Restricted Substance Problem Solution Prevention Library

1
Restricted Substance Problem Solution Prevention
Library
Heavy Metals
Formaldehyde
Aromatic Amines
Disperse Dyes
APEOs
Organotins
Phthalates
2
Problem 1

• 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
3

• 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 childrens garments

Problem 1
Formaldehyde
4
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

• Printer looked for a non-formaldehyde catalyst
  system for discharge designs.
• Printer and garment factory only show prototypes
  to brand that meet RSL requirements

Formaldehyde
5
Problem 2

• 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
6
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 be
  established
• Developed a new material that would meet
  the performance needs
  and RSL requirements

Formaldehyde
7
Problem 2

• PREVENTION
• Low level formaldehyde failures were still
  common in the cap factories
• Factory had not switched materials for all
  customers

• Contamination from drying units and factory air
  handling units
• Phase out of all formaldehyde containing
  chemicals was the only way to guarantee 100
  compliance

Formaldehyde
8
Problem 3

• Urea formaldehyde resins are common chemicals
  used in durable press resins
• Resins are used to trap wrinkles and stiffen
  fabrics

• Cotton t-shirt designed by brand to have
  wrinkled effect by using durable press resin
  treatment
• Garment had formaldehyde concentration above RSL
  limit

Formaldehyde
9
Problem 3

• 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
10
Problem 3

• PREVENTION
• 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

Formaldehyde
11
Problem 4

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

• An alternative approach is to use a blocked
  diisocyanate crosslinker which is formaldehyde
  free
• Isocyanates can be sensitizing and carcinogenic
  so proper curing is required

Formaldehyde
12
Problem 4

• 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 utilizing diisocyanate crosslinkers

Formaldehyde
13
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

• EHS must also be considered when utilizing new
  technologies
• Work closely with suppliers, technical
  professionals, and laboratories when starting new
  techniques

Formaldehyde
14
Problem 5

• Cotton fabric failed childrens 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 Brands
  formaldehyde requirements

Formaldehyde
15
Problem 5

• Fabric supplier checked their production record
  and found 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
16
Problem 5

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

• 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
17
Problem 6

• 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 chemicals without any intended
  chemical function

Formaldehyde
18
Problem 6

• As a short-term solution, Leather supplier took
  strict measure of decreasing the usage of the
  Formaldehyde containing chemical in its formula
  to reduce Formaldehyde content level in finished
  products
• For long-team action, Leather supplier found a
  Formaldehyde free chemical to replace the
  contaminated chemical in its re-tanning process

Formaldehyde
19
Problem 6

• PREVENTION
• 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

Formaldehyde
20
Problem 1

• Brand designed a corded childrens sweater
• Factory chose the cord supplier because it was
  considered a standard item
• Cord supplier used a dyestuff that contained
  prohibited azo-dyes

Aromatic Amines
21
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
  requirements
• RSL Compliant dyestuff from quality chemical
  company with little to no cost impact available

Aromatic Amines
22
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
23
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
24
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
25
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
26
Problem 2

• 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
27
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
28
Problem 2

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

• Compliance of raw materials will lead to
  compliant finished products

Heavy Metals
29
Problem 3

• 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
30
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 its
  suppliers

Heavy Metals
31
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
32
Problem 4

• Lead was detected in the coating on the top
  cover fabric of 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
33
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
34
Problem 5

• Chromium was detected on wool/nylon fabric
• It appeared the mill had used a metalized dye
• The mill already had 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
35
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
36
Problem 6

• 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 that had
  contaminated a mixing beaker

Heavy Metals
37
Problem 6

• PREVENTION
• Heat transfer supplier eliminated suspected
  cleaning agent
• Changed its 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
38
Problem 1

• Many screen print inks contain PVC
• PVC screen print 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
39
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
40
Problem 1

