CPSC Hotline: 1-800-638-CPSC (2772) CPSC's Web Site: http://www.cpsc.gov

Staff Report 

Cadmium in Children’s Metal Jewelry

October 2010
ii

Table of Contents

Staff Report....................................................................................................................................iii

TAB A: Staff Responses to Peer Review Comments................................................................... 14

TAB B: Toxicity Review of Cadmium......................................................................................... 19
iii

Staff Report
UNITED STATES

CONSUMER PRODUCT SAFETY COMMISSION

4330 EAST WEST HIGHWAY

BETHESDA, MARYLAND 20814

Memorandum

CPSC Hotline: 1-800-638-CPSC (2772) CPSC's Web Site: http://www.cpsc.gov

Date: October 14, 2010

TO : Mary Ann Danello, Ph.D., Associate Executive Director, Directorate for Health 

Sciences

THROUGH: Lori E. Saltzman, M.S., Director, Division of Health Sciences

FROM : Kristina M. Hatlelid, Ph.D., M.P.H., Toxicologist, Directorate for Health 

Sciences

SUBJECT : Children’s Cadmium-Containing Metal Jewelry1,2

Introduction

The U.S. Consumer Product Safety Commission (CPSC) administers federal laws concerning 

children’s products and other consumer products. Federal laws and CPSC regulations apply 

nationwide to the consumer products in interstate commerce that are within its jurisdiction. 

Since its inception, the CPSC has played a prominent role in protecting the public, especially 

children, from the hazards of exposure to toxic chemicals. While the CPSC and other federal 

agencies, as well as local, state, and other organizations, have paid close attention to the potential 

for exposure to lead, many other chemicals may be found in products that, if exposure occurs, 

could result in adverse health effects in the users of those products.

Young children may be exposed to chemicals in consumer products from the direct mouthing of 

objects, from handling such objects and subsequent hand-to-mouth activity, or from swallowing 

a small object or a small part of a product. The specific types and frequency of behavior that a 

child will engage in depends on the age of the child and the characteristics and pattern of use of 

the product. 

Recently, CPSC staff identified a number of products, particularly jewelry intended for use by 

children that presented a risk of adverse health effects from exposure to cadmium.

Regulatory framework

The CPSC protects children, and consumers in general, from hazardous exposure to substances,

such as cadmium in consumer products, under the Federal Hazardous Substances Act (FHSA)

(15 U.S.C. §§ 1261–1278). The Federal Hazardous Substances Act requires that certain 

hazardous household products (“hazardous substances”) bear cautionary labeling to alert 

 1 These comments are those of the CPSC staff and have not been reviewed or approved by, and may not necessarily reflect the 

views of, the Commission.

2 A draft of this document was disseminated for external peer review. A summary of the peer review comments and the staff 

responses to the comments may be found in Tab A.
2

consumers to the potential hazards that those products present and to inform them of the 

measures they need to take to protect themselves from those hazards. Any product that is toxic, 

corrosive, flammable or combustible, an irritant, a strong sensitizer, or that generates pressure 

through decomposition, heat, or other means requires labeling, if the product may cause 

substantial personal injury or substantial illness during or as a proximate result of any customary 

or reasonably foreseeable handling or use, including reasonably foreseeable ingestion by 

children.

The FHSA gives the Commission authority to ban by regulation a hazardous substance if it 

determines that the product is so hazardous that the cautionary labeling required by the act is 

inadequate to protect the public. Any toy or other article that is intended for use by children and 

that contains a hazardous substance is also banned under the FHSA if a child can gain access to 

the substance.

Regulating products under the FHSA generally requires assessment of exposure and risk. 

Assessments are generally conducted on a case-by-case basis, considering the specific 

characteristics of the product, the intended consumers of the product, and the interaction between 

the consumer and the product.

This document provides the staff’s approach to assessing products under the FHSA, summarizes

the relevant toxicology of cadmium, derives limits for exposure that, if exceeded, could result in 

adverse health effects, and discusses the results from analytical tests that could result in further 

scrutiny of products that may cause excessive exposure to cadmium in children who use the 

products.

Cadmium Toxicology

This section includes a brief overview of cadmium toxicology. The staff prepared a separate 

toxicity review that includes a broader discussion of the available data,

3

The adverse health effects of cadmium exposure in humans have been documented largely in 

occupational settings, and mostly through inhalation, although nonworker populations have been 

studied as well. The principal effects of long-term exposures are chronic obstructive pulmonary 

disease and emphysema from inhalation of cadmium and cadmium compounds, and chronic 

renal tubular disease from inhalation and oral exposures. Depending on the dose and duration of 

exposure, effects have been observed in multiple organ systems and tissues, including kidney, 

liver, and bone. Although cadmium exposure in workers through inhalation is associated with 

lung cancer, there is insufficient evidence in humans or experimental animals to determine 

whether cadmium is carcinogenic from oral exposure.

which may be found in 

Tab B.

Cadmium and cadmium compounds are poorly absorbed following ingestion, unless the levels 

are high enough to cause damage to the gastrointestinal tract. Absorbed cadmium accumulates 

largely in the kidney and liver, with a very long half-life, which is measured in decades. Only a 

small portion of the absorbed cadmium is excreted in the urine or in feces. Consequently, 

cadmium exposures are cumulative.

 3 “Toxicity Review of Cadmium.” CPSC Memorandum from Dominique J. Williams and Kristina M. Hatlelid, Ph.D., M.P.H. to 

Mary Ann Danello, Ph.D. August 2010.
3

The forms of cadmium in consumer products vary from cadmium metal in certain metal alloys, 

including materials used in soldering and electroplating, to cadmium salts and other compounds 

used in materials such as paints and plastics. Cadmium is found widely in the environment, in 

foods, and in tobacco. Diet is the major source of cadmium exposure for most people.

Exposure to cadmium also may occur through contact with some consumer products. Exposures 

from products, especially in children, are most likely from handling objects and then transferring 

material from the hands to the mouth, through direct mouthing of objects, and from swallowing 

small objects or parts of products. Staff identified information relating to ingestion of cadmium 

and cadmium compounds as most relevant to the assessment of cadmium exposures from 

consumer products.

Existing Exposure Limits

Several limits for exposure to cadmium have been established for regulatory or other purposes. 

For example, the World Health Organization (WHO) has developed a Provisional Tolerable 

Monthly Intake level (PTMI) of 25 micrograms per kilogram body weight per month4 (25 

μg/kg/month) (or 0.8 μg/kg/day) (JECFA, 2010). The U.S. Environmental Protection Agency 

(EPA) developed an oral reference dose (RfD5

) of 1 μg/kg/day for food intake and 0.5 μg/kg/day 

for cadmium in drinking water (different levels of absorption of cadmium from food or from 

water account for the different RfD values) (EPA, 1994). The Agency for Toxic Substances and 

Disease Registry (ATSDR) developed a minimal risk level (MRL6

) for chronic7

The ATSDR’s 2008 draft toxicological profile also includes an MRL for intermediate length 

exposure of 0.5 μg/kg/day based on effects on bone in experimental animals. Due to 

inadequacies in the acute oral exposure database, the ATSDR has not derived an acute duration 

MRL.

oral exposure of

0.1 μg/kg/day (ATSDR, 2008). These limits were based on studies of kidney effects in humans.

The preceding exposure limits are for general use (e.g., PTMI, MRL) or apply to specific 

exposure media (e.g., RfD for food or water). A child-specific standard for cadmium exposure

exists in the form of the European toy safety standard EN 71-3 (European Standard EN 71-3, 

1994). Under this standard, the limit for exposure to cadmium from toys for young children is 

0.6 μg per day, based on information concerning normal background cadmium intake levels and 

a policy decision to limit cadmium exposure from toys to 5 percent of the assumed background 

exposure. Recently, the EC toy safety directive (Council Directive, 2009) established new 

health-based exposure limits for toys, using recent data on kidney effects in humans, including 

studies considered by the ATSDR (2008) and CPSC staff in the current evaluation. Effective 

July 20, 2013, the European toy safety standard for cadmium exposure from toys is based on an 

exposure limit of about 0.2 μg per day. Note that these toy safety standard daily limits are not 

 4 Exposure limits are generally expressed in terms of milligrams of exposure per kilogram body weight. Since 1 mg = 1,000 μg, 

1 μg/kg/day is equivalent to 0.001 mg/kg/day.

5 The EPA’s RfD is defined as an estimate (with uncertainty spanning perhaps an order of magnitude) of a daily exposure to the 

human population (including sensitive subgroups) that is likely to be without an appreciable risk of deleterious effects during a 

lifetime.

6 The ATSDR’s MRL is an estimate of the daily human exposure to a hazardous substance that is likely to be without appreciable 

risk of adverse noncancer health effects over a specified duration of exposure.

7 As defined in the ATSDR toxicological profiles, chronic exposure is exposure to a chemical for 365 days or more; intermediate

exposure is 15 through 364 days; acute exposure is 1 through 14 days.
4

expressed in terms of body weight, but are daily limits for cadmium exposure that have been 

adjusted to account for the weight of a young child (7.5 kilograms for the revised standard—

about 16.5 pounds).

Long-Term Exposure

A number of additional chronic exposure studies are now available that allow for dose-response 

analysis, and can be used to estimate an acceptable daily intake level (ADI). The staff’s 

calculations generally are based on the study reporting the lowest exposure levels associated with 

adverse effects (lowest observed adverse effect level or LOAEL) or a dose that was not 

associated with an adverse effect (no observed adverse effect level or NOAEL). A number of 

high quality studies have considered cadmium-related adverse effects in the kidney and bone, 

reporting quantitative estimates for the level of cadmium intake that is associated with adverse 

effects ranging across about one order of magnitude (i.e., the high end of the range is about 10 

times the low end of the range). 

Staff chose the analysis of an epidemiological study by Suwazono et al. (2006) as the key study 

for a number of reasons, including that the study was based on a large, well-characterized 

population without any identified source of environmental or occupational exposure; the 

modeling included multiple covariates to account for potential confounders; and the estimated 

cadmium exposures associated with adverse health effects were among the lowest of several 

studies. Suwazono et al. (2006) used a benchmark dose8 approach to analyze the data from a 

study of 820 Swedish women. The analysis estimated the concentration of cadmium in urine 

associated with urinary protein markers for adverse effects in the kidney. These researchers 

reported 0.5 micrograms cadmium per gram creatinine9

Because the BMDL is a measure of cadmium excreted in urine, additional analysis is required to 

estimate the corresponding level of cadmium intake into the body. This can be done using 

modeling techniques. The derivation of the MRL presented in the draft ATSDR Toxicological 

Profile for Cadmium (ATSDR, 2008) has applied such an analysis using the results of several 

studies of European populations, including Suwazono et al. (2006). For a 0.5 μg/g creat. urinary 

concentration, the analysis published by the ATSDR (2008) estimated a level of cadmium intake 

of 0.33 μg/kg/day. This is the intake level chosen by CPSC staff as the critical exposure level.

in the urine (0.5 μg/g creat.) as the lower 

confidence limit of the cadmium concentration benchmark dose level (i.e., BMDL associated 

with a 5 percent excess risk of protein in the urine). Similar results were reported by Uno et al. 

(2005) and Järup et al. (2000).

The scientific community generally addresses uncertainty in the comprehension of toxicology 

and dose-response through the use of uncertainty factors. CPSC staff also uses an uncertainty 

factor approach in evaluating exposure levels to account for a lack of robust data from animal 

studies or a lack of information from human exposures (CPSC, 1992). CPSC staff may apply up 

to three uncertainty factors, depending on the completeness and relevance of the available data. 

An uncertainty factor may be used if data are available only in studies of animals and not in 

humans. An uncertainty factor is applied if the available studies do not identify a dose or 

 8 A benchmark dose approach uses mathematical modeling to characterize exposure-response relationships. 

9 Urinary cadmium concentrations were normalized to the amount of creatinine also present in the urine, a common method that 

accounts for the variations in excretion of urine and that allows comparison of urinary measurements over time, between subjects, 

or from different studies.
5

exposure level that is not associated with an adverse effect (NOAEL). When a benchmark dose 

approach is used, the BMDL is treated as a NOAEL. The third type of uncertainty factor is 

applied to account for sensitive populations if the available studies do not adequately address 

such concerns.

In this case, only one uncertainty factor is needed, which is intended to account for the 

possibility of sensitive members of the population. The staff has chosen to apply a reduced 

uncertainty factor of 3, rather than the factor of 10 that is more typically used because of lack of 

knowledge of effects throughout a population. The reduced uncertainty factor is appropriate in 

this case because of the strength of the data that supports the identified critical exposure level,

which is based on multiple studies of large numbers of people in different parts of the world. 

Therefore, an uncertainly factor of 3 applied to the intake level of 0.33 μg/kg/day results in an 

acceptable daily intake (ADI) of 0.1 μg/kg/day. This is the level of chronic exposure that should 

not be exceeded to avoid adverse health effects.

The key study used to estimate the ADI (Suwazono et al., 2006) was based on data from adult 

women in a population that had no particular source of exposure to cadmium. Because the study 

participants likely experienced exposures to cadmium throughout their lives, such as through 

normal dietary sources, staff believes that the ADI may be applied to various scenarios involving 

exposures from consumer products during childhood and later in life.

Another issue to consider is the use of toxicokinetic modeling to relate intake of cadmium to 

absorption into the body, distribution within the tissues and organs of the body, and elimination 

from the body. Recent data indicate that children ages 6 through 11 years and females show 

increased urinary excretion of cadmium (Ruiz et al. 2010). This finding could indicate important 

differences in exposure and uptake of cadmium in these populations. Again, the epidemiological 

study that was used to estimate the acceptable daily intake level was conducted in women who 

likely experienced exposures to cadmium throughout their lives, including childhood. Although 

uncertainty remains on the implications of possible differences among various groups, the 

relatively large body of literature concerning long-term exposure and effects of cadmium 

supports the staff’s approach.

Intermediate and Acute Duration Exposure

Documented acute10

 10Acute exposures, 14 days or less, 16 C.F.R. §1500.3(c)(2)(i). Intermediate exposure duration is not defined within CPSC 

regulations, but generally means longer than acute exposure, but less than chronic; this term is defined in the ATSDR 

toxicological profiles as 15 to 364 days.

exposures in humans generally have involved exposure to relatively large 

amounts of cadmium compounds, resulting in severe adverse effects, including death. One 

report of a nonfatal exposure in humans was published by Nordberg et al. (1973). This case 

involved gastrointestinal symptoms in boys 13 through15 years old following ingestion of a 

beverage containing cadmium from a soda machine. Investigation of this case included analysis 

of a sample of water from the machine that contained 16 milligrams of cadmium per liter 

(16 mg/L). It is not clear from the report when the water sample was collected or how it was 

handled prior to testing for cadmium content. Based on information collected from the boys 

about five months after the incident, symptoms began within 15 minutes of consumption of the 

drink, and included headache, nausea, vomiting, abdominal pain, and diarrhea. All symptoms 

resolved within seven hours, and most of the boys returned to school when classes resumed after 

the weekend three days later. The children reported consuming 0.5 to 2.5 glasses of the drink, 
6

with an average of about one glass. Although the volume of beverage consumed was not 

reported, information in the publication’s discussion suggests that the investigators considered a 

glass to be about 0.15 L. Using this estimate for the average intake, the toxic dose of cadmium 

was about 2.4 mg. Because of the high level of uncertainty in this quantitative estimate and 

inadequate documentation of the case, staff finds this study unacceptable for further quantitative 

analysis or derivation of an exposure limit. Staff has not located other studies or reports of 

health effects from short-term oral exposure in humans at doses that are not associated with 

severe adverse health effects or death. Nor has staff located any reports of persistent effects after 

a brief exposure has ended, or studies that measured long-term effects resulting from an acute 

exposure to cadmium.

Several studies in animals have been conducted involving single exposures or short-term dosing, 

usually at relatively high doses. Adverse effects have been reported for multiple tissues and 

organ systems, including death, and effects in the liver, kidney, and bones. Most of the studies 

are not suitable for use in dose-response analysis for deriving exposure limits because of the 

severity of the adverse effects associated with the dose levels chosen for the studies. Of the 

studies that are appropriate for use in extrapolating to an acceptable intake level for humans, the 

staff chose as the key study, the evaluation of short-term exposure in rats through drinking water 

by Borzelleca et al. (1989). 

This study involved groups of male and female rats that were exposed to cadmium chloride in 

drinking water for 10 days. Cadmium exposure was calculated at 1.1, 7.8, and 11.1 mg/kg/day in 

males, and 1.1, 8.1, and 13.8 mg/kg/day in females, based on the concentration of cadmium 

chloride in the water and the animals’ water intake. The authors noted a dose-dependent 

decrease in body weight gain among males. The summary data also appear to show reduced 

body weight in the highest dose group in males, and dose-related reduced body weight gain in 

females, but statistical analyses were not presented.

Because of the disagreeable taste of water containing cadmium chloride, reduction in body 

weight or reduction in body weight gain may be due to the tendency of the animals to reduce 

their water intake with a concomitant reduction in food intake. However, the same publication 

(Borzelleca et al., 1989) included a study in which dosing through gavage (i.e., delivery of the 

dose directly into the stomach through a feeding tube) also resulted in reduced body weight and

reduced body weight gain. This latter study suggests that cadmium exposure affects body weight 

through means other than the effect on the taste of the drinking water, and, therefore, changes in 

the body weight endpoints should be considered related to the exposure. The results of this study 

are supported by findings of body weight effects in two other animal studies involving dosing 

through gavage (Baranksi, 1985; Machemer and Lorke, 1981).

For exposures through both gavage and drinking water, Borzelleca et al. (1989) also noted 

significant changes in certain clinical chemistry measures, suggesting systemic effects in 

addition to the effects on body weight. Therefore, staff concludes that short-term exposure to 

cadmium is associated with adverse effects in animals. The lowest dose administered in the 

drinking water study (1.1 mg/kg/day) (Borzelleca et al., 1989) can be considered the no 

observed adverse effect level (NOAEL) and is appropriate for extrapolating to an acceptable 

intake level for humans. 

As with the estimation of a longer term ADI, for an acute duration exposure limit, staff identifies 

the LOAEL or NOAEL and applies up to three uncertainty factors to account for sensitive 
7

individuals, the use of a LOAEL instead of a NOAEL if that is the case, and for the use of data 

from studies in animals instead of in humans if that is also applicable. Consequently, the acute 

ADI for cadmium is 11 μg/kg/day, based on the NOAEL of 1.1 mg/kg/day, and the use of an 

uncertainty factor of 10 for the use of data from animals rather than humans, and another factor 

of 10 to account for sensitive individuals in human populations.

No information was located for human oral exposures of intermediate length duration. However, 

recent studies in young rats demonstrate dose-related effects on bone metabolism and bone 

biomechanical properties for exposures up to 12 months (Brzóska and Moniuszko-Jakoniuk 

2005). Based on a number of effects reported at the lowest dose tested, the LOAEL for the 

intermediate duration study is approximately 0.2 mg/kg/day. The intermediate exposure MRL of 

0.5 μg/kg/day presented in the recent draft toxicological profile (ATSDR 2008) was derived 

using a benchmark dose approach to analysis of this data.

In general, the animal studies conducted in acute exposure scenarios and intermediate duration 

scenarios indicate a very wide range of LOAELs and NOAELs (i.e., orders of magnitude 

difference between lowest and highest reported values) including, in some cases, adverse effect 

dose levels that are comparable to the LOAELs and NOAELs reported in longer-term studies 

(see summary in Table 3.6, ATSDR 2008). As discussed above, ADIs, MRLs, and RfDs derived 

from chronic and intermediate duration studies range across about one order of magnitude. No 

acute exposure limits have been derived previously for oral exposure to cadmium.

Because cadmium is found in the environment, in foods, and in tobacco, most people experience 

some level of exposure to cadmium. Any additional exposure to cadmium from consumer 

products will add to the overall risk of adverse health effects that might be associated with other 

sources of cadmium.

Evaluation

Children’s jewelry is not a distinct, easily-defined product for a specific group of consumers. 

Rather, this category of products could encompass a large variety of jewelry products suitable for 

children of specific ages or for children of all ages. Because exposure to substances is the focus 

of staff’s assessment, the assessment will focus on a group of children likely to participate in the 

behaviors that could result in excess exposure to the substances, and who are also the most 

vulnerable to the effect of the possible exposures. In this case, staff has chosen to consider 

young children ages 2 through 6 years old. Children in this age group still have significant 

mouthing behaviors, and occasionally may swallow—accidentally or intentionally—small 

objects. This age group may also be of special concern because of the potential health effects of 

cadmium exposure in people at early stages of development, similar to the concern about lead 

exposure in young children. However, data currently do not exist that clearly show adverse 

health effects specifically associated with exposures in early childhood.

Children are not expected to use certain pieces of jewelry, such as a charm bracelet, throughout 

their daily life. Some jewelry, such as jewelry with seasonal themes, may be used for a few 

weeks, and pieces that are especially valued by the child or by their parents, may be worn only 

occasionally. However, some jewelry, such as inexpensive items, may be used frequently or

until the item is no longer favored by the child or is lost. For this evaluation, staff assumes that a 

child will use a jewelry item frequently over weeks, months, or years.
8

Exposure to cadmium from metal jewelry items or similar objects could occur during handling or 

mouthing the product, or from swallowing a pendant, bead, or other small component part of 

jewelry.

An ingested product could result in an acute or short-term exposure, because ingested objects are 

usually eliminated from the body within a few days or possibly weeks. Therefore, data on the 

effects of acute or short-term cadmium exposure would be most relevant for an assessment of 

swallowed jewelry items. 

As discussed above, acute exposure in humans and experimental animals causes a number of 

adverse effects. Because of the uncertainty regarding the circumstances and quantitative details 

of human exposure cases, staff has chosen to evaluate short-term exposures using the study in 

experimental animals by Borzelleca et al. (1989) to derive an ADI for acute exposure of 

11 μg/kg/day.

To assess children’s cadmium-containing jewelry, staff assumes that the vulnerable group of 

children is 2 to 6 years old, with an average weight of 18.2 kg (40 pounds) (Ogden et al. 2004). 

Given the 11 μg/kg/day acute ADI, the maximum allowable acute exposure for a young child 

is about 200 μg/day.

Handling or mouthing a product could result in a longer-term exposure because use of the 

product could occur over many weeks, months, or years. In contrast to acute exposure, longterm exposure to cadmium has been studied extensively and is well characterized. Given data 

from multiple studies, staff prefers to use studies in humans for characterization of human risks. 

Thus, because of the strength of the evidence in studies of human populations, staff has chosen to 

use epidemiological information (Suwazono et al. 2006) in the assessment of exposure to 

cadmium from children’s jewelry. As discussed above, staff derived an acceptable daily intake 

level (ADI) for cadmium of 0.1 μg/kg/day for chronic exposure. Given the 18.2 kg body weight 

for children ages 2 to 6 years, and the 0.1 μg/kg/day ADI, the maximum allowable chronic 

exposure for young children is about 1.8 μg/day.

Ingestion of foreign bodies

As discussed in the staff’s briefing package on lead-containing children’s metal jewelry, several 

cases show that excessive exposure to lead resulted from children swallowing lead-containing 

metal jewelry items (CPSC 2006a).

Further, as documented in the briefing package, jewelry items are among the most commonly 

ingested items by young children (CPSC 2006b). Staff analyzed data from the National 

Electronic Injury Surveillance System (NEISS) database on emergency room-treated injuries 

associated with ingestion of consumer products by children. For 2000–2005, the staff estimated 

302,587 emergency room-treated injuries, nearly 80 percent of which were children under age 

7 years. The objects most commonly swallowed were coins (accounting for nearly half of 

ingestions); jewelry; toys not elsewhere classified; and nails, screws, tacks, or bolts.

Additional data on ingestion of objects are found in a 1998 study that evaluated 100 children 

ages 9 months to 13 years, who ingested various foreign bodies, including coins, ball bearings, 

pins, marbles, screws, buttons, a light bulb, a novelty nail file, and a clothespin (Macgregor and 

Ferguson, 1998). This study evaluated how long an ingested object might remain within the 

gastrointestinal tract. The total transit time for passage (from ingestion to elimination through 
9

the rectum) of the items ranged from 1 to 46 days. The peak time of passage was 2 days, with a 

median time of 6 days. The authors noted that the mean transit time for an ingested object 

increased with age; it was greater than 15 days for 13 year olds, while it was typically 5 days for 

4 through 10 year olds.

Thus, the available information shows that children may swallow items such as jewelry, and that 

ingested items can cause excessive exposure to chemicals from the swallowed items.

Assessment

Exposure to cadmium from children’s metal jewelry could occur as children use and interact 

with a product. This exposure might occur from activities such as mouthing a product or 

handling the product with subsequent hand-to-mouth transfer of cadmium that might be removed 

from the surface of the product. This exposure could occur over the many days or months that a 

child uses a product such as metal jewelry. Exposure to cadmium also might occur if a child 

swallows a small item or a part of an item. In the case of ingestion of a product, the exposure 

would occur during the usually short time that the item remains in the gastrointestinal tract, 

notwithstanding the possibility that an ingested object sometimes is retained in the body for 

several weeks.

