Consumer Product Safety Commission

Questions and Answers: Lead Paint on Public Playground Equipment

Prepared by CPSC Staff
October 1, 1996



Question: Why is the CPSC concerned about lead paint on playground equipment?

Response: While deteriorating lead paint in homes poses the most significant lead risk to young children, 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 or wood playground equipment that present an additional lead poisoning hazard primarily to children six years and under. Some equipment was painted with lead paint, and over time, the paint has deteriorated into chips and dust containing lead, due to exposure to sunlight, heat, moisture, and normal wear and tear. The lead paint chips and lead dust can be ingested by young children who put their hands on the equipment while playing and then put their hands in their mouths. Since adverse health effects from lead exposure are cumulative, the exposure to lead from playground equipment contributes to the overall lead risk.

Question: What testing was conducted to support the CPSC's conclusions that some playgrounds are a lead hazard?

Response: The CPSC has conducted an investigation of older equipment in 26 playgrounds in 13 cities in 11 states across the United States. CPSC staff found 20 playgrounds in 11 cities had equipment with lead levels over the CPSC 0.06 percent allowable level. Sixteen of these playgrounds had equipment with lead levels in excess of 0.5 percent; the level that is identified in Title X of the 1992 Residential Lead-Based Paint Hazard Reduction Act as a priority for hazard reduction activities. The paint on the playground equipment that exceeded 0.5 percent lead ranged from 0.62 percent to 8.76 percent (w/w), with a median lead level of 1.47 percent.

In addition to the 26 playgrounds tested by CPSC, playground equipment with high lead levels have also been reported from several states and cities. The CPSC staff received reports of testing in 223 playgrounds in 19 cities in 9 states and the District of Columbia. In 11 cities, 125 playgrounds had lead paint on their playground equipment that was over the 0.06 percent CPSC level. The content of the lead in the paint on the equipment reportedly ranged from 0.09 percent to 29 percent. These reports corroborate the CPSC findings. The information received from the cities did not identify the extent to which the paint exceeded the 0.5 percent level.

Question: How much lead paint from playground equipment would a child have to ingest to get lead poisoning?

Response: The amount of lead paint from playground equipment a child would have to ingest to get lead poisoning depends in part on the amount of lead in the paint on equipment at that particular site and how much of the lead can be absorbed into the body. For playground equipment with 1.47 percent lead in the paint, CPSC staff has determined that daily ingestion over about 15-30 days of as little as one tenth (0.1) of a square inch of this paint (the size of the head of a pencil eraser) could result in blood lead levels at or above the 10 microgram per deciliter (ug/dl) amount the Federal government considers a health concern for young children. Such sustained blood lead levels have been linked with behavior and learning problems, damage to the brain and nervous system, slowed growth, and hearing problems. Since adverse health effects from lead exposure are cumulative, ingestion of even very small amounts of lead from playground equipment would be additive with a young child's lead exposure from other sources.

Question: How does the hazard from deteriorating lead paint on playground equipment compare to the hazard posed by lead in paint in homes?

Response: Deteriorating lead paint in homes poses a significant health risk to young children and requires immediate attention. Deteriorating lead paint on playground equipment is an additional source of lead to which children may be exposed. Since the health effects of lead are cumulative, exposure to lead on playground equipment adds to the risk to children. Exposure of children to lead should be minimized.

Question: How does the hazard from lead paint on playground equipment compare to the hazard posed by lead in miniblinds?

Response: Adverse health effects from lead result from cumulative exposure to lead. The exposure of young children to lead sources should be reduced whenever possible. Households with children six years and under should remove and dispose of all lead-containing vinyl miniblinds that are accessible to these young children. In addition, the exposure of young children to deteriorating lead paint on playground equipment should also be minimized.

Question: How many children have gotten lead poisoning from playground equipment?

Response: The Commission does not have any reports of children with lead poisoning from playground equipment. However, because of the high levels of lead found on some playground equipment tested and because the health effects from lead are cumulative, exposure to lead from playground equipment should be avoided.

