This Nerf Super Soaker XP20 water gun (sold at Target) was recalled — but BABY BOTTLES with greater Lead levels were NOT. Why?

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For those new to this website:

Tamara Rubin is a multiple-Federal-award-winning independent advocate for childhood Lead poisoning prevention and consumer goods safety, and a documentary filmmaker. She is also a mother of Lead-poisoned children (two of her sons were acutely Lead-poisoned in 2005). Since 2009, Tamara has been using XRF technology (a scientific method used by the U.S. Consumer Product Safety Commission) to test consumer goods for toxicants (specifically heavy metals — including Lead, Cadmium, Mercury, Antimony, and Arsenic). All test results reported on this website are science-based, accurate, and replicable. Items are tested multiple times to confirm the test results for each component tested. Tamara’s work was featured in Consumer Reports Magazine in February of 2023 (March 2023 print edition).

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“Brown paper packages tied up with string — these are a few of my favorite things!”

Well, I got the neatest package in the mail recently, sent from Florida. An environmentally-hip reader of the website sent me a toy she knew I was really hoping for this holiday (the first clue it was sent by a fellow environmentalist was it being in a reused cardboard box). When I opened the box, inside was (literally!) a package wrapped in brown paper and tied up with (a brown natural fiber) string. I wish I had taken a picture before I opened it — but I was too curious and excited and tore the string right off, opening up the paper! Inside was the recalled Nerf XP20 Super Soaker water gun (sold exclusively at Target)!

I had written about this toy earlier this summer.

When the toy was recalled this summer (and when I wrote this original article and shared it with my readers), I told my readers that I wanted to have the opportunity to test one of these myself. I was really curious as to what the actual XRF-detectable levels of Lead were in the recalled component. Specifically, the toy was recalled because of a sticker (with the logo/branding/product name) — that tested positive for unsafe levels of Lead and I wanted to see for myself how much Lead was in these stickers.

I had never had the opportunity before to do extensive testing on a product that was recalled (at least not in a situation where my work didn’t initiate or contribute to the recall in question) and the news stories and CPSC recall press releases never seem to include any actual data — such as specific detected Lead levels from which one could infer how much an item has to exceed the regulatory limits for the CPSC to determine that it warrants an enforcement action such as a recall. So I was really curious to discover how much Lead actually prompted a recall, in this case!

Why this recall makes me furious (it’s not why you would expect)!

I was furious to learn about this recall — given the “only” component that tested positive was the exterior logo marking/sticker — but not for the reason anyone might imagine; the reason I was furious was because over the past several years, I have tested no fewer than five INFANT-FEEDING PRODUCTS that have all also been positive for unsafe levels of Lead — Lead also found “only” in the logo/branding markings on the outside of the product (like with this Nerf gun). Yet none of which has been recalled — or even deemed worthy of a mention by any news agency!

These glass BABY BOTTLES and reusable glass BABY FOOD STORAGE JARS (as well as some stainless options also with high Lead levels in different components) WERE SOMEHOW EVIDENTLY NOT DEEMED TOXIC ENOUGH TO WARRANT A RECALL! But a Nerf gun was? This made no sense. 

Why? Why weren’t these Leaded baby feeding products recalled?

My understanding is that the argumentation (used by the CPSC and the manufacturers that left them choosing NOT to issue any kind of official recall for these baby-feeding products) was that the amount of Lead found in the infant and child-feeding products in question was not considered “enough Lead” in relation to the total overall weight of the product — simply because the paint on the outside of the glass was not considered to technically/legally constitute a “separate component” of the product (and was measured instead as part of the glass, diluting the ppm reading to a number they considered insignificant).

This was apparently also the case with the stainless steel baby bottles and kid-centric stainless food containers; the nearly solid-Lead sealing dot in the base of these items was also not considered a “separate component” of the product, and as such, no recall was initiated.

With the recalled Nerf Super Soaker, the logo/branding sticker on the outside of the recalled water gun is (somehow) considered a separate component (because it is a sticker and not paint?), and so a recall was determined to be necessary. 

But wait, there’s more … it gets more unbelievably ridiculous.

Not only were these baby feeding products not recalled, the amount of Lead in the logo markings of EACH and EVERY ONE of these glass baby feeding products turned out to be considerably higher than the amount of Lead found in the logo/ brand marking sticker on this NERF brand Super Soaker water gun that was recalled! 

