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Neyamul HasanIntertek Consumer Goods

Bangladesh24 Nov-2012

RESTRICTED SUBSTANCESIN CONSUMER GOODS

(WITH SP. REFERNCE TO TEXTILES & APPARELS)

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RSLRSL means themeans the RRestrictedestricted SSubstancesubstances LListist

Chemicals that are health hazards

- Carcinogenic

- Toxics

- Sensitizing – allergenic

RSL

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Common List of Restricted Substances

Allergenic Disperse DyesAllergenic Disperse Dyes

Azo DyesAzo Dyes

Heavy metal contentHeavy metal content

Nickel ReleaseNickel Release

CadmiumCadmium

Chromium VIChromium VI

LeadLead

FormaldehydeFormaldehyde

Phenol contentPhenol content

Dimethyl Fumarate (DMF)Dimethyl Fumarate (DMF)

Carcinogenic dyes DyesCarcinogenic dyes Dyes

PhthalatesPhthalates

TriclosanTriclosan

PCBsPCBs

APEOsAPEOs

PesticidePesticide

Flame Retardant Flame Retardant

Organotin compoundsOrganotin compounds

COCCOC

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RS - Azo

Azo dyes (which degrade to form one of the carcinogenic amines listed on the restricted substance list)

Description: Azo dyes incorporate one or several azo groups (-N=N-)bound with aromatic compounds. Thousands of azo dyesexist, however, only those which can degrade to form thelisted amines are restricted. Maximum permissible limit: 30 mg/kg in finished articles or in dyed parts

Where they may be found:

In textiles and apparel, azo dyes (which may degrade to form 22 listed amines) may be found in dyed fiber or leather.

Toxicity Amines are Considered as Carcinogenic

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RS - Azo

Allergy from textile dyes in Leg & Abdomen area

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RS - APEOs

APEO/AP (Alkyphenol Ethoxylates/Alkylphenols)

Description: NPEOs/OPEOs are included in the group of non-ionic surfactantscalled alkylphenol ethoxylates (APEOs). NPEOs and OPEOs can degrade to NP and OP respectively. Maximum limit: 0.1 % in preparations

Where they may be found:

APEOs are used in detergents, scouring agents, wetting agents, softeners, emulsifier/dispersing agents for dyes and prints.In leather tanning, APEO is used in de-greasing, finishing etc.In silk production for de-gumming. APEO could also be present in dyes and pigment preparations..

Toxicity APEO can cause cancer, disrupt hormone system and reduce fertility.

Important Info

Our statistical data says: SILK is the most potential groups offiber where APEOs get fail very frequently.

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RS – Disperse Dyes

Sensitizing Disperse Dyes

Description: Disperse dyes is a group of dyes generally used to dyesynthetic fiber, eg, Polyester. Maximum permissible limit: Not detected (<5 mg/l)

Where they may be found:

Disperse dyes are used to dye synthetic or manufacturedfibers (polyester, acetate, and polyamide).

Other Dyes: Navy Blue or Blue colorant as a dye mixture also kind ofdisperse dyes.

Toxicity Some of Disperse dyes suspected to cause allergicreactions.

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RS - Formaldehyde

Formaldehyde

Description: Formaldehyde is a volatile compound used widely in apparel and textile manufacturing as an anti-creasing and an anti-shrinking agent. In addition, formaldehyde is often used in polymeric resins (e.g. phenol-formaldehyde and urea-formaldehyde). Maximum permissible limits 20 ppm 0-36 months, 75 ppm for Adult

Where it may befound:

In apparel and textiles, formaldehyde could be found in artificially stiffened fabric. Since formaldehyde is volatile, cross contamination of material may occur.

Toxicity It is an irritant to eyes, nose, lung and may cause allergic reactions. Suspected carcinogen.

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RS - Phenols

Pentachlorophenol (PCP)

Description: PCP is a polychlorinated compound used as apreservative to wood, leather, and textiles (Natural Fiber).

Where it may be found:

PCP has been used as an antifungal in textiles,leather, and some wood products. Specially duringstoring & Transportation PCP is used as insect killer.

Regulation/Directive/Legislation

Legislation - 91/73/EEC prohibits the marketing anduse of PCP and its salts and esters in substances orpreparations in a concentration equal to or greaterthan 0,1 % by mass.

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RS – Organotin

Organotin Compounds

Description: Organotins are a class of chemicals combining tin and organicssuch as butyl and phenyl groups.

