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The threshold

Same metal, two thresholds

By Dwight Davis, Founder

On this page11
A factor of about twenty eight. And the substance is identical.

Two federal provisions in this library set a limit on lead

One is the paint ban at 0.009 percent of the dried film. The other is the definition of lead free for plumbing at a weighted average of 0.25 percent over the wetted surfaces of a fitting, and 0.2 percent for solder and flux.

The gap between them is about twenty eight fold

Same metal, same toxicology, two numbers that are not close to each other. Which is the clearest case in this library of a threshold describing a situation rather than a substance.

The paint figure is about a child and a surface

The Commission found an unreasonable risk of lead poisoning in children associated with lead content in paints and coatings to which children have access. The exposure route is direct contact with a film that can be chewed or shed as dust.

The plumbing figure is about water passing through metal

A fitting is a solid alloy and the exposure is whatever leaches into water crossing its wetted surface. Which is a far less efficient route than a surface a child can put in their mouth.

And the two are measured on different bases as well as at different levels

The paint figure is a proportion of the nonvolatile content or of the dried film. The plumbing figure is a weighted average over an area, so geometry enters one calculation and not the other.

Which means neither number can be used to check the other

A coating that passes the plumbing figure comfortably would breach the paint ban by a factor of nearly thirty. The numbers are not points on one scale.

This is the general lesson and it recurs across these properties

A threshold is not a property of a chemical. It is the output of a judgment about who is exposed, how, and how often, and two rules about the same substance will differ wherever those answers differ.

The paint ban also carries a date rather than a phase in

It applies to products manufactured after February 27, 1978, and the lower figure took effect on August 14, 2009. Two dates, both hard, with no transitional band.

And the scope is drawn by the statutory definition of a consumer product

Which is why paints and coatings for motor vehicles and boats are outside the ban: not because the risk differs but because they fall outside that definition.

So the boundary of this ban is partly jurisdictional

A coating can be identical in composition and inside or outside the ban depending on what it is sold for. Which is the same mechanism the model aircraft exemption uses, applied in the other direction.

References

16 CFR 1303.2(b)(2): "Lead-containing paint means paint or other similar surface coating materials containing lead or lead compounds and in which the lead content (calculated as lead metal) is in excess of 0.06 percent (0.06 percent is reduced to 0.009 percent effective August 14, 2009) by weight of the total nonvolatile content of the paint or the weight of the dried paint film." 16 CFR 1303.1(a) and (c) carry the same parenthetical correction, noting the reduction was "mandated by Congress in section 101(f) of the Consumer Product Safety Improvement Act of 2008". 16 CFR 1303.4 states the ban: paint and similar surface-coating materials which are lead-containing paint, toys and other articles intended for use by children that bear it, and furniture articles that bear it, manufactured after February 27, 1978. law.cornell.edu
Written from 16 CFR part 1303 and from the catalog as it stood on 19 October 2026. Part 1303 bans lead-containing paint and certain products bearing it; it does not govern ballast, couplers, scenery material or static grass, and it does not reach any container on this shelf. Nothing here states the lead content of anything, whether any product is a toy or article intended for use by children, or whether any coating complies with anything, and nothing here is guidance about using, stripping or disposing of paint. This shelf is shared identically by nine groups and the sewing notions property enumerates the inventory.