Toxic lead found in paint brushes used for food preparation in the Philippines

Based on the XRF screening data, lead above the regulatory limit of 90 parts per million (ppm) was detected in 79 out of 95 paint brushes, particularly in the mostly yellow-coated handles. Of these leaded paint brushes, 11 were found to contain lead exceeding 10,000ppm, 37 had over 5,000ppm, and 70 had lead above 1,000ppm.

Background: Health effects of lead

Children are exposed to lead from paint when lead-containing paint on walls, windows, doors or other painted surfaces begins to chip or deteriorate since this process releases lead to dust and soil. Lead dust is also produced, when a surface previously painted with lead paint is sanded or scraped in preparation for repainting, very large amounts of lead-contaminated dust is produced, which can also constitute a severe health hazard.
Children playing indoors or outdoors get house dust or soil on their hands, and then ingest it through normal hand-to-mouth behaviour. If the dust or the soil is contaminated with lead, the children will ingest lead. Hand-to-mouth behaviour is especially prevalent in children aged six years and under, the age group most easily harmed by exposure to lead. A typical one- to six-year-old child ingests between 100 and 400 milligrams of house dust and soil each day.

In some cases, children pick up paint chips and put them directly into their mouths. This can be especially harmful because the lead content of paint chips is typically much higher than what is found in dust and soils. When toys, household furniture, or other articles are painted with lead paint, children may directly ingest the lead- contaminated, dried paint when chewing on them. Nonetheless, the most common way that children ingest lead is through lead-contaminated dust and soil that gets onto their hands.

While lead exposure is also harmful to adults, lead exposure harms children at much lower levels. In addition, children absorb up to five times as much ingested lead as adults. Children with nutritional deficiencies absorb ingested lead at an even increased rate.

The younger the child, the more harmful lead can be, and the health effects are generally irreversible and can have a lifelong impact. The human fetus is the most vulnerable, and a pregnant woman can transfer lead that has accumulated in her body to her developing child. Lead is also transferred through breast milk when the lead is present in a nursing mother. Once lead enters a child’s body through ingestion, inhalation, or across the placenta, it has the potential to damage several biological systems and pathways. The primary target is the central nervous system and the brain, but lead can also affect the blood system, the kidneys, and the skeleton. Lead is also categorised as an endocrine-disrupting chemical (EDC). It is generally agreed that one key element in lead toxicity is its capacity to replace calcium in neurotransmitter systems, proteins and bone structure, altering function and structure and thereby leading to severe health impacts. Lead is also known to affect and damage cell structure.

According to the World Health Organization (WHO): “Lead has no essential role in the human body, and lead poisoning accounts for about 0.6 percent of the global burden of disease.” Evidence of reduced intelligence caused by childhood exposure to lead has led WHO to list “lead-caused mental retardation” as a recognised disease. WHO also lists it as one of the top ten diseases whose health burden among children is due to modifiable environmental factors.
In recent years, medical researchers have been documenting significant health impacts in children from lower and lower levels of lead exposure. According to a factsheet on Lead Poisoning and Health from WHO: “There is no known level of lead exposure that is considered safe.”

When a young child is exposed to lead, the harm to her or his nervous system makes it more likely that the child will have difficulties in school and engage in impulsive and violent behaviour. Lead exposure in young children is also linked to increased rates of hyperactivity, inattentiveness, failure to graduate from high school, conduct disorder, juvenile delinquency, drug use, and incarceration. Lead exposure impacts on children continue throughout life and have a long-term impact on a child’s work performance, and—on average—are related to decreased economic success.

Lead paint regulatory framework in the Philippines

The Philippines, through the Department of Environment and Natural Resources (DENR) Administrative Order 2013 24, also known as the Chemical Control Order for Lead and Lead Compounds (or the CCO), establishes a total lead content limit of 90ppm for lead used as a pigment, drying agent or some other intentional purposes in paint formulations. The CCO sets a phase-out deadline of three years (2013-2016) for lead-containing paints used for architectural, decorative and household applications and six years (2013- 2019) for lead-containing paints used for industrial applications. By 2020, the Philippines had completed the phase-out of lead in all paint categories. In 2015 and 2016, the EMB issued two Memorandum Circulars (MCs) clarifying certain prohibited uses of lead and lead compounds as listed in the CCO.

