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  • Writer's pictureMichael Skalka

Proper Art Material Labeling Issues

Summary: Most artists are careful about the art materials they purchase, especially when it comes to the color, opacity, and handling properties of the paints they use, but a few painters are stating that some of the usual information is missing from their paint labels.  Read about why it is important to purchase paint that is labeled properly.




This essay is my opinion and does not constitute any legal advice, an official judgment by the American Society of Testing and Materials (ASTM,) or an analysis of the composition of art materials that identify toxicity issues related to pigments.


How did questions about having information missing from paint labels come about? I believe a common dynamic that exists among artists is a yearning to use materials that meet their method of painting and for paints to be made with quality and integrity.  In a few cases, artists post about their distrust of large major brand paints and express the feeling that big manufacturers make paint that is of poor quality, adulterated with fillers and/or dryers. Some artists state that they do not want paint made by a large, unapproachable, corporation, but that they rather purchase products from a company that crafts hand-made paint using a recipe composed of only pigment and binder and nothing else.


Through various means, artists have discovered manufacturers that produce wonderful paint both from major manufacturers and small production companies. For some artists, the criteria for evaluating and selecting their art materials appears to be paint made by small companies that also allow artists to contact and speak to paint makers directly.


Some artists on painting forums post that the companies they are buying from do not sell their products in stores. They sell exclusively online.  Most of the pigments are traditional but artists love that some of the colors produced are unique and venture outside of what is commonly sold in a typical paint line. 


Everything sounds fine except for one critical factor. A few artists expressed some confusion and have reported that the labels some manufacturers are putting on paint tubes have sparse information. One of the most important standards for the art materials industry is called D4236. This standard is overseen by a subcommittee of the American Society of Testing and Materials (ASTM) that deals with artists’ materials.


The standard clearly states that all art material sold in the United States must have a specific number of pieces of information on the label, or if that is not possible because of the type of product (a solid pigment pastel stick, for example) it can appear in company published materials. Without proper labeling, the product does not meet the federal requirement to allow it to be sold in the United States.  Note that a component of this legislation was created to protect Americans from inconsistently labeled foreign brands.  All art materials sold in the United States require labeling that indicates conformance to the health and safety standard called ASTM D4236. This law was enacted by Congress in the 1980s by ASTM D01.57 participants (artists and paint manufacturers) to protect consumers, especially because many of the pigments used by artists have toxic properties that should not be ignored.


The legislation is outlined for manufacturers on a website page belonging to the Consumer Product Safety Commission (CPSC).  Here is the page for your reference should you wish to visit it:


For those who do not want to visit the CPSC website and plod through the details, here is a digest version of what it says. The Labeling of Hazardous Art Materials Act (LHAMA) requires that art materials manufacturers have the raw materials they select to make products reviewed by a certified toxicologist to ensure that none of the pigments or binders contain acute hazards. However, if a material does contain an acute hazard, it can still be sold, but the products must be labeled with text and a graphic warning to alert the consumer of the hazard.


Upon reading this, your reaction might be, “But doesn’t everyone use the same pigment sources, and manufacturers who make paint know which pigments are safe or have toxic materials?” In my opinion, the answer is “No.”  I believe that a multitude of pigment sources are available to manufacturers from a variety of countries.  Paint makers are reticent to share where they obtain their materials so every manufacturer must come up with their source of pigments that need to be evaluated.


With so many suppliers of pigments, paint makers need to have toxicologists evaluate or, in some cases, test the products they are selling to determine if they contain components that need to be indicated on the label.  It is not the pigment maker's responsibility. Outside of the paint world, we would never visit a local hardware store to purchase cleaning products that only displayed a company name and an ambiguous title of what was contained in the bottle, jar, or tube. 


All paint manufacturers selling paint in the United States under current federal law have a responsibility to make sure their materials are properly reviewed by a certified toxicologist and that the paint is labeled appropriately. 


The LHAMA labeling guidelines are very explicit to legally sell art materials in the United States.  Paints need to have the following:


·        Color Name.

·        Pigment Chemical Description.

·        Compliance Statement: “Conforms to ASTM D4236” or similar language.

·        Required Warnings if Warranted:  Skull and Crossbones, Danger, Orange Square with Black X (for sale overseas) Yellow Triangle.

·        Company Contact Information.


The last bullet point is important because the means to contact the paint company must be on the label so that consumers can call 800-222-1222, the National Poison Control Center, if a person or animal (family pet) accidentally consumes an art material. This facilitates poison control obtaining product ingredients directly from the paint maker to guide a medical professional to properly treat the victim that has ingested an art material.


If you want to read more about labeling from the perspective of a manufacturer that is responding to LHAMA requirements, visit this page from Golden Artist Colors’ “Just Paint” publication. Website: https://justpaint.org/label-update-new-health-safety-format/


Why don’t some small paint makers conform to LHAMA as part of their business mission? In my opinion, some may not know that LHAMA requirements exist. Some may have overlooked them and believe they only apply to large manufacturers.  Starting a paint-making operation is expensive and new paint makers put their startup funds into equipment and materials and may have forgotten about conformance because it would have been a burden to set aside the money and time to get products reviewed.


New artists are always emerging into the world of painting. An additional concern that is impacted by sparse information on labels is that a novice artist taking advice from another more seasoned artist may purchase paint without complete labeling and are not aware that what they purchase contains lead for example. With the purchase of a white paint labeled Flake or Cremnitz White, without the name of the pigment and the appropriate warning label, they might not realize the paint contains lead.  One can never assume all artists know the composition of paint using old traditional names.


What can consumers do?  In my opinion, understand from this essay that a LHAMA compliance labeling problem is scattered about in the paint manufacturing industry. Questions posed by artists about what is in the tube of paint they purchased pop up in forums on paint materials.  Next, be assured that my intent in writing this is not to shame or hurt any company that is missing the required information on product labels.  I just want to see artist consumers and the companies that make paint work together so that everyone is protected properly. 


This is an opportunity for artists to have their voices heard and encourage companies that have missing label information to become compliant.  Everyone wins. The manufacturer becomes a compliant seller of goods, diminishing any problems they might encounter because of improper labeling, and as a bonus, these companies can potentially expand the sales potential of their products to be considered by art educational facilities, many of which require products to conform to ASTM D4236 or be on the approved list published by ACMI.


Please take time to examine the products in your paintboxes. If the labels do not match the information listed in the bullet points above, visit the company’s website to post a message or call them and respectfully encourage them to do what is needed to become compliant with LHAMA requirements. We are all a part of making art as safe as possible for everyone. Also, note that not all small companies are out of LHAMA compliance.  Websites and images of products appear to indicate that a few well-known brands may be out of LHAMA compliance as well.


Lastly, please refrain from purchasing foreign art material listed by sellers on Etsy.  Many foreign paints are perfectly fine for sale in their home countries but are seriously out of compliance with US laws. Some of the pigments described are potential acute health hazards.  See a previous Syntax essay on grey market paints.  https://www.syntaxofcolor.com/post/gray-market-paints-not-a-pretty-color Check the inventory of materials you use.


The Syntax of Color

 

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