Health And Safety Labeling

Are you a label reader? If so, you might notice that the Health and Safety information on our labels is different from that of other artist material manufacturers. Much of the industry uses the Art and Creative Materials Institute (ACMI) AP and CL Seals on their labels, and for many years we did as well. AP stands for APPROVED PRODUCT and is usually accompanied by the word "Nontoxic". CL is an abbreviation for Cautionary Label, and is used when risk and safety information is required on the label.

Several years ago, we introduced a new symbol for our products that do not pose significant health risks during use, formerly "AP Nontoxic" products. This symbol is an image of a playing marble. The marble symbolizes that although relatively safe, the products should still be kept out of ones mouth.

Our concern with the "nontoxic" message was for several reasons. First, potentially toxic chemicals are likely present at some level in all products, regardless of risk assessment; second, it is inappropriate to assume that all possible chronic hazards of chemicals are currently known; and third, personal exposure should be prevented when using chemical products. Over the years, feedback from our customers indicated that reading "nontoxic" on the label implied the paints could be used for things we did not intend; such as body painting, painting with the fingers or tongue, tattooing, and decorating dishware.

Risk Assessment?
For years, federal law has required that toxicologists evaluate art materials and appropriately label them with warnings for any potential acute or chronic health hazards. This evaluation is performed according to the guidelines of ASTM D 4236, Standard Practice for Labeling Art Materials for Chronic Health Hazards. The assessment uses factors such as chemical form and concentration, anticipated frequency and duration of use, and bioavailability1 of the chemical.

This mathematical process necessarily relies upon the use of averages and assumptions, as well as significant compensating safety factors. The nature of the process is such that there is room for debate over many of the individual factors used. The result is that different opinions may arise as to the relative toxicity of a material. These are complex issues and there is validity in more than one opinion.

Toxicological assessment can only rely upon current scientific and medical knowledge of chemical hazards. Although ASTM D 4236 states that "knowledge about chronic health hazards is incomplete", we have seen the leap made from the "absence of known hazards" to the declaration that a product is "non-toxic" under this Standard. We do not believe these phrases mean the same thing and our labels reflect this.

California Prop 65 Warnings
The State of California has unique labeling requirements for products that contain certain chemicals. These chemicals are listed, under rules of the California Safe Drinking Water and Toxic Enforcement Act (otherwise known as Proposition 65), as being known to cause cancer and/or reproductive toxicity. If chemicals on this list are in products sold in California, the product label is required to provide clear and reasonable warning to that effect. The Act exempts products that do not pose a "significant risk" from the labeling requirement. However, as described above, "significant risk" is debatable. The result is that we apply warnings to all products which contain any Prop 65 -listed chemicals, where such are listed as ingredients on the product's Material Safety Data Sheet and/or label. Chemicals on the Prop 65 List include cobalt, nickel compounds, cadmium compounds, carbon black, chromium, lead and crystalline silica. For products containing these chemicals, we label with a phrase such as: "WARNING: This product contains a chemical known to the State of California to cause cancer".

X Means Harmful
So how do users quickly differentiate between products that do and do not pose significant known risks? Products deemed to present a significant risk under conditions of foreseeable use, based upon Federal guidelines (ASTM D 4236), carry the European symbol for a harmful product, which is a prominent black X on an orange background. All GOLDEN cadmium colors are included in this group in order to draw attention to the fact they should not be spray-applied. Other GOLDEN products carrying the X symbol and related warnings include Varnishes, Acrylic Flow Release, and GAC 900.

It's A Better Label
We have always believed that people have a right and need to know what chemicals they are working with, and that they should follow basic precautions when using any of our products. This approach is reflected on our labels, which give pigment identification information as well as general guidelines for safe use, and on our Material Safety Data Sheets (MSDS) which list hazards of product components without incorporating the use assumptions of toxicological risk assessment. Our label advice for using chemical products safely, while conservative, emphasizes the need to err on the side of caution when using art materials. We reinforce this message by explaining why. It's a lot of information to fit onto a label, but we believe it's the best we can offer. For more information, contact our Product Safety staff.

1 bioavailability is the extent that a substance can be absorbed in the body in a biologically active form