The Consumer Product Safety Commission did the right thing last week in ruling rubber duckies and other vinyl toys pose "no demonstrated health risk" to children. This should end a long-running controversy contrived by environmental extremists.
"Consumers may have a high level of assurance that soft plastic products pose no risk to children," said Commissioner Mary Sheila Gall following a unanimous vote by CPSC commissioners.
Vinyl toys are made from polyvinyl chloride (PVC), softened by the chemical diisononyl phthalate (DINP). DINP has been used for more than 50 years in applications such as flooring, wall coverings, carpet backing, cable sheathing and toys. There are no reports of harm caused by DINP in commercial products.
Despite this track record of safety, the National Environmental Trust, Greenpeace, Physicians for Social Responsibility and other activist groups petitioned the CPSC in November 1998 to "ban polyvinyl chloride from all toys and products intended for children five years of age and under and to issue a national advisory on the health risks that have been associated with PVC toys and products."
The ostensible reason for the requested ban — we’ll get to the real reason later — was the alleged risk of liver and kidney damage to children exposed to DINP by mouthing PVC toys.
In December 1998, the CPSC released the results of a preliminary study of DINP concluding, "few, if any, children are at risk of liver or other organ toxicity from mouthing teethers, rattles, and other PVC toys that contain DINP."
Still, the CPSC said further study was desirable, and convened a special panel to study DINP in toys.
The special panel’s three-year review concluded, "there may be a DINP risk for any young children who routinely mouth DINP-plasticized toys for 75 minutes per day or more. For the majority of children, the exposure to DINP from DINP-containing toys would be expected to pose a minimal to non-existent risk of injury." The panel also concluded DINP posed no risk of cancer or reproductive and developmental harm.
CPSC staff then conducted a behavioral observation study to better quantify DINP exposure to children.
One hundred sixty-nine children between the ages of 3-36 months were studied by trained observers for two hours on each of two days. The average daily mouthing time of soft plastic toys for children 12-24 months of age (the age group with the highest mouthing time) was 1.9 minutes per day — well below the 75 minutes per day that the special panel indicated might be of concern.
CPSC staff also conducted a hypothetical "worst-case" analysis involving pacifiers, which have the highest mouthing times of any toys. The staff assumed pacifiers contained DINP — they currently do not — and that the pretend-DINP migrated out of the pacifiers at the same extremely low rate as observed in soft plastic toys.
In this worst case analysis, even at the 99th percentile of exposure, the acceptable daily intake of DINP for a child would not be exceeded.
The staff concluded, "Since children mouth other products even less than they mouth toys and dermal penetration is expected to be minimal, [we] do not believe they would pose a risk to children five years of age and under."
The irony of the controversy is that the Greens aren’t really concerned about DINP or children’s health at all. The attack on DINP is simply a tactical ploy to advance the Greens’ broader war against the element chlorine — a key ingredient in the production of innumerable consumer products, including PVC.
The Greens previously have tried unsuccessfully to scare the public about other PVC ingredients. They try these roundabout attacks because the direct assault on chlorine has failed.
The Greens have wanted to ban the industrial use of chlorine since at least 1994. They nearly convinced the Clinton administration to support a legislative proposal to that effect.
But even the activist-friendly Clintonites realized the foolhardiness of banning chlorine.
About 12 million tons of chlorine are produced in North America annually for use in manufacturing other important chemicals, pharmaceuticals and plastics; pulp and paper bleaching; and drinking water purification and wastewater disinfection.
Chlorinated drinking water is generally acclaimed as one of the greatest advances in public health of the 20th century.
A chlorine ban would risk public health and cost consumers more than $90 billion per year for alternative products and process — with no guarantee of equivalent performance or quality, according to the Chlorine Chemistry Council.
When the Greens filed their November 1998 petition to ban PVC in toys, Newsweek headlined its story, "Vinyl Ducky, Out of Lucky." An updated headline based on 5 years of review might read, "Vinyl’s ducky, Greenies yucky."
Steven Milloy is the publisher of JunkScience.com, an adjunct scholar at the Cato Institute and the author of Junk Science Judo: Self-defense Against Health Scares and Scams (Cato Institute, 2001).