Health Committee on May 28th, 2009

[The Chair, Conservative, Joy Smith]

Good afternoon, ladies and gentlemen.

Welcome to our guests, our presenters, today. We're very, very happy to have you here today. We are going to listen to our witnesses and each group will have seven minutes per organization

We have the Brain Injury Association of Canada here, with Richard Kinar and Harry Zarins. Hi, Harry, nice to see you again.

We also have the Canadian Association of Fire Chiefs, with Kim Ayotte and Vicky Roper; and there is the Canadian Association of Speech-Language Pathologists and Audiologists, with Ondina Love—a beautiful name—and Chantal Kealey. Welcome to you.

Also, we have the Canadian Consumer Specialty Products Association, Shannon Coombs, the president; and from McGill University, Joe Schwarcz, director of the Office for Science and Society.

We will start with the Brain Injury Association. You have seven minutes. We're going to hear from each of the organizations, and then we'll go into a round of questions following that.

Mr. Kinar, please go ahead.

[Richard Kinar, Board Member, Preventable Injuries and Health Safety, Brain Injury Association of Canada]

Thank you so much.

I'm a little intimidated by the group I am talking to here, but I'd like to give you some history, because it references back to the Hazardous Products Act and the new bill that is proposed, and perhaps tell you about our frustration in trying to access a consumer product that we feel should have been covered under the old HPA. And reading through the new act, we wonder if you can actually get something through in a reasonable length of time.

If you consider that injury is a leading killer and disabler of our children, and that head injury is the leading killer of males under the age of 35, and that any injury prevention strategy talked about in this country incorporates the use of sport helmets, we are unable to reference a standard in Canada for most of these helmets. We've developed the world's best standards with the Canadian Standards Association. These have gone through a certification process, but they are now just sitting in limbo.

Looking at the old HPA, and considering that we've worked for a couple of years to have this new standard covered under the HPA, we're just concerned about any new amendments that don't address the need for a speedy resolution of particular things, such as the leading killer and disabler of our children. It truly is an important health issue, and we would like to be able to address it in some way. We're just frustrated with the process and wanted to be able to talk about that, when we have such an important health issue here.

[The Chair, Conservative, Joy Smith]

Is that your presentation, Mr. Kinar?

[Richard Kinar]

I think so, yes. Truly, we feel that perhaps there hasn't been enough consultation on the new part. That was our concern, just how we access it and get a speedy resolution to important health issues under the act.

[The Chair, Conservative, Joy Smith]

That's very good. Thank you for your comments. When we have questions and answers, you'll have an opportunity to expand on that as well.

We'll hear from the Canadian Association of Fire Chiefs, the deputy chief in the Ottawa region, Mr. Ayotte.

[Kim Ayotte, Deputy Chief, Ottawa Region, Canadian Association of Fire Chiefs]

Thank you, Madam Chair.

My name is Kim Ayotte, and I am a chief officer with Ottawa Fire Services. I am here today, however, representing the Canadian Association of Fire Chiefs, the government relations committee.

The CAFC counts as its members over 1,000 fire chiefs located in every province and territory. Overwhelmingly, like me, its members are municipal public servants with the mandate of protecting the lives and property of citizens of the various communities. Within our membership, we also have fire chiefs from industry; airports; other institutions, such as universities and hospitals; armed forces; and many of the country's first nations. No other association can claim this breadth of support, making CAFC truly the voice of fire services in Canada.

The throne speech of October 2007 contained the following statement that was most welcome to Canadian fire services:

Our Government shares the concern of parents about the safety of consumer products and food. Canadians should expect the same standards of quality from imported goods as they do from products made at home. The Government will introduce measures on food and product safety to ensure that families have confidence in the quality and safety of what they buy.

The CAFC stated its support for the throne speech announcement. It supported Bill C-52 and it supports Bill C-6. The primary reason for our strong endorsement of Bill C-6 is stated in our brief, which I'd like to state for the record today.

A significant percentage of responses for every fire department has important consumer product safety implications. Stovetop fires, electrical fires, electrocutions, accidental poisonings, strangulations, and the careless use of candles as well as matches and lighters are a few examples in this regard.

Special mention, however, should be made for the increasing use of chemical compositions in residential furnishings and clothing. Our submission points out that counterfeiting is a serious consumer product safety problem. The use of counterfeit certification marks enables unsafe and deficient products to gain widespread access to the market, and are a direct risk to consumers.

