Number

207-EN

Section

General Section

Use

Abstract

A kindergarten in Copenhagen decided to get rid of as many problematic chemicals as possible in the children's environment. This included toys containing phthalates and wood preservatives, lotions with parabens and potentialallergens and items containing azo dyes and/or solvents.

Substituted substances

Reliability of information

Evidence of implementation: there is evidence that the solution was implemented and in use at time of publication
Evidence of assessment: there is evidence of an official (positive) assessment of the substitution

Reason substitution

CMR

Other type of alternative

Elimination of items containing substances listed on the REACH candidate list. Screen all purchases against list of substances allowed by Nordic Ecolabel. Toys made of natural materials.

Hazard Assessment

Substances to be substituted: A number of widely used phthalates (DEHP, DIBP, BBP, DBP) are on the REACH authorisation list. The concentration of these phthalates in products produced and placed on the market after 7th of July 2020 is limited below 0.1% by weight by a restriction REACH (Annex XVII, entry 51). Azo compound: azo dyes which can release a carcinogenic amine component through a reductive azo splitting, azo dyes which can release 3,3'-dimethylbenzidine (o-tolidin) through a reductive azo splitting, azo dyes which can release benzidine through a reductive azo splitting Alternative substance: Natural material-No further information available.

Description of Substitution

In 2008 a mother arrived at her daughter’s day care centre “Abel” and noticed a" foul chemical" smell. The very same day the care centre had purchased some new pretty oilcloth (table covers) - these proved to be the origin of the smell. The cloths were removed – an unfortunate buy. This incident became the origin for forming the parent group with a critical view on chemicals in items, in particular toys, in their children’s every day environment. They received a strong support from the educational leader and care centre board. A little later in the process, day care centre “Viktoria” joined, since a fusion between the centres was already planned. The project was named “Lavkemisk Leg” which roughly translates into "Less chemicals in play” and it was executed between 2008 and 2011. Primus motors for the project were some enthusiastic parents who started out by composing a “screening guide”. Next step was to sort the existing toys; The early steps were not very systematic due to the difficulty to obtain information on product substances from the distributors. All taken into consideration, this was the major obstacle.During a number of evenings, a group of parents and a few members of staff sorted through the centres toys by using the screening guide. Objects could be divided into four categories: Keep, might contain harmful substances, Contain harmful substances and Content unknown. Primary sources of information for the parents were a number of home pages, containing both some general information as well as more concrete guidelines regarding choices of products. : There were a number of focus areas. Some examples: -decoration: Phthalates and PVC Denmark holds a dispensation when it comes to phthalates in toys aimed at age group 0-3 years. Denmark has a complete prohibition on import, sale and use of phthalates in toys and items intended for small children, if the products contain more than 0.05% phthalates. (http://www.retsinformation.dk/Forms/R0710.aspx?id=126137 Directive on prohibition on phthalates in toys and small items, Danish Ministry of the Environment, directive 855 by 5 Sept. 2009) This restriction is valid for Denmark only, and is not general for the EU. In addition, valid for all of EU, are prohibits on manufacturing, import and sale of toys intended for children aged 0-14 years:

• if the products contain any of the phthalates: DEHP (Di(2-ethylhexyl)phthalate), DBP (Dibutyl phthalate),BBP (Butyl benzyl phthalate)
• Or if the product can enter the mouth, contains any of the phthalates; DINP (Diisononylphthalate), DIDP (Diisodecyl phthalate), DNOP (di-n-octyl phthalate).

A product or a part of a product is estimated to be able to enter the mouth if one of the dimensions are less than 5 cm. (Guidance Document on the interpretation of the concept “which can be placed in the mouth” as laid down in the Annex to the 22nd amendment of Council Directive 76/769/EEC ). Products are not allowed to contain more than 0.1% of the above mentioned phthalates. Other sources of information on how to screen for toys without phthalates and PVCworth mentioning are:

• http://www.forbrugerkemi.dk/test-og-rad/born/ftalater-i-borneprodukter/svommeudstyr-og-badebassiner-uden-ftalater-og-pvc/svommeudstyr-og-badebassiner-uden-ftalater-og-pvc Swimming equipment without phthalates and PVC;
• http://taenk.dk/test/leget%C3%B8j Test performed by consumer magazine “Tænk”, of toys intended for children aged 0-3 yrs.

