Federal Hazardous Substances Act — Household Product Safety Labeling

The Federal Hazardous Substances Act (FHSA) is the federal law that requires hazardous household products and children's articles to carry specific safety warnings. If you see a label on a cleaning product that says DANGER — Causes Severe Burns or a toy with a warning that CHOKING HAZARD — Small Parts, Not for Children Under 3 Years — those disclosures are required by the FHSA or regulations under it, enforced by the Consumer Product Safety Commission (CPSC).

The FHSA covers toxic, corrosive, flammable, irritating, or pressure-generating household products; electrical, mechanical, and thermal hazards in toys and children's articles; lead content in children's products; and art materials with chronic health hazards. A product that fails to carry required warnings is legally a "misbranded hazardous substance" and cannot be lawfully sold. A product banned under the Act cannot be sold at all.

Current Law (2026)

Legal Authority

• 15 U.S.C. § 1261 — Definitions: hazardous substance (toxic, corrosive, irritating, strong sensitizer, flammable/combustible, pressure-generating), misbranded hazardous substance (inadequate labeling), banned hazardous substance (labeling cannot protect the public)
• 15 U.S.C. § 1262 — CPSC may officially designate substances as hazardous; may add special labeling rules; may ban toys or children's articles with electrical, mechanical, or thermal hazards
• 15 U.S.C. § 1263 — Prohibited acts: selling or distributing misbranded or banned hazardous substances; falsifying guaranties; tampering with labels; selling hazardous substances in repurposed food/drug containers; selling lead solder over 0.2% without warning
• 15 U.S.C. § 1264 — Penalties: misdemeanor with up to $500/$5,000 fine; knowing/willful violation up to 5 years; civil penalties up to $100,000 per violation/$15,000,000 series cap
• 15 U.S.C. § 1265 — Seizure: federal courts can seize and condemn non-compliant products
• 15 U.S.C. § 1270 — Inspections: CPSC inspectors may enter manufacturing and storage facilities on notice to inspect and sample products
• 15 U.S.C. § 1273 — Imports: Treasury must give CPSC samples of hazardous substances being imported; non-compliant goods denied entry or must be exported/destroyed
• 15 U.S.C. § 1274 — Remedies: CPSC may require manufacturers to notify consumers, recall products, repair, replace, or refund for banned hazardous substances or defective children's products
• 15 U.S.C. § 1277 — Art materials: labeling must follow ASTM D-4236 chronic hazard communication standard; manufacturers must evaluate all art materials for chronic health risks
• 15 U.S.C. § 1278 — Toy labeling for small parts: specific warnings required on packages of toys with small parts for children ages 3 to 6; applies to balloons, balls ≤1.75 in., and marbles for children under 8
• 15 U.S.C. § 1278a — Lead in children's products: banned above 100 ppm total lead in any accessible part; CPSC reviews limits every 5 years

How It Works

The FHSA creates two categories of non-compliant products: misbranded and banned. A misbranded hazardous substance has an actual hazard but lacks proper warning labeling — it can come into compliance through relabeling. A banned hazardous substance is one where no label would adequately protect the public, so it simply cannot be sold; CPSC must go through formal rulemaking, with cost-benefit analysis and public comment, to ban a substance. Labels must be specific, not generic: the law requires the manufacturer's name and address, the common or usual name of the hazardous ingredient, a signal word (DANGER, WARNING, or CAUTION), a statement of the principal hazard, precautionary measures, first-aid instructions, handling and storage guidance, and a child-safety statement when appropriate. Generic warnings ("may be hazardous") do not satisfy the statute. Under §1277, manufacturers and importers of art materials — from children's markers to professional oil paints — must evaluate every product for chronic health risks (cancer, reproductive harm, organ damage) and label accordingly; CPSC regulations adopted the ASTM D-4236 standard for this purpose, which is why some professional paints carry specific warnings about chromium, cadmium, or other heavy metals.

