The SVHC Candidate list has been updated to include 181 substances

On the 15th of January, ECHA published thier decision to add seven new substances of very high concern (SVHCs) to the Candidate List. The BPA entry was updated to reflect an additional reason for inclusion due to its endocrine disrupting properties causing adverse effects to the environment. BPA is already listed on the Candidate List because of its toxicity for reproduction and endocrine disrupting properties. The SVHC Candidate List now includes a  total of 18 batches, 181 substances.

No. Substance Name EC No. CAS No. Potential Use Intrinsic property(ies) in SVHC
1 Chrysene 205-923-4 218-01-9 Normally not produced intentionally but rather occurs as a constituent or impurity in other substances. Carcinogenic (Article 57a)

PBT (Article 57d)

vPvB (Article 57e)

2 Benz[a]anthracene 200-280-6 56-55-3 Normally not produced intentionally but rather occurs as a constituent or impurity in other substances. Carcinogenic (Article 57a)

PBT (Article 57d)

vPvB (Article 57e)

3 Cadmium nitrate 233-710-6 10325-94-7 Used for the manufacture of glass, porcelain and ceramic products and in laboratory chemicals. Carcinogenic (Article 57a)
Mutagenic (Article 57b)
Specific target organ toxicity after repeated exposure (Article 57(f) – human health)
4 Cadmium hydroxide 244-168-5 21041-95-2 Used for the manufacture of electrical, electronic and optical equipment and in laboratory chemicals. Carcinogenic (Article 57a)

Mutagenic (Article 57b)

Specific target organ toxicity after repeated exposure (Article 57(f) – human health)

5 Cadmium carbonate 208-168-9 513-78-0 Used as a pH regulator and in water treatment products, laboratory chemicals, cosmetics and personal care products. Carcinogenic (Article 57a)

Mutagenic (Article 57b)

Specific target organ toxicity after repeated exposure (Article 57(f) – human health)

6 Dechlorane plus (including any of its individual anti- and syn-isomers or any combination thereof) 236-948-9

etc.

13560-89-9; 135821-74-8; 135821-03-3

etc.

Used as a non-plasticising flame retardant, used in adhesives and sealants and in binding agents. Used as a non-plasticising flame retardant, used in adhesives and sealants and in binding agents.
7 Reaction products of 1,3,4-thiadiazolidine-2,5-dithione、formaldehyde and 4-heptylphenol, branched and linear (RP-HP) [with ≥0.1% w/w 4-heptylphenol, branched and linear] Used as a lubricant additive in lubricants and greases. Endocrine disrupting properties (Article 57(f) – environment)

Legal Obligations of Companies
Producers and exporters of articles containing any of the SVHC candidates shall notify ECHA if both of the following conditions apply:
i. the substance is present in those articles in quantities totaling over on tonne per producer or exporter per year, and
ii. the substance is present in those articles above a concentration of 0.1% weight by weight.

Five substances added to the hazardous substances list of PRO 65

Effective October the 27th 2017 the Office of Environmental Health Hazard Assessment (OEHHA) is adding N,N-dimethylformamide, 2-mercaptobenzothiazole, and tetrabromobisphenol A to the list of chemicals known to the State of California to cause cancer.

Effective November 10, 2017, the Office of Environmental Health Hazard Assessment (OEHHA) is adding perfluorooctanoic acid (PFOA) and perfluorooctane sulfonate (PFOS) to the list of chemicals known to the state to cause reproductive toxicity.

Substance Introduction

Chemical CAS No. Endpoint Main uses
N,N-Dimethylformamide 68-12-2 cancer Mainly used as reaction solvent, and intermediate in organic synthesis, containing in leather, PCB, etc.
2-Mercaptobenzothiazole 149-30-4 cancer Used for the manufacture of rubber products
Tetrabromobisphenol A 79-94-7 cancer Flame retardants, used in plastics, rubber, textile, fiber and paper, etc.
Perfluorooctanoic acid (PFOA) 335-67-1 Developmental toxicity In paint, coatings, printing ink industries as flow flat, anti-sticking, antifouling agent; In the fire industry used as the light water foam fire extinguishing agent; In polymer system used as emulsifying agent, release agent, antifoggant and antistatic agent; In the electronics industry as a cleaning agent, flux, oxidation inhibitors; As a lubricant in metal fabrication, rinse additive, corrosion inhibitor.
Perfluorooctane sulfonate (PFOS) 1763-23-1 Developmental toxicity Widely used in surface treatment, paper protection, electroplating inhibitory spray and other fields because of  excellent waterproof and oil-resistance function.