In addition, we are deeply concerned about the vast quantities of cigarettes being imported into this country that do not meet the low ignition propensity standards that CAFC, Health Canada, and the standing committee worked diligently and cooperatively to enact. These illegal cigarettes are far more likely to remain ignited when unattended, and are therefore products that not only threaten the consumers of such cigarettes; they also jeopardize innocent third parties.

Clauses 6 through 9 of Bill C-6 require that no person shall manufacture, import, advertise, or sell a consumer product that is a danger to human health and safety. The CAFC believes the Canada Consumer Product Safety Act will be useful in combatting counterfeit products and illegal products that are currently available to Canadians.

Some submissions that have been presented to the standing committee call for amendments to Bill C-6. To the degree that these amendments are being offered with a view to improving these provisions, they are welcomed by the Canadian Association of Fire Chiefs. However, to the degree that they will weaken the bill, and are intended to unnecessarily delay its implementation, we trust that the standing committee will not support them.

Officials at Health Canada and the members of the standing committee are all to be congratulated when it's considered how far we have come towards improving consumer product safety since October of 2007.

On behalf of our association, I want you to know that I truly appreciate the opportunity you've given me to speak here today. I look forward to receiving your questions.

Thank you.

[The Chair, Conservative, Joy Smith]

Thank you very much for your presentation. It's very appreciated and insightful.

I will now go to the Canadian Association of Speech-Language Pathologists and Audiologists, to Ms. Love.

[Ondina Love, Executive Director, Canadian Association of Speech-Language Pathologists and Audiologists]

Thanks very much for the invitation to be here. Joining me today is Dr. Chantal Kealey. She is the director of audiology with CASLPA.

First, I'd like to explain a little bit about what CASLPA is, our 5,400 members across the country, and what they do. CASLPA is the only national body that supports and represents the professional needs of speech language pathologists, audiologists, and supportive personnel. In doing so, we support our members in maximizing the communication and hearing potential of the people of Canada. Prevention is a key role in this regard.

I think it's worth highlighting the role of audiologists. Audiologists are hearing health professionals who identify, diagnose, and manage individuals with peripheral or central hearing loss, tinnitus, and balance disorders. Audiologists, speech language pathologists, and supportive personnel play an active role in promoting hearing health and in encouraging government policy to ensure that Canadians don't needlessly suffer from permanent hearing damage.

As part of this, CASLPA audiologists have paid particular attention to the hearing health of children, especially as it relates to the safety of children's toys. CASLPA firmly believes that with Bill C-6 the government is moving in the right direction to ensure that the products we have in our homes are safe. It does so by placing an onus on manufacturers to ensure that their products are safe and by giving government the power and capacity to make sure this happens.

Putting the onus on industry to ensure product safety is a welcome change from the status quo and helps to encourage a culture of safety for those who make and sell goods to people in Canada. Giving the minister power to order safety tests on products and, when needed, mandatory recalls ensures that the government is able to respond quickly when problems do arise. Doubling the number of inspectors--the eyes and ears of consumer safety legislation--increases the government's ability to anticipate and respond to consumer product issues.

In short, CASLPA firmly believes that Bill C-6 is a step in the right direction for consumer product safety, but there are other steps to take specifically as this relates to children's toys. Absent from Bill C-6 is a commitment to reduce the acceptable decibel level for toys from the current 100 decibels to a level more in line with international standards, such as the World Health Organization standard of 75 decibels.

Choking hazards and lead in toys may be more apparent dangers to the public. The danger of noisy toys is often trivialized or dismissed as just annoying to parents, but the danger these toys pose is very real and can cause permanent hearing damage.

On this issue, there are two important considerations: how the amount of permissible noise is measured and how much noise is actually safe for children's small ear canals. Currently, schedule I of the Hazardous Products Act limits the amount of noise children's toys can make to 100 decibels, measured at arm's length. This is markedly higher than the 75 decibels suggested by the WHO. Also, the International Organization for Standardization has recommended that close-to-the-ear toys not exceed 65 decibels.

As a contrast, in a workplace, exposure to 100 decibels would only be considered safe for 15 minutes, and that's for adults. Children, because of their smaller ear canals, are more susceptible to the effects of noise.