Lead and small-parts rules operate as bright-line standards that require no additional rulemaking. Under §1278a, any children's product with total lead content above 100 parts per million in any accessible part is automatically a banned hazardous substance — tightened from the original 600 ppm limit by the Consumer Product Safety Improvement Act of 2008, and separate from the 90 ppm lead-in-paint standard. This is why vintage lead-containing toys cannot legally be resold as children's products and why importers face strict customs screening. Toys and articles intended for children ages 3 through 6 must carry specific choking hazard warnings when they include a small part (one that fits entirely in the cylindrical small-parts tester simulating a child's throat); the warning must appear on packaging, in instructions, and in direct-purchase advertising. Latex balloons, balls 1.75 inches or smaller in diameter, and marbles require warnings for children under 8 — not just the under-3 rule. The FHSA is distinct from but related to the Consumer Product Safety Act (15 U.S.C. §§ 2051–2089), which gives CPSC its general recall and enforcement authority; a children's product can simultaneously be non-compliant under the FHSA (bad or missing label) and subject to a CPSA recall (dangerous defect). See Consumer Product Safety Commission for the broader CPSC framework.

How It Affects You

If you have young children or buy children's products: The FHSA's lead limits directly protect children from one of the most consequential preventable hazards — childhood lead exposure causes permanent cognitive damage with no safe threshold. Federal law caps lead content in children's products at 100 parts per million (ppm) in any component; substrate materials (the base material) must be below 90 ppm. These limits have been federal law since the Consumer Product Safety Improvement Act of 2008. If you buy a vintage or secondhand toy — especially anything made before 2008 — be aware it may not meet current lead limits: toys manufactured before the CPSIA are not required to be relabeled, and older painted toys may contain lead paint at levels far above current limits. When buying secondhand for children under 12, check whether the item was manufactured before 2008 and consider whether paint chips or flaking are a concern. Small parts are the other major FHSA children's hazard: any product intended for children under 3 must pass a "small parts cylinder" test — any component that fits in the cylinder (approximately 1.25 inches diameter, 2.25 inches deep) cannot be in the product. If you see "Not for children under 3" on a toy, that's a mandatory FHSA warning, not a marketing choice. If you believe a product violates these requirements, report it to CPSC at saferproducts.gov — the agency tracks consumer complaints and can initiate recalls.

If you buy or use household chemical products: The signal word system on cleaning, pesticide, and chemical products is not voluntary branding — it is a mandatory FHSA labeling scheme calibrated to actual acute toxicity and physical hazard. DANGER (or DANGER-POISON with skull-and-crossbones) means the product is highly toxic, corrosive, or flammable; even small amounts can cause severe harm or death. WARNING means moderately hazardous. CAUTION means slightly hazardous. These designations are based on LD50 (lethal dose) testing and corrosivity/flammability measurements regulated by the FHSA and CPSC's regulations at 16 CFR Part 1500. First-aid instructions on the label are also legally required and calibrated to the product's specific hazard — if a product says "if swallowed, do not induce vomiting," that instruction is there for a chemical reason, not a legal formality. If you or a family member is exposed to a household chemical product, call Poison Control at 1-800-222-1222 — the label's first-aid instructions are the right starting point, but Poison Control can provide real-time clinical guidance for your specific situation.

If you make or sell art supplies, craft materials, or educational products: Every art material product you sell must bear a toxicological evaluation by a licensed toxicologist certifying that chronic hazard labeling requirements under ASTM D-4236 have been met. This requirement applies to paints, inks, dyes, adhesives, solvents, fixatives, and similar materials marketed as art supplies — regardless of whether they're sold to adults or children. Products for children in pre-kindergarten through grade 6 receive extra scrutiny: CPSC can recommend against purchase of labeled art materials for this age group, and art materials with chronic hazard warnings should not be marketed for young children. If your product is unlabeled (carrying the AP-Approved Product or CL-Cautionary Labeling seal from ACMI), those seals confirm the toxicological evaluation has been completed. If you're a school art teacher or district purchasing coordinator, check that art supply vendors provide current ACMI certification for all products used in lower-grade classrooms; the Art and Creative Materials Institute (acminet.org) maintains a searchable certified products database.

If you import children's products or manufacture products containing chemicals: Lead testing before sale is mandatory — this is not a voluntary quality program. Children's products must be tested by a CPSC-accredited third-party laboratory (list at cpsc.gov/testing) and accompanied by a Children's Product Certificate (CPC) before they can be imported or sold. U.S. Customs and Border Protection enforces this at the border; products failing the 100 ppm lead test will be denied entry and may be seized. The test must cover each component separately — a toy where the body passes but the painted decal fails the lead test fails overall. For chemical manufacturers and importers, the FHSA requires that hazardous household substances intended for home use carry proper FHSA labeling before import. CPSC coordinates with CBP on enforcement; the CPSC business guidance page at cpsc.gov/Business--Manufacturing provides the current compliance requirements and a list of accredited testing labs. Non-compliance can result in import detention, civil penalties up to $15 million per violation series, and potential criminal liability for knowing violations.

