Module 1a: Pentland Restricted Substances List (RSL)

Transcription

1 Module 1a: Pentland Restricted Substances List (RSL)

2 Module 1a: Pentland Restricted Substances List (RSL) Pentland Standards and Guidelines for Managing Restricted Substances 1a. Pentland Restricted Substances List (RSL) 1b. Appendices 2. Restricted Substances Management Process 3. Explanatory Notes and Guidance Page 2 of 11

3 Introduction Pentland requires that products are manufactured with regard for the safety of consumers, the safety of workers involved in their manufacture and with consideration for the wider environment. Pentland s Standards and Guidelines for Managing Restricted Substances is a guide to help suppliers ensure that customers and workers within the supply chain are not exposed to harmful chemicals in the manufacture or use of products that are sold by Pentland brands. It provides details of chemicals that are restricted by Pentland, information on why they are restricted, details of test methods, and details of allowable limits on products that are placed on the market. The Pentland RSL (below) and accompanying documents apply to all products sold under the name of any of the Pentland brands, unless communicated otherwise in writing. It is the supplier s responsibility to avoid the use of harmful or illegal chemicals in the production of Pentland brands products. Pentland brands may provide further product-specific guidance that summarises the specific chemical concerns for the components used in their product lines and details the risk-based testing regime they require for each product group. Deliberate Application Not Permitted Chemicals that must not be deliberately used in 100% form or as part of a formulation AL limits in operation Chemicals that can be deliberately used as part of a chemical formulation but for which we have an upper limit (e.g. formaldehyde) PSA Product Specific Allowance Chemicals that must not be used without written permission (e.g. selected anti-microbials, waterproofing) BP Best Practice / Advisory These chemicals are permitted, but we advise the use of safer, alternative chemicals or processes. Information only Note regarding limit of quantification Analytical laboratories can detect chemicals at low concentrations and say with great confidence that it is definitely a specific chemical that has been detected. However, there must be a measurable amount of that chemical present before they can say with great confidence how much is present this is termed the limit of quantification. We only expect laboratories to report results above the limit of quantification. In the table below not detected refers to not detected at quantifiable levels. Results from laboratories below the limit of quantification should be reported as not detected at quantifiable levels or not detected. Page 3 of 11

4 Pentland RSL Chemical / Chemical Banned Amines Listed in Appendix 1 Skin Sensitizing Dyes Listed in Appendix 3 Carcinogenic Dyes Listed in Appendix 4 Comments Test Method of These are carcinogenic amines that can be formed when certain azo dyes split. It is illegal to use formulations or sell products containing these dyes in many countries. A list of dyes that can yield these amines in provided in Appendix 2. Legislation applies to dyes only in EU but to dyes and pigments in China. A small number of disperse dyes are known to cause severe skin irritation and are widely restricted. Some disperse dyes are covered by legislation in Germany. Textiles EN part 1 (natural fibres) and part 2 (synthetic fibres). LFGB B for p-aminoazobenzene (not applicable in China) Leather CEN ISO/TS China GB/T (textiles) GB/T (leather and fur) For EU 30 ppm 30 ppm EU+ 20 ppm China 64 LFGB B DIN ppm 45 ppm A small number of dyes that are carcinogenic. DIN ppm Not Detected Alkyl Phenol Ethoxylates (APEO) APEO s are a class of chemical used as detergents and emulsifying agents that are illegal in many countries above certain concentrations because they are endocrine disruptors for aquatic species. Solvent Extraction LCMS Using in-house methods 20 ppm 500 ppm for NPEO 1000 ppm total of APEO s Carrier dyeing of polyester using: halogenated aromatic hydrocarbons, tri-chlorobenzene, biphenyl or ortho phenyl phenol Organic solvents that are known to be harmful to workers are used for dyeing polyester at reduced temperatures. Some chemicals in this class are illegal in some countries. Organo Tin Compounds These are a group of chemicals that are known to be bioaccumulative, toxic and also endocrine disruptors. They are recognised as being harmful and several are labelled as SVHC under Reach legislation and/or illegal in certain countries. Pentachlorophenol (PCP) and derivatives PCP is a carcinogen that is restricted by legislation. Solvent Extraction GC MS (recommend DIN 54232) (recommend Mod LFGB for OPP) ISO 17353:2004 Solvent Extraction GC MS (water method) (CEN) has been developed for textiles and polymers In-house tests using GCECD e.g. LMBG B or SATRA TM342:1995 Leather: EN TS 14494: ppm 1 ppm total/for each 100 ppm OPP (guidance) 0.2 ppm 1 ppm Total Tribuyl Tin (TBT) and triphenyl tin (TPhT)in extract. 2.5 ppm total of all other Organotin compounds (including MOT, DBT, DOT, TeBT). 1 ppm 1ppm total PCP and TeCP Page 4 of 11

