This is a special page for the Participants in the State of Utah Lead Risk Assersssor's training held in Salt Lake City, Utah on August 17 & 18, 2000. I promised you a sample copy. Remember, this is the abbreviated Lead Hazard Screen and not the full Risk Assessment Report. This is what I use in Real Estate transactions and it usually accompanies a full Home Inspection. The Clients are always Buyers and they are needed to know the main control measures needed to improve the overall safety. They are generally strapped for cash with all of the other home buying expenses and they cannot afford the full Lead Inspection or the full Risk Assessment. They generally know that they are going to encounter lead and they really just love to spend time on site discussing their future plans.
Sample Lead Hazard Screen I look forward to your feedback and goals for using the LBP information that you have learned.
Questions & Comments:
I wish to apologize to Bob Ford of the publicly for the things which I stated throughout my presentation time at the Lead Based Paint Training. Many of the participants felt that my remarks were out of line and felt that I made him look bad. I apologize for that.
What I wish to be known is that Bob is doing a great job. Bob works for the State of Utah Division of Air Quality and he always attends the official lead trainings. Bob is very professional and he should be considered as the first line of help when we, as Lead Risk Assessor's try to implement the lengthy and somewhat confusing LBP guidelines. Bob does not have ultimate control over the guidelines, but he has a great working knowledge of them. Bob has ALWAYS been very helpful when I have called upon him in the past few years.
The frustrations which were taken as being attacks towards him during the presentation were in fact my own personal frustrations regarding the much bigger FHA/HUD guidelines. These jabs were not at Bob, but at the FHA/HUD beuracratic processes involved in the Lead program decision making. I should have tempered these opinions, but they came through and I apologize for that. I, in no way meant to make Bob Ford look bad. I also did not mean for my opinions to get in the way of the bigger message of which I was called upon present to the class. If my actions and words were offensive to you in any way, please accept my apologies..... Michael Leavitt
The following is a section out of my recent Monday Morning Messenger dealing with Lead in vinyl mini-blinds. The information comes directly from the EPA website and is very valuable for Lead Risk Assessors to archive.....
EDITOR'S NOTE: I am involved with teaching the State of Utah Lead-Based Paint course this week in Salt Lake City and I came upon the comprehensive information regarding lead in the mini-blinds. Regardless of what the CPSC says, these blinds were still being sold in 1998 here in Utah.
HUD Technical Bulletin Issued: August 23, 1996
1. PURPOSE - The purpose of this Bulletin is to provide technical information to HUD staff and HUD program participants on the potential exposure hazard from lead dust that forms on imported, non-glossy, vinyl mini blinds. The Bulletin discusses the recent Consumer Product Safety Commission (CPSC) announcement on this subject, and provides recommended work practices to be followed when removing the blinds from residential units, if property owners decide on removal.
This document is not intended to establish HUD policy on this issue. Interested readers should contact the appropriate HUD office for specific program guidance.
2. SUMMARY - Because of the potential lead exposure hazard, it is advisable that property owners remove imported, non glossy, vinyl mini blinds from units housing or frequented by young children (ages 5 and younger). Testing for lead in the vinyl plastic or in the dust that forms on the blinds is unlikely to be cost-effective, except in limited circumstances. If sampling is conducted, concentrations of less than 200 ppm lead in the vinyl are considered insignificant and surface lead-dust loadings of less than 500 æg lead/ft2 are considered acceptable.
Use safe removal techniques, as described in this Bulletin, when removing blinds.
3. INFORMATION FROM THE CONSUMER PRODUCT SAFETY COMMISSION - Because of the potential lead poisoning hazard, the Consumer Product Safety Commission issued a press release on June 25, 1996 recommending that parents remove imported, non-glossy, vinyl mini blinds in housing units with children ages six and under (see Attachment A). The plastic window blinds have horizontal slats about one inch wide and come in a variety of colors. The blinds are inexpensive products (generally $5 to $10 per set) imported primarily from China, Taiwan, Mexico and Indonesia. Lead was added to the vinyl plastic as a stabilizer. Metal and highly glossy plastic mini blinds are not included in the CPSC warning. The CPSC reported that nonleaded vinyl mini blinds should be available on the market as early as July, 1996.
