About the Action Guide

• Why we need HealthyStuff.org
• Findings
• Using the site
• Product rating
• Methodology
• Product safety
• About us
• HealthyStuff mobile

Rating System for HealthyStuff.org

To establish levels considered low, medium, or high for the chemicals of concern, HealthyStuff.org consulted existing voluntary product standards, as well as mandatory toy, packaging, electronics, and vehicle standards. HealthyStuff.org also evaluated recent state and federal legislation regulating consumer products. The levels are not intended to correspond to levels known to cause health effects. Rather, they are meant to provide a relative measure of the level of the chemical on or near the surface of the product.

Comparative Method Rating
For products types that have a standard set of components we developed a "comparative method".  Vehicles are one example of a product type in which any product will have a similar set of components.  Every vehicle has seats, steering wheel, instrument panel, etc.   For these types of products, we normalize overall test results and provide comparative ranking of all products of a particular type.  Vehicles and children's car seats are rated using this method.

Level of Detection Method Rating
For product types that have widely varying sizes, shapes and number of components we developed a "level of detection method". Toys are an example of a product type that can have a wide range of different components.  A wooden block is one type of material, while a plastic doll house may have several different plastics and dozens of different individual pieces.  For product categories of this type we report the highest level detected for each chemical of concern in the product as a whole (regardless of how many components the product has).  Toys, pet beds, pet chew toys and purses are rated using this method.

For all products we also provide the raw test results.  HealthyStuff.org is committed to transparency.

 

Comparative Method

For product types for which there are common, identical components in all products, HealthyStuff.org uses a method which allows all products of that particular type to be evaluated against other products of the same type. A total of 11 components from each vehicle was selected for sampling, including: the steering wheel, shift knob, armrest/center console, dashboard, headliner, carpet, seat front, seat back, seat base, hard and soft door trim. Vehicle samples were taken over two testing periods. The first included vehicles of model years 2006 and 2007 sampled from October to December of 2007. The second sampling phase was conducted from April to June of 2008 and included vehicles with model years ranging from 2007 to 2009. Due to constant turnover of vehicles on a dealer's lot, we were restricted by the model years present on the lot on the day of sampling.

Child car seats were evaluated using a similar method. The car seats sampled included all of the on-the-shelf models available at several major national retailers in Michigan. Child car seats were sampled in January 2007 (2007 model seats), June 2008 (2008 model seats) and June 2009 (2009 model seats). The major components in each car seat were sampled, including the seat cushion, foam backing, seat base, seat belt clip and sun shade (when available). Different components were analyzed for different types of car seats. For example, infant seats include sun shades, whereas convertible and booster seats do not. Car seat ratings were calculated based on the XRF results from the components that were sampled on all seats of the same type.

The components were selected based on the following criteria:

• Potential of exposure, i.e. components that drivers or passengers come in contact with, that are subject to abrasion, or that otherwise release vapors or particles to the environment;
• Surface area and relative size of component;
• Potential to off-gas or degrade during heat and/or UV-ray exposure;
• Ease of access to component for sampling.

For both vehicles and child car seats, the elements tested for include: Antimony, Arsenic, Bromine, Chlorine, Chromium, Cobalt, Copper, Lead, Mercury, Nickel and Tin. These components were chosen for two primary reasons: 1) They could be easily and quickly identified using non-destructive methods. Sampling for this project was limited to new vehicles, which prevented the use of any testing that would damage vehicle components. 2) These elements have already been subject to regulatory restrictions and/or voluntary limits by industry associations or third party environmental certification organizations. These "chemicals of concern" may impact the environment and/or health during all phases of a product's lifecycle, including production, use and end-of-life.

For a detailed description of the HealthyStuff.org vehicle and child car seat rating systems and methodology, download the comparative methodology summary.

Level of Detection Method

For products categories without a consistent set of components for each product, HealthyStuff.org consulted existing voluntary toy standards - as well as mandatory toy, packaging, electronics, and vehicle standards - to establish levels considered low, medium, or high for the chemicals of concern. HealthyStuff.org also evaluated recent state and federal legislation regulating children's products. The levels are not intended to correspond to levels known to cause health effects. Rather, they are meant to provide a relative measure of the level of the chemical on or near the product's surface.

