Technical Exchange Conference

1. Technical Exchange Conference Siena, Italy November 10 – 12, 2001

2. International Crystal Federation Is the International Crystal Federation Just One Federation Too Many ? Head of ICF Secretariat Dr. John A. Kennedy Head of Technical Services Waterford Crystal

3. INTRODUCTION • 230,000 People • 22,000,000 Tonnes • Raw Materials • Indirect Employment • 80% Crystal in U.S.

4. CPIV • APFE • GEPVP • FEVE • EDG • ESGA

5. ICF • Is the ICF Just One Federation Too Many ? • Usefulness or Effectiveness of Glass Federations • Objectives and Achievements of ICF

6. Foundation • January 1991 Lead in Crystal to the Fore • Article by Graziano in the “Lancet” • Detailed Migration of Lead from Decanters Over Five Years • Cause for Concern, Deserved Further Study

7. In the Resulting Controversy in U.S. • Industry Slow and Ineffectual • No Body Represented World Wide Crystal Industry • International Crystal Federation Formed • Represents Interests of Crystal Industry

8. Fully Supports Adoption and Strict Enforcement of Responsible, Scientific Safety Standards • Supported by Mandatory International Lead Release Standards.

9. Assisting National and International Regulatory Authorities • Assessing Safety of Crystal Products • Improving Safety and Quality of Products • Educating Consumers • Initiatives Eliminating Public Health Concerns

10. Internal Objectives • ICF’s Safety Assessment • ICF’s Voluntary Standards • Compliance and Commitment Programme • Consumer Education • Technical Exchange Conference • Technical Support Group

11. Internal Objectives • ICF’s Safety Assessment

12. Commission A Comprehensive Safety Assessment • Submitting it to U.S. Food & Drug Administration • Extensive Testing Programme • 3000 Individual Chemical Tests • Focusing on Extraction of Lead

13. Market Research Company • Extensive Customer Survey • Consumer Pattern of Use Involving 20,000 Households in the U.S. • Analysed by Independent Health Science Consultancy

14. Independent Survey • Lead Intake from Crystal Decanters • Negligible Public Health Concern • Not for Long Term Storage • Use for Serving Purposes Only • Crystal Tableware < 2% of Maximum Safe Level • Not a Public Health Concern

15. Internal Objectives • ICF’s Safety Assessment • ICF’s Voluntary Standards

16. Control Lead Release to Maximum Extent • Voluntary Lead Release Limits for Tableware • Uniform International Standards • Basis for National Regulations

17. ISO 7086 Since 1982 • Regarded as Too Loose • 1991 Voluntary Limit 50% Below ISO • Reduced on Two Occasions • Final Voluntary Standard 1994

18. TABLE No. 1Lead Release Standards

19. Internal Objectives • ICF’s Safety Assessment • ICF’s Voluntary Standards • Compliance and Commitment Programme

20. Management Responsibility • Design • Materials and Suppliers • Process Control • Inspection and Testing • Control of Non Conforming Material • Corrective Action

21. Internal Objectives • ICF’s Safety Assessment • ICF’s Voluntary Standards • Compliance and Commitment Programme • Consumer Education

22. Very Important Element of Programme • Customer Care and Use Booklet • Correctly Prepare Crystal for Use • Clean Properly to Maximise Brilliance • Advice on Storage • More Effective Response than Regulation Alone

23. Internal Objectives • ICF’s Safety Assessment • ICF’s Voluntary Standards • Compliance and Commitment Programme • Consumer Education • Technical Exchange Conference

24. Most Important Element of Programme • Companies had Proprietary Information • Could Readily Benefit Industry and Should Be Shared • Conference • Lead Migration, Health, Safety and Environment, Production Technolgy

25. Spread Over 3 Days with 15 – 20 Presentations • Open Forum • Factory Visit • Opportunity for Open Exchange of Views and Ideas • More Important than Conference • No Other Forum

26. Internal Objectives • ICF’s Safety Assessment • ICF’s Voluntary Standards • Compliance and Commitment Programme • Consumer Education • Technical Exchange Conference • Technical Support Group

27. Drawn from Members of Technical Committee • Support Manufacturers in Efforts to Reduce Lead Release • Queries from Government, Regulators, and Consumers • Greater Co-operation and Understanding

28. ICF’s External Relations & Achievements • Proposition 65 (1991 – 1993) • Organisation for Economic Co-operation and Development (1993 – 1994) • EU Packaging Directive (1994) • ISO 7086 (1995 – 2000) • U.S. Food and Drug Administration (1995-2001) • The Danish Lead Ban (1998 – 2001) • Proposition 65 (2000 – 2001)

29. ICF’s External Relations & Achievements • Proposition 65 (1991 – 1993)

30. Safe Drinking Water and Toxic Enforcement Act 1986 • Reduce or Eliminate Human Exposure to Chemicals Causing Cancer or Reproductive Harm. • Requires a Warning to Given if Product Exposes Them to Such a Chemical • Not a Standard or a Regulation • Level Extremely Low – 0.5 p.p.b.

