### ------ -----

AAP Headquarters 141 Northwest Point Blvd Elx Grove Village, IL 60007·1019 Phone: 8471434-4000 Fax: 847/434-8000 E-mail: kidsdocs@aap.org www.aap.org Reply to Department ofFederal Affairs Homer Building. Suite 400 N 601 13th St NW Washington, DC 20005 Phone: 2021347-8600 Fax: 202/393-6137 E-mail: kidslst@aap.org

Executive Committee President O. Manon Surton, MD, FAAP President-Elect Robert W Block, MD, FAAP Immediate Put President JudIth S. Palfrey, MD, FAAP Executive Director/CEO Errol R. Alden, MD, FAAP Board of Directors District I Carole E. Allen, MD, FAAP Arlington, MA District II HenryA. Schaeffer, MD, FAAP Brooklyn, NY District III Sandre Gibson Hassink. MD, FAAP Wilmington, DE DistrictIV Francis E. Rushton, Jr, MD, FAAP Beaufort. SC District V Manlyn J Bull, MD, FAAP Indianapolis, IN DistrictVI Michael V. Severson, MD, FAAP Brainerd, MN DistrictVII Kenneth E Matthews, MD, FAAP College Station, TX DistrictVIII Mary P Brown. MD, FAAP Bend, OR DistrictIX Myles B. Abbott, MD, FAAP Berkeley, CA District X Jotm S, Curran, MD. FAAP Tampa, FL 

# Anlerican AcadenlV ofPediatrics .I DEDICATED TO THE ilEA Ttl OF AI.!. CHll.lllU-:;\J



### ---....**-------~, ~-------** 

March 24,20

### II
The Honorable Ann Northup Commissioner U,S. Consumer Product Safety Commission 4330 East West Highway Bethesda, MD 20814
Dear CommissionerNorthup:
Thankyou for this opportunity to respond to your questions following my testimony on behalfofthe American Academy ofPediatrics (AAP) on February 16, 20II at the Consumer Product Safety Commission (CPSC) hearing, "Children's Products Containing Lead: Technological Feasibility of 1OOppm for Lead Content."
I. Inyourwritten testimony, you state thatan object with 77ppm "wouldbe capable of' raising a child's bloodleadlevel to a level that wouldresult in the loss of one IQpoint. By "capable oJ:" doyou mean that 

## if an**o~ject** with 77ppm were swallowedandallowedtopass through a child'sdigestive\)'slem. that wouldbe the result? Pleaseprovide the study orstudies upon which that conclusion is based.
Your understanding ofmy statement is correct Attached is a version ofmy testimony with all sources cited. I have also attached a copy ofa January 2009 letter provided to Senate Commerce Committee Chairman John Rockefeller explaining in detail the development ofthe AAP's recommendation to limit lead in children's productsto 40 parts per milIion (ppm).
2. Your testimony also identffies the consequence of the "ingestion" of an ilenl containing300ppmof lead. By ingestion, doyou mean a child'sswallowing of an object andthe object thenpassingthrough the child'sdigestive system? Pleaseprovide the studyorstudies upon which those consequences are based.
In my testimony, ingestion refers to the process oftaking an item or material into the body by oral consumption. Most such items will pass through the digestive tract, although in the case ofvery small amounts ofmaterial (e.g. lead dust), it may be absorbed directly into the bloodstream before reaching the lower reaches ofthe digestive tract. Some items may pass through the digestive tract relatively rapidly, while others could remain in the stomach for very long periods oftime. The attached copy ofmy testimony contains rderencesto the studies used to formulate these conclusions.

### 3. Is it

### true thatthe amount ofbioavailable leadin an object that is ingestedby a child is afimction of both theppm of lead in the object andthe totalsize of the object? 

## !l so, how does the datayou citedregarding thepotentialeffoct ofobjects with particularppm of leadtake into account the size of the object? 

### The amount ofbioavailable lead in an object may vary based on a range offactors related to both the object and the individual child. With regard to the object involvcd, variables may include the parts per million, the particular type ofmaterial (metal, plastic, vinyl, crystal, etc.), the age orcondition ofthe item (new versus worn), and the size or number ofitems ingested, among other things. In addition, each individual child may have a greateror lower risk than average, which can vary based on factors such the child's age, stage ofgrowth (Le. sensitive windows ofdevelopment) and nutritional status. The surface area presented by the object can also affect the amount oflead released into the digestive tract. Digestive fluids interact with surfaces oflarger items to increase absorption from those items. A significant surface area can be presented by one larger item or several small items ifingested. In the case oflead dust, the individual particles may be invisible to the naked eye but are absorbed directly from the digestive tract into the bloodstream with high efficiency. 

### 4. Does the amount ofbioavailable leadin anobject also dependupon other characteristics of the material in which the leadis contained, such as its density, hardness orthe other components itcontains (i.e. brass, othermetalalloy, paint)? 

## !l so, how does the datayou citedregardingthepotentialeffect ofobjectswith particularppm of/eadtake into account the othercharacteristics of the material in which the leadis contained? 

### As noted in the question above, the amount ofbioavailable lead may vary depending on factors related to both the material and the individual child, making computations difficult. Chang etal., 

### found high bioaccessibility in the stomach (up to 77%) oflead vacuumed from carpets. 1 

### This high bioaceessibility limit worked best in models to predict children'sblood lead levels.
5. Pleaseprovide me with anystudies of whichyouare aware that show the afJecl to a child'shealth, IQ. orotherrllise, causedby a childlicking, butnot swallowing, a metalobjectcontainingleadin the metalsubstrate. 

### The main pathway for lead ingestion is getting lead on hands and putting hands in mouth. Lead can be transferred from a surface to the hand and then to food or other objects put into the mouth orthe hand directly put into the mouth. Onc particularly high quality study involved observation ofchiIdren playing in ayard; researchers video-observed their hand-to-mouth behavior and then evaluated relationship oforal behaviors to children's blood lead levels. Children with higher hand-to-mouth occurrences had correspondingly higher blood lead levels. Investigators video-observed children ages I years putting a hand in their mouth 7times hourly (maximum 67 times/hour) and an object or food in their mouth 17 times hourly (maximum 125 

### timeslhour).2

### Areview ofreports that describe children's mouthing was published by the U.S. Environmental Protection Agency (EPA) in 2009.3 

### The EPA report has a significant quantity ofsimilar data, with frequency oforal behaviors and minutes/day ofmouthing. The amount oflead that would betransterred to 

