The recently released “Standard Consumer Safety Specification for Adult Jewelry” (ASTM F2999) is surprisingly similar to ASTM F2923 which specifies requirements for Children’s Jewelry. The limits are identical for the content of paints and surface coatings for antimony (Sb), arsenic (As), barium (Ba), cadmium (Cd), chromium (Cr), mercury (Hg), and selenium (Se). While the lead (Pb) limits are raised higher and some of the testing criteria are somewhat relaxed, adoption of this standard by the Consumer Product Safety Commission could impose a significant testing and certification requirement that the industry has not previously experienced.
The scientific rationale behind the standard is confusing both in the type of testing it requires and in the explanations offered within the standard. The Children’s Jewelry standard (ASTM F2923) is “based on the assumption that exposure of young children to chemicals in toys may not exceed a certain health based level…The risk assessment calculation by which the limits were derived are [sic] predicated on an assumed weight of a very young child weighing 7.5kg.” The new Adult Jewelry standard makes minimal modifications to the limits despite acknowledged differences in risk between adults and children. “While higher limits can be justified on a scientific basis, compliant coatings are widely available that meet these requirements.” The availability of compliant coatings is not a scientific basis for requiring their use.
Remarkably, the Adult Jewelry standard requires the identical testing methods that are designed to mimic mouthing behaviors and the impact of unintentional swallowing of objects by children. The scientific basis for requiring such testing in children is well established, as multiple published studies have demonstrated age-specific behaviors have a direct correlation to exposure pathways. Requiring that same testing for adults is dubious since the risk that an adult would be mouthing (e.g., licking, sucking) jewelry or accidently swallowing it is much different than children. The standard appears to recognize this difference in its rationale: “The Subcommittee considered, and rejected, international standards, such as limits on cadmium in jewelry in the EU, because they apply to adult and to children’s products without distinguishing the difference in how adults and children handle jewelry and thus the differing potential risks.” However, the requirements imposed do not match this rhetoric.
The Adult Jewelry standard issues requirements based on safety not product performance. Yet many of its required test methods are not based on behaviors that would be reasonably anticipated by adults during normal or intended use (this standard covers things as variable as bracelets, tiaras, earrings, watches, and necklaces). With this precedent, one wonders whether future ASTM safety standards will require swallowing or mouthing testing for office supplies, building hardware, automotive parts, or other non-food items that are sold to adults.