Staff evaluates possible exposures to cadmium or other chemicals from children’s products by 

measuring leaching of the cadmium from the item using a saline solution to mimic the effects of 

mouthing, and a dilute hydrochloric acid solution to simulate the gastric effects on a swallowed

item. The staff’s standard laboratory procedure is to immerse an item in the saline solution for a 

period of six hours. Because of the data showing that ingested items sometimes remain in the 

stomach for several days, for products such as metal jewelry, staff conducts the dilute acid 

leaching test for 24 hours. Data generated by the staff indicates that 24 hours is generally 

sufficient time to identify products that could leach large amounts of chemicals. 

Mouthed object

For the case of mouthing, staff assumes that each minute of extraction in the saline solution 

represents a minute of mouthing of the object by a child. A CPSC study of mouthing behaviors 

of young children estimated an average daily mouthing time of 37 minutes for all objects

(excluding pacifiers) for children ages 24–36 months (CPSC 2001).

Using the saline extraction to simulate the effects of mouthing a jewelry item, with the 

assumption that mouthing a children’s product for 37 minutes per day represents an excess 

exposure, and that the ADI for chronic exposure to cadmium is 1.8 micrograms per day for a 

young child, the ADI would be exceeded if the results of the saline extraction of the item exceeds 

18 micrograms total cadmium extracted during the 6-hour saline extraction (Eq. 1).

(1.8 μg/day)/(37 min/day) x (6 hours x 60 min/hour) = 18 μg (Eq.1)

where

1.8 μg/day is the chronic acceptable daily intake level (ADI) for children 2–6 years old,

37 min/day represents the daily mouthing time of jewelry, and 

6 hours x 60 min/hour is the number of minutes each jewelry item is tested for leaching 

of cadmium into the saline solution in the laboratory evaluation.
10

Therefore, a test result for saline extraction of a mouthable product that exceeds 18 μg indicates

that the product may meet the criteria established in the FHSA for a product to be considered a 

hazardous substance.

Swallowed object

Swallowing a cadmium-containing object is an acute exposure situation, for which the available 

toxicology database is limited. However, the need to evaluate products for the potential for acute 

exposure to cadmium prompted staff to choose data from acute studies in experimental animals 

to derive an acute exposure limit of 200 μg/day. 

In contrast to repeated exposures to small amounts of a chemical over time, ingestion of an item 

results in the total exposure from the item occurring within a short time (i.e., an acute exposure). 

The acute ADI would be exceeded if the result of the acid extraction of the item exceeds 

200 micrograms total cadmium extracted during the 24-hour acid extraction. 

Therefore, based on the available data on acute exposures, a test result for acid extraction of a 

swallowable product that exceeds 200 μg would indicate that the product may meet the criteria 

established in the FHSA for a product to be considered a hazardous substance.

Conclusion

Given the available information on cadmium toxicity and the assumptions about children’s 

interactions with cadmium-containing products, staff has estimated limits for testing that may be 

used for evaluating children’s jewelry under the FHSA. For a product that may be mouthed by a 

child, staff concludes that a result from the 6-hour saline extraction test that exceeds 18 μg would 

indicate that the product may meet the criteria established in the FHSA for a product to be 

considered a hazardous substance based on chronic toxicity. For a product or part of a product 

that may be swallowed by a child, the staff concludes that a result for the 24-hour acid extraction 

test that exceeds 200 μg would indicate that the product may be considered a hazardous 

substance based on acute toxicity.

In order for a substance to be considered a hazard under the FHSA, both exposure and the risk of 

adverse health effects associated with handling and use of the substance must be taken into 

account. Therefore, the characteristics of the product and a child’s behaviors and interactions 

with the product must be considered along with the information on toxicity.

Discussion

This evaluation provides an approach to assessing cadmium-containing children’s metal jewelry 

that takes into account both acute exposure (e.g. from swallowing) and longer term exposures 

(e.g. from repeated mouthing behaviors over time). 

A key consideration in the toxicology of cadmium is that once absorption of cadmium occurs, it 

remains in the body, particularly in the kidneys and liver, for many years. Given the very long 

half-life of cadmium in the body, exposures that occur from swallowing an object or from 

mouthing an object over time could have significant impacts on the overall exposure to cadmium 

from all sources and contribute to the risk of adverse health effects from cadmium exposures.

The evaluation is based on a number of assumptions about children’s behaviors, product 

characteristics, and relevant testing methods, and the existing knowledge base for cadmium 

toxicology. Because of the known hazards associated with human exposure to cadmium, staff 

has taken a conservative approach by using an estimated acceptable daily intake level (ADI) for 
11

chronic exposure and assuming a relatively high level of mouthing activity. The acute exposure 

scenario was evaluated using data on adverse health effects from short-term exposure to 

cadmium in animals because that data is most relevant to the possible scenario in which a child 

swallows a cadmium-containing item.

The approach in this assessment to longer term exposure from mouthing items is conservative, 

largely because of the assumptions about the behaviors expected in very young children. Staff 

used data from an observation study for mouthing of all objects during a day, which would 

overestimate exposure that might occur from a particular product. Furthermore, the staff’s 

assessment of mouthing behaviors that occur over time is based on an acceptable daily intake 

level that is not expected to cause adverse effects if the exposure occurred over many years.

While staff has taken a conservative approach, exposure to cadmium is associated with 

significant health effects, and any exposure from consumer products, such as jewelry, is in 

addition to exposures that most people experience from food, water, and other sources.
12

References

ATSDR (2008) Toxicological Profile for Cadmium (Draft). Agency for Toxic Substances and 

Disease Registry. U.S. Department of Health and Human Services.

http://www.atsdr.cdc.gov/toxprofiles/tp5.html.

Baranski B (1985) Effect of exposure of pregnant rats to cadmium on prenatal and postnatal 

development of the young. J Hyg Epidemiol Microbiol Immunol 29:253–262. 

Brzóska MM, Moniuszko-Jakoniuk J (2005) Disorders in bone metabolism of female rats 

chronically exposed to cadmium. Toxicol Appl Pharmacol 202(1):68–83.

Council Directive 2009/48/EC of 18 June 2009 on the safety of toys. Official Journal L 170, 

30.6.2009, pp. 1–36.

CPSC (1992) Labeling requirements for art materials presenting chronic hazards; guidelines for 

determining chronic toxicity of products subject to the FHSA; supplementary definition of 

"toxic" under the Federal Hazardous Substances Act; final rules. 57 Fed. Reg.: 46626–46674 (9 

October 1992).

CPSC (2001). A mouthing observation study of children under 6 years. CT Kiss.

CPSC (2006a) Memorandum from Kristina M. Hatlelid and Jacqueline Elder to the Commission, 

Todd A. Stevenson, Secretary. “Petition HP 06-1 Requesting Ban of Lead in Toy Jewelry,” dated 

December 4, 2006. In: Briefing Package for Petition Requesting Ban of Lead in Toy Jewelry 

(Petition No. HP 06-1). December 4, 2006.

CPSC (2006b) Memorandum from Craig O’Brien to Kristina M. Hatlelid. “Analysis of Data on 

Child Ingestions,” dated November 30, 2006. In: Briefing Package for Petition Requesting Ban 

of Lead in Toy Jewelry (Petition No. HP 06-1). December 4, 2006.

EPA (1994) Integrated Risk Information System, Cadmium (CASRN 7440-43-9). 

http://www.epa.gov/iris/subst/0141.htm.

European Standard EN 71-3 (1994) Safety of Toys—Part 3: Migration of certain elements.

Järup L, Hellstrom L, Alfven T, Carlsson MD, Grubb A, Persson B, Pettersson C, Spang G, 

Schutz A and Elinder CG (2000) Low level exposure to cadmium and early kidney damage: The 

OSCAR study. Occup Environ Med 57(10):668-672.

JECFA (2010) Summary and conclusions of the seventy-third meeting, Geneva, 8–17 June 2010. 

Geneva, World Health Organization, Joint FAO/WHO Expert Committee on Food Additives.

Macgregor D, Ferguson J (1998) Foreign body ingestion in children: an audit of transit time. J 

Accid Emerg Med 15: 371–373.

Machemer L and Lorke D (1981) Embryotoxic effect of cadmium on rats upon oral 

administration. Toxicol Appl Pharmacol 58:438–443. 

Nordberg G, Slorach S, Steinstrom T (1973) [Cadmium poisoning caused by a cooled-soft-drink 

machine.] Lakartidningen 70: 601–604.

Ogden CL, Fryar CD, Carroll MD, Flegal KM (2004) Mean bodyweight, height, and body mass 

index, United States 1960–2002. Advance data from vital and health statistics; no 347. 

Hyattsville, Maryland: National Center for Health Statistics.
13

Ruiz P, Mumtaz M, Osterloh J, Fisher J, Fowler BA (2010) Interpreting NHANES 

biomonitoring data, cadmium. Toxicol Lett 198(1):44–48.

Suwazono Y, Sand S, Vahter M, Filipsson AF, Skerfving S, Lidfeldt J, Akesson A (2006) 

Benchmark dose for cadmium-induced renal effects in humans. Environ Health Perspect

114:1072–1076.

Uno T, Kobayashi E, Suwazono Y, Okubo Y, Miura K, Sakata K, Okayama A, Ueshima H, 

Nakagawa H and Nogawa K (2005). Health effects of cadmium exposure in the general 

environment in Japan with special reference to the lower limit of the benchmark dose as the 

threshold level of urinary cadmium. Scand J Work Environ Health 31(4): 307–315.
14

TAB A: Staff Responses to Peer Review Comments T

A

B 

A
UNITED STATES

CONSUMER PRODUCT SAFETY COMMISSION

4330 EAST WEST HIGHWAY

BETHESDA, MARYLAND 20814

Memorandum

CPSC Hotline: 1-800-638-CPSC (2772) CPSC's Web Site: http://www.cpsc.gov

Date: October 14, 2010

TO : Mary Ann Danello, Ph.D., Associate Executive Director, Directorate for Health 

Sciences

THROUGH: Lori E. Saltzman, M.S., Director, Division of Health Sciences

FROM : Kristina M. Hatlelid, Ph.D., M.P.H., Toxicologist, Directorate for Health 

Sciences

SUBJECT : Staff Responses to Peer Review Comments on “Children’s Cadmium–

Containing Metal Jewelry” 1

In June 2010, Consumer Product Safety Commission (CPSC) staff sought external scientific peer 

review of staff’s draft document, “Children’s Cadmium-Containing Metal Jewelry.” Comments 

from the three reviewers were received by staff in July 2010. Staff revised the draft document 

based on the peer reviewers’ comments and provides brief responses to the comments here. 

Similar comments or comments pertaining to specific topics are grouped and addressed together.

Comment

There were several specific observations related to sentence structure, wording, or clarity of the 

text, and a general comment that the document should contain more background on the purpose 

of the document and the regulatory approach.

Response: Staff revised the text accordingly to address both the specific and general comments 

about the document.

Comment

Among the three reviewers’ comments were somewhat conflicting conclusions that the ADI 

approaches and data used are appropriate, or that there are deficiencies in the approach and 

discussion. 

Response: The staff carefully considered each comment and revised the draft document to best 

address the comments and present an appropriate evaluation of the available data and 

information.

 1 The responses to the peer review comments are those of the CPSC staff and have not been reviewed or approved by, and may 

not necessarily reflect the views of, the Commission.
16

Comment

A comment concluded that the review is incomplete, specifying that the form of cadmium and 

dose route in the toxicology studies should be included, as well as the form of cadmium expected 

from exposure to children’s products. The review should include discussion of the renal cortex 

concentration threshold concept and database. 

Response: The staff document was revised to include additional material and a greater level of 

detail to address the reviewers’ concerns, although this document is not intended to be a 

standalone toxicity review. Staff’s toxicity review of cadmium, a document produced separately 

from the reviewed evaluation, also addresses some of the reviewers’ comments.

Comment

Consider the bone effects in the derivation of the ADI.

Response: While adverse effects on bone are important outcomes from exposure to cadmium, 

published analyses of epidemiological data show that for long-term exposure, effects in kidney 

are more sensitive endpoints. Thus, staff chose the study of effects in kidney for the doseresponse analysis and derivation of the chronic duration ADI.

Comment

If long-term and intermediate-term LOAELs and NOAELs are similar, what does this mean for 

the minimum exposure period needed to produce a long-term effect?

Response: The available information indicates that the relationship between cadmium exposure 

and adverse health effects is complex, with considerable variability in responses, depending on 

dose, route of administration or exposure, and species or strain of animal or human population. 

Further, there are a variety of endpoints for cadmium toxicity, each with its own dose-response

relationship. Many effects of cadmium are observed only at relatively high exposure levels, 

regardless of duration of exposure. Other effects have been seen following longer term 

exposures at lower levels, such as the adverse effects in kidney and bone that are the most 

significant and most sensitive endpoints for chronic exposures. The results of studies in 

experimental animals that show, in some cases, similar LOAELs and NOAELs in intermediate or 

longer term studies may be due to the specific endpoints considered in the studies, or the specific 

conditions of the studies, such as choice of species. However, the data do not provide for a clear 

conclusion to be made about the minimum exposure period needed to produce a long-term effect.

Comment

The application of the default uncertainty factor in the derivation of the chronic ADI could be 

reconsidered. Based on the large size of the populations included in the epidemiological studies, 

a factor of 3 would be appropriate. However, some remaining uncertainty, such as the possibility 

of effects of childhood exposure to cadmium, should be discussed.

Response: Staff agrees that the database for chronic exposure to cadmium is robust, and that 

uncertainty can be characterized using a factor of 3, rather than the default value of 10, to 

account for effects in sensitive subpopulations. Although children have not been specifically 

studied with respect to adverse effects from long-term exposure to cadmium, the epidemiological 

studies included populations with general environmental exposures to cadmium that likely 

occurred throughout their lives, including during childhood. Therefore, the results of those 

studies would, in part, reflect childhood exposure.
17

Comment

CPSC staff should model short-term exposure and derive ADI based on effects on cadmium 

concentration in the kidney.

Response: At this time, the staff does not believe that such an analysis, using available 

information, would significantly reduce the uncertainties related to data on short-term exposures. 

However, staff agrees that the approach to the short-term exposure data in the draft document is 

inadequate, and has revised the evaluation using information from published studies of acute 

exposure in experimental animals.

Comment

The approach to the swallowing scenario does not make sense and is not appropriate. 

Response: Staff’s approach to evaluating the acute exposure scenario was developed because of 

the lack of data specific to acute exposure to cadmium, particularly from foreign body ingestion, 

such as swallowing jewelry. Staff has reconsidered this approach and made appropriate changes 

to the report. Staff is now using published studies of acute exposure in experimental animals for 

the swallowing scenario assessment.

Comment

An acute exposure limit is needed. Reevaluate the available acute data or use an intermediate 

duration limit. Provide more details about the acute exposure data, including GI effects.

Response: Staff agrees that an acute exposure limit is needed. While staff still considers the 

available database on effects from acute exposures to be limited, this section of the report was 

revised to include information from published acute exposure studies in experimental animals.

Comment

How might the acute and chronic mechanisms of action differ?

Response: The toxicological effects of cadmium are many, and depend on dose, form, and 

route of exposure, whether the effect is observed in humans, and the species and strain of animal 

used in experimental studies. Systemic effects (multiple organs and tissues) are observed from 

both acute and chronic exposures. Acute exposures often involve higher exposure levels, which 

may result in effects that are not observed with lower dose, longer term exposures (e.g., effects 

directly on gastrointestinal tissue that are related to high doses). Some actions of cadmium 

would be expected to occur regardless of the duration of exposure; some effects involving certain 

biological systems or processes may occur only after longer term exposures because repeated 

exposures over time are required to perturb the systems. Thus, acute and chronic toxicity may 

share certain mechanisms, depending on dose and other factors of exposure, while some 

mechanisms are relevant only with longer-duration exposure.

Comment

A commenter suggested that staff consider recent data that show increased urinary excretion of 

cadmium in children ages 6 through 11 years, as well as for females, which could indicate 

important differences in exposure and uptake of cadmium in these populations.

Response: Staff added discussion to the report, but because staff’s analysis is based on a study in 

women who likely also had been exposed in childhood, the conclusions have not changed. 
18

Although uncertainty remains on the implications of possible differences among various groups 

of people, the relatively large body of literature concerning long-term exposure and effects of 

cadmium supports the approach taken by staff.

Comment

It appears that the CPSC is deriving a different (higher) ADI than the ATSDR chronic MRL or 

USEPA RfD.

Response: As described in the draft document, CPSC staff derived an oral, chronic ADI that is 

lower than either the existing or draft MRL derived by the ATSDR, or the existing RfD derived 

by the EPA. The difference between the CPSC staff’s draft ADI and the EPA’s RfD stems from 

using different epidemiological studies as the basis for the analysis. Similar data were used to 

estimate the ADI in CPSC staff’s draft analysis and the ATSDR’s draft, but CPSC staff applied 

an uncertainty factor of 10 to account for sensitive members of the population, while the ATSDR 

used a factor of 3. ADI estimates are divided by uncertainty factors, so that using a factor of 

10 results in a lower estimated ADI. Based on the peer review comments and additional 

consideration of this issue, the revised CPSC staff analysis includes an uncertainty factor of 

3 rather than the default value of 10 (to account for effects in sensitive subpopulations) because 

of the strength of the numerous epidemiological studies. Therefore, staff’s revised ADI is the 

same as the ATSDR’s draft chronic MRL.

Comment

Are there data specifically on ingestion of jewelry regarding GI transit time?

Response: The CPSC databases allow estimates of the number of cases involving ingestion of 

jewelry, but few cases, if any, provide details about the incidents, such as GI transit time. The 

scientific literature discusses cases of foreign body ingestions, but jewelry ingestions have not 

been considered specifically, and the cases that have been reported are not well-described.

Comment

The dose associated with emesis should not be normalized to body weight; volume of stomach 

contents would be a more appropriate measure for extrapolation to different ages.

Response: The staff agrees with this comment, and revised the description of the data 

accordingly.

Comment

For the mouthing scenario, an intermediate duration exposure limit would be more appropriate.

Response: The staff used data from studies in humans to derive the exposure limit for longer

term exposures. An intermediate duration study, conducted in animals, was not chosen for use in 

the assessment because data in humans, when available, is preferable to animal studies. In 

addition, in this case, the numerous, well-conducted studies in humans, lead to a higher level of 

confidence in the results than would occur using the study in animals.
19

TAB B: Toxicity Review of Cadmium T

A

B 

B
UNITED STATES

CONSUMER PRODUCT SAFETY COMMISSION

BETHESDA, MD 20814

Memorandum

CPSC Hotline: 1-800-638-CPSC (2772) CPSC's Web Site: http://www.cpsc.gov

Date: October 14, 2010

TO : Mary Ann Danello, Ph.D., Associate Executive Director, Directorate for Health 

Sciences

THROUGH: Lori E. Saltzman, M.S., Director, Division of Health Sciences

FROM : Dominique J. Williams, Toxicologist, Division of Health Sciences

Kristina M. Hatlelid, Ph.D., M.P.H., Toxicologist, Directorate for Health 

Sciences

SUBJECT : Toxicity Review of Cadmium1

This memorandum provides the U.S. Consumer Product Safety Commission’s (CPSC) Health 

Sciences staff assessment of the potential toxicity associated with cadmium and cadmiumcontaining compounds.

CPSC staff assesses a product’s potential health effects to consumers under the Federal 

Hazardous Substances Act (FHSA). The FHSA is risk-based. To be considered a “hazardous 

substance” under the FHSA, a consumer product must satisfy a two-part definition. 15 U.S.C.

§1262 (f)(1)(A). First, it must be toxic under the FHSA, or present one of the other hazards 

enumerated in the statute. Second, it must have the potential to cause “substantial illness or 

injury during or as a result of reasonably foreseeable handling or use.” Therefore, exposure and 

risk must be considered in addition to toxicity when assessing potential hazards under the FHSA 

(CPSC, 1992; summarized at 16 C.F.R. §1500.135).

The FHSA addresses both acute and chronic hazards. While the FHSA does not require 

manufacturers to perform any specific battery of toxicological tests to assess the potential risk of 

chronic health hazards, the manufacturer is required to label a product appropriately according to 

the requirements of the FHSA. The first step in the risk assessment process is hazard 

identification, that is, a review of the available toxicity data for the chemical under consideration 

and a determination of whether the chemical is considered “toxic” under the FHSA. Chronic 

toxicity data (including carcinogenicity, neurotoxicity, and reproductive and developmental 

toxicity) are assessed by CPSC staff using guidelines issued by the Commission (CPSC, 1992). 

If it is concluded that a substance is toxic under the FHSA due to chronic toxicity, then a 

quantitative assessment of exposure and risk is performed to evaluate whether the chemical may 

be considered a “hazardous substance” under the FHSA.

 1 These comments are those of the CPSC staff and have not been reviewed or approved by, and may not necessarily reflect the 

views of, the Commission.
21

This memo represents the first parts of the risk assessment process, that is, the hazard 

identification and dose-response steps.

Staff’s conclusion is that the data concerning the toxicity of cadmium, discussed below, are

sufficient for cadmium to be considered toxic under the FHSA due to effects on multiple organ 

systems and toxic endpoints, including kidney dysfunction.

Staff has developed an acceptable daily intake level (ADI) for chronic exposure to cadmium by 

the oral route of 0.1 micrograms cadmium per kilogram body weight per day (0.1 μg/kg/day)

based on studies in human populations. This is the level of chronic exposure that should not be 

exceeded in order to avoid health effects.

Introduction

Cadmium is a metal found in the earth’s crust, and is known to be associated with zinc, lead, and 

copper ores. Pure cadmium is a soft, silvery-white metal that is insoluble in water; soluble forms 

include cadmium chloride and cadmium sulfate. Most cadmium used in the United States comes 

from the processing of other metals, such as lead, as well as recycling of nickel-cadmium 

batteries. According to Agency for Toxic Substances and disease Registry’s Draft Toxicological 

Profile for Cadmium (ATSDR, 2008), approximately 83 percent of cadmium is used in batteries.

For nonsmokers, the primary source of cadmium is food. Those regularly consuming shellfish 

and organ meat have higher exposures. Leafy vegetables also contain high levels of cadmium. 

Tobacco leaves accumulate cadmium from the soil, leading to increased cadmium exposure 

among smokers (ATSDR, 2008).

Blood cadmium concentrations reflect recent and cumulative exposures; urinary cadmium levels 

reflect both cadmium exposure and the concentration of cadmium in the kidneys. As part of its 

National Health and Nutrition Examination Survey (NHANES), the Centers for Disease Control 

and Prevention (CDC) measured cadmium in the blood and urine of a representative sample of 

the U.S. population. From the 2003–2004 survey (CDC, 2009), the geometric mean blood and 

urine cadmium levels for the group 20 years of age and older was 0.378 micrograms per liter 

(μg/L) in blood and 0.260 μg/L in urine. Females (0.326 μg/L, blood; 0.216 μg/L, urine) had 

slightly higher levels than males (0.283 μg/L, blood; 0.206 μg/L, urine).

Several agencies have established recommendations or regulations for cadmium. The U.S. 

Environmental Protection Agency (EPA) developed an oral reference dose (RfD2

 2 The EPA’s RfD is defined as an estimate (with uncertainty spanning perhaps an order of magnitude) of a daily exposure to the 

human population (including sensitive subgroups) that is likely to be without an appreciable risk of deleterious effects during a 

lifetime.

) of 1 

μg/kg/day for food intake and 0.5 μg/kg/day for cadmium in drinking water (different levels of 

absorption of cadmium from food or from water account for the different RfD values) (EPA, 

1994) and has established limits for cadmium concentration in drinking water of 0.04 mg/L for 

exposures up to 10 days, or 0.005 mg/L for lifetime exposures (EPA, 2003). The U.S. Food and 

Drug Administration (FDA) established the limit for cadmium in bottled water at 0.005 mg/L 

(FDA, 2009). For exposure through inhalation in the workplace, the Occupational Safety and 

Health Administration (OSHA) established a limit of 5 micrograms per cubic meter of air (5 

μg/m3) for an 8-hour workday (OSHA, 2009).
22

The ATSDR’s 2008 draft toxicological profile includes a minimal risk level (MRL3) for chronic4

Toxicokinetics 

oral exposure of 0.1 μg/kg/day, based on kidney effects in humans (ATSDR, 2008). The draft 

toxicological profile also includes an MRL for intermediate length exposure of 0.5 μg/kg/day 

based on effects on bone in experimental animals. Due to inadequacies in the acute oral 

exposure database, ATSDR has not derived an acute duration MRL.

