How to Implement a Restricted
Substance List (RSL)
Greg Montello, New Balance
outdoorindustry.org
outdoorindustry org
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C
i ht ©2012 Outdoor
O td
Industry
I d t Association
A
i ti
| All rights
i ht reserved.
d
Copyright ©2012 Outdoor Industry Association | All rights reserved.
1
Webinar Logistics
- Questions and comments welcome!
- We will hold questions until the end of the
program
- “Raise your hand” or type a question into the
Questions p
pane as we g
go along
g
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Today’s Agenda
By the end of this webinar, brands and retailers will be better informed on both
what an Restricted Substance List (RSL) is and how to implement it.
Timing
Objectives
5 minutes
•
Review agenda, provide a brief overview of the Chemicals
Management Working Group and introduce speakers
15 minutes
•
What is an RSL and Why do I need One?
15 minutes
•
Characteristics of a successful RSL and implementation
strategy
t t
15 minutes
•
What to do if a product is in violation of your RSL
10 minutes
•
Additional Q&A
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Chemicals Management Working Group
Mission: “Provide education, guidance and decision-making tools to drive continuous
improvement and innovation in chemicals management practices industry-wide, in
order
d to
t accelerate
l
t the
th d
development
l
t and
d use off G
Green Ch
Chemistry,
i t and
d ultimately
lti t l
reduce or eliminate hazardous chemicals in consumer products and their
emissions to the environment and workplace.”
1
Increase CM
Awareness &
Understanding
2
3
Enable Better
Decision-making
Collaborate with
like-minded efforts
outdoorindustry.org
Chemicals
Management
Education Series
Performance Indicators
(for index)
Chem. Mgmnt. Tools
Evaluation
 OIA-supported, in collaboration
with Sustainable Apparel
Coalition
 ~100
100 members (predominantly
(predominantl
brand, retail, suppliers)
 Steering Committee
 Technical Committee
 6 small teams driving work
product development
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Today’s Speaker
Greg Montello,
G
M t ll P
Product
d tC
Compliance
li
Manager, New Balance
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What is an RSL?
Chemical substances either:
• Prohibited from use
• Limited in the product
• Restricted in manufacturing
•
L i l ti
Legislation
• NGO
• Consumer / worker protection
protection
• Environmental p
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Chemicals
• Critical for consumer products
• Unique properties
• Unique purpose
• Where does the chemical end up?
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End of Life
worker
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Focus on Product
RSL Focus
• Chemical on product
• Day
• Night
g
• Direct skin contact
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Why is an RSL Important?
• Product safety
• Responsibility
• Comply with legislation
• Brand image
g
• Right thing to do
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Legislation
Formaldehyde
y
• China, Japan, Russia, South Korea, EU
Countries
Li it ffor product:
Limit
d t
Indirect: 150 ppm
Direct: 75 ppm
Baby: 20 ppm *
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Consumer Protection
Types of consumer reactions:
• Skin irritation
• Sensitization
• Cancer
• Respiratory irritation
Dyes,
y , Finishes,, Solvents
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Environmental Protection
Chemicals into environment:
Air
Water
Soil
E
Examples
l
• APEOs
• Dyes
y metals
• Heavy
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Why an RSL?
• Comply with the law
• Protect the consumer
• Protect the environment
• Meet NGO concerns
• Protect business
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AFIRM Toolkit Contents
1. Introduction
2. Restricted Substance List (RSL)
3. Where are the risks?
4. Educate the Supply Chain
5. RSL Testing
6 RSL Implementation
6.
7. Links to brand RSLs
8. Appendices
www.afirm-group.com
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Causes of Confusion
Human Behavior
Raw Material Management
Chemical Management
Production Processes
H
Human
B
Behavior
h i Sit
Situation:
ti
1. Misunderstanding
2 Wrong interpretation
2.
3. Poor communication
4. Lack of accountabilityy
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Understanding the RSL
Read the RSL and
Toolkit!!!
