We provide testing services to certify product and materials compliance, support quality control, and ensure the health and safety of workers and their environment. We provide assistance for clients who are not sure what tests they need. Our accredited materials characterization laboratory is the foundation of all the services of RJ Lee Group provides, including standardized testing for compliance, industrial hygiene and environmental analyses, quality control, and materials research and development.

We provide credentialed expertise supported built by robust scientific data. We provide significant support to industrial clients for product development, industrial hygiene and overall production support.

RJ Lee Group maintains a visible and respected reputation within the legal community, having offered scientific support in civil litigation matters for nearly 30 years. 

  • Product Liability 
  • Toxic Tort
  • Construction Defect
  • Fugitive Emission
  • Personal Injury
  • Patent Infringement
  • Contract Disputes
  • Insurance Subrogation

Subject Matter Experts

From our core business of providing scientific solutions to our clients, we have developed innovative products. Some are produced internally, and some have arisen from partnerships with other research organizations. 

For example, we build lab software solutions to help manage and streamline your labs data, and environmental testing products for a variety of applications. 

  • IntelliSEM is a powerful automated particle analysis system.
  • ParticleID is  a customizable cloud hosted web application used to identify foreign particulate matter and  assist with root cause investigations. 

Other products we create count particles and help keep the air and environment safe.

RJ Lee Group is a materials analysis laboratory and consulting company which serves many different industries. We offer scientific solutions such as industrial forensics services, laboratory and testing services, litigation support, and laboratory software to many industries:

CPSC’s Decision on Cadmium in Toy Jewelry – Solubility and Accessibility Matter

Matthew J. Perricone, Ph.D.

February 6, 2013

The U.S. Consumer Product Safety Commission recently denied a petition asking the Commission to ban “any metal toy jewelry containing more than trace amounts of cadmium by weight, which in a foreseeable manner could be ingested by children” as a hazardous substance. The Commission’s engagement with ASTM committees in the development of ASTM standards (ASTM F963-11, which applies to toy jewelry and was made mandatory by the Consumer Product Safety Improvement Act of 2008, and ASTM F2923-11, which applies to children’s jewelry) resulted in restrictions in these standards that reflect the understanding that risk only exists where exposure is possible.

ASTM F963 and ASTM F2923 set “soluble” limits for cadmium and other heavy metals, determined by laboratory testing that simulate ingestion of a metal part: “Although incidental mouthing or handling and touching of products are more reasonable and likely exposure pathways for heavy metals in jewelry, just as it is for toys, accidental ingestion of a product containing an element represents the most health conservative (worst-case) scenario.”

"Bling" may be popular among young children, but accidentally ingesting cadmium-containing parts in toy jewelry can pose certain risks depending on solubility.

“Bling” may be popular among young children, but accidentally ingesting cadmium-containing parts in toy jewelry can pose certain risks depending on solubility.

Consequently, the standards require three threshold tests to determine if a laboratory simulation is necessary: 1) is the part accessible during normal use or abuse, 2) are parts small enough to swallow through normal use or abuse – including if breakage occurs, 3) does the material contain more than 300 ppm of cadmium? This last requirement is based on recognition that not all cadmium in the part or coating will release during an exposure event. “Consequently this standard adopts a total content screening limit [300 ppm], with migration testing to be conducted where covered items exceed the screening level.”

The distinction between total cadmium content and soluble content is critical. The assessment of health risks associated with accidental ingestion is based on the amount of cadmium available for absorption which is known to be less than the total amount of cadmium in the part. The scientific work performed by CPSC staff and others supports this interpretation. “CPSC has concluded that ‘soluble cadmium migration is not generally proportional to [total] cadmium content.” One should always be cautious in interpreting a positive laboratory result in assessing potential health concerns. Inherent in the standard testing process is evaluation of the entire ingestible part, which is only directly applicable to total ingestion, not mouthing, licking, or touching – exposure pathways that are considered to be less aggressive.

The standards promulgated by ASTM and supported by the CPSC recognize the scientific understanding that products found to contain heavy metals like cadmium are not necessarily hazardous in and of themselves. Petitioners wanted to ban jewelry that contained any level of cadmium (above a scientifically imprecise “trace” amount) regardless of shape, size, or intended use or age group. Any future modifications of standard limits by CPSC or ASTM will need to consider the detection limits of available analytical methods where the result is never zero but rather less than a detection limit. The ability for manufacturers to prove compliance will have a practical limit. The CPSC should be commended for its restraint.

Related Posts