16 CFR Part 23, Guides for the Jewelry, Precious Metals, and Pewter Industries, Project No. G711001 #560895-00003 

Submission Number:
560895-00003 
Commenter:
Samuel Getz
Organization:
Samuel Getz Private Jewelers & Designers, Inc.
State:
Florida
Initiative Name:
16 CFR Part 23, Guides for the Jewelry, Precious Metals, and Pewter Industries, Project No. G711001

I would like to comment on a few of issues as it relates to "16 CFR Part 23, Guides for the Jewelry, Precious Metals, and Pewter Industries, Project No. G711001", in particular, Lead-Glass-Filled Rubies, Synthetic Diamonds, and Dyed Pearls. Regarding Lead-Glass-Filled Rubies, at the least, this material should be classified as imitation. It has always been my understanding from what I learned to become a Graduate Gemologist in 1980 was that to be considered a synthetic, it must have virtually the same physical and chemical properties as it's natural counterpart. Lead-Glass-Rubies do not meet this threshold. As an industry, we must get a quick resolution to establish a standard and thus enforcement and consequence regarding the misrepresentation of this material. Otherwise, it will significantly harm the credibility of the industry as a whole for not doing enough to protect the consumer. The same standard should be held for diamonds as well. The term "Cultured" may lead to confusion for the end user. "Cultured" seems better suited referring to something organic. I believe that it is important to keep to a minimum the descriptive terms to avoid confusion in the marketplace. If Freshwater Pearls are being developed by manually inserting an irritant into the oyster, why shouldn't it be considered "Cultured"? The dying of Pearls should be disclosed. Though it is a long established practice, this is something that the consumer should be aware of just as they should know that they are "Cultured" and not "Natural". I understand that these answers are simplistic and are exclusive of underlying factors that could lead to some increased costs to the consumer. However, it is important that we see things from the perspective of the consumer who wants to be informed, especially as it relates to the value of what they are purchasing. Thank you for allowing me to provide some input. Regards, Samuel Getz