Product Safety and Restricted Substances in Apparel | Subrata Das


Product Safety and Restricted Substances in Apparel 2nd Edition
By Subrata Das

Product Safety and Restricted Substances in Apparel


Preface xi
Foreword xv
List of tables xvii

1 Introduction 1
1.1 Risk analysis of textile and apparel 1
1.2 Sources of restricted substances in textile and apparel 2
1.3 Evaluation of restricted substances 2
1.4 Legal requirements of harmful substances 4
1.5 Product compliance for environmental protection 5
1.6 Need for chemical management system 5
References 6

2 Management of restricted substances in the textile and apparel supply chain 8
2.1 Purpose and importance of restricted substances list 8
2.2 Risk associated with restricted substances 9
2.3 Education of the supply chain 9
2.4 Importance of evaluation through testing 12
2.5 Implementation procedure of a RSL program 13
References 14 

3 Review of restricted substances in textile and apparel supply chain 16
3.1 Introduction 16
3.2 Restricted substances in fabric 17
3.3 Restricted substances in trim 25
3.4 Restricted substances in embellishments 27
3.5 Restricted substances in apparel 28
3.6 Overview of Manufacturing Restricted Substances
List (MRSL)(41, 42) 28
References 31

4 Compliance of restricted substances in safety aspects of textile and apparel 35
4.1 Introduction 35
4.2 Banned amines in azo dyes 36
4.3 Allergenic disperse dyes 36
4.4 Carcinogenic dyes 39
4.5 Formaldehyde 39
4.6 Heavy metals 41
4.7 Pentachlorophenol, tetrachlorophenol, and orthophenylphenol 42
4.8 Organotin compounds 43
4.9 Chlorinated organic carriers 44
4.10 Fluorocarbons 44
4.11 Phthalates 46
4.12 Polyvinyl chloride 46
4.13 Alkyl phenol ethoxylates 47
4.14 Flame retardants 48
4.15 Polyaromatic hydrocarbons (PAH) 48
4.16 Solvents 49
4.17 Dioxins and furans 50
4.18 Residual pesticides 51
4.19 Chlorinated paraffins 54
4.20 Dimethyl fumarate (DMFu) 55
4.21 Isocyanates 56
4.22 Asbestos 56
4.23 Adsorbable organic halides (AOX) 57
References 58

5 Product safety requirements of children’s apparel 62
5.1 Importance of safety issues 62
5.2 Small parts – choking hazards 63
5.3 Metal fasteners 63
5.4 Zipper fasteners 65
5.5 Dungaree clips (hasps) and sliders 67
5.6 D-rings 68
5.7 Functional and non-functional drawstrings, cord/ties 69
5.8 Toggles 73
5.9 Fixed bows 73
5.10 Buttons 74
5.11 Pom-poms and frings 74
5.12 Decorative trims and embellishments 75
5.13 Bead 76
5.14 Sequins 76
5.15 Jewel 76
5.16 Heat transfer diamante (rhinstone) and stud guidelines 77
5.17 Fire safety 78
5.16 Sun protection 78
References 78

6 Safety review of children’s apparel 81
6.1 Introduction 81
6.2 Safety review 81
6.3 Flammability requirements in children apparel 97
References 104

7 Some important test methods to evaluate restricted substances in textile and apparel 105
7.1 Introduction 105
7.2 Lead content in surface coating 106
7.3 Lead content in substrate (metal) 110
7.4 Lead content in substrate (non-metal) 114
7.5 Cadmium in coated/plastic items 120
7.6 Evaluation of phthalates 122
7.7 Nickel release test: BS EN 1811 (22) and BS EN 12472 (23) 127
7.8 Test method for formaldehyde (24) 130
7.9 Test method of azo dyes (25, 26) 131
7.10 Test method of azo dyes (polyester fabric) (27, 28) 132
7.11 New standard for azo dyes 133
7.12 Miscellaneous test methods 138
References 140 

8 Global regulatory requirements on harmful substances in textile and apparel 143
8.1 Introduction 143
8.2 Canada Hazardous Products Act 144
8.3 Canada Consumer Product Safety Act (CCPSA) 144
8.4 EU regulations 145
8.5 Global Organic Textile Standard (GOTS) 174
8.6 OEKO- TEX Standard 100 190
8.7 US regulations 191
8.8 China (GB18401–2010) 214
8.9 Korea Certification 217
8.10 Japanese regulation (28,29) 220
8.11 Regulation of Vietnam (32, 33) 221
8.12 Regulation of Taiwan (34) 222
8.13 Regulation of India (35, 36, 37) 223
References 224

9 Understanding chemical management system for compliance in textile/apparel supply chain 228
9.1 Introduction 228
9.2 Practices for restricted substances compliance (1) 229
9.3 Role of NGO campaigns to tackle toxic chemicals 234
9.4 Understanding of 11 classes of priority chemicals (2) 234
9.5 Impact of zero discharge of hazardous chemicals on the supply chain (2) 235
References 236
10 Conclusion 237
Index 239

