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RE: Labeling of lead in products

Certain rules of labeling do not require mention of "de minimus" quantities
of lead.  For instance, under the Lead Based Paint Poison Prevention Act,
"lead free" paint must only contain less than 600 PPM.  A TCLP of paint with
600 PPM could show several times the RCRA level for hazardous waste (if the
paint became a waste). 

Other than having the products tested yourself, calling the company's
customer service number is the only way to find out.  And this does not
always work: I called a paint company's customer service number to find out
what they would tell me about their latex house paint.  The representative
told me that latex was lead free and lead free meant lead free until I
insisted on talking to their supervisor who educated the rep.

(On the other hand, lead free paint indicates that the company did not
purposely introduce lead, but it could have gotten contaminated.)

Steve Hillenbrand
Industrial Waste Reduction Engineer
Process & Prevention Services, Tennessee Valley Authority
(423) 632-8489; (423) 632-3616 (fax)
TVA P&PS HomePage  www.tva.gov/orgs/iwr/iwrhome.htm

> ----------
> From: 	Kirsten Koepsel[SMTP:kkoepsel@arrirs04.uta.edu]
> Reply To: 	Kirsten Koepsel
> Sent: 	Friday, November 13, 1998 4:21 PM
> To: 	p2tech@great-lakes.net
> Subject: 	Labeling of lead in products
> Hey guys,
> I have a question regarding the labeling of products that contain lead. I
> have 
> searched on the Internet in OSHA and EPA for this topic and can't seem to
> find 
> any definite information.
> We have a manufacturer that is making a product that contains some lead in
> it 
> (yes, I know that it is hazardous. They have searched for a substitute but
> there 
> is nothing at the current time.). This is a consumer product that goes
> into 
> homes and military bases. Currently it is labeled as to "Keep out of the
> reach 
> of children." There is no labeling anywhere as to the fact that it does
> contain 
> lead.
> In addition, they are shipping the product across the US and possibly
> overseas. 
> Nowhere on the boxes is any mention that the product contains lead.
> What I am looking for is what are the labeling requirements for lead?
> What reporting requirements do they have- with the EPA or OSHA? 
> Thank you.
> Kirsten Koepsel
> Kirsten M. Koepsel
> Texas Manufacturing Assistance Center
> 7300 Jack Newell Blvd., South
> Fort Worth, TX  76118
> 817-272-5925
> 817-272-5977 (fax)
> kkoepsel@arri.uta.edu (e-mail)