I was surprised when I opened MWAN, Vol. 11, No. 4 (March/April 1993) to find a letter that I had written to Hal being quoted in his editorial #62. My letter was to announce that we would no longer be casting miniatures using lead alloys. We had been planning on eliminating the lead for some time and made the change in January of this year. By switching from lead-based metal to lead-free pewter we now offer a comparable, but safer, product for those hobbyists who want to avoid exposing their children and others to the potentially toxic effects of lead. Hal raised the question in his editorial that we might be turning our backs on other manufacturers by not defending the continued use of lead. He mentions that experienced casters for one of the major manufacturers have never shown an increased blood lead level, even after years of exposure. I also have been a lead caster for the past 39 years and have not shown any apparent symptoms of excess lead. But is this to say that 20 years from now I still won't show any symptoms? What about my children and grandchildren and those of our customers? What is behind the recent increase in concern over exposure to lead? The latest stimulus was the short-lived "ban" on lead miniatures placed in effect by the State of New York. How did the New York ban come about? To find out, I contacted the State of New York Department of Health, Bureau of Toxic Substance Assessment (the laboratory that conducted the tests on the miniatures). They reported back to me as follows: "On December 2, 1992, pursuant to Section 16 of the New York State Public Health Law, the Department issued an Order for Summary Action which directed certain manufacturers of lead figurines to immediately cease the sale and/or distribution of their products in New York State." They further reported that "An administrative hearing on the order was held on December 15-16, at which several of the manufacturers presented arguments against the Order. At the conclusion of the hearing, the Administrative Law Judge indicated that he would recommend that the Commissioner of Health withdraw the Order. In a separate action, a manufacturer and a distributor brought suit in New York State Supreme Court seeking an injunction to stay the Commissioner's Order. On December 18, 1992, the Court granted an injunction which suspends the Order. The Health Department has decided not to appeal, but rather to pursue the regulatory route, which will limit the amount of lead in many consumer products. Although the ban on the sale of lead figurines is no longer in effect, the Department of Health considers these items to represent a potentially significant and unnecessary source of lead exposure for some children." THE NEW YORK STATE HEALTH DEPARTMENT REPORT The report from the Health Department is a comprehensive review of the history of lead poisoning and a detailed report of their chemical tests conducted on lead figurines using simulated handling and oral ingestion. The report is much too long to quote in its entirety, but the conclusions drawn are of interest to all of us in the miniatures hobby. The report is entitled "A PRELIMINARY EVALUATION OF LEAD EXPOSURE ASSOCIATED WITH LEAD FIGURINES", published by the New York State Department of Health, Center for Environmental Health, Wadsworth Center for Laboratories and Research, October, 27, 1992. I will quote what I consider pertinent sections of the report and the Executive Summary: "Small collectible figurines made of an alloy containing lead and lesser amounts of tin, antimony, and other metals have been identified as potential sources of lead exposure in children following a recent report of elevated blood lead levels in two children who owned a collection of approximately 14 figurines... An extensive review of the literature produced limited information on lead poisoning associated with lead figurines or similar objects. However, several case reports of children poisoned from ingestion of lead objects were identified.. .The Centers for Disease Control (Lead Poisoning Prevention Branch) and the NYS Department of Health Injury Control Program have not received any reports of childhood lead poisoning associated with lead figurines or similar objects. However, the National Injury Information Clearinghouse of the Consumer Product Safety Commission (CPSC) received several consumer complaints about lead figurines. These complaints identify lead figurines from several manufacturers and antique lead soldiers as potential sources of lead exposure. Two series of laboratory experiments were performed to measure the amount of lead that can be removed from figurines by hand contact and by direct oral contact. Unpainted small and large figurines and a painted figurine were tested. Hand contact experiments were performed by handling figurines with either dry filter paper or filter paper moistened with antificial perspiration. Oral contact experiments measured the amount of lead removed by artificial saliva. Results of these experiments showed that lead is easily removed from figurine surfaces...Results for the painted figurine show that painting is ineffective in preventing lead removal from figurine surfaces...Experimental data simulating oral contact with a large figurine showed an increasing amount of lead removed from the figurine in each successive day's testing.. .When compared to other sources of lead, the results of this evaluation show that lead figurines may be a more important source of exposure for some children than lead in diet, soil or water...Although no data are available on measured gastrointestinal absorption rates of metallic lead in children, the available information suggests that it will be relatively well absorbed. The case reports.. .demonstrate that when large lead objects are ingested, lead is sufficiently absorbed to produce lead poisoning...The experimental results obtained in this evaluation indicate that lead can be readily removed from figurine surfaces. Children who handle the figurines may be exposed to lead by hand-to-mouth contact and direct oral contact. The range of estimated lead intake and blood lead levels resulting from exposure by these pathways suggests that while impacts on some children with low frequency of contact and little hand-to-mouth activity