Dangerous Arts
Part II: Read the Label
by
Cindy Ellen Hill, Esq. for Fine Art Registry™
"Paint pigments can include lead, cobalt, cadmium and manganese; inks
contain solvents, and thinners contain volatile organic chemicals like turpentine and acetone.”
While ‘doing art’ seems like a perfectly benign activity, the components of art materials include a frightening array of potentially hazardous elements. Paint pigments can include lead, cobalt, cadmium, and manganese; inks contain solvents, and thinners contain volatile organic chemicals like turpentine, xylene, acetone, and toluene; the fumes from kiln firings and textile dyeing include heavy metals. These materials impact human health through inhalation, ingestion, skin contact, and eye contact; some create broader dangers through being corrosive or flammable.
Before the health impacts of these hazards began to be understood, many an artist suffered mental, emotional, and physical health detriments unknowingly caused by the tools of their arts. While the dangers of many of these materials remains today, labeling information required by law or adopted by industry convention can help artists to understand the risks in working with various materials. With this knowledge, artists can then choose to either avoid the product, experiment with non-hazardous alternatives, or minimize their exposure to the danger by using appropriate protective gear.
The Federal Hazardous Substance Act (FHSA), which requires testing and labeling and substances that create acute dangers and health hazards, such as materials that are corrosive, flammable, and highly toxic. FHSA requires the chemical contents of the container to be identified and the acute hazards to be prominently displayed on the label.
Labeling of Hazardous Art Materials
But many art materials are not so powerfully and immediately harmful that they meet the criteria of the FHSA. In 1988, Congress passed the Labeling of Hazardous Art Materials Act (LHAMA) to supplement the FHSA and require testing and labeling of art materials which, through ongoing exposure over time, may cause long-term health effects such as cancer, or milder or chronic ailments such as allergies and skin irritations. The statute requires manufacturers to place an appropriate warning label onto all art materials that create a chronic hazard. Under LHAMA, 15 USC Section 1277(b)(1), “art material” includes any substance marketed or represented by the producer or repackager as suitable for use in any phase of the creation of any work of visual art of any medium.” Consumer Product Safety Commission publications indicate that they consider this to include components of artwork, such as paints and inks, as well as materials commonly associated with the art-creation process, such as cleaners, solvents, and photo chemicals. However, the statute does not cover paints, adhesives and solvents sold for household and construction use, so if an artist is buying their supplies from a home supplies store, working in, say, gallons of housepaint instead of little tubes of ‘artists’ paints, then the art labeling laws do not apply.
Art Supplies in the School
The statute was particularly inspired by concerns over the ongoing exposure of school children to things like paint, glue and crayons. While short-term contact with potentially damaging ingredients within these common art supplies is not likely to cause problems, school children – as well as art teachers and artists whose art-creation work is a daily, full-time endeavor – are in direct physical contact with these materials on a regular daily basis, and the potential for cumulative harm becomes greatly magnified.
Under LHAMA, schools can’t provide students in grades 6 and under with chronic-hazard labeled products; however, these products are approved for grades 7 to 12, and there is no restriction on their sale to any artist or private studio or non-federal-funds supported courses or workshops. The CPSC directs that all non-hazardous art materials will be labeled “conforms to ASTM D-4236”, and they recommend that parents and teachers only buy art materials with this label for their children and students; this advice also makes sense for any artist who is in ongoing regular contact with art production materials. (More information about CPSC labeling requirements can be found at www.cpsc.gov)
While the labels required by the federal FHSA and LHAMA laws are helpful in identifying the most dangerous materials, these statutes do not require manufacturers to list all ingredients in art supplies, and there is no registration and approval process as there are for drugs and pesticides. So there is no guarantee that the labels are in compliance with federal requirements, or that any particular user won’t have a negative health effect from any given product.
To supplement the LHAMA and provide more information to art supply consumers, the Art and Creative Materials institute, a manufacturers’ association (www.acminet.org) has also devised a recommended testing and labeling program for its members. The ACMI toxicologist staff tests art materials and issues permission for manufacturers to apply one of two labels: either a hexagonal seal bearing the letters “CL” for ‘cautionary label,’ which means that the product may have health risks, but that the health risks are properly listed and warned on the label; and a round seal bearing the letters “AP” meaning approved product.
The ACMI labels are a beneficial supplement to federal labeling requirements. However, it is fair to say that not all children’s health advocates agree with the organization’s standards or conclusions regarding all products. Publicly published concerns including a report by the Vermont Public Interest Research Group indicating that PVC polymer clays leave phthalates – plastic softeners suspected to cause birth defects – on users hands, despite the AP seal. Also an independent report by the Seattle Post Intelligencer that found asbestos in crayons that ACMI had certified nontoxic. ACMI responds to these criticisms on their website, and posts additional information from time to time about controversies which arise regarding art material health effects.
"Carefully reading the labels of supplies you purchase for art is a wise first step in determining the potential risks of any art materials you buy.”
Additional Sources for Information
Carefully reading the labels of supplies you purchase for art and looking for both the federally-mandated and the ACMI labeling information is a wise first step in determining the potential risks of any art materials you buy. Another good source of information is the Material Safety Data Sheets which other federal hazardous waste generation and disposal laws require all manufacturers to produce for most chemicals. In a workplace environment, employers are required to have MSDS’s available on most chemicals used for things like manufacturing processes and cleaning (more information on this coming in the next article on Occupational Safety and Health Regulations regarding art studios), but these information sheets are also handy for anyone working with any chemicals. Your art materials supplier may have the MSDS’s on hand for products they store and sell. If they are not readily available, the Oklahoma State University maintains a website with comprehensive links to most on-line available lists of Material Safety Data Sheets: http://www.pp.okstate.edu/ehs/links/msds.htm MSDS contains info on properties, manufacturers, precautions to be taken for storage and use.
Once you’ve acquired the label and MSDS information for the art materials you are working with, it is of course up to you what you do with that information. The laws and industry standards provide the resources for you to become knowledgeable about the hazards of art materials – but the responsibility remains on you as the consumer to decide what risks you deem acceptable and what works for your personal health, lifestyle, and art creation requirements. The MSDS’s will have recommendations for the safe storage, use, and disposal of products. You may want to consider looking for nontoxic alternatives to any hazardous materials you might otherwise use on an ongoing basis, such as experimenting with alternatives like citrus-based solvents for thinners or paints made from organic pigments. Many of these products, like organic foods, are relatively expensive in the short term; however, the long-term health and environmental benefits can easily make up for their initial cost – and the more people buy them, the more commonly available and competitively priced they will become.
If avoiding hazardous supplies is not practical for your art applications, minimize exposure by using appropriate ventilation, respirators, gloves, and eye protection. Useful suggestions for healthful studio strategies can be found in the United Educators Safety Guide for Art Studios by Thomas Oimet, http://www.conncoll.edu/offices/envhealth/Documents/Artsafety.pdf.
— Cindy Ellen Hill, Esq. | December 26, 2006
Read the series:
Dangerous Arts Part I: Hazards in the Studio Resource Conservation and Recovery Act
Dangerous Arts Part II: Read the Label
Dangerous Arts Part III: Occupational Safety and Health
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