Image from Oprah’s Favorite Things List 2018 on Amazon.com
Please bear with me here, and read this entire post to follow my logic and see my concern about the bracelets pictured on this post.
I used an XRF instrument to test the “FEARLESS” bracelet from Oprah’s Favorite Things List for 2018. While the bracelet was 100% Lead-free (which is great!), it did come in with Cadmium readings as high as 303 ppm (as detectable with an XRF instrument.)
While this is a fairly low level of Cadmium in many respects, it is a level that is above several regulatory thresholds for how much Cadmium is legally allowed in items intended for use by children. I am sure that the manufacturer has not designed this as jewelry intended for use by children — however, given the presence of Cadmium at this level, in the marketing for this item there are a couple of quotes that really stuck out for me as being concerning…
- In the preview with Oprah’s written comment (see below) Oprah is quoted as saying “The words you see below are the ones I want my girls at the Oprah Winfrey Leadership Academy to use to describe themselves. Now they can wear a delicate reminder right on their wrist.”:
- In the description on Empowered By Maya main page for the product (see below) they have the following sentence included in their product description: “To empower girls in our community we teamed up….”
So while one could easily argue that this bracelet is “not intended to be used by children” (and not expressly marketed for use by children), the impression the reader/consumer is very likely left with after reading these advertising blurbs is that these are an appropriate gift for “girls”.
To go a little further down this rabbit hole, I decided to get back to basics in researching the commonly understood definitions of some terms (for instance, to see what the term “girl” is understood to mean in general usage – and more specifically, how it is to be understood in relation to Oprah’s Leadership Academy).
What is a girl?
If we look at what that might mean from a general usage standpoint (i.e. the generally accepted working definition understood by consumers viewing these products), “girls” are generally perceived to be female children under the age of 14 (and sometimes under the age of 16 or 18, depending on the context.)
If we look at Oprah’s Leadership Academy for Girls, in this case “Girls” include “8th to 12th grade students” in the boarding school she founded in South Africa.
What is an 8th grader?
Going a little deeper into this inquiry, I looked up how old one might expect an 8th grader to be in Africa, and came up with a range that is similar to current norms in the United States. An 8th grade girl is usually in the range of 12 to 14 years old. [Source: Wikipedia.]
Image from Wikipedia’s “8th Grade” Post.
So adding this information together, one could anticipate that Oprah has at least some 12 or 13 year-old girls in her Academy, and based on her quote in the advertisement for this product she feels these bracelets might be an appropriate gift for these girls. And given Oprah’s level of influence on our culture (especially our consumer culture), combined with Oprah’s choice to make a public statement about wanting to give these bracelets to the girls in her Academy – I think it is a reasonable assumption that many who see this advertising/marketing material might buy these bracelets for younger girls without consideration to the fact that they are not expressly marketed as a jewelry item “intended for children” (and these consumers would also buy these without any knowledge of or concern about the fact that, absent that explicit language by a manufacturer or distributor (“intended for use by children”), these bracelets are exempt from the regulations designed to protect children from toxicity — and in fact, are not subject to any toxicity regulations whatsoever).
Now… here we come upon the larger problem:
Cadmium Regulatory Standards
(please read this post about Cadmium for more specifics.)
In the U.S., Cadmium regulatory standards vary, State-to-State! Here’s a quick overview of some standards for you to review for consideration:
- US Federal Standard: Toys “intended for children under the age of 14” cannot contain more than 75 ppm Cadmium [via solubility*** testing]. But jewelry is exempt (no mandatory Federal standard for Cadmium levels at all)!
- California: Considers jewelry “marketed to children 6 years old or younger” illegal if Cadmium levels are 300 ppm or higher [based on total content – by weight]. This includes anything “advertised as appropriate for use by children”.
- Washington (State): Considers jewelry marketed to children illegal if Cadmium levels are 40 ppm or higher [based on total content – by weight]. This includes anything advertised as appropriate for use by children. [Note: To my knowledge, an age limit for what determines someone to be a child here is not set – although I need to see the full text of the regulation to be sure.]
- Connecticut: Considers children to be 12 years old and younger (for the purpose of this regulation), and requires that Cadmium levels in jewelry marketed to be used by children be below 75 ppm [total content – by weight.]
- Illinois: Considers children to be under 12 years old (for the purpose of this regulation) and requires that Cadmium levels in jewelry marketed to be used by children be below 75 ppm [via solubility*** testing].
- Minnesota: Considers children to be age 6 years old and under (for the purpose of this regulation) and requires that Cadmium levels in jewelry marketed to be used by children be below 75 ppm [via solubility*** testing]. [It is unclear if the second part of this legislation applies a 75 ppm limit by weight as well.]
- Maryland: Considers children to be under 13 years old (for the purpose of this regulation) and requires that Cadmium levels in jewelry marketed to be used by children be below 75 ppm [total content – by weight.]