may be quite small, contact with lead figurines may also result in potentially significant increases in blood lead levels. In 1991, the Centers for Disease Control recommended that the goal of all lead poisoning prevention activities should be to reduce children's blood lead levels below 10 ug/dL (author's note: ug/dL = micrograms per day intake)...Results of the present evaluation show that under some conditions, handling of lead figurines may result in blood lead levels above 10 ug/dL." This alarming report shows that there is a serious concern among state and national health agencies concerning exposure to lead. We know that lead-based pewter has been banned from food service utensils. We know that lead-based glazes have been banned in the manufacture of pottery intended for food use. Concerns such as these are being transmitted to our governing bodies at all levels in ever-increasing numbers. As noted in the introduction, New York may have lost the battle to immediately ban lead miniatures, but they are intending to continue the war at the state legislative level. There will be increased regulatory interest in other states and also at the Federal level. We all realize that miniatures are not the only source of lead -- there are potential sources in many consumer products. However, we must also remember that the manufacturing of miniatures is a very small industry and thus, considered an "easy target". Inevitably, there will be legislation passed and lead miniatures will be contolled or even banned. Is it worth fighting the inevitable? Can we, as manufacturers, continue to pour countless thousands of dollars into the bottomless pit of legal defense of a known toxic material? I think not. Is there a solution? I believe there is. AN ALTERNATIVE TO LEAD MINIATURES Is there an alternative to lead-based miniatures? What are the pros and cons? I decided to find out. The first step was to contact our metal supplier. He assured me that other companies in the casting business have been using lead-free pewters for years and that if I tried one I might be surprised. At first I was skeptical because the industry rumors warned that the cost would be too high, the molds wouldn't work, etc. However, I bit the bullet (figuratively) and bought samples of lead-free pewter which contain a high percentage of tin. The cost was more than double that of lead alloy -- a negative. After thoroughly cleaning the equipment the first lot of pewter was tested. It melted at a couple hundred hundred degrees below that of lead alloy -- a positive (less fuel consumption and the molds would not burn up as fast). A variety of molds containing everything from regular infantry to artillery pieces and small accessory parts such as muskets and bullet pouches were then spin cast. Everything cast exactly as it should! Virtually 100% fill in every mold--the rumors I had heard were unfounded. OK, my skepticism was starting to wane. But, would the general public buy into non-lead figures? To test these stormy waters, I contacted some of the world's finest critics -- the local wargaming club! I invited several members of the Colorado Military Historians to a Bash-the-Pewter meeting. Sets of identical lead and lead-free miniatures were circulated and the group was asked to critically evaluate them. The inevitable first question was: "How much will the price increase?" Of course, the metal cost would be more than double and other costs would be involved (new labels, etc.). But there were other considerations that would offset these costs. The tin-based pewter is about 34% lighter than lead alloy. That meant we could get 34% more figures per pound and the shipping costs would be less. Productivity would also increase since we could get almost 100% fill in each mold spin. These are definite positives, but they are rarely mentioned in discussions concerning figure costs. "So, what else don't you like?", I asked the group. After several rounds of murmurs and head shakes I heard: "These are really nice." "I can bend them and they don't break!" "The detail is fantastic, but how will they paint up?" Having anticipated that last question, we had painted a sample and, again, the comments were all favorable. "These tin figures won't tarnish like the lead ones - we won't have to paint sabers and bayonets, just leave them the natural pewter color!" By the time the group left nobody had found a reason not to switch to the lead-free pewter other than the increased cost of the metal, which I had estimated to be in the range of 1-2 cents per 15mm figure or 2-3 cents per figure for our 22mm ACW line. After the meeting, we were convinced that we had made the right decision and went to work. By mid-January we had completed the switch. It was difficult watching thousands of lead figures being melted down and cast back into ingots, but it was painless. Our metal supplier bought back the lead alloy, we bought a supply of pewter and are now in the process of building up our figure stock. The response to date has been very positive. Our customers call or write with words of encouragement. We also hear that several other manufacturers have converted, or are in the process of converting, to non-lead or low-lead alloys. As stated earlier, the only negative point raised concerning non-lead castings has been the slight price increase. But what price can you put on a child's life? Our hobby is considered an adult hobby and there is no documented case of a child's death due to handling or ingesting lead miniatures. But, do want your child to be the first? And what about that price increase? I think we tend to focus too much on the cost of metal. It is just one part of the overall cost of manufacturing miniatures -- a minor cost compared to taxes, labor, insurance, advertising, facilities, utilities, lawsuits, etc. Lawsuits? Has anyone considered how much figure costs will skyrocket if we continue to defend lead with $50,000 law suits? I'll take lead-free pewter any day! Related: The Lead Plague. Back to MWAN #63 Table of Contents Back to MWAN List of Issues Back to MagWeb Magazine List © Copyright 1993 Hal Thinglum This article appears in MagWeb (Magazine Web) on the Internet World Wide Web. Other military history articles and gaming articles are available at http://www.magweb.com