CA 65 Introduction

Proposition 65, the Safe Drinking Water and Toxic Enforcement Act of 1986, was enacted as a ballot initiative in November 1986. The Proposition was intended by its authors to protect California citizens and the State‘s drinking water sources from chemicals known to cause cancer, birth defects or other reproductive harm, and to inform citizens about exposures to such chemicals. so, in theory, all products containing hazardous substances within the scope of its control, including but not limited to Electrical and electronic products, textile products, toys, food contact materials, jewelry products and home decor products.

Proposition 65 requires the state to maintain and update a list of chemicals known to the state to cause cancer or reproductive toxicity.

 

CTI Suggestion

California‘s 65 does not set limit to the material. The limit of substances in the products should refer to any existing lawsuit aiming at this kind of product or agreement. Enterprises should compare the existing lawsuit of substances control requirements and focus on newly added substances and risky chemicals. In  order to reduce the risk of breach of the law, companies are suggested to conduct a supply chain survey and perform testing if necessary.

TMA and DCHP are planned to be identified as SVHCs

ECHA has submitted two notifications the to the TBT: G/TBT/N/EU/519,  and G/TBT/N/EU/520 aims at identifying TMA as a substance of very high concern due to its respiratory sensitisation properties according to Article 57(f) of Regulation (EC) No 1907/2006 (REACH) , DCHP as a substance of very high concern due to its classification as toxic to reproduction according to Article 57(c) of Regulation (EC) No 1907/2006 (REACH) and due to its endocrine disrupting properties whose effects to human health give rise to an equivalent level of concern according to Article 57(f) of that Regulation. DCHP and TMA  was respectively on the fifteenth and  sixteenth batch SVHCs public consultation  list.

Proposed date of adoption: March 2018

Proposed date of entry into force: March 2018

Final date for comments: 60 days from notification

Proposed Substances

No. Substance Name EC No. CAS No. Use Reason for proposing
1 benzene-1,2,4-tricarboxylic acid 1,2 anhydride (trimellitic anhydride, TMA) 209-008-0 552-30-7 Manufacture chemicals, such as polyester resin, polyimide resin, high temperature insulation materials, PVC plasticizers, etc. Equivalent level of concern having probable serious effects to the environment (Article 57 f)
2 Dicyclohexyl phthalate (DCHP) 201-545-9 84-61-7 Consumer Uses in adhesives and sealants, coating products, fillers, putties, plasters, modelling clay, finger paints, non-metal-surface treatment products, inks and toners, polishes and waxes, polymers and textile treatment products and dyes ; PVC, rubber , plastic  articles as plastisol. Toxic for reproduction (Article 57 c)
Equivalent level of concern having probable serious effects to human health and the environment (Article 57 f)

Legal Obligations of Companies

Producers and exporters of protucts containing any of the SVHC candidates shall notify ECHA if both of the following conditions apply:

i. the substance is present in those articles in quantities totaling over on tonne per producer or exporter per year, and

ii. the substance is present in those articles above a concentration of 0.1% weight by weight.

CTI Suggestion

As the SVHC Candidate List is consistently updated, companies are facing increasing numbers of control requirements. Producers of articles shall notify the ECHA within six months after a substance has been included in the SVHC Candidate List if they meet the conditions. Companies should focus on REACH news and take necessary preventative actions as soon as possible.

ECHA Launches a public consultation on 9 potential SVHCs

ECHA has launched a public consultation on 9 proposed substances of very high concern (SVHCs). The public consultation was open for 45 days and ended on the 20th of Oct 2017. Interested parties were invited to join the public consultation by posting their comments on the ECHA website. Substances passing the public consultation will become the eighteenth batch SVHCs. For BPA is already listed on the Candidate List because of  its endocrine disrupting properties.

Proposed Substances

No. Substance Name EC No. CAS No. Potential Use Reason for proposing
1 Dechlorane plus (including any of its individual anti- and syn-isomers or any combination thereof) 236-948-9

etc.

13560-89-9; 135821-74-8; 135821-03-3

etc.

