Comment from Paul O'Byrne

This is a "no brainer". The Consumer Product Safety Commission must ban cadmium, a dangerous toxin, in children's toy jewelry. Congress has empowered the Consumer Product Safety Commission to protect the public from dangerous products. Cadmium in toy jewelry has emerged as a potential risk to children's health, and the Commission must take action. Cadmium is used by manufacturers in children's toy jewelry, sometimes at very high levels, because it is a cheap alternative to lead. Cadmium has been known to hinder brain development in the young children and cause kidney damage if ingested. The Consumer Product Safety Commission has warned manufacturers about cadmium in products and issued several recalls, but it must do more to protect the public from dangerous products. I strongly encourage the Commission to regulate cadmium by: Classifying Toy Jewelry Containing Cadmium as a Banned Hazardous Substance. By classifying cadmium as a hazardous substance manufacturers and importers will be obligated to test and certify their products, just as for lead. Revising Test Method to Reflect Real Scenarios. Children swallow, chew and break their toys. Because of this, the Commission must compel manufacturers prove these real scenarios will not cause cadmium exposure in children. Requesting the Environmental Protection Agency to Adopt Immediate Testing and Reporting Requirements. The Commission must use its authority under the Interagency Testing Committee to gather any information it needs on cadmium to make sound decisions on the toxin. Specifically, the Commission should include metal jewelry in its scope and require importers and processors to test toy metal jewelry for cadmium. The Commission has already made it clear it believes cadmium is a danger by recalling 74,000 items and by sending manufacturers and importers warnings about the health risks cadmium can have on children. Now is the time for the Commission to use its full authority to regulate cadmium and protect our families.