On any logical, rational — let alone ethical — basis, this simply makes no sense, and I call “BULLSHIT!”

Here is a comparison of the test results (each is a link to the article for that item):

1. Nerf Super Soaker XP20 Water Gun (2020):  2,761 ppm Lead — RECALLED
2. Green Sprouts glass sippy cup (c. 2016/2017): 3003 ppm Lead — no recall
3. Jervis & George glass baby food jars (c. 2018): 5,732 ppm Lead — no recall
4. Jervis & George glass baby food jars (c. 2019): 6,422 ppm Lead — no recall
5. Glass Nuk baby bottle (c. 2018): 19,900 ppm Lead — no recall
6. Hevea glass baby bottle (c. 2017/2018): 27,000 ppm Lead — no recall

Also of concern (but not an outside logo marking)

1. Made Safe Certified Pura Kiki Insulated Stainless Baby Bottle (c. 2016/2017/2018): near solid Lead sealing dot under bottom cap — no recall
2. Paulie Jar insulated food container for children (2020) — near solid Lead sealing dot under the bottom cap — no recall

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Continue reading below the images of the products in question.

To me, this is a clear sign that the world of children’s product regulation is simply broken!

If a toy water gun can be recalled — ostensibly because a component that a child can touch and interact with tests positive for 2,761 ppm Lead, it truly makes no sense that BABY BOTTLES testing positive for Lead in the range of 3,003 to 27,000 ppm Lead (in a similar way — in the EXTERIOR PAINTED MARKINGS that an infant can and WILL touch, hold, lick, suck, etc.) are not recalled.

It also seems to me to rise to the realm of some criminal negligence that these baby bottle manufacturers (and baby food container manufacturers) are not REQUIRED to issue a very visible public statement about the Lead levels found in their baby feeding products.

INSTEAD, after being notified about the findings of Lead in their products (by me personally or by my readers), they are allowed — somehow — to just relatively silently change their formulations and “move on” to making Lead-free products (an action some manufacturers, but not all, have taken).

These companies have faced no government sanctions or actions. However, a more egregious consideration: they have not even been required to notify ANYONE WHO PREVIOUSLY PURCHASED ONE OF THESE DURABLE GOODS TO USE TO FEED THEIR CHILDREN that these products were positive for high levels of Lead.

What this means is:

• These Leaded products likely STILL EXIST in people’s homes,
• Many of the original owners of these products are not at all aware of the concerns,
• These toxic products (documented to have unsafe levels of Lead in their paint, coatings, or other components) have perhaps been handed down to other unsuspecting families to use with their children (families who are unaware of the consequences of potential trace Lead exposure to their children possible as a result of using these products).

The system is simply broken.

It is for this reason I urge YOU to please share this article. We NEED to get the word out to parents of young children because clearly — incredibly — NO ONE ELSE IS GOING TO DO IT.

For those looking for safer baby bottle and sippy cup choices, here is my overview article covering most of the brands I have tested.

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To see the full XRF test results for the recalled water gun (pictured), continue reading below.

When tested with an XRF instrument, the Nerf Super Soaker XP20 sold exclusively at Target and recalled in August 2020 for unsafe levels of Lead, had the following readings:

Focus on the yellow orb (circle? sun?) of the sticker:
60-second test in consumer goods mode

• Lead (Pb): 2,761 +/- 118 ppm
• Chromium (Cr): 4,865 +/- 780 ppm
• Silver (Ag): 27 +/- 6 ppm
• Nb: 2,331 +/- 75 ppm
• Palladium (Pd): 14 +/- 5 ppm
• Platinum (Pt): 525 +/- 98 ppm
• Zinc (Zn): 50 +/- 25 ppm
• Copper (Cu): 308 +/- 65 ppm
• Iron (Fe): 701 +/- 189 ppm
• Indium (In): 43 +/- 12 ppm
• Titanium (Ti): 132,300 +/ 5,300 ppm

Other colored areas of the sticker were tested, and Lead was not found to be present in those colors of the ink. Other yellow areas were also tested and concluded with similar results.

As always, thank you for reading and for sharing our work. Please let me know if you have any questions and I will do my best to answer them personally as soon as I have a moment (but that may be a while because I have had children underfoot with no childcare since the start of the pandemic in March of 2020!). If you would like to make a contribution in support of our independent consumer goods testing and childhood Lead poisoning prevention advocacy work, you can read more about that here.

Tamara Rubin
#LeadSafeMama