Cadmium: The New Lead
01-13-2010
By David Schmeltzer
Did you know that the Consumer Product Safety Commission (CPSC) has the authority to recall a consumer product that endangers the public, even when the product does not violate any specific CPSC regulations? It’s true – the Federal Hazardous Substances Act grants the CPSC that power. The agency has exercised that power before for lead, and now manufacturers must be prepared in case the agency does the same for cadmium. It’s a constant reminder that regulatory compliance is a moving target, and recall preparedness and having recall strategies in place is critical.
Results of an Associated Press investigation released over the weekend found that manufacturers from China have been using cadmium to replace lead, particularly in children’s jewelry, after new CPSC regulations drastically limited the amount of lead permissible in children’s products. As a result, the CPSC has publicly promised to “take action as quickly as possible to protect the safety of children.”
While the CPSC does not currently place any restrictions on cadmium in children’s jewelry, the toxic metal is in its sight. New regulations of children’s products under the Consumer Product Safety Improvement Act of 2008 placed the first explicit restrictions on cadmium – but only applied to painted toys. Given recent analysis by the Associated Press, the CPSC may look to implement new regulations on the cadmium.
Just because there are currently no standards for cadmium in children’s jewelry products does not mean that manufacturers should not be concerned. The CPSC may still go after the products containing cadmium, utilizing power granted under the Federal Hazardous Substances Act. Or, the agency may quickly put new cadmium standards in place that would support the agency’s ability to recall products with high levels of cadmium and protect consumers well into the future.
It is critical that manufacturers and retailers are prepared to manage a recall and have a recall strategy in place. Whether or not there are restrictions on cadmium use in children’s jewelry is irrelevant if the CPSC demands a recall.
Stericycle ExpertRECALL™ is the industry leader in recall logistics and regulatory compliance for consumer product, pharmaceutical, medical device, juvenile product, and food and beverage recalls. ExpertRECALL’s professionals are experts in recall management who can help you streamline the entire product recall process.
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