Comment from Michael McCall

My company manufactures decals used to provide permanent decoration on glass and ceramic substrates. We take inorganic metallic oxides, mix them with oils and screenprint these inks onto transfer paper. The images are transferred from the paper onto a glass or ceramic substrate. The substrate is next fired in an oven at temperatures ranging from 1100 to 1500 degrees Fahrenheit. This causes all of the organic materials in the ink to burn off and only leave the inorganic metallic oxides. At this point the ceramic colors are permanently attached to the substrate. Any small amounts of lead that may be present are not free to be released from the substrate as they are vitrified in the firing process. Most of the decals that we produce use lead free colors (metallic oxides). The majority of our color suppliers are only able to certify the lead content of the colors to a level of <300 ppm. A lead content level of 100 ppm is impossible for certify, as most of our suppliers do not offer products with lead content levels this low. One of the reasons for this is the amount of background levels of lead found in the environment. To make a cobalt blue color our suppliers take cobalt, which is mined from the earth, and grind it into a powder which we use to make our ink. Metallic oxides mined from the earth have varying and inconsistent concentrations of background levels of lead. Given the limitations of our vendor's inability to produce products that can be certified to have a lead content less than 100 ppm, it is not feasible for us to produce a decal that can be used on glass or ceramic products under this Act. Is the real question the appropriate lead content level of a children's product or the potential amount of lead that can be released from a children's product? Products that are decorated with ceramic decals have very little potential for any lead release.