Toxic Toys "R" Us: PVC Toxic Chemicals in Toys and Packaging — A Report to the National Commission of Inquiry into Toxic Toys

Overview

This 47-page Center for Health, Environment & Justice (CHEJ) PVC Campaign and Teamsters Office of Consumer Affairs report, authored by Michael Schade (CHEJ PVC Campaign Coordinator) with X-ray fluorescence (XRF) toy and packaging testing performed by Jeff Gearhart of the Ecology Center (Ann Arbor, MI) and a Statement of the National Commission of Inquiry into Toxic Toys, evaluates whether Toys “R” Us has kept its February 15, 2008 corporate pledge “to phase out the sale of toys containing lead or phthalates, reduce the sale of PVC-containing products and offer more PVC-free products.” The investigation conducted two rounds of handheld portable XRF screening: a first round in June 2010 on nine licensed-film-tie-in toy items and seven of their packaging materials purchased at a single Toys “R” Us retail store in Ann Arbor, Michigan, and a second, broader round in Fall 2010 on 60 randomly selected toys, children’s and infant products and 44 of their packaging materials purchased at a Toys “R” Us in Rockville, MD and a Babies “R” Us in Silver Spring, MD. Chlorine (Cl) was used as a surrogate for the presence of polyvinyl chloride (PVC) and tin (Sn) was used as a surrogate for the presence of organotin stabilizers; lead (Pb) and cadmium (Cd) were measured directly as additive chemicals of concern. The report finds that, 33 months after the 2008 corporate pledge, 72.5% of 69 retail-purchased toys/children’s products contained chlorine indicative of PVC, 20.3% contained tin indicative of organotin stabilizers, 5.8% contained low levels of Pb and 1.4% contained low levels of Cd; 52.9% of 51 packaging materials contained chlorine indicative of PVC, 52.9% contained tin, 5.9% contained Pb and 0% contained Cd; and only 1 of 60 Fall 2010 products carried any PVC-content labeling visible to consumers at point of purchase. The Commission, the report, and the recommendations frame the findings as a regulatory-policy event (Toxic Substances Control Act reform; CPSC labeling regulation) rather than as a per-brand consumer-ranking document. This page records the XRF screening findings as occurrence data for toy and toy-packaging product categories; HMTc threshold-setting is not addressed and is out of scope per Part 2.

Key numbers

Sampling frame (pp. 7, 20, 23, Tables 1–6)

Total XRF-scanned sample units: 120 across two rounds. 69 toys/children/infant products + 51 packaging materials.
Round 1 sample frame (Toys “R” Us, Ann Arbor, MI; purchased June 15, 2010): 9 licensed-film-tie-in toy items and 7 of their packaging materials (Tables 1, 2).
Round 2 sample frame: 52 products purchased from a Toys “R” Us in Rockville, MD on August 31, 2010 + 8 products purchased from a Babies “R” Us in Silver Spring, MD on September 6, 2010 = 60 products; 44 of those products had their packaging analyzed (Tables 3, 4, 5, 6).
Product-type composition of Round 2 (n=60), Table 4: Infant & Baby Feeding 4; Bath Time 11; Animal 7; Dramatic Play 3; Ball 5; Doll 8; Figurine 22.
Age-target composition of Round 2 (n=60), Table 5: 3-to-12 months and up 15; 18-to-36 months and up 32; 4-to-6 years and up 13.
Country of manufacture (Fall 2010): 98% of toys made in China (p. 9).
Per-element observed XRF limits of detection (LODs), Appendix A: Pb 5 ppm; Cd 61 ppm; Sn 130 ppm; Sb 109 ppm; Cl 2.80%; arsenic (As) 1 ppm; chromium (Cr) 39 ppm; mercury (Hg) 7 ppm; nickel (Ni) 27 ppm; Cu 38 ppm; Co 37 ppm; Br 2 ppm.

Combined occurrence (Chapter 4 Discussion, pp. 32–33)

Chlorine (PVC indicator) in toys/children’s products: 72.5% (50/69).
Tin (organotin indicator) in toys/children’s products: 20.3% (14/69).
Lead in toys/children’s products: 5.8% (4/69).
Cadmium in toys/children’s products: 1.4% (1/69).
Chlorine (PVC indicator) in packaging: 52.9% (27/51).
Tin (organotin indicator) in packaging: 52.9% (27/51).
Lead in packaging: 5.9% (3/51).
Cadmium in packaging: 0% (0/51).

Round 1 toy results (Toy Story 3 tie-in cohort, June 2010, Table 1; concentrations ppm)

Round 1 toy n = 9. Chlorine >LOD in 77.8% (7/9); range 73,889 to 550,000 ppm. Two items below the chlorine LOD (a sheriff-figure lasso accessory and a water-blaster gun) (Table 1).
Round 1 toy tin >LOD: 0/9.
Round 1 toy Cd >LOD: 1/9 (11.1%). A sheriff-figure plastic lasso accessory measured at 71 ppm Cd.
Round 1 toy Pb >LOD: 1/9 (11.1%). A purple-and-white water-blaster gun component measured at 11 ppm Pb.
Doll hair (a Barbie-format figurine, named in the source as a licensed-character product) measured at 550,000 ppm Cl — the XRF upper-reporting limit for chlorine (Table 1).

