16 CFR Part 23, Guides for the Jewelry, Precious Metals, and Pewter Industries; Project No. G711001 #00053

Submission Number:
George Loder
Initiative Name:
16 CFR Part 23, Guides for the Jewelry, Precious Metals, and Pewter Industries; Project No. G711001
I want to quailify myself in that I have a MFA degree speializing in jewelry andit's history and techniques. Casting is a process which is utilized in the field of jewelry covering both handmade (hand crafted) and mass (industrialized) production. To eliminate this process form the language (vocabulary) of the artist, is to restrict many works which are multi-component, simply because industry has adapted the process for mass production of stand-alone units. (i.e., reproduction for reproduction's sake) All methods of casting utilize a mold of some type, that the "lost wax" process is just one method(the use of an investment) that has been developed and rates in the history with carved and impression molds (it is in fact an impression mold, in the round, it is not an invention of the industrial age, rather it has been adapted by it) The basic techniques of producing jewelry have not changed for millenniums a modern adaption of the use of machines do nothing but speed the processes. The Etruscans had a primitive foot powered lathe, an adaptation in process allowed metal forms to be "spun" as an advancement of sinking or raising hollowware pieces. Does the Federal Trade Commission intend to extend the reach of its long arm to classify a technique which History and the population of the entire civilized world calls ART, to be non-hand made, simply because of natural step advance? How primitive!!! It is right that pieces mass produced, not be called neither "hand-made "or "hand-crafted" yet lost wax (investment) casting of single or a base for a limited series of (individual stand-alone pieces) or multi-component works as bracelets , neck-pieces, belts, etc. cannot be classed as not handmade. The intent of a separation of handmade/crafted from mass production is in both the intent and utilization of the producer, not the technical process of casting; individual pieces as a series and components aside, it is the mass production of the item which causes concern to the individual jeweler. The final judgment of if a body of work is intended as mass produced or intended as a series (choice in variety) would be up to the vender in maintaining the standards which them uphold. The FTC was intended to set and maintain industry not the craftsman; example: there is an art to beading, putting stuff on a string is not beading, yet no one seems to want to regulate that venue, the customer does fine at this task. The amount of pieces contained within a series, may very well be a major part of the ART STATEMENT.