***Similar to leach testing standards for dishware (i.e. merely whether the toxicant in question is leaching out at the time of manufacture, rather than a detection and measurement of actual toxicant presence and content).
In conclusion, my concern is that, based on the Cadmium levels found in this bracelet (see the specific XRF readings listed below), there is at least some ambiguity about the appropriateness (and legality) of these bracelets – from a toxicity concern standpoint – when distributed for [obviously probable] use by children.
Without knowing the solubility test results from this item (and being armed only with XRF test results), in at least Washington, Connecticut and Maryland, it looks like it may be considered illegal to market and sell this item for use by a child who might be in 8th grade.
Beyond the question of regulatory compliance, Cadmium is a known carcinogen and (in my opinion) does not belong in products intended for use by HUMANS (regardless of regulatory standards about whether or not it belongs in products intended for use by children and young women.)
#SIMPLE SOLUTION: It would be fairly inexpensive for the company that makes these bracelets to switch to making them out of sterling silver and gold plated sterling silver INSTEAD of gold-plated brass. If they make that change their products will likely test completely negative for Cadmium.
Tamara… and So What?! What would you like to come of this revelation?
I would like to see a SPECIFIC and OBVIOUS WARNING on the Amazon listing page for each of the products sold by this company that notes (at least) these pieces of Jewelry “are only intended for people 14 years old and older”.
Additionally, I hope that Oprah or her people read this post and perhaps have me over for a visit, to test some of her other “Favorite Things” with an XRF instrument [here are the other items I have concerns about] and help to give her guidance to make #SaferChoices for herself and her followers in the future. [Acutally, over the years I’ve often thought it would be great to collaborate with Oprah on Lead Poisoning Prevention initiatives!]
Armed with this information (potential toxicants in consumer goods), Oprah has an incredible opportunity to help change the world in regards to generating awareness of environment toxicants in consumer goods — and the importance of eliminating toxicants from the manufacturing/waste stream altogether (to protect our children and our planet), and I would like to help her take advantage of that opportunity. [Oprah, in case you want to be in touch about this my cell is 415-609-3182, it’s best to text me or to e-mail since I have my hands full with disabled kiddos most of the time! My e-mail is TamaraRubin@mac.com.]
As always, please let me know if you have any questions!
Thank you for reading and for sharing my posts.
Tamara Rubin
#LeadSafeMama
Mother of Lead Poisoned Children
*Links on this page may be Amazon affiliate links. If you purchase something after clicking on one of these links I may receive a small percentage of what you spend at no extra cost to you.
Related: #AskTamara: What do you use to test for Lead and other toxicants?
XRF Test Results for the “FEARLESS” bracelet pictured here detailed in full below.
Focus on Chain of Bracelet (image above):
(Reading One, 180 seconds)
- Lead (Pb): Non-Detect / Negative
- Mercury (Hg): Non-Detect / Negative
- Arsenic (As): Non-Detect / Negative
- Cadmium (Cd): 257 +/- 46 ppm
- Antimony (Sb): Non-Detect / Negative
Focus on Chain of Bracelet:
(Reading Two, 180 seconds)
- Lead (Pb): Non-Detect / Negative
- Mercury (Hg): Non-Detect / Negative
- Arsenic (As): Non-Detect / Negative
- Cadmium (Cd): 237 +/- 44 ppm
- Antimony (Sb): Non-Detect / Negative
Focus on Lobster Clasp of Bracelet (image above):
(Reading One, 181 seconds)
- Lead (Pb): Non-Detect / Negative
- Mercury (Hg): Non-Detect / Negative
- Arsenic (As): Non-Detect / Negative
- Cadmium (Cd): 199 +/- 48 ppm
- Antimony (Sb): Non-Detect / Negative
Focus on Lobster Clasp of Bracelet:
(Reading Two, 181 seconds)
- Lead (Pb): Non-Detect / Negative
- Mercury (Hg): Non-Detect / Negative
- Arsenic (As): Non-Detect / Negative
- Cadmium (Cd): 191 +/- 43 ppm
- Antimony (Sb): Non-Detect / Negative
Focus on Letters of Bracelet (image above):
(Reading One: 185 Second Test)
- Lead (Pb): Non-Detect / Negative
- Mercury (Hg): Non-Detect / Negative
- Arsenic (As): Non-Detect / Negative
- Cadmium (Cd): 169 +/- 39 ppm
- Antimony (Sb): Non-Detect / Negative
Focus on Letters of Bracelet:
(Reading Two, 181 seconds)
- Lead (Pb): Non-Detect / Negative
- Mercury (Hg): Non-Detect / Negative
- Arsenic (As): Non-Detect / Negative
- Cadmium (Cd): 175 +/-45 ppm
- Antimony (Sb): Non-Detect / Negative
Leave a Reply