Where they may be found:

In textiles and apparel, organotins may be associated withplastics, inks, paints, and heat transfer material. Mostly they usedas antifoulants in paints, but they can also be used as biocides(antibacterials) and / or heat stabilizer in plastics

Toxicity 3 Listed Organotin (i.e. Monobutyl tin trichloride, Tetrabutyl tin,Monoheptyl tin trichloride)Suspected to be endocrine disrupters

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RS - PVC

Polyvinyl chloride (PVC)

Description: PVC (also known as vinyl) is a chlorinated polymer usedextensively. Generally, PVC is used for soft plasticaccessories like badges or zip pullers, as coating ontextiles for rainwear, as prints etc.Limit: Not detected in toys and products intended to be in mouth

Where it may be found:

PVC can be found in plastic items and trim in apparel andtextiles. In addition, PVC can often be found in screenprints and inks.

Toxicity Environmentally persistent, and their manufacture anddisposal often results in highly toxic wastes (e.g.DIOXINS)

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RS - Phthalates

Phthalates

Description: Colorless, odorless liquids which are used as “plasticizers”Soften the polyvinyl chloride plastic (PVC), Rubber products, paints, printing inks, adhesives, lubricants and some Cosmetics.

Where they may be found: In textiles and apparel, phthalates may be associated with flexible plastic components, trims and screen prints.

Toxicity 6 Listed PhthalatesVery low volatility, do not readily dissolve in water and are persistent in the environmentThey are suspected to be carcinogenic and to disturb the hormone system

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RS - Nickel

Nickel

Description: Nickel is an abundant metal often combined with other metals to create alloys with increased hardness and resistance to corrosion.

Where it may be found: In textiles and apparel, nickel may be associated is mostly with metal accessories. Very rarely could be found in clothing, paints, inks, trims and plastics.

Toxicity It can cause allergenic reaction to human beings

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Effect of Nickel Poisoning

Earring containing Nickel and

dermal effects observed

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RS - Lead

Lead

Description: Lead is a naturally occurring metal important to theproduction of batteries, fuels, paints, plastics (as a heatstabilizer), ceramics and solders.

Where it may be found:

In textiles and apparel, lead may be associated with plastics,paints, inks, pigments, and metal components.

Toxicity Lead can affect the central nervous system (particularchildren) and can damage the kidneys and immune system

Lead is one of the potential risky & common RS in the field of CG

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Adverse effect of Lead to Human

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Adverse effect of Lead to Human

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Adverse effect of Lead to Human

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RS - Cadmium

Cadmium

Description: Cadmium is a naturally occurring and abundant metal that does not easily corrode (rust). Maximum permissible limit: 100 mg/kg

Where it may be found: In textiles and apparel, cadmium may be associated with plastics, pigments (particularly red, orange, yellow, and green), and as a surface layer for metals.

Toxicity In like other Heavy Metals Cadmium also anticipated to be carcinogens .

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RS – Chromium VI

Chromium VI

Description: Chromium is a kind of metal that can exist in three main forms (Chromium (0), Chromium (III), and Chromium (VI). In nature, Cr (III) is the predominate form, Cr (0) and Cr (VI) do not occur in nature or are rare.

Where it may be found: In textiles and apparel, chromium may be associated with plastics, pigments and mainly in tanned leather.

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Effect of Heavy Metal Poisoning

Arsenic Poisoning

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RS – Dimethyl Fumarate

DMFu (Dimethyl Fumarate)

Description: DMF is a stable compound classified as irritant and even harmful for the skin, eyes, mucous membranes and upper respiratory tracts, by simple contact. Limit: 1 mg / kg (the lab should have a method detection limit of < 0.1 mg/kg)

Where it may be found: This chemical substance is a BIOCIDE and could be found in Textiles/Apparel, Leather and most likely in Silica Gel, etc.

Toxicity Sevier Instant Irritation

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Common RS Requirement (based on current regulations/legislation) – EU & USA

RSEU Market USA Market

Applicability General Requirement

Applicability General Requirement

Azo √ 30 ppm NA

Phthalates √ 1000 ppm √ 1000ppm

Formaldehyde √ 20, 75 ppm √ 20, 75 ppm

pH √ Variable √ variable

Lead NA √ 90/300 ppm

PVC √ ND

DMFu √ 0.1 ppm NA

Allergenic Disperse Dyes

√ 1, 5 mg/l NA

Carcinogenic Dyes √ 1, 5 mg/l NA

Chlorophenols(PCP/TeCP)