State Variations

The FHSA generally does not preempt state hazardous substances laws the way the Flammable Fabrics Act preempts state flammability standards. States may maintain hazardous substances labeling requirements that are stricter or different from federal requirements:

• California's Proposition 65 requires warnings for products containing chemicals known to the state to cause cancer or reproductive harm — much broader than FHSA requirements
• Some states have enacted additional restrictions on lead in toys or children's jewelry
• For children's products, CPSC's lead limits set a federal floor, but states may enforce higher standards

Implementing Regulations (Key 16 CFR Parts)

• 16 CFR Part 1500 — Hazardous Substances and Articles: Administration and Enforcement Regulations (65 sections — CPSC's comprehensive labeling rules implementing the Federal Hazardous Substances Act; specifies how hazard categories translate into required label elements):

  • § 1500.12 — Products declared hazardous under FHSA § 3(a): CPSC may declare by regulation that a product is a hazardous substance requiring labeling; Section 3(a) substances include items determined to be toxic, corrosive, flammable, irritating, strong sensitizers, or pressure-generating; once declared, the product must carry all required label elements regardless of the manufacturer's own risk assessment
  • § 1500.13 — Strong sensitizer listing: CPSC maintains a list of substances recognized as strong sensitizers — chemicals that can cause allergic hypersensitivity upon repeated exposure even at low concentrations (e.g., certain formaldehyde-releasing compounds, dyes, and latex proteins); products containing listed sensitizers must carry specific sensitization warnings even if the product's acute toxicity would not otherwise require labeling
  • § 1500.121 — Label prominence and conspicuousness: required label elements must be prominently displayed with such conspicuousness and contrast as to render them likely to be read by ordinary individuals; CPSC specifies minimum type sizes keyed to label surface area; signal words (DANGER, WARNING, CAUTION) must be larger than other required text; the signal word must appear in a contrasting color box or panel; labels buried in fine print or placed on the back of a container while hazard-specific warnings are on the front do not comply
  • § 1500.122 — Deceptive disclaimers: a label that contains required FHSA warnings but also contains statements that undermine those warnings is non-compliant; examples include "non-toxic as formulated" adjacent to a toxicity warning, or "environmentally safe" on a product that requires a flammability warning; the presence of disclaimer language that contradicts required warnings makes the product "misbranded" under the FHSA
  • § 1500.127 — Multiple hazards: when a product presents more than one type of hazard (e.g., both flammable and toxic), the label must address all hazards; the signal word used must be for the most severe hazard (DANGER takes precedence over WARNING, which takes precedence over CAUTION); the precautionary statements for each hazard must all appear
  • § 1500.130 — Aerosol/pressurized container labeling: self-pressurized containers (spray cans) must include a warning that the container is pressurized and instructions not to puncture or incinerate; containers propelled by flammable gases must carry flammability warnings; aerosol products are one of the highest-frequency FHSA enforcement categories because of the combination of pressurized delivery, inhalation hazard, and flammability risk

  The signal word system (DANGER = highly toxic/corrosive/extremely flammable; WARNING = moderately hazardous; CAUTION = slightly hazardous) is based on acute toxicity data (LD50 — the dose lethal to 50% of test animals) and physical hazard measurements. The specific threshold for each signal word is tied to the statutory FHSA hazard definitions: "highly toxic" means LD50 ≤ 50 mg/kg oral, ≤ 200 mg/kg dermal, or causing severe eye damage; "toxic" means LD50 ≤ 500 mg/kg oral, ≤ 1000 mg/kg dermal. The differences between signal words thus reflect order-of-magnitude differences in lethality risk. CPSC enforces Part 1500 through market surveillance, retailer audits, and consumer complaint investigation — misbranded products can be subject to civil penalties up to $100,000 per violation and, for products with known hazards, mandatory recall.