Question: My child plays on playground equipment with deteriorating paint and is still putting his/her hands in his/her mouth. Should I take my child to the doctor or hospital?

Response: No, it is not necessary to be alarmed if children six years and younger played on a playground with deteriorating paint even a few times and then put their hands in their mouth. If your child does this on a regular basis, you might want to call the local authorities or whomever maintains the playground and ask if that playground has been painted with lead paint. You should also consult your child's physician. You and the physician can determine what, if anything, needs to be done. Additionally, we recommend that if the paint is deteriorating, you know it contains lead, and if young children play on the playground equipment, they do not put their hands in their mouths and eat paint chips and they wash their hands immediately after playing on the playground.

Question: The playground my child plays in not only has deteriorating paint on the equipment but I can see paint chips in the soil around the equipment. Is that a concern? What should be done about it?

Response: Children should not eat paint chips from any source. EPA is currently developing an addendum to their July 14, 1994 (60 Federal Register 47248) guidance on lead-based paint, lead- contaminated dust, and lead-contaminated soil. The addendum will address the issue of soil and playgrounds.

Question: My child has an elevated blood lead level and plays in a playground with paint that is deteriorating, i.e. peeling, cracking, chipping, or chalking. Do I need to report this case to you?

Response: If your child has an elevated blood lead level, playgrounds are just one of the many potential sources of lead exposure. You should work with your state or local health department, local poison prevention program or personal physician to determine the source(s) of lead exposure for your child and follow their recommendation to reduce that exposure. If it is determined that the playground was a source of the lead exposure, CPSC staff are very interested in knowing about this. You can file a report by calling the CPSC Hotline at 1-800-638-CPSC or 1- 800-638-8270 for the hearing impaired. You can also report to us using the form on CPSC's internet web site. Once at CPSC's site (http://www.cpsc.gov), go to "Report unsafe products", and then "Report an injury, death, or unsafe product to us", to report your information directly to us. Also, you can report to us by e-mail at info@cpsc.gov.

Question:Since there are so many playgrounds across the country that contain equipment with lead paint and can pose a hazard to young children, what is the CPSC doing about it?

Response: The CPSC has provided information to help local jurisdictions determine if they have a problem and the extent of the problem. CPSC also has developed recommendations on how to address the problem. Finally, the Commission is getting the word out to parents that they must be vigilant and notify public playground owners if painted equipment is deteriorating so they can determine if the paint contains lead. They must also be sure to wash their children's hands if they play on equipment with deteriorating paint.

Question: If there is a standard for the amount of lead allowed in paint, how did excessive levels of lead get onto the playground equipment?

Response: There is a standard for the amount of lead allowed in paint. In 1978 CPSC banned the sale of paint for consumer use containing in excess of 0.06 percent lead. CPSC also banned other products intended for use by children, including public playground equipment, bearing paint containing lead in excess of 0.06 percent by weight because they pose a risk of lead poisoning in young children. However, lead containing paint is still available for commercial and certain other uses and may have been applied to older playground equipment. In some cases, the equipment is very old and has been repainted many times. Even if the playground has been repainted with paint that does not contain lead, the older layers of paint may contain lead. The paint may deteriorate and flake off, as all the repainted surfaces deteriorate, exposing children to the lead paint.

Question: The CPSC standard for lead in paint is 0.06 percent, but you don't recommend control measures unless the lead level is equal to or greater than 0.5 percent. Why?

Response: Nationwide efforts to address lead paint hazards in homes and elsewhere have used 0.5 percent lead by weight as the level of lead in paint that should be targeted for lead hazard control measures. This level, which comes from the Residential Lead-Based Paint Hazard Reduction Act (Title X), has helped focus attention and resources on controlling the most significant lead paint hazards. In providing advice on controlling lead hazards from playground equipment, it makes sense to use the same lead level as is used in making such decisions for other sources of lead paint. Authorities should give priority attention to playground equipment with lead levels at 0.5 percent lead and above. CPSC staff believes that a reduced priority, but nevertheless important for authorities to consider, is the risk that exists to children from lead paint at levels between 0.06 percent and 0.5 percent. Local jurisdictions will have to decide how to respond to the potential hazard of lead paint on playground equipment. The appropriate control measures 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, and overall safety; the financial resources available to address this and other lead paint hazards; the relative costs of control measures; and the regulatory requirements of individual states, cities, and localities.

