Restricted Substance Problem Solution Prevention Library Formaldehyde Aromatic Amines Heavy Metals...

Restricted Substance Problem Solution Prevention Library

Formaldehyde

Aromatic Amines

HeavyMetals

APEO’s

Phthalates

Organotins

Disperse Dyes

Misc.

• Soft hand screen print using discharge printing technique

• Printer performed a strike off

• Strike off approved for appearance

• Printer could not meet formaldehyde requirements of the brand because the ink system used Zinc Formaldehyde Sulfoxylate (ZFS) catalyst

Formaldehyde

Problem #1

• Discharge ink systems require chemicals to break down the color of the dyed garment

• Many discharge systems contain formaldehyde

• Printer worked with ink supplier to optimize printing concentrations, curing times and temperatures

• Reduced but did not remove 100% of formaldehyde in the final prints.

• Product could not be used on children’s garments.

Formaldehyde

Problem #1

PREVENTION:• Printer developed a quality control process to manage print recipes

• Curing times and temperatures kept consistent to meet RSL requirements for adult products

Formaldehyde

Problem #1

• Printer looked for a non-formaldehyde catalyst system for discharge designs.

• Printer and garment factory only show protos to brand that meet RSL requirements

• Urea formaldehyde resins are common chemicals used in durable press resins

• Resins are used to prevent wrinkles and stiffen fabrics

• Resin was applied to the backing fabric on the cap to maintain its shape

• Backing fabric was less than 1% of the weight of the cap, but the amount of formaldehyde in the resin exceeded RSL limits by almost 200%

Formaldehyde

Problem #2

• Caps were not able to ship while solutions and alternatives were investigated

• Some materials were washed to reduce the formaldehyde

• Some other materials were replaced with alternatives

• No process to control the formaldehyde could not be established

• Developed a new material that would meet the performance needs and RSL requirements.

Formaldehyde

Problem #2

PREVENTION:

• Low level formaldehyde failures were still common in the cap factories

• Factory had not switched materials for all customers

Formaldehyde

Problem #2

• Contamination from drying units and factory air handling units

• Phase out of all formaldehyde containing chemicals was the only way to guarantee 100% compliance

• Urea formaldehyde resins are common chemicals used in durable press resins

• Resins are used to trap wrinkles and stiffen fabrics

Formaldehyde

Problem #3

• Cotton t-shirt designed by brand to have wrinkled effect by using durable press resin treatment

• Garment had formaldehyde concentration above RSL limits

• Wrinkle finish had been cured for too short a time

• Cure temperature was also too low

• Process changes improved durability and RSL compliance

• Always follow manufacturer guidance for process conditions

• Always tell chemical supplier your compliance needs

Formaldehyde

Problem #3

PREVENTION:

• In some cases a chemical on an RSL can be used

• Conditions must be carefully controlled to manage finished product compliance

Formaldehyde

Problem #3

• Work with high quality chemical suppliers

• Always follow chemical supplier guidelines

• Formaldehyde releasing melamine resin is commonly used as a crosslinker in pigment printed garments and will cause formaldehyde failures

Formaldehyde

Problem #4

• An alternative approach is to use a blocked diisocyanate crosslinker which is formaldehyde free

• Isocyanates can be sensitizing and carginogenic so proper

curing is required

• Diisocyanate crosslinker must be fully cured, used in correct ratios, and dried off

• Printer will have to work with chemical supplier to develop proper conditions depending on equipment, temperature, and humidity

• Measures must be taken to prevent occupational hazards when utilitizing diisocyanate crosslinkers

Formaldehyde

Problem #4

PREVENTION:

• In this case chemical supplier provided formaldehyde free option because printer requested it, but printer did not ask if any new problems were created

Formaldehyde

Problem #4

• ES&H must also be considered when utilizing new technologies

• Work closely with suppliers, technical professionals, and laboratories when starting new techniques

• Cotton fabric failed Formaldehyde children’s Formaldehyde standard

• Supplier knew that Formaldehyde was contained in the raw chemicals applied to the fabric

• Supplier had worked with chemical supplier to control the concentration applied to meet Brand’s formaldehyde requirements

Formaldehyde

Problem #5

• Fabric supplier checked their production record and found out a typo in the batch formula which caused the formaldehyde concentration to exceed RS requirement

• Supplier has changed their quality control procedures to review the formula before official production to avoid the same mistakes in the future.

