At Turnertoys, we are taking what steps we can to assure the safety of everything we sell. We have never carried products that, for reasons of design or manufacturing quality, we believed might pose a safety hazard of any sort. We have made the hard decision not to carry products that were carried by many of our competitors, and that we knew we could sell, because we did not feel they met our standards of safety and quality. 

Turnertoys Product Quality and Safety Standards
1. A toy must be durable enough to withstand continuous use and some abuse for a length of time commensurate with its cost and its designed purpose.
2. A toy must function mechanically well enough to allow a child in the toy's intended age range to use it for its intended purpose without unanticipated mechanical failure, difficulty, or restriction, except for requirements of learning or practice intended as part of the product design.
3. A toy must be free of any hazard not anticipated in the product design and not foreseeable by the user, taking into account the intended age range of the toy.
(These standards address only manufacturing quality and safety. Play value is the other important domain of toy quality.)

     An example of the third requirement is that all finishes must be free of toxic substances that may be inhaled or ingested by the user, either by getting on the child's hands, or by direct introduction into the mouth. 
The most acute of these hazards, we have alway felt, is lead.  Lead is a cumulative toxin that interferes with neural function and development in children, is stored in bone, and is especially a threat to the life-long health of girls and women. There is no lower limit below which small concentrations are safe for children, although adults are vulnerable only to acute affects of relatively high concentrations.
     For this reason, and because of the immediacy of the hazard suggested by the Thomas toy trains and Mattell incidents, we are concentrating on establishing the absence of lead toxicity in the paints of the toys we sell. Lacquer or varnish (clear finish on natural wood) is less of a concern because these finishes have no pigments, which is where metals such as lead are found. Likewise, completely unfinished wooden products such as unit blocks and My Very Own® Rattle cannot present a lead hazard or any similar toxicity problem.

Possible Hazards vs. Unlikely Problems and how Turnertoys is addressing them
     Only two categories of toy, among all those we sell, are candidates for heavy metal toxicity. Of most concern are painted toys. The other principal candidate for lead content is PVC (vinyl), in which lead may be found either as pigment to provide bright color (usually red or yellow) or as stabilizer (see  What is PVC (vinyl)? Use of Lead and other stabilizers). We sell no toys that contain any PVC. A few are packaged in clear PVC, which cannot contain lead. 
     We keep in inventory most of the toys we sell (everything but the large iems, such as furniture and riding or rocking toys). Relatively few of the toys we carry in inventory are painted.  
     Our primary concern is with toys manufactured in China. We were surprised to find how few of our toys are made there. Most of our toys decorated with paint are made either in Germany, or in the USA. These include the colorful wooden block sets in our Block Shoppe. 
     All of our wooden toy trains were made in the U.S. All of the Haba or T.C. Timber products (architectural, Storybook World, and Action block sets in The Block Shoppe ) are made in Germany and are CE (EN71 -  a rigorous standard required for toys sold in the European Union, that includes destructive testing and chemical analysis of both product and package) certified.  The alphabet blocks are made in USA, and are also 
CE certified. 
     Among our "Folk Toys", only the Old Fashioned Top, the throwing top, and the Sew'N'Sew stitching block are made in China. The pegs for the Jumpo and Ntangle were made in USA (by us, the Elwood Turner Co) with non-toxic paints.
The PDI 2-layer wooden puzzles and the Haba Sunnyland puzzles are also made in China. 
     Our wooden flying toys have essentially no paint, and are not of concern. All of the balsa planes, and gliders, and model kits are made in USA. Our plastic flying toys and accessories have no PVC, the only plastic with a potential for lead content. Lead would not typically be part of the formulation for other kinds of plastic. A small sampling of these non-PVC plastic parts revealed no lead in the pigments.
     Our Working Rigs construction vehicles are not painted; and further, have CE, ASTM, and ISO9001 certifications, indicating very high quality standards.
     Our Dollhouses by Real Good Toys are made in Thailand, not China. (Their dollhouse kits are made in USA.) Thailand has had a mature, technically sophisticated wood products industry for at least 15 years, and has not ever been found to generate the sorts of quality problems that been have associated with Chinese-made toys. Nonetheless, we have requested formal data from the importer.
     Some of our large items of furniture made by Guidecraft, who imports from Asia, may be made in Thailand, not in China, although we generally have no easy way to find this out. 