### a child may depend on mouthing behavior (times/hour and minutes/day) and the transfer rate oflead from the object to the hand (ifthe object is touched and not directly mouthed). Children as old as 10-12 years put their hand in their mouth an average of4 times hourly. This rate is much higher among younger children, and exposures from mouthing behaviors can be occurring for several hours daily per child. Even for adult workers, hand lead is associated with blood lead leveJ.4
In addition, the Centers for Disease Control and Prevention's Mortality and Morbidity Weekly Report (CDC MMWR) has published cases oflead poisoning not related to ingestion ofobjects. Most recently, the MMWR published a case study ofa toddler poisoned by a metal charm on a necklace he wore and mouthed regularly.5 The MMWR has also published cases oflead poisoning from eating offlead-tainted dishware;6 lead dust contamination offamily vehicles;7 and exposure to lead at a firing range among adolescent members ofa shooting team. 8


### 6. Please explain how the studies upon whichyou rely to correlateprecise IQpOint 1: 

### 'ss with the ingestion of objects withparticularppm of leadcontrol for other factors known orsuspectedto also reduceIQ in children, such as glues andothersolvenls, poornutrition, andtobacco. Studies that examine the effect oflead on IQ and other outcomes measure the confounding factors associated with lead. While each study may vary in what is measured, key variables to assess include maternal TQ, Home Observation for Measurement ofthe Environment Inventory score (which is a measure ofthe quality and quantity ofstimulation and support available to a child in the home environment), maternal education, and birth weight. Many studies to examine the impacts oflead on children have rigorously assessed and adjusted findings for numerous other influences which theoretically could be associated with the outcome measured. The findings ofmaternal solvent exposures during pregnancy negatively influencing child developmental outcomes is a relatively new report, with exposures occurring in the workplace and othercharacteristics ofthe mother not differing between exposed and control groups.9 While this is an important issue that bears further investigation, it does not cast any doubt upon the substantial literature documenting IQ decrements associated with lead exposure. 7. Pleaseprovide me with all of the studies upon whichyou relied inpreparingyour written testimony. See attached copy ofmy testimony as well as the letterto Chairman Rockefeller.

### 8. Please tellme with**re~pect** 

### to eachstudyprovidedin response to Question 

### 7whether it ispeerreviewed, whether it is recognizedby the Centers for Disease Controland the NationalInstitute of Health. andwho commissionedthe study. 

### All ofthe published studies referenced in my testimony appeared in peer-reviewed journals. The CDC and NIH do not "recognize" studies per se. InJurmation on funding lor each study is generally required to be disclosed and is pubUshcd as part ofthe study. As you will see in the attached letter to Chairman Rockefeller, the AAP also made use of the California Office ofEnvironmental Health Hazard Assessment analysis that evaluated the upper 97.5% confidence level ofblood lead level associated with this effect, a 1IQ point loss would be prevented by limiting a child's BLL increase to no more than I mcg/dL.JO 

### The AAP utilized the CPSC's data and calculations set out in its 2005 Interim Enforcement Policy Lead Levels. 11 

### Finally, the AAP took into account the U.S. Food and Drug Administration's upper limit for lead in food at 6 mcg/lead/day for children aged <6 years, which the FDA states is expected to cause a child's blood lead level to rise by I mcg/dL. 9. Why does theAAPwebsite. which contains extensive writing.'}' andwarnings concerningthe hazards of leadingestion by children, not recommendtakingaway from children, includingeven those atthe "tippingpoint" for leadpoisoning, older bicycles, tricycles, toy trucks, scooters, wagons, andany otherproducts containing substantiallymore lead in the substrate than ;,'1

### permitted under currentlaw? 

### Because lead is invisible to the consumer or parent, it is impossible to know whether any given toy or children's product contains lead. The AAP strongly urges parents to follow the age recommendations for toys and to be vigilant about products that may contain lead. However, because it is essentially impossible for parents, caregivers or pediatricians to determine ifan individual product contains lead, it remains incumbent upon the CPSC to protect children by minimizing lead exposure in consumer products.
10. How doyou reconcile EnvironmentalProtectionAgencyregulations thatpermit 80,OOOppm of leadinpipes carryingwaterforhuman consumption withyour testimony that more than 40ppm of leadin substrate is an unacceptable safety hazard? 

### The EPA permits the use ofwater pipes and fittings that contain up to 8% lead, which is equivalent to 80,OOOppm. It should be noted, however, that EPA's "action level" for lead in the drinking water supplied by those pipes is 15 parts per billion (ppb), while bottled water is subjectto the even stricter standard of5 ppb. Under normal circumstances, tap water is not corrosive in nature, and so should nottypically extract lead from water pipes. Human saliva and digestive fluids are corrosive, however. Ira child happened to ingest a fragment ofpipe containing 8% lead, a significant amount oflead would be released and absorbed into the bloodstream.The AAP has a long history ofexpressing concern about the safety ofdrinking water and urging the EPA and other regulators to act in the best interests ofchildren when considering water standards options. However, the pernicious nature oflead requires 

### that efforts proceed with great caution. In January 2011, the AAP wrote to the EPA calling upon the agency to declare an immediate halt to all partial replacement oflead lines after studies indicated that partial line replacement may actually cause the release ofadditional lead into water supplies. The AAP continually follows the developing science and literatureto ensure that our positions renectthe latest and most up-to-date science and refine ourpositions accordingly to protect child health. Again, thank you for this opportunity to respond to your questions. Ifthe American Academy ofPediatrics or I may be offurther assistance, please contact Cindy Pellegrini in the AAP's Washington, DC office at 202/347-8600. Sincerely,

Dana Best, MD MPH FAAP

1Chang H, Lih-Ming Y, Lioy P. The Bioaccessibility ofLead (Pb) from Vacuumed House Dust on Carpets in Urban Residences. RiskAnalysis. 2006 Feb;26(1): 125-134. 2 Ko S, Schaefer P, Vicario C, Binns H, Safer Yards Project. Relationships ofvideo assessments of touching and mouthing behaviors during outdoor play in urban residential yards to parental perceptions of child behaviors and blood lead levels. J Expo Sci Environ**l~pidemio/.** 2007 Jan; 17(I):47-57. Iml1ilwv. IV

.lid)i . n1m

.nih.g(1**!1u~lb)11 C'lLL(1~2~tHllZ**  3 U.S. Environmental Protection Agency. Child-Specit1c Exposure Factors Handbook. August 2009, (EPA/600/R-08/]35). 4 Rodrigues E, Virji M, McClean M, Weinberg J, Woskie S, Pepper L. Personal exposure, behavior, and work site conditions as determinants ofblood lead among bridge painters. J Occup Environ Hyg, 20 10 Feb;7(2):80-7. 5Lead Poisoning ofaChild Associated with the Use ofaCambodian Amulet New York City, 2009. lyfMWR, January 28, 2011. 60(03);69-71. httlLl'\\ww.cdc.gl).yLIJ.!.!llIvr/previelv**jIlj}1~YIIJlmlilln1()O():;** a2JJlm
6 Childhood Lead Poisoning from Commercially Manufactured French Ceramic Dinnerware