Formaldehyde

Problem #5

PREVENTION:

• The only 100% method to meet RS requirements is to eliminate the use of chemicals on an RSL

Formaldehyde

Problem #5

• If a supplier knows they are using a chemical on an RSL they must establish and carefully monitor control procedures to ensure compliance

• Supplier should also increase testing for affected products during development and production

• Formaldehyde was found in a Full Grain Leather material

• Leather supplier initiated investigation and found out that Formaldehyde was used in one of the re-tanning chemical without any intended chemical function

Formaldehyde

Problem #6

• As a short-term solution, Leather supplier took strict measurement of decreasing the % usage of the Formaldehyde containing chemical in their formula to reduce Formaldehyde content level in their finished products

• For long-team action, Leather supplier found a Formaldehyde free chemical to replace the contaminated chemical in their re-tanning process.

Formaldehyde

Problem #6

Formaldehyde

Problem #6PREVENTION:

• In some cases a chemical on an RSL can be used

• Conditions must be carefully controlled to manage finished product compliance

• Work with high quality chemical suppliers

• Always follow chemical supplier guidelines

• When possible search for formaldehyde free alternatives

• Brand designed a corded children’s sweater

• Factory chose the cord supplier because it was considered a “standard” item

• Cord supplier used a dyestuff that contained prohibited aromatic amines

Aromatic Amines

Problem #1

• Product was already manufactured so the only solution was an expensive decision not to sell the product

• Lots of draw cords available to meet RSL

• Dyestuff from quality chemical company with little to no cost impact

Aromatic Amines

Problem #1

PREVENTION:

• RS requirements must be communicated to all suppliers

• Laws require product compliance

• A small component prevented the entire garment from being sold

Aromatic Amines

Problem #1

• Cadmium found in outer PVC (polyvinyl chloride) layer of soccer ball

• PVC commonly contains heavy metal stabilizers

• PVC also often contains phthalates for flexibility

• Cadmium was used as a stabilizer

• Cadmium can also be used in pigments

Heavy Metals

Problem #1

• PVC layer was substituted with a TPU (thermoplastic polyurethane)

• TPU was tested to be RSL compliant

• TPU had performed better for feel and durability

Heavy Metals

Problem #1

PREVENTION:

• When investigating new materials or production techniques brands and suppliers have to work together to meet a variety of goals including:

- price

- performance

- quality

- safety

Heavy Metals

Problem #1

• Red paint used on trim of an infants shoe found to contain lead exceeding RSL limits.

• Lead was used as a pigment in the paint

• Lead is acutely toxic in high concentrations

Heavy Metals

Problem #2

• Brand voluntarily recalled product at a cost of $6.7 million

• Factory began more complete testing program for sourced raw materials

• Lead in raw material will still be lead in finished product

Heavy Metals

Problem #2

PREVENTION:

• Source raw materials from reliable suppliers with a well controlled manufacturing process

Heavy Metals

Problem #2

• Compliance of raw materials will lead to compliant finished products

• PU (polyurethane) coated fabric was found to contain high levels of lead

• PVC and phthalates had been eliminated from the product

• Lead could be used as a stabilizer or pigment

• Not likely caused by contamination

Heavy Metals

Problem #3

• Brand gave RSL requirements to garment factory

• Not all of the requirements were communicated to PU fabric vendor

• Factory is expected to communicate RSL to their suppliers

Heavy Metals

Problem #3

PREVENTION:

• Brands include all members of supply chain in RSL training

• Garment factories must fully communicate all brand requirements to their downstream suppliers

• Strategically test products at all stages of production

Heavy Metals

Problem #3

• Lead was detected in the coating on the top cover fabric of some sock liners

• Heavy metals including lead are often used in low cost pigments and inks

• Lead pigment was used in the heat transfer on the sock liner.

Heavy Metals

Problem #4

PREVENTION:

• Brands include all members of supply chain in RSL training

• Garment factories must fully communicate all brand requirements to their downstream suppliers

• Consider even the smallest components in the RS compliance scenario

• Strategically test products at all stages of production

Heavy Metals

Problem #4

• Chromium was detected on wool/nylon fabric

• It appeared the mill had used a metalized dye

• This same mill had already has the same problem before

• Mill provided dye recipe and dye lot records and the recipe was not the problem

• During mill audit brand reviewed dyes and auxiliary chemicals – all okay

Heavy Metals

Problem #5

PREVENTION:

