Invited Perspective: Why Aren’t We Doing More to Ensure Consumer Products Are Free of Lead?

Numerous case reports and news bulletins, as well as a few carefully completed studies,^1–2 demonstrate time and again that certain consumer products remain potential sources of lead exposure. Ever since its first issue in May 1936, the consumer product testing and advocacy group Consumer Reports (previously known as Consumers Union) has highlighted dangerous levels of lead in the marketplace (Figure 1).³ From cinnamon and applesauce to stainless steel cups, vinyl backpacks, and beaded jewelry, recent headlines suggest that the lead problem is far from over.^4–8

Regulatory limits on the lead content in consumer products—such as paint, gasoline, food packaging, and toys—have contributed to successful efforts by federal agencies to lower blood lead levels in the US population.⁹ However, given the overall reduction in environmental and housing-related sources of lead over time, the relative contribution of lead in consumer products remains an important consideration. Lead exposure can have serious detrimental consequences, particularly for children, because even low levels of exposure can affect neurodevelopment and cause long-term health issues.¹⁰

So, why are we not doing more to ensure consumer products are free of lead?

In a commentary in this issue of Environmental Health Perspectives, Porterfield et al.¹¹ reviewed data from home lead investigations conducted in California; Oregon; and King County, Washington, over the period 2010–2021, and in New York City in 2019. Consumer products were consistently identified as one of the main sources of lead exposure—and the only identified source of exposure in 15%–38% of cases—in investigations of children with blood lead levels $\ge 5\mathrm{\mu }\mathrm{g}/\text{dL}$. In California and Oregon, consumer products were identified as the sole source of exposure in comparable proportions to housing-related sources alone and, in certain years, exceeded housing-related sources as the only attributed potential source of lead exposure.

This commentary is particularly important because the relative contribution of consumer products to lead-exposure risk has not previously been evaluated in comparison with other sources in the home environment. In addition, although consumer products have previously been tested for lead content, there has not been a such a thorough and comprehensive evaluation of these sources in relation to blood lead levels. Some reports, for example, indicate that certain immigrant and refugee populations are at increased risk for exposure to lead-containing products,^12,13 and others suggest there are only isolated incidents of consumer products containing lead.^14,15 The surveillance study by Porterfield et al.¹¹ shows the extent to which consumer products have been associated with actual cases of elevated blood lead levels in children over an extended period of time in four US jurisdictions.

Hundreds of millions of children globally are exposed to lead, with about $\mathrm{800\hspace{0.17em}}\text{million}$ at or above the World Health Organization’s recommended action level of $5\mathrm{\mu }\mathrm{g}/\text{dL}$.¹⁶ A wide variety of consumer products—such as certain foods, dietary supplements, spices, and food additives; ceramic and metal foodwares; cosmetics, ceremonial and cultural powders, and traditional health remedies; children’s toys, clothing, and jewelry; vinyl miniblinds; and ammunition, among others—are increasingly recognized as important sources of potential lead exposure.^17,18 With increased globalization¹⁹ involving transnational travel, global commerce, and the cross-cultural exchange of foods and other products, the potential risk of lead exposure from consumer products is real.

Lead has been intentionally added to various products for centuries due to desirable properties such as its ability to improve durability, flexibility, and coloring, as well as its purported health benefits in some cultures.²⁰ To reduce the risk of lead exposure from consumer products today, regulatory agencies impose restrictions on the amount allowed in various products. The US Consumer Product Safety Commission (CPSC) is responsible for establishing and enforcing regulatory limits and for reducing lead in certain products intended for children under the Consumer Product Safety Act of 1972 [(16 CFR $\&1303$) and amended by the Consumer Product Safety Improvement Act of 2008 (Pub. L. 110–314)].²¹ However, testing products for lead can be expensive and time consuming, so some companies may forego testing as a cost-saving measure, whereas others may not fully understand the importance of ensuring their products are lead-free. Additional CPSC authority and jurisdiction over a wider range of products could be provided to help bridge this gap.