5 Polychlorinated Biphenyls (PCB s) They are on the POP and Ospar lists and known to be endocrine disruptors and are persistent in the environment. EU Directive 76/769 EEC - prohibits the use and reuse of PCBs and PCTs, and any mixture containing them, in more than 0.005% by weight. EU Directive 96/59/EC aims at complete disposal of PCBs. Polychlorinated Terphenyls (PCT s) They are on the POP and Ospar lists and known to be endocrine disruptors and are persistent in the environment. EU Directive 76/769 EEC - prohibits the use and reuse of PCBs and PCTs, and any mixture containing them, in more than 0.005% by weight. Short Chain Chlorinated Paraffins (SCCP s) Comments Test Method of GC-ECD Method: B or DIN F2 1 ppm 1 ppm DIN F2 or EPA 8082A 1 ppm 1 ppm These are highly toxic and are illegal in some countries. Solvent Extraction GC-MS 5 ppm 5 ppm Poly Aromatic Hydrocarbons (PAH s) Appendix 7 Some are known to be carcinogenic and mutagenic and are therefore illegal in some countries. ZEK CEN test expected Spr ppm 1 ppm benzo(a)pyrene 10 ppm total for 16 EPA restricted PAH s Dimethyl Fumarate (DMFu) DMFu is known to be a severe irritant and is illegal in some countries. GC-MS CEN ISO/TS 16186: ppm 0.1 ppm Heavy Metals and Compounds Tin Heavy metals are a concern in their elemental metallic form and also as part of chemical compounds. Metallic forms are generally a concern for components such as zips, buttons and fasteners and the heavy metal compounds can be present in a number of chemical formulations such as pigments, paints, coatings, fixatives and process chemicals. The legislation that covers heavy metals and their compounds is varied and complex some is focused on total metal content (via digestion methods) and some is focused on extractable metals (via extract methods). It is common for EU toy legislation limits to be applied to textiles and leather but the Pentland standards are separated into limits for Textiles and limits for components. See organotins above Page 5 of 11

6 ChromiumVI Chrome VI is a severe irritant and carcinogen and can be present on chrome tanned leather and after-chrome dyed wool. German legislation introduced in 2010 makes presence above 3ppm illegal in leather. AL Chromium Chromium used in the tanning process should be either bound to the leather and any excess removed. Chromium is used as an integral part of some dye molecules that should not be removed by this test. Mercury This is extremely toxic and should not be present in any components. It is illegal in some countries Comments Test Method of iso (WITHOUT AGEING) 3 ppm 3 ppm DIN EN ISO (extractable) 3 ppm 3 ppm for textiles 250 ppm for leather EN ISO 105-E04 / DIN EN ISO ppm 0.02 ppm Cadmium Cadmium and its compounds are very toxic and illegal in some countries EN ISO 105-E04 / DIN EN ISO (extraction method) Microwave digestion + DIN EN ISO (total digestion) 0.1 ppm 0.1 ppm for textiles 1 ppm 40 ppm for metals, plastics and coatings Lead Lead and its compounds are extremely toxic and are illegal in some countries. The US authorities have determined that there is a need for mandatory testing and certification for some children s items EN ISO 105-E04 / DIN EN ISO (extraction method) Microwave digestion + DIN EN ISO (total digestion) 0.2 ppm 1 ppm for textiles 1 ppm 90 ppm for plastics, coatings and metals Nickel Nickel is used as an integral part of some dyes and should not be removed by this test. EN ISO 105-E04 / DIN EN ISO (extraction method) 0.2 ppm 1 ppm TEXTILES Nickel metal is known to be severe irritants and it is illegal in some countries. EN 12472:2005+A1:2009 / DIN EN ISO μg/cm2/week for metallic components Antimony Antimony and its compounds are known to be irritants EN ISO 105-E04 / DIN EN ISO (extraction method) 1 ppm 30 ppm Asbestos Carcinogenic, causes lung disease (asbestosis) EPA 66/R-93/116 n/a Not detected Page 6 of 11

