Regulatory Information for Heavy Metal Use in Glass & Ceramic Decorating

	I.Introduction Ceramic and glassware are often decorated with permanent, kiln-fired colors that have traditionally contained heavy metals. The use of these metals, primarily lead and cadmium, has come under examination in relation to negative health and environmental impacts.
When in contact with foods and beverages, the metals can leach out of the decorations. Prolonged or repeated food contact can result in chronic poisoning. Ceramic or glass packaging that enters the waste stream also leaches the poisons, which can have severe consequences on the environment and our water supply.
	In response to these concerns, there are a number of regulations limiting the amount of heavy metals in food-bearing vessels and disposable packaging. The FDA and EPA have established national guidelines, in addition to which there are individual state laws and voluntary industry standards. The summaries and links below are provided to help you understand the regulations and potential consequences of heavy metal use in glass and ceramic decoration, and to offer you safe and effective decorating options.
	II. Federal Food & Drug Administration A. Ceramic Food Bearing Surfaces The FDA's Compliance Guide sets forth the standards for the leaching of lead (CPG 7117.07) and cadmium (CPG 7117.06) from the food contact surface of ceramic tableware. B. Lip and Rim Area A voluntary industry standard limits the amount of lead and cadmium leaching from the top 20 mm of the outside of a ceramic cup, mug, or drinking glass. The limits are not more than 4ppm of lead and not more than .4ppm for cadmium. The standard does not apply to ceramic or glass ware that have less than 60 mm of decorating area below the rim and which is not intended for usage by children. C. Decorative Ware In addition to tableware, the FDA has a regulation (21CFR109.16) for the proper labeling and representation of decorative ceramic and glass ware containing heavy metals. These requirements include a clearly visible sticker warning of the poisoning potential on the top of the piece, a similar, permanent label on the bottom, and may sometimes include altering the piece to ensure it cannot be used to prepare, hold, or serve food.


III. California Regulations California has led the charge in more specific regulation to protect the safety of their residents; some other states have followed with similar laws of their own. It is important that manufacturers and distributors be familiar with all applicable laws in all states in which their product(s) will be sold. A. Tableware Safety Law This law prohibits the sale of tableware that leaches lead and/or cadmium in excess of the levels noted in the FDA guidelines. B. Proposition 65 The Safe Drinking Water and Toxic Enforcement Act requires that tableware leaching lead in excess of the standard set forth by the regulation have proper warnings when they are sold or displayed. The manufacturer must inform retailers when warnings are required and provide the appropriate signs. Related links: California Childhood Lead Poisoning Prevention Branch: Lead in Tableware Business & Legal Reports: Proposition 65 IV. Model Toxics in Packaging Legislation MTPL was developed to reduce the amount mercury, lead, cadmium, and hexavalent chromium used in packaging. The goal of this legislation is to lower the harmful effects of these metals on the environment and water supply by reducing the amount of toxic metals entering the environment through the waste stream. As of July 2004, legislation built on this model had been adopted by 19 states. Properly vitrified glass or ceramic decals are not considered to be a separate packaging component. The finished glass or ceramic package must pass the leaching test as described in the U.S. EPA Document SW-846. Related link: Toxics in Packaging Clearinghouse V. Toxicity Testing Standards A. ASTM C1606-04 ASTM (American Society for Testing and Materials) International has established the C1606-04 Standard Test Method for Sampling Protocol for TCLP (Toxicity Characteristic Leaching Procedure) Testing of Container Glassware. This procedure outlines the proper preparation for leaching tests on container glassware for accurate results. Click here for details or to purchase the complete ASTM procedure. B. Maximum Allowances The maximum allowed amounts of individual heavy metals as a result of the TCLP test are: 1.0 ppm (parts per million) lead, 5.0 ppm cadmium, and 5.0 ppm hexavalent chromium.
VI. Heavy Metal Free Decorating with Decals Article: Working with Heavy Metal Free Glass Decals by Michael McCall. An overview of color palette options in glass decorating and the challenges presented by regulations limiting heavy metal content. Regulations and safety concerns have initiated the research and development of safer decorating methods with inks free of lead and other heavy metals. Heinrich Ceramic Decal is proud to be a leader in this technology and offers completely heavy metal free color palettes for both ceramic and glass decoration. As always, our decals are screen printed with ceramic oxides, which you or your decorator apply to the piece and fire in a kiln. The result is a high quality, permanent decoration. Decals also have superior capabilities in a wide range of special effects, fine detail, 4-color process, art reproduction, tight registration, just-in-time production, and consistency. Heinrich is experienced in manufacturing custom decals to fulfill unique decorating goals. We are prepared to work with you to develop the best possible decoration for your project. Heinrich is happy to share our knowledge with our customers; please remember that specific regulatory requirements are dependent on a number of factors and the responsibility of meeting them is with the manufacturer of the final product. Please call us at 508-797-4800, e-mail info@heinrich-decal.com, or visit our web site: heinrich-decal.com. VII. Media Coverage of Lead Safety Concerns Below are links to news stories, articles, and other media coverage of lead safety concerns. Please let us know if you have additional links that may be of interest. May It Please the Court Legal WebLog, Newport Beach, CA: Deal to Pay Defense Firm Out of Plaintiff's Prop 65 Settlement Pending Before AG WPXI, Pittsburgh: Lurking Lead Lead Poisoning News: Lead exposure occurs not just in the workplace Environmental Defense: Lead in China Dishes: A Dish Buyer's Guide FDA Consumer Magazine, at Kid Source online: Lead Threats Lessen, but Mugs Pose Problem VIII. About UnleadedDecal.com This web site was created by Heinrich Ceramic Decal, Inc. to serve as a resource to manufacturers, decorators, and retailers in the glass and ceramic industries. Every effort has been made to keep information current and links updated, but please note there is no warranty, express or implied, and Heinrich is in no way responsible for the products or actions of others. It is the responsibility of the manufacturer to be sure their goods meet all applicable regulations. Heinrich strongly supports legal and ethical practices in glass and ceramic decorating. We are leaders in developing high quality, heavy metal free decals for glass and ceramic decoration. Should you have a project with which we may be of assistance, please call us at 508-797-4800 or visit our web site: Heinrich Ceramic Decal.