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.
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