Dear Planeteers,

I just wanted to inform you about an alarming process over here in Europe.

The EU plans to forbid the use of lead in any products that could come in the mouths of little children – this also means tin figures. By now tin figures are not on the list of excemptions, like fishing supplies, diving belts and other things. I have attached the guideline, so you can read this all in detail.

The KLIO (German Society of friends and collectors of historical tin figures ) and as far as I know the BFFS (British Flat Figure Society) just placed their statements to the EU.
____________________

Here are some passages of the KLIO statement:

>>Die KLIO hat auf folgende Gesichtspunkte hingewiesen: Zinnfiguren sind ein Jahrhunderte altes europäisches Kulturgut und dienen seit langem nicht mehr als Spielzeug, sondern als Sammelobjekt, weshalb sie auch nach EU-Recht nicht als Spielzeug gelten. Zinnfiguren benötigen zwingend den Zusatz von Blei, da andernfalls keine Wiedergabe der Reliefgravur möglich ist. Auch für den Fall, dass sie von einem Kleinkind in den Mund genommen werden sollten, besteht keine Gefahr eines anhaltenden Lutschens. Es wird daher beantragt, Zinnfiguren in die Liste der Artikel aufzunehmen, die von der Richtlinie ausgenommen sind.<<

KLIO pointed out the following: For hundreds of years tin figures are an European object of cultural value and for a long time they are no toys but collecting items. Because of that fact the tin figures don`t apply as toys according to European regulations. Tin figures need the addition of lead, otherwise casting of fine engravings is not possible. Even for the case, that a little infant takes a figure in his/her mouth, a danger of sucking it for a longer time is not given. Therefore we apply to include the tin figures into the list of articles, which are excluded from that Guideline.

>>Für den Herausgeber größere Bedeutung hat die Unmöglichkeit, Zinnfiguren anders als mit einer Bleibeimengung gießen zu können. Daher würde eine Untersagung einem faktischen Berufsverbot gleich kommen.<<

For editors it is very important that it is impossible to cast tin figures without lead. In fact such a ban would be an occupational ban for all editors of tin figures.
________________

I ask all european figure organisations, figure enthusiasts, and figure companies to place their statements to the planned resolution - the deadline to place your thoughts is the 11.06.2015.

Contact Adresses:

EU:
ECHA EUROPEAN CHEMICALS AGENCY, ANNANKATU 18, P . O . BOX 400, FI - 00121 HELSINKI FINLAND

http://echa.europa.eu/addressing-ch...mments-and-evidence/-/substance-rev/7902/term

BRD:
BAuA Bundesanstalt für Arbeitsschutz und Arbeitsmedizin Friedrich-Henkel-Weg 1-25, 44149 Dortmund

Reference: Draft guideline on the scope of the upcoming amendment of Entry 63 of Annex XVII to REACH on: Lead and its compounds in articles supplied to the general public that can be mouthed by children.
Name: Lead and its compounds
EC Number: 231-100-4
CAS Number: 7439-92-1

Thanks in advance for your interest and hopefully your help.

Do the major figure producers use lead? I've been painting game miniatures for a while and I thought they don't. Although I must admit the figures that I know contained lead are a breeze to clean up.

A. : Before panicking, I consulted the officials document

The text contain statement : ( in the ECHA document http://echa.europa.eu/documents/10162/a55e40f4-9515-475a-a6de-25bd991c3f84 )

Table 2-B Article types which are exempted as covered by European Union legislation specifically regulating lead content
.....
3. Toys Directive 2009/48/EC on the safety of toys.

B. : Then I read the directive
Now in the Directive, we read ( http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2009:170:0001:0037:en:PDF )
List of products that, in particular, are not considered as toys within the meaning of this Directive (as referred to in Article 2(1))
....
2. Products for collectors, provided that the product or its packaging bears a visible and legible indication that it is intended for collectors of 14 years of age and above. Examples of this category are: (a) detailed and faithful scale models; (b) kits for the assembly of detailed scale models; (c) folk dolls and decorative dolls and other similar articles; (d) historical replicas of toys; and (e) reproductions of real fire arms.


So I think that from now, all producers, importers, sellers must add on the packaging " intended for collectors of 14 years of age and above "
But, I guess, it must be written in the country official language .. So importers prepare some stickers ( exemple; in Belgium it must be in french, netherland, german . those are the 3 officials in Belgium )


I'm not an expert, but I think ( hope ) our hobby is protected that way .
Best

Can we ban EU to?

