LEAD Action News

LEAD Action News vol 4 no 4 Spring 1996  ISSN 1324-6011
Incorporating Lead Aware Times ( ISSN 1440-4966) and Lead Advisory Service News ( ISSN 1440-0561)
The journal of The LEAD (Lead Education and Abatement Design) Group Inc.

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Lead in Toys

by Robin Mosman, Information and Referral Project Officer,
NSW Community Lead Advisory Centre

The issue of lead in children's toys arose when the mother of an 11 year old boy contacted CLAS with concerns about the leaded model toys being sold by Games Workshop outlets. "A sign at the shop says 'Wash your hands because of lead' so I rang Consumer Affairs but they didn't want to know about it, they haven't got back to me." Her son "plays with them every day. They cut bits off and change them around, then paint them. It's a real craze with young boys his age."

A CLAS project officer then went to a Games Workshop outlet, where she observed a young boy of about 11 painting one of the figures with no visible supervision. There was an A4 sign on a wall stating "Wash your hands because of lead" but no sign of any washing facilities. When a salesman was asked where the facilities were, he said "Behind that door."

She asked the salesman how much lead was in the figures. He said "There's very little - 2 to 3% I think. You would have to eat it to worry. I handle them all the time." He stated that when handling the figures you were supposed to hold them by the plastic base. The model bought by the project officer had no plastic base. Children at the workshops are shown how to do "conversions" by cutting limbs off models with a hacksaw, then super-gluing them back on in different positions. When pressed about the amount of lead in the models, the salesman asked the manager, who stated that the models were 90% to 95% lead. Another young salesman who had indicated that he conducted workshops said to the manager "We weren't told that - we were told they had very little lead. I should be having blood lead tests." The manager stated "Our people over in England who make them have blood tests." At this time it was school holidays and workshops were being organised for school children.

Further inquiries by CLAS with an officer of the Department of Consumer Affairs revealed that because the manufacturers say the Warhammer models are marketed for mature age hobbyists, they are not considered a toy - the games rules are considered too complicated for children. Consumer Affairs legal advisers agree with the manufacturers. Consumer Affairs considered the models as "collectors’ pieces for adults, because adults collect the pieces and then play out battles with them. If they were classified as a toy, even 2% lead would be over the limit."

Australian Standard 1647 - 1995 (Children's toys - safety requirements) states:

5. PROHIBITED SUBSTANCES A toy shall not include or comprise the following substances:

a) Metallic lead and alloys of lead, that are accessible either before or after the toy has been subjected to the appropriate normal use and reasonably foreseeable abuse tests specified in AS 1647.2 (constructional requirements).


2 Referring to Clause 5(a) above, the purpose of prohibiting metallic lead and alloys of lead is not only to prevent the sale of lead soldiers as toys, but also to generally reduce the child's contact with lead in his or her environment. This is not to suggest that metallic lead and alloys of lead are totally prohibited from toys as the requirement refers to accessible (see Clause 4.1) lead or alloys of lead. Accordingly, lead (e.g. as contained in solder) may be used, provided that the lead is suitably shielded. Further, as may be seen from the requirements of Clause 6, compounds of lead may be used as a colouring agent, provided that the lead content, calculated as the element, complies with the limitations specified in that clause.


6.2 Coatings When tested in accordance with Appendix A, the concentration of leachable elements from coatings of paints, varnishes, lacquers, printing inks and similar coatings on toys or parts of toys, shall not exceed the limits specified in Table 1



Maximum migrated element in mg/kg toy material

Toy material









Any material given in Clause 2, except modelling clay and finger paint









Modelling clay and finger paint









Abbreviations: Sb = Antimony, As = Arsenic, Ba = Barium, Cd = Cadmium, Cr = Chromium, Pb = Lead, Hg = Mercury, Se = Selenium

However, this Standard is voluntary. The Australian Toy Association can only advise its members that they abide by it.

An officer of the Department of Fair Trading decided to look further into the issue and went to check on one of the outlets himself. He was surprised at the number of children there. The manager claimed they were all over 14. However, the officer met the mother of one of the boys outside of the outlet, who said her son was 10, and that she had never been asked about his age or heard of recommendations for hand washing being given.

Games Workshops was then requested to attend a formal interview to explain these circumstances, at which they were asked to abide by the spirit of the Standard. As a result, they undertook to carefully vet supply of the product to over-14 year olds only - if there was any doubt about age, the product would not be sold. They further undertook to enforce hygiene, and to supply wet wipes for people using the products in the workshops. They have become aware of the increasing community concern about lead, and are investigating the feasibility of replacing the lead in their product.

For more information on leaded product recalls, go to
lead poisoning hazard consumer product recalls

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