In what manner is lead used in jewelry manufacturing?

A jewelry item may contain lead due to three main reasons ( Lead Check, 2005): · Most metal alloys used in jewelry making contain lead in varying amounts. Further, a jewelry item may contain a lead core coated with a thin coat of another material ( usually nickel). · A jewelry item may be decorated with brightly colored lead containing enamel. · Some ornaments may be attached to the main piece of jewelry with leadcontaining solder. Further, in independent testing commissioned by Center for Environmental Health ( CEH), PVC cords on children's jewelry have routinely tested over the screening level established for metal jewelry components ( CEH, 2005).

Why is there lead in most metal alloys used in jewelry manufacturing?

Lead provides critical fluidity to traditional white metal alloys. Without it, manufacturers can have difficulty casting jewelry in tin ( Wade, 1999).

Are there lead free alternatives to white metal alloys used in jewelry manufacturing?

Yes. Some of the lead free alloys offered by metal suppliers include: · 92% tin, 7.75% antimony, 0.25% copper · 97.255 tin, 0,. 25% copper, 2.5% bismuth, 0.25% silver · 96% tin, 2% bismuth, 2% antimony · 92% tin, 7.25% antimony, 0.5% copper, 0.25% silver There are also variations on these alloys offered by metal suppliers ( Wade, 1999).

What are the implications of using lead free alloys in jewelry manufacturing?

The lead free alloys are more expensive and require various adjustments to operations, such as · Use of higher grade of black rubber to compensate for the altered rate of solidification · Use of a wider or thicker gate · Addition of vents · Use of a bottom pour self skimming ladle Further, lead free alloys result in approximately a 10% reduction in mold life ( Wade, 1999).

What is the prevalence of toy jewelry containing hazardous levels of lead?

Maas et al. ( 2005) of University of North Carolina's Environmental Quality Institute conducted a research study on the lead content and exposure from jewelry products. They sampled 285 costume jewelry items from 20 different stores in California. The costume jewelry items sampled were intended for both older children and adults. They found that there is a considerable amount of lead being used in the production of most of the sampled jewelry items. Of the total samples tested, 54% contained at least 3.0% lead by weight in at least one portion of the jewelry piece. These samples showed a wide range of lead weight percentages, from a low of essentially zero to a maximum of essentially 100% lead. In fact, 40% of the samples were found to contain more than 50.0% lead by weight and 12.0% contained more than 75.0% lead. Items categorized as ` children's jewelry' showed an overall mean lead content of 27.85, while those pieces intended for all ages had a mean lead content of 35.6%.

The study findings imply that the probability of purchasing a high lead containing jewelry item ( one with a lead percentage of 10% or more), is over 54% in their sample.

Are lead containing jewelry items manufactured domestically, imported, or both?

Based on recall data from the Consumer Product Safety Commission ( CPSC), all of the jewelry items recalled due to high lead levels during the 1997 2006 period were imported. Further 94 percent of the recalled jewelry items were manufactured in India and the remaining 6 percent were manufactured in China.

Which countries are the top U. S. exporters of costume jewelry?

The top five countries that export costume jewelry to the U. S. include, in descending order ( by 2005 CIF value): · China · Austria · India · Korea, and · Czech Republic Imports from China amount to 65 percent of all costume jewelry imports. Currently, about 60 percent of all costume jewelry export volume in China is low end, 30 percent midrange and 10 percent high end. About 65 percent of costume jewelry makers in China are small companies and around 90 percent are privately owned. Large manufacturers account for no more than 5 percent of all exporters, and only about 10 percent are foreign owned or joint ventures. The type of costume jewelry imported from China include rings, earrings, choker& necklaces, bracelets and anklets, brooches and are mostly low end. While high end costume jewelry is noted as being lead free, the low end items typically made from based metals potentially contain lead ( Global Sources, 2006).

References Center for Environmental Health. ( 2005). Analysis of CPSC policy on lead tainted children's jewelry. CEH Press Release. February 9. Global Sources. ( 2006). Costume Jewelry  China Sourcing Report. Global Sources. January. Lead Check. ( 2005). Testing for lead in jewelry. http:// www. leadcheck. com/ PB 21. html. Maas, R. P., S. C. Patch, T. J. Pandolfo, J. L. Druhan, and N. F. Gandy. ( 2005). " Lead content and exposure from children's and adult's jewelry products." Bulletin of Environmental Contamination and Toxicology, 74: 437 444. Wade, S. ( 1999). " Getting the lead out." AJM Magazine. April. Jewelry metals information Metal density ( lb/ in3) melting point ( fahrenheit) U S G S p r i c e p e r o u n c e Lead 0.41 621 $ 0 . 0 4 Tin 0.26 449 $ 0 . 2 3 Copper 0.32 1984 $ 0 . 1 1 Stainless steel 0.28 2745 $ 0 . 1 2 Silver 0.38 1763 $ 6 . 5 2 From Joe Callahan 5/ 8/ 06


March 1, 2001 Donald R. Lynam Vice President, Air Conservation Ethyl Corporation 330 South Fourth Street Richmond, VA 23219 4304 Dear Dr. Lynam,

On November 16, 2000, the Ethyl Corporation ( Ethyl) submitted to the Environmental Protection Agency ( EPA) a draft emission characterization study protocol for MMT, as required under the Alternative Tier 2 Health Effects Testing Requirements. These requirements were finalized in the notification received by Ethyl on May 25, 2000 (" the notification"). As you know, the notification requires EPA review and approval of these protocols. In this letter, we are transmitting to you our comments on the protocols you submitted.

