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Restricted Substance Problem Solution Prevention Library

Restricted Substance Problem Solution Prevention Library

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Restricted Substance Problem Solution Prevention Library

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  1. Misc. Restricted Substance Problem Solution Prevention Library Heavy Metals Formaldehyde Aromatic Amines Disperse Dyes APEO’s 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 children’s 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 • EH&S 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 fabricfailed 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

  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 children’s 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 infant’s 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 coverfabric 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 APEO’s (alkylphenol ethoxylates) as a surfactant • APEO’s will remain on the fabric after the scouring process APEO’s

  45. Problem #1 • Vendor chose scouring agent because it removed all oils for even dyeing • Vendor knew 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

  46. Problem #1 • PREVENTION: • Communication • Alternatives exist for most restricted chemicals • Just ask for them APEO’s

  47. Problem #2 • 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

  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 APEO’s

  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 APEO’s

  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 APEO’s