Approaches to Assessing Risks from Chemicals Used in Toys
In the absence of
population based measures of risks associated with chemical exposures from
toys, alternative approaches to assessing or predicting risks are needed,
particularly in the area of non-acute health risks. Ideally, we would know the precise chemical
content of toys, the full spectrum of toxicities associated with all chemicals
used in toys, the bioavailability of potentially hazardous chemicals within toys,
the level of exposure from intended play and reasonably anticipated abuse, and the
number of children with unsafe exposures would all be objectively measurable. There are many barriers to gathering such
complete information, yet all of these categories of information are relevant
and necessary if risk is to be quantitatively defined.
Most often the chemical
content of toys is not readily available. Commercial toy manufacturers are likely to
know relevant information on chemical hazards from safety data sheets
transmitted from suppliers. It cannot be assumed, however, that toy manufacturers
know the exact chemical content of all of the components of their products. Toys may be made from a number of
pre-manufactured parts, such as fabric, metal pieces (springs, rods),
electronic motors, beads, stuffing, etc. for which the precise chemical content
may not be readily available, and chemical manufacturers often supply chemicals
as a mixture that meets certain performance specifications. Absent strict specifications about chemical
content, there also may be batch to batch variation in chemical mixtures used
for toys. Additionally, the chemicals
used in toys may change rapidly in response to market forces, or may be
protected as proprietary information. The chemicals used in toys made by
smaller manufacturers, at home, or in cottage industries may be less well
controlled and/or undocumented.
Even if chemical content is consistent
and recorded, toxicological information about chemicals used in toys
may not be complete. The Forum IV
information paper noted that complete basic Screening Information Data Sets
(SIDS) were not available for over 80% of the 5000 high production volume (HPV)
chemicals in current use.[i] Since that time, more data are becoming
available on HPV chemicals. (see SIDEBAR)
SIDS data, however, are for screening purposes only, and not intended to
directly explore risks to children from early life-stage exposures. For non-HPV chemicals fewer toxicity data are
available. Thus, there remain few data directly related to understanding the
potential for early life toxicity. The SIDEBAR describes some efforts to
address this knowledge gap. A wide range
of potential chemical harms pertain to early life exposures, and protocols to
test for some hazards are still underdevelopment. Both the dose and the timing of exposures are
important in evaluating children's chemical risk. New work evaluating low-dose effects of
chemical exposures on cell-to-cell signaling, endocrine sensitive pathways, and
functional developmental differentiation have added to concerns about how to
evaluate chemical toxicities in infants, children and adolescents. Thus, even if all chemical content were known
and fully disclosed, without complete, life-stage specific, toxicological data
it may be difficult to ensure chemical safety.
The bioavailability of
a chemical in the context of toy safety refers to the ability of the chemical
to be released from a product or toy and absorbed into a child's body via the gastrointestinal
tract, the lungs, or the skin and mucus membranes. If a chemical is not bioavailable, even if it
has some toxicity in pure form, it may not represent a health hazard. Both the physical design of a toy and the
chemical composition can affect the bioavailability of a specific
chemical. For example, a toy that
contains a liquid can be problematic if the structure is not engineered to
ensure that the liquid remains locked in place.
A plastic toy may contain plasticizers, softeners or stabilizers to
reduce fragility and breakage, but these modifying chemicals may be capable of
leaching from the structural material, making them bioavailable to a child
rubbing or mouthing the object.
It is well established that
bioavailability does not correlate simply with chemical content; i.e. the mere
presence of a chemical in a toy does not translate into exposure.[ii] Methods
for estimating a child's level of exposure to chemicals from playing with toys
are under active development.[iii]
A variety of approaches are being explored, but none has emerged as the
"gold standard." Because
children interact with toys differently at different ages and developmental
stages, exposure models must consider a range of behaviors including both
intended use and reasonably anticipated misuse of the toy. Children interact and experiment with objects
in their environment and will mouth, throw, hit, scrape, scuff, bend and break
toys just to learn what will happen.
