Presentation on theme: "Restricted Substance Problem Solution Prevention Library"— Presentation transcript:
1 Restricted Substance Problem Solution Prevention Library HeavyMetalsFormaldehydeAromatic AminesDisperse DyesMisc.APEO’sOrganotinsPhthalates
2 Problem #1 Formaldehyde Soft hand screen print using discharge printing techniquePrinter performed a strike offStrike off approved for appearancePrinter could not meet formaldehyde requirements of the brand because the ink system used Zinc Formaldehyde Sulfoxylate (ZFS) catalystFormaldehyde
3 Problem #1 Formaldehyde Discharge ink systems require chemicals to break down the color of the dyed garmentMany discharge systems contain formaldehydePrinter worked with ink supplier to optimize printing concentrations, curing times and temperaturesReduced but did not remove 100% of formaldehyde in the final prints.Product could not be used on children’s garments.Problem #1Formaldehyde
4 Problem #1 PREVENTION: Formaldehyde Printer developed a quality control process to manage print recipesCuring times and temperatures kept consistent to meet RSL requirements for adult productsPrinter looked for a non-formaldehyde catalyst system for discharge designs.Printer and garment factory only show protos to brand that meet RSL requirementsFormaldehyde
5 Problem #2 Formaldehyde Urea formaldehyde resins are common chemicals used in durable press resinsResins are used to prevent wrinkles and stiffen fabricsResin was applied to the backing fabric on the cap to maintain its shapeBacking 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 Formaldehyde Caps were not able to ship while solutions and alternatives were investigatedSome materials were washed to reduce the formaldehydeSome other materials were replaced with alternativesNo process to control the formaldehyde could not be establishedDeveloped a new material that would meet the performance needs and RSL requirements.Formaldehyde
7 Problem #2 Formaldehyde PREVENTION: Low level formaldehyde failures were still common in the cap factoriesFactory had not switched materials for all customersContamination from drying units and factory air handling unitsPhase out of all formaldehyde containing chemicals was the only way to guarantee 100% complianceFormaldehyde
8 Problem #3 Formaldehyde Urea formaldehyde resins are common chemicals used in durable press resinsResins are used to trap wrinkles and stiffen fabricsCotton t-shirt designed by brand to have wrinkled effect by using durable press resin treatmentGarment had formaldehyde concentration above RSL limitsFormaldehyde
9 Problem #3 Formaldehyde Wrinkle finish had been cured for too short a timeCure temperature was also too lowProcess changes improved durability and RSL complianceAlways follow manufacturer guidance for process conditionsAlways tell chemical supplier your compliance needsFormaldehyde
10 Problem #3 Formaldehyde PREVENTION: In some cases a chemical on an RSL can be usedConditions must be carefully controlled to manage finished product complianceWork with high quality chemical suppliersAlways follow chemical supplier guidelinesFormaldehyde
11 Problem #4 Formaldehyde Formaldehyde releasing melamine resin is commonly used as a crosslinker in pigment printed garments and will cause formaldehyde failuresAn alternative approach is to use a blocked diisocyanate crosslinker which is formaldehyde freeIsocyanates can be sensitizing and carginogenic so proper curing is requiredFormaldehyde
12 Problem #4 Formaldehyde Diisocyanate crosslinker must be fully cured, used in correct ratios, and dried offPrinter will have to work with chemical supplier to develop proper conditions depending on equipment, temperature, and humidityMeasures must be taken to prevent occupational hazards when utilitizing diisocyanate crosslinkersFormaldehyde
13 Problem #4 Formaldehyde PREVENTION: In this case chemical supplier provided formaldehyde free option because printer requested it, but printer did not ask if any new problems were createdES&H must also be considered when utilizing new technologiesWork closely with suppliers, technical professionals, and laboratories when starting new techniquesFormaldehyde
14 Problem #5 Formaldehyde Cotton fabric failed Formaldehyde children’s Formaldehyde standardSupplier knew that Formaldehyde was contained in the raw chemicals applied to the fabricSupplier had worked with chemical supplier to control the concentration applied to meet Brand’s formaldehyde requirementsFormaldehyde