The potential hazard was brought to CPSC's attention by reports from two States that children had apparently been lead poisoned through contact with dust on mini blinds. CPSC then made its recommendation following confirmation of high lead-dust levels on the surface of used mini blinds. Lead dust, which may not be visible to the naked eye, can form on the surface of the blinds as the vinyl deteriorates from exposure to sunlight and heat. Also, although it appears to occur infrequently, high levels of leaded dust may also occur on new, unused nonglossy, vinyl mini blinds as a byproduct of the manufacturing process.
CPSC has also released a series of "questions and answers" on the topic (see Attachment B). These include the most common questions and concerns addressed to CPSC following release of their original announcement. This should be a useful reference when responding to tenants' questions regarding this potential hazard.
CPSC has advised HUD that wipe sampling of dust on used blinds showed wide variability in the lead content of the dust, with an average lead-dust loading of approximately 1,050 micrograms lead per square foot of blind (æg/ft2). For comparison, HUD's clearance guideline for lead on interior window sills (based on wipe sampling) is 500 æg/ft2 (see HUD Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing, Chapters 5 and 15).
Significant concentrations of lead were detected in samples of the vinyl plastic taken from ALL of the blinds that CPSC examined, both used and new. The average lead concentration of the vinyl was approximately 1.0% by weight (that is, 10,000 parts per million (ppm)), with a range of approximately 0.8% to 1.2%. CPSC did not identify a relationship between the amount of lead in the surface dust on blinds and the lead concentration of the vinyl plastic.
CPSC believes that the variability in the lead content of surface dust on the used blinds is primarily due to the fact that the blinds were exposed to differing amounts of ultraviolet radiation from direct sunlight, which is believed to be the major factor in their deterioration.
It is not expected that chewing or eating the vinyl would normally be a significant source of exposure for children, although this may occur on occasion. Of greatest concern is the potential for young children to be exposed to lead-contaminated dust by mouthing the blinds or touching them and then putting their hands in their mouths.
4. CONCLUSION REGARDING POSSIBLE ACTIONS IN RESPONSE TO THE CPSC RELEASE - If a property owner wants to respond to the CPSC notice, there appear to be two general options: (a) removal of all or some of the blinds, or (b) testing the blinds for lead as a basis for removal decisions. CPSC does not believe that occasional cleaning of the mini blinds is a viable option because it is difficult to completely remove the dust and it would have to be performed periodically (see Attachment B). Another factor arguing against this option is that the cleaner would be at risk of exposure, especially if the blinds were dry-dusted, which should be avoided.
A) Removing the mini blinds
The HUD Office of Lead-Based Paint Abatement and Poisoning Prevention believes that removing the imported, non-glossy mini blinds from housing units is the property owner's best response to this issue. This is a permanent solution to this potential childhood lead exposure hazard. As with any lead hazard control effort, property owners could adopt a priority-based approach in which housing units with children ages 5 and younger would be first targeted for removal, followed by units which may house young children in the future. (Note: Although the CPSC press release defines "young children" as ages 6 and younger, HUD defines the age group at highest risk for lead exposure as ages 5 and younger. HUD adopted this definition, as has EPA, from the U.S. Centers for Disease Control and Prevention (CDC)) Suggested removal procedures are provided in section 5(A) below.
If leaded mini blinds are removed, property owners would have the option of replacing them with relatively inexpensive "non-leaded" mini blinds which should currently be available at retail outlets.
B) Testing mini blinds for Lead Content Before Removal
Testing mini blinds for lead content as a basis for deciding whether to remove them is generally not a cost-effective option, although there may be situations when the owners of multifamily housing complexes that contain a large number of blinds may decide to conduct some testing. The two types of testing that can be used to characterize the lead content of mini blinds include testing of the vinyl plastic for lead concentration and wipe-testing of slats to determine the surface loading of lead dust.
Testing the vinyl plastic for lead concentration: The CPSC has advised HUD that they believe that all imported, non-glossy vinyl mini blinds contain significant amounts of lead. This is based on their own test results as well as discussions with manufacturers. Property owners may decide to test samples from mini blinds if they are unsure if the mini blinds installed in their properties are the leaded variety or if there is a desire to confirm that newly purchased mini blinds have negligible lead content. These questions could be answered by analyzing a small number of plastic samples. The analysis should be conducted by a qualified Analytical laboratory, not by portable XRF analyzer or chemical spot test kits.
