Is Lead in Hardware a Concern?
Concerns about lead have suddenly appeared on the radar of the window and door industry. Most of the attention has focused on new Environmental Protection Agency rules covering renovation work in pre-1978 homes that may have lead-based paint. Lead content, however, has also emerged as a topic of discussion in the window and door hardware arena.
One reason for the discussion involves work within the American Architectural Manufacturers Association. Many years ago, that organization established stringent limits on lead content in vinyl lineals to be used in the construction of certified and labeled windows and doors. AAMA, working with its partners in development of the North American Fenestration Standard, is now looking at applying the same type of limits to the entire product assembly, including hardware components.
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Die Casting Association
The topic of lead content in hardware has also been raised by one particular supplier—Lawrence Industries. The North Carolina-based hardware manufacturer and one-time zinc die caster, has been heavily promoting the benefits of its “lead-free” composite sash locks and other hardware, suggesting to window manufacturers that the lead content of zinc die cast products could be a potential problem.
“Lead is bad. I don’t think there’s a lot of argument about that,” says Brandon Lawrence, director of marketing for the hardware supplier. “Can I say lead content in hardware is safety hazard? No,” he continues. “But I can give you plenty of reasons why you wouldn’t want it in your hardware if you didn’t need it.”
Consumer Products Safety Commission Lead Content Criteria
Maximum allowable level of lead content in most consumer products to be at 600 parts per million (ppm). For children’s products containing lead, the Consumer Product Safety Improvement Act (CPSIA) is phasing in limits over the course of three years. Beginning, February 10, 2009, products designed or intended primarily for children 12 and younger could not contain more than 600 ppm of lead.
Truth Hardware asserts that any discussion of lead content criteria for window and door hardware should begin with the lead content criteria set by the Consumer Product Safety Commission for consumer products in general (see box at right). Even though windows and doors do not fall under CPSC guidelines as products designed for children under 12, Truth's zinc die cast products meet those requirements as well, reports Matt Kottke, marketing support manager for the hardware manufacturer. Pointing to CPSC lead regulations for children's products and the new EPA lead paint rules, he stresses the need to avoid getting caught up by "those trying to mix and then confuse issues for their own gain on what these regulations are intended to address."
Cindy Ihrke, Truth’s marketing services manager, reports that ASTM B240-09 is the regulating guideline for zinc and zinc-aluminum alloys used for die castings and it sets a maximum level of lead equal to 40 ppm (0.004%) which is 13 percent of the allowable CPSC ppm standard. The hardware manufacturer’s internal audits of material content also show that the levels of lead content net lower than the 40 ppm standard on a regular basis, she notes. “Our zinc products substantially outperform the requirements of the ASTM standards. These standards (while not required) meet the level of children 12 and younger in accordance with the Consumer Products Safety Improvement Act.”
Regarding current discussions at AAMA to apply lead content limits for not just vinyl lineals, but for the entire window and door product, Ihrke notes that the current AAMA requirements for PVC (AAMA 109) put the limit at 200 ppm for lead content. While she can't speak for all hardware producers, she reports, “Truth Hardware’s zinc products fall well under that level giving us a confidence factor that should ratings become stricter, we would still comply.”
“While, at this time, there exists no lead limit standard for window and door hardware, nor is there currently a requirement for testing of detectable lead levels in window and door hardware, VIG has taken the initiative to submit our hardware, coated and uncoated, for lead level testing,” reports Luke Liang, of Vision Industries Group, another supplier. “Results of the tests, performed by SGS, a leading inspection, verification, testing and certification company, indicated that the detectable lead level of the base metal and coating materials, used by VIG, to be significantly below the limits as specified by the U.S. Consumer Product Safety Commission.”
Despite such claims from other producers, Lawrence suggests there may be problems with relying on ppm standards set by the CPSC. “If you measure ppm, one assumes that the lead is homogenous and evenly distributed throughout the part, but that is not the case in the parts we have tested,” he states. “The surface areas show much higher percentages when checked with LeadCheck.”