Cadmium is not well absorbed into the body, especially after ingestion or through the skin. After 

absorption, cadmium is widely distributed throughout the body, but is predominantly found in 

the liver and kidney. Excretion is very slow, with approximately 0.007 and 0.009 percent of the 

body burden being excreted in the urine and feces, respectively, per day (ATSDR, 2008).

Absorption

Based on a number of studies, the ATSDR (2008) reported that absorption from oral exposure 

likely ranges between 1 and 10 percent. While exposures through inhalation are important in the 

workplace, inhalation exposures are less likely from consumer products than exposures through 

ingestion of cadmium-containing substances and products.

All of the studies reviewed suggest that the absorption of cadmium via the dermal route is slow. 

Less than 1 percent of the administered dose is absorbed through the skin during dermal 

exposures. Dermal absorption generally would be a concern when solutions come into contact 

with the skin for several hours or more, such as in an occupational setting (ATSDR, 2008). 

Distribution

Cadmium can be detected in all tissues, with the largest concentrations in the liver and the 

kidneys. Kjellström (1979) presented data from an international investigation of cadmium 

exposure. In this study, analysis of tissues from hundreds of people in Japan, Sweden, and the 

United States showed geometric mean concentrations in the kidneys and liver increased from 

less than 1 microgram per gram tissue weight (1 μg/g) in early childhood to a peak of 40–50 μg/g

in the kidney, and 3–4 μg/g in the liver that occurs at around 50 to 60 years of age. After about 

age 60, tissue cadmium concentrations decrease over time.

Metabolism

After absorption, cadmium does not undergo direct metabolic conversion such as oxidation, 

reduction, or alkylation. However, the cadmium ion binds to proteins and other molecules, 

especially the proteins albumin and metallothionein (Nordberg, 1984). Cadmium in the blood is 

found primarily in protein complexes.

Elimination

Kjellström and Nordberg (1978, 1985) studied the available data and developed a human 

toxicokinetic model for cadmium to describe cadmium absorption, distribution, and excretion. 

Based on the available data, cadmium excreted from the body in feces is largely unabsorbed 

material from the gastrointestinal tract. Most of the cadmium that is absorbed into the body is 

 3 The ATSDR’s MRL is an estimate of the daily human exposure to a hazardous substance that is likely to be without appreciable 

risk of adverse noncancer health effects over a specified duration of exposure.

4 As defined in the ATSDR toxicological profiles, chronic exposure is exposure to a chemical for 365 days or more; intermediate

exposure is 15 through 364 days; acute exposure is through 14 days.
23

excreted slowly, with urinary and fecal excretion being approximately equal. Urinary excretion 

is dependent on blood and kidney concentrations, and the total excretion is assumed to be equal 

to the daily intake of cadmium at steady state. 

From the model, these authors estimated that daily excretion in feces and urine is approximately 

0.007 and 0.009 percent of body burden, respectively. The model also predicts that the half-life 

for cadmium in human tissue is in the range of 6 to 38 years in the kidney and 4 to 19 years in 

the liver.

Acute Toxicity

Investigation of suicide involving cadmium ingestion found that death occurred due to massive 

fluid loss, edema, and widespread organ destruction. Buckler et al. (1986) described a case of an 

estimated exposure of 1,840 mg/kg cadmium chloride that resulted in death within 33 hours. 

Wisniewska-Knypl et al. (1971) reported death within 7 days of ingestion of 25 mg/kg cadmium 

iodide.

In a less severe case of acute toxicity, Nordberg et al. (1973) reported gastrointestinal effects in 

children who ingested 16 mg/L cadmium from soft drinks. This case involved gastrointestinal 

symptoms in boys 13 to15 years old following ingestion of a beverage containing 16 milligrams 

cadmium per liter of beverage (16 mg/L). Based on information collected from the boys about 

five months after the incident, symptoms began within 15 minutes of consumption of the drink, 

and included headache, nausea, vomiting, abdominal pain, and diarrhea. All symptoms resolved 

within seven hours, and most of the boys returned to school when classes resumed three days 

later. The children reported consuming 0.5 to 2.5 glasses of the drink, with an average of about 

one glass. Although the volume of beverage consumed was not reported, information in the 

publication’s discussion suggests that the investigators considered a glass to be about 0.15 L.

Studies in experimental animals show that the oral LD50

5

Systemic Toxicity

ranges from approximately 100 to 

300 mg/kg in rats and mice (Baer and Benson, 1987; Kostial et al., 1978; Kostial et al., 1979). 

The lowest dose of cadmium found to cause death (2 of 20 animals) was 15.3 mg/kg

administered as cadmium chloride in water in a single dose by gavage in Sprague-Dawley rats 

(Borzelleca et al., 1989). Other adverse effects from acute oral exposure include: reduced body 

weight or reduced body weight gain (cadmium doses greater than about 2 mg/kg/day);

hemorrhages, ulcers, and reddening of the stomach and intestinal tract (61 mg/kg/day); testicular 

atrophy (66 mg/kg/day); and necrotic changes in the kidney (15.3 mg/kg/day) and liver 

(138 mg/kg/day) (Baranski, 1985; Borzelleca et al., 1989; Machemer and Lorke, 1981).

Ingestion of cadmium is associated with numerous effects, primarily in the kidney and bone. 

The main effects and key studies are summarized below.

Kidney

The adverse effects of cadmium in the kidney are related to the concentration of cadmium within 

the kidney, particularly within the kidney cortex. Studies have been conducted using kidney 

cortex cadmium concentration as the measure of exposure. Because the concentration of 

cadmium in the kidney is associated with the concentration of cadmium in the urine, the latter 

 5 LD50, or lethal dose-50, is the dose that produces death in half of the group of test animals under specified conditions and test 

duration.
24

metric has been used in studies of living humans, in which kidney levels of cadmium cannot be 

directly measured.

Tubular dysfunction is considered one of the first signs of kidney damage, characterized by an 

increase in urinary, low-molecular-weight protein excretion, such as β2-microglobulin (β2M), 

human complex-forming glycoprotein (pHC) (also known as α1-microglobulin(α1M)), and 

retinol binding protein; or increased levels of intracellular enzymes, such as N-acetyl-βglucosaminidase (NAG) in the urine (European Chemicals Bureau, 2007; Järup et al., 1998). 

Exposure at higher levels is associated with excretion of high-molecular-weight proteins, such as 

albumin, as demonstrated in studies of workers with exposure by inhalation (Bernard et al., 

1979, 1990; Chen et al., 2006a, 2006b; Elinder et al., 1985; Roels et al., 1989, 1993; Thun et al., 

1989).

In workers exposed to high levels of cadmium, ending exposure does not usually lead to the 

reversal of the damage affecting the kidney. The increases in urinary levels of β2M, retinol 

binding protein, or total protein, or the decreases in glomerular filtration rate (GFR) have been 

seen years after the cadmium exposure in workers ended (Elinder et al., 1985; Järup et al., 1993; 

Mason et al., 1999; Piscator, 1984; Roels et al., 1989; Thun et al., 1989). For workers with low 

exposure levels of cadmium, decreases or no change in urinary β2M levels were seen after 

exposure ended (McDiarmid et al., 1997; van Sittert et al., 1993). Roels et al. (1997) and 

Trzcinka-Ochocka et al. (2002) found that reversibility of cadmium-induced tubular dysfunction 

was dependent on the cadmium body burden and the severity of microproteinuria at the time 

cadmium exposure was reduced or stopped.

A number of large epidemiological studies have examined the effects of cadmium exposure on 

the kidney. A few such studies are summarized here.

Järup et al. (2000) examined 1,021 individuals living near a nickel-cadmium battery plant in 

Sweden for at least five years (n=799) or employed as battery workers (n=222). The mean 

urinary cadmium levels were 0.81 and 0.65 μg/g creatinine6

The European Chemicals Bureau (2007) recalculated the probability of pHC proteinuria (using 

the raw data from Järup et al., 2000) to account for the differences in age of the reference 

population (mean of 40 years) and study population (mean of 53 years). Based on these 

recalculations, the urinary cadmium level associated with a 10 percent increased probability of 

abnormal pHC values (20 percent total probability) was 2.62 μg/g creatinine for the total 

population. In the nonworker subgroup, a urinary cadmium level of 0.5 μg/g creatinine was 

associated with a 13 percent probability (representing a doubling of the probability for the

reference population) of abnormal pHC values.

in males and females, respectively. 

Urinary cadmium levels were significantly associated with urinary pHC levels, after adjustment 

for age, in the whole study population, or with the workers removed from the analysis. The 

prevalence of abnormal pHC values (defined as exceeding the 95th percentile in a Swedish 

reference population) was estimated to increase by 10 percent at urinary cadmium levels of 

1 μg/g creatinine.

 6 Measurement of creatinine levels in the urine or blood is used to evaluate kidney function. Urinary protein measurements are 

often normalized to creatinine to account for the variations in excretion of urine and allow comparison of urinary measurements 

over time, between subjects, or from different studies.
25

Noonan et al. (2002) examined 361 residents in Pennsylvania living near an old zinc smelting 

facility (geometric mean urinary cadmium level of 0.14 μg/g creatinine) and a reference 

community (without an identified exposure source) located 10 miles from the facility (geometric 

mean urinary cadmium levels of 0.12 μg/g creatinine). The data from the two communities were 

pooled because there were no differences in urinary cadmium levels between them. β2M, NAG, 

alanine aminopeptidase (AAP), and albumin (ALB) levels were measured as biomarkers of renal 

dysfunction. The geometric mean urinary cadmium levels were 0.07 and 0.08 μg/g creatinine in 

88 males and 71 females ages 6 to17 years old, and 0.24 and 0.23 μg/g creatinine in 71 males 

and 80 females aged ≥18 years. No significant correlations between urinary cadmium levels and 

renal biomarkers were observed in the children, after adjustment for creatinine, age, and gender. 

In adults, significant correlations (after adjustment for creatinine, age, gender, smoking, and selfreported diabetes or thyroid disease) between urinary cadmium and NAG (partial correlation 

coefficient of 0.20, 95% CI of 0.05–0.36) and AAP (partial correlation coefficient of 0.21 and 

95% CI of 0.05–0.36) were observed. Significant dose-effect relationships also were found for 

these two biomarkers. Urinary cadmium levels were not significantly associated with elevated 

levels of β2M or ALB.

Jin et al. (2002) examined three populations living various distances from a nonferrous metal 

smelter. The geometric mean levels of urinary cadmium were 11.18 and 12.86 μg/g creatinine in 

males (n=294) and females (n=171) in the highly polluted area, 3.55 and 4.45 μg/g creatinine in 

males (n=243) and females (n=162) in the moderately polluted area, and 1.83 and 1.79 μg/g 

creatinine in males (n=253) and females (n=155) in the control area. Significant correlations 

were found between urinary (and blood) cadmium levels and renal biomarkers (β2M, retinol 

binding protein, and ALB). 

Dose-Response Relationships for Effects in Kidney

Several dose-response analyses have been done using a number of studies, including those 

summarized above, investigating the relationship between adverse effects in the kidney and 

urinary cadmium levels as a biomarker of cadmium concentration in the kidney.

Investigators analyzed data involving hundreds of people from studies in Europe (Järup et al., 

2000; Suwazono et al., 2006), Japan (Kobayashi et al., 2006; Shimizu et al., 2006; Uno et al.,, 

2005), and China (Jin et al., 2004). The study populations lived in cadmium-polluted areas or 

had no particular source of cadmium exposure. Several studies used benchmark dose7

In a population of workers and environmentally exposed people in Europe, Järup et al. (2000) 

found a 10 percent excess in urinary pHC at a cadmium concentration 1.0 μg/g creat. 

approaches to estimate critical exposure levels. Most of these studies considered urinary 

excretion of pHC, NAG, β2M, retinol binding protein, ALB, or other proteins, and markers for 

changes in GFR as biomarkers of kidney injury. The analyses differed in choice of study 

population and also in the choice of model and parameters resulting in estimates of critical 

urinary cadmium concentrations (i.e., the cadmium concentration associated with a specified 

level of risk for kidney dysfunction) ranging from about 0.3 to 15 micrograms cadmium excreted 

in urine per gram creatinine in urine (μg/g creat). These studies are summarized below.

Jin et al. (2004) examined a population living in a cadmium-contaminated area of China. Using 

a benchmark dose approach and cutoff value for defining abnormality for excretion of β2M of 

 7 A benchmark dose approach uses mathematical modeling to characterize exposure-response relationships. 
26

0.8 mg/g creat., these researchers estimated a critical cadmium concentration of about 4 to 

15 μg/g creat. for a 5 percent excess risk.

In an analysis of data collected in a region of Japan without a source of cadmium pollution, 

Kobayashi et al. (2006) estimated a critical cadmium concentration for a 5 percent excess risk of 

about 2-4 μg/g creat.

Shimizu et al. (2006) analyzed people living in a cadmium-contaminated area of Japan. Using a 

benchmark dose approach and cutoff value for defining abnormality for excretion of β2M of 

1 mg/g creat., these researchers estimated a critical concentration between 1 μg/g creat. and 

4 μg/g creat. 

Suwazono et al. (2006) used data from a study of Swedish women who had no particular 

environmental or occupational exposure to cadmium. Using a benchmark dose approach, and a 

cutoff based on the 95th percentile for urinary protein excretion estimated for a person with no 

cadmium exposure, the critical concentration was estimated at 0.6-1 μg cadmium/g creat. for a 

5 percent excess risk based on excretion of NAG and pHC.

Another study in Japanese populations not exposed to a known source of cadmium resulted in an 

estimated critical concentration of 0.3-3 μg cadmium/g creat. (Uno et al., 2005).

Another analysis of several studies conducted mostly in Japanese populations was conducted by 

Gamo et al. (2006), with a focus on studying the effects of age and sex. Urinary cadmium was 

used as a biomarker of exposure and the prevalence of abnormal levels of β2M as an indicator of 

kidney dysfunction. The authors concluded that a significant increase in the prevalence of 

abnormal β2M levels would not result if the geometric mean urinary cadmium level in a 

nationwide population does not exceed 2 μg/g creat.

Diamond et al. (2003) considered data from 15 different epidemiological studies. These authors 

developed a pharmacokinetic/pharmacodynamic (PK/PD) model to determine the relationship of 

low molecular weight (LMW) proteinuria with cadmium exposure. The authors estimated tissue 

cadmium concentrations, rather than using cadmium excretion in the urine as a marker of dose, 

and estimated intake levels corresponding to the specified probabilities of observing LMW 

proteinuria in a model of a 55-year-old person. The analysis resulted in an estimate for 10 

percent risk for LMW proteinuria with a median kidney cortex concentration of 153 μg cadmium 

per gram tissue, corresponding to a cadmium intake of 2 μg/kg/day in females and 4.3 μg/kg/day

in males.

Liver

While liver tends to accumulate cadmium, it does not appear to be as sensitive to cadmium 

effects as the kidney.

The two cases involving death in humans discussed above (Buckler et al., 1986; WisniewskaKnypl et al., 1971) included liver injury; but studies of lower doses in human have not shown 

significant liver-specific effects (Ikeda et al., 1997, 2000).

In experimental animals, exposure in rats for 10 days to drinking water containing 

13.9 mg/kg/day was not associated with liver effects, while a dose of 138 mg/kg/day caused 

severe effects, including necrosis of hepatocytes (Borzelleca et al., 1989). Longer term studies 

have shown liver effects at lower doses. A 10-week study in male Rhesus monkeys at a dose of 

4 mg/kg/day by gavage found decreased glutathione peroxidase and glutathione S-transferase 
27

(GST) activity in the liver and other tissues (Sidhu et al., 1993). A number of other studies have 

noted histopathologic changes in the liver and changes in liver-associated enzymes in other 

laboratory animals at doses as low as about 2 mg/kg/day (Groten et al., 1990; Müller and Stacey, 

1988; Schroeder et al., 1965; Steibert et al., 1984; Stowe et al., 1972). Other studies with similar 

doses did not observe liver effects (Loeser and Lorke, 1977a; Kotsonis and Klaassen, 1978).

Musculoskeletal Toxicity

Cadmium effects on the bone in humans are evident in a cadmium-contaminated area in Japan, 

where some residents suffer from a disease known as Itai-Itai or “ouch-ouch” disease involving 

osteoporosis and osteomalacia. 

In a study of a population of Swedish men and women living in an area with past sources of 

cadmium pollution, significant decreases in bone mineral density were observed in the group 

more than 60 years of age with the highest blood cadmium levels compared to lowest exposed 

group (Alfvén et al., 2002). Åkesson et al. (2006), in a study of Swedish women without a 

particular exposure to cadmium, reported a significant negative relationship between urinary 

cadmium levels and bone mineral density. The median urinary cadmium concentration was 

0.67 μg/g creat. in this population. These two study populations also were used to examine the 

relationship between cadmium exposure and kidney toxicity (see above).

A study in a group of Flemish women (Schutte et al., 2008) showed effects on several measures 

of bone health in the absence of evidence of kidney dysfunction in most of the subjects. 

In an analysis of women in the United States, Gallagher et al. (2008) used data from the Third 

U.S. National Health and Nutrition Examination Survey (NHANES) 1988–-1994, as well as 

NHANES 1999–-2004, to evaluate the association of urinary cadmium levels and osteoporosis. 

These researchers reported that women who were at least 50 years of age with urinary cadmium 

levels between 0.50 and 1.00 μg/g creat., were at 43 percent greater risk for osteoporosis, relative 

to those with levels less than or equal to 0.50 μg/g creat. Because smokers did not show a 

statistically increased risk, the authors concluded that dietary sources of cadmium, rather than 

cigarette smoke, are related to the osteoporosis risk. These authors also concluded that perhaps

21 percent of osteoporosis prevalence among women at least 50 years of age may be attributed to 

cadmium.

Recently, Suwazono et al. (2010), following their analysis of kidney effects in a population of 

Swedish women, looked at cadmium-induced bone effects. Using the benchmark dose approach, 

these researchers estimated the critical cadmium concentration of 1.8-3.7 μg/g creat. for a 

5 percent excess risk of low bone mineral density. The lower confidence limit of the critical 

cadmium concentration (BMDL) is 1.0-2.1 μg/g creat.

Brzóska and colleagues published a series of studies demonstrating effects of cadmium on bone 

in experimental animals (Brzóska and Moniuszko-Jakoniuk, 2004a, 2004b, 2005a, 2005b, 2005c, 

2005d; Brzóska et al., 2004, 2005a, 2005b, 2005c). Osteopenia and osteoporosis were noted in 

male rats exposed for 12 months to cadmium at 0.5 mg/kg/day and 4 mg/kg/day, respectively. In 

female rates, osteopenia was reported after exposure at 0.08 mg/kg/day for 12 or 18 months, and 

osteoporosis was observed with exposed at 0.08 mg/kg/day for 24 months. Altered mechanical 

properties of bone also were observed by these researchers and others (Ogoshi et al., 1989). A 

number of studies reported decreased bone calcium and increased urinary excretion of calcium in 

intermediate- and chronic-duration studies with doses of 0.2–8 mg/kg/day (Brzóska and 
28

Moniuszko-Jakoniuk, 2005d; Kawamura et al., 1978; Nogawa et al., 1981; Pleasants et al., 1992; 

Watanabe et al., 1986).

Reproductive Toxicity

Several studies investigated the relationships between cadmium in blood, serum, or semen and 

hormone levels (testosterone, follicle stimulating hormone, luteinizing hormone, prolactin, 

estradiol) and measures of fertility. In a study of Eastern European men, Jurasović et al. (2004) 

reported a number of significant associations between reproductive health endpoints and 

cadmium blood concentrations, after adjusting for smoking status. Akinloye et al. (2006) also 

reported significant relationships between physical measures of decreased fertility and blood 

serum cadmium measurements. Seminal plasma cadmium concentration was not associated with 

the fertility outcomes. For hormone measurements, only seminal plasma cadmium concentration 

had a significant effect, and only for follicle stimulating hormone levels. In a study of men in the 

United States, using data from the third National Health and Nutrition Examination Survey

(NHANES III), Menke et al. (2008) reported no association between urinary cadmium levels and 

serum testosterone and estradiol levels, after adjusting for smoking status. 

No studies were found on reproductive effects in women after oral exposure to cadmium. 

Several studies in experimental animals considered reproductive effects of cadmium exposure. 

Borzelleca et al. (1989) noted testicular atrophy in rats after exposure to 66 mg/kg/day by gavage 

for 10 days. A single dose of up to 25 mg/kg in rats had no effect (Dixon et al., 1976). Longer

term studies (up to 17 weeks) in rats showed testicular effects with doses of about 5–

12 mg/kg/day (Pleasants et al., 1992; Pleasants et al., 1993; Saxena et al., 1989).

In studies of female animals, no effects on reproductive organs were noted in rats after exposure 

up to 138 mg/kg/day by gavage for 10 days (Borzelleca et al., 1989). Baranski and Sitarek 

(1987) observed a significant increase in the duration of the estrous cycle in rats administered 

40 mg/kg by gavage 5 days/week for 14 weeks.

A two-generation study involving male and female rats exposed to 2.5 mg/kg/day in drinking 

water for 180 days showed decreased litter size and increased interval between litters, and failure 

to breed in three of five second-generation pairs (Schroeder and Mitchener, 1971).

Developmental Toxicity

Several studies have considered the possible effects of cadmium exposure on pregnancy and 

offspring in humans. Salpietro et al. (2002) reported a significant association between cord 

blood cadmium levels and decreased newborn birth weight in a small study of women with 

relatively low cadmium exposures. Nishijo et al. (2002) reported decreased birth weight, 

probably secondary to early delivery, associated with maternal urinary cadmium levels. Zhang 

et al. (2004) reported an association between cord blood cadmium level and infant height, but 

not weight, or other pregnancy outcomes. These and other similar studies involved small 

numbers of participants, and did not control for confounding factors that might also be related to 

pregnancy outcomes, resulting in limited evidence of a causal relationship between cadmium 

exposure and pregnancy outcomes.

Numerous studies in experimental animals provide clearer evidence for developmental toxicity. 

Several studies reported reduced fetal or pup weight and increased incidence of skeletal 

malformations, missing internal organs or tissue, failure of testes to descend, and cleft palate in 
29

offspring of mothers exposed to cadmium at doses of about 1–20 mg/kg/day (Ali et al., 1986; 

Baranski, 1985; Baranski, 1987; Machemer and Lorke, 1981; Schroeder and Mitchener, 1971).

In multigenerational studies of rats, Nagymajtenyi and colleagues reported that cadmium 

administration of 7–14 mg/kg by gavage during pregnancy, lactation, and after weaning resulted 

in significant behavioral and electrophysiological effects in the offspring (Nagymajtenyi et al., 

1997; Desi et al., 1998). 

In a study in rats, Saxena et al. (1986) reported no developmental effects from exposure to either 

cadmium acetate (21 mg/kg/day as cadmium in drinking water) or lindane (20 mg lindane/kg by 

gavage), when administered alone during gestation. Coexposure to cadmium and lindane 

resulted in maternal toxicity and developmental toxicity. Effects in the dams included decreased 

weight gain; developmental effects included decreased fetal body weight, increased intrauterine 

death, and skeletal anomalies. 

Neurologic Toxicity

A few studies have evaluated neurological effects from cadmium exposure. Based on analysis of 

metal content of hair, Thatcher et al. (1982) and Marlowe et al. (1985) reported associations 

between cadmium exposure and measures of intelligence or behavior. Because of shortcomings, 

including lack of control for confounding factors, such as exposure to lead, and inadequate 

assessment of cadmium exposure, the significance of these studies is unclear.

In studies in experimental animals, in both short-term and long-term studies with doses ranging 

from about 1 to 50 mg/kg/day, a number of neurologic endpoints, including decreased motor 

activity, weakness and muscle atrophy, increased aggressive behavior, increased passive 

avoidance behavior, and other changes in certain cells and enzyme levels have been observed 

(Baranski and Sitarek, 1987; Kotsonis and Klaassen, 1977; Kotsonis and Klaassen, 1978; Murthy 

et al., 1989; Nation et al., 1984; Nation et al., 1990; Sato et al., 1978; Valois and Webster, 

1989).

Carcinogenicity

The carcinogenicity of cadmium and cadmium compounds has been evaluated largely in 

populations exposed through inhalation in workplace settings. Although deficiencies exist in the 

available information, the evidence supports the relationship between inhalation of cadmium and 

cancer (see ATSDR, 2008 for review of inhalation exposure studies). Cadmium and cadmium 

compounds are listed as “known to be human carcinogens” in the Report on Carcinogens, largely 

based on studies in workers (NTP, 2005).

A few investigations also have considered the relationship between cancer and oral exposure to 

cadmium in humans. Studies of populations in areas with known cadmium sources have not 

found significant associations with cancer (Bako et al., 1982; Hardell et al., 1994; Inskip et al., 

1982; Lauwerys and De Wals, 1981; Nakagawa et al., 1987; Shigematsu, 1984). Some of these 

studies had methodological shortcomings or lacked statistical power to show effects, if such 

effects exist.