Testing surface dust for lead content: Wipe-testing of lead in dust on the surface of mini blinds provides the best indication of the immediate risk posed to young children. However, there are serious disadvantages with this approach. One problem is that blinds found to have low surface lead loading following wipe-testing would need to be retested on a periodic basis, and there is no information regarding the rate at which leaded dust forms on the surface of mini blinds. Another problem is that there appears to be considerable variability in the lead-dust loading on the surface of blinds. Although it is known that certain factors such as amount of direct sunlight and patterns of use are associated with this variability, a thorough study of this subject has not been conducted. Therefore, it is difficult to ensure that a "representative sample" is being collected for the purpose of characterizing lead loading on blinds in a multifamily housing complex.
5. GUIDANCE FOR REMOVING OR TESTING MINI-BLINDS: Following are suggested procedures for the removal or testing of mini blinds.
A) Removing mini blinds From Housing Units
Workers involved in removing blinds are covered under the OSHA General Industry Lead Standard (29 CFR 1910.1025). Workers may also be covered by an applicable State lead regulation. Based on "reasonable worst case" exposure calculations conducted by HUD, it appears very unlikely that the levels of airborne lead associated with the removal procedure (as described below) would reach or exceed the OSHA action level of 30 micrograms lead per cubic meter of air (æg/m3) as an 8-hour time-weighted average; however, employers may decide to conduct exposure monitoring in order to confirm this.
If it is assumed that the action level would not be reached during the removal operation, only basic worker training is required, including instruction in: I) The hazards of lead (as described in Appendix A of the OSHA standard); ii) The requirements of the OSHA General Industry Standard (described in Appendix B of the OSHA standard); and, iii) The work practices associated with the job. The topics that are covered in Appendices A and B of the OSHA General Industry Standard are presented in Attachment C of this Bulletin. Because workers whose only lead exposure is from removing mini blinds would be very unlikely to be exposed to airborne lead above the OSHA action level, employers would not be required to comply with many of the elements of the lead standard (e.g., respiratory protection, medical monitoring, posting signs).
EPA has stated that mini blinds originating from residential housing units (single or multifamily) are exempt from hazardous waste regulations under the Resource Conservation and Recovery Act (RCRA) and can be disposed of as ordinary household waste (memo from G. Helms, EPA Office of solid Waste, to M.F. Toro, CPSC, July 12, 1996). mini blinds originating from nonresidential units, such as offices and day care centers, are not considered household waste, and may have to be disposed of as hazardous waste. (Owners or lessors of nonresidential space should contact EPA or State hazardous waste offices for details).
The following is a brief outline of recommended work practices to be followed in removing previously installed mini blinds:
B) Testing mini blinds Before Taking Further Action
For additional information contact Dr. Peter Ashley in HUD's Office of Lead-Based Paint and Poisoning Prevention at (202) 755-1785, ext. 115.
NEWS from CPSC - U.S. Consumer Product Safety Commission - Office of Information and Public Affairs, Washington, DC 20207
FOR IMMEDIATE RELEASE CONTACT: Kathleen Begala June 25, 1996 .......... (301) 504-0580 Ext. 1193 .......... Release # 96-150
WASHINGTON, D.C. - After testing and analyzing imported vinyl mini blinds, the U.S. Consumer Product Safety Commission (CPSC) has determined that some of these blinds can present a lead poisoning hazard for young children. Twenty-five million non-glossy, vinyl mini blinds that have lead added to stabilize the plastic in the blinds are imported each year from China, Taiwan, Mexico, and Indonesia.
CPSC found that over time the plastic deteriorates from exposure to sunlight and heat to form lead dust on the surface of the blind. The amount of lead dust that formed from the deterioration varied from blind to blind.
In homes where children ages 6 and younger may be present, CPSC recommends that consumers remove these vinyl mini blinds. Young children can ingest lead by wiping their hands on the blinds and then putting their hands in their mouths. Adults and families with older children generally are not at risk because they are not likely to ingest lead dust from the blinds.
Lead poisoning in children is associated with behavioral problems, learning disabilities, hearing problems, and growth retardation. CPSC found that in some blinds, the levels of lead in the dust was so high that a child ingesting dust from less than one square inch of blind a day for about 15 to 30 days could result in blood levels at or above the 10 microgram per deciliter amount CPSC considers dangerous for young children.