They may attempt to eat small toys or toy fragments or insert such small
pieces into nose, ears or other body orifices.
They will cuddle, rub, or sniff surfaces of toys. Different children have different sensory
preferences, and the behavior of a given child will change from day to
day. Finally, while certain behaviors
tend to cluster at certain chronological ages, (e.g. mouthing behaviors peak
between 6 and 36 months), there is a considerable range of normal behaviors
which extend well beyond the "average" or "median" age. This range is further enlarged when considering
children with developmental delay or disability, mental retardation, emotional
or behavior problems, or other mental health conditions.
Some of the
approaches used to estimate children's exposures have involved short-term direct
observation of children at play to assess behaviors such as mouthing of objects
and hands, analysis of video recordings of children a play, and parental logs
of specified behaviors over several days.[i],[ii],[iii] In some cases, adults have been used to
simulate play in a variety of settings. In vitro,
and mechanical approaches have been used to simulate chewing of toys and
measure chemical leaching rates.[iv] All of this work has been done in
industrialized, western countries, raising questions of cultural bias in the
data collected, and its relevance to the rest of the world. On the other hand, these
approaches can be enhanced and adjusted statistically to aid in accounting for various
sources and levels of uncertainty.
For any model to be useful, it must
be validated, a process which involves testing predictions for accuracy and
reproducibility against empiric data from groups of representative individuals.
None
of the available exposure models for assessing likely or predicted exposures
from toys has been validated on large numbers of children, across cultures and
regions, or with matched biomonitoring and toy chemical content sampling. All
of these models are based on small sample sizes and short duration of
observations. For ethical reasons, it
will never be possible to validate the accuracy of exposure model predictions
using direct biomonitoring of children exposed to toys of known chemical
content. Validated in vitro studies, and validated and controlled studies of adults
will always need to be extrapolated to the special case of children and some
uncertainty is unavoidable. In vitro
leaching methods were developed in Europe in the late 1990s as a proposed basis
for a regulatory approach to limit the risks from exposure to phthalates in
teething toys, although the conclusion that these methods had been validated
for this purpose received some criticism.[v],[vi]
Assessing
chemical risks to children from exposure to toys requires considering
information on the nature of the chemical itself, the actual use of the product
and the characteristics of the population or populations of concern in order to
establish an expected range of effects. (Figure 1) By convention, chemical
risk assessment is
a four part process involving 1) identifying a specific chemical hazard, 2) determining
the amount or dose that causes damage, 3) estimating levels of exposure in the population
at risk, and 4) generating a risk estimate usually expressed as the probability
of adverse health effects from a range of specific exposures to the populations
of concern. For non-cancer causing chemicals, it is generally assumed that
there is a threshold effect, i.e. a level of exposure below which no harm
occurs. There is no threshold assumed
for carcinogens. In general, the
likelihood of cancer occurring is considered proportional to the dose, and
exposures are usually averaged over a 70 year lifetime regardless of when
exposures occur. Regulations are then
set in the case of carcinogens to prevent excess cancers above a level set by
authorities, and in the case of non-carcinogens to hold exposures below the
theoretical threshold level causing disease.
When assessing chemical risks for children, however, additional issues
must be considered.[vii] The
traditional emphasis on dose may be inadequate without also considering the
timing of the exposure with respect to critical windows of development. For example, recent data suggest that the
relative importance of early life-stage exposures to later disease, both cancer
and non-cancer, may be disproportionately large for some chemicals.[viii] This may require additional
"weighting" of chemical exposures during childhood, rather than a
simple averaging. In some cases there is
an additional uncertainty factor added for children. The assumption that
non-cancer adverse health outcomes exhibit threshold behavior is called into
question when toxicities associated with early lifestage exposures are
considered. An example of this is the failure to demonstrate a true threshold
to the developmental neurotoxicity of lead poisoning in children.[ix] These examples illustrate the complexities
involved in attempting to assess and mitigate risks, particularly non-acute
risks, to children from chemicals in toys.