Studies in experimental animals and in vitro studies show that cadmium may have effects that 

could be associated with cancer. Kurokawa et al. (1989), in a study investigating whether certain 

metal compounds act as promoters of tumors initiated by other chemicals, reported that cadmium 

exposure at 61 ppm in drinking water did not affect the incidence of renal cell tumors, but was 
30

associated with increased numbers of dysplastic foci in the kidney. These authors also reported 

that cadmium chloride did not act to increase tumors in the liver, stomach, pancreas, or skin. 

In a study investigating cadmium carcinogenesis and dietary zinc deficiency in rats, Waalkes and 

Rehm (1992) reported a number of effects of exposure to cadmium in the diet at 0, 25, 50, 100, 

or 200 ppm for 77 weeks. The incidence of prostate tumors was slightly increased compared to 

controls at 50 ppm, but not the other dose groups. An increase in testicular tumors was noted 

only in the highest dose group that also received adequate levels of zinc, but not in groups that 

were fed the zinc-deficient diet. Leukemia incidence also was increased in the cadmiumexposed groups. The authors conclude that cadmium is associated with the incidence of tumors 

in exposed animals, and that dietary zinc deficiency has a complex, inhibitory relationship in 

cadmium carcinogenesis.

Although cadmium exposure carcinogenesis is not clearly shown in the human and animal 

studies, recent work in vitro provides evidence that cadmium exposure could be related to 

cancer. Benbrahim-Tallaa et al. (2009) showed that cadmium transformed normal human breast 

cells into cells that displayed characteristics of basal-like breast carcinoma. These cells, when 

injected into mice, produced invasive, metastatic cancer.

In a study of effects of cadmium on kidney cells, Chakraborty et al. (2010) reported that 

cadmium exposure caused changes in the cells related to proliferation and survival of 

preneoplastic cells, possibly providing a mechanism for cadmium-induced carcinogenicity.

Discussion

Cadmium is poorly absorbed in the body following exposure by inhalation (about 25 percent) or 

ingestion (about 1–10 percent). Cadmium that is absorbed can be found largely in the liver and 

kidney. Cadmium is excreted slowly; estimated half-lives of cadmium in tissues are 6–-38 years 

for the human kidney and 4–19 years for the human liver. 

Cadmium has effects on numerous organ systems and cells within the body, principally the 

kidney and bone. Although cadmium exposure through inhalation in workers is associated with 

lung cancer, there is insufficient evidence in humans or experimental animals to determine 

whether cadmium is carcinogenic from oral exposure. CPSC staff concludes that the data are 

sufficient for cadmium to be considered toxic under the FHSA.

Based on a review of the data, the effects in the kidney can be considered the most sensitive 

endpoint. Cadmium exposure is associated with increased excretion of biomarkers for kidney

dysfunction, including urinary N-acetyl-β-D-glucosaminidase (NAG), human complex-forming 

protein (pHC), β2-microglobulin (β2M), and total protein, and decreased glomerular filtration 

rates (GFR). 

CPSC staff identified the analysis of Suwazono et al. (2006) as the key study for an exposureresponse analysis because this analysis was based on a large, well-characterized population of 

women who had no particular environmental or occupational exposure to cadmium; the study 

population excluded individuals such as those with diabetes, kidney cancer, or those who used

certain medications; the analysis controlled for other potential confounders; and the estimated 

critical effect level was among the lowest estimated from the many published analyses. 

Suwazono et al. (2006) used a benchmark dose approach to analyze the data from the study of 

820 Swedish women. The analysis estimated the concentration of cadmium in urine associated 

with urinary protein markers (NAG and pHC) for adverse effects in the kidney. These 
31

researchers reported a benchmark dose (BMD) for a 5 percent excess risk for each of the proteins 

excreted in the urine of 0.6 micrograms cadmium per gram creatinine in the urine 

(0.6 μg/g creat.). The lower confidence limit of the cadmium concentration BMD (i.e., BMDL) 

was 0.5 μg/g creat. Similar results were reported by Uno et al. (2005) and Järup et al. (2000).

Because the BMDL is a measure of cadmium excreted in urine, additional analysis is required to 

estimate the corresponding level of cadmium intake into the body. This can be done using 

modeling techniques. The derivation of the MRL presented in the draft ATSDR Toxicological 

Profile for Cadmium (ATSDR, 2008) has applied such an analysis using the results of several 

studies of European populations, including Suwazono et al. (2006). For a 0.5 μg/g creat. urinary 

concentration, the analysis published by ATSDR (2008) estimated a level of cadmium intake of 

0.33 μg/kg/day. This is the intake level chosen by CPSC staff as the critical exposure level.

The scientific community generally addresses uncertainty in the understanding of toxicology and 

dose-response through the use of uncertainty factors. CPSC staff also uses an uncertainty factor 

approach in evaluating exposure levels to account for a lack of robust data from animal studies, 

or a lack of information from human exposures (CPSC, 1992). CPSC staff may apply up to three 

uncertainty factors, depending on the completeness and relevance of the available data. An 

uncertainty factor may be used if data are available only in studies of animals and not in humans. 

An uncertainty factor is applied if the available studies do not identify a dose or exposure level 

that is not associated with an adverse effect (no observed adverse effect level or NOAEL). 

When a benchmark dose approach is used, the BMDL is treated as a NOAEL. The third type of 

uncertainty factor is applied to account for sensitive populations if the available studies do not 

adequately address such concerns.

In this case, only one uncertainty factor is needed, which is intended to account for the 

possibility of sensitive members of the population. Staff has chosen to apply a reduced 

uncertainty factor of 3, rather than the factor of 10 that is more typically used because of lack of 

knowledge of effects throughout a population. The reduced uncertainty factor is appropriate in 

this case because of the strength of the data that supports the identified critical exposure level,

based on multiple studies of large numbers of people in different parts of the world. Therefore, 

an uncertainly factor of 3 applied to the intake level of 0.33 μg/kg/day results in an acceptable 

daily intake (ADI) of 0.1 μg/kg/day. This is the level of chronic exposure that should not be 

exceeded in order to avoid health effects.

Conclusion

The data concerning the toxicity of cadmium is sufficient for cadmium to be considered toxic 

under the FHSA due to effects on multiple organ systems and toxic endpoints, including kidney 

dysfunction. CPSC staff has developed an ADI for chronic exposure to cadmium by the oral 

route of 0.1 μg/kg/day, based on studies in human populations. Chronic exposures above the 

ADI of 0.1 μg/kg/day could cause adverse health effects.
32

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CPSC Hotline: 1-800-638-CPSC(2772) CPSC's Web Site: http://www.cpsc.gov

Staff Report on Toy Standard Test Methods with Data 

from Testing Metal Jewelry and Other Materials

August 2010
ii

Table of Contents

Staff Report....................................................................................................................................iii

TAB A: Summary of Test Results for Lead in Children’s Metal Jewelry...................................... 9

TAB B: Assessment of Cadmium Migration from Materials....................................................... 28
iii

Staff Report
UNITED STATES

CONSUMER PRODUCT SAFETY COMMISSION

4330 EAST WEST HIGHWAY

BETHESDA, MARYLAND 20814

Memorandum

CPSC Hotline: 1-800-638-CPSC(2772) CPSC's Web Site: http://www.cpsc.gov

Date: August 10, 2010

TO : Robert J. Howell, Assistant Executive Director, Office of Hazard Identification 

and Reduction

THROUGH: Mary Ann Danello, Ph.D., Associate Executive Director, Directorate for Health 

Sciences

Lori E. Saltzman, M.S., Director, Division of Health Sciences, Directorate for 

Health Sciences

FROM : Kristina M. Hatlelid, Ph.D., M.P.H., Toxicologist, Directorate for Health 

Sciences

SUBJECT : CPSC Staff Discussion of Toy Standard Test Methods1

Background

U.S. Consumer Product Safety Commission (CPSC) staff, as part of its work on possible hazards 

of children’s jewelry and other products has considered the toy safety standards with respect to 

the requirements and test methods for certain chemical elements, such as cadmium. This 

discussion and the accompanying staff technical reports consider methods that CPSC staff has 

used to test and evaluate certain children’s products, describe the current toy safety standards, 

and provide the staff’s preliminary conclusion about testing methods for certain types of 

products.

Toxicological evaluation

Assessment of children’s products for regulation under the Federal Hazardous Substances Act 

(FHSA) involves identification of possible hazards, including toxicity. Staff evaluates chemicals 

through toxicological review and quantitative dose-response analysis. With sufficient data on 

the chemical of interest, staff may estimate the level of exposure that if exceeded would be 

associated with adverse health effects, generally termed the acceptable daily intake level (ADI). 

Exposure to elements from consumer products

To assess whether use of a product could result in excess exposure to a child, staff estimates 

possible chemical exposure through testing of products.

 1 These comments are those of the CPSC staff, have not been reviewed or approved by, and may not necessarily reflect the views 

of, the Commission.
2

Children may be exposed to chemicals in products from direct mouthing of objects, from 

handling such objects and subsequent hand-to-mouth activity, or from ingesting a small item or a 

portion of a product.

CPSC’s Directorate for Laboratory Sciences (LS), Division of Chemistry (LSC) staff evaluates 

possible exposures to chemicals from children’s products that may be mouthed or swallowed by 

measuring leaching of the chemical from the item using a saline solution to mimic the effects of 

mouthing, and a mild acid solution to simulate the effects of swallowing an item. In some cases 

in which exposure might occur from handling a product and subsequent hand-to-mouth activity, 

staff may use a procedure that simulates hand contact with a product through repeated swiping of 

the surface with a moistened wipe. Both the saline and acid leaching methods involve placing 

the item in the solution for specified time periods of at least six hours. For mouthing, the staff 

assumes that each minute of extraction in the saline solution represents a minute of mouthing of 

the object by a child. For the ingestion scenario, staff assumes that the leaching time represents 

the time the item is exposed to the acidic environment of the stomach.

Staff has used an acid extraction test carried out over six hours to reflect the length of time it 

takes for food to move through the stomach and small intestine, where the absorption of

chemicals generally takes place. However, in the course of testing and evaluation of children’s 

metal jewelry containing lead over the past several years, staff learned that these test conditions 

may not necessarily mimic the circumstances of ingestion of products.

As part of a previous staff project on lead in children’s metal jewelry, the staff examined data 

from three cases in which ingestion of a lead-containing jewelry item was associated with 

prolonged exposure to an item. A four-year-old Oregon boy had a blood lead level (BLL)2 of 

123 μg/dL approximately three to four weeks after swallowing a pendant containing 38.8 percent 

lead (VanArsdale et al. 2004). The pendant was surgically removed from the child. A 4-yearold Minnesota boy died with a BLL of 180 μg/dL after ingesting a bracelet charm3

Numerous other reports in published literature and CPSC databases demonstrate that children 

ranging in age from 9 months to 17 years have had exposure to lead from ingesting products 

such as jewelry, game pieces, crayons, chalk, lead weights/sinkers/pellets, lead shot/bullets, and 

curtain weights (Durback 1989, Fergusson 1997, Greensher 1974, Hugelmeyer 1988, Mowad 

1998, Sprinkle 1995; CPSC databases). 

, determined 

by the state public health department laboratory as containing 99.1 percent lead (CDC 2006). A 

nine-year-old boy’s BLL rose to 27 μg/dL four days after he swallowed a ring containing 90 

percent lead. Three days later his BLL rose to 54 μg/dL, at which time endoscopy was 

performed to remove the ring (CPSC files).

As demonstrated by these cases, ingested foreign bodies may not be eliminated quickly from the 

body, but can be retained within the digestive tract for an extended period of time. This has been 

shown in a 1998 study of 100 children aged 9 months to 13 years who ingested various foreign 

bodies (objects included coins, ball bearings, pins, marbles, screws, buttons, a light bulb, a 

novelty nail file and a clothespin) (Macgregor and Ferguson 1998). The total transit time for 

 2 BLL is a measure of recent exposure to lead. From a recent national survey, the geometric mean BLL in children aged 

1-5 years was 1.9 μg/dL (CDC 2005). There is no known threshold for adverse effects of lead; CPSC staff has evaluated product 

exposures using 10 μg/dL as the level that should not be exceeded in order to avoid serious adverse health effects.

3 The length of exposure in this case is unknown, but several days passed between initial presentation of illness and the discovery 

of the object in the gastrointestinal tract.
3

passage (from ingestion to elimination through the rectum) of these items ranged from 1 to 46 

days. The peak time of passage was two days with a median time of six days. The authors noted 

that the mean transit time for an ingested object increased with age; it was greater than 15 days 

for 13-year-olds while it was typically five days for 4 through 10-year-olds.

Ingestion of items such as jewelry is not an infrequent occurrence for children of all ages. As 

presented in Tab D of the Briefing Package for Petition Requesting Ban of Lead in Toy Jewelry 

(Petition No. HP 06-1)4

Data: Lead in Jewelry

, CPSC’s Directorate for Epidemiology, Division of Hazard Analysis 

staff analyzed data from the National Electronic Injury Surveillance System (NEISS) database on 

emergency room-treated injuries associated with ingestion of consumer products by children. 

The staff searched the data for cases involving ingestion of foreign objects by children aged 18 

years and younger and, because NEISS is a probability sample, established national estimates for 

ingestions by age group and product type. For 2000-2005, the staff estimated 302,587 

emergency room-treated injuries, nearly 80 percent of which were children under seven years of 

age. The remaining 20 percent of the estimated injuries were reported in youths aged seven to 18 

years. The objects most commonly swallowed were coins, accounting for nearly half of 

ingestions, followed by jewelry, toys not elsewhere classified, and nails, screws, tacks or bolts. 

Other major product categories included batteries, marbles, and non-electric Christmas 

decorations. Just considering cases involving jewelry, the staff estimated nearly 20,000 total 

emergency room-treated ingestions, about 62 percent of which were in children under age seven 

years, with the remaining 38 percent in children aged seven to 18 years.

In 2004, CPSC staff increased efforts to protect children from lead in products. In particular, the 

staff focused on hazardous lead exposures from swallowing lead-containing metal jewelry. To 

avoid exceeding the 10 μg/dL blood lead level (BLL) of concern from acute exposure, the staff 

recommended that children not ingest more than 175 μg of accessible lead in a short period, such 

as might occur if a piece of jewelry were ingested. Therefore, children’s metal jewelry samples 

that resulted in extraction of more than 175 μg of lead would be considered to be potentially 

associated with excess lead exposure if ingested by a child.

Staff analyzed hundreds of jewelry items such as beads, pendants, and other components of 

jewelry using the mild acid extraction test. The acid extraction test to simulate the effect of 

stomach acid on an ingested item was typically carried out for six hours to reflect the length of 

time it takes for food to move through the stomach and small intestine. Results of testing 

children’s metal jewelry for lead content and lead solubility after six hours of extraction were 

presented in the staff briefing package for the petition on lead in toy jewelry (Tab B of the 

petition package).

Since CPSC staff was interested in the accessibility of lead from ingested items that might 

remain in the gastrointestinal tract for longer periods of time, an additional extraction period of 

18 hours (for a total extraction time of 24 hours) was added to the extraction protocol. The 

staff’s test protocol for each sample involved a one-hour extraction, followed by a two-hour 

extraction with fresh extraction solution, followed by a three-hour extraction with fresh solution, 

for a total of six hours. The latter time point was followed by an addition of fresh extraction 

 4 Available at http://www.cpsc.gov/library/foia/foia07/brief/LeadToyJewelry.pdf.
4

solution for the remaining 18 hours of extraction. Results of testing using this revised protocol 

for samples collected in and tested in fiscal year 2007 are presented in Tab A.

Both the 2004 and 2007 data sets described above showed that, for most samples, the amount of 

lead that migrated from the item generally depended on the amount of lead present in the sample, 

with larger levels of extraction from samples with higher total lead content, although there is no 

strict relationship between content and solubility.

The 2007 report shows that migration of lead generally increases with increasing time in the acid 

extraction solution. However, in many cases, there is little change in the amount of lead 

migration over the first several time points. The staff also observed for many samples that low 

levels of lead extraction at the early time points were followed by large increases in lead release 

either at the six-hour point or the 24-hour point.

This report included acid extraction results for 378 metal jewelry items. For the 197 items that 

had more than 0.06 percent total lead that were tested for accessible lead, 110 (56%) had 

accessible lead greater than 175 μg after 6 hours, and 125 (63%) had accessible lead greater than 

175 μg after 24 hours. Of the 218 metal items that had less than ten percent total lead, six had 

accessible lead greater than 175 μg after six hours, and ten had greater than 175 μg after 24 

hours.

Thus, increasing the extraction time for metal items from six hours to 24 hours showed an 

increase in the proportion of product samples with accessible lead more than 175 μg, as well as 

levels of accessible lead that were much higher at the later time point. The average amount of 

accessible lead after 24 hours (8,200 μg) was about five times larger than the average after six 

hours (1,600 μg).

While the focus of the staff’s jewelry analyses was on metal items, a number of non-metal 

samples were tested for lead accessibility. Of 71 non-metal items tested, 31 were crystal. Some 

of the crystal items had total lead content up to 25 percent, but none had extractable lead greater 

than 175 μg after testing for up to 48 hours. Plastic items accounted for most of the remainder of 

the items tested. Only polyvinyl chloride (PVC) types of plastics had significant lead content. 

As with the metal items, lead migration tended to increase with increasing length of extraction 

time. Of nine PVC plastic items, containing lead up to 0.8 percent, two had extractable lead 

results greater than 175 μg after 24 hours of testing, and an additional two samples exceeded 175

μg after 48 hours. All four of these samples were relatively large necklace cords or choke collar 

necklaces.

Data: Cadmium in Jewelry

Recently, staff has evaluated the potential for hazardous exposures to cadmium that might occur 

from mouthing or swallowing cadmium-containing children’s metal jewelry (Tab B). At this 

time, the amount of data on cadmium-containing children’s metal jewelry is limited compared to 

that for lead-containing children’s metal jewelry. Also, the staff has not identified a specific 

total cadmium content level that might indicate a possible hazard, or a level of cadmium 

exposure that children should not exceed that would be used to identify products with the 

potential to cause excess exposure to cadmium or to define a cadmium extraction limit for 

certain products.

Staff evaluated 20 cadmium-containing jewelry items (i.e., finished products of various sizes and 

designs, generally including electroplating or other surface finishes), several non-product metal 
5

alloy samples in wire or powder form, and several non-product plastic samples. The extraction 

test methods used were the same methods used to evaluate lead content and lead extraction from 

children’s metal jewelry.

The limited data on extraction of cadmium from jewelry items show that, like lead, there is no 

strict relationship between cadmium content and cadmium solubility. However, for many 

samples, those with higher total cadmium content generally had higher levels of extraction. The 

staff did not collect as much data for cadmium-containing jewelry as is available for the leadcontaining samples. Thus, the staff does not have data on the extraction of cadmium over time 

from electroplated jewelry samples. 

Data from testing cadmium-containing alloys that were not electroplated or coated show 

proportionally increasing extraction of cadmium over time. The staff would hypothesize that the 

presence of electroplating would have resulted in initially low levels of extraction, followed by 

increasingly higher amounts of extraction, but this cannot be shown at this time.

As with the testing of plastic for lead migration, cadmium extraction from plastics was 

considerably less than extraction from metals. Again, an extraction limit for cadmium from 

children’s products has not been defined. Therefore, the staff cannot conclude whether cadmium 

leaching from plastic items would be excessive or not.

Toy Standards: ASTM F963, EN71-3

The ASTM International Standard Consumer Safety Specification for Toy Safety (ASTM F963) 

covers migratable (i.e., soluble, leachable) elements from paints and coatings on toys, with a 

specific test method.

The current European Standard Safety of Toys-Part 3: Migration of certain elements (EN 71-

3:1994) covers any toy material, clay, and finger paint, in addition to paints and coatings, with 

specified test methods. Thus, the materials included in the scope of EN 71-3 exceed the scope of 

ASTM F963. However, EN 71-3 does not apply to all toys. This standard is for toys that are 

likely to be sucked, licked, or swallowed, especially toys for children up to age six years, as well 

as cosmetic toys, writing instrument toys, and toys for food contact. Jewelry is not included in 

the scope of either the ASTM or EN standard, except for toy jewelry. Children’s jewelry is 

generally not toy jewelry. Staff is not aware of a European standard for jewelry, except for the 

nickel directive5

Except for the differences in scope, the two standards have similarities. Both standards include 

requirements for migratable chemicals, not total chemical content. The test methods in both 

indicate that certain types of materials are to be ground or homogenized, such as paints and 

coatings. In EN 71-3, some materials are extracted whole, such as glass/ceramic/metallic 

materials, if the toy or component fits entirely within the small parts cylinder. Both standards 

indicate the amount of material to be tested, how the test material is to be prepared, the amount 

of acid to be used for the test, and other details for different materials; but generally, the test 

methods are similar, and the migration limits are the same.

, which restricts the amount of nickel that may contact skin due to the potential 

for health effects from sensitization.

 5 Directive 2004/96/EC of the European Parliament and of the Council of 27 September 2004 amending Council Directive 

76/769/EEC as regards restrictions on the marketing and use of nickel for piercing post assemblies for the purpose of adapting its 

Annex I to technical progress.
6

A key aspect of the methods in both standards that differs significantly from the CPSC staff 

approach to evaluating certain products for the presence of a chemical hazard is that the 

extraction period in the toy standards is two hours. In contrast, CPSC staff typically uses an 

extraction period of at least six hours. 

The basis of EN 71-3 is that a child is assumed to have an average daily intake (ingestion) of toy 

material of 8 milligrams (mg) per day. The standard acknowledges that in certain individual 

cases this figure might be exceeded. CPSC staff believes that the 8 mg/day assumption might be 

reasonable for paints and coatings, or materials that can be scraped off or that break up into small 

bits. As the language of the standard acknowledges, this level of ingestion could be exceeded in 

some cases.

To understand the implications of conditions of a test, consider the case of ingestion of small 

amounts of a toy material, such as paint or other scrapings or small bits. In this case, a two-hour 

extraction period may reasonably indicate whether excess leaching might occur. For such small 

bits, we might expect that ingestion would be followed by a relatively normal rate of elimination 

from the body as the small scrapings or pieces become mixed up in food and are transported 

through the gastrointestinal tract. Even if such small bits were not eliminated from the body 

within a day or two, as is the typical transit time for food, the exposure to chemicals that might 

migrate from the ingested materials is limited by the small size of the particles.

On the other hand, items such as the glass/ceramic/metallic components that fit within the small 

parts cylinder and are tested intact, or any other item that is ingested as a piece rather than as a 

scraping or small bit, generally are considerably larger than 8 mg, with mass perhaps up to about 

5 grams. These large items might remain in the stomach or GI tract for longer periods of time. 

As we learned from the jewelry ingestion cases, and from a report in the literature on ingested 

foreign bodies (Mcgregor and Ferguson 1998), an object may remain in the body for days or 

weeks. For these larger objects, a two-hour test may not be adequate to determine whether 

excessive leaching might occur. On the other hand, for certain materials such as glass, a longer 

extraction time may not result in significantly more leaching than a shorter time. This is because 

some materials are not susceptible to dissolving under the test conditions of the standards, and 

only chemicals at the immediate surface of the product are available for leaching. 

Another reason that the shorter test might not be appropriate for some products is that plating or 

coating, if present on the product or component, could initially block the migration of the 

elements. Again, from the staff’s jewelry investigations, we know that such coatings will 

eventually weaken and allow the acid to reach the underlying material. In these cases, leaching 

would be evident only after several hours in the acid solution.

New EU standard 

There is a new EU toy safety directive6

 6 Directive 2009/48/EC of the European Parliament and of the Council of 18 June 2009 on the safety of toys.

that will result in significant changes in the EN 71-3

migration of elements standard. The new requirements for chemicals in toys are to go into effect 

in 2013. The exact form of the new standard is not known, since some of the details for 

implementing the new directive need to be worked out. However, the new standard will include 

a ban of certain fragrance chemicals and restrictions on chemicals that are carcinogenic, 

mutagenic, or reproductive toxicants; it adds more elements to the migration standard, sets 
7

different migration limits for the elements that are in the current standard, and sets different 

migration limits for different types of materials. The staff has not yet evaluated the 

appropriateness of including the additional chemicals, or the revised migration limits, and cannot 

address methods that are not yet available. It is not clear to staff at this point if the scope of 

products or materials covered by the standard will change, or whether the test methods will be 

significantly revised. The staff does not know when the revised standard will be available.

Conclusion

Considering the available data on small swallowable metal jewelry items and the information 

about children’s ingestion of small objects, including cases of serious adverse effects and death 

from the chemical content of some of the items, the staff has concerns about the appropriateness 

of the two-hour solubility test in both the ASTM F963 and EN 71-3 toy safety standards. 