What's more, how government currently measures a toy's sound often underestimates its actual effect. As mentioned, currently sound is measured at arm's length. It is no secret that during the routine course of play children will hold toys substantially closer than that, increasing the toy's relative noise and its risk of permanently damaging hearing. Since government cannot mandate how children play with toys, current testing protocols must be revised to reflect actual play situations.

Through Bill C-6, the government has shown a firm commitment to improving Canada's consumer product safety, requiring manufacturers and suppliers to ensure their products' safety while giving the government the tools needed to ensure accountability. This work is to be commended.

It is important that government extend the same effort to help protect the auditory health of children in Canada by further limiting the decibel level of noisy toys to the WHO level of 75 decibels, as echoed in another important piece of legislation, Bill C-357. It should also improve the method by which this level is measured. Under current standards, the amount of allowable noise of a child's toy would be considered a workplace health hazard, even at moderate exposure.

Given the irreversible nature of hearing damage from noise exposure, it is important that government seize the opportunity of this legislation to include a safer noise standard for children's toys. CASLPA members have seen at first hand the hearing, speech, and language implications that can arise from hearing loss due to unacceptable noise conditions.

Thank you. I look forward to your questions.

[The Chair, Conservative, Joy Smith]

Thank you for your presentation. It's very much appreciated.

We're now going to go to the Canadian Consumer Specialty Products Association. We'll hear from Shannon Coombs.

[Shannon Coombs, President, Canadian Consumer Specialty Products Association]

Thank you.

Good afternoon, Madam Chair and honourable members of the committee. It is a pleasure to be here today to provide an overview of CCSPA's suggestions to improve Bill C-6, the Canada Consumer Product Safety Act. I have to say that it's a bit of a tongue twister for me, as our acronym is CCSPA.

My name is Shannon Coombs and I am the president of the CCSPA. I have proudly represented this industry for 10 years. Our accomplishments as a proactive and responsible industry will be clearly visible as I make my presentation.

We are a national trade association that represents 45 member companies across Canada. Collectively, we are a $20-billion industry employing 12,000 people in over 100 facilities. Our companies manufacture, process, package, and distribute consumer, industrial, and institutional specialty products such as soaps, detergents, domestic pest control products, aerosols, hard-surface disinfectants, deodorizers, and automotive chemicals. I have provided the clerk with copies of our one-pager, which has a picture of our products, and I'm sure many of you use them every day.

Why are we here? The health and safety of Canadians is a priority for all CCSPA members and we support this legislation. Our member companies are leaders in the responsible use of chemicals for consumer and institutional products in this country. We are committed to the appropriate and safe use of our products.

Over the past year, we have announced various exciting initiatives, such as the “William, Won't You Wash Your Hands?” initiative, which all of you would have received a copy of a few weeks ago and which we asked you to donate to your local day care or child care facility. That was a partnership with the Public Health Agency of Canada as well as the Canadian Institute of Child Health.

We also announced the voluntary lowering of phosphorus in automatic dishwasher detergent. As well, we have a “Concentrate on the Future” initiative, which is a communication initiative for consumers. I'm sure many of you have seen the 2X or 3X that is now on your laundry or bleach products.

As well, last April, we announced a voluntary ingredient communication initiative that is going to allow companies the ability to disclose all of their ingredients on product labels or members' websites. The great feature of the program is the ability to do this on the website, as it allows companies to explain the benefits and the chemistry behind the products. The program is effective January 1, 2010, and it will cover air care products, automotive and cleaning products, and polishes and floor maintenance products.

Are our member companies' ingredients in products regulated? Yes, they are. Canadians can be confident that the products are safe and that the products they purchase have had various levels of government review and oversight. That oversight depends on the type of product.

In Canada, all substances and products such as laundry powder and liquids, fabric softeners, and dishwashing liquids have had either a new substance notification review or an existing substance review under CEPA and under the chemicals management plan. If any of those consumer products make a claim such as “kills 99.9% of germs”, for example, they're also regulated under the Food and Drugs Act.

As well, the labels on our products are regulated by the consumer chemicals and containers regulations, based under the Hazardous Products Act, which now will fall under Bill C-6. The foundation of that regulation is science. It's a hazard classification, but it provides risk communication to consumers. It has provided precautionary labelling for consumers for the last 39 years. It was just modernized, in 2001, and continues to be an excellent regulatory tool for communicating to Canadians. Elements of CCCR-2001 extend to other products such as food and domestic pest control products.