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Following the adoption of the CCO, the Bureau of Philippine Standards (BPS) of the Department of Trade and Industry (DTI), with the active participation of the members of the BPS Technical Committee on Paints, harmonised the outdated limit on lead in paint from 1,000ppm to 90ppm in accordance with the CCO. The Department of Education (DepEd), the Department of Interior and Local Government (DILG), and the Department of Social Work and Development (DSWD) also took important steps to reinforce the ban on lead in paints in line with DENR A.O. 2013-24.

DepEd Order 4, Series of 2017 on the “Mandatory Use of Lead-Safe Paints in Schools” requires the use of independently certified lead-safe paints/ coatings in the painting and repainting, among other things, of school facilities and amenities such as a playground, covered court and the like. DILG Memorandum Circular 2018-26 on the “Mandatory Use of Lead Safe Paints by Local Government Units (LGUs)” enjoins provincial governors, city mayors, municipal mayors and barangay chairpersons to adopt a “Lead-Safe Paint Procurement Policy” for painting jobs paid out of public funds. This circular further instructs local officials to ensure prohibited uses of lead, including their use in indoor and outdoor playground equipment, are duly observed.

Also, the DSWD memorandum issued in 2017 requires the use of lead-safe paints as a mandatory requirement in facilities catering to disadvantaged and vulnerable sectors. According to the memorandum, “the Standards Bureau/Unit shall ensure compliance by all social welfare and development agencies that their residential and non-residential facilities, including furniture, fixture, and equipment, are using lead safe paints or coatings prior to licensing or re-
accreditation.”

Locally, the Quezon City Government and the Davao City Government enacted ordinances in 2018 requiring the mandatory procurement and use of certified lead-safe paints, including enamels, glazes, lacquers, primers, stains, varnishes and other surface coatings, in government-funded construction, maintenance and renovation projects. As a result of the EcoWaste Coalition-IPEN joint study on lead concentrations in spray paints sold locally, the Food and Drug Administration (FDA), through Advisory No. 2020-1585, issued a public health warning against the purchase and use of 37 spray paints containing significant levels of lead in excess of the 90ppm maximum limit.

While third-party certification is not integrated into the CCO, the promulgation of the policy led to the birth of a voluntary Lead Safe Paint® Certification programme initiated by the International Pollutants Elimination Network (IPEN) and the EcoWaste Coalition with support from the Philippine Association of Paint Manufacturers (PAPM). This third-party certification program verifies and certifies that a paint brand has less than 90ppm lead allowing it to use the Lead Safe Paint® logo, a visual tool that can assist consumers in making an informed choice when purchasing paints.

Most recently, the DILG released an advisory on 14 April 2023 reiterating the compulsory use of lead-safe paints by LGUs and enjoining local government officials to:

• Adopt best practices and design and implement a “Lead-Safe Paint Procurement Policy” to ensure that LGUs adopt green procurement policies and incorporate environmental considerations into their procurement processes;
• Ensure compliance with Department of Education (DepEd) Order No. 4, s.2017, on the mandatory use of lead-safe paints in all schools and the observance of proper lead paint abatement and removal to avoid the generation and dispersion of lead-containing dust;
• In accordance with the previous items, consider utilising locally- produced paint products that meet the government’s regulatory standards, as well as the standards under the Lead Safe Paint® Certification Program of IPEN;
• Promote compliance with other prohibited uses of lead as specified under DENR AO No. 2013-24, such as the prohibition on the use of lead in the manufacturing and distribution process of food and beverage packaging, cosmetics, learning materials, school supplies, toys, and other children’s products, including indoor and outdoor play equipment;
• Promote industrial compliance with chemical control policies and lead-free production practices, as well as public awareness on the debilitating impacts of lead and lead compounds on human health and the environment through information, education and communication (IEC) initiatives;
• Co-operate with concerned national government agencies regarding compliance with and implementation of established product recall mechanisms and protocols; and
• Participate in the annual celebration of International Lead Poisoning Prevention Week, an initiative of the Global Alliance to Eliminate Lead Paint (Lead Paint Alliance) jointly led by the United Nations Environment Programme (UNEP) and the World Health Organization (WHO), every last week of October of each year.

