One of the great puzzles of the CPSIA is its obsession with Children's Products as a focal point in the "war on lead". Okay, I think I am able to perceive that the object of the law is to protect children from certain health hazards (lead, principally) and further, that children use Children's Products which could be the source of those health problems. But no one has explained to me in terms I can understand why Children's Products are "the" problem, or even consistitute a problem at all.
Here's an analogy that comes to mind: Let's say you decide "Enough is enough, I am getting too fat" and resolve to take action by eliminating crackers from your diet. Yes, that nightly snack of brie on crackers is clearly a problem, and no one can deny that the crackers are adding to your weight problem in some way. Eliminating that source of calories must help, almost as a matter of mathematics. How could anyone defend eating crackers anyhow? Isn't it obvious that you would be "safer" from fat if you eliminate crackers from our diet?
Frankly, I have no way of knowing the answer to that question. How could we determine if you will lose weight or even arrest the upward trajectory of your weight if you eliminate the crackers? I doubt crackers, in or out of your diet, will affect your belt line in any way. First of all, the amount of calories you are eliminating is probably immaterial based on your daily intake of food. Second, there is little reason to believe that the crackers are the root of the problem. In fact, it is highly likely that the delicious hot fudge sundae that you enjoy at the end of each dinner, and the loaded baked potato you prefer for lunch, not to mention your constant snacking between meals and lack of exercise, may be more important factors in your ongoing weight problem. If those larger sources of calories are not controlled, crackers or no crackers, you are still fat and getting fatter. If it were very costly for you to eliminate crackers from your diet, is this where you would start your weight loss work? Would crackers be the rational focus of your resources and effort to lose weight?
Are Children's Products "crackers" in the war on lead? Perhaps. It is clear (to me) that the oft-cited 20-year steady decline in blood lead levels is related to environmental issues, like elimination of leaded house paint and leaded gasoline. Other environmental controls, like restrictions on lead-in-paint on consumer products (but not on your car!) and the gradual replacement of lead plumbing pipes, have also contributed to these sharp improvements in lead health. Is there any rational reason to believe that elimination (on a zero tolerance basis) of lead from Children's Products will move the needle in blood level studies? I don't believe it myself. The total mass of lead introduced into the U.S. economy annually via Children's Products is a mere pittance compared to environmental exposure EVEN TODAY.
If Children's Products are an immaterial source of lead (or phthalates, for that matter) and if much more significant sources in daily life are left entirely unaffected by this "groundbreaking" law, what exactly has been achieved? It's just cracker crumbs, in my view.