Because an ingested foreign body may remain in the gastrointestinal tract for extended periods of 

time, and some materials are susceptible to excessive leaching of chemicals in the acid 

conditions of the stomach, the two-hour test may not identify products that could lead to excess 

exposure. As demonstrated with the results of the staff’s testing of lead- or cadmium-containing 

jewelry and metal alloys, increasing the length of time in an acidic solution generally results in 

increasing solubility of the chemicals from products. Therefore, for small, swallowable items, 

especially metal items, the staff preliminarily recommends that the test procedure be carried out 

for 24 hours.
8

References

CDC (Centers for Disease Control and Prevention) (2005) Blood Lead Levels – United States, 

1999-2002. MMWR 54(20): 513-516.

CDC (Centers for Disease Control and Prevention) (2006) Death of a child after ingestion of a 

metallic charm – Minnesota, 2006. MMWR 55(Dispatch): 1-2.

Durback LF, Wedin GP, Seidler DE (1989) Management of lead foreign body ingestion. J 

Toxicol Clin Toxicol 27(3): 173-82.

Fergusson J, Malecky G, Simpson E (1997) Lead foreign body ingestion in children. J Paediatr 

Child Health 33: 542-544.

Greensher J, Mofenson HC, Balakrishnan C, Aleem A (1974) Lead poisoning from ingestion of 

lead shot. Pediatrics 54(5): 641-643.

Hugelmeyer CD, Moorhead JC, Horenblas L, Bayer MJ (1988) Fatal lead encephalopathy 

following foreign body ingestion: case report. J Emerg Med 6(5): 397-400.

Macgregor D, Ferguson J (1998) Foreign body ingestion in children: an audit of transit time. J 

Accid Emerg Med 15: 371-373.

Mowad E, Haddad I, Gemmel DJ (1998) Management of lead poisoning from ingested fishing 

sinkers. Arch Pediatr Adolesc Med 152(5): 485-488.

Sprinkle JD, Hingsbergen EA (1995) Retained foreign body: associations with elevated lead 

levels, pica, and duodenal anomaly. Pediatr Radiol 25(7): 528-529.

VanArsdale JL, Leiker RD, Kohn M, Merritt TA, Horowitz BZ (2004) Lead poisoning from a 

toy necklace. Pediatrics 114(4): 1096-1099.
9

TAB A: Summary of Test Results for Lead in Children’s 

Metal Jewelry T

A

B 

A
UNITED STATES

CONSUMER PRODUCT SAFETY COMMISSION

4330 EAST WEST HIGHWAY

BETHESDA, MARYLAND 20814

Memorandum

CPSC Hotline: 1-800-638-CPSC(2772) CPSC's Web Site: http://www.cpsc.gov

Date: Aug 1, 2007

TO : Kristina M. Hatlelid, Ph.D., M.P.H., Toxicologist, Directorate for Health 

Sciences 

THROUGH: Andrew G. Stadnik, P.E., Associate Executive Director, Directorate for 

Laboratory Sciences

Joel R. Recht, Ph.D., Director, Division of Chemistry, Directorate for 

Laboratory Sciences

FROM : David Cobb, Chemist, Division of Chemistry, Directorate for Laboratory 

Sciences

SUBJECT : Summary of Test Results for Lead in Children’s Metal Jewelry1,2

Summary: 

This memorandum provides a summary of the test results of U.S. Consumer Product 

Safety Commission (CPSC) staff testing for lead (Pb) in children’s metal jewelry in fiscal year 

2007. The CPSC Directorate for Laboratory Sciences (LS), Division of Chemistry (LSC) staff 

has analyzed 384 children’s metal jewelry items from 104 official compliance samples and 73 

non-metal items such as plastic and crystal from 27 official compliance samples. There were 

198 metal items tested that had total lead of 0.06% or more. In general, the staff notes that by 

visual inspection or XRF (data not shown), the metal items and components were finished with 

non-lead metallic coatings or platings, e.g., copper, nickel. While the integrity of such coatings 

was not specifically evaluated, the data show that coatings do not necessarily prevent 

accessibility of lead from the item. 

Background:

Under the Federal Hazardous Substances Act (FHSA), 15 U.S.C. 1261(f)(1), children’s 

metal jewelry items that expose children to hazardous quantities of lead under reasonably 

foreseeable conditions of handling or use are banned hazardous substances. In 2005, CPSC’s 

Office of Compliance issued an Interim Enforcement Policy for Children’s Metal Jewelry 

 1

These comments are those of the CPSC staff, have not been reviewed or approved by, and may not necessarily reflect the views 

of, the Commission.

2 Note this document was initially prepared in 2007 as part of a briefing package considering a ban on lead in children’s metal 

jewelry, and does not reflect changes due to the enactment of the Consumer Product Safety Improvement Act of 2008 (CPSIA) 

and other later changes. Current testing methods and summaries of regulations for lead in children’s products according to the 

CPSIA can be found at http://www.cpsc.gov/about/cpsia/sect101.html
11

Containing Lead for manufacturers, importers, and retailers.3 The policy was accompanied by a 

two part testing procedure.4

Test Method:

 The procedure calls for the determination of the total lead content of 

a metal jewelry item by a specified method. Distinct metal component items within a jewelry 

sample, such as pendants, hooks, or beads are tested separately for total and accessible lead. If 

the total lead in a metal jewelry item is more than 0.06%, then an acid extraction for 6 hours is 

conducted by a second specified method. Metal jewelry with more than 175 μg of accessible 

lead by this method is subject to further review for age grading, and other risk factors and a risk 

assessment may result in enforcement action. Non-metal jewelry is not addressed in the Interim 

Enforcement Policy, but is subject to the FHSA.

Total Lead in Metal

The current test method4 for total lead is based on methodology found in Canada Product 

Bureau Method C-02.4, and has been used for samples analyzed since December 2004. This 

method requires that the aliquots be ground into small particles to increase the rate of dissolution, 

and the procedure also contains a step for adding hydrochloric acid to assist in dissolving certain 

metal alloys.

Total Lead in Plastic

Plastic items were ashed in a muffle furnace at 600°C. 10-50 mg aliquots of the ashen 

item were dissolved in 2-3 ml of nitric acid on a hot plate. The digests were analyzed using 

inductively coupled plasma atomic emission spectroscopy (ICP) to determine lead content.

Total Lead in Crystal

Aliquots of crystal items were microwave digested with 2 ml of nitric acid and 1 ml of 

hydrofluoric acid. The digests were diluted with 4% boric acid to neutralize any free fluoride 

and analyzed by ICP to determine lead content. 

Accessible Lead

The acid extraction test method4 for accessible lead calls for an acid extraction that 

simulates exposure to metal that is ingested into the alimentary tract. The acid extraction 

involves placing an intact jewelry item in 0.07N hydrochloric acid (HCl) at 37°C for 6 hours. 

This procedure is based on methodology found in ASTM C927, C738, D5517, and F963. 

Extended acid extractions to 24 hours were performed on metal items. Plastic and crystal items 

were extracted with 0.07N HCl at 37°C for up to 48 hours.

 3

Interim Enforcement Policy for Children’s Metal Jewelry Containing Lead - 2/3/2005.

4

CPSC Standard Operating Procedure for Determining Lead (Pb) and Its Availability in Children’s Metal Jewelry 2/3/05, 

http://www.cpsc.gov/businfo/pbjeweltest.pdf.
12

RESULTS AND DISCUSSION:

The test results for the samples are contained in Tables 1 and 2. The results showed that 

197 out of 381 metal items tested (52%) had total lead of 0.06% or more. Acid extractions were 

done on 378 metal items; for the 197 items that had more than 0.06% total lead that were tested 

for accessible lead, 110 (56%) of those items had accessible lead greater than 175μg after 6 

hours, and 125 (63%) had accessible lead greater than 175μg after 24 hours. Of the 218 metal 

items that had less than 10% total lead, 6 of those had accessible lead greater than 175μg after 6 

hours, 10 had greater than 175μg after 24 hours. One item that had less than 0.06% total lead 

had accessible lead greater than 175μg after 24 hours.

Increasing the extraction time for metal items from 6 hours to 24 hours showed an increase 

in the proportion of products with accessible lead greater than 175 μg. The results also showed

that the levels of accessible lead were much higher after 24 hours compared to 6 hours. The 

average 24 hour accessible lead (8183μg) was about 5 times as large as the average 6 hour 

accessible lead (1564μg).

There were 71 non metal items tested. Crystal accounted for 31 of those items. Some of 

the crystal items had total lead up to 25%, but none of the crystal items had extractable lead 

greater than 175μg. Plastic items accounted for most of the remainder of the items tested. Only 

polyvinyl chlorine (PVC) types of plastics had significant total lead. There were 9 PVC plastic 

items tested with lead levels up to 0.8%. Four of these items, with extractable lead results

greater than 175μg after 48 hours of testing, were relatively large necklace cords or collars, 

weighing several grams.
13

Table 1. Metal Jewelry Results

Sample Sub Sample

Type Parts Weight 

(grams)

% Pb

μg of Pb extracted Total Extractable 

Pb, μg

Acid Extraction Time (hour) 1+2+3 = 

6 

1+2+3+

18=24

1.0 2.0 3.0 18

06-810-3976 3 necklace chain 0.015

06-810-3976 3 necklace

teardrop 

pendant 96.2

06-810-3976 3 necklace hook 98.7

06-810-3976 3 necklace heart pendant 97.8

06-810-3976 4 necklace chain 0.38 2.5 0.4 0.0 0.9 2.9 3.8

06-810-3976 4 necklace

teardrop 

pendant 0.38(2) 494 684 659 8265 1838 10103

06-810-3976 4 necklace hook 0.68 1207 1030 1203 7276 3440 10717

06-810-3976 4 necklace heart pendant 5.04 5.0 12.6 47.9 3150 65.5 3216

06-810-3976 5 necklace chain 0.38 2.3 0.8 0.6 1.1 3.7 4.8

06-810-3976 5 necklace

teardrop 

pendant 0.42(2) 466 735 1014 7476 2215 9691

06-810-3976 5 necklace hook 0.66 544 1052 1065 1019 2663 3683

06-810-3976 5 necklace heart pendant 5.18 12.9 5.2 20.7 1347 38.8 1386

06-810-3976 6 necklace chain 0.002

06-810-3976 6 necklace

teardrop 

pendant 99.2

06-810-3976 6 necklace hook 87.3

06-810-3976 6 necklace heart pendant 93.5

06-840-7517 1 anklet charm 3.3 87.6 892 1685 3143 23362 5720 29082

06-840-7517 2 anklet charm 3.1 80.9 405 766 1279 17658 2450 20108

06-840-7642 3 bracelet charm 2.69 0.44 7.7 0.5 0.4 9.0 8.6 17.6

06-840-7642 4 bracelet charm 2.57 0.43 5.8 2.3 4.6 5.1 12.8 17.9

07-810-4655 3 Necklace Charm back 6.615 95.3 31.8 65.9 98.3 7259 196 7455

07-810-4655 6 Necklace Charm back 5.867 92.1 750 1202 3168 36372 5120 41492

07-302-0045 1 necklace pendant 5.55 25.1 6936 14238 22312 104706 43486 148192

07-302-0046 1 necklace cross pendant 4.64 44.2 559 988 1791 15776 3338 19114

07-302-0046 1 necklace

cross pendant 

clasp 3.5

07-302-0046 1 necklace star pendant 4.18 44.4 62.7 130 234 1521 426 1948

07-302-0046 1 necklace

star pendant 

clasp 42.5

07-302-0075

1 key chain pendant 20.32 0.023 0.0 0.0 0.0 0.0

07-302-0075

2 key chain pendant 20.38 0.068 17.4 0.0 0.0 0.0

07-302-0075 3 key chain pendant 20.10 0.025 43.0 0.0 0.0 0.0

07-302-0075 4 key chain pendant 20.89 4.27 226 284 356 1569 866 2435

07-302-0075 5 key chain pendant 21.88 0.121 118 0.0 0.0 118

07-302-0075 6 key chain pendant 20.81 0.131 0.0 0.0 0.0 0.0

07-302-0075 4 key chain chain 3.50 0.235 2.0 0.0 0.0 1199 2.0 1201

07-302-0075 5 key chain chain 3.47 0.009 2.7 2.0 0.0 407 4.7 412
14

Sample Sub Sample

Type Parts Weight 

(grams)

% Pb

μg of Pb extracted

Total Extractable 

Pb, μg

Acid Extraction Time (hour) 1+2+3 

= 6 

1+2+3+18

=24

1.0 2.0 3.0 18

07-302-0075 4 key chain key ring 3.92 10.8 2.6 0.0 236 13.4 249

07-302-0075 5 key chain key ring 3.92 3.1 0.0 0.0 46.5 3.1 49.6

07-302-0075 6 key chain key ring 0.008

07-302-0075 6 key chain key ring 0.002

07-302-0093 1 Token Token 16.208 0.0 0.0 8.3 11865 8.3 11874

07-302-0093 6 Token Token 14.808 0.0 0.0 0.0 12.1 0.0 12.1

07-302-3734 1 Ring 0.576 76.9 253 418 758 2678 1429 4107

07-302-3734 2 Ring 0.622 55.5 587 1189 1523 7239 3299 10538

07-810-1371 1 necklace hook 4.46 0.229 16.8 2.8 0.4 2.6 20.0 22.6

07-810-1371 1 necklace Clasp 1.16 84.4 2820 1906 2834 18854 7560 26414

07-810-1371 1 necklace pendant 0.011

07-810-1371 2 necklace hook 4.71 0.026 2.7 0.5 0.5 0.3 3.7 4.0

07-810-1371 2 necklace Clasp 1.33 95.7 918 1471 2021 11990 4410 16401

07-810-1371 2 necklace pendant 0.01

07-810-1372 1 Ring 8.82 0.003 3.8 2.1 0.0 1.5 5.9 7.4

07-810-1372 2 Ring 5.6 0.001 1.8 1.5 0.5 0.0 3.8 3.8

07-810-4100 1 bracelet 4.02 0.01 0.0 0.0 0.0 0.0 0.0 0.0

07-810-4100 2 bracelet 4.7 0.043 0.0 0.0 4.7 9.4 4.7 14.1

07-810-4126 1 key chain charm 22.6 100 1021 2863 5396 92950 9280 102230

07-810-4126 2 key chain charm 22 96.4 921 2245 3390 67779 6556 74335

07-810-4127 1 Ring 9.16 77.9 257 540 5083 875 5959

07-810-4127 2 Ring 88.5

07-810-4127 4 Ring 90.5

07-810-4127 5 ring 11.97 186 496 797 7727 1474 9201

07-810-4172 1 necklace hook 0.4739 0.062 0.8 0.7 0.0 1.5 1.6 3.1

07-810-4172 1 necklace pendant-lock 0.4279 0.008 0.2 0.0 0.0 0.0 0.2 0.3

07-810-4172 1 necklace pendant-heart 0.7316 0.075 19.1 0.0 0.0 1.3 19.1 20.4

07-810-4172 2 necklace hook 0.4222 0.107 9.1 1.3 0.7 2.1 11.1 13.2

07-810-4172 2 necklace pendant-lock 0.4496 0.007 31.0 1.9 0.2 0.9 33.1 34.0

07-810-4172 2 necklace pendant-heart 0.6730 0.038 0.2 0.0 0.0 0.0 0.2 0.2

07-810-4173 1 necklace hook 0.4 0.062 15.9 31.6 0.7 0.6 48.2 48.8

07-810-4173 1 necklace Pendant 1.815 0.004 8.0 0.2 0.0 0.0 8.1 8.1

07-810-4173 1 necklace

Pearl earringsetting 0.124 0.001 0.9 13.8 5.7 0.4 20.5 20.9

07-810-4173 2 necklace hook 0.4631 0.072 20.5 1.4 0.9 1.1 22.9 23.9

07-810-4173 2 necklace Pendant-metal 1.475 0.022 55.8 12.1 12.1 1.8 80.0 81.8

07-810-4173 2 necklace

“diamond” 

earring-setting 0.4082 0.032 15.9 0.2 0.0 0.1 16.1 16.2

07-810-4173 2 necklace

Pearl earringsetting 0.1762 0.015 39.2 22.8 10.6 4.0 72.7 76.7
15

Sample Sub Sample

Type Parts Weight 

(grams)

% Pb

μg of Pb extracted

Total Extractable 

Pb, μg

Acid Extraction Time (hour) 1+2+3 

= 6 

1+2+3+18

=24

1 2 3 18

07-810-4294 1 Ring dark blue stone 1.76 65.1 110 176 1548 351 1899

07-810-4294 2 Ring dark blue stone 92.5

07-810-4294 3 Ring blue stone 2.09 81.2 18.9 108 288 4084 415 4499

07-810-4294 3 Ring no stone 1.6 71.9 53.6 103 169 952 326 1278

07-810-4294 4 Ring no stone 0.68 0.031 1.4 1.0 2.0 23.1 4.4 27.5

07-810-4294 5 Ring green stone 1.19 68.9 6.0 0.0 3.6 49.2 9.6 58.8

07-810-4294 5 Ring pink stone 1.79 80.5 0.0 0.0 9.0 388 9.0 397

07-810-4294 5 Ring blue stone 1.92 73.7 82.6 280 720 5260 1083 6344

07-810-4294 6 Ring

no stone/thin 

ban 1.8 75.9 3.6 24.3 70.2 1863 98.1 1961

07-810-4470 1 necklace pendant 13.36 0.004 0.0 0.0 0.0 7.3 0.0 7.3

07-810-4470 1 necklace hook 0.49 0.009 0.7 0.0 0.0 1.2 0.7 1.9

07-810-4470 1 necklace

tear drop 

charm 0.17 4.15 0.1 0.1 0.1 86.4 0.3 86.7

07-810-4470 3 necklace pendant 13.39 0.004 0.0 0.0 14.4 6.1 14.4 20.5

07-810-4470 3 necklace hook 0.49 0.011 0.3 0.5 1.5 2.0 2.3 4.3

07-810-4470 3 necklace

tear drop 

charm 0.17 3.71 0.0 0.2 0.0 3.4 0.2 3.6

07-810-4471 1 zipper pull 0.02 4.37 9.4 2.0 0.0 0.0 11.4 11.4

07-810-4471 1 zipper hook 0.007 0.71 15.9 25.7 30.3 23.1 71.9 95.0

07-810-4471 4 zipper pull 0.023 4.35 7.7 2.8 2.1 2.4 12.6 15.0

07-810-4471 4 zipper hook 0.012 0.65 0.0 0.0 0.0 4.5 0.0 4.5

07-810-4471 5 zipper pull 0.153 4.37 4.0 0.0 0.0 3.0 4.0 7.0

07-810-4471 5 zipper hook 0.012 0.72 13.7 22.5 32.2 51.0 68.4 119

07-810-4502 3 necklace charm 9.529 0.037 0.0 0.0 0.0 0.0 0.0 0.0

07-810-4502 3 hook 0.477 0.022 0.2 0.0 0.0 0.0 0.2 0.2

07-810-4502 6 charm 9.626 0.01 0.0 0.0 0.0 0.0 0.0 0.0

07-810-4502 6 hook 0.023 0.0 0.0 0.0 2.2 0.0 2.2

07-810-4502

3 and 

6 tear drops 0.304 4.48 1.8 0.1 0.6 344 2.5 346

07-810-4519 1 bracelet pendant 11.37 1829 2891 6248 77362 10968 88330

07-810-4519 1 bracelet hook 1.11 957 2244 3481 22600 6682 29282

07-810-4519 2 bracelet pendant 10.38 296 270 441 8874 1007 9882

07-810-4519 2 bracelet hook 1.08 643 2214 4358 32098 7214 39312

07-810-4519 3 bracelet pendant 10.98 102 115 225 1290 1631

07-810-4519 3 bracelet hook 83.6

07-810-4519 4 bracelet pendant 11.2 90.6 5.6 28.0 89.6 123

07-810-4519 5 bracelet pendant 97.4 475 520 6817 1676

07-810-4519 5 bracelet hook 11.43 92.4

07-810-4519 6 bracelet pendant 10.77 91.3 0.0 21.6 64.7 86.3

07-810-4599 4 Ring 1.9 0.01 0.0 0.0 0.0 3.8 0.0 0.0

07-810-4599 5 Ring 0.31 0.001 1.1 0.0 0.0 0.0 1.1 0.0
16

Sample Sub Sample

Type Parts Weight 

(grams)

% Pb

μg of Pb extracted

Total Extractable 

Pb, μg

Acid Extraction Time (hour) 1+2+3 = 

6 

1+2+3+

18=24

1 2 3 18

07-810-4600 1 Ring 1.799 0.063

07-810-4600 3 Ring 1.557 0.076

07-810-4601 3 Bracelet 0.0 0.0 0.0 0.0 0.0 0.0

07-810-4601 6 Bracelet 0.0 0.0 0.0 0.0 0.0 0.0

07-810-4654 1 ring 13.48 3321 4252 5042 28552 12622 41175

07-810-4654 2 ring 80.2

07-810-4654 5 ring 12.71 1794 2620 2932 13546 7339 20886

07-810-4654 6 ring 85.5

07-810-4655 3 necklace charm 6.615 95.3 31.8 65.9 98.3 7259 196 7455

07-810-4655 6 necklace charm 5.867 92.1 750 1202 5120 34419 7072 41491

07-810-4656 1 necklace Clasp 0.4136 65.6

07-810-4656 2 necklace Clasp 0.439 68.0

07-810-4656 3 necklace Pendant (pink) 0.808

07-810-4656 3 necklace Clasp 536 758 1128 7242 2421 9664

07-810-4656 4 necklace Pendant (pink) 4.9 1.5 0.3 0.9 6.7 7.6

07-810-4656 4 necklace Clasp 459 623 1203 6730 2285 9015

07-810-4656 5 necklace Pendant (blue) 1.9 0.6 0.4 2.2 2.9 5.1

07-810-4656 6 necklace Pendant (blue) 0.192

07-810-4674 1 necklace pendant 1.82 0.05 0.0 0.0 0.0 0.0 0.0 0.0

07-810-4674 1 necklace hook 0.16 0.012 0.2 0.0 0.0 0.2 0.2 0.4

07-810-4674 2 necklace pendant 1.84 0.068 0.9 0.0 0.0 0.0 0.9 0.9

07-810-4674 2 necklace hook 0.16 0.017 0.2 0.0 0.0 0.5 0.2 0.7

07-810-4675 1 necklace pendant 5.373 3.7 0.6 1.4 3.9 5.7 9.2

07-810-4675 1 necklace hook 0.177 0.1 0.1 0.0 0.0 0.2 0.2

07-810-4675 2 necklace pendant 5.333 1.7 1.4 0.0 2.6 3.1 8.2

07-810-4675 2 necklace hook 0.171 0.0 0.1 0.0 0.0 0.1 0.2

07-810-4675 4 necklace pendant 5.14 0.02

07-810-4675 4 necklace hook 0.174 0.015

07-810-4675 5 necklace pendant 5.28 0.198

07-810-4675 5 necklace hook 0.166 0.014

07-810-4703 2 necklace Hook 0.557 81.7 263 709 1180 11085 2152 13237

07-810-4703 2 necklace pendant 3.274 77.6 616 1028 1634 16926 3278 20204

07-810-4703 3 necklace Hook 0.537 72.2 979 2037 2485 20878 5501 26379

07-810-4703 3 necklace pendant 3.037 75.5 1427 2544 4189 21535 8160 29695

07-810-4704 3 necklace Hook 0.514 76.2 584 1446 2289 17316 4319 21635

07-810-4704 3 necklace pendant 2.964 92.1 244 52.0 57.0 846 353 1199

07-810-4704 4 necklace Hook 0.587 70.3 572 1629 2608 18961 4809 23770

07-810-4704 4 necklace pendant 2.345 89.8 52.0 14.0 25.0 198 91.0 289

07-810-4705 1 necklace Hook 0.572 91.6 572 1404 2228 17058 4204 21262

07-810-4705 1 necklace pendant 2.471 86.9 14.0 42.0 24.0 2198 80.0 2278

07-810-4705 2 necklace Hook 0.581 85.6 1189 2958 5352 22800 9499 32299
17

Sample Sub Sample

Type Parts Weight 

(grams)

% Pb

μg of Pb extracted

Total Extractable 

Pb, μg

Acid Extraction Time (hour)