15 Problem #5 Formaldehyde Fabric supplier checked their production record and found out a typo in the batch formula which caused the formaldehyde concentration to exceed RS requirementSupplier 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 Formaldehyde PREVENTION: The only 100% method to meet RS requirements is to eliminate the use of chemicals on an RSLIf a supplier knows they are using a chemical on an RSL they must establish and carefully monitor control procedures to ensure complianceSupplier should also increase testing for affected products during development and productionFormaldehyde
17 Problem #6 Formaldehyde Formaldehyde was found in a Full Grain Leather materialLeather supplier initiated investigation and found out that Formaldehyde was used in one of the re-tanning chemical without any intended chemical functionFormaldehyde
18 Problem #6 Formaldehyde 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 productsFor long-team action, Leather supplier found a Formaldehyde free chemical to replace the contaminated chemical in their re-tanning process.Formaldehyde
19 Problem #6 Formaldehyde PREVENTION: In some cases a chemical on an RSL can be usedConditions must be carefully controlled to manage finished product complianceWork with high quality chemical suppliersAlways follow chemical supplier guidelinesWhen possible search for formaldehyde free alternativesFormaldehyde
20 Problem #1 Aromatic Amines Brand designed a corded children’s sweater Factory chose the cord supplier because it was considered a “standard” itemCord supplier used a dyestuff that contained prohibited aromatic aminesAromatic Amines
21 Problem #1 Aromatic Amines Product was already manufactured so the only solution was an expensive decision not to sell the productLots of draw cords available to meet RSLDyestuff from quality chemical company with little to no cost impactAromatic Amines
22 Problem #1 Aromatic Amines PREVENTION: RS requirements must be communicated to all suppliersLaws require product complianceA small component prevented the entire garment from being soldAromatic Amines
23 Problem #1Cadmium found in outer PVC (polyvinyl chloride) layer of soccer ballPVC commonly contains heavy metal stabilizersPVC also often contains phthalates for flexibilityCadmium was used as a stabilizerCadmium can also be used in pigmentsHeavy Metals
24 Problem #1PVC layer was substituted with a TPU (thermoplastic polyurethane)TPU was tested to be RSL compliantTPU had performed better for feel and durabilityHeavy Metals
25 Problem #1PREVENTION: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 Metals
26 Problem #2Red paint used on trim of an infants shoe found to contain lead exceeding RSL limits.Lead was used as a pigment in the paintLead is acutely toxic in high concentrationsHeavy Metals
27 Problem #2Brand voluntarily recalled product at a cost of $6.7 millionFactory began more complete testing program for sourced raw materialsLead in raw material will still be lead in finished productHeavy Metals
28 Problem #2 Heavy Metals PREVENTION: Source raw materials from reliable suppliers with a well controlled manufacturing processCompliance of raw materials will lead to compliant finished productsHeavy Metals
29 Problem #3PU (polyurethane) coated fabric was found to contain high levels of leadPVC and phthalates had been eliminated from the productLead could be used as a stabilizer or pigmentNot likely caused by contaminationHeavy Metals
30 Problem #3 Heavy Metals Brand gave RSL requirements to garment factory Not all of the requirements were communicated to PU fabric vendorFactory is expected to communicate RSL to their suppliersHeavy Metals
31 Problem #3 Heavy Metals PREVENTION: Brands include all members of supply chain in RSL trainingGarment factories must fully communicate all brand requirements to their downstream suppliersStrategically test products at all stages of productionHeavy Metals
32 Problem #4Lead was detected in the coating on the top cover fabric of some sock linersHeavy metals including lead are often used in low cost pigments and inksLead pigment was used in the heat transfer on the sock liner.Heavy Metals
33 Problem #4 Heavy Metals PREVENTION: Brands include all members of supply chain in RSL trainingGarment factories must fully communicate all brand requirements to their downstream suppliersConsider even the smallest components in the RS compliance scenarioStrategically test products at all stages of productionHeavy Metals
34 Problem #5 Heavy Metals Chromium was detected on wool/nylon fabric It appeared the mill had used a metalized dyeThis same mill had already has the same problem beforeMill provided dye recipe and dye lot records and the recipe was not the problemDuring mill audit brand reviewed dyes and auxiliary chemicals – all okayHeavy Metals
35 Problem #5 Heavy Metals PREVENTION: Determined that mill had old stock of fabric that had failed previouslyMill had submitted wrong sample to laboratory for testingBe aware of your inventory management systemsIf 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 Heavy Metals Printed heat transfer failed for mercury Mercury can be used as a pigmentIn this case the source of the mercury was determined to be a cleaning solvent which contaminated a mixing beakerHeavy Metals
