The declarations of Greenpeace e.V., Germany, contradict the facts
About children's toys made of soft PVC there were recent scares here and there. Greenpeace e.V., Hamburg, in a press release of November 29, 1997, released research results that could suspect dangers for children from the use of these toys. The environmental organisation in this context pointed to the use of phthalates for toys made of soft PVC for children under three and asked to withdraw these toys. Before that, there were warnings from Denmark and The Netherlands, about elevated levels of migrated softeners in children's toys.
The German Toy Industry Union did take these allegations very seriously. They offered Greenpeace e.V., Hamburg, to do a joint test of that kind of products. Earlier tests and new ones, based on the allegations, could not reproduce the results of Greenpeace e.V., Hamburg. But the co-workers of the environmental organisation, specifically Judith Kanthak, refused a joint test.
The AgPU (German industrial workgroup for PVC and the environment) and the toy manufacturer Mattel therefore asked experts to analyse the laboratory tests that were done for Greenpeace e.V., Hamburg. The questions asked were: Are there specific points that must be followed by further research and how solid are the analytical practises used by the laboratories. The results of this secondary analyses are ready now and presented here.
At November 29, 1997 Greenpeace e.V., Hamburg, came out with the following alarm notice to the general public:
"Greenpeace has tested randomly 23 toys from the marks Mattel, Fisher-Price, Tyco and Safety First. For twelve toys, the amount of leaking softeners surpassed the by the BgVV (federal institute for the consumer safety and animal medicin, a subsudiary of the federal health committee) recommended limit of 3 milligram per quadratic decimeter by a multiple."
(Press release Greenpeace e,V., Hamburg, of November 29, 1997)
Mattel GmbH, one of the leading toy manufacturers, as wel as the AgPU e.V., ordered, on ground of these allegations, three independent institutes to test the allegations of the environmental organisation:
The results of all three laboratories were identic: no elevated migration of phthalates could be measured. In near all cases, the migration was below detection limits. Specifically the establishment of Greenpeace e.V., Hamburg, that the limit of 3 mg/dm2 was not met, was false and misleading. This limit is imposed for rests of volatile components like solvents. The BgVV has made recommendations for a testmethod for the part of migrating volatile products by a very laborate differential analyses. But neither the by Greenpeace, nor the by the Industry mandated laboratories have performed the tests under that form. Therefore, the Total Organic Carbon or TOC-value can not be used to solve the question if the limit of 3 mg/dm2 was exceeded.
The analyses of the laboratories in charge explicitely indicated that the TOC-value in no way can be used as a surrogate for phthalate migration. From the results it can clearly be seen that a lot of other components do migrate concurrently and are responsable for the higher TOC-values. If the TOC should be used as a surrogate for phthalate migration, then there must be similar results in both analyses (TOC and phthalate measurements).
But Greenpeace e.V., Hamburg has set TOC-values and phthalate migration more or less equal to each other, under the following remark:
"From experience it is known that phthalates are widely the largest part of migrating materials from PVC-products, that means that in this case the TOC-value is essentially identical to the total amount of phthalates."
(background information Greenpeace e.V., Hamburg, "Kinderspielzeug aus Weich-PVC: Umweltgift in Kindermund!" - Children's toys of soft-PVC, an environmental poison in children's mouth - November 1997)
This opinion is nevertheless proven false, as the analyses of the LGA Bayern have proved: For all 10 analysed toys, similar high TOC-values were measured, but no correponding migration values for phthalate-softeners:
"The measured TOC-values are in the same order of magnitude as the by Greenpeace published TOC-values. Higher deviations were only found by the TOC-values for the Tiger suckfoot toy. Therefore no significant differences between the TOC-values could be found.
From this it can be determined that the laboratory, charged by Greenpeace, has used similar methods and that an additional mechanical movement of the toys during the test probably was not used.
The migration solutions, which were obtained after a 24-hour test, were subsequently used for the specific analyses of the phthalate esters. In particular the chemicals DEHP and DINP should be detected and quantified. The concentration of both analysed chemicals in all solutions was in any case below detection limits. The solutions were also analysed in the so-called SCAN-test to detect any migration of other phthalates. But no other phthalate esters could be identified.
The high migration of phthalate esters, published by Greenpeace, could not be established under the named testconditions."
(Landesgewerbeanstalt - LGA - Bayern, section environmental protection, testreport of December 19, 1997)
After some notices from Denmark and The Netherlands, that significant higher migrations were found in children's toys, the BgVV has ordered to do similar tests in Germany. The testresults submitted by the official instances of the different states didn't give cause to concern (letter of the Federal Ministery of Health to the German Toy Industry Union of November 13, 1997). Also tests that were performed in other EC-countries under the normal national testconditions, didn't reveal higher migration values of phthalates from children's toys.
Alarmed by the publications of Greenpeace e.V., Hamburg, the BgVV eventually warned in December 1997 for the load of high softener migration from children's toys (BgVV press service 30/97 of December 12, 1997). The warning was seriously taken into consideration by the industry. Therefore they ordered, as already mentioned, the laboratories Dr. Budde, TÜV Rheinland und LGA Bayern to do their own analyses. But the by Greenpeace e.V., Hamburg, published results could not be reproduced.
