Lead in paint and coatings

The limit

Paint and similar surface coating materials containing lead or lead compounds in which the lead content is in excess of 0.009 percent of the weight of the total nonvolatile content of the paint or the weight of the dried paint film are banned hazardous products.

How it got there

The limit was 0.06 percent, and it was reduced to 0.009 percent effective 14 August 2009 as mandated by Congress in section 101(f) of the Consumer Product Safety Improvement Act of 2008. An old reference that still says 0.06 percent is reading a superseded figure.

It is a different measurement

0.009 percent is 90 parts per million, and it is measured against the nonvolatile content or the dried film, not against the whole article. Confusing it with the 100 ppm content limit is easy and the error runs in both directions.

And the article itself is banned

The regulation is not limited to the paint. Toys and other articles intended for use by children that bear lead-containing paint are themselves banned hazardous products, as is furniture for consumer use bearing it.

What counts as paint here

Paint and similar surface coating materials. An enamel on a charm, a colored lacquer on a plated finding and a printed detail are all worth treating as coatings until someone with the formulation says otherwise.

Practical consequence for a bead pack

The uncoated parts are a content question and the colored parts are a coating question, and they can be answered by different test methods on different samples. Counting the colored items in a mixed assortment is the first thing to do, because it tells you how many separate questions you have.

References