Consumer awareness to purchase safe and eco-friendly products is on rising trend. Adequate knowledge of restricted/harmful substances helps apparel industry to understand complex product safety and chemical management requirements in order to address consumer preferences in the niche market. One can define hazardous chemicals according to an intrinsic property approach and consider properties such as persistence, bioaccumulation, toxicity, carcinogenicity, mutagenicity and toxicity to reproduction, endocrine disruption and equivalent concerns when assessing the risks associated with certain substances. An effort to educate on such issues shall create a safer and more sustainable supply chain. Among many other supply chain challenges restricted chemicals is a very important one that the buyers or retailers needs handle to keep their supply chain risk free to avoid all sorts of possible customs seizure, product recall, penalties, lawsuit, etc. At the same time they must protect their brand liability by ensuring consumer safety. The common approach of handling the things risk free and easily is to set a Restricted Substances List (RSL) by the retailers. To keep our global apparel industry competitive and compliant in the marketplace, restricted substances list provides clear and concise information on the newest developments in global product safety standards covering chemicals and other substances whose presence in a product is restricted through a government regulation or law to ensure that they are environmentally safe. RSL for them is not only a list of chemicals but also elaborated with supply chain partner responsibilities, voluntary restrictions and standards, chemical limits, test methods, testing procedure, product safety policy, etc. When a product does not comply with restrictions, immediate action needs to be taken to ensure the best possible solution taking into consideration people’s health and the environment. Any incidence of non-compliance would demand a thorough root cause analyzis and result in a plan for how to avoid any recurrence.

The MRSL or Manufacturing Restricted Substances List is an approach to control and monitor the hazardous and restricted substances used in the manufacturing process of textile and trim materials. It is a list of substances subjected to a Usage Ban, while allowing for reasonable expected manufacturing impurities or unintentional contaminations that should be consistently achievable by responsible chemical manufacturers. MRSL will assist brands, their supply chains and the broader industry to adopt a harmonized approach to the control of hazardous substances used to process textile and trim materials in apparel.

Product risk review is an imperative requirement across all brands of the world applying physical, chemical product safety and conformity standards. To ensure product quality and to produce consumer-safe products, all materials and product samples have to pass a rigid compliance process and are tested in accordance with standardized material and product testing specifications and procedures.

Best practices such as appointment of an product safety/compliance manager, implementing good purchase practices, chemicals related documentation, screening of inputs for restricted substances, testing of finished articles for restricted substances, training for internal team and chemical suppliers, screening of new chemicals, preparing database of restricted substances non-compliance with corrective actions, can be implemented in the factory to ensure restricted substances compliance of finished articles.

This book arose out of a need, when interacting with the apparel fecundity at different parts of the world, for a comprehensive guideline on the product risk review and chemical compliance of restricted substances in various merchandise products to which different stakeholders could be referred. The approach to the subject and the topics covered are those, which have been developed over the recent years on the global platform in apparel sectors by retailers and regulatory bodies. The apparel industry has had a long history of producing different merchandise products in accordance with the necessity of various classes of consumers and the nature of their utilization. As a result, various safety and restriction of chemical parameters have been investigated and benchmarked by following international standard norms and accumulated experience of different renowned brands to fulfill the performance requirements of different apparel products. This book is then a distillation of these collective efforts and hopefully a concise document of wisdom inculcated over the years in the area of product safety and restricted substances in apparel.

The book is aimed at textile and apparel industry professionals, retailers, factory heads, buying offices and students intending to join the industry in the areas of quality assurance covering safety and chemical compliance. In order to produce and deliver safe, sustainable, and environmental friendly products to the customer adherence to the appropriate specification, standard, law and regulation applicable for the merchandise is important. Restricted substances List (RSL) and Manufacturing Restricted Substances List (MRSL) are dynamic in nature and thus ever changing based on the feedback of consumers, regulatory bodies, international associations and retailers. Therefore, it is always desirable to refer to a latest version of document while applying any tests and regulations, which are difficult to cover in a book of this nature, and more so international standards, regulations and restricted chemicals with their harmful impacts are continuously been updated, owing to the change in expectation of performance and for better consumer interest.

The emphasis throughout the book is on the overview of the restricted substances present in fabrics, apparels and accessories and their acceptable limits or total ban, management of such restricted substances in the supply chain, standard and regulatory test methods. Manufacturing Restricted Substances address hazardous substances potentially used and discharged into the environment during manufacturing and related processes, not just those substances that could be present in finished products. Safety requirements and review of risk of different garments have been covered including varieties of accessories. Global and country specific regulations on the restriction of various harmful chemicals used in the manufacturing process of fabrics, apparels and related accessories are also discussed in detail.

Product risk review and restricted substances has been the subject of many recent discussions. Though scattered information is available, but it is sometimes difficult to access, because of restriction by proprietary rights of different buyers as a guarded secret to the brand. Many restricted substances, their harmful effects; their limits are still under investigation under RSL and MRSL categories. Apart from revision in existing regulations, some country specific regulations are yet to come in the coming years. In such a dynamic environment, I have covered the topics in this book to disseminate knowledge because very little has been available in published literature. I believe that the subject will be of sufficient interest to textile and apparel industry to warrant its inclusion and so provide a wider circulation of information concerning health and safety issues in textile and apparel supply chain.

Dr. Subrata Das

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