- New York City, 2003. MMWR, July 9,2004. 53(26);584-586. hI**tp;i/I~.,.;;:di,:** .go" IIIImwr!prev il:V.'/l1lmwrlllmIL.!.1lln5.1.:(,:1"1.htm
7 Childhood Lead Poisoning Associated with Lead DustContamination ofFamily Vehicles and Child Safety Seats

- Maine, 2008. MMWR, August 21, 2009. 58(32);890-893.**1ll.!1l~'/** \ \ow**\£~:.ill;** ..g(lvIIII**fJl\:!lit21:£yiQ!~m!'~J** VVrhtil]III11111.5..&.32<1:1.hIll] 8 Lead Exposure from Indoor Firing Ranges Among Students on Shooting Teams

- Alaska, 2002-2004. MMWR, June 17,2005.54(23);577-579.**hljlL/i\\\v~y,edc.gOY~WlmY!:::nreviewiI11Inl\EIl.Lln!· mm~42:SJJ.ltm**  9 Laslo-Baker D, Barrera M. Knittel-Keren 0, Kozer E, Wolpin J, Khattak S, Hackman R, Rovet 1, Koren G. Child neurodevelopmental outcome and maternal occupational exposure to solvents. Arch l'edialr Ado/escMed 2004 Oct;158(10):956-61. 10 Carlisle J, Dowling K. Development ofHealth Criteria for School Site Risk Assessment Pursuantto Health and Safety Code Section 90l(g): Child-Specific Benchmark Change in Blood Lead Concentrationfor School Site Risk Assessment. Integrated Risk Assessment Branch Office ofEnvironmental Health Hazard Assessment California Environmental Protection Agency. April 2007. Available at hHn.::jwww,oehha.cwglpubllc;**illnl!pllbli1~L1j~l82d[l:lllJG** V041.i07**.p~r** II Consumer Product Safety Commission. Interim Enforcement Policy Lead Levels. February 14,2005. Available at**http://.\j}v\V.cl!~~~l.yO:ll:'S**INF();llhJ!Cwl**'.j~ll.**

# AmericanAcademy ofPediatrics
DEDICATED TO THE IIEAl.TH OF ALL CHll..llRI;N'

AAP Headquarters 141 Northwest Point Blvd Elk Grove Village, IL 60007·1098 Phone: 847/434-4000 Fax: 8471434·8000 E·mail: kidsdocs@aap,org www,aap,org Replyto Departmentof Federal Affairs Homer Building. Suite 400 N 601 13th St NW Washmgton, DC 20005 Phone: 2021347·8600 Fax: 2021393-6137 E,mail kidslst@aap,org

Executive Committee Prasident David T, Tayloe, Jr, MD, FAAP Presldent·Elect Judith S, Palfrey, MD, FAAP Immediate Past President Ramie R, Jenkins, MD, FAAP Executive DirectorlCEO Errol R. Alden, MD, FAAP Board of Directors District I Edward N, Bailey, MD, FAAP Salem, MA District II Henry A. Schaeffer, MD, FAAP Brooklyn, NY District III Sandra Gibson Hassink, MD, FAAP Wilmington, DE DistrictIV Francis E. Rushton, Jr, MD, FAAP Beaufort, SC DistrictV Marilyn J. Bull, MD, FAAP Indianapolis, IN DistrictVI Mich"el V, Severson, MD, FAAP Brainerd, MN DistrictVII Kennelh E. Matthews, MD, FAAP College Station, TX DistrictVIII Mary p, Brown, MD, FAAP Bend, OR District IX Myles S, Abbol\, MD, FAAP Berkeley, CA District X Jelln S. Cllmm, MD, FAAP Tampa, FL January 21, 2009 The Honorable John D, Rockefeller 

### TV Chairman Committee on Commerce, Science and Transportation 508 Dirksen Senate Office Building Washington, DC 20510
Dear Chairman Rockefeller:
The American AcademyofPediatrics, a non-profit professional organization of60,000 primary care pediatricians, pediatric medical sub-specialists, and pediatric surgical specialists dedicated to the health, safety, and well-being ofinfants, chiIdren, adolesccnts, and young adults, appreciates this opportunity to respond to your inquiry for morc details on the development ofour recommendations for limiting lead content in children's products. 

### LeadandChildren;sHealth
There is no "safe" level oflead exposure. The vulnerability ofchildren to lead poisoning during development oftheir brain:, and nervous system has been amply demonstrated, and the literature is very consistent. Onaverage, children whose blood lead levels (BLLs) rise from IOta 20 micrograms per deciliter (mcg/dL) lose two to three 

### 10 points. More recent studies have shown an even greater impact on 

### 10 ofBLLs under 10 mcg/dL. Key studies reported a loss of4 to 7 

### 10 points in children whose lead levels rose from I meg/dL to 10 mcg/dL,I,2 These studies suggest that "low" levels ofexposure - meaning BLLs less than 10 mcg/dL cause proportionately greater harm than higher levels. The effects oflead on health do not stop once the child's brain and nervous system mature orthe I3LL falls, !\ recent study found that in a group of7 year old children who had experienced a BLL of20­ 44 mcg/dL around age 2 years, the concurrent BLL (i.e., BLL taken at age 7 years when the 

## TO test was administered), was more closely associated with 

### [0 at age 7 years that BLL at age 2 or age 5 years.3
Another important lasting effect oflead exposure is on behavior, with higher rates 

### of behavioral problems reported in teens and adults exposed to lead during childhood, Children with elevated lead are more likely to have problems with inattention and reading, and are at higher risk offailing to graduate from high school,4 Investigators have idenlilied associations between lead exposure and increased aggression, commission ofcrime and antisocial or delinquent behaviors.s,6,7,X Studies have suggested that several nations which began reducing lead exposure aggressively in the 1970s experienced corresponding decreases in crime rates two to three decades later.9 Other effects include abnormal balance, poor eye-hand coordination, longer reaction times, and sleep disturbanccs. 1o,lu2

### Lead is easily absorbed by ingestion or inhalation. The most common route ofexposure ofchildren is through ingestion, usually by putting hands and other objects in their mouth·. Both hand-to-mouth exploration and playing on floors are typical behaviors for children, especially younger children. Studies using videos to record oral behaviors of young children report hand or object in mouth activities 20 or more times per hour.''.:**~** 