Question: What should my local jurisdiction or whoever is responsible for my playground be doing?

Response: What needs to be done to the playground depends on a variety of things-the condition of the paint, the age and location of the playground, if the paint does or does not contain lead, the amount of lead, where the paint is located, the age of the child for which the playground is intended, and the potential for exposure. Deteriorating paint on playground equipment should be tested for lead. A decision to implement control measures for playground equipment with lead-containing paint will depend on an assessment of a number of relevant factors, including the availability of financial resources, the percent of lead present, the condition of the paint, the playground equipment's age, location, use, and overall safety, and the relative costs of the control measures. The CPSC has provided information to help with the assessment of the hazard and determination of what should be done.

Question: What is the cost of remediation for a playground with lead containing paint?

Response: The cost for remediation will depend upon the remediation measure chosen and the number of affected pieces of equipment in the playground. Visual inspection of playgrounds may have no additional cost if it is integrated into a regular safety inspection. The following information is from four jurisdictions that have each taken a different approach to remediation. This information should not be assumed to represent the full range of costs for particular remediation measures. In two jurisdictions it cost $235 and $312 per playground to test to determine if lead paint was present. One jurisdiction encapsulated practically every affected piece of equipment at an approximate cost of $275 per affected piece. In one jurisdiction, it cost $14,000 for the removal of equipment from one playground. One jurisdiction is replacing in excess of 100 pieces of equipment with similar pieces of equipment at a cost of $106,000. In another jurisdiction, where there was an artist designed playground, they wanted to leave the playground as it was. The estimate for stripping and repainting this playground ranged between $9,000 and $12,000. One of the jurisdictions is in the process of replacing older pieces of equipment for safety reasons, and will address the lead hazard by accelerating the replacement process.

Question: If a jurisdiction decides to remove and dispose of a piece or multiple pieces of playground equipment, are there rules for the manner in which disposal is to occur?

Response: Because of varying regulations regarding hazardous waste storage and transport and disposal, state/local health departments or environmental agencies should be contacted to find out what laws are applicable in a given area.

Question: Does playground equipment being manufactured or sold today contain hazardous levels of lead?

Response: CPSC has inspected the largest public playground manufacturers to assure that public playground equipment being manufactured today does not violate the Commission's lead paint banning regulation. That regulation bans lead paint that exceeds 0.06 per cent lead by weight.

We have found what appears to be a few isolated violations of the lead paint regulation in current production playground equipment.

The CPSC is working with the firms involved to recall any violative playground equipment. The much more significant concern is the problem of lead paint on repainted playground equipment and equipment manufactured before 1978.

Question: Why isn't the CPSC recalling playground equipment that has high levels of lead?

Response: The vast majority of the playground equipment with high levels of lead was either manufactured before 1978 when the Commission's ban on lead paint that exceeded 0.06 percent went into effect, or is equipment that has been repainted on site. Equipment manufactured before 1978 while not subject to the banning regulation, may nonetheless present a health hazard if it has high levels of lead. We are providing guidance on steps to be taken for this equipment and for repainted equipment.

If the CPSC identifies playground equipment that violates the Commission's regulations when manufactured, we will seek appropriate corrective action.

Question: How much of the lead found on playground equipment is from repainted equipment and how much of it is from original equipment?

Response: We do not know the origin of the lead found on playground equipment. Equipment manufactured after February 1978 should not have paint with lead in excess of 0.06 percent.

Question: Do I need to be concerned about my home playground equipment containing lead?

Response: To date, CPSC has received no reports of lead on backyard playsets. We have done some initial testing and will continue to monitor backyard playsets but, at this time, we do not believe them to be a potential lead poisoning hazard.