31. Action Triggered by AG or Private Plaintiff • Typical Settlement Costs > $1m • 1991 Action Against a Number of Crystal Manufacturers • Industry Agreed ICF Act on its Behalf • Settlement Costs of $1.5m Reduced to $800,000 • 130 Brands

32. ICF’s External Relations & Achievements • Proposition 65 (1991 – 1993) • Organisation for Economic Co-operation and Development (1993 – 1994)

33. Risk Reduction Monograph No.1 for Lead • Targeted • Shot & Fishing Sinkers • Gasoline Additives • Plastics • Paints and Inks • Ceramic and Crystalware etc. • Host Workshop in Canada September 1994 • Detailed Position Paper and Personal Presentation

34. ICF Made Strong Case in Support of Crystal Industry. • Concentrated on Safety Assessment, Support for Product, and Voluntary Standards. • “Recognised the Existence of the Voluntary Standard Developed by the ICF, which is Followed by a Majority of the Industry, and Appreciated that it is More Stringent than that of ISO. It is Acknowledged that the Current ICF Voluntary Standard has Contributed to Reducing the Level of Exposure. The ICF Standard Could Form the Basis of an International Standard”.

35. ICF’s External Relations & Achievements • Proposition 65 (1991 – 1993) • Organisation for Economic Co-operation and Development (1993 – 1994) • EU Packaging Directive (1994)

36. Packaging Waste Directive 1994 to Control Heavy Metal Content • Levels Very Challenging and Have Been a Cause for Concern • Companies Recycling Glass Experiencing Difficulties • In Particular Lead Levels Have Been Very Difficult • Contamination from Lead Foil

37. Prior to Introduction concern Among ICF Members • Required Lead Content Meant Crystal Could Not Be Used for Packaging • Crystal Decanters with Spirits and Perfume Bottles • Under Definition Of Packaging These Would Have Exceeded the Limits • ICF Asked to Negotiate • Exemption for Crystal

38. ICF’s External Relations & Achievements • Proposition 65 (1991 – 1993) • Organisation for Economic Co- operation and Development (1993 – 1994) • EU Packaging Directive (1994) • ISO 7086 (1995 – 2000)

39. ISO Standard in Existence Since 1982 • Outdated by Early 1990’s as Too Loose • ISO Secretariat Commenced Review in 1995 • 1998 ICF Found Revised Standard Set Limits Less Strict Than ICF’s Voluntary Standards.

40. Recognised Ideal Opportunity to Have ICF’s Standards Legitimised into International Standard • Opened Negotiations With Secretariat • Explained How and Why • Incorporate ICF’s Voluntary Standard In New Revised ISO 7086 • Came Into Force in 2000

41. TABLE No. 2Lead Release Standards

42. ICF’s External Relations & Achievements • Proposition 65 (1991 – 1993) • Organisation for Economic Co-operation and Development (1993 – 1994) • EU Packaging Directive (1994) • ISO 7086 (1995 – 2000) • U.S. Food and Drug Administration (1995- 2001)

43. In-depth Discussions Concerning Format for Safety Assessment • All FDA Recommended Changes Were Implemented • Safety Assessment Presented at End 1992 • Regular Subsequent Contact • 1995 Agreed Regular Annual Meetings

44. A Summary Prepared of All Presentations • Shown Particular Interest In • Consumer Education Programme • Consumer Commitment Programme • Voluntary Standards • Instituted Annual Testing Programme • Products Broadly Representative • Randomly Selected and Tested

45. Two Occasions FDA Representatives Addressed ICF Membership • On Other Occasions Have Published Statements on the Work of ICF • Programme “We believe that these positive steps by the ICF will contribute to consumer protection and urge the earliest initiation of all elements of your programme”.

46. ICF Technical Conferences “We appreciate the efforts the ICF is making to characterise the exposure to lead from crystal and to develop and commercialise processes to reduce leachability from crystalware. We strongly urge the ICF to continue the development of improved processes. With such efforts the industry will be able to assure the public of the safety of crystalware products”.

47. ICF’s External Relations & Achievements • Proposition 65 (1991 – 1993) • Organisation for Economic Co-operation and Development (1993 – 1994) • EU Packaging Directive (1994) • ISO 7086 (1995 – 2000) • U.S. Food and Drug Administration (1994-2001) • The Danish Lead Ban (1998 – 2001)

48. Danish EPA Ban Importation, Sale, and Production of Lead and Lead Products. • Products Listed Included Crystalware • Concerned That a Precedent Might be Set • Prepared Very Detailed Paper on Issue • Proposed Ban Neither Justified Nor Proportionate Within Treaty of Rome and Violated Gatt Rules.

49. Paper Forwarded to E.U. and ICF Members Shared it With Their National Governments. • Detailed Opinions and Comments Filed By Twelve Countries From the E.U. and also by the U.S. • Paper and Comment Forwarded to Danish Authorities by E.U. • E.U. Invited ICF and Other Organisations to Meet and Present Case.

50. E.U. Scientific Committee Issued Fairly Devastating Indictment of Ban. • Not Provided Sound Scientific Evidence. • Introduction of Ban Would Result in Additional Reduction in Body Burdens. • Ban Went into Effect March 2001. • Lead Crystal Exempted Until Further Notice.