37 Problem #6 Heavy Metals PREVENTION: Heat transfer supplier eliminated suspected cleaning agentChanged their process to mix inks in disposable mixing containersEstablished time frames for keeping custom mixed inksPrinter already had a separate mixing kitchen for this brand due to PVC requirementsHeavy Metals
38 Problem #1 Phthalates Many screen print inks contain PVC PVC screen prink inks often contain phthalatesPhthalates are used to soften ink and prevent crackingPrinted t-shirts did not meet phthalate requirements for DEHPAll print chemicals were tested phthalate free prior to printingPhthalates
39 Problem #1Spray adhesive used to hold garment in place during printing contained DEHPAdhesive contaminated finished garmentPrinter substituted a different spray adhesive to achieve compliancePhthalates
40 Problem #1 Phthalates PREVENTION: Contamination is a big problem in RSL complianceWhen developing a program think about everything that touches the productThe best approach is to make sure all raw materials meet the RSL requirementsPhthalates
41 Problem #2Plasticizers are commonly used in plastics and foams to increase flexibility and improve performanceMany phthalate based plasticizers have been banned as toxic or reproductive hazardsManufactured claimed to use acetyltributylcitrate (ATBC) as plasticizer alternative in flip flop sandalsATBC is considered a safer plasticizer alternativePhthalates
42 Problem #2Consumer complaints that the flip flops had tacky feeling and were removing lacquer finish on wood floorsLaboratory analysis detected tributycitrate (TBC) instead of ATBC as manufacturer claimedTBC is a known solvent for decoating furnitureManufactured substituted TBC as a cheaper alternative for ATBCPhthalates
43 Problem #2 Phthalates PREVENTION: Manufacturers must stick to recipes described to brandsAny substitutions should be approved by brandChemical substitutions should not be made on price alone without safety, quality, performance impactPhthalates
44 Problem #1Scouring agent is used to remove oils and fats from textilesMany scouring agents contain APEO’s (alkylphenol ethoxylates) as a surfactantAPEO’s will remain on the fabric after the scouring processAPEO’s
45 Problem #1Vendor chose scouring agent because it removed all oils for even dyeingVendor new it contained APEO’sVendor did not know brand was concerned about APEO’s on finished productVendor sourced an APEO free alternative scour agent with no cost increaseAPEO’s
46 Problem #1 APEO’s PREVENTION: Communication Alternatives exist for most restricted chemicalsJust ask for themAPEO’s
47 Problem #2 APEO’s APEO was detected in an insole board Supplier investigated fibers used to produce the board and confirmed no APEO’s were usedEmulsion used to coat fiber board was contaminated with APEO’sSupplier switched to a new batch of emulsion and component passed RS testingAPEO’s
48 Problem #2PREVENTION:Contamination is a big problem in RSL complianceWhen developing a program think about everything that touches the productChemicals and tools must be properly handled, stored, and sanitized to prevent contamination.APEO’s
49 Problem #3 APEO’s NPEO was detected in pig skin leather NPEO is usually associated with the degreasing agentsTheir previous source of degreasing agent is from Japan and known not to contain NPEOA ban on raw materials exported from Japan forced them to change to an alternate sourceNPEO source was identified as new degreasing agent.APEO’s
50 Problem #3 APEO’s PREVENTION: When switching suppliers, for any reason, always share RS requirements with new supplierA thorough RS testing program should focus testing on high risk items, unknown materials, or inexperienced suppliersAPEO’s
51 Problem #1Foil screen prints on children’s t-shirts found to contain organotinsOrganotins are often used as heat stabilizers in printing and transfer processesOrganotins were found through testing of the foil backing adhesiveOrganotins
52 Problem #1Print house had MSDS for all foil print papers and adhesivesAll chemical suppliers were contacted to see if they used organotinsSome of the cheap adhesives contained organotinsOrganotins
53 Problem #1 Organotins PREVENTION: Communication High quality adhesive chemicals should be requestedNon-organotin heat stabilizer alternatives are availableOrganotins
54 Problem #1Phenol was detected in the adhesive used to manufacture shoes during a random auditChemical supplier believed that there was no Phenol in their adhesiveSupplier individually tested each of the chemical used to manufacture adhesive to detect for Phenol.Misc.