Used as a non-plasticising flame retardant, used in adhesives and sealants and in binding agents vPvB
2 4,4’-isopropylidenediphenol (bisphenol A; BPA) 201-245-8 80-05-7  Used in the manufacture of polycarbonate, as a hardener for epoxy resins, as an anti-oxidant for processing PVC and in the production of thermal paper Endocrine disrupting properties

(Article 57(f) – environment)

3 Benz[a]anthracene 200-280-6 56-55-3 Normally not produced intentionally but rather occurs as a constituent or impurity Carcinogenic ;
PBT ;
vPvB.
4 Cadmium nitrate 233-710-6 10325-94-7 Used in laboratory chemicals and for the manufacture of glass, porcelain and ceramic products Carcinogenic ;
Mutagenic ;
Specific target organ toxicity after repeated exposure.
5 Cadmium carbonate 208-168-9 513-78-0 Used as a pH regulator and in water treatment products, laboratory chemicals, cosmetics and personal care products Carcinogenic ;
Mutagenic ;
Specific target organ toxicity after repeated exposure.
6 Cadmium hydroxide 244-168-5 21041-95-2 Used in laboratory chemicals and for the manufacture of electrical, electronic and optical equipment Carcinogenic ;
Mutagenic;
Specific target organ toxicity after repeated exposure.
7 Chrysene 205-923-4 218-01-9 Normally not produced intentionally but rather occurs as a constituent or impurity Carcinogenic ;
PBT ;
vPvB .
8 Reaction products of 1,3,4-thiadiazolidine-2,5-dithione, formaldehyde and 4-heptylphenol, branched and linear (RP-HP) [with ≥0.1% w/w 4-heptylphenol, branched and linear] Used as a lubricant additive in lubricants and greases Endocrine disrupting properties
9 Tricobalt tetraoxide containing ≥ 0.1% w/w nickel oxides 215-157-2 1308-06-1 Used in laboratory chemicals, pH regulators and in water treatment products, semiconductors, polymers and coating products Carcinogenic

CTI Suggestion

As the SVHC Candidate List is consistently being updated, companies are facing increasing numbers of control requirements. Producers of products shall notify the ECHA within six months after a substance has been included in the SVHC Candidate List if they meet the conditions. Companies should focus on REACH news and take necessary preventative actions as soon as possible.

Taiwan BSMI will implement RoHS control of six products in July 2017

The Taiwan Bureau of Standard, Metrology and Inspection (BSMI) announced the following six categories of products will be incorporated into the Taiwan RoHS control on the 1st of July 2017. According to CNS 15663 requirements, the contents of the restricted substances should be marked. Product categories include:

         Automatic data processors,

         Printers,

         Image copiers,

         Televisions,

         Monitors,

         Monitors used in the automatic data processing system.

       Scope and Restricted Substances Requirement

BSMI has announced standard “CNS 15663 Guidance to reduction of the restricted chemical substances in electrical and electronic equipments” In 2013, which includes restricted substances, maximum concentration values and marking for EEE.

Table 1 scope, restricted substances, and maximum concentration values.

Scope Substance MCV wt %
1. Large household appliances

2. Small household appliances

3. IT and telecommunications equipment

4. Consumer equipment

5. Lighting equipment

6. Electrical and electronic tools

7. Toys, leisure and sports equipment

8. Automatic dispensers

9. other equipment

Pb 0.1
Hg 0.1
Cd 0.01
Cr6+ 0.1
 PBB 0.1
PBDE 0.1

Table 2 marking example

Equipment name:XXX,model:XXX
units Restriced substances and chemical symbols
Pb Hg Cd Cr+6 PBB PBDE
…… …… …… …… …… …… ……

Remark: If the concentration doesn’t exceed the MCV, mark “0”; if concentration exceeds the MVC, mark “exceeding 0.1 wt%”or “exceeding 0.01 wt%”; if concentration exceeds the MCV but is exempt, mark “–”.

Marking Requirement

The standard stipulates that the restricted substance should be marked on the body of the goods, packaging, labels or instructions.

The identification code of the commodity inspection mark needs to indicate the content of restricted material, such as RoHS or RoHS (XX.XX), the identification code must be placed on the bottom or right side of the second line of the commodity inspection mark. Examples are as follows:

 

The SVHC Candidate List is updated to include 174 substances

On the 7th of July 2017 ECHA published a Decision adding PFHxS to the SVHC Candidate List, and at the same time BPA add endocrine disrupting properties as Intrinsic properties in SVHC. BPA is already listed on the Candidate List because it is toxic for reproduction now the SVHC Candidate List includes a total of 174 substances in 17 batches.