### If hands or objects placed in the mouth have lead, these usual childhood activities deliver doses oflead. Once lead enters the body it remains there for years. Lead is similar to calcium from the elemental perspective. This means that our bodies "sec" lead as calcium, absorb it into blood and then store it in bone. These stores oflead can be released years later, when bone changes occur or demands on calcium stores are made.ls 

### Another consequence of storing lead in bone is that exposures separated by months or years have an additive effect on the body'sburden oflead and can exert effects over decades. Acquisition of lead in the body even in small amounts (i.e., amounts that result in BLLs less than 10 mcg/dL) contributes to this accumulation oflead. This means that even short term or small cumulative exposures can have lasting negative effects. Over the past 30 years, average BLL has declined dramatically in the 

### U.s., due largely to the elimination ofIcad from gasoline and mandated restriction oflead content in paint. At the same time, however, elevated BLL is still not uncommon. Eliminating elevated blood lead levels was established as akey goal under the federal Healthy People 2010 initiative. 16 

### The AAP believes firmly that our nation must continue efforts to reduce childhood lead exposure and its pernicious impacts. In the past three years alone, the AAP has pushed the Environmental Protection Agency to reduce airborne lead emissiuns underthe National Ambient Air Quality Standards; urged the Food and Drug Administration to eliminate lead in imported candies and their wrappers; and continued our long-term engagement with the Department ofHousing and Urban Development to reduce children's exposure to lead paint in older housing and through home renovation activities. We intend to sustain these efforts to ensure that children's potential for exposure to lead is reduced as much as possible and new avenues ofexposure are not created. Leadin Children'sProducts 

### As you know, prior to the passage ofthe Consumer Product Safety Improvement Act (CPSIA), our government had never set limits for acceptable lead content in children's products, with the exception oflead in surface paint. The restriction oflead content to 600 parts per million (ppm) dates back to 1978 and does not apply to any other material or component in toys or children's products. As aresult, toys and children'S products could have unlimited amounts oflead in areas other than surface paint without violating any mandatory standard. Further, the 600 ppm limit for paint docs not represent a healthbased standard. Lead can tind its way il1to toys and children's products as a naturally-occurring component ofmaterials used or as a deliberate or incidental additive. Lead is used



### 2directly in certain materials, such as to stabilize some vinyl compounds and in lead crystal. Lead may also be a contaminant in air, water or soil that comes into contact with materials orcomponents during the manufacturing process. Regardless ofits source, however, lead's toxic effect on the developing brain requires us to examine these processes and minimize exposure whenever possible. Because there is no "safe" blood lead level in children, the AAP focused attention on limiting lead to trace amounts that would not represent "added" lead to products. 

### Developmentof theAAP

### LeadRecommendation
In September 2007, the AAP was asked by the House Committee on Energy and Commerceto testify about the hazards oflead and to make specific recommendations for lead contentthat would be used in the development ofproduct safety legislation. While the AAP had published guidelines on lead exposure prevention, detection and management in the past, we had never attempted nor been requested to provide specific targets for lead content in products. The recommendation delivered to Congress was an ancillary effort that builds upon but is not inconsistent with or contradictoryto our previously published statements. The AAP's recommendations were developed by our Committee on Environmental Health (COEH), which comprises 9 top pediatric environmental health experts serving in a volunteer capacity. While child health issues were their guiding principle, the COEH also wentto great lengths to examinethe associated practical issues involved to ensure that the final recommendations would be pragmatic and feasible. The primary considerations were: 1) no "safe"threshold for blood lead levels for chiIdren has been identified;l? 2) lead negatively affects health and development at levels well below 10 micrograms perdeciliter (mcg/dL) blood lead level;18 and 3) lead is a naturally-occurring element and may therefore be present is a wide array ormaterials so "lead-free" status may not be achievable in some products. Therefore, children's exposures to lead in products should be severely limited, but some low level ofexposure, a "trace" amount, could be expected. Theprimary goal ofthe COEH in developing these recommendations was to establish a guideline based directly on child health issues, rather than the selection ofan arbitrary number. Aftermuch discussion, the committee agreed that the appropriate benchmark for its recommendation should be the loss of 

### 1IQ point. Using California Office of Environmental Health Hazard Assessment analysis that evaluated the upper 97.5% confidence level ofblood lead level associated with this effect, a I IQ point loss would be prevented by limiting a child's BLL increaseto no more than I mcg/dL. 19 Supporting a rationale on 

### 1mcg/dL rise is the FDA upper limit for lead in food at 6 mcg/lead/day for children aged <6 years, which is expected to cause a child's BLL to rise by I mcg/dL.20 There is no logical reason to accept a higher rise in blood lead level from product exposure than from food exposure.

3TheCOEH's next task was to determine the amount oflead that would result in a child's BLL increasing by 

### 1mcg/dL from exposure to a child's product. This evaluation focllscci on information posted by CPSC evaluations.21 The committee determined as follows:

• Based on the 

### 1999-2000 National Health and Nutrition Examination Survey (NHANES), the average blood lead level ofa child aged 

### 1-5 years in the US in 

### 1999-2000 was 

### 2.2 mcg/dL. • In developing its recommendation for lead in toyjewelry, the CPSC calculated that an extractable lead content of 

### 175 mcg would cause an average child's BLL to rise to J0 mcg/dL over a 

### 1month exposureperiod. The agency determined that this level ofexposure occurs at a level of0.06% lead hy weight (600 ppm, coincidentally, the same limit as the 

### 1978 lead paint ban).22 • As noted above, however, the COEH had already determined that waiting for BLL to rise to 

### 10 mcg/dL was not acceptable due to the neurological damage that would occur. In orderto limit the BLL rise to I mcg/dL, the CPSC figures were divided by 

### 7.8, which represents the rise in BLL from 

### 2.2 mcg/dL to 

### 10 mcg/dL, to obtain the figure that would correlate to a BLL increase of I mcg/dL. Accordingly, 600 ppm lead divided by 

### 7.8 equals 77 ppm lead being capable or causing a BLL increase of 

### 1mcg/dL.
In its next step, the COEHtook into account the fact that most children are exposed to lead from a variety ofsources, which may include lead paint hazards in the home, airborne lead emissions, contaminated soil, and other consumerproducts. Since lead is bioaccumulative and highly persistent in the body, it is important to provide a margin of safety to ensure that exposure to a single toy or children's product cannot cause BLL to increase 1mcg/dL.
In determining how to setthis margin ofsafety, the

## com
.. examined the practical issues associated with lead exposure. Lead occurs naturally in the environment, so setting lead content at zero was not deemed to be a feasible recommendation. The committee examined data from a variety ofsourcesto learn about the naturaIgeological occurrence oflead in the United States. The U.S. Geological Survey provides nationwide data on lead exposure, which illustrates that naturally occurring lead levels generally top out at 30 ppm.23 The AAPconfirmed this data with Geological Survey and independent geologists. Given this evidence, the COEH recommended a two-fold margin ofsafety for lead content in children's products, dropping the recommendation from 77 ppm to 40 ppm. You may note thatthis is considerably lowerthan the margin ofsafety mandated under other federal laws; for example, the tolerance for pesticide residue on food requires a ten-fold margin ofsafety (i.e., limit set at one tenth ofthe amount estimated to cause the negative effect) for vulnerable populations, including children. 