Round 1 packaging results (n=7, Table 2)

Chlorine >LOD: 100% (7/7) at 550,000 ppm (the XRF Cl upper-reporting bound) on every packaging sample.
Tin >LOD: 100% (7/7). Range 980 to 2,359 ppm; max on a figurine-toy packaging in the Round 1 tie-in cohort.
Pb >LOD: 0/7. Cd >LOD: 0/7.

Round 2 toy results (Fall 2010, n=60, Table 3)

Chlorine >LOD: 71.7% (43/60) indicating PVC.
Tin >LOD: 23.3% (14/60) indicating likely organotin stabilizer use.
Of tin-positive toys, 85.7% (12/14) also contained high chlorine, indicating tin co-occurs with PVC.
Pb >LOD: 5% (3/60). Per-item values from Table 3:
- A robotic hamster-toy fur-covered exterior component (Round 2): 9 ppm Pb.
- A baby-feeding table-topper orange-plastic placemat (Round 2): 12 ppm Pb.
- A stretchy-dragon animal toy underside (Round 2): 51 ppm Pb.
Cd >LOD: 0% (0/60).
Highest Cl values in Round 2 (Table 3): 550,000 ppm (XRF Cl upper bound) on a licensed-character reach-for-the-stars tote bag (flesh-coloured face component), a mini soccer ball (white section), and a “Baby on the Go” generic tote bag.

Round 2 toy results by product type (Table 4, % >LOD)

Product type	n	% Cl (PVC indicator)	% Sn (organotin indicator)
Infant & Baby Feeding	4	25%	0%
Bath Time	11	91%	9%
Animal	7	29%	14%
Dramatic Play	3	0%	0%
Ball	5	60%	0%
Doll	8	87.5%	0%
Figurine	22	95%	50%
All Round 2 product types	60	71.7%	23.3%

Round 2 toy results by age group (Table 5, % >LOD)

Suggested toy age group	n	% Cl (PVC)	% Sn (organotin)
3 months and up to 12 months and up	15	67%	7%
18 months and up to 36 months and up	32	81%	19%
4 years and up to 8 years and up	13	62%	46%

Age groupings as labeled on the toy packaging.

Round 2 packaging results (n=44, Table 6)

Chlorine >LOD: 45.5% (20/44) indicating PVC packaging.
Tin >LOD: 45.5% (20/44) indicating likely organotin stabilizer use.
Of tin-positive packaging, 95% (19/20) also contained high chlorine, indicating tin co-occurs with PVC packaging.
Pb >LOD: per p. 31 Summary, “6.8% (3/33)” of toy packaging materials contained low levels of lead. Per-item values from Table 6: a princess-figurine purple cardboard packaging 11 ppm Pb; a baby-bath inflatable-tub green cardboard packaging 20 ppm Pb; a barnyard-playset green cardboard packaging 28 ppm Pb. The 3/33 denominator on p. 31 differs from the 3/51 combined denominator on p. 33 and from the implied 3/44 denominator of the Round 2 packaging cohort; see Verification notes.
Cd >LOD: 0% (0/44).

Labeling discipline (pp. 8, 32)

Of the 60 Fall 2010 products tested, only 1 of 60 was labeled as containing PVC, and that label was hidden under the cardboard packaging and visible only after purchase.
None of the products tested were labeled as containing organotins, lead or cadmium.
91% of toy packaging carried no markings or labels that would let a consumer identify the plastic type. Only 2 of 51 packaging samples carried a PVC marking, and both markings were on the bottom of the package, hard to see, and required extensive inspection.

Methods (brief)

Sampling. Round 1: nine licensed-film-tie-in toy items and their seven packaging components purchased at a single Toys “R” Us retail store in Ann Arbor, MI on June 15, 2010 (the “newest merchandise from a well-known brand to come onto market” at the time of testing). Round 2: 52 toys/children/infant products purchased at a Toys “R” Us in Rockville, MD on August 31, 2010 plus 8 from a Babies “R” Us in Silver Spring, MD on September 6, 2010, with 44 of their packaging components also analyzed. Purchases shipped to the Ecology Center, Ann Arbor, MI for analysis.

Instrument. Handheld portable X-ray fluorescence (XRF) analyzer manufactured by Innov-X Systems, Inc. (model not stated by name; LODs reported as “InnovX Model ABC XRF Detector detection estimates”). XRF is the screening technique used by the EPA for packaging, by the FDA for food, and by state/county health departments for residential lead paint.