Materials and methods

From 23-31 May 2023, the EcoWaste Coalition procured a total of 95 paint brushes from 62 general merchandise, hardware and home improvement stores located in 13 cities in Metro Manila, namely Caloocan, Las Piñas, Makati, Malabon, Mandaluyong, Manila, Marikina, Parañaque, Pasay, Pasig, Quezon, Taguig, and Valenzuela Cities. The paint brushes represented 50 brands with prices ranging from P11 to P120 each depending on the size. Paint brushes with yellow-coated handles were prioritised for this study. Excluded were paintbrushes with plain wood or plastic handles. Each paint brush was given a sample number and information about its manufacturer and/or country of origin, as shown on the label, was duly recorded. The samples were screened for lead using a portable Olympus Vanta M Series X-Ray Fluorescence (XRF) spectrometer.

Results

Seventy-nine of the 95 paint brushes (83%) had total lead content above the 90ppm threshold limit under the DENR A.O. 2013-24, or the Chemical Control Order for Lead and Lead Compounds. Lead at concentrations ranging from 120 to 17,930 ppm was detected in these samples. Seventy of the 79 lead-painted brushes contained lead above 1,000ppm;
37 had lead above 5,000 ppm; and 11 contained high concentrations of lead exceeding 10,000ppm. A Camel paint brush registered with the highest lead concentration at 17,930ppm.

Sixty-one of the 71 paint brushes with yellow handles (86%) were coated with lead paint. The non-detection of lead in 10 paint brushes coated with yellow paint, the colour of choice for paint brushes, indicates that such paint can be made without lead additives. None of the 79 lead-decorated paint brushes provided lead hazard warning on the product label. There was no precautionary statement on the label that such brushes should not be used for food preparations. Also, none of the “unleaded” paint brushes were labeled “lead-free” or “lead-safe.”

Among the paint brushes found to contain lead in the previous study, Butterfly paint brushes showed the most significant lead content reduction: from 10,500ppm in 2018 to no detectable lead in 2023. 2B paint brushes also showed some reductions — from 11,300ppm in 2018 to 65ppm, 160ppm, and 3,160ppm in 2023 – but still above the 90ppm limit. Panclub was the only paintbrush with a yellow-coated handle that was found negative for lead in 2018. However, for the current study, four Panclub paint brushes contained 260ppm to 5,125ppm lead (the fifth sample had 40ppm).

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Discussion

The detection of lead on the coated handles of paint brushes suggests non-compliance with the country’s lead paint regulation, which sets a maximum limit of 90ppm for lead in all paints. With the completion of the phase-out deadlines for lead- containing decorative paints in December 2016 and lead-containing industrial paints in December 2019, it would only be logical for painting tools such as brushes to be safe from lead.

As paint brushes are commonly used for other purposes at home, school or office, it is important that such brushes do not pose lead-based paint hazard. Some people, for instance, may use paint brushes to remove dust and dirt from collections of delicate objects and toys, laptop keyboard, electric fans, and other gadgets and appliances. Frequent use of the brush will cause the paint to break or crumble into dust posing lead exposure risk through the ingestion or inhalation of lead-containing paint chip or dust. The flaking of the lead-coated handles of such brushes, which can occur with repeated use, may result in the unintentional contamination of the paint that does not contain lead and should be avoided.