1+2+3 

= 6 

1+2+3+18

=24

1 2 3 18

07-810-4705 2 necklace pendant 2.184 79.9 133 42.0 53.0 1853 228 2081

07-810-4711 4 earring metal 1.058 0.049 8.4 3.3 2.5 2.5 14.2 16.7

07-810-4711 5 earring metal 1.426 0.051 6.5 6.1 5.2 4.4 17.8 22.2

07-810-4724 6

hair clip, 

green 0.001

07-810-4724 6

hair clip, 

purple 0.003

07-810-4724 6 hair clip, red 0.529 0.3 0.0 0.0 0.5 0.3 0.8

07-810-4724 6

hair clip, 

yellow 0.547 0.0 0.0 0.0 0.5 0.0 0.5

07-810-4725 1 pin 11.02 88.4 334 1303 7660 90173 9297 99471

07-810-4725 3 pin 10.94 90.1 440 1142 3881 66501 5463 71964

07-810-4946 1 anklet pendant 3.18 53.4 448 1217 3070 17505 4734 22240

07-810-4946 3 anklet pendant 3.16 50.5 1821 3197 6849 35960 11867 47828

07-810-4946 5 anklet pendant 2.58 16.5 90.7 166 377 7424 634 8058

07-810-4946 6 anklet pendant 2.86 54.7 28.1 111.4 224.5 8375 364 8739

07-810-4947 3 Bracelet Connector 0.1209 0.010 0.1 0.1 0.1 0.1 0.4 0.5

07-810-4947 3 Pendant 1 0.9423 0.201 0.5 0.3 0.4 1.0 1.2 2.2

07-810-4947 3 Pendant 2 1.1407 0.100 2.0 0.9 0.7 0.4 3.6 3.9

07-810-4947 5 Connector 0.1213 0.013 0.2 0.1 0.1 0.3 0.4 0.7

07-810-4947 5 Pendant 1 0.8961 0.481 0.4 0.3 0.4 0.8 1.2 2.0

07-810-4947 5 Pendant 2 1.3189 0.104 0.8 0.4 0.4 0.3 1.6 1.9

07-810-4948 2 Bracelet charm, P 1.064 0.059 2.9 0.0 0.0 0.0 2.9 2.9

07-810-4948 2 charm, S 1.035 0.093 0.0 0.0 0.0 0.0 0.0 0.0

07-810-4948 4 charm, P 1.081 0.077 0.0 0.0 0.0 0.0 0.0 0.0

07-810-4948 4 charm, S 1.151 0.046 4.7 0.0 0.0 0.0 4.7 4.7

07-810-5001 1 kit chain 3.11 0.04 64.4 5.8 2.0 0.5 72.2 72.7

07-810-5001 1 kit hook 0.495 0.017 1.1 0.3 0.2 0.3 1.6 1.9

07-810-5001 1 kit charm-bag 0.872 0.019 0.2 0.2 1.5 0.2 1.9 2.1

07-810-5001 1 kit charm-dog 0.997 0.017 0.2 0.2 0.3 0.0 0.6 0.7

07-810-5001 2 kit chain 3.301 0.006 5.7 1.5 0.2 0.0 7.4 7.4

07-810-5001 2 kit hook 0.485 0.024 0.5 0.4 0.5 0.5 1.3 1.8

07-810-5001 2 kit charm-bag 0.758 0.013 0.4 3.0 0.6 0.1 3.9 4.1

07-810-5001 2 kit charm-dog 0.933 0.009 1.2 0.3 0.2 0.3 1.7 2.0

07-810-5002 1 necklace pendant 1.505 79.5 33.1 75.3 98.0 1625 206 1832

07-810-5002 1 necklace hook 0.188 0.018 0.0 0.2 0.0 0.1 0.2 0.3

07-810-5002 5 necklace pendant 1.37 74 161 227 302 1506 691 2197

07-810-5002 5 necklace hook 0.186 0.255 0.0 0.0 0.0 0.5 0.0 0.5

07-810-5027 3 earring 0.024

07-810-5027 4 necklace chain 1.24 0.007 0.0 0.0 0.0 0.0 0.0 0.0

07-810-5027 4 necklace pendant 1.93 0.011 0.0 0.0 0.0 0.0 0.0 0.0

07-810-5027 4 necklace hook 0.27 0.016 0.0 0.0 0.0 0.3 0.0 0.3

07-810-5027 4 earring 0.44 0.2 0.0 0.0 0.0 0.2 0.2
18

Sample Sub Sample

Type Parts Weight 

(grams)

% Pb

μg of Pb extracted

Total Extractable 

Pb, μg

Acid Extraction Time (hour) 1+2+3 

= 6 

1+2+3+18

=24

1 2 3 18

07-810-5027 6 necklace pendant 1.79 0.023 0.0 0.0 0.0 0.0 0.0 0.0

07-810-5027 6 necklace hook 0.25 0 0.4 0.0 0.0 0.0 0.4 0.4

07-810-5027 6 earring 0.4 0.011 0.0 0.6 0.0 0.2 0.6 0.8

07-810-5028 1 necklace charm 0.021

07-810-5028 1 necklace hook 85.5

07-810-5028 2 necklace charm 0.041

07-810-5028 2 necklace hook 0.021

07-810-5028 4 necklace charm 2.24 0.159 1.2 0.0 0.0 0.0 1.2 1.2

07-810-5028 4 necklace hook 0.49 0.045 0.4 0.3 0.0 0.0 0.7 0.7

07-810-5028 5 necklace hook 0.75 94.5 249 583 1105 9331 1937 11269

07-810-5028 6 necklace charm 1.93 0.041 0.0 0.0 0.0 0.0 0.0 0.0

07-810-5028 6 necklace hook 0.49 0.027 0.0 0.0 0.0 0.0 0.0 0.0

07-810-5032 1

spring 

bracelet 2.580 0.003 0.0 0.0 0.0 0.0 0.0 0.0

07-810-5032 5

spring 

bracelet 2.618 0.002 0.0 0.0 0.0 0.0 0.0 0.0

07-810-5033 2 metal ring 1.3285 0.003 0.0 0.0 0.0 0.0 0.0 0.0

07-810-5033 5 metal ring 2.3045 0.015 0.0 0.0 0.0 0.0 0.0 0.0

07-810-5035 3 necklace charm 0.721 0.101 55.1 0.0 0.0 0.9 55.1 56.0

07-810-5035 6 necklace charm 0.653 0.085 190.5 5.2 1.8 4.6 198 202

07-810-5121 4 necklace pendant 7.1 81.92 32.0 5.3 17.4 73591 54.7 73646

07-810-5121 4 necklace hook 0.77 85.7 947 2214 2566 23251 5727 28979

07-810-5121 6 necklace pendant 7.36 84.67 475 310 379.4 40443 1164 41608

07-810-5121 6 necklace hook 0.61 82.28 976 1879 1190 3128 4045 7174

07-810-5122 5 ring 0.006 0.0 0.0 0.0 0.0 0.0 0.0

07-810-5122 6 ring 0.008 0.0 33.0 33.0

07-810-5126 2 necklace chain 3.62 0.005 0.0 0.0 1.9 9.4 1.9 11.3

07-810-5126 5 necklace chain 2.81 0.012 0.0 0.0 1.5 6.9 1.5 8.4

07-810-5126 5 necklace pendant 2 0.004 0.0 0.0 0.0 2.5 0.0 2.5

07-810-5127 1 ring 1.88 0.005 0.0 0.0 0.0 5.9 0.0 5.9

07-810-5127 6 ring 2.91 0.005 0.0 0.0 0.0 0.0 0.0 0.0

07-810-5128 2 necklace pendant 0.996 0.017 0.0 0.8 0.5 1.3 1.3

07-810-5128 3 necklace pendant 1.081 0.004 2.6 2.6 1.7 4.8 6.9 11.7

07-810-5128 4 necklace pendant 1.187 0.006 0.7 1.0 1.1 3.6 2.8 6.4

07-810-5128 5 necklace pendant 0.872 0.008 0.0 0.4 0.7 1.9 1.1 3.0

07-810-5176 1 necklace

key shaped 

pendant 0.004

07-810-5176 1 necklace

heart shaped 

pendant 0.001

07-810-5176 1 necklace

crown shaped 

pendant 0.002

07-810-5176 4 necklace

key shaped 

pendant 0.539 0.029 0.3 0.3 0.3 0.3 0.9 1.2
19

Sample Sub Sample

Type Parts Weight 

(grams)

% Pb

μg of Pb extracted

Total Extractable 

Pb, μg

Acid Extraction Time (hour)

1+2+3 

= 6 

1+2+3+18

=24

1 2 3 18

07-810-5176 4 necklace

heart shaped 

pendant 0.394 0.003 0.2 0.2 0.2 0.5 0.6 1.1

07-810-5176 4 necklace

crown shaped 

pendant 1.099 0 0.5 1.0 0.3 0.6 1.8 2.4

07-810-5176 6 necklace

key shaped 

pendant 0.561 0.0 0.0 0.0 0.0 0.0 0.0

07-810-5176 6 necklace

heart shaped 

pendant 0.396 0.0 0.2 0.0 0.5 0.2 0.7

07-810-5176 6 necklace

crown shaped 

pendant 1.021 0.0 0.0 0.0 0.0 0.0 0.0

07-810-5177 2 Bracelet

key shaped 

cross pendant 1.465 86.5 7928 1649 8389 43384 17966 61350

07-810-5177 2 Bracelet

curved shape 

cross pendant 1.473 57.3 896 506 938 7560 2340 9900

07-810-5177 2 Bracelet square cross 1.264 60.4 993 155 524 3166 1672 4838

07-810-5177 2 Bracelet

thick cross 

pendant 2.897 92.5 6840 2909 6944 34119 16693 50812

07-810-5177 2 Bracelet Hook 0.922 81.3 657 199 3643 36763 4499 41262

07-810-5177 6 Bracelet

key shaped 

cross pendant 1.754 92.7 1460 348 2498 14250 4306 18556

07-810-5177 6 Bracelet

curved shape 

cross pendant 1.347 63.7 678 267 1071 3623 2016 5639

07-810-5177 6 Bracelet

square cross 

pendant 1.219 68.6 1452 374 2761 5051 4587 9638

07-810-5177 6 Bracelet

thick cross 

pendant 2.909 83.1 3450 1572 2262 44240 7284 51524

07-810-5177 6 Bracelet Hook 1.096 80.6 700 34.2 4194 33726 4920 38646

07-810-5178 4 Choker

Large Butterfly 

charm 3.838 82.5 2083 774 4825 31284 7362 38986

07-810-5178 4 Choker

small butterfly 

charm 1.827 90.9 968 1028 2002 9746 3998 13744

07-810-5178 4 Choker

large heart 

charm 3.472 53.3 4447 2298 3591 35057 10336 45393

07-810-5178 4 Choker

Heart with 

crystal charm 2.197 91.6 2859 2716 3678 191066 9253 28359

07-810-5178 4 Choker Hook 0.754 78.1 293 956 1820 7128 3069 10197

07-810-5178 6 Choker

Large Butterfly 

charm 4.254 88.6 1957 2189 5292 34428 9438 43866

07-810-5178 6 Choker

small butterfly 

charm 1.937 91 1418 1724 4385 23742 7527.0 31269
20

Sample Sub Sample

Type Parts Weight 

(grams)

% Pb

μg of Pb extracted

Total Extractable 

Pb, μg

Acid Extraction Time (hour) 1+2+3 

= 6 

1+2+3+18

=24

1 2 3 18

07-810-5178 6 Choker

large heart 

charm 3.074 77.9 10158 2311 6428 34604 18897 53501

07-810-5178 6 Choker

Heart with 

crystal charm 2.094 97 2416 5191 1929 7602. 9536 17138

07-810-5178 6 Choker Hook 0.753 86.4 153 617 1201 3145 1971 5116

07-810-5221 4 charm 2.677 0.007 0.0 0.0 0.0 1.6 0.0 1.6

07-810-5221 6 charm 2.684 0.008 1.4 0.0 0.0 1.5 1.4 2.9

07-810-5259 2 Ring Pendant 0.8 4.18 2.4 0.4 0.4 0.4 3.2 3.6

07-810-5259 2 necklace Pendant 0.88 2.2 1.3 0.0 0.4 0.4 1.7 2.1

07-810-5259 6 Ring Pendant 0.84 0.5 1.3 0.0 0.4 0.8 1.7 2.5

07-810-5259 6 necklace Pendant 0.8 0.59 0.4 0.0 0.0 0.4 0.4 0.8

07-810-5260 2 Ring pendant 0.47 0.303 0.2 0.2 0.2 0.2 0.7 1.0

07-810-5260 2 necklace pendant 2.01 0.166 1.0 0.0 1.0 0.0 2.0 2.0

07-810-5260 5 Ring pendant 0.49 2.333 0.5 0.3 0.5 0.3 1.3 1.5

07-810-5260 5 necklace pendant 2 0.363 0.0 0.0 1.0 1.0 2.0

07-810-5260 5 necklace shoe pendant 1.64 0.118 0.8 0.0 0.8 1.6 1.6 3.3

07-810-5261 1 necklace

butterfly 

pendant 1.66 0.114 0.0 0.0 0.8 0.8 0.8 1.7

07-810-5261 1 necklace

ladybug 

pendant 1.36 1.922 0.0 0.0 0.0 0.7 0.0 0.7

07-810-5261 1 necklace clover pendant 1.26 1.188 2.5 0.6 0.6 0.6 3.8 4.4

07-810-5261 4 necklace

butterfly 

pendant 1.62 1.305 4.9 0.8 0.8 0.8 6.5 7.3

07-810-5261 4 necklace

ladybug 

pendant 1.42 0.556 4.3 0.0 0.7 0.7 5.0 5.7

07-810-5261 4 necklace clover pendant 1.2 0.435 0.0 0.0 0.0 0.6 0.0 0.6

07-810-5275 2 Bracelet charm 1.135 0.015 26.0 0.9 1.4 2.1 28.4 30.4

07-810-5275 5 Bracelet charm 1.154 0.007 0.4 0.0 0.0 1.2 0.4 1.5

07-810-5276 2 Bracelet charm 0.494 0.013 116.1 4.7 1.8 2.9 122 125

07-810-5276 2 Bracelet 0.53 0.008 4.5 0.6 0.2 2.0 5.2 7.3

07-810-5276 5 Bracelet charm 1.377 0.578 29.5 21.1 29.8 391 80.4 471

07-810-5276 5 Bracelet 0.476 0.008 1.0 0.4 0.2 1.7 1.7 3.3

07-810-5277 2 necklace clasp 0.494 0.116 19.0 0.1 2.3 45.7 21.4 67.1

07-810-5277 2 necklace 0.53 0.385 5.5 3.1 2.0 12.8 10.6 23.4

07-810-5277 5 necklace clasp 1.377 0.117 2.0 2.8 4.8 33.5 9.6 43.0

07-810-5277 5 necklace 0.476 0.24 4.7 2.0 1.5 12.6 8.2 20.8

07-810-5645 2 ring 0.086

07-810-5645 3 ring 0.091

07-810-5645 6 ring 4.6 2.3 4.4 11.3

07-840-6040 2 ring 0.904 0.043 4.3 2.2 2.5 43.6 9.0 52.6

07-840-6040 3 ring 0.702 0.042 1.6 1.5 2.4 13.5 5.5 19.0
21

Sample Sub Sample

Type Parts Weight 

(grams)

% Pb

μg of Pb extracted Total Extractable 

Pb, μg 

Acid Extraction Time (hour) 1+2+3 = 

6 

1+2+3+

18=24

1 2 3 18

07-840-6041 2 necklace pendant 2.857 0.005 0.0 0.0 0.0 1.1 0.0 1.1

07-840-6041 2 chain 2.526 0.006 0.0 0.0 0.0 2.9 0.0 2.9

07-840-6041 6 ring 0.485 0.005 0.0 0.0 0.3 0.0 0.3 0.3

07-840-6042 1 body claps charm 0.708 0.015 1.0 0.0 0.0 0.6 1.0 1.6

07-840-6042 4 body claps charm 0.384 0.006 0.3 0.0 0.0 6.4 0.3 6.7

07-840-6042 5 body claps charm 0.526 0.01 0.0 0.4 0.0 0.0 0.4 0.4

07-840-6137 2 necklace pendant 2.51 0.0 0.0 0.0 0.0 0.0 0.0

07-840-6137 2 necklace hook 0.48 0.5 0.3 0.0 0.7 0.8 1.5

07-840-6137 4 necklace pendant 0.012

07-840-6137 4 necklace hook 0.03

07-840-6137 5 necklace pendant 2.66 6.7 0.0 0.0 0.0 6.7 6.7

07-840-6137 5 necklace hook 0.55 0.3 0.0 0.0 0.0 0.0 0.3

07-840-6137 6 necklace pendant 0.058

07-840-6137 6 necklace hook 0.055

07-840-6138 5 necklace Pendant 5.3 0.036 10.4 0.0 0.0 0.0 10.4 10.4

07-840-6138 5 necklace Hook 0.48 0.006 0.0 0.0 0.0 0.0 0.0 0.0

07-840-6138 6 necklace Pendant 5.26 0.036 11.5 0.0 0.0 0.0 11.5 11.5

07-840-6138 6 necklace Hook 0.5 0.012 0.0 0.0 0.0 0.0 0.0 0.0

07-840-6139 1 charm charm 0.013

07-840-6139 2 charm charm 0.01

07-840-6139 4 charm charm 2.34 0.0 0.0 0.0 0.0 0.0 0.0

07-840-6139 5 charm charm 2.32 0.0 0.0 0.0 0.0 0.0 0.0

07-840-6143 1 necklace Clasp 0.99 0.009

07-840-6143 2 necklace Pendant 0.6342 0.031

07-840-6143 3 necklace Pendant 1.1 0.3 0.1 1.4 2.9

07-840-6143 4 necklace Clasp 0.0985 0.012

07-840-6143 5 necklace Pendant 0.6301 0.008

07-840-6143 7 necklace Pendant 0.4 0.7 0.1 1.1 2.3

07-840-6143

3,7,2,

5 necklace 4 Clasps 1.0 0.2 0.0 1.1 2.3

07-840-6169 3 necklace Pendant 2.6156 87.4 357 6054 8620 59429 15031 74461

07-840-6169 4 necklace Pendant 1.9664 84.3 1610 3038 4132 52938 8780 61717

07-840-6170 3 necklace Pendant 5.289 0.02 12.4 4.7 2.8 5.4 19.9 25.3

07-840-6170 4 necklace Pendant 4.851 0.46 2.4 2.1 2.4 71.4 6.9 78.4

07-840-6187 1 necklace pendant 3.14 0.867 0.0 0.0 0.0 0.0 0.0

07-840-6187 4 necklace pendant 0.144

07-840-6187 5 necklace pendant 2.84 0.0 0.0 0.0 0.0 0.0

07-840-6187 6 necklace pendant 2.1 4.1 0.9 0.0 0.0 5.0 5.0

07-840-6188 1 necklace pendant 0.064

07-840-6188 2 necklace pendant 1.34 7.2 0.0 0.0 0.0 7.2 7.2

07-840-6188 3 necklace pendant 0.045

07-840-6188 4 necklace pendant 1.64 2.3 0.0 0.0 1.2 2.3 3.5

07-840-6188 6 necklace pendant 1.3 3.7 0.0 0.0 1.0 3.7 4.7
22

Sample Sub Sample

Type Parts Weight 

(grams)

% Pb

μg of Pb extracted Total Extractable 

Pb, μg

Acid Extraction Time (hour)

1+2+3 = 

6 

1+2+3+

18=24

1 2 3 18

07-840-6190 1 necklace chain 0.007

07-840-6190 4 necklace chain 0.013

07-840-6224 3

Ring

necklace Ring 2.969 0.002 0.0 0.4 0.6 0.0 1.0 1.0

07-840-6224 3

Ring

necklace pendant 2.800 0.008 0.0 0.0 0.0 0.0 0.0 0.0

07-840-6224 5

Ring

necklace Ring 2.946 0.001 0.0 0.0 0.0 0.0 0.0 0.0

07-840-6224 5

Ring

necklace pendant 2.885 0.004 0.3 0.0 0.0 0.0 0.3 0.3

07-840-6225 4 necklace pendant 3.712 0.006 0.0 0.0 0.0 0.0 0.0 0.0

07-840-6225 4 necklace pendant 3.455 0.003 0.0 0.0 0.0 0.0 0.0 0.0

07-840-6225 6 necklace pendant 3.525 0.003 0.0 0.0 0.0 0.0 0.0 0.0

07-840-6225 6 necklace pendant 3.544 0.003 0.0 0.0 0.0 0.0 0.0 0.0

07-840-6238 1 necklace pendant 6.166 91.1 10.4 55.6 75.9 585 142 727

07-840-6238 1 necklace tear drops 0.474 84.8 228 286 318. 1576 833 2409

07-840-6238 1 necklace clasp 0.62 88.9 1210 1975 2806 15891 5990 21881

07-840-6238 2 necklace pendant 5.702 52.5 38.3 75.5 98.7 647 212 859

07-840-6238 2 necklace tear drops 0.474 84. 7 3.4 0.3 4.6 6921 8.2 6929

07-840-6238 2 necklace clasp 0.636 85.2 1585 3110 5372 31218 10067 41285

07-840-6320 1 Bracelet bracelet 5.73 0.128 0.0 0.4 1.0 2.6 1.4 3.9

07-840-6320 2 Bracelet bracelet 5.57 0.021 0.0 0.0 1.8 3.2 1.8 5.0

07-840-6321 1 Ring Ring 2.99 0.063 0.0 0.0 0.0 4.7 0.0 4.7

07-840-6321 2 Ring Ring 3.26 0.063 0.0 0.3 5.5 0.0 5.9 5.9

07-840-6356 2 necklace charm 3.184 0.021 2.0 1.5 10.0 14.2 13.5 27.7

07-840-6356 2 necklace clasp 0.35 0.031 2.3 1.7 3.5 0.3 7.4 7.7

07-840-6356 5 necklace charm 2.901 0.034 3.8 3.5 4.9 12.2 12.2 19.5

07-840-6356 5 necklace clasp 0.35 0.03 86.1 4.7 3.1 93.9 93.9 94.9

07-840-6357 2 necklace pendant 2.316 0.005 15.5 0.3 0.7 1.1 16.5 17.6

07-840-6357 5 necklace pendant 2.281 0.006 1.7 0.0 0.6 0.3 2.3 2.5

07-840-6397 4 Bracelet hook 0.0988 0.002 0.0 0.0 0.0 0.0 0.0 0.0

07-840-6397 5 Bracelet hook 0.0974 0.000 0.0 0.0 0.0 0.0 0.0 0.0

07-840-6397 4 Bracelet chain 0.5115 0.001 0.0 0.0 0.0 0.0 0.0 0.0

07-840-6397 5 Bracelet chain 0.529 0.006 0.0 0.0 0.0 0.0 0.0 0.0

07-840-6398 4 Bracelet chain 0.4098 0.001 0.0 0.0 0.0 0.0 0.0 0.0

07-840-6398 4 Bracelet hook 0.0826 0.001 0.0 0.0 0.0 0.0 0.0 0.0

07-840-6398 4 Bracelet charm 0.8434 0.001 0.0 0.0 0.0 0.0 0.0 0.0

07-840-6398 6 Bracelet chain 0.3988 0.001 0.0 0.0 0.0 0.0 0.0 0.0

07-840-6398 6 Bracelet hook 0.0919 0.001 0.0 0.0 0.0 0.0 0.0 0.0

07-840-6398 6 Bracelet charm 0.8075 0.000 0.0 0.0 0.0 0.0 0.0 0.0

07-840-6399 1 Bracelet chain 0.3781 0.000 0.0 0.0 0.0 0.0 0.0 0.0

07-840-6399 1 Bracelet hook 0.085 0.001 0.0 0.0 0.0 0.0 0.0 0.0

07-840-6399 1 Bracelet charm 0.5921 0.001 1.4 1.5 3.5 0.0 6.4 6.4

07-840-6399 2 Bracelet chain 0.361 0.001 0.0 0.0 0.5 0.0 0.5 0.5
23

Sample Sub Sample

Type Parts Weight 

(grams)