Our disinfectants are regulated by Health Canada. They have a pre-market assessment and, as with any kind of new substance, review under CEPA as well.

Given the diversity of products, we are subject to various laws and regulations such as CEPA, the Pest Control Products Act, and the Food and Drugs Act. Therefore, we believe that our experience is most beneficial to the committee, as we have been actively involved in the modernization of all these pieces of legislation.

We are seeking two additional clauses for Bill C-6, which include provisions for hoaxes and a provision for a ministerial advisory council. Both amendments would enhance the legislation.

Why? In our experience, a minister's advisory council, such as the one that exists currently under the Pest Control Products Act, and which I'm a member of, is a valuable tool for exchanging information and providing constructive feedback to the minister and the department to help shape and form current and future policies and regulations.

Given the three-pronged approach outlined by the officials--active prevention, targeted oversight, and rapid response--an advisory council could be only another effective tool to the minister and the department for implementing Bill C-6. We believe it would enhance outcomes and actions of Health Canada.

Why a provision for hoaxes? We believe that people should be accountable for information or misinformation they provide about consumer products and their ingredients. The provision for hoaxes is borrowed from the legislation that was tabled last April in Bill C-51, the amendments to the Food and Drugs Act.

Clearly the government believes there is a problem and they need the authority to take action on Food and Drugs Act products, as it was included in this proposed legislation. Therefore, in the spirit of consistency with other Health Canada legislation, Bill C-6 would be strengthened by providing the government with the authority to deal with people who deliberately seek to mislead consumers on these products as well. The goal should be that consumers have the information they need to make balanced and well-informed choices. Fear should not be allowed to be a marketing tool.

We respectfully request that the committee consider these two additions to the proposed law. We have provided some other minor amendments, such as a consistent precautionary statement in the preamble that would be consistent with CEPA and the Pest Control Products Act, plus some other housekeeping items.

I would like to touch on the issue of labelling, as it was raised here at committee during testimony today. I don't believe there has been enough information, or enough factual information, provided to the honourable members from the department on current regulatory authorities for labelling in this country; nor do I believe the information provided in previous testimony to be complete.

Is additional precautionary labelling warranted, and does it need to be included in this bill? As I stated in my opening remarks, labels on consumer products that contain substances are regulated by CCCR. The regulations are science-based, and they include risk communication. Canadians have been using this system for 39 years. Children are even taught to identify the symbols as early as junior kindergarten. What would be achieved by adding another labelling provision to this act?

Canadians are protected by CCCR. Including an amendment in this legislation for labelling of carcinogens; offering up a California Proposition 65 system; using a straight list-based system, such as using substances listed on schedule 1 of CEPA or IARC; even using the building blocks of GHS--we do not believe these meet the needs of Canadians.

CCSPA supports the consumer's right to know, the right to meaningful information, and the right to accurate information. Do any of those systems provide balanced information to the consumer? How would the government even enforce such a law?

In our opinion, by having parliamentarians amend Bill C-6 to include additional labelling, it would effectively be creating a loophole that would have two negative outcomes--one, the sale of unsafe products; and two, misleading claims on safe products.

Why would there be unsafe products? If a product bears a warning statement or a symbol, then consumers have been duly warned; therefore, where is the accountability? Canadians have public policy and legislative frameworks based on risk. This is not the American system of buyer beware. If a product is unsafe, the Canadian government should take it off the market--period. Why would we put forward an act that allows the government to take action via the general prohibition on unsafe products but allows unsafe products on the market to be sold as long as they're labelled?

Why would there be misleading claims? A system that penalizes ethical companies—my member companies—whose businesses are founded on consumer product confidence, and whose products are safe and do not cause cancer.... They will be forced to be put on their products a misleading claim, because a symbol of “C” on sunscreen or hand sanitizers is not accurate, as the end product is safe, even though they contain IARC-listed substances.

Right now Health Canada does not allow companies to make a claim unless it's true--for example, the level of calcium or vitamin C in products. Therefore, why would government force companies to put a “C” on a label for a product that is not a carcinogen?

If a new labelling amendment does go forward, what will we end up with? We'll end up with chaos in the marketplace and consumer confusion, asking moms to make decisions and do their own risk assessments at the retail level; an ineffective law that can't be enforced; flourishing allegations and lawsuits that waste taxpayers' dollars, exactly as has happened in California; companies forced to overlabel; and barriers to trade. I think we would agree that this is not where we want to be.