"Some of the vinyl blinds had a level of lead in the dust that would not be considered a health hazard, while others had very high levels," said CPSC Chairman Ann Brown. "Since consumers cannot determine the amount of lead in the dust on their blinds, parents with young children should remove these vinyl mini blinds from their homes."
CPSC asked the Window Covering Safety Council, which represents the industry, to immediately change the way it produces vinyl mini blinds by removing the lead in these blinds. Manufacturers have made the change and new mini blinds without added lead should be widely available over the next 90 days.
Stores will sell the new vinyl blinds packaged in cartons indicating that the blinds are made without added lead. The cartons may have labeling such as "new formulation," "nonleaded formula," "no lead added," or "new! non-leaded vinyl formulation." New blinds without lead should sell in the same price range as the old blinds at about $5 to $10 each.
CPSC recommends that consumers with young children remove old vinyl mini blinds from their homes and replace them with new mini blinds made without added lead or with alternative window coverings. Washing the blinds does not prevent the vinyl blinds from deteriorating, which produces lead dust on the surface.
The Arizona and North Carolina Departments of Health first alerted CPSC to the problem of lead in vinyl mini blinds. CPSC tested the imported vinyl mini blinds for lead at its laboratory.
The laboratories of NASA's Goddard Space Flight Center and the Army's Aberdeen Test Center used electron microscope technology to confirm that as the plastic in the blinds deteriorated, dust formed on the surface of the blind slats. This testing also established that the dust came from the blinds and not from another source. CPSC laboratory tests confirmed that this dust contained lead.
"This lead poisoning is mainly a hazard for children ages 6 and younger," said Chairman Brown. "Adults and older children generally are not at risk because they are not likely to ingest lead dust from the blinds."
U.S. CONSUMER PRODUCT SAFETY COMMISSION WASHINGTON, D.C. 20207
Question: Why is the CPSC concerned about lead in vinyl mini blinds?
Response: All non-glossy vinyl mini blinds tested by CPSC contained lead. Some of the non-glossy blinds tested had high levels of lead on the surface. The lead was in the form of a layer of dust that could be easily dislodged and ingested by young children. Children 6 years and under often put their hands in their mouths. If they regularly touch the mini blinds with high levels of lead dust and then put their hands in their mouths, they could develop blood lead levels that have been linked with behavior and learning problems, damage to the brain and nervous system, slowed growth, and hearing problems.
Question: What testing was conducted to support the CPSC's conclusions that some vinyl mini blinds are a lead hazard?
Response: CPSC's Health Sciences Laboratory investigated the potential release of lead from various brands of mini blinds by measuring the amount of lead in the miniblind and the amount of lead available in the dust on the surface of the blind. In some cases, an assessment of the home also was conducted to rule out other likely environmental sources of lead. For some miniblind samples, the investigation also included accelerated aging with ultraviolet light and high temperatures. The accelerated aging attempted to simulate exposure to sunlight to determine whether the vinyl would deteriorate.
Initial testing indicated that non-glossy mini blinds contained lead, but glossy mini blinds did not. This testing was later confirmed by the industry who reported that lead was used as a stabilizer only in non-glossy mini blinds. Reportedly, all of the non-glossy vinyl mini blinds are imported.
CPSC staff then focused its investigation on both "brand new" and "used" imported non-glossy vinyl mini blinds. The used blinds were obtained from consumers; the "new" blinds were purchased at retail stores. The testing indicated that as the plastic deteriorates from exposure to sun and heat, the lead contained in the plastic becomes available for ingestion as dust on the surface of the slats. Further, in homes with no other likely sources of lead, lead dust levels on floors and window sills near the mini blinds with high lead dust levels, were not elevated. This indicated that the likely source of lead on the surface of the slats was from the slats.
Lead dust levels varied from blind to blind. Differences in environmental conditions (exposure to sunlight, heat, etc.) and the chemical composition of the mini blinds probably caused much of the variability in the dust levels.
Further testing at the laboratories of the National Aeronautics and Space Administration and the Army's Aberdeen Proving Grounds using scanning electron microscopy (SEM) supported the findings that non-glossy vinyl blinds deteriorate with age under certain environmental conditions. SEM revealed distinct differences between the new blinds and used blinds. The particles at the surface of the new blinds were largely bound in the vinyl matrix. In contrast, the used blinds showed a greater quantity of loose particles at the surface. Further, because silica (common to dirt and clays) was not found on the surface of used blinds (verbal communication with labs), the testing established that the lead came from the blind and not from another source, such as house dust.