7 Flame Retardants Comments Test Method of Flame retardants should not be used at all unless there is a legislative requirement to meet flammability standards. We encourage suppliers to use the lowest impact solutions whilst meeting flammability requirements and information reliable information can be obtained from companies such as Huntsman, Avocet or Thor. Polybrominated biphenyls (PBB) PBB has been illegal in the EU for many years. DIN F2 or EPA 8082A 0.1 ppm Not detected Tris-aziridinyl-phosphinoxide (TRIS) TRIS has been in illegal in the EU for many years. Solvent Extraction / GC-MS 1 ppm Not detected Octa and penta bromo diphenyl ether (Brominated BDE s) These brominated flame retardants are illegal in the EU. Deca brominated BDE is now classified as an SVHC. Solvent Extraction / GC-MS 1 ppm Not detected PSA Anti-microbial finishes EU Biocidal Products directive require Pentand brands to label any product, including packaging, that has an anti-microbial function with the name of the active ingredient. Therefore, suppliers must provide the name of the active chemical (not trade names) and the brands must authorise its use prior to orders being confirmed. There are many different types of chemical used as anti-microbials to either control odours or to protect products from microbial degradation. Where anti-microbial properties are desirable and requested by Pentland the use of quaternised silicones and selected silver based products is recommended. PFOS...and C8 Fluorocarbons based on electrofluorination PFOS is a by-product of the manufacture of C8 fluorocarbons by the electrofluorination process. It is persistent, bioaccumulative and some negative health effects have resulted in legislation being introduced in some countries. The use of C8 products based on electrofluorination is not permitted. PVC The use of PVC is not permitted unless there are no practical alternatives and written permission for the use of PVC has been given by a Pentland Brand. Solvent extraction GC-MS 1 ppm of detection FprCEN/TS μg/m2 Belstein Test and confirmation by FTIR Not Detected Page 7 of 11

8 Phthalates in PVC Some phthalates are suspected endocrine disruptors / carcinogens. Where PVC use is authorised by Pentland Brands the PVC should be free from the phthalates restricted by EU legislation, CPSIA legislation and any listed as SVHC s under Reach legislation unless there are no practical alternatives. PSA Volatile Organic Solvents The use of solvent based systems for any process of product is not permitted without written permission from a Pentland Brand. Solvents are used for a number of purposes including adhesives, coatings, print systems and paints - and can also be used for cleaning. Many solvents are known to be harmful and some are illegal in some countries. Comments Test Method of GC-MS (confirmation with LC-MS) BS EN (TEXTILES) EN (CHILD USE AND CARE) EN (FOOTWEAR) GC-MS with headspace analysis Labs should be contacted to discuss test methodology prior to sending samples for analysis. Any information on solvents likely to be present helps the laboratory 100 ppm 500 ppm for an individual listed phthalate 1000 ppm total for all listed phthalates 1 ppm Any result over 10 ppm to be reported to Pentland Brands BP AL Nitrosamines N-Nitrosodimethylamine N-Nitrosodiethylamine N-Nitrosodibutylamine N-Nitrosomorpholine N-Nitrosodipropylamine N-Nitrosopiperidine N-Nitrosopyrrolidine N-Nitroso-N- methylaniline N-Nitroso-N-ethylaniline Water based technology should be used wherever practicable and the use of volatile organic solvents should only be used with the permission of Pentland. Particular attention is drawn to the solvents listed in Appendix 12. All practical steps must be taken to minimise exposure of workers to any organic solvent and residues are not permitted in Pentland products. Nitrosamines are restricted in China GB/T EN (TEATS) 0.1 PPM AL Formaldehyde Irritant to mucous membranes and skin. Some workplace limits are in place. Japan law 112 Textile: EN ISO Leather EN ISO China GB/T ppm Not Detected 20 ppm 75 ppm adult Page 8 of 11