• Determined that mill had old stock of fabric that had failed previously

• Mill had submitted wrong sample to laboratory for testing

• Be aware of your inventory management systems

• If all product is not RS compliant, provide clearly marked storage areas

***It is a best practice to produce only compliant materials in order to avoid contamination issues.

Heavy Metals

Problem #5

• Printed heat transfer failed for mercury

• Mercury can be used as a pigment

• In this case the source of the mercury was determined to be a cleaning solvent which contaminated a mixing beaker

Heavy Metals

Problem #6

PREVENTION:

• Heat transfer supplier eliminated suspected cleaning agent

• Changed their process to mix inks in disposable mixing containers

• Established time frames for keeping custom mixed inks

• Printer already had a separate mixing kitchen for this brand due to PVC requirements

Heavy Metals

Problem #6

• Many screen print inks contain PVC

• PVC screen prink inks often contain phthalates

• Phthalates are used to soften ink and prevent cracking

• Printed t-shirts did not meet phthalate requirements for DEHP

• All print chemicals were tested phthalate free prior to printing

Phthalates

Problem #1

• Spray adhesive used to hold garment in place during printing contained DEHP

• Adhesive contaminated finished garment

• Printer substituted a different spray adhesive to achieve compliance

Phthalates

Problem #1

PREVENTION:

• Contamination is a big problem in RSL compliance

• When developing a program think about everything that touches the product

Phthalates

Problem #1

• The best approach is to make sure all raw materials meet the RSL requirements

• Plasticizers are commonly used in plastics and foams to increase flexibility and improve performance

• Many phthalate based plasticizers have been banned as toxic or reproductive hazards

Phthalates

Problem #2

• Manufactured claimed to use acetyltributylcitrate (ATBC) as plasticizer alternative in flip flop sandals

• ATBC is considered a safer plasticizer alternative

• Consumer complaints that the flip flops had tacky feeling and were removing lacquer finish on wood floors

• Laboratory analysis detected tributycitrate (TBC) instead of ATBC as manufacturer claimed

Phthalates

Problem #2

• TBC is a known solvent for decoating furniture

• Manufactured substituted TBC as a cheaper alternative for ATBC

PREVENTION:

• Manufacturers must stick to recipes described to brands

• Any substitutions should be approved by brand

Phthalates

Problem #2

• Chemical substitutions should not be made on price alone without safety, quality, performance impact

• Scouring agent is used to remove oils and fats from textiles

• Many scouring agents contain APEO’s (alkylphenol ethoxylates) as a surfactant

• APEO’s will remain on the fabric after the scouring process

APEO’s

Problem #1

• Vendor chose scouring agent because it removed all oils for even dyeing

• Vendor new it contained APEO’s

• Vendor did not know brand was concerned about APEO’s on finished product

• Vendor sourced an APEO free alternative scour agent with no cost increase

APEO’s

Problem #1

PREVENTION:

• Communication

• Alternatives exist for most restricted chemicals

APEO’s

Problem #1

• Just ask for them

• APEO was detected in an insole board

• Supplier investigated fibers used to produce the board and confirmed no APEO’s were used

• Emulsion used to coat fiber board was contaminated with APEO’s

• Supplier switched to a new batch of emulsion and component passed RS testing

APEO’s

Problem #2

APEO’s

Problem #2

• Chemicals and tools must be properly handled, stored, and sanitized to prevent contamination.

PREVENTION:

• Contamination is a big problem in RSL compliance

• When developing a program think about everything that touches the product

• NPEO was detected in pig skin leather

• NPEO is usually associated with the degreasing agents

• Their previous source of degreasing agent is from Japan and known not to contain NPEO

• A ban on raw materials exported from Japan forced them to change to an alternate source

• NPEO source was identified as new degreasing agent.

APEO’s

Problem #3

APEO’s

Problem #3

• A thorough RS testing program should focus testing on high risk items, unknown materials, or inexperienced suppliers

PREVENTION:

• When switching suppliers, for any reason, always share RS requirements with new supplier

• Foil screen prints on children’s t-shirts found to contain organotins

• Organotins are often used as heat stabilizers in printing and transfer processes

• Organotins were found through testing of the foil backing adhesive

Organotins

Problem #1

• Print house had MSDS for all foil print papers and adhesives

• All chemical suppliers were contacted to see if they used organotins

• Some of the cheap adhesives contained organotins

Organotins

Problem #1

PREVENTION:

• Communication

• High quality adhesive chemicals should be requested

Organotins

Problem #1

• Non-organotin heat stabilizer alternatives are available

• Phenol was detected in the adhesive used to manufacture shoes during a random audit

• Chemical supplier believed that there was no Phenol in their adhesive

• Supplier individually tested each of the chemical used to manufacture adhesive to detect for Phenol.