Question: I saw my child touch the mini blinds and then put his/her hands in his/her mouth. Should I take my child to the doctor or hospital?
Response: No, it is not necessary to be alarmed if your child has touched the non-glossy vinyl mini blinds once or even a few times and then put his/her hands in his/her mouth. If you think that the child has done this repeatedly you might want to consult a physician and tell him/her that you suspect your child may have been exposed to lead. The physician will determine what if anything needs to be done. Additionally, we would recommend that you remove the miniblind(s) that your child is able to reach so he/she does not touch them repeatedly.
Question: How does lead get into vinyl mini blinds?
Response: According to the manufacturers, lead has been intentionally added to the non-glossy vinyl as a stabilizer to make the plastic more heat stable, rigid and durable.
Question: Can something other than lead be used as a stabilizer?
Response: Yes, manufacturers of polyvinyl chloride in the United States have been using stabilizers other than lead. Companies have provided CPSC with the names of several stabilizers that are currently being used. A monomethyltin and a dimethyltin being used in mini blinds have been approved by the FDA for use in plastics used for food storage and for the manufacture of pipes intended for contact with water in food processing plants. The two tin stabilizers approved by the FDA for contact with food surfaces were approved based primarily upon the low exposure expected. While there is toxicity associated with the organotins being used as stabilizers, if exposure to these organotins is kept to a minimum, staff believes that use of these stabilizers is acceptable. CPSC staff has indicated to the manufacturers that they are responsible for ensuring the safety of the stabilizers they are using. Staff will continue to monitor the use of these non-lead stabilizers.
Question: Will there still be lead in the vinyl mini blinds once the manufacturers stop using lead stabilizers?
Response: There may be low levels of lead as a contaminant in blinds even after lead is no longer used as a stabilizer. But, these levels should not present a health hazard. For example, when lead was no longer used as an intentional additive in paints, the majority of paints CPSC tested had lead levels less than 0.02%. If manufacturers of mini blinds clean their factories appropriately and follow good manufacturing practices, similarly low lead levels could be achieved.
Question: If children 6 years and under can develop health problems due to exposure to lead from vinyl mini blinds, why is CPSC not recalling all vinyl mini blinds?
Response: CPSC did not recall the blinds because a several factors must exist for there to be a problem: 1) the vinyl mini blinds must have been exposed to sun and heat; 2) the home must have a child six years and under; 3) the mini blinds must be within reach of these children, and 4) the child must gain access to the blinds and ingest enough lead dust for 15-30 days to result in elevated blood lead levels. Because of the variety of factors that must be present for there to be a problem, no recall was sought in this case. To eliminate the possibility of this hazard in the future, companies are changing their formulations.
Question: Why is the Consumer Product Safety Commission not banning the future production of lead-containing vinyl mini blinds or setting a mandatory standard for the amount of lead allowed in vinyl mini blinds?
Response: When the Commission staff became aware of the potential problem of lead in vinyl mini blinds, they called in the industry and the major industry association, the Window Covering Safety Council, an umbrella group representing 90% of the vinyl mini blinds manufacturers. These manufacturers/importers/ retailers have been working with us to solve the problem. They have indicated to us that they have begun to produce a vinyl miniblind with no lead intentionally added. In addition, they have cleaned up their manufacturing plants to minimize the amount of lead present from contamination. These new vinyl mini blinds with no lead stabilizer added started appearing in stores around July 1, 1996. Because companies are discontinuing the use of lead, no standard appears to be needed.
Question: I have children 6 years old and under and have old non-glossy vinyl mini blinds that the children can reach. What should I do? Response: The Commission staff recommends that you remove these vinyl mini blinds from your windows and dispose of them.
Question: How can I dispose of my vinyl mini blinds?
Response: You can discard non-glossy vinyl mini blinds from residences with your regular trash. Make sure that when you dispose of the blinds they are not readily accessible to young children.
Question: Do consumers who remove vinyl mini blinds with lead need to wash their window sills and surrounding areas?
