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CPSC Analysis Faulty

CPSC's analysis, as linked above, is faulty at best.  The largest single problem is that they continue to based their decision on whether or not the lead in a product is hazardous on the basis of whether or not they expect it to raise a child's blood lead level to 10 mcg/dL.  This level is CDC's level of concern for public health interventions in communities.  It is not a level at which there is not expected to be harm to a child, and even the CDC agrees that research shows lead impacts a child's brain and reduces IQ scores at levels well below 10. Even if you accept that 10 is an acceptable standard, CPSC bases their calculations on an "average" child, using national data to show that the "average" child has an existing background level of 3 mcg/dL of lead in their blood.  Children who live in older homes or who live in urban centers are much more likely to have higher "background" levels of lead exposure, meaning that CPSC standards are hardly safe for these children.  

CPSC analyzed turf for both total lead content and used wipe tests to gauge exposure.  The total lead contents ranged from non-detects to 8,800 PPM. 600 PPM is the maximize level of lead allowed in paint. The wipe tests were conducted using a method CPSC developed for testing arsenic from CCA wood. Folks in the lead poisoning prevention business typically use a slightly different wipe test in homes to gauge risks from lead based paint. While CPSC's test is different, it is quite similar in intent. To gauge the turf risk, CPSC took their wipe results and divided them by 5 to reflect an estimated difference between the amount of dust that the wipe picks up versus what someone's hands pick up.  They further divided that by 2 to account for the difference between what gets on your hand versus what would go in your mouth. These "fudge factors" were loosely based on a study they did for CCA, and are not well justified. The highest result using this method was an intake of 9.9 micrograms.  Their standard, again based on the notion that you have to get to a BLL of 10 to be hazardous, is 15 micrograms. Clearly if CPSC had been using a lower level of concern or had slightly altered their "fudge factors" they would have been labeling at least some of the products hazardous.

For residential purposes, it is typical to look at the number of micrograms of lead per square foot. EPA set a standard of 40 micrograms per square foot as the safe level of lead for floors. Assuming there is rough equivalency between CPSC's dust wipes and residential dust wipes, CPSC sampled about 400 square centimeters of turf (8 wide by 50 long - actually less than that since the circular shape would miss the corners...). 400 square centimeters is .4306 square feet.   So if you divide CPSC's "wipe sampling result" by .4306, you can get an estimate of the number of micrograms per square foot.  The highest wipe was 229 mcg/ft^2 and all of the wipes on the first sample would have failed a 40 mcg/ft^2 floor standard.  The second sample, which was collected from an indoor field, calculates out to 33 mcg/ft^2 - getting close to the standard.

Although I would not advocate that turf is providing a major source of lead exposure to a broad range of children, it's clearly not as cut and dried as the CPSC implied with their cheerful "Go out and play" message.   I would further suggest that this is another sad example of CPSC's commitment to protecting industry over consumers and illustrative of the backwards and scientifically deficient approach they take towards regulating lead and other toxins.
On Artificial turf found not harmful to children posted 1 year, 4 months ago 10 Responses