• 16 CFR Part 1501 — Method for identifying toys presenting choking hazards

• 16 CFR Part 1505 — Requirements for electrically operated toys

• 16 CFR Part 1512 — Requirements for bicycles

• 16 CFR Part 1303 — CPSC Ban on Lead-Containing Paint: the foundational rule declaring lead-containing paint a "banned hazardous product" under CPSA §§ 8–9. Key provisions:

  • § 1303.1 — Lead-containing paint is banned for consumer use; toys and articles for children bearing lead-containing paint are banned; furniture articles bearing lead-containing paint are banned; ban applies to products manufactured after February 27, 1978
  • § 1303.2 — "Lead-containing paint" means paint or similar surface coating with lead content exceeding 0.06 percent (600 ppm) of the total nonvolatile content or dried film weight — tightened by Congress in the Consumer Product Safety Improvement Act of 2008 to 0.009 percent (90 ppm) effective August 14, 2009; this 90 ppm limit for lead-in-paint is distinct from CPSIA's 100 ppm total lead content limit for children's products under 16 CFR Part 1307
  • § 1303.3 — Exemptions: artists' paints, industrial and commercial coatings (for bridges, marine use, industrial machinery), and products for outdoor non-residential use may be sold if labeled with the required "Contains Lead" warning on the main panel, plus a secondary statement prohibiting use on toys, children's articles, furniture, and accessible dwelling surfaces; the warning must remain legible for the product's shelf life
  • § 1303.4 — Banned products: any paint exceeding the threshold, any children's toy or article bearing such paint, and any furniture bearing such paint manufactured after the 1978 effective date are banned hazardous products regardless of labeling

  The 1978 ban predated the CPSIA's tighter limits and applied exclusively to consumer paints. The 2009 reduction to 90 ppm aligned the consumer paint ban with CPSIA and significantly tightened requirements for children's products — most notably eliminating the broad "antique/vintage" market exemption that some sellers had used. A product manufactured before 1978 and sold secondhand is not subject to the ban (it predates it), but a retailer knowingly reselling a lead-contaminated toy as a new children's product would violate CPSA § 15(c). EPA's lead-in-paint rules under Title X (Residential Lead-Based Paint Hazard Reduction Act) — covering disclosure, renovation, and abatement in pre-1978 housing — operate separately from this CPSC ban.

• 16 CFR Part 1307 — Prohibition of Children's Toys and Child Care Articles Containing Specified Phthalates. Note: the existing stub describing this Part as "lead content limits" was inaccurate — Part 1307 covers phthalate plasticizers, not lead; total lead content limits for children's products are at 16 CFR § 1500.87 (implementing CPSIA § 101). Key provisions:

  • § 1307.1 — Scope: prohibits the manufacture for sale, offer for sale, distribution in commerce, or importation into the U.S. of any children's toy (consumer product designed or intended for a child age ≤12) or child care article (consumer product designed or intended to facilitate sleep, feeding, sucking, or teething for a child age ≤3) containing any specified phthalate above the threshold
  • § 1307.3 — Banned phthalates and concentration limit: >0.1% (1,000 ppm) of any of the following plasticizers is prohibited in covered products: (a) Permanent CPSIA § 108(a) bans: DEHP (di-(2-ethylhexyl) phthalate), DBP (dibutyl phthalate), BBP (benzyl butyl phthalate); (b) Additional CPSIA bans: DINP (diisononyl phthalate), DCHP (dicyclohexyl phthalate), DHEXP (di-(2-ethylhexyl) phthalate isomers), DPENP (di-n-pentyl phthalate), DIBP (diisobutyl phthalate)

  Phthalates are chemical plasticizers added to PVC (polyvinyl chloride) to make plastic flexible — the same compounds that make soft plastic toys, teethers, bath toys, and vinyl flooring pliable. They are endocrine disruptors: animal studies link high-dose exposure to reproductive and developmental effects, and some epidemiological studies associate phthalate exposure with hormonal disruption in humans. The 0.1% threshold applies to each phthalate individually, not cumulatively. Testing is required for children's products; manufacturers must have CPSC-accepted third-party testing labs confirm compliance before import or sale. Products that violate Part 1307 are subject to CPSC mandatory recall authority and civil penalties (up to $100,000 per violation). The 2008 CPSIA phthalate bans complemented the earlier lead limits — together they represent the two major chemical-content standards CPSC applies to children's products.