decoration: Azo-colourings. Small children tend to put thing like toys, dolls, coloured feathers, wooden items etc. in their mouths. The parents therefore decided to add colourings to their focus areas list. It is prohibited to import or sell textiles or leather if it is dyed with one of 22 specific azo-colourings, if they can come in contact with the oral cavity for a prolonged time. It is also prohibited to import, sell or use the blue http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2009:164:0007:0031:da:PDF azo-colouring with index nr. 611-070-00-2 and EF-nr. 405-665-4, for use in textiles or leather ware. Annexes 8 and 9. (link to Danish legislation) decoration: Other substances Use of certain other substances also hold regulations. http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2009:164:0007:0031:da:PDF Toys are not allowed to contain benzene, nickel, cadmium, lead or bromated flame retardants (Penta- and Octo-. Now the great chase for information started. The parents wanted to elaborate a positive-list for purchases based on “knowledge-of-content” for the products. One of the major obstacles for a systematic approach was the difficulty in obtaining information on product contents. The parents have claimed their right according to REACH to be informed of substances mentioned on the REACH candidate list. To begin with the parents approached the distributors with the wish to gain information on, if their products contained any of the substances from the REACH candidate list. Only one single distributor answered back that 6 of their products did not contain substances from the candidate list; But what about the rest? It was then decided to take on the resource demanding task of approaching the producers abroad, this time with a little more luck. For instance, a Danish distributor succeeded to obtain information from the Swedish company Ökonorm about their crayons and felt tip pens that the day care centre then decided to use. None of the other products from the company satisfied the day care centres criteria. The parents tried to get specifications on colourings by linking them to EU codes for additives, but they never managed to gain any full answers. Due to the difficulty of gaining information, some “softer” criteria became relevant for the screening process, as for instance:

• Companies that had provided faulty information, had to withdraw products from the market, and had products with poor results in consumer tests (DK: Forbrugerrådet).
• Companies with production based in Europe; preferably Nordic countries, Holland and Germany, were first choice compared to products from e.g. China.
• Brightly coloured and strong smelling products.
• Suspicious products not relevant for toddlers (Glitter, palliates).
• Soft plastic.

In December 2010 the Danish Consumer Council (Forbrugerrådet) performed the testing of a variety of toys. The results were, from the parents’ point of view, depressing. 14 out of 20 products contained prohibited substances, including products from a Swedish company that had previously been deemed reliable. A tested item from the company – produced in China – contained bromated flame retardants, nickel and polyaromatic hydrocarbons (PAH). -decoration: Accomplished substitutions – some examples decoration: Adhesives The choice was to pick a brand that carried the Nordic Ecolabel (Svanemærket), trusting that this meant general limitations on what substances it could contain. -decoration: Modelling clay Pre-fabricated modelling clay may contain different hazardous substances, and in addition a number of colourings. In the day care centres the staffs choose to start making the modelling clay themselves and limit the use of colourings to a few types approved as food additives. Recipe for modelling clay: 4 dl water 2 tbsp. vegetable oil and food colouring (not azo-colouring) is brought to boil and allowed to cool off. Then mix with 400-500g of wheat flour, 100 g of fine table salt 2 tsp. of citric or wine acid as preservative. decoration: Lotions A lotion containing parabens was substituted with a lotion carrying the Nordic Ecolabel (Svanemærket) -decoration: Issues raised during the project Clashes of interest can of course occur between parents and staffs. The parents might wish to discard items that the day care centre had previously purchased, and day care centres are on tight budgets. In addition to this, some toys may hold a specific educational function that the staffs wish to use. With this in mind it is therefore important to show flexibility from both sides in order to have a fruitful collaboration between staff and parents. It is also important to focus on how items are purchased in order to not make unfortunate buys and it is therefore of great interest to have close collaboration with the person responsible. Abel's example regarding this is for instance the buy of the oilcloths that launched the entire project.Another example was the purchase of several expensive sack chairs that the staffs really appreciated. At the same time a test performed by the Danish Consumer Council showed that these pillows gave off some unfortunate volatiles. As a result they were taken down to the basement for storage right away. Further, two readily accessible purchase guides, one for parents and one for staff members, were elaborated. There might have been a greater degree of goodwill to deliver information if the County, who is a major customer, had approached the distributors instead of justtworandom parents. A whole third issue regarding buys is the limitations in product range due to the County’s purchase agreements. In the beginning the day care centres could only buy specific products that the County had purchase agreements on. Those products were listed in a catalogue. Later on it became possible to widen the range if some of the day care centres wished for alternate products than those listed. This removed a major obstacle for the possibility to let “chemical consciousness” be a part of the product choice. Working with substitutions in the children’s every day environment may clash with the families’ personal priorities. The discarding of the “fatboys” can state an example, since a number of families had these types of pillows in their own homes. It can produce a bit of a dilemma for the parents to be able to support discarding of a type of furniture in the day care centre, and still keep the same type of item at home where the child might spend even more hours. Information can be hard to obtain and difficult to comprehend for both staff members and parents. It is time consuming and participants often experience failures. Since the staffs in the day care centres are short of time to evaluate a purchase, ecolabeling can prove to be a reliable shortcut. Parent driven projects are often affected by the limited time that their child is enrolled in the day care service. A project of this type is resource demanding and has a long time span. At some point the project received a great deal of attention with support from the County, who wanted to communicate the process to all their other day care services, but external circumstances made it unsuccessful. The project finished in august 2011 with the hand-over of the material in a readily accessible form, allowing the day care centre and new coming parents to continue the work. The project group would have liked to communicate the results to other day care centres, but in their opinion the project had not been elaborated enough.