Hopefully we'll get our referendum and get out but I ain't holding my breath
Steve

I was asking myself
Must the warning be translated in Scotish and Welsh

Hey now. As someone of Scottish, Welsh (and German) ancestry, I'm not amused. Smiley face notwithstanding.

Its all a load of old!....

'Brussels Sprouts;'! ..High intake, and lots of wind. Once alleviated, and the smell has dissipated. Things will be business as usual.


Mark

Another reason to leave the EU. It's been the biggest Con ever fostered on the British People.

But meantime you're still in there in the EU. So write against it how Markus has proposed.

Cheers

I have hope.

Marc

Does this mean that when we drop a nuclear bomb on the EU talking shop, we have to make sure it doesn't contain lead? (Wouldn't want to give all those disembodied atoms lead poisoning).

I can't say whether the EU banning lead-tin figure manufacturing is a good or bad idea. I can kinda see both sides.

From what I can tell, the amount of lead in such figures varies a great deal depending on their date of manufacture and the maker. The US and a lot of the world banned lead in gasoline in the 70s and the transition from leaded fuels to non-leaded fuels was very difficult and costly, but the right thing to do ultimately. Banning lead in lead-tin figures would result in such a transitional process again, admittedly on a much smaller scale, but I suggest that it might ultimately be the better choice.

Prior to my retirement I worked in the field of workplace environmental exposures, hazardous materials control, etc. I was a board-certified industrial hygienist and have 30 years of experience working in a wide range of environments that included abating lead in buildings and protecting employees that were welding/torch-cutting on lead painted structures. So - I know a little about lead.

All exposure to lead should be minimized. Adults doing hobby tasks on lead-tin figures can control their exposures using simple precautions. Children, particularly infants with quickly developing nervous systems, are another matter. Exposing children to even small amounts of airborne lead should be avoided.

Do any of you grind, sand, cut, or smooth pieces of lead-tin figures, particularly with power tools, while children are close enough to breathe in the dusts that you create? Do you solder or weld pieces of lead-tin figures while children are close enough to breathe in the welding or soldering fumes? Do you make and pour molten lead-tin mixtures while children are close enough to breathe the fumes or the dusts deposited when the fumes cool and deposit on surfaces? Probably 99.99% of you answered no to all three questions. If you answered yes or maybe to any of these, in my opinion, you need to have a hard re-think.

I recommend that you do these jobs and any job where lead dust or fume is produced in work shops or out of doors, not in your home. Personally, I would wear a dust respirator and gloves when doing any of these jobs. With respirator and gloves still on, I would thoroughly clean your work area with soap and water and disposable towels. After clean-up, change the filters in the dust respirator or if it is a disposable, put the filters and gloves in a sealed plastic bag. Finally I would wash my hands and face with soap and water.

If you don't believe me or want more information, please go to http://www.atsdr.cdc.gov/substances/
and read the CDC/Agency for Toxic Substances and Disease Registry lead profile and toxguide.

If you have questions, I'll try to answer them online.

All the best,
Dan

Fascism is fascism, even with a smiley face on it.

The EU that I object to and it was never asked of the British People, is the Laws that are now made on the Continent by people that i never voted for , and our Parliament has to abide by these laws . We voted for a Common Market, a Trading Agreement , nothing else. The sooner we are out the better. General De Gaul kept the British out of it for years, he had some deep seated hatred towards us, but little did he realise that he was doing us a great favour. Roll on the Referendum.

I say we bring out our Long bows , sharpen our swords and put a nice point on the end of our bayonets and then march into Brussels and drive these mad bastards out OR if they are really interested in children's health and well being then shut down Ebay with all the fake crap coming from the Far East (China) with more toxic chemicals in them than any 54 mm metal figure can ever have . I can't remember when I last read about a child dying from sucking on a tin soldier but I can remember reading about a boy who was killed by a fake battery charger from the Far East (China) .
chippy

I like the idea of longbows, Swords And Bayonettes, much more discerning than a nuclear bomb. Bags we give Jean Claude Juncker and Guy Verhofstadt a five minute head start.

It's OK Akaryu, we know their hiding places!!!