In addition, the Commission adopted Implementing Decision (EU) C(2017) 4462 of 4

July 2017 identifying BBP, DEHP, DBP, DIBP as substances having endocrine disrupting properties whose effects to human health give rise to an equivalent level of concern. These four substances are already listed on the Candidate List their entries shall now be updated to reflect the additional intrinsic properties of concern.

New  Substances in SVHC Candidate List

No. Substance Name EC No. CAS No. Potential Use Intrinsic property(ies) in SVHC
1 Perfluorohexane-1-sulphonic acid and its salts (PFHxS) In paint, coatings, printing ink industries as flow flat, anti-sticking, antifouling agent. vPvB (Article 57e)

Update of Intrinsic properties in SVHC Candidate List

No. Substance Name EC No. CAS No. Potential Use Intrinsic property(ies) in SVHC
1 4,4’-isopropylidenediphenol (bisphenol A; BPA) 201-245-8 80-05-7 Manufacture of polycarbonate, epoxy resins and chemicals; hardener in epoxy resins Toxic for reproduction (Article 57c)

Endocrine disrupting properties (Article 57(f) – human health)

2 Benzyl butyl phthalate (BBP) 201-622-7 85-68-7 Plasticizer synthetic resins and polymers (mainly PVC)
3 Bis(2-ethylhexyl) phthalate (DEHP) 204-211-0 117-81-7
4 Dibutyl phthalate (DBP) 201-557-4 84-74-2
5 Diisobutyl phthalate (DIBP) 201-553-2 84-69-5

Legal Obligations of Companies
Producers and exporters of articles containing any of the SVHC candidates shall notify ECHA if both of the following conditions apply:

i. the substance is present in those articles in quantities totaling over on tonne per producer or exporter per year, and

ii. the substance is present in those articles above a concentration of 0.1% by weight.

EU amends exemption list of Annex 3 of RoHS 2

On the 16th of June 2017 the Official Journal of the European Union has published Directives (EU) (EU)2017/1009,(EU)2017/1010 and (EU) 2017/1011 to amend point 9(b) and point 13(a) regarding an exemption on lead , and 13(b) as regarding an exemption on lead  and cadmium. The directives shall enter into force on the twentieth day following that of its publication in the Official Journal of the European Union.

The main update subdivides the exemptions material uses and adds the expirys time accordingly.

Main amendments

9(b) Lead in bearing shells and bushes for refrigerant-containing compressors for heating, ventilation, air conditioning and refrigeration (HVACR) applications Applies to categories 8, 9 and 11; expires on:

—  21 July 2023 for category 8 in vitro diagnostic medical devices,

—  21 July 2024 for category 9 industrial monitoring and control instruments and for category 11,

—  21 July 2021 for other subcategories of categories 8 and 9.

9(b)-(I) Lead in bearing shells and bushes for refrigerant-containing hermetic scroll compressors with a stated electrical power input equal or below 9 kW for heating, ventilation, air conditioning and refrigeration (HVACR) applications Applies to category 1; expires on 21 July 2019.’
13(a) Lead in white glasses used for optical applications Applies to all categories; expires on:

—  21 July 2023 for category 8 in vitro diagnostic medical devices;

—  21 July 2024 for category 9 industrial monitoring and control instruments and for category 11;

—  21 July 2021 for all other categories and subcategories

13(b) Cadmium and lead in filter glasses and glasses used for reflectance standards Applies to categories 8, 9 and 11; expires on:

—  21 July 2023 for category 8 in vitro diagnostic medical devices;

—  21 July 2024 for category 9 industrial monitoring and control instruments and for category 11;

—  21 July 2021 for other subcategories of categories 8 and 9

13(b)-(I) Lead in ion coloured optical filter glass types Applies to categories 1 to 7 and 10; expires on 21 July 2021 for categories 1 to 7 and 10’
13(b)-(II) Cadmium in striking optical filter glass types; excluding applications falling under point 39 of this Annex
13(b)-(III) Cadmium and lead in glazes used for reflectance standards

EU amends Annex 17 of REACH regulation regarding PFOA

On the 14th of June 2017 the Official Journal of the European Union published (EU) 2017/1000, adding Entry 68 of Annex XVII to the REACH Regulations regarding PFOA. This Regulation shall enter into force on the twentieth day following that of its publication in the Official Journal of the European Union.