I offer these comments to you today as a way of continuing and informing this important debate. If the honourable members are contemplating a substantial change to our risk-based society, then the facts all need to be on the table.

In our opinion, Bill C-6 is a modern piece of legislation that allows this government to take an aggressive and responsive approach to protecting Canadians. It has mandatory recall provisions, incident reporting, a general prohibition to take action on products, and fines. The labelling discussion should not detract us from our collective goal, which is to pass this piece of legislation.

I would be most pleased to answer any questions that the committee has.

[The Chair, Conservative, Joy Smith]

Thank you very much.

We'll now go to Joe Schwarcz, from McGill University.

[Dr. Joe Schwarcz, Director, Office for Science and Society, McGill University]

Thank you very much for the invitation to address the group.

I direct McGill University's Office for Science and Society, which is a rather unique enterprise in Canada, and probably in the world. It's the first time any major university--depending on which ranking you look at in the world, we're anywhere from number 12 to 17--has said that our job is not over the moment our students leave our gates; that today there is tremendous hunger out there for scientific information, and if the hunger is not fulfilled in a proper, reliable, scientific fashion, then people will end up listening to whoever is standing on the tallest soapbox yelling the loudest, usually the charlatans.

Our goal, then, is to demystify science for the public, to make sure that we separate sense from nonsense, and to foster critical thinking. If all that works, we thus try to keep them out of the clutches of charlatans.

Through my office and through my radio shows and TV appearances, I think I have my finger on the pulse of the public. What I detect is a tremendous amount of worry out there. People are worried about microwave ovens, they're worried about cell phones, they're worried about asbestos, and they're worried about formaldehyde. It depends on which day; every day there seems to be some new worry that arises.

The word “chemical”, unfortunately, rears its head, and it has become a dirty word. In the popular press, it's almost always preceded by a pejorative adjective--“dangerous”, “toxic”, or “poisonous”. There isn't the public realization that everything in the world is made of chemicals. They're not good or bad. They don't make decisions. We make decisions.

The chemical world is tremendously complex. Since the end of the Second World War, we've introduced some 80,000 synthetic chemicals into the marketplace to go along with the hundreds of thousands of naturally occurring compounds.

The human body makes no distinction between synthetic and natural in the way that we detoxify these substances. Therefore, there should be no need to make any distinction on any kind of label about synthetic or natural toxins.

The word “carcinogen” is a very loaded word, and it's a very frightening word for most people. They don't realize what it really means. Technically, the definition of a carcinogen is that it is a substance that in any animal, in any dose, causes any sort of cancer. It does not mean that is known to be a human carcinogen.

Formaldehyde is listed as a carcinogen. Indeed, there are studies that show that people who are exposed to high levels of formaldehyde in the occupational environment are more prone to certain cancers. This has no bearing on the trace amounts of formaldehyde that may be used as a preservative in a shampoo.

Our allegiance through my office is solely to the scientific method and to peer-reviewed literature. We take no funding from any interest whatsoever. It is totally funded by the university. To me personally, it really makes no difference whether BPA is banned or not, or castigated, or made into an angel. The only thing I want is to abide by the scientific method.

I'll just point out a few curiosities. Much of what we know about toxicology comes from animal studies--mostly rodents, mostly rats. Well, the fact is that the human, with a few exceptions of course, is not a giant rat. It is very difficult to extrapolate. But the public doesn't really appreciate the fact that something that has been called a carcinogen in a rat has a completely different effect in humans. That notion will be lost if something is just labelled as a carcinogen.

Why would we then not label apples as being carcinogenic? They contain formaldehyde, naturally occurring, in fact in higher doses than one would find in most cosmetics.

Take the coinage that we use. Nickel is on a group one list as a carcinogen. When we handle a nickel, the surface is oxidized. It's nickel oxide. That's a carcinogen.

Why do we not label sunshine as a carcinogen? Because we use reason. The dosages are important. The exposure is important. That always has to be taken into account.

I think one very important way to look at all of these issues is to take a look and see what the real experts say about this. It should all be ruled by science, not by emotion.