% Pb

μg of Pb extracted Total Extractable 

Pb, μg

Acid Extraction Time (hour) 1+2+3 = 

6 

1+2+3+

18=24

1 2 3 18

07-840-6399 2 Bracelet hook 0.095 0.001 0.0 0.0 0.0 0.0 0.0 0.0

07-840-6399 2 Bracelet charm 0.573 0.001 0.0 0.0 0.0 0.0 0.0 0.0

07-840-6400 5 Bracelet hook 0.0925 0.002 0.0 0.0 0.0 0.0 0.0 0.0

07-840-6400 5 Bracelet chain 0.542 0.001 0.0 0.0 0.0 0.0 0.0 0.0

07-840-6400 6 Bracelet hook 0.1001 0.001 0.0 0.0 0.0 0.0 0.0 0.0

07-840-6400 6 Bracelet chain 0.5167 0.001 0.0 0.0 0.0 0.0 0.0 0.0

07-840-6401 2 ring Ring 0.326 0.002 0.2 0.0 0.0 0.0 0.2 0.2

07-840-6401 3 ring Ring 0.293 0.001 0.3 0.1 0.0 0.0 0.4 0.4

07-840-6402 2 ring Ring 0.2545 0.001 0.0 0.0 0.0 0.0 0.0 0.0

07-840-6402 6 ring Ring 0.327 0.001 0.0 0.0 0.0 0.0 0.0 0.0

07-840-6411 2 necklace pendant 1.432 0 0.6 0.2 0.1 0.3 0.8 1.1

07-840-6411 1 necklace pendant 0.965 0 0.8 0.2 0.4 2.0 1.5 3.5

07-840-6412 1 necklace pendant 6.958 0 1.6 0.5 0.5 0.7 2.6 3.3

07-840-6412 2 necklace pendant 11.306 0 7.9 0.3 0.6 1.6 8.9 10.4

07-840-6428 4 ring set ring 1 1.024 0.218 1.4 0.7 1.1 4.5 3.2 7.7

07-840-6428 4 ring set ring 3 1.141 0.065 5.0 4.2 0.8 0.8 10.0 10.8

07-840-6428 6 ring set ring 1 1.296 92.7 14.4 29.0 48.1 255 91.5 346

07-840-6428 6 ring set ring 3 1.238 0.048 0.6 0.0 0.0 0.9 0.6 1.5

07-840-6429 3 necklace Pendant 1.493 0.031 0.0 0.0 0.0 0.7 0.0 0.7

07-840-6429 4 necklace Pendant 1.574 0.03 0.0 0.0 0.0 1.0 0.0 1.0

07-840-6465 1 necklace Pendant 19.0 37.9 7.5 56.8 64.4 121

07-840-6465 2 necklace Pendant 4.8 1.6 4.8 6.4 11.2 28.8

07-840-6465 5 necklace Pendant 7.996 0.062

07-840-6465 6 necklace Pendant 8.0217 0.045

07-840-6466 1 bracelet 850 8.5 0.0 0.0 0.0 8.5 8.5

07-840-6466 3 bracelet 0.006

07-840-6466 4 bracelet 0.005

07-840-6466 5 bracelet 867 0.0 0.0 0.0 0.0 0.0 0.0

07-840-6518 1 necklace pendant 9.317 0.011 1.6 0.0 0.1 0.5 1.7 2.8

07-840-6518 1 necklace pendant 2.891 0.01 1.1 0.2 0.0 0.2 1.3 1.5

07-840-6518 2 necklace pendant 9.066 0.008 1.0 1.6 0.5 0.7 3.1 3.8

07-840-6518 2 necklace pendant 2.845 0.01 0.8 0.3 0.6 0.3 1.7 2.0

07-840-6519 1 mixed pendant 2.206 0.01 4.2 0.8 0.2 0.2 5.2 5.4

07-840-6519 2 mixed pendant 2.265 0.01 1.3 0.6 0.2 0.1 2.1 2.2

07-840-6520 1 necklace pendant 3.261 nd 2.4 0.5 0.6 0.3 3.5 3.8

07-840-6520 1 necklace pendant 4.183 nd 1.6 0.2 0.0 0.0 1.7 1.7

07-840-6520 2 necklace pendant 2.503 nd 0.6 0.7 0.0 0.3 1.3 1.6

07-840-6520 2 necklace pendant 4.238 nd 2.7 0.0 0.2 1.6 2.8 4.4
24

Sample Sub Sample

Type Parts Weight 

(grams)

% Pb

μg of Pb extracted Total Extractable 

Pb, μg

Acid Extraction Time (hour) 1+2+3 = 

6 

1+2+3+

18=24

1 2 3 18

07-840-6787 1 necklace charm 10.08 0.023 8.5 0.0 0.0 37.1 8.5 45.6

07-840-6787 1 necklace clasp 0.39 0.063 2.5 2.5 5.6 23.6 10.6 34.2

07-840-6787 2 necklace charm 9 0.193 0.0 0.0 0.0 38.9 0.0 38.9

07-840-6787 2 necklace clasp 0.42 0.066 1.0 1.9 4.0 6.9 6.9

07-840-6788 1 Bracelet bracelet 4.48 0.028 1.6 0.0 0.0 2.1 1.6 3.6

07-840-6788 2 Bracelet bracelet 4.54 0.047 0.7 0.0 0.0 1.1 0.7 1.8

07-840-6969 3 necklace Hook 0.432 67.5 629 1392 3566 8954 5587 14541

07-840-6969 5 necklace Hook 0.615 52.2 472 1608 3380 10029 5460 15489

07-840-7061 6 Bracelet charm 88.7 353 734 1165 17474 2252 19726

07-840-7061 6 Bracelet ring 1 87.2 234 549 1130 13529 1914 15443

07-840-7061 6 Bracelet ring 2 87.1 63.4 51.8 53.9 2573 169 2742

07-840-7061 6 Bracelet hook 84.8 874 1696 2291 29050 4860 33910

07-840-7061 6 Bracelet tear drop 89.9 144 182 239 1277 565 1842

07-840-7061 8 Bracelet charm 85.4 810 1210 1415 10858 3435 14293

07-840-7061 8 Bracelet ring 1 89 806 1756 2757 27871 5320 33191

07-840-7061 8 Bracelet ring 2 84.8 767 1459 1875 16097 4101 20198

07-840-7061 8 Bracelet hook 86 737 1801 2495 18704 5032 23736

07-840-7061 8 Bracelet

tear drop 

charm 85.4 226 340 366 1955 931 2887

07-840-7064 21 Bracelet charm 11.52 89.2 1931 4205 16685 137393 22822 160214

07-840-7064 21 Bracelet link 2.597 89.3 2223 3300 3869 30166 9292.4 39459

07-840-7064 21 Bracelet clasp 2.539 91.8 2220 3699 4799 38513 10612 49125

07-840-7064 22 Bracelet charm 10.015 94.5 2412 6228 13298 109385 21938 131323

07-840-7064 22 Bracelet link 2.701 87.0 2805 3591 3676 25696 10072 35768

07-840-7064 22 Bracelet clasp 2.262 94.9 430 5675 7267 39761 13372 53134

07-840-7171 3 ring 5.78 11.9 85.0 114 167 968 366 1334

07-840-7171 5 ring 5.57 6.52 238 288 457 2923 983 3906

07-840-7172 4 necklace pendant 9.57 1.37 5.8 0.0 0.0 33.3 5.8 39.1

07-840-7172 4 necklace hook 0.55 88.9 274 459 673 2233 1406 3638

07-840-7172 7 necklace pendant 8.14 0.50 0.00 0.00 0.00 0.00 0.00 0.00

07-840-7172 7 necklace hook 0.54 89.3 663 931 1735 9702 3329 13030

07-840-7173 8 ring #1 solder 5.676 13.7 404 572 733 3175 1710 4885

07-840-7173 8 ring Crown solder 5.626 1.65 130 85 39 230 254 484

07-840-7173 8 ring ring metal 0.006

07-840-7174 5 ring 1.559 0.266 764 1023 1572 4862 3358 8220

07-840-7174 5 chain 0.973 0.001 2.8 0.0 0.0 0.0 2.8 2.8

07-840-7174 8 ring 1.589 1.21 690 1198 1872 7281 3759 11041

07-840-7174 8 chain 0.99 0.006 0.7 1.0 0.0 0.0 1.7 1.7
25

Table 2. Non-Metal Jewelry Results

Sample Sub Sample

Type Parts Material Weight g

* XRF % Pb μg Pb

1st 24 

hours

μg Pb

2nd 24 

hours

Total 

μg Pb 

48 

Pb Lα Pb Lß hours

07-302-0045 1 necklace cord PVC 1.68 7.6 3.3 0.039 26.9 14 41

07-302-0046 1 necklace crystal crystal 116.9 107.6 23.5

07-302-0046 1 necklace crystal crystal 88 101 17.3

07-810-4076 2 bracelet plastic (ABS) nd nd

07-810-4076 2 ring plastic(ABS) nd nd

07-810-4076 2 hair clip plastic (ABS) nd nd

07-810-4076 3 false nails plastic (ABS) 1.3 nd

07-810-4076 3 ring plastic (ABS) nd nd

07-810-4076 6 false nails plastic (ABS) nd nd

07-810-4077 4, 5 Ring plastic 0.7258

0.283/2.

283 0/0.8 0.0013

07-810-4173 1 necklace

Crystal from 

pendant crystal 465 507 13.57

07-810-4173 2 necklace

Crystal from 

“diamond” 

earring crystal 13.68

07-810-4294 1 beads/stone) Epoxy Resin ND ND

07-810-4294 3 beads/stone) Epoxy Resin ND ND

07-810-4294 5 Ring beads/stone) Epoxy Resin ND ND

07-810-4294 5 Ring beads/stone) crystal 14.8

07-810-4294 5 Ring beads/stone) Epoxy Resin ND ND

07-810-4654 2 ring

plastic(meth

yl acrylate) 

gemstone nd nd

07-810-4711 4 earring crystal crystal 0.015

07-810-4711 5 earring crystal crystal 0.051

07-810-4948 2 Beads(5x)

plastic 

(PVC) 0.4416 388 361 0.198 2.74 1.82 4.56

07-810-4948 4 Beads(5x)

plastic 

(PVC) 0.4428 388 361 0.202 4.80 0.24 5.04

07-810-5027 2 necklace pendant glass crystal 0.064

07-810-5027 3 earring glass crystal 92 65 0.549

07-810-5027 3 necklace pendant glass crystal 0.083 2.6 1.3 3.9

07-810-5034 2 necklace bead

plastic (ABS) 

with metal 

foil 3.5 ND 0.01 0.4 0.8 1.2

07-810-5034 4 necklace bead

plastic (ABS) 

with metal 

foil 6.5 ND 0.014 0.6 0.3 0.9

07-810-5034 5 necklace green bead

plastic (ABS) 

with metal 

foil 3.2 ND 0.014 0.2 0.4 0.6

07-810-5034 5 necklace gold bead

plastic (ABS) 

with metal 

foil 2.8 ND 0.026 0.2 0.2 0.4

07-810-5222 3 necklace cord plastic (PVC) 2.45 0.596 85.2 105.1 190.3
26

Sample Sub Sample

Type Parts Material Weight g

* XRF

% Pb μg Pb

1st 24 

hours

μg Pb

2nd 24 

hours

Total 

μg Pb 

48 

Pb Lα Pb Lß hours

07-810-5222 3 necklace bead plastic 0.4026 0 0 0

07-810-5222 4 necklace cord

plastic 

(PVC) 2.58 0.604 81.1 101.2 182.3

07-810-5222 4 necklace bead plastic 0.4205 0 0 0

07-810-5178 4 Choker crystal 0.0387 12

07-810-5178 4 Choker collar

plastic 

(PVC) 166 202 0.48 298 292 590

07-810-5178 6 Choker crystal 0.0347 17.2

07-810-5178 6 Choker collar

plastic 

(PVC) 0.83 146 117 262

07-810-5259 2&6 Ring Pendant crystal 0

07-810-5259 2&6 necklace Pendant crystal 0

07-810-5260 2 Ring bead

crystalline 

bead 0.035 6.5 1.2 7.7

07-810-5260 2 necklace bead

crystalline 

bead 0 22.3 0.9 23.3

07-810-5260 5 Ring bead

crystalline 

bead 0.041 22.2 12 34.2

07-810-5260 5 necklace bead

crystalline 

bead 0 0 0 0

07-810-5260 2&5 necklace pendant crystal 0

07-810-5261 1 necklace beads

crystalline 

bead 0.01 0 0

07-810-5261 4 necklace beads

crystalline 

bead 0.018 0 0

07-810-5261 1&4 necklace

butterfly 

pendant crystal 0

07-840-6137 4 necklace crystal glass crystal 5.9

07-840-6137 6 necklace crystal glass crystal 7.54

07-840-6137 ** necklace crystal glass crystal 0.0705 0.8 0.4 1.2

07-840-6171 4 necklace charm plastic 6.136 0.01 0 0 0

07-840-6171 4 necklace chain plastic 13.78 0.01 0 0 0

07-840-6171 8 necklace charm plastic 6.167 0.012 0 0 0

07-840-6171 8 necklace chain plastic 13.85 0.005 0 0 0

07-840-6172 5 bracelet bead plastic 0.474 0.001 0.4 0 0.4

07-840-6172 5 bracelet battery holder plastic 0.534 0.008 1.9 1.3 3.2

07-840-6172 8 bracelet bead plastic 0.432 0.0004 0.5 0 0.5

07-840-6172 8 bracelet battery holder plastic 0.527 0.005 1.2 0.3 1.5

07-840-6189 1 necklace pendant plastic PA nd nd

07-840-6190 1 necklace pendant plastic PA nd nd

07-840-6220 4 jeans 

yellow 

rhinestone

crystal metal 

backing 483 360 3.34 30.6 19.8 50.4

07-840-6220 4 jeans 

orange 

rhinestone

crystal metal 

backing 0.035 23.5 14.5 38

07-840-6220 4 jeans 

silver 

rhinestone

crystal 

(metal 

backing) 933 970 10.4 0.5 11.7 12.2
27

Sample Sub Sample

Type Parts Material Weight g

* XRF

% Pb μg Pb

1st 24 

hours

μg Pb

2nd 24 

hours

Total 

μg Pb 

48 

Pb Lα Pb Lß hours

07-840-6224 1

Ring 

necklace Ring crystal 0.147

07-840-6224 2

Ring 

necklace Ring crystal 0.146

07-840-6466 3 bracelet glass crystal 22.8

07-840-6466 4 bracelet glass crystal 25.2

07-840-6466 *** crystal glass crystal 0.148 2.4 1.8 4.2

07-840-6519 1 mixed plastic band

plastic 

(PVC) 0.787 30.26 28.36 0.102 24.38 5.43 29.81

07-840-6519 2 mixed plastic band

plastic 

(PVC) 0.796 0.022 5.86 1.77 7.63

07-840-6970 1 necklace

painted 

wood nd nd

07-840-7642 3 necklace

coated plastic 

beads plastic 0.004 2.8 0 2.8

07-840-7642 4 necklace

coated plastic 

beads plastic 11.6 0 11.6

*Note: XRF = x-ray fluorescence spectroscopy. Items were screened using XRF to determine 

presence of Pb. The analysis done was qualitative, not quantitative although intensity values for 

Pb La and Lb are related to amount of lead present. nd= not detected

** -4 subs used

***- 12 subs used

PA -Polystyrene Acetonitrile
28

TAB B: Assessment of Cadmium Migration from Materials T

A

B 

B
UNITED STATES

CONSUMER PRODUCT SAFETY COMMISSION

4330 EAST WEST HIGHWAY

BETHESDA, MARYLAND 20814

Memorandum

CPSC Hotline: 1-800-638-CPSC(2772) CPSC's Web Site: http://www.cpsc.gov

Date: June 3, 2010

TO : Kristina Hatlelid, Ph.D., M.P.H.

Toxicologist

Division of Health Sciences

THROUGH: Andrew G. Stadnik, P.E., Associate Executive Director, Directorate for 

Laboratory Sciences

Joel Recht, Ph.D.

Director, Laboratory Sciences, Division of Chemistry

FROM : Ian A. Elder, Ph.D.

Chemist, Laboratory Sciences, Division of Chemistry

SUBJECT : Assessment of Cadmium Migration from Materials1

1.0 EXECUTIVE SUMMARY

In response to concern about cadmium in children’s consumer products, the primary goal 

of this study is to produce data that can be used in determining the public health and 

clinical significance of exposure to cadmium at levels that may migrate from metal and 

plastic materials. Study results may be useful with derived exposure limits for acute and 

chronic cadmium toxicity in the establishment of total cadmium content limits similar to 

regulations for lead. Products tested for cadmium under the Federal Hazardous Substances 

Act are currently evaluated for estimates of exposure levels using the time-consuming 

migration tests described in this memorandum.

The test procedures used in this study were designed to estimate exposure from products 

like children’s jewelry. Migration of cadmium from material surfaces was characterized 

with solutions that simulate saliva and gastric acid. The study attempted to correlate total 

cadmium content levels with extractable cadmium within specific material types. For 

metal-based materials, the study found that product composition factors, such as element 

content and coatings, have a larger effect on cadmium migration than does total cadmium 

content. Alloys containing zinc were found to leach less cadmium than those that are free 

of zinc. Plastics did not leach detectable levels of cadmium. 

 1 These comments are those of the CPSC staff, have not been reviewed or approved by, and may not necessarily reflect the views 

of, the Commission.
30

The study plan was also designed to produce information on the accuracy and precision of 

analytical techniques used by the U.S. Consumer Product Safety Commission (CPSC) staff 

for measuring cadmium content and migration. The development of efficient concentrationbased referral levels for metal products may be complicated by the effect of coatings on xray fluorescence (XRF) analyzer accuracy and the effects of coatings and zinc content on 

soluble cadmium migration.

2.0 SCOPE AND APPLICABILITY

Some children’s jewelry products have been found to contain very high levels of cadmium 

(Ref. 1). There is concern that migration of cadmium from these products may result in 

exposure to toxic levels of cadmium for the children who use such products. The study 

described herein examines the accessibility of cadmium in metal and plastic materials 

containing different levels of cadmium. The cadmium-containing materials include 

reference standards and children’s jewelry products. An understanding of cadmium leach 

rates may be useful when developing content regulations to ensure that exposures are less 

than health-based limits. The study also evaluates analytical techniques employed by CPSC 

staff for the identification of children’s products that are likely to contain hazardous levels 

of accessible cadmium.

Since 2007, CPSC staff has tested a variety of jewelry items for cadmium content and 

cadmium solubility. Dilute hydrochloric acid (HCl) and saline are used to simulate the 

leaching expected during the digestion and mouthing of materials, respectively. As 

confirmed by Figures 1 and 2, staff perception has been that cadmium solubility is highly 

variable and not necessarily proportional to a material’s cadmium concentration (data 

included in Table 1). It seems reasonable to expect reduced cadmium migration relative to 

total cadmium content when a base material is coated (e.g., painted or electroplated) with 

cadmium-free material. Likewise, a coating with cadmium or a cadmium-containing 

material without such a coating could represent a worst-case scenario. The primary issue 

this study sought to resolve was whether cadmium solubility is proportional to cadmium 

content in homogenous materials. 
31

Figure 1. Soluble migrated cadmium from jewelry components with 24

hours of exposure to 0.07N HCl.

Figure 2. Soluble migrated cadmium from jewelry components with 

six hours of exposure to 0.9% NaCl.
32

Table 1. Cadmium Data from Jewelry Analysis

Component

Content by 

ICP-OES

(%)

Content 

by XRF

(%)

Migrated into

0.07N HCl, 24h 

(μg/g)

Migrated into 

0.9% NaCl, 6h 

(μg/g)

08-302-2601 Charm 1.32 1.16 - -

08-302-2600 Charm 1.02 0.923 - -

08-302-2599 Charm 1.35 1.30 - -

08-302-2598 Charm 1.32 1.04 - -

08-810-5399 Ball 22.1 - 0.84 -

08-810-5399 Big Tree 23.9 - 7.20 -

08-810-5399 Tree 30.1 - 0.85 -

08-810-5399 Hat 27.5 - 3.04 -

08-810-5399 Stocking 29.5 - 4.08 -

08-840-7192 Globe 37.7 15.4 - -

08-840-7192 Bird 43.6 13.8 - -

08-840-7306 Charm 36.0 - 83.3 16.7

08-840-7306 Charm 36.0 - 212 15.5

08-840-7306 Charm 36.0 - 54.8 -

09-810-7596 Hook 33.4 11.3 - -

09-810-7596 Link 36.2 12.1 - -

10-302-2023 Clasp 5.98 1.20 988 455

10-302-2023 Flake 98.2 28.4 110 228

10-302-2023 Man 99.1 30.2 2519 21.6

10-302-2024 Clasp 6.47 1.50 1520 429

10-302-2024 Tree 85.3 34.1 1374 95.3

10-302-2024 Cane 96.1 31.7 773 40.6

10-302-2024 Deer 99.3 33.2 13668 135

10-302-2206 Heart 89.9 42.6 10215 495
33

Table 1 Continued. Cadmium Data from Jewelry Analysis

Component

Content by 

ICP-OES

(%)

Content 

by XRF

(%)

Migrated into

0.07N HCl, 24h 

(μg/g)

Migrated into 

0.9% NaCl, 6h 

(μg/g)

10-302-2206 Key 0.0285 0.0248 1.21 0.67

10-304-3090 Flower 19.0 12.3 0.72 0.08

10-304-3415 Metal 75.5 27.1 9552 122

10-304-3415 Star 30.3 19.1 40.8 0.88

10-304-3416 Star 30.7 18.2 140 0.35

10-304-3417 Heart 36.1 17.2 21.6 5.23

10-304-3417 U 29.7 13.4 103 0.64

10-304-3418 Heart 37.7 14.7 3.76 3.90

10-304-3418 Crown 30.2 16.3 22.7 -

10-304-3419 Bracelet 87.8 23.7 19362 169

10-304-3420 Bracelet 90.0 34.2 3545 142

10-304-3421 Bracelet 89.9 29.7 8506 143

10-304-3422 Bracelet 89.0 25.4 3008 108

10-304-3815 Pendant 16.0 13.8 - -

10-304-3816 Pendant 15.4 6.94 - -

10-304-3817 Pendant 16.4 5.39 - -

10-304-3818 Pendant 15.6 8.97 - -

10-810-5600 Tag 29.8 8.11 16.4 -

10-810-5600 Pendant 29.9 15.5 726 -

10-810-5600 Clamp 26.0 9.17 12.3 -

10-810-5601 Tag 27.2 16.2 45.6 -

10-810-5601 Pendant 26.0 18.5 36.5 -
34

3.0 SUMMARY OF METHOD

3.1 Selection of Test Materials

A brief survey of 20 metal components from 14 children’s jewelry products 

(submitted to the laboratory due to expected cadmium content) found that copper and 

zinc were the most prevalent metals (Figure 3). Other elements preliminarily 

identified by XRF include: tin, silver, bismuth, antimony, titanium, nickel, lead, and 

iron. These elements were present less frequently and at lower concentrations than 

copper and zinc. A variety of commercially available materials was acquired for use 

as standards in this study. Metal alloy and plastic standards include materials similar 

to the substrates and coatings used in the jewelry products described above. Study 

materials contain a range of cadmium concentrations and, unlike most children’s 

jewelry, the study materials are homogenous. Certificates of chemical analysis are 

included in the Appendix2

. 

A material’s surface area is expected to affect its soluble cadmium. In an effort to 

standardize the exposed area between study alloys, materials were acquired in wire 

form with diameters of 2.36-2.39 mm whenever possible. Plastics and some alloys 

were not available with these dimensions, so extractions were also conducted using 

powdered material. Powdered materials represent a surface area limit that is 

significantly greater than what is expected for accessible areas on children’s products.

Figure 3. XRF estimates of copper and zinc content in jewelry components. Note, XRF 

accuracy for copper and zinc have not been determined at CPSC. The values presented 

above should be considered relative estimates only. As shown elsewhere in this 

memorandum, cadmium XRF measurements for real-world (inhomogeneous) metal 

samples generally have poor accuracy.

 2 Manufacturer specific information has been coded and certificates of analyses redacted pursuant to section 6 (b) of the 

Consumer Product Safety Act.
35

3.2 Test Material Preparation

Plastic materials and metals purchased in powder form were used without cleaning or 

sanding. Metal materials received in wire, disc, or bar form were cleaned using 

standard practices for the preparation of corrosion test specimens (Ref. 2). In brief, 

the materials were each washed in hexanes, and then sanded with 600-grit silicon 

carbide abrasive paper. Sanded materials were washed thoroughly with deionized 

water followed by acetone and then dried with hot air. Powdered metal material was 

made from cleaned bulk solids with a rotary grinding tool. Plastics purchased in pellet 

form were ground to powder with a cryogenic mill.

3.3 Data Collection and Handling

The instrumentation and procedures described in this report are routinely used (with 

adaptations as necessary) by CPSC staff and are similar to those that were used to 

evaluate the migration of lead from children’s products (Ref. 3). Each of the study 

materials was tested for cadmium content by XRF and inductively coupled plasmaoptical emission spectrometry (ICP-OES), and for cadmium migration in saline and 

dilute acid. 

Twelve replicate measurements were made for each determination of cadmium 

content and for each soluble cadmium migration test of a reference alloy. 

Measurements that were outside of plus or minus three times the replicate set’s 

standard deviation were not included in calculations of cadmium content, accuracy, 

and precision data. The final values include a minimum of ten replicate 

measurements. Measurement precision is illustrated in plots with error bars at plus 

and minus two times the standard deviation. For plastic materials, cadmium migration 

was found to be less than the method detection limits, so only six replicate 

measurements were made. Due to the difficulties involved in quantitatively 

transferring small portions of material, replicate XRF measurements were not 

performed for study materials in powder or pellet form.

