Restricted Substance Problem Solution Prevention Library

Misc. Restricted Substance Problem Solution Prevention Library Heavy Metals Formaldehyde Aromatic Amines Disperse Dyes APEO’s Organotins Phthalates

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

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

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 protos to brand that meet RSL requirements Formaldehyde

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

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 • 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

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 limits Formaldehyde

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

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

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 carginogenic so proper curing is required Formaldehyde

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

Problem #5 • Cotton fabricfailed 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 • 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

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 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 • 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

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 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 #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

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 • Compliance of raw materials will lead to compliant finished products Heavy Metals

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

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 #4 • Lead was detected in the coating on the top coverfabric 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 #5 • 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 #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 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 #1 • 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 • The best approach is to make sure all raw materials meet the RSL requirements Phthalates

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

Problem #2 • 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 • TBC is a known solvent for decoating furniture • Manufactured substituted TBC as a cheaper alternative for ATBC Phthalates

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

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

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 • Just ask for them APEO’s

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

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

Problem #3 • 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 • 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

Restricted Substance Problem Solution Prevention Library