9 AL PFOA PFOA is a by-product of the manufacture of C8 fluorocarcarbons by the telomerisation process. It is persistent and bioaccumulative. The use of C8 telomers are permitted provided the levels of PFOA meet the standard. AL Pesticides and Insecticides Appendix 11 Comments Test Method of Pesticides and insecticides are used in agriculture and can be present on finished products especially where raw or ecru products are used. Some are controlled under POP convention and other legislation. FprCEN/TS ppm 0.5 ppm HPLC or GCMS e.g. EPA 8082A / 8151A 0.05 ppm 0.05 ppm total for cotton 0.5 ppm total for wool AL Isocyanates Diphenylmethane diisocyanate (MDI) Hexamethylenediisocyanate (HDI) Isophorone diisocyanate (IPDI) Tetramethylxylene diisocyanate (TMXDI) Toluene diisocyanate(tdi) Isocyanates can be present in polyurethanes and they are known to be irritants BP Chlorine Some worker safety and environmental issues with chlorine and also with chlorinated compounds Some water regulations set limits Free - Solvent extraction + HPLC Blocked - Solvent extraction + GCMS Injector block at 300oC, confirm at 180oC 1 ppm Guidance 1 ppm of free isocyanates and 50 ppm blocked isocyanates Best Practice only no testing Best practice only no limit BP Potassium Permanganate Skin irritant protection systems such as water curtains are advised Best Practice only no testing Best practice only no limit BP Sequesterants Can affects natural balance of water courses Some water regulations set limits Best Practice only no testing Best practice only no limit PSA Sand Blasting Can cause silicosis Best Practice only no testing Best practice only no limit BP Metals in dyes Some metals such as chromium, nickel and copper are used as an integral part of dye molecules in order to deliver enhanced technical performances. Pentland brands recommend the use of metal-free dyes where metal-free dyes can deliver the same technical performance as a metal containing option Best Practice only no testing Best practice only no limit Page 9 of 11

10 REACH SVHC s Chemicals listed as SVHC s under Reach legislation must not be used without written permission from Pentland Brands any deliberate use has to be declared. SVHC s not otherwise covered by specific limits as part of these standards must not be present above 100ppm. Ozone depleting substances We do not permit the deliberate use of any ozone depleting substances and they must not be present in finished products. Information on ozone depleting substances can be found at Comments Test Method of Please see detailed info in Module 3. EPA 8260 B AL ph ph must be controlled between 4-9 to comply with Chinese legislation 4-7 EPA 8260 B Sundries Electrical Items and electrical components Notes It is an expectation that suppliers of electrical equipment have in-house experts who are conversant with global legislation who manage restricted substances in these products. There are certain pieces of legislation relating to the electrical function and safety of electrical items such as the Low Voltage Directive 2006/95/EC and Electro Magnetic Compatibility (EMC) Directive 2004/108/EC and it is a requirement for all equipment to comply with such legislation. There is also a requirement for products to comply with recycling requirement such as WEEE Directive 2002/95/EC and 2002/96/EC (For example Under the WEEE Directive components and batteries containing Mercury should be removed and collected separately from electronic and electrical waste). The RoHS (Restriction of Hazardous Substances) Directive 2002/95/EC is legislation that covers restricted substances that seeks to substitute and reduce the use of hazardous substances in electrical and electronic goods. Electronic equipment put on the market should not contain Lead, Mercury, Cadmium, Chromium (VI), polybrominated biphenyls (PBB) or polybrominated diphenyl ethers (PBDE). The maximum permitted concentrations are 1000 ppm (except for cadmium, which is limited to 100 ppm) by weight of homogeneous material. This means that the limits do not apply to the weight of the finished product, or even to a component, but to any single substance that could (theoretically) be separated mechanically for example, the sheath on a cable or the tinning on a component lead. NOTE: The RoHS and WEEE Directives do not apply directly to textile or leather products, but would apply to battery-operated items such as flashing lights on children s shoes, jackets with in-built ipod connectors, heat-cell jackets etc. Page 10 of 11