• Substances
• Limits
• Testing
T ti
Toolkit reference:
Chapter 1: Introduction
Chapter 2: Restricted Substance List
Human Behavior
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Education and Communication
All staff,, with focus on:
• Material / chemical purchaser
• Production manager
• Chemical room manager
• A
Anyone that
th t touches
t
h
chemicals
Toolkit reference:
Chapter 4: Educate the Supply Chain
Human Behavior
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Education and Communication
Your Supply Chain
• Raw material supplier
• Chemical supplier
pp
• Subcontractors
• Packaging supplier
• Sundry supplier
Must Have:
2 Way Communication
Human Behavior
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Causes of Confusion
Human Behavior
Raw Material Management
Chemical Management
Production Processes
Raw material management situation:
1. Purchase raw material containing
restricted substance
2. Incorrect use of material
3. Contamination
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Raw Material Management
Know what you purchase
•
•
Type of material
Chance for failure
Source of raw material
•
•
Reputable supplier
Small corner shop
Assurance from supplier
•
•
Ra Material
Raw Material Management
outdoorindustry.org
Test reports, eco labels, declarations
Recent date, valid test method, same material
Maintain a comprehensive understanding of
your raw material to minimize failure risk
y
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Raw Material Management
Understand p
potential failures for each type
yp of
material and test accordingly
Example: Natural Fibers
•
Core tests: metals, azo dyes, etc.
•
Supplemental tests: PCP
Toolkit reference:
Ra Material
Raw Material Management
outdoorindustry.org
Chapter 3: Where are the Risks?
material to minimize failure risk
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Raw Material Management
• Require
q
suppliers
pp
to follow yyour testing
g
requirements
• Proactive internal education and
random testing
• Require test reports from raw material
suppliers
Toolkit reference:
Ra Material
Raw Material Management
outdoorindustry.org
Chapter
p 5: RSL Testing
g
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Causes of Confusion
Human Behavior
Raw Material Management
Chemical Management
Production Processes
Chemical management situation:
1. Purchase chemical containing restricted
substance
2. Incorrect use
3. Wrong dosage
4 Contamination
4.
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Chemicals Management
Chemicals include:
• Dyestuff and colorants
• Printing
P i ti inks
i k and
d bi
binders
d
• Detergent, fixing agents,
softeners
ft
• Chemicals for special finishing
( i kl ffree / easy care))
(wrinkle
• Adhesives and solvents
Chemical
Ch
i l
Management
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Chemicals Management
• Provide yyour RSL and education to
your chemical suppliers
• Obtain Material Safety Data Sheet
(MSDS)
• Require documented assurance of
compliance
If they don
don’tt know what they’re
they re
selling, don’t buy their chemical!!
Chemical
Ch
i l
Management
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Chemicals Management
Chemical p
purchase p
price is not the only
y
factor when selecting chemicals
Chemical
Price
Usage per
garment
g
Price per
garment
A
B
$50/kg
$150/kg
25 g
grams
8g
grams
$1.25
$1.20
Chemical
Ch
i l
Management
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Chemicals Management
In-house chemical management
g
• Maintain a current chemical inventory
• Label and segregate all chemical
containers properly
• Cover all containers – avoid spillage
and contamination
• Educate staff who handle chemicals
• Document and maintain formulations
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Causes of Confusion
Human Behavior
Raw Material Management
Chemical Management
Production Processes
Chemical management situation:
1 P
1.
Purchase
h
chemical
h i l containing
t i i restricted
ti t d
substance
2. Incorrect use
3. Wrong dosage
4. Contamination
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Production Processes
•Worker education
• Document all chemical formulations
• Regular calibration of equipment
• Appropriate chemical use:
• Dying, printing, finishing
y g, p
g,
g
• Comprehensive documentation
• Technical Data Sheets (TDS)
Technical Data Sheets (TDS)
• Material Safety Data Sheets (MSDS)
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Restricted Substance Found
1. Don’t panic!
2. Inform your customer – Stop
shipments
3 Involve
3.
I
l raw material
t i l and
d chemical
h i l
suppliers in investigation
4 Track the source of the failure
4.
• Raw materials
• Chemicals
5. Test all product ingredients
6. Verify process control, TDC, MSDS
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Today’s Agenda
By the end of this webinar, brands and retailers will be better informed on both
what an Restricted Substance List (RSL) is and how to implement it.
Timing
Objectives
5 minutes
•
Review agenda, provide a brief overview of the Chemicals
Management Working Group and introduce speakers
15 minutes
•
What is an RSL and Why do I need One?
15 minutes
•
Characteristics of a successful RSL and implementation
strategy
t t
15 minutes
•
What to do if a product is in violation of your RSL
10 minutes
•
Additional Q&A
outdoorindustry.org
Copyright ©2012 Outdoor Industry Association | All rights reserved.
32
Th
kY
Thank
You.
outdoorindustry.org/OU
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outdoorindustry org
Copyright
C
i ht ©2012 Outdoor
O td
Industry
I d t Association
A
i ti
| All rights
i ht reserved.
d
Copyright ©2012 Outdoor Industry Association | All rights reserved.
33