• 16 CFR Part 1507 — Fireworks Devices: CPSC's safety standards for consumer fireworks (other than firecrackers, which are banned under 16 CFR § 1500.17). Consumer fireworks — sparklers, fountains, ground spinners, rockets, cones, and novelty devices — are regulated under the FHSA as hazardous substances; Part 1507 specifies the physical design standards and prohibited chemical composition requirements that consumer fireworks must meet to be lawfully sold in the U.S.:

  • § 1507.2 — Prohibited chemicals: consumer fireworks may not contain arsenic sulfide, arsenates, or arsenites; boron; chlorates (with limited exceptions for colored smoke devices); gallates; magnesium (as a powder or ribbon); mercury compounds; phosphorus (red or white, but yellow/white phosphorus is banned); picrates and picric acid; thiocyanates; titanium; zirconium; or mixtures of potassium chlorate and sulfur; these prohibitions address chemicals that are unstable, produce highly sensitive compositions, or are associated with catastrophic failures including explosions during manufacture or storage
  • § 1507.3 — Fuse requirements: consumer fireworks that require a fuse must use only coated or treated fuses that reduce the chance of side ignition; minimum fuse length must provide at least 3 seconds but not more than 9 seconds between ignition and device function; this window gives users enough time to move to a safe distance while preventing overly long fuses that create uncertainty about when the device will fire; fuses must be securely attached to the device
  • § 1507.4 — Base dimensions: fireworks devices that operate in an upright position must have base dimensions (width or diameter) at least equal to one-third of the device's height; this stability requirement reduces tip-over that can cause devices to discharge horizontally into spectators rather than vertically
  • § 1507.5–1507.6 — Pyrotechnic leakage and blowout: the pyrotechnic chamber must be sealed to prevent powder leakage during shipping and handling; the chamber must be constructed to allow normal function without burnout (failure of the casing before the pyrotechnic composition fires) or blowout (premature rupture expelling unburned composition)
  • § 1507.7 — Handle requirements: hand-held fireworks must have a handle at least 4 inches long that remains intact during normal use; the handle must be clearly distinct from the fireworks portion and must be strong enough that users don't inadvertently hold the device near the discharge point
  • § 1507.10–1507.12 — Device-specific standards: rockets with sticks must have rigid, straight guiding sticks that remain attached after firing (preventing the stick from becoming a projectile); party poppers (champagne poppers) may not contain more than 0.25 grains of pyrotechnic composition; multiple-tube devices with any tube exceeding 1.5 inches inside diameter must meet additional stability requirements

  Consumer fireworks cause approximately 11,500 injuries (and about 10 deaths) annually in the U.S., primarily from sparklers (hot enough to melt aluminum at 1,200°F), aerial devices, and firecrackers. The Part 1507 standards define the minimum federal floor for consumer fireworks safety; states may and do impose additional restrictions. Firecrackers, cherry bombs, M-80s, and other "professional-use" devices are banned for consumer purchase under 16 CFR § 1500.17(a)(3); "professional" or "display" fireworks are governed by ATF regulations under the Safe Explosives Act.

• 21 CFR Part 1230 — Regulations Under the Federal Caustic Poison Act (FDA, 29 sections — the implementing regulations for the Federal Caustic Poison Act of 1927 (15 U.S.C. §§ 1261–1278), one of the earliest U.S. consumer product safety statutes; the Act requires labeling of containers holding specified dangerous caustic or corrosive substances in household-sized retail packaging; despite its codification in the FHSA's USC chapter, Part 1230 is administered by the Food and Drug Administration, not CPSC — a legacy of the Act's 1927 origins when FDA's predecessor (the Bureau of Chemistry in the Department of Agriculture) had jurisdiction over chemical product labeling):