### Developmentof the CPSIA Stmulcml (f1U1

### Exceptions Clause
Overthe yearthat Congress spent working intensively on this legislation, the AAP engaged in a detailed dialogue with both House and Senate offices regarding the merit of various possible exemptions to the lead guidelines. In partnership with these offices, the

4AAP collaborated on the development oflegislative language that empowersthe ConsumerProduct Safety Commission (CPSC) to accept and evaluate applications for such exemptions. This process will include possible exemption for inaccessible lead, although the definition ofinaccessibility was the subject ofmuch debate. Forexample, it was questioned whether lead would be considered inaccessible ifit were covered by paint or electroplating, or included in a compound such as vinyl or lead crystal. In each of these cases, the COEH advised that lead was not inaccessible because barriers like paint and electroplating can be breached, vinyl deteriorates with time and use, and lead leaches from crystal in the presence ofacid (including stomach fluids).
In the final legislation, the CPSC is specifically directed to examine the application ofthe lead standard to electronic products, including batteries, and to develop guidelines for minimizing children's exposureto lead that cannot be eliminated from these products. The AAP supported these proposals, which will allow for the transparent, science-based evaluation ofproposals to permit lead in certain components oftoys and children's products. The AAP anticipates offering our views and guidance to the CPSC as such applications are submitted and examined.

The AAP is acutely aware ofthe impact ourrecommendations can have, and we strive to ensure that all AAP recommendations are based on science and practical to implement. Led by the COEH, the AAP engaged in a thorough, evidence-driven review to develop our lead recommendations. Following that, AAP members and staffspent countless hours engaged with numerous Congressional offices to explore the issues associated with lead in children's products and to assist in crafting a final bill that would protect children's health through pragmatic, feasible standards. The AAP strongly supported 

### this legislation and looks forward to working with the Consllmer Product Safety Commission on its implementation in the coming years. I hope this letter satisfies your request for information and gives you confidence that the AAP's recommendations represent an empirically-based solution grounded in science. If the Academy may be offurther assistance, please contact Cindy Pellegrini in our Washington, D.C. Office at**202/347~8600.** Sincerely,



# ""l (\ 1'.

# '-7 f

# c:~JV<.~5~/ J

# ~**,,~ ~~K.**  

# 1\ (\, David T. Tayloe, 

### Jr., MD FAAP President

DTT:cp



### 5I Canfield RL, Henderson CR, Jr., Cory-SlechtaDA, Cox C, Jusko TA. Lanphear BP. Intellectual impairment in children with blood lead concentrations below 10 microg perdeciliter. NEnglJ Med 2003;348(16): 15 I7-J526. 2 Lanphear BP, Hornung R, Khoury J, et at. Low-level environmental lead exposure and children's intellectual function: an international pooled analysis. Environ Health Perspect. lui 2005;113(7):894-899. 3 Chen A, Dietrich KN, Ware lH, RadcliffeJ, Rogan WJ. IQ and blood lead from 2 to 7 years ofage: are the efTecls in olderchildren the residual ofhigh blood lead concentrations in 2-year-olds? Environ H£'alth Perspect. 2005;113(5):597-601. 4 Centers for Disease Control and Prevention. !Ifaf1agingElevatedBloodLeadLevelsAmong Young Childrell Recommendations/rom the Advisory Committee on ChildhoodLeadPoisoningPrevention. Atlanta, GA: Centers for Disease Control and Prevention.; 2002. 5 Dietrich KN, Ris MD, Succop PA, BergerOG, Bornschein RL. Early exposure to lead andjuvenile delinquency. Neurotoxico/Terato!' Nov-Dec 2001 ;23(6):511-518.
6 Ris MD, Dietrich KN, Succop PA, Berger OG, Bornschein RL. Early exposureto lead and neuropsychological outcome in adolescence.J Int Nl;iurop,lycho! Soc. Feb 2004:261-270. 1 BurnsJM, Baghurst PA, Sav.yer MG, McMichael AJ, Tong SL. Lifetime low-level exposure to environmental lead and children's emotional and behavioral development at ages 11-13 years. The Port Pirie Cohort Study.AmJ E"pidemiol. Apr 151999;149(8):740-749. 8 Nevin R. Understanding international crime trends: the legacy ofpreschool lead exposure.**"~nl'iron** Res, 2007;104(3):315-336. 9 Ibid. I(J Centers for Disease Control and Prevention. Managing ElevatedBloodLeadLevelsAmong Young Children. Recommendations/rom theAdvisory Committee on ChildhoodLeadPoisoning Prevention. Atlanta, GA: Centers for DIsease Control and Prevention; 2002. II Bhattacharya A, Shukla R, Dietrich KN, Bornschein RL. Effect ofearly lead exposure on the maturation of children's postural balance: a longitudinal study.Neurotoxicol Terato!' 2006;28(3):376-385. 12 Chiodo LM, Covington C, Sokol RJ, et al. Blood lead levels and specific attention effects in young children. Neurotoxical Teratol. Apr 21 2007. I] Reed KJ, Jimenez M, Freeman NC, Lioy PJ. Quantification ofchildren's hand and mouthing activities through a videotaping methodology.J ExpoAnalEnviron Epidemiol. 1999;9(5):513-520.
14 Ko S, Schaefer PO, Vicario CM, Binns HJ. Relationships ofvideo assessments oftouching and mouthing behaviors during outdoorplay in urban residential yards to parental perceptions ofchild behaviors and blood lend levels.J ExpoSciEnviron Epidemiol. 2007;17(1):47-57. 15 O'Flaherty EJ. A physiologically based kinetic model for lead in children and adults. Environ Health Perspecl. 1998;106 SuppI6:1495-1503. 16 Centers for Disease Control and Prevention, Healthy People 2010. '.:"":I.:

..**:.~** ...:._:....: ..: ..C

..**:_='.':.:.".'.:~.~=** ..:.,,'=C=".: 17 Centers for Disease Control and Prevention. Preventing Lead Poisoning in Young Children. Atlanta: CDC; 200S. IS Centers for Disease Control and Prevention. Interpretingand Managing Blood Lead Levels <10**~g/dL** in Children and Reducing Childhood Exposures to Lead: Recommendations ofCDC's Advisory Committee 011 Childhood Lead Poisoning Prevention. lvlMWR. November 2, 2007; 56(RR08):1-14;J6.
19 CarlisleJ, Dowling K. Development ofHealth Criteriafor School Site Risk Assessment Pursuant to Health and Safety Code Section 901(g): Child-Specific Benchmark Change in Blood Lead Concentration for School Site Risk Assessment. Integrated Risk Assessment Branch Office ofEnvironmental Health Hazard Assessment California Environmental Protection Agency. April 2007. Available at 11!illJW\,\If:ncbhi.Lm.!:!lj)J1bl ie info,]1Ib Iicil..id"indm:!illL;v()413U7.!.l1s.Ij'. 20 "DangersofLead Still Linger," FDA Consumer. U,S. Food and Drug Administration, January-February 1998. AvaiIabIe at**~j"c;** ••**-'-'--''-.':..'.c~C!.!.!.!.'-'-''.',',.';;.:''-'-'--._.'''.''.,'** ....' ",,,-,,-,'..'!,".**',-!.,.,~.** 21 Consumer Product Safety Commission. Interim Enforcement Policy Lead Levels. February 14.2005. Available at**b.!!.i~~.** c;z."'.e,,**'4"="'-1=-'C:""'.""""'!'~_'** ,.._,-""-,,.,,:'""--'-".!.o!:.j.'''''' :2 Consumer Product Safety Commission. Interim Enforcement Policy Lead Levels. February 14,2005. Available at bJ1Jl:.!iW\vw.cpsc,!!.Q.Y!.ltLSIN F O!pble-.;.cJ::CJ)ilJ 23 

### U.s. Geological Survey Professional Paper 1648. Geochemical Landscapes ortlle Conterminous united States­ New Map Presentations for 22 Elements. Figure 17. November200I. Available at 

### hIm:'ipubs.usgs.gov!ppipI

### 64S'nlS1

### '13.:pdf.
6

# Anlerican Academy ofPediatrics
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### Wednesday, February 16, 2011 Testimonyof DanaBest,MD, MPH, FAAP



### On behalfofthe AmericanAcademyofPediatrics



### BeforetheConsumerProductSafetyCommission "Children's Products Containing Lead: Technological Feasibilityof100ppm for Lead Content"

American Academy of Pediatrics • Department of Federal Affairs 601 13th Street NW, Suite 400 North • Washington, DC 20005 Tel: 800.336.5475 • E-mail: kids1st@aap.orgDana Best, MD, MPH, FAAP American Academy of Pediatrics Children's Products Containing Lead: Technological Feasibility of lOOppm for Lead Content February 16, ::011

ChairmanTenenbaum and Commissioners Adlcr, Moore, Nord and Northup, thankyou for this opportunity to speakto you today. My name is Dana Best, MD, MPH, FAAP, and I am pleased to represent the American Academy ofPediatrics (AAP), a non-profit professional organization of60,000 primary care pediatricians, pediatric medical sub-specialists, and pediatric surgical specialists dedicated to the health, safety, and well-being ofinfants, children, adolescents, and young adults. I am an Associate Professor ofPediatrics at George Washington University School ofMedicine and an attending physician atChildren'sNational Medical Center in Washington, D.C. I served tor six years on the AAP's Committee on Environmental Health, which is the primary body within the AAP that handles lead and other environmental health issues. Under the Consumer Product Safety Improvement Act of2008 (CPSIA), the Consumer Product Safcty Commission (CPSC) is directed to reduce to 100 parts per million (ppm) the allowable levels oflead in chiIdren's products in August2011, "unlessthe Commission determines that a limit of 100 parts per million is not technologically feasible for a product or product category." The AAP appreciates the Commission's diligence in seeking public input about the public health and other impacts ofreducing the permissible lead levels to lOOppm.
TheCommission has undoubtedly received and reviewed a tremendous amount ofmaterial about the research behind lead exposure and its impact on child health. I will therefore give only a briefoverview ofthe state ofthe science. Lelltll\'a

### Known Neurotoxin Lead has been recognized as a potent neurotoxin since the time ofthe Roman empire, although the mechanisms by which it inflicts brain damage have only been explored and understood in the past century. The brain damage caused by lead exposure is permanent and irreversible. Few options exist tortreating lead exposure at high levels, and these treatments have potentially dangerous side effects. No options exist for treating lead exposure at [ow to moderate levels. Exposure to lead is amply documented to cause the loss ofintellectual capacity. On average, children whose blood lead levels (BLLs) rise from 10 to 20 micrograms per deciliter (mcg/dL) lose two to three IQ points. More recent studies have shown an even greater impact on IQ of BLLs under 10 mcg/dL. Key studies reported a loss of4 to 7 IQ points in children whose lead levels rose from I mcg/dL to 10 mcg/dL. I ,2 These studies suggest that "low" levels ofexposure

meaning BLLs less than 10 mcg/dL

- cause proportionately greater harm than higher levels.
In addition to these impacts on IQ, lead exposure has documented effects on behavior, with higher rates ofbehavioral problems reported in young children, teens and adults exposed to lead during childhood. Investigators have identified associations between lead exposure and increased aggression, commission ofcrime and antisocial ordelinquent behaviors.J,4,5.6 Children with elevated lead are more likely to have problems with attention deficit, reading disabilities, and to fail to graduate from high school. Othereffects include abnormal balance, poor eye-hand 8 coordination, longer reaction times, and sleep disturbances.7

. ,9

Page 2 of 6Dana Best, MD, MPH, FAAP American Academy of Pediatrics Children's Products Containing Lead: Technological Feasibility of lOOppm for Lead Content February 16, 2011



### With all ofthis information in mind, it is critically important to note that lead is bioaccumulative. Apercentage oflead will be excreted by the body, and the rate ofclearance is dependent on a number offactors, including nutritional status. Buta percentage oflead is also stored in the body, primarily in bone. These body stores can persist over decades. When a woman becomes pregnant, her body draws upon its calcium stores to create her fetus's bone structure. Iflead has been stored in the bone, the developing fetus will be exposed to doses oflead at points throughout pregnancy. 10 