Chemical	Low/Non-detect Level	Medium Level	High Level
Lead	Non-detect to 40 ppm	41 ppm to 299 ppm	300 ppm or above
Cadmium	Non-detect to 40 ppm	41 to 100 ppm	Above 100 ppm
Mercury	Non-detect to 40 ppm	41 to 100 ppm	Above 100 ppm
Arsenic	Non-detect to 40 ppm	41 to 100 ppm	Above 100 ppm
Chlorine/PVC	Under 10,000 ppm	Over 10,000 ppm
Bromine	Non-detect to 1,000 ppm		Above 1,000 ppm
Antimony	If antimony was detected at 100 ppm or above, it was noted
Tin	If tin was detected at 100 ppm or above, it was noted
Chromium	If chromium was detected at 100 ppm or above, it was noted

Note: "ppm" represents parts per million.

Note: HealthyStuff.org ratings do not provide a measure of health risk or chemical exposure associated with any individual product, or any individual element or related chemical. HealthyStuff.org ratings only provide a relative measure of high, medium, and low concentrations of several hazardous chemicals or chemical elements in a product in comparison to criteria established in the site methodology.

 

Rationale for assigned levels

Lead

Although no amount of lead is safe for children, the American Academy of Pediatrics has recommended a maximum of 40 ppm of lead in children's products. Products that tested below this level, including non-detects, were assigned a LOW level of lead.

Products with lead levels above 40 ppm but below 299 ppm were assigned a MEDIUM level. U.S. and European Union packaging standards limit lead to an upper limit of 100 ppm in packaging. There is a proposed rule in Canada to limit lead in children's toys that can be put in the mouth to 90 ppm. Current U.S. regulations limit lead in paint on children's products to 300 ppm (Code of Federal Regulations 2007). As of August 2009, products containing a concentration of lead - both in the paint and in the product itself - greater than 300 ppm shall be listed as banned hazardous substances. This limit shall be lowered to 100 ppm as of August 2011 if Consumer Product Safety Commission (CPSC) determines it is feasible to reach the lower level. Electronic toys in the United States are exempt from the lead ban, though this is subject to change by the CPSC as technology improves (CPSIA 2008).

Products with lead levels at 300 ppm or higher were assigned a HIGH level.

Note: The European toy standard EN 71 (for migration from toys) is 90 ppm. The U.S. voluntary toy standard ASTM F973-07 (for migration from toys) is 90 ppm.

Cadmium

Levels below 40 ppm, including products with no detectable cadmium, were deemed to be LOW. Products with cadmium between 41 and 100 ppm were assigned a MEDIUM level of cadmium. U.S. and European Union packaging standards limit cadmium to an upper limit of 100 ppm. The European Restriction of Hazardous Substances (RoHS) directive sets a limit of 100 ppm. The European end-of-life vehicle standard is set at 100 ppm. Products with cadmium above 100 ppm were assigned a HIGH level of cadmium.

Note: The European toy standard EN 71 (for migration from toys) is 75 ppm. The U.S. voluntary toy standard ASTM F973-07 (for migration from toys) is 75 ppm.

Mercury

Levels below 40 ppm, including products with no detectable mercury, were assigned a LOW level. Products with mercury between 41 and 100 ppm were assigned a MEDIUM level of mercury. U.S. and European Union packaging standards limit mercury to an upper limit of 100 ppm. The European RoHS directive sets a limit of 100 ppm. Products with mercury above 100 ppm were assigned a HIGH level of mercury.

Note: The European toy standard (for migration from toys) for mercury is 60 ppm. The U.S. voluntary toy standard (for migration from toys) is 60 ppm.

Arsenic

Levels below 40 ppm, including products with no detectable arsenic, were deemed to be LOW. Products with arsenic between 41 and 100 ppm were assigned a MEDIUM level. Products with levels of arsenic above 100 ppm were assigned a HIGH level of arsenic.

Note: The European toy standard EN 71 (for migration from toys) is 25 ppm. The U.S. voluntary toy standard ASTM F973-07 (for migration from toys) is 25 ppm.