Take a look at toxicologists, for example. A survey was recently done by an American society of toxicologists. Close to a thousand of them were surveyed and asked about such things as BPA and phthalates. Ten percent of these guys said they think BPA is a real risk, and about the same percentage said that phthalates are a real risk. Twelve percent thought that high-fructose corn syrup is a real risk. And these are the people who really do know what they are talking about.

Unfortunately, information in real scientific terms is very difficult to acquire. Toxicology is a tremendously complex subject. It's very difficult to translate that information to the public, but unfortunately it's pretty easy to scare the public. There's a whole industry out there today that scares the public.

I want to finish up by giving you an example, because I think it is very, very important to take into account the effect that warnings have on people in terms of physical health. A study was done very recently with a group of students. They were told that a cylinder contained air that was mixed with an environmental toxin that can trigger headaches and nausea.

The students were divided into two groups. Half of them were asked to inhale this air. Well, of course, it was bogus; there was nothing in the cylinder except air. But as you can imagine, the ones who inhaled it started to develop the symptoms, whereas the others did not. In a subsequent experiment, when the students were shown a subject who had inhaled this air and developed nausea, they themselves developed it as well, even though they were inhaling just ordinary air.

If that isn't frightening enough, the ultimate case is that of a gentleman who was diagnosed with liver cancer and was told that he had three months left to live. Indeed, he died within that period of time of bizarre symptoms. He became very, very sick. Upon autopsy, they learned that he didn't have cancer at all. It was a misdiagnosis, which of course is very pertinent today, because yesterday we heard about all the problems in Quebec with pathological misdiagnosis.

This is why this is so important: because the mind has a fantastic effect on the body. Before we start labelling things as carcinogens in consumer products that have not been shown to cause cancer in humans--and if they have, of course, they should not be on the market--we have to take into account the effect they may have.

As one final idea, we test urine, and you hear all of these studies about chemicals being present in the urine; you drink from a plastic bottle and you find BPA in the urine. This is meaningless unless the levels can be linked to some knowledge about what those levels actually mean. If you drink a cup of coffee--

[The Chair, Conservative, Joy Smith]

Mr. Schwarcz, I have to interrupt you. We've gone a bit over time and I just want to make sure that everyone has a fair amount of time. Thank you so much. You'll have a chance to answer questions, because we're now going into our first round of seven minutes of questions and answers, with seven minutes per person.

We'll start with Ms. Murray, please.

[Joyce Murray, Liberal, Vancouver Quadra, BC]

Thank you.

First, I would like to ask a question and I'm interested in each panel member's response. Did you have an opportunity to be part of the consultations for Bill C-52 when that was first being put together, and did you feel you were adequately consulted?

[Richard Kinar]

No.

[Kim Ayotte]

Yes. The Canadian Association of Fire Chiefs was consulted and did support it.

[Ondina Love]

We were invited to one consultation.

[Shannon Coombs]

Yes.

[Dr. Joe Schwarcz]

I was not involved.

[Joyce Murray, Liberal, Vancouver Quadra, BC]

I should be clear about my question. I mean consultation as distinguished from an information session, where there was a soliciting of input and ideas that you then saw reflected in the work, as opposed to them simply explaining what was being planned. Would that still be a yes on consultation?

[Richard Kinar]

For us, absolutely not. We weren't consulted and weren't aware of any of the process that was taking place.

[Kim Ayotte]

I don't have that information before me, so I couldn't answer that.

[Ondina Love]

I would say it was minimal.

[Joyce Murray, Liberal, Vancouver Quadra, BC]

Okay. So clearly it was not full consultation, so it's great that you're able to be here and talk to us about what you see as right or wrong or what could be improved. Obviously, the consultation process could be improved.

In terms of hearing, I'm really interested in your recommendations around the decibel levels. I'm just wondering what benchmarks you were using when you made your proposals. Are they benchmarks from somewhere else?

[Ondina Love]

Thank you very much for this question.

We met with many members of the health committee over the past year. Many of the members recommended that we look at international standards, that rather than doing and funding Canadian research and developing our own standards, we look to international standards. That's exactly what we did.

That's why we looked at the recommended standard from the World Health Organization, which is 75 decibels. The International Organization for Standardization has 65 decibels for close-to-the-ear toys and 85 decibels for other toys. The U.S.A has a voluntary standard of 70 decibels for toys held close to the ear. So we did look at international standards and we made our recommendation in that regard.