LeadCheck swabs, available at any lumber yard, are one of the options that can be used under the new EPA Lead Renovation Repair and Painting rules. Lawrence predicts they may become the de facto standard. Although the new EPA rules focus primarily on lead paint, the increased awareness about lead and the use of LeadCheck that come with the new rules could impact window and door hardware as well, he says. “If you look at the intention of the RRP rules, you understand that the EPA wants to remove lead from human exposure,” he states, noting that he has been trained and certified under the program. “One whole chapter is devoted to lead dust, from whatever source. Protective suits, masking, quarantining areas, are all steps to prevent not only contractors, but consumers from being exposed to lead dust.”
Kottke responds by questioning Lawrence's comment that LeadCheck will become the "de facto" standard. "I defer to comments that appear on the warranty of the LeadCheck instruction sheets: 'The test is a presumptive test for lead and should not be considered quantitative.'"
Kottke points to the latest draft of the next edition of AAMA/WDMA/CSA 101/I.S.2/A440, the NAFS standard, for those looking for more appropriate standards for lead content. The current wording, reviewed at the AAMA meeting in Februarys, says “at the point of manufacture, hardware intended for repetitive human touch shall be tested for presence of lead in accordance with ASTM 1753,” which is a swab test. If the swab indicates lead, the surface lead content must be sampled and tested in accordance with EPA 747-R-95001 and EPA 747-R-96-003. Based on such procedures conducted by an EPA approved lab, the outermost surface of the part shall not exceed 0.02 percent (200 ppm).
The scenario Lawrence paints for hardware is that in some pre-1978 home, where lead is found initially and then removed, the home will be checked again when the job is done. “The contractor must use LeadCheck to check for surface area lead and provide the homeowner with a report. Since the consumer will pay more for the installation, he is now educated to the problems, expenses, and testing procedures associated with lead contamination,” he states.” If the contractor should check the raw cams on a lock for instance upon the clearance procedure, he may notice that the cams will turn red, indicating lead.” The contractor must then go back to the window dealer or manufacturer and address the issue with new hardware and or new windows before the job is completed.
The other scenario, he suggests, is if the contractor fails to check the window hardware itself during clearance, but the homeowner happens to do it six months or a year later. “Is the contractor going to be faced with the heavy fines we hear about?” Lawrence asks. “Is the window maker liable behind the contractor, are lumber yards liable, and if so how much? With the building industry taking a beating, they do not need any potential additional burdens. As contractors understand their exposure to risk, I am sure they will make it an issue.”
“If you are doing any remodeling in a home pre 1978, you will need to take the necessary precautions as provided by the EPA,” says Steven Groves, Truth's senior VP of sales and marketing , who does not see the new EPA rules affecting hardware at all. “This action taken by the EPA is for control of dust created by lead based paints in homes built prior to 1978,” he continues. "Concerns like those presented by Lawrence are primarily designed to create anxiety within the window and door industry."
Vision Hardware’s Liang also advises caution on the issue. “We realize the requirements for the safety and ‘greening’ of the products we manufacture and sell will continue to become more stringent,” he states. The company currently offers a line of lead-free composite window hardware, he notes, and adding that as requirements evolve, the company “will work with regulatory agencies and industry organizations to ensure that we are providing window manufacturers and consumers the safest products possible.”
Pointing to the new EPA regulations, as well as previous regulations set by CPSC and OSHA, Lawrence says, "Look at them from the perspective of the consumer, parents, and the governing agencies that are charged with removing lead as a potential threat to public safety." When it comes to his company's hardware, he reports, "We just took the whole issue off of the table, just as we suggest to the window maker, 'Just get rid of it, and don't worry about it anymore.'"
“Take the time and make the effort to understand the facts,” Truth's Groves advises window and door manufacturers. “Use facts to refute sensationalism and inaccurate positions that may be taken by companies or individuals—who might benefit from the confusion—created by partial or incomplete statements.“ Finally, he notes, “Be informed–understand all the facts. Ask if information is not available to you. Leverage data from independent sources or standards.”