• PREVENTION
• Contamination is a big problem in RSL compliance
  
• When developing a program think about everything
  that touches the product

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

Phthalates
41
Problem 2

• 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

• Manufacturer claimed to use acetyltributylcitrate
  (ATBC) as plasticizer alternative in flip flop
  sandals
• ATBC is considered a safer plasticizer
  alternative

Phthalates
42
Problem 2

• Consumer complaints that the flip flops had
  sticky feeling and were removing lacquer finish
  on wood floors
• Laboratory analysis detected tributycitrate
  (TBC) instead of ATBC as manufacturer claimed

• TBC is a known solvent for decoating furniture
• Manufacturer substituted TBC as a cheaper
  alternative for ATBC

Phthalates
43
Problem 2

• PREVENTION
• Manufacturers must stick to recipes described to
  brands
• Any substitutions should be approved by brand

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

Phthalates
44
Problem 1

• Scouring agent is used to remove oils and fats
  from textiles
• Many scouring agents contain APEOs (alkylphenol
  ethoxylates) as a surfactant
• APEOs will remain on the fabric after the
  scouring process

APEOs
45
Problem 1

• Vendor chose scouring agent because it removed
  all oils for even dyeing
• Vendor knew it contained APEOs
• Vendor did not know brand was concerned about
  APEOs on finished product
• Vendor sourced an APEO free alternative scour
  agent with no cost increase

APEOs
46
Problem 1

• PREVENTION
• Communication
• Alternatives exist for most restricted chemicals

• Just ask for them

APEOs
47
Problem 2

• APEO was detected in an insole board
• Supplier investigated fibers used to produce the
  board and confirmed no APEOs were used
• Emulsion used to coat fiber board was
  contaminated with APEOs
• Supplier switched to a new batch of emulsion and
  component passed RS testing

APEOs
48
Problem 2

• PREVENTION
• Contamination is a big problem in RSL compliance
  
• When developing a program think about everything
  that touches the product

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

APEOs
49
Problem 3

• NPEO was detected in pig skin leather
• NPEO is usually associated with degreasing
  agents
• Their previous source of degreasing agent was
  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

APEOs
50
Problem 3

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

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

APEOs
51
Problem 1

• Foil screen prints on childrens 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
52
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
53
Problem 1

• PREVENTION
• Communication
• High quality adhesive chemicals should be
  requested

• Non-organotin heat stabilizer alternatives are
  available

Organotins
54
Problem 1

• Phenol was detected in the adhesive used to
  manufacture shoes during a random audit
• Chemical supplier believed that there was no
  Phenol in its adhesive
• Supplier individually tested each of the
  chemicals used to manufacture adhesive to detect
  Phenol

Misc.
55
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

Misc.
56
Problem 1

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

- Especially if a restricted chemical is a known
precursor.
Misc.
57
Problem 2

• Molded black rubber logo failed testing for
  Polyaromatic Hydrocarbons (PAHs)
• Rubber raw material supplier confirmed that one
  of the rubber raw materials, Naphthenic oil,
  contained PAHs

Misc.
58
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

Misc.
59
Problem 2

• PREVENTION
• RS requirements must be communicated to all down
  stream suppliers
• Down stream suppliers must understand RS
  requirements and impacts of raw material choices

Misc.
60
Problem 3

• 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.
61
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.
62
Problem 3

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

• (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

Misc.
63
Problem 4

• 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.
64
Problem 4

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

• 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

Misc.
65
Problem 5

• 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

Misc.
66
Problem 5

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

Misc.
67
Problem 6

• Black cotton / rayon socks were a high volume
  carryover item
• No customer complaints 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

Misc.
68
Problem 6

• Socks were tested for VOCs 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

• 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

Misc.
69
Problem 1

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

Disperse Dyes
70
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

Disperse Dyes
71
Problem 1

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

Disperse Dyes
72
Restricted Substance Problem Solution Prevention
Library
Heavy Metals
Formaldehyde
Aromatic Amines
Disperse Dyes
APEOs
Organotins
Phthalates