Misc.

Problem #1

• One of the chemicals used to produce adhesive had small residual of Phenol

• Phenol used in the manufacturing but was supposed to be removed during processing

• Supplier reviewed the chemical recovery process to ensure complete recovery of Phenol

Problem #1

Misc.

PREVENTION:

• Establish routine testing procedure for presence of restricted substances in all process chemicals

Problem #1

Misc.

- Especially if a restricted chemical is a known precursor.

• Molded black rubber logo failed on Polyaromatic Hydrocarbons (PAHs)

• Rubber raw material supplier confirmed that one of the rubber raw materials, Naphthenic oil, contained PAHs

Misc.

Problem #2

• Rubber supplier reformulated material and substituted naphthenic oil out of formula

• RS testing of the improved sample showed the new formula is RS compliant

Problem #2

Misc.

PREVENTION:

• RS requirements must be communicated to all down stream suppliers

• Down stream suppliers must understand RS requirements and impacts of raw material choices

Problem #2

Misc.

• PFOA was detected in a webbing (65% Polyester + 35% recycled PET)

• Previous test of material met RS requirements

• Supplier told brand that a non-wicking treatment had been applied to the material to provide water repellency since the last RS testing.

Misc.

Problem #3

• MSDS for the non-wicking chemical showed PFOA content and tests failed RS requirements

• Supplier worked with the non-wicking additive supplier and replaced it with a non-wicking additive which is PFOS/PFOA free

Misc.

Problem #3

PREVENTION:

• Review MSDS to see if any restricted chemicals are present, evaluate usage and process conditions

Misc.

Problem #3

*(MSDS will not include low percentage chemicals and chemical concentration in finished product will depend on chemical and application. MSDS should not be used to determine RS compliance.)

• Alternatives exist for most restricted chemicals – ask for them

• Small amount of Volatile Organic Compounds (VOC) was detected in the ink raw materials at screen print facility

• Printer investigated and discovered contamination from solvent supplier recycling solvent tanks

Misc.

Problem #4

PREVENTION:

• Chemicals and tools must be properly handled, stored, and sanitized to prevent contamination.

Misc.

Problem #4

• Know the contents of spot cleaners and other cleaners because they will be used in contact with finished products

• Any chemical supplier to a facility must know the RS requirements to avoid contamination

• Phenol was detected on silk fabric with a print during pre-production testing

• By analysing individual raw materials the thickener (guar gum) was identified to be contaminated

• Printer switched from guar gum to alginate thickener to avoid contamination problems

Problem #5

Misc.

PREVENTION:

• Pre-production testing provided time to seek out alternatives and achieve chemical compliance

Problem #5

Misc.

• Black cotton / rayon socks were a high volume carryover item

• No customer complaints for , until a cluster of 5 complaints for skin irritations within 1 month

• Samples tested for pH, formaldehyde, restricted dyes – all tests negative

• Samples pulled from store stock were noted to have a “solvent” smell

Problem #6

Misc.

• Socks were tested for VOC’s and found to contain Dimethylformamide, methylene chloride, and acetone

• Supplier was found to be lubricating the knitting yarn with an unlabelled solvent with no MSDS information

Problem #6

Misc.

SOLUTION:• Production was stopped immediately• All current stock/shipments destroyed• Supplier is under review and production in

their facility has been suspended• Supplier required to prove factory

corrective action plan before production can resume

• Restricted disperse dye was found in a woven label

• All the yarns used to make this label were from well known suppliers and there was no history of RSL failure

• Supplier tested all yarns used to make this label & no restricted disperse dye was detected

Disperse Dyes

Problem #1

• Only remaining component was the backer

• Testing of the backer only produced a positive result for restricted disperse dye

• Backer was changed and supplier destroyed all the inventory of failed backer color

Problem #1

Disperse Dyes

Problem #1

Disperse Dyes

PREVENTION:

• Laws require product compliance

• A small component or part of a component can cause a product to be non-compliant

Restricted Substance Problem Solution Prevention Library

Formaldehyde

Aromatic Amines

HeavyMetals

APEO’s

Phthalates

Organotins

Disperse Dyes

Misc.