Case/substitution evaluation

Stating a good example on how close collaboration between staff and parents can reduce the chemical burden for the children. A case that could serve as inspiration source for other areas of the public sector. Supplement information from SUBSPORTplus: There are no longer any regulations for adhesives carrying the Nordic Ecolabel, but at one point labelled adhesives did not contain any substances classified as problematic for the environment according to EU directive 67/548/EEG (repealed by CLP-Regulation (EC) No. 1272/2008), with adaptations valid for Denmark, Finland, Norway, Iceland and Sweden, are only allowed up to 1.0%for a single substance and 2.0%in total. The content of substances estimated as allergenic, carcinogenic, mutagenic or genotoxic according to current regulations with associated substance lists in any Nordic country cannot exceed 0.1%. - Quoting from ”Nordic Ecolabel” (Nordisk Miljømærkening), translation from DK 4.4. Requirements on chemicals 4.4.1. Requirements on contained substances. The product cannot contain or be added ingredients containing - Phthalates (ester derivates of 1,2-benzodicarboxyacid) - Alkylated phenol ethoxylates and other alkylated phenol derivates (substances which emit alkylated phenols on degradation) - Halogenated solvents. - Ethylene glycol ethers with CAS nr. 109-86-4, 110-49-6, 110-80-5, 111-15-9, 111-77-3 and 111-90-0. 4.4.2. Binders If the binder is a synthetic polymer there are requirements on the maximum content of residual monomers. Maximum allowed concentration of residual monomer is 1 mg/g freshly produced binder. The concentration of residual monomers decline with time, which is the reason for giving the specifications for fresh binder. 4.4.3. Preservatives Preservatives are not allowed to be bio accumulative according to OECD test regime 107, 117 or 305. Requirements are valid for both binders and adhesives. 4.5.1. Volatile organic compounds, VOC. Adhesives, with the exception of wall paper adhesives and adhesives intended for upholstery material in furniture, are not allowed to contain more than 1% VOC’s with a boiling point125 ml, and if the adhesive contains VOC’s with a boiling point < 260°C, there are requirements for TVOC (Total Volatile Organic Compounds) emissions. Emission of TVOC (Total Volatile Organic Compounds) measured by CEN EN 13419, parts 1-3 and analysed by ISO DIS 16000-6.2 (see part 7.3.1), can after 4 weeks not exceed 0,2 mg/m2hconverted to toluene equivalents. -decoration: Modelling clay target="_blank" rel="noopener">Pre-fabricated modelling clays may contain harmful substances and in addition contain a number of colourings. Lotions Products carrying the Nordic Ecolabel are not allowed to contain perfumes, substances on EU’s list of possible endocrine disruptors, including parabens. Substances listed in target="_blank" rel="noopener">Table 1 in the criteria document version 2.3 are prohibited in Nordic Ecolabelled products.

State of implementation

In use

Enterprise using the alternative

Kindergarden Abel

Availability ofAlternative

On market

Type of information supplier

User

Contact

Kindergarden Abel

Further information

http://www.mst.dk The Danish EPA info-pages on for instance toys.Independent consumer info-centre founded by Danish Ministry of the Environment.http://www.forbrugerkemi.dk/test-og-rad/born/legetoj/plastlegetoj/fakta-om-plastlegetoj Facts on toys.http://www.forbrugerkemi.dk/forsta-maerkerne/emballage-til-fodevarer/plastpile Food packaging - labeling. The Danish Consumer Council (Forbrugerrådet) Book by Lene Midtgaard and Tino Rabe Tønnesen; Familie uden kemi. Lindhardt og Ringhof, 2008. Reach 65.000 reasons for better chemicals.

Date, reviewed

November 26, 2021