. Recalls Various Thomas & Friends™ Wooden Railway Toys Due to
Lead Poisoning Hazard,” accessed on November 7, 2010 at
http://www.cpsc.gov/CPSCPUB/PREREL/prhtml07/07212.html.
15
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, 2010).
16
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, 2010 at
http://www.cpsc.gov/cpscpub/prerel/prhtml07/07283.html.
17
U.S. PIRG analysis of CPSC recall announcements.
18
16 CFR 1303.
19
15 U.S.C. 1261(f)(1)
20
15 U.S.C. 1261(q)(1)
21
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.
22
BC Blount et al, ―Levels of Seven Urinary Phthalate Metabolites in a Human Reference Population,‖ Environmental
Health Perspectives 108: 979-982, 2000.
23
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.
24
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

PIRG’s Trouble in Toyland Page 27

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.
25
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.
26
G Latini et al, ―In-Utero Exposure to Di-(2-ethylhexyl)-phthalate and Human Pregnancy Duration,‖ Environmental
Health Perspectives 111:1783-1785, 2003.
27
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.
28
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.
29
CPSC, ―CPSC Releases Study on Phthalates in Teethers, Rattles and Other Children‘s Products,‖ press release,
December 2, 1998, accessed November 7, 2010 at www.cpsc.gov/CPSCPUB/PREREL/PRHTML99/99031.html.
30
CPSC, ―CPSC Releases Study on Phthalates in Teethers, Rattles and Other Children‘s Products,‖ press release,
December 2, 1998, accessed November 7, 2010 at www.cpsc.gov/CPSCPUB/PREREL/PRHTML99/99031.html.
31
Report to the U.S. Consumer Product Safety Commission by the Chronic Hazard Advisory Panel on Diisononyl
Phthalate, June 2001. Accessed November 7, 2010 at http://www.cpsc.gov/LIBRARY/FOIA/Foia01/os/dinp.pdf.
32
CPSC, Letter to Jeffrey Becker Wise, National Environmental Trust, February 26, 2003, accessed November 7, 2010
at http://www.cpsc.gov/library/foia/foia03/petition/ageunder.PDF.
33
―Results of Competitiveness Council, Brussels, 24th September 2004,‖ Memo/04/225.
34
Bette Hileman, ―EU Bans Three Phthalates from Toys, Restricts Three More,‖ Chemical and Engineering News, July
11, 2005.
35
News release, Environment California, 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-to-protect-kids-from-toxic-toys.
36
16 CFR 1501.2(b)
37
16 CFR 1501.2(a)
38
16 CFR 1501.3
39
16 CFR 1501.4(b)(2)
40
16 CFR 1500.19
41
16 CFR 1500.18(a)(17)
42
16 CFR 1500.18(a)(17)
43
16 CFR 1500.19(b)(3)
44
16 CFR 1500.19(a)(2)
45
16 CFR 1500.19(a)(4)
46
16 CFR 1500.19(a)(8)
47
CPSC, ―Playskool Voluntarily Recalls Toy Tool Benches after the Death of Two Toddlers,‖ press release, September
22, 2006.
48
CPSC, “Little Tikes™ Recalls Children’s Toy Workshop Sets and Trucks Due to Choking Hazard,” press release,
August 13, 2009. http://www.cpsc.gov/CPSCPUB/PREREL/prhtml09/09304.html
49
ASTM International, ―Standard Consumer Safety Specification for Toy Safety,‖ F963.4.33.
50
Statement of Celestine T. Kiss, Engineering Psychologist, CPSC, at the CPSC Premium Toys Seminar, Bethesda,
MD, January 9, 2001. Accessed November 7, 2010 at http://www.cpsc.gov/businfo/celstalk.pdf.
51
CPSC, ―Guidelines for Drawstrings on Children‘s Upper Outerwear,‖ accessed November 7, 2010 at
http://www.cpsc.gov/CPSCPUB/PUBS/208.pdf.
52
CPSC, Letter to Manufacturers, Importers and Retailers of Children‘s Upper Outerwear, , May 19, 2006, accessed
November 7, 2010 at http://www.cpsc.gov/BUSINFO/Drawstring.pdf.
53
ASTM F1816-97, ―Standard Safety Specification for Drawstrings on Children‘s Upper Outerwear.‖
54
CPSC, ―Guidelines for Drawstrings on Children‘s Upper Outerwear,‖ accessed October 31, 2006 at
http://www.cpsc.gov/CPSCPUB/PUBS/208.pdf.
55
CPSC, Letter to Manufacturers, Importers and Retailers of Children‘s Upper Outerwear, May 19, 2006, accessed
October 31, 2006 at http://www.cpsc.gov/BUSINFO/Drawstring.pdf.

PIRG’s Trouble in Toyland Page 28

56
CPSC Press Release #09-129, August 13, 2009. Strangulation Death of a Child Prompts Hill Sportswear To
Recall Hooded Sweatshirts with Drawstrings
57
A technical description of EPA Test Method 6020 is available at U.S. EPA, ―Inductively Coupled Plasma-Mass
Spectrometry,‖ accessed November 7, 20106 at
http://www.epa.gov/epawaste/hazard/testmethods/sw846/online/6_series.htm . A technical description of EPA Test
Method 3050B is available at U.S. EPA, ―Acid Digestion of Sediments, Sludges, and Soils,‖ accessed November 3,
2006 at http://www.epa.gov/epaoswer/hazwaste/test/pdfs/3050b.pdf.
58
A technical description of EPA Test Method 8270D (which has replaced test 8270C) is available at U.S. EPA,
―Semivolatile Organic Compounds by Gas Chromatography/Mass Spectrometry, accessed November 7, 2010 at
http://www.epa.gov/epawaste/hazard/testmethods/sw846/online/8_series.htm . A technical description of EPA Test
Method 3580A is available at U.S. EPA, ―Waste Dilution,‖ accessed November 7, 2006 at
http://www.epa.gov/osw/hazard/testmethods/sw846/pdfs/3580a.pdf .
59
Centers for Disease Control and Prevention, Preventing Lead Poisoning in Young Children, August 2005.

PIRG’s Trouble in Toyland Page 29