Substance Restrictions
‘68. erfluorooctanoic acid (PFOA)

CAS No 335-67-1

EC No 206-397-9

and its salts.

Any related substance (including its salts and polymers) having a linear or branched perfluoroheptyl group with the formula C7F15– directly attached to another carbon atom, as one of the structural elements. Any related substance (including its salts and polymers) having a linear or branched perfluorooctyl group with the formula C8F17– as one of the structural elements. The following substances are excluded from this designation: — C8F17-X, where X = F, Cl, Br. — C8F17-C(=O)OH, C8F17-C(=O)O-X′ or C8F17-CF2-X′ (where X′ = any group, including salts).

1. Shall not be manufactured, or placed on the market as substances on their own from 4 July 2020.

2. Shall not, from 4 July 2020, be used in the production of, or placed on the market in: (a) another substance, as a constituent; (b) a mixture; (c) an article, in a concentration equal to or above 25 ppb of PFOA including its salts or 1 000 ppb of one or a combination of PFOA-related substances.

3. Points 1 and 2 shall apply from:

(a) 4 July 2022 to: (i)equipment used to manufacture semi-conductors; (ii) latex printing inks. (b) 4 July 2023 to: (i) textiles for the protection of workers from risks to their health and safety; (ii) membranes intended for use in medical textiles, filtration in water treatment, production processes and effluent treatment; (iii) plasma nano-coatings. (c)4 July 2032 to medical devices other than implantable medical devices within the scope of Directive 93/42/EEC.

4. Points 1 and 2 shall not apply to any of the following:

(a) perfluorooctane sulfonic acid and its derivatives, which are listed in Part A of Annex I to Regulation (EC) No 850/2004; (b) the manufacture of a substance where this occurs as an unavoidable by-product of the manufacture of fluorochemicals with a carbon chain equal to or shorter than 6 atoms; (c)a substance that is to be used, or is used as a transported isolated intermediate, provided that the conditions in points (a) to (f) of Article 18(4) of this Regulation are met;(d) a substance, constituent of another substance or mixture that is to be used, or is used: (i)in the production of implantable medical devices within the scope of Directive 93/42/EEC; (ii) in photographic coatings applied to films, papers or printing plates; (iii)in photo-lithography processes for semiconductors or in etching processes for compound semiconductors; (e) concentrated fire-fighting foam mixtures that were placed on the market before 4 July 2020 and are to be used, or are used in the production of other fire- fighting foam mixtures.

5. Point 2(b) shall not apply to fire-fighting foam mixtures which were: (a) placed on the market before 4 July 2020; or (b) produced in accordance with point 4(e), provided that, where they are used for training purposes, emissions to the environment are minimised and effluents collected are safely disposed of.

6. Point 2(c) shall not apply to: (a) articles placed on the market before 4 July 2020; (b) implantable medical devices produced in accordance with point 4(d)(i); (c) articles coated with the photographic coatings referred to in point 4(d)(ii); (d) semiconductors or compound semiconductors referred to in point 4(d)(iii).’

Risk Analysis

PFOA is a persistent, toxic, and bioaccumulative substance. Due to these properties it may cause severe and irreversible adverse effects on the environment and human health. PFOA contains all the fluorine and the whole fluorine acid salts, it is mainly used in the surface treatment of household products, convenience food packaging, anti fouling materials, clothing and other consumer goods.

The EU has released (EU) 2017/752 to amend (EU) 10/2011 on plastic materials and articles intended to come into contact with food

On the 29th of April 2017 the European Commission published Regulation (EU) 2017/752[1] amending Regulation (EU) No 10/2011 on Plastic Materials and Articles Intended to Come into Contact with Food. (EU) 2017/752 updates the list of authorized Substances in Annex I of (EU) 10/2011 adding a restriction on nickel, and adjusts the food simulant assignment for testing overall migration into table form. (EU) 2017/752 shall enter into force on the twentieth day following that of its publication in the Official Journal of the European Union. The restriction on nickel shall apply from the 19th of May 2019.

