🚀 go-pugleaf

                     CONSUMER PRODUCT SAFETY COMMISSION
                            STAFF RECOMMENDATIONS
                 FOR  IDENTIFYING AND CONTROLLING LEAD PAINT
                       ON PUBLIC PLAYGROUND EQUIPMENT
                                       
                              EXECUTIVE SUMMARY

     Testing by the U.S. Consumer Product Safety Commission (CPSC) and
some state and local jurisdictions has shown that many school, park,
and community playgrounds across the United States have metal and
wooden playground equipment that presents a potential lead paint
poisoning hazard primarily for children six years old and younger.

     CPSC testing revealed that some equipment was painted with lead
paint, and over time, the paint has deteriorated into chips and dust
containing lead. The lead paint chips and lead dust may be ingested by
children six years old and younger who put their hands on the
equipment while playing, and then put their hands in their mouths. 
Older children and adults are less likely to be at risk because they
generally do not exhibit this same behavior.

     Ingestion of lead paint is a major source of lead poisoning for
children six years old and younger.  Deteriorating lead paint in homes
is the leading cause of lead poisoning in children.  The health
effects of lead ingestion are cumulative.  In children, behavioral
problems, learning disabilities, hearing problems, and growth
retardation have been associated with sustained blood lead levels as
low as 10 micrograms per deciliter (ug/dl).  

     The CPSC has tested the paint for lead on public playground
equipment from 26 playgrounds in 13 cities across the United States.
We found that equipment from 16 playgrounds in 11 cities had equipment
with lead levels that exceed the amount used by the federal government
(0.5 percent by weight) to determine lead hazards most in need of
control measures.  

     The 0.5 percent level was set by the U.S. Congress in 1992 when
it enacted the Residential Lead-Based Paint Hazard Reduction Act. This
act was designed to focus attention and resources on hazards with the
highest levels of lead.  Nationally, efforts to reduce lead hazards
are aimed at controlling lead-based paint hazards at, or above, the
0.5 percent level in Title X of the Act. 

     CPSC's own regulations ban the sale of paint containing in excess
of 0.06 percent or more lead intended for consumer use.  However, in
providing advice on controlling lead hazards from playground
equipment, CPSC is using the 0.5 percent lead level since it is
generally used by the Environmental Protection Agency (EPA) and the
Department of Housing and Urban Development (HUD) in making decisions
on controlling the most significant lead paint hazards.  
 
     In addition to CPSC's own findings, paint on playground equipment
from 223 playgrounds in 19 additional cities was tested for lead by
state and local authorities or television stations doing news stories
on lead hazards.  Of those playgrounds, 125 of them in 11 cities were
reported to have lead paint ranging from 0.09 percent to 29 percent
lead by weight.


                                 HEALTH RISKS

     The CPSC, the Centers for Disease Control and Prevention, the
EPA, HUD and other federal agencies, state that sustained blood lead
levels above 10 micrograms/deciliter (ug/dl) are a health concern. To
prevent young children from exceeding the 10 ug/dl blood lead level of
concern,  CPSC staff suggests that chronic ingestion (represented as
15-30 days) of lead from paint and other consumer products not exceed
15 ug of lead/day.
 
     Based on the playground equipment tested, CPSC determined that if
a child ingested as little as one tenth of a square inch of paint
(about the amount that would fit on the tip of a pencil's eraser)
daily for about 15-30 days, his or her blood lead levels would be at
or above the amount the Federal government considers a health concern. 
This figure is based on the median level of lead found on the
playground equipment tested (1.47 percent) and assumes that the
child's body would absorb 30 percent of the lead in the paint he or
she ingested.

                          CPSC STAFF RECOMMENDATIONS

     To reduce the risk of childhood lead poisoning, the CPSC staff
recommends the following strategy for identifying and controlling the
lead paint hazards associated with older painted metal and wood
playground equipment.  

     The appropriate control measures for this hazard must be
determined on a case-by-case basis, considering such factors as:  the
condition of the paint; the percent of lead present; the playground
equipment's age, location, use, condition, and overall safety; the
availability of financial resources for this and other lead paint
hazards; the relative costs of control measures; and the regulatory
requirements of individual states, cities, and localities.

A. Lead Hazard Assessment

     A lead hazard assessment for playground equipment may include a
visual inspection, examination of records, paint testing,
characterization of the hazard, identification of potential control
measures, and a plan for setting priorities for the implementation of
control measures.

     1)   Conduct a visual inspection of the playground and the
          equipment.
          Look for areas of paint that are cracking or peeling.
          Special attention should be paid to equipment that was
          installed prior to 1978 when the CPSC's ban on lead paint
          went into effect.

     2)   Evaluate the results of the visual inspection. 
          A. If the paint is intact and in overall good condition,
          authorities can either continue to monitor the condition of
          the paint, or have it tested to determine if it contains
          lead. Lead paint that is intact and in good condition is not
          believed to be a hazard until it begins to deteriorate. 

          
          B. If the paint is deteriorating, paint samples should be
          collected from several locations on the equipment, giving
          priority to equipment painted or repainted before 1978.

          Note:  Laboratory analysis is the most accurate and
          reliable way to determine the presence and amount of
          lead in a paint sample.  Studies conducted by the CPSC,
          EPA, and HUD indicate that lead test kits do not
          accurately and reliably discriminate between paint with
          lead and paint without lead.

     3)   Evaluate the results of the laboratory tests.

          The appropriate control measures must be determined on a
          case-by-case basis, considering the factors mentioned above
          under "CPSC RECOMMENDATIONS."

          If paint is chipping, peeling or otherwise deteriorating and
          lead leavels are equal to or exceed 0.5 percent by weight,
          priority should be given to controlling this hazard.

          If lead levels are between 0.06 percent and 0.5 percent,
          owners/managers of playgrounds may consider control
          measures.

B.   Controlling the Lead Hazard

Priority should be given to controlling deteriorating lead paint on
public playground equipment containing lead in amounts equal to or
exceeding 0.5 percent by weight.  Because playground equipment is used
by children, permanent control measures are recommended.  Permanent
measures include replacement of the equipment painted with lead paint,
or removal of the lead paint from the equipment. Continued monitoring
(visual inspection) may be an appropriate control measure for intact
paint even if that paint contains lead.

Interim control measures may be appropriate if the playground is
slated for repair or the equipment is expected to be replaced within a
few years.  Interim measures include covering the paint with nonleaded
paint or an encapsulant.

CPSC has made information available on several cities which have
already dealt with lead paint on playgrounds in an appendix attached
to the full report.

NOTE:  If you would like a copy of the full report, please call the
CPSC Hotline at (800) 638-2772 or visit the CPSC Web site on the
Internet at http://www.cpsc.gov, go to "What's Happening" and look at
the first bullet.

bclee@access.digex.net     brian.lee@iaibbs.org
Miscellaneous Et Cetera    Potomac, MD  USA