Because of the different results from the different laboratories, it can be asked if the institutes charged by the environmental organisation, Ingenieurbüro Dr. Fechter GmbH (Berlin) and Dr. Kaiser & Dr. Woldmann GmbH (Hamburg) and the laboratories charged by the industry, possibly had used different testmethods.
The BgVV had made a recommendation in 1994, how toys should be tested for migration. The recommendation was as follows:
"The test must be done by a one hour concact at 40 °C with distilled water as test liquid. For toys under form of teething rings the duration of the test is prolonged to 24 hours."
("Gesundheitliche Beurteilung von Kunststoffen im Rahmen des Lebensmittel- und Bedarfsgegenständegesetzes" - health review of plastics as part of the food and consumergoods law - appendix 111, 191. Publication of November 15, 1994, Bundesgesundheitsblatt 12/94, page 518)
In the discussion about the testmethods can be noted that this by the BgVV recommended static migration test, in view of the industry, is not sufficient to simulate the reality of what happens in a children's mouth. Therefore they support the development of a dynamic method, based on a realistic situation, in the context of a general harmonisation of the testmethods.
Today, no common, acknowledged and validated method for the determination of the intake of phthalates by small children from toys exists in the EC. At October 1997, the General Directorate XXIV of the EC-commission, responsable for consumer safety, has expressed their wish to prepare a common testmethod and has appointed a scientific committee. This committee works together with industry and government to establish a method that will enable to determine migration values of toys under biological realistic conditions in the future. Especially the chew and sucking movements and the accompanied influence on migration should be established as realistic as possible. The results of this working group are expected for August this year.
Also for Greenpeace e.V., Hamburg, the todays testmethods are not sufficient:
"These testmethods are only partially suitable to simulate the migration of softeners. Neither the dissolving properties of saliva, nor the effects of teething are taken into account. "
(Hintergrundinformation Greenpeace e.V., Hamburg, "Kinderspielzeug aus Weich-PVC: Umweltgift in Kindermund!" - Children's toys of soft-PVC, an environmental poison in children's mouth - November 1997)
Therefore, the testsmethods were modified. The review of the by Greenpeace e.V., Hamburg, ordered tests showed two differences to the BgVV recommendations:
While the by the industry ordered tests of the laboratories of LGA Bayern and the TÜV Rheinland strictly followed the testing rules of the BgVV, the analytical laboratory of Dr. Budde followed the modifications imposed by Greenpeace to have the highest grade of compatibility. But even with a 24-hours-shaking-test, the findings of Greenpeace could not be reproduced. In its test report, the Laboratory Dr. Budde stated:
"The Greenpeace testresults could not be reproduced, despite similar burden of the toys (24 hours of severe shaking in water). "
(Chemisches Untersuchungslabor Dr. Budde, testreport of 17.12.1997)
If the ultrasonic treatment and the cutting of samples, like that was done in the tests ordered by Greenpeace e.V., Hamburg, are realistic, can be questioned. In any case it can be presumed that:
"By changing testmethods ... the results can be ... rapidely changed. A much higher value, so said LGA-tester Elmar Zeitler, can be obtained e.g. by ultrasonic treatment during the test or by grinding the materials. Both are not included in the recommendations."
(Hamburger Abendblatt of December 22, 1997)
To obtain secure and by both sides accepted results, the German Union of Toy Industries offered to do a joint test to the co-operators of Greenpeace e.V., Hamburg, Judit Kanthak, Dr. Oliver Worm und Andreas Bernstorff (conversation of January 27, 1998 in Frankfurt/Main and letter of the German Union of Toy Industries of January 28, 1998). To that, Mrs. Kanthak said:
"In your letter of January 28, 1998 you are offering a joint verification test. In our opinion that is not suitable and falls behind the level of discussion already reached. Moreover, we don't find this way suitable to validate the migration values found in 1997 in order of Greenpeace."
(letter of Greenpeace e.V., Hamburg, to the Deutschen Verband der Spielwaren-Industrie e.V. - German Union of Toy Industries - of February 4, 1998)
This decline, as wel as the refuse of Greenpeace e.V., Hamburg, to hand over the tested samples for further analyses, was received with incomprehensiveness by the experts and with distrust by the toy manufacturers:
"Maybe because of this, the rumours of a 'second Brent Spar' go around in the sector. In the case of the final disposal of theShell-platform, Greenpeace had sparkled international protest against the oil concern with exaggerated figures, but had to admit their failures afterwards."
(Hamburger Abendblatt of December 22, 1997)
Dr. Gerhard Gans (BASF Aktiengesellschaft)
Dr. Sabine Lindner (Arbeitsgemeinschaft PVC und Umwelt e.V.)
Dr. Joachim Mügge (Vestolit GmbH)
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Created: April 18, 1997.
Last update: October 11, 1998.
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