### Further, a women's blood lead in pregnancy puts her at higher risk for complications from high blood pressure. Arecent study in Environmental Health Perspectives found blood pressure to be about 4-6 mmHg higher in women giving birth to infants with a cord blood lead level of 1-6 mcg/dL versus cord blood levels of:::;0.46 mcg/dL,11 The costs associated with lead exposure arc tremendous. Health economists estimate that every time average blood lead level increases by a small amount" across the children born in any given year, $7.5 billion is lost in potential earnings forthose children. 12 

### Other studies have estimated the annual costoflead poisoning in American children at $43.4 billion. 13 

### Costs are borne by our health care, education, andjustice systems, among others. Lead is naturally present in our environmentat low levels. I-Iuman activities have raised those levels through contamination, whether by adding lead actively to products like paint or gasolinc or producing it as a byproduct ofactivities like burning coal. Lead is present at low levels in our air, soil, and water, but often very dif11cult to remediate in those cases. It 

### is therefore critical to restrict lead exposure in environments directly under our control, such as consumer products. AAP'sRole in the CPSIA During the development ofthe CPSlA, the AAP was asked by Congress to recommend a limit for permissible levels oflead in children's products. The Academy engaged in a rigorous scientific process involving a review ofthe pertinent literature and ultimately recommended that lead be limited to 40ppm. AAP pediatric environmental health experts determined that, based on the most up-to-date science, an object with 77ppm lead would be capable ofraising a child's blood lead level to a level that would result in the loss ofone IQ point. Recognizing that 1110SL 

### children are exposed to other sources oflead and that it is bioaccumulative, the AAP recommended atwofold margin ofsafety and reduced the recommendation from 77 to 40ppm. The level of40ppm was also selected to fall above the naturally-occurring background levels DC 

### lead seen in various parts ofthe United States. 14


### The AAP worked closely with Congress throughout the development oftile CPSJA to provide access to pediatric environmental health experts and researchers, who consulted on varioLis aspects ofthe legislation. The final bill represented a significant step toward reducing children's

• "Small amount" is defined here as I mcg/dL increase in blood lead level.

Page 3 of6Dana Best, MD, MPH, rAAP American Academy of Pediatrics Children's Products Containing Lead: Technological Feasibility of 100ppm for Lead Content February 16, 2011



### exposure to lead, particularly by setting limits where none had previously cxisted on matcrials otherthan surface coatings in children's products. Health Effects ()fReducingLeadLimitsfrom 300 to 100ppm 

### 1 nthe January 

### 26 FederalRegister

### notice, "Children's Products Containing Lead; Technological Feasibility of 100 ppm for Lead Content," the CPSC requested public comment on several specific questions. The AAP would like to provide information on #6: "What health effects are associated with areduction ofthe lead content limit from 300 ppm to 100 ppm? From 300 ppm to some other level above 100 ppm?" Based on the AAP'spreviously-noted calculations, an object containing 77ppm oflead is capable ofraising a child's blood lead level to a level that would result in the loss ofone lQ point. Please note that this is not meant to be interpreted as adefinitive statement tor each exposed individual; rather, it is a public health statement representing what will be truc**r(,,·th,.~** 

### majority ofchildren. Individual children will have factors that either increase or decrease their vulnerability. For the majority ofchildren, ingestion ofan item containing 300ppm oflead would result in the loss ofalmost 4 (3.9) IQ points. Ingestion ofan object containing 100ppm lead would result in the loss of just over one (1.3) IQ points. When averaged across even a modest population ofchildren, the public health harm causcd by lead is significant. Consideringthat there arc about 75 million children in our nation, impacting one-halfofone percent ofall children would mean exposure of3.75 million children. Respected economic studies estimate the Joss oflifetime income at $8,346 (1995 dollars) for each loss or one IQ point. For 10,000 children, this equals approximately $83.4 million; for 100,000 children, it would be $834 million. For one million children, it would total over $8.3 billion. Other Importallt IssuesRelatedto LeadExposure 

### The Commission has received numerous comments regarding the feasibility ofreducing permissible lead levels trom 300 to 100ppm. With those in mind, the AAP would urge the Commission to keep some additional points in mind. Childrell mustbeprotected/romboth acuteandchronic exposureto lead. 

### Cases where exposure to a single lead-laden object can cause severe or fatal lead poisoning arc, happily, rarc. The CPSIA focused 011 

### preventing the often-invisible but perniciolls cases ofsilent lead poisoning, where parents or caregivers are unaware that lead exposure ever occurs. The Commission must remember that lead accumulates in the body and exposure can come from mUltiple sources, so exposure must be limited as much as possible from each individual product to avoid accumulation to dangerous levels.

Page 4 of6Dana Best, MD, MPH, FAAP American Academy of PediJtrics Children's Products Containing Lead: Technological Feasibility of lOOppm for Lead Content February 16,2011 

### Harmfrom leadis usually invisible. Most children are tested eitheronce ortwice for lead exposure, either around the ages ofone or two years, orboth. Exposures in infancy will not be detected until at least age one, and those thattake place after the age oftwo years may never be detected. In some communities where the risk oflead poisoning from older housing stock is deemed low, testing for blood lead levels may not be performed at all. As a result, parents may never be aware oftheir child's elevated blood lead level or associated damage. Moreover, there is no way for parents to know ifa given object contains lead, so they arc powerless to control exposure orprotect their children. It is the responsibility ofthe Commission to provide that protection for children and families. 

### Riskassessmentof individualproductsor classes of products is impracticalandSUbjective. Some have recommended that the CPSC engage in some form ofrisk assessment to determine the levels oflead permitted in children's products. From a medical perspective, the benefit of lead exposure is zero, and so the considerable risk will always outweigh the benefit ofhaving lead in children's products. A risk assessment scheme would introduce tremendous levels of subjectivity into this process and remove any certainty for parents and caregivers about the safety ofthe items they purchase. In addition, the CPSC would shoulder an untenable burden in attempting to perform or confirm risk assessment on variolls products. For all ofthese reasons, the AAP urges you to reject calls for risk assessment related to individual products and tl1-, amount oflead that should be permitted in them. 