√ 1 ppm NA

APEOs √ 1000 ppm NA

Organotin √ 1 ppm NA

COCs √ 1, 2 ppm NA

Solvents √ ND NA

Crhomium VI √ 3 ppm / ND NA

Sol. Heavy Metals,ASTM F963

NA √ Element wise

Mig. of Heavy Metals,EN 71-3

√ Element wise NA

Cadmium √ 100ppm √

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Major RS Tests requirement - Component/material-wise (For EU Market)

RS NaturalFiber

SyntheticFiber

Blend(Natural +Synthetic))

SyntheticLeathers,

Inks,Thermoplasti

cs,etc

Metals Leather /Coated

Leathers Trims

Azo √ √ √ √ √

Phthalates √

Formaldehyde √ √ √ √

Cadmium √

PVC √ √

Al. Disperse Dyes √ √ √

Carcinogenic Dyes √ √ √

Chlorophenols(PCP/TeCP)

√ √ √

APEOs √ √ √ √

Organotin √ √ √ √ √

COCs √ √

pH √ √ √ √ √

Crhomium VI √

Heavy Metals √ √ √ √ √ √

Nickel Release √

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Major RS Tests Requirement - Component/material-wise (For US Market)

RS NaturalFiber

SyntheticFiber

Blend(NaturalSynthetic))

Inks, Coating,Thermoplastics, etc

Metals(Children)

Non-Metals Substrate

Phthalates √

Formaldehyde √ √ √

pH √ √ √

Lead √ √ √

Sol Heavy Metals √

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Raw Fibre,

Dyes and Chemicals

Ancillary Chemicals

Poor Process control

- Poorly controlled reactions = Risk

- Reactions are controlled by…

- Ratio of reagents, Temperature, pH & Time

Many RSL failures due to non-deliberate application

- Unspecified chemicals in a formulation

- Unlabelled drums in the store

- Unlabelled buckets by the machine

Common Sources of RS in Textile/Apparel Industry

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PRODUCTION CONTROL

Chemicals

Textile

Accessories

Production

Final product

Sources of RS in Textile/Apparel Industry

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Chemicals inside the products

Fibre

Oil

Size

Dyes

Auxiliaries

Print paste

Pigment

Plastic

Metal

Synthetic fibre

Natural fibre

Detergents

Button

Zipper

Sequin

Accessories

Wet processing

Spinning

Knitting

Weaving

Washing

Final Products

Red color indicates source of Restricted chemicals

Sources of RS in Textile/Apparel Industry

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How to avoid RS failure

Very Basic:

Production Control:

- Adequate knowledge on RSL

- Record of chemical products used

- Require necessary information about chemical products

- Follow SOP

All chemicals must have:

- MSDS (Material Safety Data Sheet)

- Compliance declaration to RSL

- Labelled containers

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How to avoid RS failure - Educate the supply chain

Brands Factories Vendors Other

suppliers

Agents,

traders

Brands are responsible for educating factories on the RSL, and the supplier is responsible for educating

vendors on the RSL as well.

Make sure all of your subcontractors, accessory suppliers, dye mills, print mills, tanneries, chemical

suppliers etc. are aware of the brand’s specific RSL restrictions and have the latest updated version

available.

Only do business with RSL compliant companies.

Use and encourage the use of dyestuffs, pigments and textile auxiliaries from reputable manufacturers.

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How to avoid RS Failure

Risk Assessment:

Technical Managers must risk assess each product to decide if:

- A product needs testing?

- What it needs to be tested for?

When Deciding What to Test

- All new suppliers are deemed high risk and will be subject to a high test frequency in their first season until

a level of confidence is established.

-All suppliers who have historically performed well are deemed as low risk and can only be subjected to

random testing.

All infant, babies, and children’s products are considered high risk

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RSL Failur

Frequent Failure observed in Products Manufactured in Bangladesh

Allergenic Disperse Dyes (mainly in Polyester Dyes) Allergenic Disperse Dyes (mainly in Polyester Dyes)

Azo DyesAzo Dyes

FormaldehydeFormaldehyde

SCCP (mainly in leather)SCCP (mainly in leather)

Phthalates (soft plasticsPhthalates (soft plastics

APEOsAPEOs

Lead in PaintLead in Paint

Lead in MetalLead in Metal

Chromium VI (leather)Chromium VI (leather)

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One Year Analyzed Data

RS % Failure Remarks

Azo Dyes 4.6%

Disperse Dyes 3.8%

Carcinogenic Dyes 0%

Phthalates 6.8%

Organotin 0.3%

Phenols (PCP/TeCP) 1.6%

COCs 0.37%

Formaldehyde 9%

Lead in Coating 4.3%

Lead in metals 6.0%

Lead in Non-metals 3.7%

APEOs 13%

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CPSIA

Key Regulations in consumer Products

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US CPSIA

• Background

• Key Definitions

• Key Requirements

• CPSIA Reform Bill – HR 2715

• Recent Activity

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CPSIA – Consumer Product Safety Improvement Act

It is targeted mostly toward "children's products",

which are defined as any consumer product

designed or intended primarily for children 12

years of age or younger.