  • § 1230.2 — Scope: the Act applies to any container that has been shipped or delivered for shipment in interstate or foreign commerce, or received from such commerce for sale or exposure for sale; coverage extends to the full chain of distribution from manufacturer through retailer; the scope provision ensures that a caustic substance packaged in one state and sold in another is subject to FDA jurisdiction regardless of where the violation occurs
  • § 1230.3 — Container definition: "container" means a retail parcel, package, or container suitable for household use — the critical limitation that distinguishes the Caustic Poison Act from industrial chemical labeling requirements; a 55-gallon drum of sodium hydroxide sold to an industrial purchaser is not subject to Part 1230, but a 2-pound can of drain cleaner sold at a hardware store is; the household-suitability determination is based on the size, packaging, labeling, and marketing of the product, not just the chemical identity
  • § 1230.10 — Label placement: the required label or sticker must be firmly attached to the container so it remains affixed while the container is being used; it must be placed so as to readily attract attention — a label hidden on the bottom or back of a container does not comply; the placement requirement ensures that consumers see the hazard warning before opening or using the product
  • § 1230.11 — Required labeling elements: the label must display: (a) the common name of the dangerous caustic or corrosive substance (e.g., "lye," "caustic soda," "sulfuric acid") using the specific names recognized in the statute or any other commonly used name; (b) the word "POISON" in uncondensed Gothic capital letters of at least 24-point type size (§ 1230.13 specifies the minimum letter dimensions); (c) the name and address of the manufacturer, packer, or distributor; (d) directions for treatment (§ 1230.14)
  • § 1230.14 — Directions for treatment: the container must bear, immediately following the word "POISON," first-aid directions covering both internal ingestion (what to do if swallowed) and, if the substance can cause external injury, directions for skin or eye exposure; the directions must be practical and actionable — general advice to "see a doctor" does not satisfy the requirement; specific antidote information and immediate first-aid steps must be included; the treatment directions reflect the Act's public health purpose: caustic substances cause severe tissue damage in seconds, and immediate first aid (e.g., dilution with water, avoiding emesis for certain corrosives) can significantly reduce injury severity
  • § 1230.16 — Exemption for non-household shipments: manufacturers and wholesalers only, at the time of shipment or delivery for shipment, are exempt from the treatment directions requirement when shipping for other than household use; this B2B exemption recognizes that industrial purchasers have separate access to Safety Data Sheets and occupational safety programs; however, distributors who repackage the product for retail household sale must include treatment directions in the final packaging
  • §§ 1230.20–1230.21 — Guaranty provisions: the Act provides a good-faith defense for retailers who purchase caustic products from manufacturers or wholesalers: if a manufacturer or wholesaler provides a general continuing guaranty certifying that all containers comply with the Caustic Poison Act's labeling requirements, a retailer who receives the mislabeled product and passes on the guaranty is not criminally liable for the violation; the guaranty may be a general umbrella document (§ 1230.20) or a specific guaranty attached to a particular bill of sale (§ 1230.21)
  • § 1230.30 — Sample collection: FDA authorized agents — as well as officers of any state, territory, or possession — may collect samples of products in commerce for examination; the sampling authority enables FDA to verify compliance throughout the distribution chain, not just at the point of manufacture; FDA may also rely on state food and drug officials and CPSC as co-enforcement partners for caustic product violations

  The Federal Caustic Poison Act was one of the pioneering federal product safety laws — enacted in 1927, eleven years before the Federal Food, Drug, and Cosmetic Act (1938) and thirty-nine years before the FHSA (1966). The substances covered include: lye and caustic soda (sodium hydroxide, used in drain cleaners), caustic potash (potassium hydroxide), sulfuric acid, carbolic acid (phenol), hydrofluoric acid, acetic acid at 50% or higher, oxalic acid and oxalates, and hypochlorite bleaches at or above 12% — products that remain in household use today. Although the FHSA (1966) created a broader framework for hazardous product labeling under CPSC jurisdiction, the Caustic Poison Act and its FDA implementing regulations remain in effect for products within their scope. In practice, FDA and CPSC coordinate enforcement, and modern caustic product labels typically comply with both the Caustic Poison Act labeling requirements and the broader FHSA signal-word and precautionary statement requirements. No major amendments to Part 1230 in recent decades — the core labeling requirements reflect the 1927 statute's original framework, which has proven durable for the relatively small set of household caustic products it covers.

Pending Legislation (119th Congress)

No major 119th Congress amendments to the FHSA's core labeling framework are pending as of April 2026. CPSC periodically updates specific regulations under the Act, including ongoing work on lead in certain electronic products and art materials.

Recent Developments

• CPSC has continued to enforce the 100 ppm lead limit aggressively for imported children's products; enforcement actions and import refusals for exceeding lead limits remain a regular feature of CPSC's compliance program
• A CPSC rulemaking on small parts in children's toys has been ongoing; questions about how to handle digital and electronic components have complicated the analysis
• See Lead Paint Hazard Reduction for the separate framework governing lead paint in homes and buildings under Title X of TSCA