Response: The Commission staff does not believe that the dust on the blinds will become airborne during removal. However, during removal, it is possible that some of the dust might wipe off on the window sill or other areas of the window area that might be accessible to young children. If consumers are concerned, they could wet wipe the sills and accessible parts of the frame with a general purpose household cleaner.
Question: Instead of disposing of my vinyl mini blinds, can I just wash the lead containing surface dust off them on a regular basis?
Response: No. Even with vigorous scrubbing, you probably will be unable to remove all the lead containing dust. In addition, deterioration of the vinyl miniblind will continue. The rate of deterioration depends upon the amount of heat and sun to which the blind is exposed as well as its chemical composition. We cannot tell you what this rate is and how often you would have to clean your blinds. That is why, if you have children 6 years and under and the blinds are within their reach, the safest thing to do is to remove them and throw them away.
Question: Can I vacuum the lead dust off the miniblind?
Response: No. Vacuuming the dust will probably not remove all of the lead dust. In addition, the deterioration of the non-glossy vinyl miniblind will continue. The rate of deterioration depends upon the amount of heat and sun to which the blind is exposed as well as its chemical composition. CPSC staff cannot tell you what this rate is and how often you would have to vacuum your blinds to insure that the dust level was kept to a minimum. If you have children 6 years and under and the blinds are within their reach, the safest thing to do is remove them.
Question: Are adults and older children still exposed to the lead dust by inhalation even though they don't ingest the lead dust?
Response: CPSC staff believes that the surface lead containing dust from the deteriorating vinyl does not become airborne and is not inhaled by people in the household. In homes with no other likely sources of lead, lead dust levels on floors and window sills near the mini blinds with high lead dust levels, were not elevated.
Question: Were/are any vinyl mini blinds made without lead?
Response: To the best of our knowledge, lead was not and is not used as a stabilizer in glossy mini blinds, only in non-glossy mini blinds. Non-glossy vinyl mini blinds made without the intentional addition of lead began appearing on the shelves of retail stores around July 1, 1996. The packaging of these blinds should bear labeling such as "New Formulation," "non-leaded formula," "no lead added," or New! Non-leaded vinyl formulation" or in some other way convey the message that they were made without the lead stabilizer.
Question: How can I tell if my mini blinds are old or deteriorating?
Response: Unfortunately there is no easy way to tell if your mini blinds are old or deteriorating. Some old, deteriorating mini blinds look no different from brand new mini blinds.
Question: Can I use a lead test kit to determine whether my mini blinds pose a hazard?
Response: The Commission staff does not recommend the use of lead test kits to test mini blinds. Tests on paint conducted in the Commissions's laboratory indicated that lead test kits did not accurately discriminate between lead and non-lead based paints. In addition, lead test kits were not designed to measure lead in plastic.
Question: Was any color more hazardous than others?
Response: No, the lead in mini blinds was unrelated to color.
Question: Are metal mini blinds safer?
Response: We are presently not aware of any lead hazards from metal mini blinds.
Question: Should I be concerned about lead in other vinyl products?
Response: The Commission staff is looking at the potential of lead release from other vinyl consumer products normally exposed to sun and heat.
Question: My child has an elevated blood lead level and lives in a house with these mini blinds. Do I need to report this case to you? Do you want the mini blinds?
Response: No, it is not necessary to report cases to the CPSC. You should follow the recommendations of your state or local health department, local poisoning prevention program or personal physician. This would include removing non-glossy vinyl mini blinds if they are accessible to your young child.
Question: What is the difference between vinyl, polyvinyl chloride (PVC) and plastic?
Response: For the purposes of the discussion of lead in vinyl mini blinds, the terms vinyl and polyvinyl chloride are used interchangeably. Polyvinyl chloride is a type of plastic.
Question: Do the blinds pose a special hazard for pregnant women?
Response: While maternal exposure to lead and low blood lead levels measured in umbilical cord blood have been associated with deficits in cognitive test performance and neuromotor performance in children, staff do not believe that these mini blinds pose a special hazard for pregnant women. The hazard posed by mini blinds is the result of ingesting the dust containing lead that forms on the surface of the blinds as they degrade, not from an inhalation hazard. Staff believes that the hazard posed by mini blinds containing lead as a stabilizer is an ingestion hazard, especially for young children who typically exhibit hand-to-mouth behavior. This is generally not a problem for adults and older children who are not expected to touch the blinds with their hands and then put their hands in their mouths.
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