History

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Background - CPSIA

• Signed into Law on August 14, 2008

• Scope: Consumer Products (as defined in CPSA)

• Key Requirements

o Lead and Phthalate Content

o Certification

General Certificate of Conformity (GCC)

Children’s Product Certificate (CPC)

o Mandatory Toys standard (ASTM F963)

o Third Party Testing for children’s product

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Key Definitions

“Children’s Product”: a consumer product designed or intended primarily for children 12 years of age or younger.

“Children’s Toy”: a consumer product designed or intended by the manufacturer for a child 12 years of age or younger for use by the child when the child plays.

“Child Care Article”: a consumer product designed or intended by the manufacturer to facilitate sleep or the feeding of children age 3 and younger, or to help such children with sucking or teething.

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Lead Requirements (CPSIA Section 101)

Total Lead in Surface Coating

• Requirement: 90ppm

Total Lead Content (Substrate)

• 14 Aug 2009 – 300ppm

• 14 Aug 2011, 100ppm – HR 2715

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Phthalate Prohibition (CPSIA Section 108)

From February10th, 2009, it became unlawful for anyone to sell:

• Any children’s toy or child care article that contains concentrations of more than 0.1% of DEHP, DBP or BBP

• Any children’s toy that can be placed in a child’s mouth or child care article that also contains concentration of more than 0.1% of DINP, DIDP or DnOP

Toys that can be placed in the mouth are: toys that can be kept in the mouth by a child so that it can be sucked or chewed, or toys or parts of toys with one dimension less than 5 cm.

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General Certification of Conformity (sec: 102)

General Certification ofConformity

Product description Date of production Place of production Place Product was tested

All rules enforceable by CPSC:

(Adult and Children product)

Certification based on Third-PartyTesting:

- Stating the product was being

tested in approved Third-party lab

for Certain Tests.

- Products without certificate or with a false certificate will be destroyed

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Third Party Testing Requirement

Third party testing for most of children’s product rules are already in place.

The CPSC published accreditation requirements for 3rd party testing for ASTM

F963 and phthalate content on August 3rd and August 10th – 2011 respectively.

Certification based on 3rd party testing will be required for applicable children’s

products manufactured on and after January 1, 2012:

http://www.cpsc.gov/about/cpsia/accredited.html

• Total lead content (Substrate)

• Phthalate content

• ASTM F963

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CPSIA third party testing – Example Timeline

Rules/Standard/Ban Non-Children’s Products GCC requirement

Children’s Products CPC based on Third party Testing requirement

Lead paint on Children’s Products (16 CFR part 1303) Not Applicable December 21, 2008

Small Parts (16 CFR part 1501) Not Applicable 15 February 2009

Lead in Metal components of Chidren’s metal Jewelry (sec 101 of the CPSIA)

Not Applicable 23 March 2009

16 CFR 1500.48 & 49 – Sharp points and sharp edges Not Applicable Sept ‘ 2009

Total Lead content in metal children’s products and in non-metal children’s products (sec 101 of the CPSIA)

Not Applicable 31 Dec’ 2011

Ban on Lead-in-paint in Paint and on Furniture 10 Feb’ 2010 Not Applicable

Flammability of Vinyl Plastic (16 CFR part 1611) 26 Jan’ 2011 19 Oct’ 2010

Flammability on Wearing Apparel (16 CFR 1610) 26 Jan’ 2011 16 Nov’2010

Phthalates (sec 108 of the CPSIA) Not Applicable 31 Dec’ 2011

Flammability of Children’s Sleepwear (16 CFR part 1615 & 1616)

Not Applicable 17 Feb’ 2011

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GCC = General Certificate of Conformity

CPC = Children’s Product Certificate

COC = Certificate of Conformity

IOR = Importer of Record

DM = Domestic Manufacturer

CPSIA = Consumer Product Safety Act of 2008

HR 2715 = House Resolution 2715 (CPSIA reform legislation passed in 2011)

CPSC = U.S. Consumer Product Safety Commission

Commonly Used Acronyms

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Valued Quality. Delivered.