0ba0c9c5_t_Red_104___Environment_Canada_Summary_table_Response
[Comment] Although the Hazardous Products Act outlines specific restrictions on lead levels in products, a commenter expressed concerns regarding misuse of the pigment products in Canada, which may result in consumer exposure to the lead chromate pigments. The commenter stated that is unclear as to whether end products such as playground equipment are painted with industrial paints or at what level people with hobbies may be exposed to these substances. [Response] 
As mentioned in the screening assessment, the Surface Coating Materials Regulations limit the total lead concentration in surface coatings materials to not more than 600 mg/kg when a dry sample is tested. This limit does not apply to surface coating materials for the purposes of arts, crafts or hobbies for adults and for other defined uses outlined in the screening assessment. However, in the instances where the total lead concentration exceeds 600 mg/kg for these purposes, a specified lead-content warning must appear on the label of the surface coating container which includes the statement "Do not apply to surfaces accessible to children or pregnant women". Although the Surface Coating Materials Regulations do not apply to the use of surface coating materials on playground structures, the Canadian Standards Association has published a voluntary standard entitled "Z614-07 Children’s playspaces and equipment". Some provinces and/or school boards mandate that the requirements of this standard be met for playground structures. This standard requires that all paints or other similar finishes be non-toxic and that non-lead-based paints be used in all new equipment and when repainting existing equipment to eliminate the risk of childhood lead poisoning from playground equipment. Items 2, 9 and 18 of Schedule I, Part I to the Hazardous Products Act prohibit furniture and other articles for children, toys, equipment and other products for use by a child in learning or play and pencils and artists’ brushes that have had a surface coating material applied to them that contains more than 600 mg/kg of total lead.
Public comments for C.I. Pigment Red 104 - Environment Canada