Leveling with Labels
Conventions Pt 2: The Art Show
August 2006; Water
Heraldry, Pt 4: Charges
Leveling with LabelsHealthy Green Artists
by Janet Chui
I have to admit, when I first proposed this column for EMG-Zine, I wondered if I would have enough material to concentrate solely on health and environmental concerns for artists for one, or possibly two, years. But every time I embark on the research for a new column, I wind up pulling at my hair wondering if the topic I had bitten off for the month was more than I could chew. This seemed to apply doubly for subjects I would think were "easy."
Safety labels are now the latest items in the history of this column to whap this author with the "It's not as simple as it looks" paddle.
If you like, read this column with easy access to all the traditional art materials you own, like paints, markers, solvents, and dry media including pencils and wax crayons. (Digital artists, you can breathe a little easier this month.) We're looking closer at safety labels, what they mean, and what they do NOT say that can harm you. We can get a little more interactive if you pick up your various materials and read them at the same time you're going through this article.
The Consumer Product Safety Commission is the US governmental body that enforces the Federal Hazardous Substances Act and the Labeling of Hazardous Art Materials Act (more on these later). CPSC defines three categories of art materials thus:
1. Those products which actually become a component of the work of visual or graphic art, such as paint, canvas, inks, crayons, chalk, solder, brazing rods, flux, paper, clay, stone, thread, cloth, and photographic film.All art materials that fall into the first two categories are the ones we'll be covering today, and by an amazing stroke of coincidence they are the ones the Commission requires to have labels indicating their potential to have acute and/or chronic health effects on their users.
The Federal Hazardous Substances Act (FHSA) has existed since the 1960s--it requires
certain hazardous household products ("hazardous substances") to bear cautionary labeling to alert consumers to the potential hazards that those products present and to inform them of the measures they need to protect themselves from those hazards. Any product that is toxic, corrosive, flammable or combustible, an irritant, a strong sensitizer, or that generates pressure through decomposition, heat, or other means requires labeling, if the product may cause substantial personal injury or substantial illness during or as a proximate result of any customary or reasonable foreseeable handling or use, including reasonable foreseeable ingestion by children.
Got a can of air-propelled fixative, varnish, or plain old spray paint? Anything that just plain smells bad and you know would be an extremely Bad Idea to swallow? The FHSA is responsible for making these products (typically varnishes, fixatives and spray paint) carry the labels "Danger!", "Warning", and "Caution". It is responsible for making sure the products carry instructions (sometimes present in all caps) that artists use them with adequate ventilation, to avoid skin contact, and not swallow the contents--or the results are HARMFUL TO THE RESPIRATORY TRACT AND NERVOUS SYSTEM OR MAY BE FATAL. (It should go without saying these products should always be kept out of the reach of children. Some of the ingredients should also be a concern to pregnant moms.)
If you think you cannot avoid a product that bears any of the three labels, always read and the follow the instructions for use. While shopping for these materials, try to keep in mind that each word carries a different level of danger to one's health. "Danger!" is at the top of the list and the most hazardous. Next up is "Warning". "Caution" is the least scary but still means the product should be handled with care. In fact, if you do not need a product bearing these warning labels, avoid buying them. It will decrease the risks of an unfortunate accident in the studio and eliminate your need to find a recycling center that disposes of toxic and hazardous products later.
The health concerns related to art materials cannot (and should not) end with acute health effects that occur during or immediately after contact with hazardous substances. (Hey, I dreamt up this column to cover the more hidden and chronic health effects from artmaking!) Let's now tackle the label that deals with long term health effects like cancer, respiratory, and nerve and brain damage. In the realm of chronic health hazards, artists in the UK and US can be grateful for the Labeling of Hazardous Art Materials Act (LHAMA).
LHAMA applies to paints, spray paints, solvents, crayons, colored pencils, glues, adhesives, putties, and other products sold for art, craft, and model-construction purposes. (It does not cover similar materials sold for household and construction uses, so bear this mind if you are actually using items typical from say, Home Depot, or your local DIY store for artmaking.) LHAMA is responsible for the label on your art material that says "Conforms to ASTM D4236" or anything similar. (Do not ever be tempted to buy any art materials that do not have this line on its original packaging!)
Here's a little more information about the most typical LHAMA labels or seals you'll see before we cover the LHAMA's shortfalls:
ASTM (as part of "ASTM D4236") refers to The American Society for Testing and Materials. It is an association of worldwide industry representatives, scientists and engineers who formulate voluntary standards for quality and safety. D4236 refers to their document that sets the Standard Practice for Labeling Art Materials for Chronic Health Hazards. When researching specific art materials, you may see references to other, additional ASTM standards that a product manufacturer may voluntarily conform to.
