AIHA Responds to USA Today Article

So, the American Industrial Hygiene Association (AIHA) has written a letter to the editor in response to the USA Today article featuring me and other bloggers. When I got the Google alert with my name, and the brief summary, my heart started pounding. I was thinking what the heck could the AIHA say about me in response to that article? I was actually scared.

Okay, and then I read it. And, I have to say, it is a tad annoying.

The AIHA letter to the editor tackles the appropriate use of the XRF analyzer for regulatory purposes. But that wasn’t even discussed in the USA Today article. And, what is even more annoying is that the letter to the editor gives the mistaken impression that you can’t use the XRF analyzer and get acceptable results, which isn’t true.

So, let me respond. And, let me just disclose (before I get some comments that I’m shilling) that I don’t work for the manufacturer of the device.

I’ll give the AIHA this. It is true that you cannot use the XRF analyzer to satisfy the requirements of the Consumer Product Safety Improvement Act (CPSIA) for children’s metal jewelry manufactured after March 23, 2009. Children’s metal jewelry manufactured after March 23, 2009 must tested by an accredited third party laboratory, and the testing that is required is a digestive testing method (Test Method CPSC-CH-E1001-08 or 2005 CPSC Laboratory SOP).

However, it is incorrect to state that the XRF analyzer cannot be used to screen children’s metal jewelry manufactured before that date for compliance with the children’s product lead content standard. Of course, the operator must recognize the limitations of the equipment. And, there may be sample preparation requirements and adjustments for substrate.

But don’t let the AIHA fool you. The CPSC, as well as a host of other agencies, such as the California Department of Toxic Substances Control (DTSC), use XRF analyzers to screen products in the field. In fact, the CPSC and the DTSC both use XRF to screen metal children’s jewelry to evaluate pieces for further testing. You can’t beat the XRF analyzer for a portable, non destructive way of screening products.

And, the CPSC has approved the use of XRF technology in certain circumstances. No doubt, the CPSC approvses the use of XRF on homogenous plastics. The CPSC recognizes that using XRF for paints and coatings may be acceptable if suitable analytical methods and standards are developed. 

The AIHA letter to the editor overlooks (or intentionally omits) the approval that the US Environmental Protection Agency has given to the use of XRF in the characterization of contaminated sites, and the approval that the US EPA and the US Department of Housing and Urban Development have given for XRF in dealing with lead based paint hazards.

Just my two cents.

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Comments

  1. I think you’ve got their attention and they’re scared 🙂

  2. Addressing the AIHAu2019s Response to USA Today Article on Consumeru2019s Use of XRF Analyzers to Detect Lead in ToysnnThe American Industrial Hygiene Association (AIHA) raises several interesting points that are worthy of discussion in their letter to the editor of USA Today (re: article u201cSmart Mama Jennifer Taggart aims to get the lead out of toys,u201d Dec. 6). They begin by correctly stating that x-ray fluorescence (XRF) analyzers are u201cwell suited for measuring lead in items that are made of a single uncoated or unpainted materialu201d u2013 a subject that has been addressed by this author in previous blog posts at http://www.thermoscientific.com/niton.nnWhere we disagree, however, is in the AIHAu2019s statement that XRF analyzers arenu2019t suitable for measuring toys u201cu2026made of several different materials.u201d They go on to reference plated jewelry and painted items as examples where XRF analyzers may not provide an accurate measurement. Letu2019s take their example of a painted item. If this hypothetical toy were u201cu2026pulverized into a uniform powder before any measurement (was) taken,u201d the accredited laboratory would provide its customer with a result that could contain significant risk of error.nIf we assume the worst-case scenario where this toy were covered with paint contaminated with lead, then homogenizing the sample would dilute the reported lead concentration by virtue of the additional base material, possibly resulting in false negative result. The preferred laboratory method for analyzing this sample would involve scraping a homogenous sample of paint from the toy rather than pulverizing it, then analyzing the paint separately from the substrate to obtain accurate results on each distinct component on the toy. nnInstead of misrepresenting the technology in the USA Today story, they could have focused on the societal benefits associated with the use of this equipment, including the rapid and accurate identification of lead-based paint in homes, the detection and measurement of toxic metals in soils at contaminated sites around the world, or how manufacturers, importers, distributors, and retailers are using handheld XRF analyzers to reduce the risk of lead- or cadmium-containing childrenu2019s products from ending up in the hands of consumers. Even CPSC inspectors use handheld XRF analyzers to help identify products that might be in violation of the Consumer Product Safety Improvement Act (CPSIA).nnHandheld XRF analyzers may never replace laboratories when it comes to certifying that child-accessible products comply with published federal or state regulations on lead or cadmium content, nor are we suggesting that they should do so. On the other hand, they do provide stakeholders the ability to test an order of magnitude larger volume of products, nondestructively, than could ever be analyzed by a fixed-site laboratory. By working with these stakeholders in the appropriate use of handheld XRF analyzers, and by helping them increase the testing frequency across entire product lines, weu2019re helping them increase the statistical confidence that their products are in compliance, supplementing (but not replacing) the results they obtain from their laboratory.

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