55 Problem #1One of the chemicals used to produce adhesive had small residual of PhenolPhenol used in the manufacturing but was supposed to be removed during processingSupplier reviewed the chemical recovery process to ensure complete recovery of PhenolMisc.
56 Problem #1PREVENTION: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 #2Molded black rubber logo failed on Polyaromatic Hydrocarbons (PAHs)Rubber raw material supplier confirmed that one of the rubber raw materials, Naphthenic oil, contained PAHsMisc.
58 Problem #2Rubber supplier reformulated material and substituted naphthenic oil out of formulaRS testing of the improved sample showed the new formula is RS compliantMisc.
59 Problem #2PREVENTION:RS requirements must be communicated to all down stream suppliersDown stream suppliers must understand RS requirements and impacts of raw material choicesMisc.
60 Problem #3PFOA was detected in a webbing (65% Polyester + 35% recycled PET)Previous test of material met RS requirementsSupplier 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 #3MSDS for the non-wicking chemical showed PFOA content and tests failed RS requirementsSupplier worked with the non-wicking additive supplier and replaced it with a non-wicking additive which is PFOS/PFOA freeMisc.
62 Problem #3 Misc. 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 themMisc.
63 Problem #4Small amount of Volatile Organic Compounds (VOC) was detected in the ink raw materials at screen print facilityPrinter investigated and discovered contamination from solvent supplier recycling solvent tanksMisc.
64 Problem #4 Misc. 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 productsAny chemical supplier to a facility must know the RS requirements to avoid contaminationMisc.
65 Problem #5Phenol was detected on silk fabric with a print during pre-production testingBy analysing individual raw materials the thickener (guar gum) was identified to be contaminatedPrinter switched from guar gum to alginate thickener to avoid contamination problemsMisc.
66 Problem #5 PREVENTION: Misc. Pre-production testing provided time to seek out alternatives and achieve chemical complianceMisc.
67 Problem #6Black cotton / rayon socks were a high volume carryover itemNo customer complaints for , until a cluster of 5 complaints for skin irritations within 1 monthSamples tested for pH, formaldehyde, restricted dyes – all tests negativeSamples pulled from store stock were noted to have a “solvent” smellMisc.
68 Problem #6 SOLUTION: Misc. Socks were tested for VOC’s and found to contain Dimethylformamide, methylene chloride, and acetoneSupplier was found to be lubricating the knitting yarn with an unlabelled solvent with no MSDS informationSOLUTION:Production was stopped immediatelyAll current stock/shipments destroyedSupplier is under review and production in their facility has been suspendedSupplier required to prove factory corrective action plan before production can resumeMisc.
69 Problem #1 Disperse Dyes Restricted disperse dye was found in a woven labelAll the yarns used to make this label were from well known suppliers and there was no history of RSL failureSupplier tested all yarns used to make this label & no restricted disperse dye was detectedDisperse Dyes
70 Problem #1 Disperse Dyes Only remaining component was the backer Testing of the backer only produced a positive result for restricted disperse dyeBacker was changed and supplier destroyed all the inventory of failed backer colorDisperse Dyes
71 Problem #1 Disperse Dyes PREVENTION: Laws require product compliance A small component or part of a component can cause a product to be non-compliantDisperse Dyes
72 Restricted Substance Problem Solution Prevention Library HeavyMetalsFormaldehydeAromatic AminesDisperse DyesMisc.APEO’sOrganotinsPhthalates