11 Food and Drink Storage Products Plastics - Any food or drink storage item made out of plastic (e.g. water bottles) must comply with EU Directive 90/128/EC Commission Directive Relating to Plastics Materials and Articles Intended to Come into Contact with Foodstuffs. The test required is EN 1186:2002, which determines the total amount of all substances that can be extracted from the product. Recycled Plastics Any recycled plastic that comes into contact with food must comply with requirements and authorisation procedure of recycling processes used in manufacture under Regulation EC 282/2008. Restricted substances include N-Nitrosamine, vinyl chloride monomers and epoxy derivatives but for more detailed information please refer to Packaging Marketing, Promotional and POS Material Standards Fumigation Care Products Suppliers are encouraged to design and select packaging materials that can be re-used or recycled. Suppliers must be familiar with legislation in the territories where products are placed on the market and ensure compliance. For example the EU Packaging & Packaging Waste Directive (94/62/EC) is concerned with minimising packaging waste material and promoting energy recovery, re-use and recycling of packaging. We require that the total metal content of Lead, Cadmium, Mercury and Chromium VI should not exceed 100ppm in accordance with the EU Packaging Directive We also remind suppliers that certain additives in packaging materials can transfer onto the products they contain and cause failures therefore it is possible that legal packaging can lead to failures against the Pentland restricted standards. We believe the use of sachets of silica gel and other desiccants to be largely useless in preventing mould and mildew during transportation. The use of any active biocides is not permitted without the permission of Pentland and suppliers are reminded that some products (such as Dimethyl Fumarate) are now illegal in certain territories, including Europe. EU Biocidal Products directive require Pentand brands to label any product, including packaging, that has an anti-microbial function with the name of the active ingredient. Therefore, suppliers must provide the name of the active chemical (not trade names) and the brands must authorise its use prior to orders being confirmed. Marketing and promotional items incorporates all additional materials used to sell or promote a brand or product. This is a very diverse category that can include paper and plastic used for displays, sweets, giveaways and gifts that can be made of virtually any type of material. Relevant legislation for restricted substances standards still applies to these items and suppliers should ensure they have in-house experts who are familiar with all relevant legislation and standards relating to their specific products. Occasionally cosmetics are provided as giveaways and a useful guide can be found at There is a legal requirement for some shipments in some countries to be fumigated to control pests and diseases. The chemicals used for this process are often stipulated by local law and Pentland will take this into account when passing judgement on chemical content of final products. There are a very small number of care products that are sold to be applied to footwear and clothing - for example cleaners and water-proofing agents. When applied according to the manufacturers recommendations the resulting textile or leather products must comply with the above restricted substances standards. It is expected that suppliers of these products have their own in-house experts to ensure they comply with all legal and regulatory requirements, including detergent legislation for cleaning products. Components In addition to meeting the standards for restricted substances COMPONENTS (e.g. zips, pulls, toggles) and trims must meet specific legislation relating to physical issues (such as choking hazards). Page 11 of 11