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  QUESTION: Comparison of US and Australian policies on lead in mats, 02 Mar 2006, Victoria Australia

I have recently purchased 2 outdoor matts from ALDI. On the back of the label it has a warning. This product contains chemicals known to the state of California to cause cancer, birth defects and/or reproductive harm.
I emailed the company and they state that "Because the drafters of Proposition 65 intended it to be a warning statute only, the level of exposure required for a warning label is minute. In fact, for lead, the exposure level triggering warning is 0.5 micrograms per day every day for a lifetime. To put this in perspective, this represents 12 milligrams of lead over a 70-year life span. This amount is significantly less lead than you would find in the average decorative brass water valve you might have in your garden." They actually do not state how much lead is in their product. Are these amounts safe in Australia?
ANSWER: 02 Mar 2006

Dear Amelia,
are the mats made of rubber or poly vinyl chloride (PVC) or something else? I think the Proposition 65 warning from California is an excellent piece of legislation because how else could anyone know that there was lead (and other toxics) in so many consumer items? The warnings have apparently inspired many manufacturers to reformulate their products to remove the offending toxics so the products don't have to carry the warning and I believe that outcome was the actual intention of the legislators. When the mat manufacturers say: "the exposure level triggering warning is 0.5 micrograms per day every day for a lifetime", I don't have an argument with that. The point is that if you had a dog (or more rarely, a child) who chewed everything in sight then you would make sure that you removed all leaded items from the dog's (or child's) environment. All these little bits of lead add up and if the product degrades then they also enter the environment, making urban environments particularly likely to be lead-contaminated. It is virtually irrelevant how much lead you could get over a lifetime from ONE product that contains the amount of lead that triggers the warning because there is no such thing as a person (or animal) who is only ever exposed to one leaded product for their entire lives. We're all exposed to lead in dozens if not hundreds of products every day - see the list of leaded products at - but be advised that we find it almost impossible to keep up-to-date with adding leaded products to the list - there are so many coming on the market - so the list will always be incomplete. One case that springs to mind as an illustration is that one of our Australian clients has a 6 yr old autistic son who has a blood lead level of 27.9 micrograms per decilitre - g/dL (the goal is for all Australians to have a blood lead level below 10 g/dL) because he has pica and therefore eats paint in his 1970 rental property plus rubbers, plastic, dirt, crayons, BluTac, anything.
Another of our clients who paid for a lab analysis herself, reported to us that her Dowl Aluminium Window had 66,000 milligrams per kilogram (mg/kg) [6.6%] of lead in the PVC rubber seal so the amount of lead in PVC rubber is by no means always minuscule. To give you something to compare that figure to, residential paint is permitted to have 0.1% lead in Australia and 0.06% lead in the USA. If a substance contains more than 1% lead in Australia, it is classified as a hazardous substance under occupational regulations. If the manufacturer hasn't told you the lead level that is in their mats, then you have to wonder, what have they got to hide? I suggest you write back and ask for a lead analysis report of their mats (from an independent laboratory) and for a Material Safety Data Sheet if there is one for the mats (this may tell you what hazardous material is in the mats and may even list the concentration).
Unfortunately in Australia, that's all you can do. If the lead result is forthcoming, then you could ask the Safety Policy Unit, Consumer Affairs Section, The Treasury (ph 0262632730) whether they regard it as a safe level, but if the result is not forthcoming then you can complain to the Safety Policy Unit and ask them to follow it up. Australian Customs (Prohibited imports) regulations do not specifically mention allowable lead levels in such products and the Australian Standard for the Uniform Scheduling of Drugs and Poisons (SUSDP) No. 20 (2005) does not mention any of the following:
  • Mats
  • Rubber
  • PVC
  • Poly Vinyl Chloride

As far as I'm aware, Australia has no similar regulations to the Californian one nor any guidance for importers etc similar to the federal USA's "Codification of Guidance Policy on Lead in Consumer Products" at which advises importers and manufacturers to "obtain sufficient tests and analyses to ensure that their products do not contain harmful levels of lead" and states: "young children should not chronically ingest more than 15 micrograms of lead per day from consumer products" and "urges manufacturers to eliminate lead in consumer products to avoid [recalls]...".
Leaded PVC miniblinds were the subject of a voluntary recall in Australia last decade but it's surely time for the Safety Policy Unit to look at actually testing rubber and PVC products for lead and banning those that pose a lead risk for children. PVC exterior wall cladding would be at the top of my list for such scrutiny, as it provides such a large surface for the sun to degrade and children to touch.
I hope this answers your question and inspires you to pursue the matter further. Aldi is the forward-looking type of company that might even consider setting a policy to limit lead in all their products so you might want to suggest it to them.
Thanks for your enquiry.
Best wishes
Elizabeth O'Brien

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