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.