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INDUSTRIAL-ECOLOGY  June 2000

INDUSTRIAL-ECOLOGY June 2000

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Subject:

HRG Petitions the CPSC to Ban Lead in Candles - please submit comment

From:

[log in to unmask]

Reply-To:

[log in to unmask]

Date:

Thu, 29 Jun 2000 02:03:58 EDT

Content-Type:

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Parts/Attachments

text/plain (214 lines)


As  you may have heard by now Public Citizen & Health Research Group has 
filed a petition to issue a legally mandatory ban  & recall on the use of 
lead in candle wicks.  I'm hoping to enlist your help by submitting your  
comments in writing in support of enacting a mandated ban of lead in any & 
all candles made or sold in the U.S.  The deadline for comments was June 
12th; however, a representative from the CPSC's Office of General Council 
contacted me last Friday to inform me that they would accept & consider any 
late arriving comments submitted - for the next several weeks.  Please try to 
get your comments in at your earliest possible convenience

*Read :
<A 
HREF="http://www.citizen.org/hrg/PUBLICATIONS/1510.htm#Supplemental%20letter">
Comments Submitted by Public Citizen & Health Research Group</A>
http://www.citizen.org/hrg/PUBLICATIONS/1510.htm#Supplemental letter

 This is an action that is so long overdue, necessary & attainable.  
Countries that are involved with free trade with the US are encouraged to 
submit comment as well. If you are active in other environmental & public 
health  advocacy lists or groups or keep in contact with people that would 
support  this  - it would be so appreciated if you could circulate this with 
some of  the groups you associate with.  The petition needs all the support 
that can possibly be brought together.  This is truly a case of every letter 
counts or they will & fully intend to sweep this again right under the rug 
with another  unenforceable, voluntary and basically meaningless, ban, 
clearly this is not in the best interests or the safety and welfare of 
consumers, their families 
& especially their children or even the "hands-on" candle makers themselves. 
[The industry & their trade association are pushing for a more lax voluntary 
action rather than mandatory ban.].

This was an issue back in 1973 & 1974 & should have been taken care of then 
but in spite of the EPA Administrator at the time urging a mandatory ban...a 
voluntary ban was approved and then not complied with or even monitored.  The 
EPA study that Mr. Train references was performed in 1974 & determined that -
 
 "Burning only two candles three hours each day on a regular basis in the 
home could increase exposure to airborne lead by a factor of 5 or more. This 
exposure to lead from candles could equal or exceed the exposure to airborne 
lead associated with the busiest freeways in America." [keep in mind this was 
a time when leaded gasoline was still fairly commonplace]. "Inhabitants of 
homes in which lead wick candles are burned could be exposed to substantial 
incremental quantities of lead which, if continued on a regular basis would 
pose a significantly high risk to health especially among children."  Mr. 
Train goes on to say: "In my opinion candles represent an unnecessary 
incremental source of lead that can readily be controlled. It is my strong 
recommendation that the Consumer Product Safety Commission do all in it's 
power to prevent exposure to the substantial and unnecessary source of lead 
in candles."
 
 To read the complete copy of the referenced letter & other related 
documents* go to: <A HREF="http://www.fiscorp.net/iaq/docs/">http://www.fiscor
p.net/iaq/docs/</A>
* These are all copies of documents from 1973 & 1974.

If you would like to read more on the current pending petitions, these 2 
links will fill you in on the details:

 <A HREF="http://www.citizen.org/hrg/PUBLICATIONS/1510.htm">Petition to ban 
lead candles</A> 
[http://www.citizen.org/hrg/PUBLICATIONS/1510.htm]

 <A HREF="http://www.citizen.org/press/pr-sid29.htm">Millions of Dangerous 
Candles Sold Throughout U.S.; Lead Wicks Pose Major  Health & Safety Hazard, 
Especially to Children</A>
[http://www.citizen.org/press/pr-sid29.htm]

At any rate, the CPSC is taking public comments regarding this 
proposal, these comments could have a significant impact & quite possibly 
even sway the decision on whether another voluntary measure is passed  or a 
manditory  directive from the CPSC banning the use of lead in any & all 
candle products  It's unbelievable that in the year 2000 we even need a 
petition & comment period to ban an insidious poison consumers may be 
unwittingly releasing into their homes & attempt to fix an erroneous policy 
on lead in candles from 26 years ago.  But the fact remains that's where we 
stand now.  I hope I can count on your participation  in  submitting 
comments, possibly even encourage like minded individuals to submit comments 
as well by sending this out to the other groups & individuals to which you 
are a member or have affiliations with.

The CPSC site also has a copy of the petition available:

 <A HREF="http://www.cpsc.gov/businfo/frnotices/fr00/wicks.html">Petition HP 
00-3 Requesting a Ban of Candle Wicks Containing Lead and of Candles 
Containing Such Wicks</A> - Comments accepted until 6/12/00 
[http://www.cpsc.gov/businfo/frnotices/fr00/wicks.html]

The address where comments need to be sent:

ADDRESSES: Comments on the petition should be sent to:

E-Mail to: <A HREF="mailto:[log in to unmask]">[log in to unmask]</A>

With the subject heading: "Petition HP 00-3--Candle Wicks 
Containing Lead."