The protocol should clearly state that the objective of the protocol is to develop additional data regarding manganese ( Mn) particulate speciation characterization and the Mn emission rate that results from using MMT in the combustion of gasoline, and is not to provide data on gaseous emissions. As noted on p. 32 of the notification, " this speciation test program is not designed or intended to address the effect of MMT use on emissions of any regulated gaseous pollutants. ... EPA has determined that this study cannot be construed as identifying or measuring the gaseous emission products of MMT, the effect of MMT on gaseous emissions, or the effects of the emission products of MMT on the performance of emission control devices or systems."

We recommend that the test fuel composition specifications be modified. First, we agree that it is appropriate to use low sulfur fuel since it would be more representative of U. S. gasoline in the future. Second, we recommend that the base fuel not contain MTBE at 11 percent by volume concentration. Two of the peer reviewers of the draft protocol pointed out that it is possible that MTBE will be reduced as an oxygenate in the future. One peer reviewer further states that because of this possible reduced use of MTBE, its use for this test program may be inappropriate. Moreover, we disagree with Ethyl's contention that the MTBE concentration specified would not affect Mn particle generation or speciation, as we do not believe that  2

adequate testing exists to allow such a conclusion to be reached. Third, Ethyl's previous emission characterization study, entitled, " Characterization of Manganese Particulates from Vehicles using MMT Fuel" dated September 10, 1997, used Howell EEE certification fuel with no oxygenates. In order to compare the results of the new emissions characterization study to the results of the 1997 study, we believe it would be best if differences between the test fuels in these two programs were kept to a minimum. Therefore, we believe the best choice of test fuel would be non oxygenated test fuel. While it is our understanding that non oxygenated test fuel is available without MTBE, it now has a somewhat lower sulfur level than the fuel used in the 1997 study. In order to keep the differences to a minimum between the test fuel used in this study compared to the fuel used in the 1997 study, we believe that it is appropriate to adjust the test fuel in this study to a 40 parts per million by weight maximum sulfur content using a non naturally occurring sulfur additive.

Ethyl has also indicated to us that it may wish to evaluate particulates collected using oxygenated fuels and the LA4 driving cycle during one or more of the particulate collection intervals. ( Although not required under the notification, particulate collection using the LA4 driving cycle was specifically recognized and permitted under the notification requirements.) We are not opposed to this evaluation. However, if Ethyl chooses to do an evaluation of oxygenated fuel on the non required LA4 driving cycles, EPA would like the protocols to reflect that collection of particulates using the required REMO/ REPO driving cycle be conducted at each mileage interval before particulate collection using oxygenated fuel on the LA4 ( or, at Ethyl's option, on an additional set of REMO/ REPO driving cycle tests in lieu of the LA4). Such an approach would alleviate concerns that the use of the oxygenated fuel might impact such things as adaptive learning prior to the required REMO/ REPO testing. We understand Ethyl is agreeable to this approach.

The draft emission characterization protocol should clarify the meaning of the sentence, " minor modifications to the modified SMA test cycle may be required to fit this cycle exactly to the testing facility." In particular, the draft should provide examples of what these changes might be and indicate that any significant changes to the protocol would need EPA concurrence.

The draft emission characterization protocols should provide the positive displacement pump ( PDP) specifications. As long as the PDP operates at sufficient cubic feet per minute ( CFM), there should be no concern that the exhaust dilution ratio would be inappropriate. This issue was raised by one peer reviewer.

The draft emission characterization protocol should indicate all the likely sources of experimental error and also indicate how the uncertainty associated with this error will be quantified in the results. For example, if it is reported that Mn sulfate comprises 20 percent of Mn containing particulate, the protocols should state how the range of  3

uncertainty around that number will be calculated.

Finally, the draft emission characterization protocol states that four of the six vehicles to be tested will be Ford products. While the study requirements did not specifically state that vehicles produced by different manufacturers must be used, we believe this is implicit in the testing objective stated in the notification which included selecting vehicles for representativeness of in use gasoline fueled vehicles. We recommend that the vehicle fleet composition be changed to include General Motors pickup trucks in the V 8 portion of the vehicle test fleet. With this change, the test fleet composition will thus represent three major manufacturers instead of two.

We look forward to Ethyl's submission of the revised draft protocol as required under the notification. If you have any questions concerning our review, please contact Joe Sopata of my staff at ( 202) 564 9034.

Sincerely,

/ s/

Robert Larson Acting Director Transportation and Regional Programs Division cc: J. Michael Davis, ORD Stan Durkee, ORD Jim Braddock. ORD, Tim Backstrom, OGC Kevin Fast, Hunton & Williams