16 CFR Part 23, Guides for the Jewelry, Precious Metals, and Pewter Industries; Project No. G711001 #00056

Submission Number:
00056
Commenter:
Vincent Zahnle
State:
Missouri
Initiative Name:
16 CFR Part 23, Guides for the Jewelry, Precious Metals, and Pewter Industries; Project No. G711001
The proposal to exclude cast jewelry from the 'Handmade Claims' section of the Jewelry Guidelines is completely inappropriate. I design and cast jewelry in silver, bronze, brass, and pewter, a few pieces at a time, using basic processes that (Aside from using electricity rather than charcoal, servants, and a bellows to melt the metal and burn out the casting flasks), go back to the Bronze Age. I pour the waxes and touch them up by hand, assemble them onto sprues one at a time, and finish the casting with hand tools aside from a handheld rotary tool and a belt sander for cleanup. The idea that my work is not 'Handmade' because some bureaucrat so decrees is insane. If the problem is industrial scale production, this is a completely wrong-headed and counterproductive way to approach it. A couple of sample pics are attached, one of my unfinished castings and two of finished pieces.