Office of the Secretary
Consumer Product Safety Commission
Washington, DC  20207
telephone (301) 504-0800
       
OR delivered to: 
Office of the Secretary, Consumer Product Safety Commission
room 502, 4330 East-West Highway
Bethesda, Maryland 20814. 

Comments may also be filed by 
Fax (301) 504-0127 

Comments should be captioned ``Petition HP 00-3--Candle Wicks 
Containing Lead.'' 

Please be sure to CC the following addresses:

<A HREF="mailto:[log in to unmask]">[log in to unmask]</A>,

<A HREF="mailto:[log in to unmask]">[log in to unmask]</A>,

<A HREF="mailto:[log in to unmask]">[log in to unmask]</A>

This whole issue was raised & attracted the attention of the media & public 
health officials by a Mom & some candles sold by the GAP, how fitting it 
would be if a flood of comments from Mothers was responsible for instituting 
an enforceable ban & possibly a Federal Law...correcting the mistake of 
almost 3 decades of looking the other way. [see: <A 
HREF="http://www.fiscorp.net/iaq/docs/">http://www.fiscorp.net/iaq/docs/</A>  
 * These are all copies of documents from 1973 & 1974.]


Women & children are the ones most profoundly affected & exposed, after all 
when you think about it isn't it women for the most part that make this 
product [especially crafters] , shop & purchase this product?  Women are the 
ones that burn them, consequently women & their children, the most vulnerable 
members of our society, face the most significant exposures.    For instance 
did you know that 7 out of 10 homes burn candles on what would be considered 
a regular basis, according to a Kline & Co. study.... Or that 96% of women 
have purchased  scented candles in the past 12 months?  If this isn't a 
women's & children's issue I don't know what is!


THIS IS ALSO A GLOBAL ISSUE:

The UK has been considering a ban ever since Australia enacted one last year 
in Sept.  but I don't think it's actually been legislated in the UK yet. As I 
understand it New Zealand has just passed an identical ban to Australia's 
[which imposes very STIFF fines PER CANDLE] & I imagine the UK will be next.  
The Minister of Health in Canada is eager to get a ban in place there but it 
looks like this is where we may run into some politics...NAFTA will 
apparently have to be considered.   There are some considerations that should 
probably be taken into account with these other free trade countries 
instituting a ban...Obviously there will be existing product that has to go 
somewhere...will there be a increased cause for concern that more of them 
will find their way to the US or other countries that don't have a ban in 
place?  Just something to consider because I think the  US anti-dumping rules 
apply only to goods coming from China & Taiwan & I don't know if the UK has 
those in place either.


WHERE IS THE LEAD:

Highly scented & aromatic container candles [candles in some sort of glass, 
metal or ceramic jar]  have never been more popular.  A predominance of this 
particular type of candle will have a thin metal wire at the core of the 
wick.  This serves the purpose of keeping the wick erect in the liquefied 
melt pool of scented wax.  The problem is that this metal wire  often times 
contains a high percentage of lead, it's not uncommon for it to be as high as 
70 to 96% lead. But all of the metal wire core wicks that have been tested by 
a number of researchers & labs have tested positive for measurable lead  
[see: <A HREF="http://unisci.com/stories/19994/1007992.htm">http://unisci.com/
stories/19994/1007992.htm</A>].  The lead is "vaporized" as the candle is 
consumed & further compounding the the problem is the fact that people will 
burn multiple candles & on top of that these sub-micron particles can stay 
airborne for up 10 days or more.  Each subsequent burn in that time frame 
further saturates the air with lead particulate.  Then these particles settle 
eventually & the lead accumulations on carpets can be staggering...think 
about that the next time you see a tot crawling around on the carpet in a 
home that burns candles.

You might want to take a look at Public Citizen's comments submitted for some 
additional hard numbers & measurments: 

 Go to:  <A 
HREF="http://www.citizen.org/hrg/PUBLICATIONS/1510.htm#Supplemental letter">Pu
blic Citizen Comments to CPSC Petition to ban lead candles</A> 
http://www.citizen.org/hrg/PUBLICATIONS/1510.htm#Supplemental letter


My heartfelt appreciation to those who take the time to respond in support of 
this petition.  I will keep you apprised of the petition's progress if you 
like.

Feel free to contact me if you have any unanswered questions pertaining to 
the petition or the issue in general.

  Regards -
  Cathy Flanders
  IAQ List Manager & Moderator
   Fax # 781-394-8288
  Personal E-Mail: <A HREF="mailto:[log in to unmask]">[log in to unmask]</A>
   <A HREF="http://www.onelist.com/community/iaq">IAQ List - Home</A>
  http://www.onelist.com/community/iaq
   <A HREF="http://www.onelist.com/links/iaq">IAQ List - Links</A>
  http://www.onelist.com/links/iaq
 
  <A HREF="http://www.fiscorp.net/iaq/">Candles and Indoor Air Quality</A>
  http://www.fiscorp.net/iaq/
  <A HREF="http://disc.server.com/Indices/41692.html">Homeowners Soot Damage  
Discussion</A>
  http://disc.server.com/Indices/41692.html


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