Thursday, March 26, 2009

CPSIA - Lead and Crackers

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.



Jen said...

Indeed. This law is so convoluted that it’s easy to get caught up in one problem or another related to compliance, and forget the fact that the entire thing makes little sense if public health and safety are truly the goal.

kathleen said...

There are 13 calories and no measurable fat in a saltine cracker. Not only would saltines not cause one to gain weight, they can be effectively used to prevent weight gain if used as a light snack substitute.

This is not to suggest of course that by analogy, children's products per se could prevent environmental lead absorption but in these crazy days (considering hare-brained claims by uspirg et al), one could make that argument. If a kid is sucking on a pacifier, he can't be eating paint chips.

Wacky Hermit said...

Kathleen wrote: "There are 13 calories and no measurable fat in a saltine cracker. Not only would saltines not cause one to gain weight, they can be effectively used to prevent weight gain if used as a light snack substitute."

With all due respect, the crackers themselves are not usually the problem. The problem is the cheese or the peanut butter that you put on them, or the cream soup that you put them in, or the sheer number of them you put in your mouth. Even at 13 calories apiece, 50 crackers is still 650 calories.

I wish our elected officials had taken that last point and considered that in order to ingest a large enough amount of lead to drop a detectable number of IQ points, a child would have to eat the whole damn library.

Lora said...


only Spock has ears with which to hear such logic.

Louise-OSET said...

Once again, well said!
Our house was bulit in 1896. Two paint layers down is lead paint.
The water supply line to the house along with most of metro Denver's supply lines are made of lead.
It is more dangerous for my kids to touch a windowsill, or drink a glass of water than it is to touch their motorbikes.
So is the Government offering a lead abatement program for our house?
No, it bans our bikes instead.