Labeling of Hazardous Art Materials Act (LHAMA; ASTM D-4236) Evaluation

Intertek’s board-certified toxicologists provide LHAMA evaluations in compliance with ASTM D-4236 for a wide range of art materials marketed in the United States.

If you are marketing art materials in the United States (U.S.), your products may need to comply with the Labeling of Hazardous Art Materials Act (LHAMA). Intertek’s board-certified toxicologists provide LHAMA evaluations in compliance with American Society for Testing and Materials (ASTM) designated D 4236 (ASTM D-4236) for a wide range of art materials marketed in the U.S.

The LHAMA regulations require that art materials be evaluated for potential to cause chronic hazards to the consumer, and suitable warning statements must be included on the label to conform to the ASTM D-4236 The reviewed materials can be labeled with “Conforms to ASTM D-4236”.

Intertek’s board-certified toxicologists review the products and specify the appropriate chronic hazard statements, as needed. Intertek can also suggest other labeling phrases, warnings and warning symbols that may be necessary on the package of the product outside the scope of LHAMA requirements (e.g., California Proposition 65). Upon request, Intertek can also evaluate the art material formulations for compliance with other regulations including the Federal Hazardous Substances Act (FHSA) (16 CFR Part 1500) and/or the Consumer Chemicals and Containers Regulations (CCCR) (SOR /2001-269) should products also be marketed in Canada.

What do our LHAMA services include?

Evaluation of the chronic toxicity of the individual chemical ingredients of the formulation used to manufacture the product:
- Each ingredient is assessed for its chronic hazard potential including carcinogenicity, neurotoxicity, reproductive and developmental toxicity, sensitization, and general organ and tissue toxicities in relation to the potential for consumer exposure to the chemical
- Potential for synergistic or unpredictable adverse effects from the combination of ingredients is considered

Exposure considerations:
- Oral, dermal, inhalation, eye contact exposures, as applicable
- Characteristics of the product such as physical form, size/volume, and accessibility
- Intended use and age of user
- Normal use and reasonably foreseeable misuse

All art material formulations are reviewed by experts certified by the American Board of Toxicology
CPSC labeling requirements (16 CFR §1500.14; 57 FR 46626)
ASTM D-4236 (LHAMA certification)

What Products require LHAMA certification?

LHAMA evaluations would apply to art materials marketed in the United States. Products include (but are not limited to):

Crayons,
Paints including watercolor disks
Inks (marker, pen, highlighter)
Chalk
Colored pencils
Clays
Ceramics
Craft products
DIY kits
Adhesives and glues

Our experts can review your product lines and determine if a LHAMA evaluation is needed for your products.

Frequently Asked Questions

16 CFR 1500.14, which is the legal LHAMA regulations, does not include the requirement for a seal on art products. Our services provide the required information for products to conform to ASTM D-4236. Our LHAMA reports will include the required language needed on the product label.

Products may require re-evaluation if any major formulation changes occur. Otherwise, products need to be evaluated every 5 years by a board-certified toxicologist. This is to account for any new toxicological data that may impact the requirement for warnings on the product label. Staying up to date on certification helps ensure a seamless process of keeping products on the market.

Although ASTM D-4236 is required for all art products sold in the United States, there are some exemptions. Tools and implements used to create art such as brushes or chisels do not require LHAMA certification. In addition, products that are not intended to create art, such as single pens not marketed as art materials may be exempt. Our expert team can evaluate your product lines to determine if any require a LHAMA evaluation.