CPSC Staff Recommendations for Identifying and Controlling Lead Paint on Public Playground Equipment

Testing by the U.S. Consumer Product Safety Commission (CPSC) and some state and local jurisdictions has shown that many school, park, and community playgrounds across the United States have metal and wooden playground equipment that presents a potential lead paint poisoning hazard primarily for children six years old and younger.

CPSC testing revealed that some equipment was painted with lead paint, and over time, the paint has deteriorated into chips and dust containing lead. The lead paint chips and lead dust may be ingested by children six years old and younger who put their hands on the equipment while playing, and then put their hands in their mouths. Older children and adults are less likely to be at risk because they generally do not exhibit this same behavior.

Ingestion of lead paint is a major source of lead poisoning for children six years old and younger. Deteriorating lead paint in homes is the leading cause of lead poisoning in children. The health effects of lead ingestion are cumulative. In children, behavioral problems, learning disabilities, hearing problems, and growth retardation have been associated with sustained blood lead levels as low as 10 micrograms per deciliter (ug/dl).

The CPSC has tested the paint for lead on public playground equipment from 26 playgrounds in 13 cities across the United States. We found that equipment from 16 playgrounds in 11 cities had equipment with lead levels that exceed the amount used by the federal government (0.5 percent by weight) to determine lead hazards most in need of control measures.

The 0.5 percent level was set by the U.S. Congress in 1992 when it enacted the Residential Lead-Based Paint Hazard Reduction Act. This act was designed to focus attention and resources on hazards with the highest levels of lead. Nationally, efforts to reduce lead hazards are aimed at controlling lead-based paint hazards at, or above, the 0.5 percent level in Title X of the Act.

CPSC's own regulations ban the sale of paint containing in excess of 0.06 percent or more lead intended for consumer use. However, in providing advice on controlling lead hazards from playground equipment, CPSC is using the 0.5 percent lead level since it is generally used by the Environmental Protection Agency (EPA) and the Department of Housing and Urban Development (HUD) in making decisions on controlling the most significant lead paint hazards.

In addition to CPSC's own findings, paint on playground equipment from 223 playgrounds in 19 additional cities was tested for lead by state and local authorities or television stations doing news stories on lead hazards. Of those playgrounds, 125 of them in 11 cities were reported to have lead paint ranging from 0.09 percent to 29 percent lead by weight.

HEALTH RISKS

The CPSC, the Centers for Disease Control and Prevention, the EPA, HUD and other federal agencies, state that sustained blood lead levels above 10 micrograms/deciliter (ug/dl) are a health concern. To prevent young children from exceeding the 10 ug/dl blood lead level of concern, CPSC staff suggests that chronic ingestion (represented as 15-30 days) of lead from paint and other consumer products not exceed 15 ug of lead/day.

Based on the playground equipment tested, CPSC determined that if a child ingested as little as one tenth of a square inch of paint (about the amount that would fit on the tip of a pencil's eraser) daily for about 15-30 days, his or her blood lead levels would be at or above the amount the Federal government considers a health concern. This figure is based on the median level of lead found on the playground equipment tested (1.47 percent) and assumes that the child's body would absorb 30 percent of the lead in the paint he or she ingested.

CPSC STAFF RECOMMENDATIONS

To reduce the risk of childhood lead poisoning, the CPSC staff recommends the following strategy for identifying and controlling the lead paint hazards associated with older painted metal and wood playground equipment.

The appropriate control measures for this hazard must be determined on a case-by-case basis, considering such factors as: the condition of the paint; the percent of lead present; the playground equipment's age, location, use, condition, and overall safety; the availability of financial resources for this and other lead paint hazards; the relative costs of control measures; and the regulatory requirements of individual states, cities, and localities.

A. Lead Hazard Assessment

A lead hazard assessment for playground equipment may include a visual inspection, examination of records, paint testing, characterization of the hazard, identification of potential control measures, and a plan for setting priorities for the implementation of control measures.

1) Conduct a visual inspection of the playground and the equipment.

Look for areas of paint that are cracking or peeling. Special attention should be paid to equipment that was installed prior to 1978 when the CPSC's ban on lead paint went into effect.

2) Evaluate the results of the visual inspection.

A. If the paint is intact and in overall good condition, authorities can either continue to monitor the condition of the paint, or have it tested to determine if it contains lead. Lead paint that is intact and in good condition is not believed to be a hazard until it begins to deteriorate.

B. If the paint is deteriorating, paint samples should be collected from several locations on the equipment, giving priority to equipment painted or repainted before 1978.

Note: Laboratory analysis is the most accurate and reliable way to determine the presence and amount of lead in a paint sample. Studies conducted by the CPSC, EPA, and HUD indicate that lead test kits do not accurately and reliably discriminate between paint with lead and paint without lead.

3) Evaluate the results of the laboratory tests.

The appropriate control measures must be determined on a case-by-case basis, considering the factors mentioned above under "CPSC RECOMMENDATIONS."

If paint is chipping, peeling or otherwise deteriorating and lead levels are equal to or exceed 0.5 percent by weight, priority should be given to controlling this hazard.

If lead levels are between 0.06 percent and 0.5 percent, owners/managers of playgrounds may consider control measures.

B. Controlling the Lead Hazard

Priority should be given to controlling deteriorating lead paint on public playground equipment containing lead in amounts equal to or exceeding 0.5 percent by weight. Because playground equipment is used by children, permanent control measures are recommended. Permanent measures include replacement of the equipment painted with lead paint, or removal of the lead paint from the equipment. Continued monitoring (visual inspection) may be an appropriate control measure for intact paint even if that paint contains lead.

Interim control measures may be appropriate if the playground is slated for repair or the equipment is expected to be replaced within a few years. Interim measures include covering the paint with nonleaded paint or an encapsulant.

CPSC has made information available on several cities which have already dealt with lead paint on playgrounds in an appendix attached to the full report.

NOTE: The full report can be found here or you can get a hard copy by writing to CPSC, Washington, DC 20207.