It seems odd to suggest that concerns about lead in children's toys are "misplaced" simply because there are also other risks in toys [Business, Sept. 12]. Design flaws can always occur, but since sources of lead are well known, it should be a simple matter to eliminate lead threats in toys. Parents are rightfully upset that toy companies have failed to do so.

Some people may be reassured that toymakers are finally doing voluntary spot testing. But the federal government still has no safety standard for lead in children's products and has not required or standardized testing. In contrast, our settlement in California lawsuits with more than 90 companies established the first legal limits on lead in children's jewelry and standardized jewelry testing.

Like the recent recalls, our legal work occurs after dangerous products are marketed. We can expect similar recalls until comprehensive federal regulation bans lead in toys and requires premarket testing for hazardous chemicals in children's products.

CHARLES MARGULIS

Communications Director

Center for Environmental Health

Oakland, Calif.