Chlorine/PVC

Chlorine was used as a surrogate for PVC plastic in our testing. Products with chlorine content above 10,000 ppm are very likely to be made primarily of PVC plastic. Products with chlorine content below 10,000 ppm chlorine cannot reliably be considered to be PVC plastic. Flexible PVC plastic may contain hazardous plasticizers called phthalates. Therefore, detection of high levels of chlorine in flexible plastics was used to infer the possible presence of phthalates even though the presence of phthalates cannot be measured directly by the XRF technology. Many toy manufacturers have been reformulating away from phthalates, but labeling is not required. Therefore, we must rely on inference because companies do not provide information about the chemical components of their products, and the government does not require it. Recent legislation now bans products containing certain phthalates in concentrations greater than 0.01% as of February 2009 (CPSIA 2008). Products that we infer are not made of PVC were assigned a LOW level. Products that we infer are made of PVC, and thus could potentially contain phthalate plasticizers, were assigned a MEDIUM level.

Bromine/BFRs

Bromine was used as a surrogate for brominated flame retardants (BFRs). Levels of bromine greater than 1,000 ppm are very likely to contain BFRs and are assigned a HIGH level. Products with bromine levels less than 1,000 cannot be reliably assumed to contain BFRs and are therefore given a LOW level.

Other Chemicals of Concern

Antimony, tin, and chromium are among other elements that are detected by the XRF technology. However, each of these elements can be present in compounds with widely varying molecular structures and toxicity. The XRF technology identifies the presence of the element, but cannot identify the particular chemical in which the element is present in the product. As a result, it is difficult to draw conclusions about the chemical in the product. Therefore, the presence of antimony, tin, and chromium is noted when detected, but their concentrations are not used in the overall ranking of the product. Antimony, tin and chromium are also used in elemental form in many alloys (e.g. stainless steel) and many materials made of ceramics or glass contain compounds of these metals. These materials typically have lower relative leaching rates under most environmental conditions. However, children's jewelry made of alloys containing lead and cadmium still pose a serious hazard, particularly when chewed or swallowed.

Antimony
If antimony was detected above 100 ppm, it was noted on the database for each product.

Note: The European toy standard EN 71 (for migration from toys) is 60 ppm. The U.S. voluntary toy standard ASTM F973-07 (for migration from toys) is 60 ppm.

Tin
If tin was detected above 100 ppm, it was noted on the database for each product.

Chromium
If chromium was detected above 100 ppm, it was noted on the database for each product.

Note: The European toy standard EN 71 (for migration from toys) is 60 ppm. The U.S. voluntary toy standard ASTM F973-07 (for migration from toys) is 60 ppm.

Calculation of Overall Rating

The overall rating was determined by the highest finding for the product for any single chemical. A toy with one or more HIGH ratings for individual chemicals would get a HIGH rating overall. A product with one or more MEDIUM ratings and no high ratings would get a MEDIUM rating overall. To get a LOW rating overall, the product must have only low ratings for lead, mercury, cadmium, and arsenic, and the product must not be made of PVC plastic.

Low Level Rating	Medium Level Rating	High Level Rating
No detection or low levels detected for the chemicals lead, cadmium, arsenic, bromine and mercury. Not a PVC product.	One or more of the chemicals lead, cadmium, arsenic and/or mercury were found at medium levels; and/or the product is made of PVC. No BFR's present.	One or more of the chemicals lead, cadmium, arsenic, bromine and/or mercury were found at high levels.

 

We also noted the presence of "other chemicals" in the overall rating. If the overall rating includes an asterisk, the product contained tin, antimony, chromium in concentrations above 100 ppm. The presence of these chemicals was not calculated as part of the overall rating because there is less data on the hazards posed by these chemicals, or because the form of the chemical in the product could not be determined. The presence of these chemicals in children's products deserves more attention and research.

XRF detection limits for highlighted elements are as follows:

Element	Manufacturers Detection Limit Guidelines(1)	Observed Detection Limits, 30 second samples(2)
Antimony	50-150 ppm	109 ppm
Arsenic	10-100 ppm	1 ppm
Bromine	10-100 ppm	2 ppm
Cadmium	50-150 ppm	62 ppm
Chlorine	1%-5%	2.80%
Chromium	10-100 ppm	39 ppm
Lead	10-100 ppm	5 ppm
Mercury	10-100 ppm	7 ppm
Tin	50-150 ppm	130 ppm

(1) Innov-X Model XRF Detector. Detection limits are estimates based on 1-2 minute test times and detection confidence of 3 sigma (99.7% confidence). Detection limits are a function of testing time, sample matrix and presence of interfering elements.
(2) Observed detection limits varied by the type of material being tested. Detection limits presented were the lowest levels observed.