Testing of items kept in inventory - defining the hazard
     Samples of most of the toys we keep in inventory have been opened and examined critically for defects of design or workmanship, and many have been play-tested, including all the flying toys. We have eliminated from the Turnertoys website any items that failed more than once to meet our very high standards, even if they had previously been satisfactory. 
    Recently we started testing surfaces of our painted toys for the presence of lead, regardless of the country of origin. We are using LeadCheck® Professional Test Kits, made by Hybrivet Systems (Natick, MA: 800-262-5323 / http://www.leadcheck.com  ). These tests indicate the presence of lead in surfaces with a concentration of more than 2µ (micrograms) per 1 cm² surface area. We score the painted surface down to the substrate to expose as much of the coating as possible, so we are not just testing the exposed surface. This is a qualitative test that does not rule out the presence of lead in lower concentrations. Any positive result using this test indicates a toy clearly not suitable for children of any age. 
     Admittedly, it is very difficult to translate results in content per unit surface area into numbers relevant to known health effects in children, which are calibrated in micrograms (µ) per deciliter (dl) of blood. 10µ/dl is considered a very rigorous standard of safety; blood levels below this are regarded by almost all scientists as not of concern. 
     However, neither the U.S. Environmental Protection Agency (EPA) nor the Consumer Products Safety Commission (CPSC) have been helpful in providing a translation formula from surface concentration to blood level, and in fact, it may not be so easy.  Surface lead (which our tests detect) indicates only available lead, not ingested lead, which will necessarily be a much smaller amount, depending on frequency, duration, and manner in which the child handles the toy. A toy not placed in the mouth is much less of a hazard than one that is not. Furthermore, a toy in which lead is bound in a paint film will release it at a rate slower than our testing indicates, since we scratch the surface in order to release as much as possible. In PVC toys, on the other hand, lead, if present, and other substances of concern, are emitted steadily by the plastic.  Again, Turnertoys does not sell toys made with PVC. 

Results of our testing
     We have tested the painted surfaces of all our Chinese-made toys, and were not able to detect any lead.  We have tested representative sample of our toys made in USA and Germany, and found no lead. We have available to us the Material Safety Data Sheets (MSDS) for our American-made toys; they are all decorated with USA-made coatings, of which the composition is known. The MSDS includes, among other data, the chemical composition of the product. 

Larger Toys - our Drop-ship Vendors
     Most of the larger toys are drop-shipped, that is, sent directly from the manufacturer's or importer's warehouse to the customer. However, we have been able to examine these carefully and critically at Toy Fair each year, and in the case of the Vermont Rocking Dory, have paid several visits to the factory in Warren, Vermont.
     We have not performed our own lead tests on these drop-shipped products. At this time, we have requested formal statements from our drop-ship suppliers regarding safety of their products, primarily with regard to paints and finishes. We are still waiting to receive these.
     Our sleds and wagons are made either in the U.S. or China. There is no paint on them. The runners are powder-coated, essentially a baked enamel finish. These sleds and wagons have been lab tested, and we have available to us a copy of the results. Our Vermont Rocking Dory is painted with American-made, brand-name paint, for which we have the formula available.
     Our new line of Kettler® premium wheeled toys are made in Germany, and are not painted. They have a polyester powder-coat finish, completely non-toxic, and far less degradable with wear than paint. The plastic parts are polyethylene, which does not present a lead hazard (nor any other acute chemical hazard - see polymer safety update). The Kettler® products are all CE certified.
     The two greatest concentrations of painted products among the large, drop-shipped items we carry are the Guidecraft and Little Colorado play furniture items (Kitchens, table & chair sets, craft tables, etc.) and the Steel Pedal Cars. 
     Little Colorado Furniture is made in the USA, using American-made paints (we understand it is Sherwin-Williams). We have an informal statement from Guidecraft that a staff member visits the Chinese factories monthly, and that the finishes are or have been subjected to periodic testing. We are expecting a more formal statement from them in the near future. 
     Most of the steel pedal cars we sell are made in China, and the importer has provided an informal statement that they believe the finishes to be lead-free, largely because they have specified the paint formula. They have notified the factory in China that they want a formal analysis, and we will have more information when they provide it.  

Ongoing Program - a continued scrutiny
    Unfortunately, it appears that Chinese factories will get away with whatever they can if not constantly watched. If Mattell, who has more influence and economic power than any other toy company on earth, and who actually owns some of their factories in China, can have problems with lead in paint, than any of the thousands of smaller importers are subject to the vagaries and vices of their Chinese suppliers, unless they have a continuing, active test program.  
     The only sure remedy would be to pull samples out of each batch of product that is packed and ready for container loading, and test them before they are shipped.  If a product fails the test, that entire batch should be rejected and destroyed in China. It would mean that the importer would be "out of stock" of that item for a while, which is a normal ocurrence in retail commerce, anyway.  Whether or not any importer is able to adopt such a rigorous standard remains to be seen. Mere observation of procedures, or questioning of factory managers, is clearly insufficient. Testing of either the paints used, or the surfaces of finished products, is needed. Again, this should be done before the products are shipped, and should be done on randomly selected, packed items, not "test samples" provided by the factory.
      Meanwhile, Turnertoys will continue to test our in-house inventory, and may consider having some of the drop-shipped items sent to us, so we can test them here.

     We have had numerous requests for information about the safety of our products, especially in regard to where they are made, and I hope this information has been helpful.

Ed Loewenton
August, 2007
www.turnertoys.com