Also, paint brushes are typically used in various food preparations in the Philippines. For example, paint brushes are often used for applying basting sauce on grilled meat such as pork and chicken barbecue or for spreading butter, oil, or glaze on food such as bread, corn on the cob and native delicacies like “bibingka” (rice cake) and “puto bumbong” (steamed sticky rice).

Using paint brushes, which are non-food grade utensils, may pose a lead contamination risk, especially when the lead-painted handle has started to crumble due to repeated use and exposure to heat when used near cooking setups (i.e., barbecue grill). The chalking, chipping, or peeling lead paint on the handle of these brushes may get onto the sauce, butter, glaze, or oil that is applied to food and into someone’s mouth. This raises the possibility for lead poisoning to occur due to the ingestion of lead-contaminated food. A review of the toxicity of lead states that “lead is thought to be quickly absorbed in the bloodstream and is believed to have adverse effects on certain organ systems like the central nervous system, the cardiovascular system, kidneys and the immune system. ”

While we have yet to see a published study co-relating lead contamination of food with the use of lead-containing paint
brushes, food preparers are advised to err on the side of caution and only use food- safe devices. One precaution that can be taken by food preparers is not to use paint brushes and to use food-grade basting brushes or mops. If food-grade basting or pastry is not affordable or available, ingenious food preparers can opt for DIY (do-it-yourself) mops made out of banana, lemon grass, or pandan leaves.

Recommendations

As the elimination of lead exposure at its source is the single most effective action against childhood as well as adult lead poisoning, the EcoWaste Coalition recommends the following action steps:

For paint brush manufacturers:

• Withdraw from the market paint brushes decorated with lead paint.
• Ensure that only lead-safe paints are used for decorating paintbrushes.
• Provide adequate product labeling information, including lead content and lead hazard warning.
• Include a precautionary warning on the label stating that paint brushes may not be suitable for food-related applications.

For hardware stores, home improvement centres and other retailers:

• Demand certified lead-safe paint brushes from suppliers and desist from selling lead-containing paint brushes.
• Put up a warning sign on the paint brush rack or shelf: “Safety First: Not Suitable for Food Preparation.

For consumers:

• Ask for lead-safe paints, as well as lead-safe paint brushes, from your favourite store.
• For food preparation, use hygienic food-grade basting mops and refrain from using paint brushes.

For the government: 

• Educate the public about the risks of misusing paintbrushes for food purposes.
• Prohibit the use of paint brushes for food preparation as a precaution against lead contamination.
• Strictly enforce the ban on lead-containing paints in the production of paint brushes and other home improvement products.

Conclusion

This study confirms that paint brushes with high concentrations of lead attributable to the use of lead paint on the brush handle are being sold in the market despite the national ban on lead-containing paints. The same study further confirms the availability of paint brushes that pose no lead paint hazard. As the nation pursues the elimination of lead-containing paints in line with the Chemical Control Order for Lead and Lead Compounds and consistent with the global goal of phasing out such paints and eventually removing the risks that such paints pose, it is essential that materials used for painting works such as paint brushes are certified and labeled lead-safe. The misuse of paint brushes for food preparations, particularly for spreading barbecue sauce, butter, glaze or oil on food, makes it all the more urgent for paint brush makers and sellers, including those engaged in online sale, to ensure that only lead-safe paint brushes are made available to consumers, while national and local government authorities take steps to halt such misuse of paint brushes for food purposes.

This is an abridged version of the report ‘Toxic lead I’m paint brushes sold in the Philippines’ by the EcoWaste Coalition, 2023. 

The coalition acknowledges with thanks Manny Calonzo for purchasing and screening the paintbrush samples for lead content and for writing the report; Jeiel Guarino, Chinkie Peliño-Golle and Aileen Lucero for reviewing it; and Ruel Kenneth Felices for the design and layout.  The EcoWaste Coalition is a non-government and non-profit network of organisations working towards the envisioned zero waste and toxics-free society where communities enjoy a healthy and safe environment.