The US Food and Drug Administration (US FDA) monitors and regulates the level of lead in some consumer products, including certain domestically produced foods, cosmetics, and foodwares, as well as imported products intended for consumer distribution in the United States.²² This excludes any products that may go undetected, such as those transported from other countries by individuals, or products that may go uninspected, such as those purchased online or for “off-label” use, and those products that are currently unregulated. Recent investigations in two US states implicated food decorating products collectively known as “luster dust” in toxic metal poisonings.²³ In one of the cases, home-baked goods had been decorated using luster dust purchased online; in the other, a commercial bakery used a product whose source ingredients were traced back to a fine copper powder that had originally been imported for use as a metallic pigment for consumer goods such as industrial floor coverings.²³ Clearly, increased FDA monitoring and enforcement are needed.

In other circumstances, lead is inadvertently added as a contaminant during manufacturing, processing, or distribution processes, particularly in low- and middle-income countries (LMICs), where environmental lead levels remain high.¹⁶ In 2021, the international food standards-setting body Codex Alimentarius revised the “Code of Practice for the Prevention and Reduction of Lead Contamination in Foods,”²⁴ but these industry “best practice” guidelines fall short of adopting science- and health-based limits for lead exposure in foods. Consumer products sold in the United States are often manufactured in countries with varying levels of regulatory enforcement and oversight.²⁵ Sargsyan et al. conducted a market-based assessment of lead in consumer products across 25 LMICs that included more than 5,000 samples from a wide range of product types and geographic locations.²⁵ The authors found that 18% of sampled products exceeded the relevant uniform reference level (i.e., established international regulatory or public health threshold values selected from existing regulatory standards and guidance values promulgated by United Nations agencies, the European Union, and the United States, and applied this study to each product type to facilitate comparisons across countries). In many instances, median levels exceeded reference levels by several-fold, with maximum levels up to 10 times the reference value for certain products.

In addition, although the use of lead has declined significantly in many US products, there are still lingering effects from historical use. For example, from the 1850s to mid-20th century, Trenton, New Jersey, was a major US pottery manufacturing center, home to more than 150 pottery factories²⁶ where lead was commonly used as a glaze.²⁷ Lead was released during the manufacturing process, impacting nearby residential properties and other areas of the city. Lead concentrations in soil currently exceed federal threshold levels at several parks and school playgrounds, prompting testing of more than 100 residential properties in East Trenton.^27,28

Finally, as we are still dealing with legacy contamination from historical industrial and manufacturing processes related to lead in consumer products in the United States, the challenge of e-waste from the vast proliferation of consumer technology has emerged.²⁹ E-waste contains both valuable and hazardous resources, including metals such as lead. However, international rules and regulations for sustainable product design, safe disposal, and recycling are limited, with LMICs bearing the brunt of the burden.

It is clear that existing national and international measures to control lead in consumer products—through the entire product lifecycle, from production to point of sale, consumer use, and eventual disposal—are not sufficient. Improved laws are needed—including enhanced monitoring efforts and attention to increasing public awareness—and existing regulations need to be enforced. Consumers must remain vigilant and take precautions, such as avoiding imported products with unknown or unverifiable lead content, checking for product recalls, and heeding warnings issued by regulatory agencies and consumer watchdogs. US consumers can learn about product recalls from six federal agencies with different jurisdictions through a single website at www.recalls.gov. There is also a need to analyze e-commerce and global supply chains for consumer products, particularly contaminated food products and foodwares, to determine their origins and how they end up in local markets and the hands of consumers. The New York City Department of Health and Mental Hygiene has provided thought leadership in this area and called for a national data repository of consumer products identified with lead to systematically monitor and allow for better communication of ongoing risks to the public.^30,31 Porterfield et al.¹¹ provide valuable data highlighting that the problem is more than just theoretical and is not limited to one geographic area of the country.

Ensuring that consumer products are free of lead and mitigating historical sources of lead from the production, manufacturing, and disposal of consumer goods are critical actions for public health. Environmental lead exposure is a global problem with local solutions tailored to relevant sources; however, lead in consumer products is a global problem that requires increased international attention and cooperation, with a concerted global effort³² for an integrated and multifaceted approach to address these ongoing challenges.