PM Technology Consultants
16 CFR Part 23, Guides for the Jewelry, Precious Metals, and Pewter Industries; Project No. G711001
I am a metallurgist by training and have worked in the jewelry industry for over 30 years. I was the Vice President of Technology at Leach and Garner (currently a Berkshire Hathaway Company) and retired from there in 2008. My comments on some of the proposed changes to the Jewelry Guidelines are given below. Below threshold (10K) Gold: FTC should keep the 10K threshold and keep the current karat gold standard. Allowing lower than the 10K item to be stamped as karat gold will result in customer confusion and disillusionment later when the item tarnishes or does not perform according to their expectations. Below threshold (925) Silver: As in the case gold, the 925 threshold for silver should be maintained. Using PPT to indicate gold fineness: PPT is used internationally and its use in the United States should allowed. The karat marking should be also allowed.