3.4 Cadmium Screening by Portable X-ray Fluorescence Analysis

XRF measurements were made using a Thermo NITON XL3t XRF Analyzer in either 

TestAll mode or Alloy mode. Measurement duration was at least 60 seconds. XRF 

detection limits were estimated for plastics and metals by taking the average of

individual detection limits from multiple non-detect measurements. The XRF limit of 

detection was 2 ppm for plastics and 48 ppm for metals. Non-detect results (i.e., less 

than the analyzer’s limit of detection) are included in tables as “nd”. Non-detect 

results are included in plots as half the limit of detection and are indicated with a 

black square (■). 
36

3.5 Soluble Cadmium Migration in Saline

Extractions were performed on 0.49-0.51 g portions of plastic pellets, 0.148-0.152 g 

portions of powders, 3 cm segments of 2.4 mm diameter wires (~ 1 g), and 23 cm 

segments of 0.8 mm diameter wire (~ 1 g). Samples were weighed and then placed in 

a 0.9% sodium chloride (NaCl) solution with a volume equal to 50 times the sample 

weight (e.g., 50 mL saline solution per gram of sample). The extraction occurred over 

six hours at 37.5 oC in a shaker bath. Extraction solutions were collected and analyzed 

by ICP-OES. Samples were diluted further and reanalyzed if cadmium values 

exceeded 1.5 times the concentration of the high calibration standard. The amount of 

migrated soluble cadmium was calculated by multiplying the measured concentration 

by the total dilution volume (e.g., 20 μg/mL x 50 mL = 1,000 μg).

3.6 Soluble Cadmium Migration in Dilute Acid

Extractions were performed on 0.49-0.51 g portions of plastic pellets, 0.148-0.152 g 

portions of powders, 3 cm segments of 2.4 mm diameter wires (~ 1 g), and 23 cm 

segments of 0.8 mm diameter wire (~ 1 g). Samples were weighed and then placed in 

a 0.07 N HCl solution with a volume equal to 50 times the sample weight (e.g., 50 

mL acid solution per gram of sample). The extraction occurred at 37.5 oC in a shaker 

bath. For wires and plastic pellets, extraction solutions were collected at 6, 24, and 48 

hours after the extraction start time (i.e., samples were placed in fresh acid solutions 

at the 6 and 24 hour time points). For powders, separate sample portions were used 

for each time point. Extraction solutions were collected from powders using syringe 

filtration units (0.45 μm). Extraction solutions were analyzed by ICP-OES. Samples 

were diluted further and reanalyzed if cadmium values exceeded 1.5 times the 

concentration of the high calibration standard. The amount of migrated soluble 

cadmium was calculated by multiplying the measured concentration by the total 

dilution volume (e.g., 20 μg/mL x 50 mL = 1,000 μg). For metal wires and plastic 

pellets, the 24 hour-cumulative soluble cadmium was calculated by summing the 

cadmium extracted over the initial six hours and the subsequent 18 hours. The 48-

hour value is the sum of measurements taken at the three time points.

3.7 Sample Preparation for Total Cadmium Content

Samples were digested following standard operating procedures for determining total 

lead in children’s products (Ref. 3). Metals were digested by the hot block method 

and plastics were digested using a microwave digestion system.

3.8 ICP-OES Calibration and Analysis

Calibration standards were prepared at 0.00, 0.10, 0.25, 0.50, 1.00, 5.00, 10.0 and 

20.0 μg/mL by the dilution of a 1,000 μg/mL cadmium standard (SCP Science, 

Champlain NY; Cat# 140-051-480). A quality control standard was prepared at 0.50 

μg/mL by the dilution of a 100 μg/mL multi-element standard (SPEX CertiPrep, 

Metuchen NJ; Cat# CL-QC-21). An internal standard solution of 2 μg/mL yttrium in 
37

2% nitric acid was prepared using a 1,000 μg/mL standard (SPEX CertiPrep, 

Metuchen NJ; Cat# PLY2-2Y). Standards, blanks, and samples were analyzed on a 

Varian VISTA-MPX CCD Simultaneous ICP-OES system (plasma flow: 15.0 L/min; 

nebulizer flow: 0.75 L/min; pump speed: 20 rpm; auxiliary gas flow: 1.5 L/min; 

cadmium wavelength: 214.439 nm; yttrium wavelength: 324.228 nm; power: 1.20 

kW; and replicates: 3). The 0-20 μg/mL calibration curves had correlation 

coefficients greater than 0.9990 with less than 5% error for the quality control 

standard. Samples with on-instrument concentrations less than 5 μg/mL were 

measured using a calibration range of 0-5 μg/mL. All other samples were evaluated 

against the full calibration range. 

ICP-OES instrument detection limits were determined for each method by 

multiplying three times the standard deviation of seven replicate measurements of 

reagent blanks. Method detection limits for ICP-OES were determined using reagent 

blanks fortified with 2-3 times the instrument detection limits. The method detection 

limits were calculated as follows: MDL = t x S, t=3.14 (99% confidence level for 7 

replicates), S = standard deviation. The instrument and method detection limits are 

included in Table 2. Non-detection ICP-OES measurements (i.e., less than the method 

detection limit) are listed in tables as “nd”. Non-detect results are included in plots 

using estimated ICP values equal to half of the method detection limit. Non-detect 

data points are indicated in plots with a black square (■).

Table 2. Instrument and Method Detection Limits for ICP-OES

Method Instrument Detection 

Limit (μg/mL)

Method Detection Limit

(μg/mL)

Cadmium Content in Plastic 0.005 0.009

Total Cadmium in Metal 0.010 0.042

Acid Extraction of Cadmium 0.001 0.045

Saline Extraction of Cadmium 0.001 0.001
38

4.0 RESULTS AND DISCUSSION

4.1 Characterization of Materials and Analytical Techniques

Figure 4 compares XRF and ICP-OES measurements for cadmium content in jewelry 

samples tested at CPSC (data included in Table 1). XRF measurements for cadmium 

in jewelry have significantly greater error than what is seen with homogenous alloys 

(Figure 5-C). In general, the relative error was found to increase with cadmium 

content (Panel 4-B). Figures 5-A and B demonstrate agreement between manufacturer 

certificates of analysis for metals and cadmium content measurements made at CPSC 

by ICP-OES and XRF. Panel 5-C shows good correlation between ICP-OES and 

XRF. Figure 6-A shows moderate agreement between vendor-certified cadmium 

levels and ICP-OES measurements for plastic test materials. Panels 6-B and C 

indicate that XRF readings did not agree very well with either the certificates of 

analysis or ICP-OES measurements. XRF measurements of cadmium in polyvinyl 

chloride standards were significantly lower than expected. 

Precision and accuracy information for cadmium measurements are included in 

Tables 3 and 4 for metals and plastics, respectively. Accuracy was evaluated with 

comparisons of XRF and ICP-OES cadmium content measurements to vendorcertified values (also see Figures 5 and 6). The precision of replicate measurements 

was determined as the relative standard deviation for each material available in wire 

or pellet form. Relatively good accuracy and precision was obtained with ICP-OES 

for most alloy materials. The precision of XRF readings for alloys was also good but 

the accuracy was off by more than 5% for half of the metals. While the accuracy and 

precision of ICP-OES analysis for plastic materials was acceptable, XRF 

measurements could be classified as having moderate to poor accuracy.
39

Figure 4. Effect of coatings on XRF accuracy (compare with Figure 5 

for homogenous materials). Panel A: XRF and ICP-OES cadmium 

measurements for jewelry components. Panel B: Relative error of XRF 

measurements compared to ICP-OES measurements (relative error = 

-(XRF concentration-ICP concentration)/ICP concentration x 100). 
40

Figure 5. Confirmation of vendor-certified cadmium levels in metal test 

materials by ICP-OES (Panel A) and XRF (Panel B) analysis. Panel C 

shows a linear relationship between ICP-OES and XRF measurements. 

Note: plots contain XRF measurements for both wires and powders.
41

Figure 6. Confirmation of vendor-certified cadmium levels in plastic test 

materials by ICP-OES (Panel A). Panels B and C show XRF readings are 

low compared to certificates of analysis and ICP measurements. Note: 

plots contain XRF measurements for both pellets and powders.
42

Table 3. Analysis of Cadmium Content in Metal Test Materials.

ICP-OES XRF

Material

Certificate 

of Analysis 

(%)

Mean

(%)

Standard 

Deviation 

(%)

RSD

(%)

Recovery

(%)*

Mean 

(%)

Standard 

Deviation 

(%)**

RSD

(%)**

Recovery

(%)*

M001 Wire 32.398 30.601 1.213 4.0 94 32.456 0.047 0.1 100

M001 Powder 32.398 - - - - 32.875 - - 101

M002 Wire 59.92 59.99 1.09 1.8 100 60.27 2.27 3.8 100

M002 Powder 59.92 - - - - 57.33 - - 96

M003 Wire 19.042 19.322 0.382 2.0 101 20.588 0.507 2.5 108

M003 Powder 19.042 - - - - 19.378 - - 102

SRM 629 Powder 0.0155 0.0185 0.0028 15.1 119 nd*** - - N/A

SRM 683 Powder 0.00011 nd N/A N/A N/A nd - - N/A

SRM 1129 Powder 0.006 0.006 0.000 0.9 100 nd - - N/A

M004 Wire 14.42 14.44 0.10 0.7 100 13.36 0.18 1.4 93

M004 Powder 14.42 - - - - 13.54 - - 94

M005 Wire 18.22 19.30 0.26 1.3 106 17.02 0.36 2.1 93

M005 Powder 18.22 - - - - 17.28 - - 95

M006 Wire 24.01 23.63 0.56 2.4 98 23.13 0.19 0.8 96

M006 Powder 24.01 - - - - 23.17 - - 96

M007 Wire 78.01 78.44 0.95 1.2 100 87.65 0.38 0.4 112

M007 Powder 78.01 - - - - 75.82 - - 97

M008 Wire < 0.01 0.02 0.00 3.9 N/A nd - - N/A

M008 Powder < 0.01 - - - - nd - - N/A

M009 Powder 31.0 30.8 0.40 1.3 99 29.2 - - 94

M010Powder 1.75 1.73 0.02 1.3 99 1.90 - - 108

M011Powder 4.99 5.02 0.04 0.9 101 4.10 - - 82

M012 Powder 0.33 0.34 0.00 0.7 103 0.35 - - 107

M013 Powder 0.37 0.38 0.00 0.5 103 0.40 - - 108

* Percent recovery was calculated using cadmium concentrations reported in certificates of analysis.

** A single XRF measurement was taken for powders so standard deviation and relative standard deviation data are not available.

*** nd = non-detect. 
43

Table 4. Analysis of Cadmium Content in Plastic Test Materials.

ICP-OES XRF

Material

Certificate 

of Analysis 

(ppm)

Mean

(ppm)

Standard 

Deviation 

(ppm)

RSD

(%)

Recovery

(%)*

Mean 

(ppm)

Recovery

(%)*

PVC001 Sample 1 0 nd** N/A N/A N/A nd N/A

PVC001 Sample 2 50 48 1 2.1 96 23 46

PVC001 Sample 3 101 100 6 6.0 99 50 50

PE001 Sample 1 0 nd N/A N/A N/A nd N/A

PE001 Sample 2 50 47 0.5 1.1 94 44 88

PE001 Sample 3 100 100 2 1.8 100 85 85

ERM-EC680k Pellet 19.6 17.9 1.7 9.5 91 18 92

ERM-EC680k Powder 19.6 17.9 - - - 17 87

ERM-EC681k Pellet 137 125 24 19 91 130 95

ERM-EC681k Powder 137 125 - - - 112 82

* Percent recovery was calculated using cadmium concentrations reported in certificates of analysis.

** nd = non-detect. 
44

4.2 Soluble Cadmium Migration

Tables 5 and 6 include data for soluble cadmium migration from metals into dilute 

acid and saline, respectively. All measurements of soluble cadmium migration from 

plastics were less than the method detection limits. Figures 7 and 8 illustrate the 

migration of cadmium over time from metal wires and powders, respectively. 

Substantially different behavior is seen for the materials, including comparisons 

between alloys. Interestingly, the amount of migrated cadmium decreased over time 

for some powdered alloys. This effect was not observed for any of the samples in 

wire form. The decrease in migrated cadmium over time seems to be more prevalent 

in powders containing high levels of zinc (32-93%), with the exception of NIST SRM 

1129 which contains only 0.006% cadmium and no documented zinc. The observed 

effect could come from differences in the test procedures for wire and powder 

samples. For wires, extract solutions were removed at each time point and the 

samples were placed in fresh solution. Extract solutions were not filtered prior to 

analysis. The cumulative soluble migrated cadmium for the 24-hour time point is the 

sum of measurements from the initial 6-hour extraction and subsequent 18-hour 

extraction. The 48-hour value is the sum of measurements from all three time points. 

For powders, different sets of materials were used for each time point (i.e., test 

materials remained exposed to extract solutions for full 6, 24, and 48-hour periods). 

Extract solutions were filtered away from powder samples using 0.45 μm syringe 

filter units. Filtration may have removed suspended cadmium precipitates.

No soluble cadmium was detected in saline or acid extract solutions for plastic study 

materials. The plastics contained low cadmium concentrations compared to most of 

the metals examined in the study. Plastic standards with high cadmium content were 

not commercially available. The plastic cadmium content levels are comparable to 

those in the NIST alloy materials and M008. It may be worthwhile to survey 

cadmium-containing plastic products to ensure that cadmium content and migration 

data from study plastics are representative of real-world products. 

Figures 9-A and B show the amount of cadmium leached from metal wires and 

powders containing different levels of cadmium after 48 hours of exposure to dilute

acid. Migrated cadmium was not proportional to cadmium content. This suggests that 

alloy composition and/or other material properties play a role in accessible cadmium. 

Figures 10-A and B show measurements of cadmium leached from metal wires and 

powders using a saline solution. In general, materials that produce elevated levels of 

migrated cadmium in saline also produce elevated levels in dilute acid (Figure 11).

Figure 12 illustrates the apparent effect of zinc on soluble cadmium migration from 

alloys. Plotting levels of migrated cadmium against the concentration of elements 

present in many of the test materials indicates an apparent trend with respect to zinc 

content. Panel A shows that cadmium migration into dilute acid decreased rapidly as 

zinc content increased, regardless of cadmium content. Panels B and C separate alloy 

powders into groups based on elemental composition. Materials high in zinc had 

relatively low migrated cadmium. Alloy materials with intermediate levels of zinc 
45

plus intermediate levels of silver and copper were found to produce moderate levels 

of migrated cadmium compared to materials with little or no zinc. 

As seen in Figures 1, 2, 9, and 10, soluble cadmium migration is not proportional to 

total cadmium content. This is due to variable composition and the presence of 

coatings (e.g., paint, electroplating) on many commercial products. Since surface 

properties are important factors in both XRF measurements and soluble cadmium 

migration, plots were made to look for a relationship between the two parameters. A 

linear correlation would be useful for predicting cadmium exposure risk using only 

the XRF data collected in the field. However, as seen in Figure 13, the overall data 

pattern is much like that in Figures 1 and 2, with cadmium concentrations shifted to 

lower values. This result is not unexpected when one considers the moderately good 

correlation seen in Figure 4-A and the relative error shown in Figure 4-B.

 
46

Table 5. Migration of Soluble Cadmium from Metals into 0.07N Hydrochloric Acid.

6h Migrated Cadmium 24h Migrated Cadmium 48h Migrated Cadmium

Material Mean 

(μg/g)

Standard 

Deviation 

(μg/g)

%RSD Mean 

(μg/g)

Standard 

Deviation 

(μg/g)

%RSD Mean 

(μg/g)

Standard 

Deviation 

(μg/g)

%RSD

M001 Wire 1449.8 101.46 7.00 5148.8 542.91 10.54 9944.6 1215.3 12.22

M001 Powder 17791 7754.8 43.59 47789 16538 34.61 59997 21940 36.57

M002 Wire nd* N/A N/A nd N/A N/A nd N/A N/A

M002 Powder 2807.4 2638.2 93.97 785.91 1316.0 167.45 76.25 128.01 167.90

M003 Wire nd N/A N/A nd N/A N/A nd N/A N/A

M003 Powder 57.94 22.76 39.29 44.63 36.46 81.70 25.30 13.16 52.02

SRM 629 Powder nd N/A N/A nd N/A N/A nd N/A N/A

SRM 683 Powder nd N/A N/A nd N/A N/A nd N/A N/A

SRM 1129 Powder 24.51 0.53 2.18 23.64 5.12 21.65 24.68 0.22 0.91

M004 Wire 86.35 7.92 9.18 319.73 39.29 12.29 753.13 77.69 10.32

M004 Powder 1712.4 78.09 4.56 3065.1 324.65 10.59 3302.1 366.95 11.11

M005 Wire 25.59 2.18 8.53 84.54 4.82 5.71 160.79 7.42 4.62

M005 Powder 1267.1 119.27 9.41 2156.7 203.58 9.44 3311.0 263.29 7.95

M006 Wire 52.31 5.69 10.87 136.54 13.43 9.84 231.70 19.52 8.43

M006 Powder 1772.2 199.64 11.27 4481.4 217.03 4.84 7474.4 213.07 2.85

M007 Wire 1137.5 35.34 3.11 3493.2 195.60 5.60 5269.0 364.17 6.91

M007 Powder 13695 1964.8 14.35 12407 2852.0 22.99 17176 4487.4 26.13

M008 Wire nd N/A N/A nd N/A N/A nd N/A N/A

M008 Powder 4.26 1.43 33.49 9.21 3.12 33.89 11.76 2.70 22.94

M009 Powder 606.09 130.99 21.61 425.95 80.48 18.89 469.76 149.78 31.88

M010Powder 8457.5 339.22 4.01 9669.4 184.08 1.90 9721.2 381.83 3.93

M011Powder 1593.2 451.52 28.34 3509.3 646.65 18.43 4859.4 1016.3 20.91

M012 Powder 532.58 82.08 15.41 1059.0 59.17 5.59 1355.2 54.35 4.01

M013 Powder 674.82 50.90 7.54 1326.1 82.04 6.19 1844.9 56.99 3.09

* nd = non-detect.
47

 Table 6. Migration of Soluble Cadmium from Metals into 0.9% Saline.

6h Migrated Cadmium

Metal

Material

Mean 

(μg/g)

Standard 

Deviation 

(μg/g)

%RSD

M001 Wire 55.21 4.40 7.96

M001 Powder 286.70 60.75 21.19

M002 Wire nd* N/A N/A

M002 Powder 64.30 18.12 28.17

M003 Wire nd N/A N/A

M003 Powder 59.29 17.53 29.57

SRM 629 Powder nd N/A N/A

SRM 683 Powder nd N/A N/A

SRM 1129 Powder 3.42 0.30 8.76

M004 Wire 25.47 1.92 7.53

M005 Powder 140.91 20.71 14.70

M006 Wire 4.08 1.20 29.44

M006 Powder 152.93 23.05 15.07

M007 Wire 168.83 23.44 13.88

M007 Powder 165.81 23.54 14.20

M008 Wire nd N/A N/A

M008 Powder 0.59 0.56 94.97

M009 Powder 63.12 12.92 20.48

M010Powder 284.74 15.98 5.61

M011Powder 128.89 32.33 25.09

M012 Powder 11.28 1.31 11.59

M013 Powder 6.44 1.33 20.60

 * nd=non-detect.
48

Time (hours)

Figure 7. Cummulative cadmium migration from wires over 6, 24, and 48 hours. 

Measurements taken at the 24 and 48 hour timepoints were summed with values from 

previous timepoints. 

Soluble Cadmium Migration (μg Cd/g Wire)

Time (Hours)
49

Figure 8. Cadmium migration from metal powder after 6, 24, and 48 hours. Each 

point is from a unique set of powders (i.e. values are not cummulative as with wires).
50

Figure 8 (Continued). Cadmium migration from metal powder after 6, 24, and 48 

hours. Each point is from a unique set of powders (i.e. values are not cummulative as 

with wires).
51

Figure 9. Cadmium leached from metal wires (Panel A) and powders 

(Panel B) containing different levels of cadmium after 48 hours of 

exposure to 0.07N HCl. 
52

Figure 10. Cadmium leached from metal wires (Panel A) and powders 

(Panel B) containing different levels of cadmium after 6 hours of exposure 

to 0.9% NaCl.
53

Figure 11. Comparisons of cadmium migration from alloys into dilute 

acid and saline over 6 hours. Panel A includes study wires and Panel B 

includes powder.
54

(< 0.01) (30.8) (0.02) (< 0.01)

 (78.4)

 (23.6)

 (19.3) (14.4) 

 

 (19.3) (60.0) 

Figure 12. Effect of zinc on cadmium migration from alloy powders. Panel A: 

Cadmium migration into dilute acid (48h) as a function of zinc content. Cadmium 

content (%) is in parentheses. Panel B: Effect of alloy composition on 48h cadmium 

migration into dilute acid (-●-: 16-33% Zn with 5-67% Cu and/or Ag; -♦-: 32-93% Zn 

with ≤1.5% Cu and Ag). Panel C: Effect of alloy composition on cadmium migration 

into saline.
55

Figure 13. Soluble migrated cadmium from jewelry compared to cadmium 

content measurements by XRF. Panel A: Cadmium migrated into 0.07N HCl

over 24 hours. Panel B: Cadmium migrated into 0.9% NaCl over 6 hours.

5.0 CONCLUSIONS

The primary goal of this study was to characterize the migration of cadmium from a variety 

of metal and plastic materials. The study found that soluble cadmium migration is not 

generally proportional to cadmium content. For alloys, product composition factors such as 

element content and coatings have a larger effect on cadmium migration than does total 

cadmium content. The presence of zinc reduces cadmium migration, and the addition of coalloyed elements such as silver and copper, seems to mitigate zinc’s effect. No detectable 

cadmium was found to migrate from plastic materials.
56

Efforts to define regulatory limits of total cadmium concentration based on cadmium 

migration tests may be complicated by coatings and the alloy effects associated with zinc. 

While one cadmium-containing metal (either as a coating or coating-free material) can 

have high cadmium migration, another metal with similar cadmium content may not yield 

hazardous levels of soluble cadmium for a variety of reasons (e.g., elemental content, 

coating type, coating thickness).

A secondary goal of this study was to provide accuracy and precision information for 

cadmium tests performed at CPSC. This information may be useful when adjusting fieldXRF sample referral levels for products that require laboratory analysis. While agreement 

between XRF and ICP-OES cadmium content measurements for homogenous alloy 

materials was good (Figure 5-C), the relative error for XRF measurements in real-world 

(inhomogeneous) samples (Figure 4) ranged from -1 to -80%. As seen in Figure 4-A, a 

cadmium XRF reading of 20% could relate to a 30-85% total cadmium measurement by 

ICP-OES. This error can be attributed to the common use of coatings (e.g., paint, 

electroplating). No linear relationship was observed between XRF cadmium measurements 

and cadmium migration from jewelry samples. For these reasons, plus the apparent effect 

of zinc content on cadmium accessibility, the development of efficient concentration-based 

referral limits would be difficult. Even jewelry with relatively low XRF readings for 

cadmium can yield relatively high levels of soluble migrated cadmium (Figure 13).

6.0 REFERENCES

1. a) United States Consumer Product Safety Commission. “FAF Inc. Recalls Children's 

Necklaces Sold Exclusively at Walmart Stores Due to High Levels of Cadmium,” 

http://www.cpsc.gov/cpscpub/prerel/prhtml10/10127.html, 2010; b) United States 

Consumer Product Safety Commission. “CPSC Issues Warning on Children’s Winter 

and Holiday-Themed Charm Bracelets with High Levels of Cadmium,” 

http://www.cpsc.gov/cpscpub/prerel/prhtml10/10162.html, 2010; c) United States 

Consumer Product Safety Commission. “Claire's Recalls Children's Metal Charm 

Bracelets Due to High Levels of Cadmium,” 

http://www.cpsc.gov/cpscpub/prerel/prhtml10/10227.html, 2010.

2. a) “Standard Practice for Preparing, Cleaning, and Evaluating Corrosion Test 

Specimens,” ASTM G 1 – 90, American Society for Testing and Materials, 1999; b) 

“Standard Guide for Conducting Corrosion Tests in Field Applications,” ASTM G 4 –

01, American Society for Testing and Materials, 2008.

3. a) United States Consumer Product Safety Commission. “Standard Operating 

Procedure for Determining Total Lead (Pb) in Children’s Metal Products (Including 

Children’s Metal Jewelry),” http://www.cpsc.gov/about/cpsia/CPSC-CH-E1001-08.pdf, 

2008; b) United States Consumer Product Safety Commission. “Standard Operating 

Procedure for Determining Total Lead (Pb) in Non-Metal Children’s Products,” 

http://www.cpsc.gov/about/cpsia/CPSC-CH-E1002-08.pdf, 2009; c) United States 

Consumer Product Safety Commission. “Standard Operating Procedure for 

Determining Lead (Pb) and Its Availability in Children’s Metal Jewelry,” 

http://www.cpsc.gov/businfo/pbjeweltest.pdf, 2005.
57

APPENDIX

Certificates of Analysis
58
59
60
61
62