Calibration. XRF machines were calibrated at the beginning of each round of sampling using a stainless steel clip and the EC681 reference standard, each with a 60-second test length. During testing, a standardization was taken after every 200 readings using both the stainless steel clip and the EC681 standard. One-time standardization was performed with Wako Chemical USA ABS discs containing cadmium, chromium, and lead at high and low concentrations (NMIJ CRM 8106-a and NMIJ CRM 8105-a) and with PVC disk standards (low and high concentrations).

Testing protocol. Standard testing time 30 seconds per component. Only one reading per material/color/component per product was taken; the analyzer was held perpendicular to the product without compressing the material; tests were taken on the flattest part of the product; products were not dismantled to test interiors. Up to 25 elements analyzed per sample. The highest detected level for each chemical of concern was reported per product as a whole regardless of how many components the product contained.

Detection limits. Observed XRF LODs (30-second sample): Antimony 109 ppm; Arsenic 1 ppm; Bromine 2 ppm; Cadmium 61 ppm; Chlorine 2.80%; Chromium 39 ppm; Cobalt 37 ppm; Copper 38 ppm; Lead 5 ppm; Mercury 7 ppm; Nickel 27 ppm; Tin 130 ppm. Manufacturer LODs are based on 1- to 2-minute test times at 99.7% confidence (3-sigma); the 30-second observed LODs are the lowest values seen across all testing.

QA/QC. Repeat samples taken once every 200 samples and for at least one product in every product category in three modes: (1) three readings from the same sampling location of one product, (2) three readings from three different sampling locations consisting of the same material/color on the same product, (3) three readings from the same sampling location on three different but identical products. All repeat data recorded and submitted for review.

Spectral interpretation. Concentrations reported by the analyzer were combined with visual examination of the spectra. Elements with known interferences (lead, bromine, arsenic) were visually confirmed in the spectrum before being reported. Where presence could not be confirmed from the spectrum, the element was not reported.

Sample matrix. Because the X-ray penetrates approximately ¼ inch into plastics and softer substrates, all measurements are surface or near-surface measurements. When materials within a single product are not homogenous and the test cannot isolate a single material, the reported levels may represent an averaging of the levels in the different materials. Interferences between Pb and As are noted as a precision-limiting factor.

Surrogate-element reasoning. High chlorine is treated as a surrogate for the presence of PVC because PVC is the only common plastic made with chlorine. Tin is treated as a surrogate for the presence of organotin stabilizers because organotins are the principal Sn-bearing additive in PVC. Phthalates were not tested because phthalates cannot be detected by XRF.

Implications

Toy and toy-packaging occurrence data (regulatory baseline). The dataset documents that, at the Fall 2010 retail snapshot, ≈72% of retail-purchased toys/children’s products at the two major specialty retailers in the Toys “R” Us / Babies “R” Us network contained PVC by chlorine-surrogate measurement and ≈20% contained organotin stabilizers by tin-surrogate measurement. Substrate Pb >LOD was found in 5.8% of toys and 5.9% of packaging at the XRF 5-ppm LOD; the maximum reported substrate Pb in either toys or packaging was 51 ppm. By the August 2011 Consumer Product Safety Improvement Act (CPSIA, Pub. L. 110-314) Section 101 substrate-Pb limit of 100 ppm, no item in this dataset would have exceeded the federal substrate-Pb content limit (a substantial reduction relative to the 1996-1997 Greenpeace baseline reported in Lead and Cadmium in Vinyl Children's Products: A Greenpeace Exposé where 24/28 Pb-positive Chicago items exceeded 200 ppm). The dataset contributes occurrence evidence supporting the “lead-down, organotin-up additive-substitution” narrative for the post-CPSIA toy supply chain.
HMTc audit implications (Part 2 firewall observed). This page reports the XRF surrogate-occurrence findings as the source describes them. It does not propose HMTc certification levels for toys, toy packaging, sippy-cup tableware, or bibs, and it does not endorse the report’s policy recommendations (TSCA reform; CPSC labeling regulation). For HMTc threshold-setting on toy and toy-packaging categories, this report contributes surrogate-occurrence baseline data on retail-availability of PVC and organotin stabilizers as of Fall 2010; it does not contribute migration or exposure values, and the per-item Pb and Cd values are at or near the XRF LOD and should not be treated as quantitative substrate concentrations.
App. Not directly relevant to ingredient contamination_profile data because no food-matrix occurrence values are reported. Relevant to a future children’s-article-screening surface that flags retail product categories likely to contain PVC and organotin stabilizers (figurines, bath squirt toys, and bath time toy categories all >85% PVC by chlorine surrogate in this dataset).
Courses. Useful primary document for the regulatory-history teaching module on the 2008 CPSIA Section 101 substrate-Pb content limit and the post-CPSIA additive-substitution dynamic (lead → organotin); for the methods module on portable-XRF screening as a regulator-accepted surrogate technique with documented LOD, calibration, and reference-standard discipline; and as a case study in the gap between corporate phase-out pledges (Toys “R” Us 2008 pledge to reduce PVC use) and retail-shelf reality (≈72% PVC by chlorine surrogate 33 months post-pledge).

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