### Leadlimitsshouldbe based 011 

### total, ratherthan accessible, leadlevels. Congress thoroughly explored the issues related to accessible versus total lead and issued a clear statutory direction for the agency to regulate based on total lead. The variability among laboratory tests for aceessible lead and the fact that accessibility can change overtime (e.g. as certain materials degrade) led Congress to reject accessibility as the appropriate standard for regulation. In fact, Congress directed the CPSC to use total lead as a way to provide greater certainty and consistency, making it easier for companies to measure compliance reliably. Challenges with consistency among tests performed by laboratories should lead the CPSC to work more closely with those entities 10 ensure the appropriateness and consistency ofprotocols used. Laboratory issues do not, however, negate the validity of 100ppm as the appropriate standard protective ofchild health.
CPSC

### shouldcollaborate closely with companiesworking to comply ingoodfail/I. The AAP appreciates that both the Commission and individual companies will undoubtedly face challenges related to compliance. In particular, very small producers may face difficulties related to the cost orcomplexity oftesting. The AAP urges the CPSC to work closely with these entitiesto craft creative, flexible solutions that reduce the regulatory burden while also preserving child health and safety.
In conclusion, I appreciate this opportunity to oITer comments on behalfofthe American Academy ofPediatrics. The AAP urges the Commission to continue placing the highest priority on protecting children from lead exposure and its devastating consequences. Large number of children's products currently on the market already comply with lead limits; we encourage you

Page 5 of6Dana Best, MD, MPH, FAAP American Academy of Pediatrics Children's Products Containing Lead: Technological Feasibility of 100ppm for Lead Content February 16, 2011

to work closely with those remaining companies who stiII face compliance challengesto identifY solutions. In any small number ofcases where the CPSC may determine that the 100ppm limit is not technologically feasible, the CPSC should use the flexibility granted by Congress und..:r the CPSIA. TheAAP stands ready to assist you in any way in this important undertaking. Please do not hesitate to call upon us.

I Canfield RL, Henderson CR, Jr., Cory-Slechta DA, Cox C, Jusko TA, Lanphear SP. Intellectual impairment ill children with blood lead concentrations below 10 microg per deciliter. N Eng!JivIed. 2003;348( 16): 1517-1526.
2 Lanphear BP, Hornung R, Khoury J, et al. Low-level environmentallcad exposure and children's intellectual function: an international pooled analysis. Environ Health Perspect. Jul 2005; 113(7):894-899. 3 Dietrich KN, Ris MD, Succop PA, BergerOG, Bornschein RL. Early exposure to lead andjuvenile delinqucm:y, Neurotoxicol Teratol. Nov-Dec 2001;23(6):511-518. 4 Ris MD, Dietrich KN, Succop PA, Berger OG, Bornschein RL. Early exposure to lead and neuropsychological outcome in adolescence. J /nt**Nellrop.\~vchnl**Soc, Feb 2004:261-270, 5Burns JM, Baghurst PA, Sawyer MG, McMichael AJ, Tong SL. Lifetime low-level exposure to environmental lead and children's emotional and behavioral development at ages 11-13 years. The Port Pirie Cohort Study.AmJ Epidemiof. Apr 15 1999;149(8):740-749,
6 Nevin R. Understanding international crime trends: the legacy ofpreschool lead exposure, Environ l?es 2007;104(3):315-336, 7 Centers for Disease Control and Prevention

.. Managing ElevatedBlood/,ead LevelsAmong Young Children: Recommendationsfrom the AdvisOlYCommittee on ChildhoodLeadPoisoning Preventiol1. Atlanta, GA: Centers for Disease Control and Prevention; 2002. 8 Bhattacharya A, Shukla R, Dietrich KN, Bornschein RL. Effect ofearly lead exposure on the maturation 01 children's postural balance: a longitudinal study. Neurotoxicol Terata!. 2006;28(3):376-385.
9 Chiodo LM, Covington C, Sokol RJ, et al. Blood lead levels and specific attention effects in young children. Nellrotoxi"ol Teratof. Apr 21 2007. 10 Schnaas L, Rothenberg SJ, Flores MF, et aL Reduced intellectual development in children with prenatal lead exposure. Environ Health Perspect, 2006;114(5):791-797, II Wells E, Navas-Acien A, Herbstman J, Apelberg 8, Silbergeld E, Caldwell K, Jones R, Halden R, Witter F, Goldman L. Low Level Lead Exposure and Elevations in Blood Pressure During Pregnancy, £nviron Ilea/til Perspect. 2011; doi: I0.1289/ehp.1002666 12 Salkever D. Updated Estimates ofEarnings Benefits from Reduced Exposure ofChiIdren to Environmental Lead, Environmental Res. 1995: 70:1·6, 13 Landrigan PJ, Schechter CB, Lipton JM, Fahs MC, Schwartz J. Environmental pollutants and disease in American children: estimates ofmorbidity, mortality, and costs for lead poisoning, asthma, cancer, and developmental disabilities. Environ Health Perspect 2002;J10:721-8. 14 lJ .S, Geological Survey Professional Paper 1648. Geochemical Landscapes ofthe Conterminous United StatesNew Map Presentations for 22 Elements, Figure 17. November 2001. Available at**IlliELJ211l!~cCLl'ill.3hmyiillUJ2lJY 18.D.L(>.:l~:UQJ.** 

Page 6 of6

### Hammond, Rocky From: Fellin, Mark Sent: Friday, April 01, 2011 9:28 AM To: Hammond, Rocky Subject: FW: QUestions for the Record Attachments: 03-24-11 CPSC Northup 100ppm questions Itr.PDF

From: Cindy Pellegrini [mailto:CPellegrini@aap.org] 

### Sent: Thursday, March 24, 2011 3:43 PM To: Fellin, Mark 

### Subject: Re: Questions for the Record
Dear Mark, Attached please find a letter from Dr. Best responding to Commissioner Northup's questions for the record ofthe Feb. 16 hearing. Please let me know ifthere's anything further I should do to ensure that the response appears in the hearing record. Thank you! Regards, Cindy
Cindy Pellegrini Associate Director, Dept. of Federal Affairs American Academy of Pediatrics 60113th St, NW, Suite 400N Washington, DC 20005 (202) 347-8600 main (202) 724-3307 direct (202) 393-6137 fax»> "Fellin, Mark" <MFellin@cpsc.gov> 3/1/2011 9:54 AIVl »> Dr. Best,
Attached you will find Comm. Northup's follow-up questions forthe record. I will also be sending you 

### a hard copy for your records. Please let me know ifyou have any questions. Thanks!
Mark S. Fellin Office ofCommissioner Anne M. Northup Consumer Product Safety Commission (301) 504-7780 http://www.safetyandcommonsense,blogspot,comL

*****!!! Unless otherwise stated r any views or opinions expressed in this e-mail (and any attachments) are solely those ofthe author and do not necessarily represent those ofthe U.S. Consumer Product Safety Commission. Copies of product recall and product safety information can be sent to you automatically via Internet e-mail r as they are released by CPSC. To subscribe or unsubscribe to this service go to the following web page: https:/Iwww.cpsc.qov/cpsclist.aspx *****!!!

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