The main amendment

(1).   The authorized Substances list in Annex I of (EU) 10/2011 is amended as follows:

(a)   in point 1, Table 1 is amended as follows: (i) in column 11 as regards the entries for the substances with FCM substance numbers 142, 168, 202, 387, 462, 467, 481, 502, 662 and 779, the reference to note ‘(1)’ is deleted; (ii) inserted six substances in numerical order of the FCM substance numbers

(b)   in point 3, in Table 3, the following entry is added:

‘(24) The substance or its hydrolysis products are authorised food additives and compliance with Article 11(3) shall be verified’;

(2).   in point 1 of Annex II, the following line is inserted after Manganese:

‘Nickel = 0,02 mg/kg food or food simulant.’;

(3).   in Annex III, point 4 is replaced by the following:

4. Food simulant assignment for testing overall migration

For tests to demonstrate compliance with the overall migration limit food simulants shall be chosen as set out in Table 3:

Table 3
Food simulant assignment for demonstrating compliance with the overall migration limit

Foods covered Food simulants in which testing shall be performed
all types of food 1. distilled water or water of equivalent quality or food simulant A (Ethanol 10 % (v/v));

2. food simulant B (Acetic acid 3 % (w/v)); and

3. food simulant D2 (Vegetable oil ).

all types of food except for acidic foods 1. distilled water or water of equivalent quality or food simulant A (Ethanol 10 % (v/v)); and

2. food simulant D2 (Vegetable oil ).

all aqueous and alcoholic foods and milk products food simulant D1 (Ethanol 50 % (v/v))
all aqueous, acidic and alcoholic foods and milk products 1. food simulant D1 (Ethanol 50 % (v/v)); and

2. food simulant B (Acetic acid 3 % (w/v))

all aqueous foods and alcoholic foods up to an alcohol content of 20 % food simulant C (Ethanol 20 % (v/v))
all aqueous and acidic foods and alcoholic foods up to an alcohol content of 20 % 1. food simulant C (Ethanol 20 % (v/v)); and

2. food simulant B (Acetic acid 3 % (w/v)).’

(4).   in Annex IV, point 8(iii) is replaced by the following:

‘(iii) the highest food contact surface area to volume ratio for which compliance has been verified in accordance with Article 17 and 18 or equivalent information;’

Implementation time and transition period

(1) (EU) 2017/752 shall enter into force on the twentieth day following that of its publication in the Official Journal of the European Union.

(2) The restriction of nickel shall apply from 19 May 2019.

(3) Plastic materials and articles complying with Regulation (EU) No 10/2011 as applicable before the entry into force of this Regulation, may be placed on the market until 19 May 2018 and may remain on the market until exhaustion of stocks.

Suggestion:

(EU) 10/2011 has been revised 8 times since it was issued in 2011. The first six amendment focus on the authorized substances in Annex 1. The seventh amendment (EU) 2016/1416 published on august 2016 has greater impact. (EU) 2016/1416 revised the authorized substances in Annex 1 clarified and corrected some definitions; re- restricted the migration of heavy metals and adjusted the test conditions of specific migration.

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EU Commission amends 2009/48/EC to reduce lead in toys

On the 25th of September 2014 the European Commission (EC) has notified the World Trade Organization (WTO) a revision to the lead limit in Annex II under the Toy Safety Directive 2009/48/EC (TSD). The EU proposes to adopt the amendment in the first quarter of 2015, with it coming into force in the third quarter of 2016.

On 27 April 2017, the European Commission has published Directive (EU) 2017/738 , amending Annex II of the toy safety Directive 2009/48/EC to reduce the limits of lead in toys which will come into force on the 28th of October 2018.

The revised content is as follows:

MIGRATION LIMITS FOR LEAD
CategoryⅠ: Dry, brittle, powder like or pliable materials

(mg/kg)

CategoryⅡ: Liquid or sticky materials

(mg/kg)

CategoryⅢ:Scraped-off materials

(mg/kg)

2009/48/EC(TSD) 13.5 3.4 160
(EU)2017/738 2.0 0.5 23

Lead (CAS No. 7439-92-1) as a toxic metal which can cause serious damage to human health and children’s intelligence. Even low-level exposure to lead can damage the brain and nervous system and even cause a decline in memory and cause learning difficulties. The probability of lead poisoning of children is more than 30 times that of adults. As children grow their organs are not yet mature and as such their detoxification function is not perfect meaning they are more sensitive to lead.