Restricted Substance Problem Solution Prevention Library Formaldehyde Aromatic Amines Heavy MetalsAPEOs Phthalates Organotins Disperse Dyes

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) catalystFormaldehydeProblem #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 childrens garments

FormaldehydeProblem #1

PREVENTION: Printer developed a quality control process to manage print recipes Curing times and temperatures kept consistent to meet RSL requirements for adult productsFormaldehydeProblem #1 Printer looked for a non-formaldehyde catalyst system for discharge designs. Printer and garment factory only show prototypes 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% FormaldehydeProblem #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 requirementsFormaldehydeProblem #2

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

FormaldehydeProblem #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 fabricsFormaldehydeProblem #3 Cotton t-shirt designed by brand to have wrinkled effect by using durable press resin treatment

Garment had formaldehyde concentration above RSL limit

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 needsFormaldehydeProblem #3

PREVENTION: In some cases a chemical on an RSL can be used Conditions must be carefully controlled to manage finished product complianceFormaldehydeProblem #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 failuresFormaldehydeProblem #4 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

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 crosslinkersFormaldehydeProblem #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 createdFormaldehydeProblem #4 EH&S must also be considered when utilizing new technologies Work closely with suppliers, technical professionals, and laboratories when starting new techniques

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 FormaldehydeProblem #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. FormaldehydeProblem #5

PREVENTION: The only 100% method to meet RS requirements is to eliminate the use of chemicals on an RSLFormaldehydeProblem #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 chemicals without any intended chemical function FormaldehydeProblem #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 processFormaldehydeProblem #6

FormaldehydeProblem #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 childrens sweater Factory chose the cord supplier because it was considered a standard item Cord supplier used a dyestuff that contained prohibited azo-dyesAromatic AminesProblem #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 availableAromatic AminesProblem #1

PREVENTION: RS requirements must be communicated to all suppliers Laws require product compliance A small component prevented the entire garment from being soldAromatic AminesProblem #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 MetalsProblem #1

PVC layer was substituted with a TPU (thermoplastic polyurethane) TPU was tested to be RSL compliant TPU had performed better for feel and durabilityHeavy MetalsProblem #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- safetyHeavy MetalsProblem #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 MetalsProblem #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 productHeavy MetalsProblem #2

PREVENTION: Source raw materials from reliable suppliers with a well controlled manufacturing processHeavy MetalsProblem #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 contaminationHeavy MetalsProblem #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 suppliersHeavy MetalsProblem #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 productionHeavy MetalsProblem #3

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 MetalsProblem #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 productionHeavy MetalsProblem #4

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 okayHeavy MetalsProblem #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 MetalsProblem #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 that had contaminated a mixing beakerHeavy MetalsProblem #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 requirementsHeavy MetalsProblem #6

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 printingPhthalatesProblem #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 compliancePhthalatesProblem #1

PREVENTION: Contamination is a big problem in RSL compliance When developing a program think about everything that touches the productPhthalatesProblem #1 The best approach is to make sure all raw materials meet 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 hazardsPhthalatesProblem #2 Manufacturer 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 sticky feeling and were removing lacquer finish on wood floors Laboratory analysis detected tributycitrate (TBC) instead of ATBC as manufacturer claimedPhthalatesProblem #2 TBC is a known solvent for decoating furniture Manufacturer substituted TBC as a cheaper alternative for ATBC

PREVENTION: Manufacturers must stick to recipes described to brands Any substitutions should be approved by brandPhthalatesProblem #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 APEOs (alkylphenol ethoxylates) as a surfactant APEOs will remain on the fabric after the scouring processAPEOsProblem #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 increaseAPEOsProblem #1

PREVENTION: Communication Alternatives exist for most restricted chemicalsAPEOsProblem #1 Just ask for them

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 testingAPEOsProblem #2

APEOsProblem #2 Chemicals and tools must be properly handled, stored, and sanitized to prevent contaminationPREVENTION: 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 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 agentAPEOsProblem #3

APEOsProblem #3 A thorough RS testing program should focus testing on high risk items, unknown materials, or inexperienced suppliersPREVENTION: When switching suppliers, for any reason, always share RS requirements with new supplier

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 adhesiveOrganotinsProblem #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 organotinsOrganotinsProblem #1

PREVENTION: Communication High quality adhesive chemicals should be requestedOrganotinsProblem #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 its adhesive Supplier individually tested each of the chemicals used to manufacture adhesive to detect PhenolMisc.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 PhenolProblem #1Misc.

PREVENTION:

Establish routine testing procedure for presence of restricted substances in all process chemicals Problem #1Misc.- Especially if a restricted chemical is a known precursor.

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.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 #2Misc.

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 #2Misc.

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 testingMisc.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 freeMisc.Problem #3

PREVENTION: Review MSDS to see if any restricted chemicals are present, evaluate usage and process conditionsMisc.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 tanksMisc.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 problemsProblem #5Misc.

PREVENTION:

Pre-production testing provided time to seek out alternatives and achieve chemical compliance Problem #5Misc.

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 smellProblem #6Misc.

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 informationProblem #6Misc.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 failures Supplier tested all yarns used to make this label & no restricted disperse dye was detectedDisperse DyesProblem #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 colorProblem #1Disperse Dyes

Problem #1Disperse DyesPREVENTION: 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 HeavyMetalsAPEOs Phthalates Organotins Disperse Dyes

****