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clay toxicity and monona

updated mon 31 mar 97


Monona Rossol on fri 21 mar 97

Kris Griffith wrote:
>>I am posting this for a friend who runs a clay manufacturing business...He
>>is interested in finding out how to have his clay body and or formulas
>>tested for toxicity.<<

> Monona; I am supprised at the tone of your response to this post. I would
> think that you would encourage this guy to have his formulas tested, as well
> as answering his question as how to go about it! Instead, I suspect he
> found your reply to be something less than helpfull: "he has a big
> problem...I don't like the standard...the labeling standard/law
> sucks...etc"<

Testing the frit is essentially irrelevant to both the leach-performance of
the glaze and the toxicity of the frit by inhalation and ingestion--so why
would I encourage him to test a raw glaze formula or a frit and WASTE his

> Anyway; Kris, pass this information along. Effictive November 1990 the art
> material labeling law known as ASTM D-4236....<

No! The law is Public Law 100-695, an amendment to the Federal Hazardous
Substances Act. This law references ASTM D-4236, a standard developed
earlier by the American Society of Testing and Materials (ASTM) ordinally as
a VOLUNTARY chronic hazard labeling standard for art materials. It is
important to understand that the people on this committee who developed this
standard were almost exclusively (my guess over 90 %) art materials
MANDATORY. Nevertheless, I supported (along with many other individuals and
public interest groups) passage of the law and incorporation of ASTM D-4236.
We did this primarily because the new law's criteria were better than the old
Federal Hazardous Substances Act criteria which allowed *known* carcinogens
such as asbestos to be labeled "non-toxic" because they were negative on
two-week-long animal tests!

>.... requires manufacturers to
> evaluate their products for their ability to cause chronic illness and to
> place labels on those that do. Manufacturers must have their products
> evaluated by a toxicologist under the provisions of ASTM D-4236 to verify
> that no chronic hazard label is required. If a chronic hazard label is
> called for in this toxicological review, a label with health and use
> information is needed. <

I am on the ASTM D-4236 subcommittee. That's WHY I know what the problems
are with the tests and assumptions about chronic toxicity. At this MOMENT, I
am writing an expert opinion on two depositions in a lawsuit, one given
by the President of a certifying agency and the other by their toxicologist.

> This toxicoligy review can be acomplished either by submitting formulas to
> a qualified toxicoligist, or by joining a certifying organization (bring a
> big checkbook).

> 1. The Art and Craft Materials Institute, Inc.
> 715 Boylston Street
> Boston, Massachusetts 02116 <

They changed their name to "The Art and *Creative* Materials Institute and
they moved to *100* Boylston St--same zip.

> 2. Ceramic Manufacturers Association
> PO Box 2188
> Zanesville, OH 43702
> If you need the name of an independant toxicoligist email me privately and
> I'll send you one. <

So will I. Because he must meet this law if he sells the product. There are
several toxicologist doing this work now. The problem, I REPEAT, is the
standards they use. They ought to simply list all toxic metals on the label
of the glaze or frit and make no assumptions about bioavailability unless
they have done animal tests by inhalation and ingestion.

Monona Rossol, industrial hygienist
Arts, Crafts and Theater Safety
181 Thompson St., # 23
New York, NY 10012-2586 212/777-0062