When considering the toxic potential of a chemical used in a toy, it
should be within the context of the benefits of using that same chemical, as
well as the suite of alternatives to that use, i.e., changes in toy design and
the use of alternatives.
[i] Reed KJ, Jimenez M, Freeman NCG,
Lioy PJ. Quantification of children's
hand and mouthing activities through videotaping methodology. J Exposure Analysis Environ Epidemiol
1999:9;513-520.
[ii] Koneman WH. Phthalate release from soft PVC baby
toys. Report from the DUtch Consensus
Group. RIVM report 613320 002. September 1998.
[iii] Greene M. Report to CPSC. Mouthing Times of Young
Children from Observational Data. Page
16-48. June 2002. Available at http://www.cpsc.gov/LIBRARY/FOIA/FOIA02/brief/Fiveyearpt4.pdf
Accessed 24 May 2006
[iv] Bouma K, Schael DJ. Migration of phthalates from PVC toys into
saliva stimulant by dynamic extraction.
Food Additive Contaminants 2002:19;602-612.
[v] Santillo, D.,
Johnston, P. & Singhofen, A. (1999). Critique of the validation studies
conducted to date of in vitro methods for determination of leaching rates of
phthalates from PVC toys (conducted by TNO and LGC), and of the in vivo study
underlying the validation of the Dutch methodology (as conducted by RIVM).
Submitted to the EU Scientific Committee for Toxicity, Ecotoxicity and
Environment. Greenpeace Research Laboratories Technical Note 02/99, September
1999. Available at http://www.greenpeace.to/publications_pdf/CSTEE%202001%20comments.PDF Accessed 6 June 2006
[vi]Santillo, D., Johnston, P. &
Stringer, R. (2001). Comments on the opinion expressed by the CSTEE regarding
the report "Validation of methodologies for the release of
diisononylphthalate (DINP) in saliva simulant from toys (2001 EUR 19826
EN)". Greenpeace Research Laboratories Technical Note 09/2001, July 2001:
4 pp. Available at http://www.greenpeace.to/publications_pdf/cstee%20critique.PDF Accessed 6 June 6,
2006
[vii] IFCS FCS Working Group Chaired by Hungary. Protecting Children from Harmful Chemical
Exposures; Chemical Safety and
Children's Health. IFCS/FORUM-IV/11 INF
7 October 2003. Available at http://www.who.int/ifcs/documents/forums/forum4/en/11inf_en.pdf Accessed 13 May 2006
[viii] IFCS FCS Working Group Chaired by Hungary. Protecting Children from Harmful Chemical
Exposures; Chemical Safety and
Children's Health. IFCS/FORUM-IV/11 INF
7 October 2003. Available at http://www.who.int/ifcs/documents/forums/forum4/en/11inf_en.pdf Accessed 13 May 2006
[ix] Canfield RL,
Henderson CR Jr, Cory-Slechta DA, Cox C, Jusko TA, Lanphear BP. Intellectual impairment in children with
blood lead concentrations below 10 microg per deciliter. N Engl J Med.
2003:348(16);1517-1526.
[i]IFCS FCS Working Group Chaired by Hungary. Protecting Children from Harmful Chemical
Exposures; Chemical Safety and
Children's Health. IFCS/FORUM-IV/11 INF
7 October 2003. Pg 6-7. Available at
http://www.who.int/ifcs/documents/forums/forum4/en/11inf_en.pdf Accessed 13 May 2006
[ii]
Stringer R, Labunska I, Santillo D, Johnson P, Siddorn J, Stephensen A. Concentration
of phthalate esters and identification of these additives in PVC children's
toys. Environmental Sci Pollution Res
2000:7(1);27-36.
[iii] Hubal EAC, Sheldon LS, Burke JM,
McCurdy TR, Berry MR, Rigas ML, Zartarian VG, Freeman NCG. Children's exposure assessment: A review of factors influencing children's
exposure, and the data available to characterize and assess that exposure. Environ Health Perspect 2000:108;475-486.
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