ACMI stands for the The Art & Creative Materials Institute, Inc. and is an international non-profit association with a membership composed of over 200 art and creative materials manufacturers. (And it only invites membership from manufacturers.) ACMI offers certification for products that conform with ASTM D4236. ACMI Manufacturers desiring the ACMI seals (either "AP" or "CL") submit formulas for their products to the ACMI certification program. ACMI works with a toxicology team at the Duke University Medical Center, and the formula is evaluated using current scientific information available about the ingredients.
AP (Approved Product) Seal identifies art materials that are certified by a toxicologist to contain no materials in sufficient quantities to be toxic or injurious to humans, including children, or to cause acute or chronic health problems. This seal is currently replacing the previous non-toxic seals: CP (Certified Product), AP (Approved Product), and HL Health Label (Non-Toxic).
The CL (Cautionary Label) Seal identifies products with toxic substances but deemed as "tested" and appropriate for adult use when it is labeled with warnings and safe use information. It replaces the HL Health Label (Cautions Required) seal.
The main distinction between AP and CL is that CL products should definitely be kept out of the hands of children--not only because the young ones may not follow the instructions for safe use, but because their higher metabolisms and immature organ immune systems could mean the toxic substances will affect them more severely.
But the AP seal and even the words "Non-toxic" cannot gaurantee complete safety for children and adults, and this is where I'm going to tackle the shortfalls of LHAMA, FHSA, and ACMI at the risk of receiving angry retorts. "Non-toxic" materials, even with the ASTM D4236 label can still cause long-term toxicity. Here's why:
ACMI does not conduct any tests for the long term effects of any products on child or adult health. If you read carefully earlier, the certification process only asks requires that the formula submitted does not use ingredients that are known or recognized to be hazardous to the toxicologist doing the certification. (Are your alarm bells ringing yet?) Critics have pointed out that ACMI (which still remains an orgnization mostly of manufacturers) does not publish or provide detailed information on its standards of toxins and toxicity, which makes it difficult to assess how rigorous their standards are. In fact, the danger of phthalates in particular (which I've covered before) is not recognized by ACMI, and has led to a conflict between ACMI and the Vermont Public Interest Research Group. VPIRG found, in their 2002 study Hidden Hazards, that polymer clays leave a significant of phthalates on the hands of children and adults even after washing. Phthalates are also released during the baking process.
(ACMI's reply to the VPIRG's results--which VPIRG obtained from two independent labs-- was unassuring, in this author's opinion. ACMI could not deny the presence of phthalates in polymer clay but it cited the FDA's stance of the unproven toxicty of the phthalates--and the FDA and the politics of its ineffectuality are the subject of a few scholarly books I will recommend outside of this column if asked. Two, for some reason I can't fathom, ACMI's reply seems to muddy waters by bringing up polymer clay's lack of VOCs--volatile organic compounds--and acid gases, which is not related to the hazard of phthalates. If you're further interested in the health hazards of working with polymer clay or clay media, there are books and webpages out there, or watch this space!)
Another failing of LHAMA and ACMI's certification program: It has been pointed out that manufacturers are nowhere required by the existing laws to list all of their ingredients to ACMI or a certifying body. Moreover, ACMI certification does not guarantee that a product (only its submitted formula) has been tested for all contaminants of toxic substances. For instance, in 2000, an independent investigation by the Seattle Post-Intelligencer revealed that some crayons were contaminated with asbestos, even though ACMI had certified the crayons "non-toxic."
And ACMI certification cannot guarantee that a product labeled "non-toxic" is completely free of toxic substances. The "non-toxic" label is basically permitted even when toxic substances are present, but are deemed to be beneath hazardous levels for children. It remains open to question what level of the presence of the substance (especially over a lifetime of cumulative effect from art materials and other substances) is really safe.
At the risk of sounding like a coddling grade-school teacher, let's sum up: the presence of an art material available at your local art supply store cannot be taken as a guarantee that a product is completely safe. At the end of the day, the Consumer Product Safety Commission, only requires that all art materials carry a certain label, not that the product is completely safe. Michael McCann, the author of Artist Beware, estimates that humans are exposed to 20,000 known toxic chemicals, with 500 new chemicals being introduced into the market every year. Most of these new chemicals have never been tested for their long-term effects on the human body. So it's worth keeping up with new findings of the suspected harmful substances around us--and reading this column!
Recommended further reading:What’s on the Label: Art and Hobby Supplies by Allison Sloan
(Children's Health Environmental Coalition)
Choosing Better Art Supplies
Health and Safety in the Arts
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