1. No category

How to Implement a Restricted
Substance List (RSL)
Greg Montello, New Balance
outdoorindustry.org
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.
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
outdoorindustry.org
Copyright ©2012 Outdoor Industry Association | All rights reserved.
2
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.
3
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
Copyright ©2012 Outdoor Industry Association | All rights reserved.
4
Today’s Speaker
Greg Montello,
G
M t ll P
Product
d tC
Compliance
li
Manager, New Balance
outdoorindustry.org
Copyright ©2012 Outdoor Industry Association | All rights reserved.
5
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
outdoorindustry.org
Copyright ©2012 Outdoor Industry Association | All rights reserved.
6
Chemicals
• Critical for consumer products
• Unique properties
• Unique purpose
• Where does the chemical end up?
outdoorindustry.org
Copyright ©2012 Outdoor Industry Association | All rights reserved.
7
End of Life
worker
outdoorindustry.org
Copyright ©2012 Outdoor Industry Association | All rights reserved.
8
Focus on Product
RSL Focus
• Chemical on product
• Day
• Night
g
• Direct skin contact
outdoorindustry.org
Copyright ©2012 Outdoor Industry Association | All rights reserved.
9
Why is an RSL Important?
• Product safety
• Responsibility
• Comply with legislation
• Brand image
g
• Right thing to do
outdoorindustry.org
Copyright ©2012 Outdoor Industry Association | All rights reserved.
10
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 *
outdoorindustry.org
Copyright ©2012 Outdoor Industry Association | All rights reserved.
11
Consumer Protection
Types of consumer reactions:
• Skin irritation
• Sensitization
• Cancer
• Respiratory irritation
Dyes,
y , Finishes,, Solvents
outdoorindustry.org
Copyright ©2012 Outdoor Industry Association | All rights reserved.
12
Environmental Protection
Chemicals into environment:
Air
Water
Soil
E
Examples
l
• APEOs
• Dyes
y metals
• Heavy
outdoorindustry.org
Copyright ©2012 Outdoor Industry Association | All rights reserved.
13
Why an RSL?
• Comply with the law
• Protect the consumer
• Protect the environment
• Meet NGO concerns
• Protect business
outdoorindustry.org
Copyright ©2012 Outdoor Industry Association | All rights reserved.
14
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
outdoorindustry.org
Copyright ©2012 Outdoor Industry Association | All rights reserved.
15
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
outdoorindustry.org
Copyright ©2012 Outdoor Industry Association | All rights reserved.
16
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
outdoorindustry.org
Copyright ©2012 Outdoor Industry Association | All rights reserved.
17
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
outdoorindustry.org
Copyright ©2012 Outdoor Industry Association | All rights reserved.
18
Education and Communication
Your Supply Chain
• Raw material supplier
• Chemical supplier
pp
• Subcontractors
• Packaging supplier
• Sundry supplier
Must Have:
2 Way Communication
Human Behavior
outdoorindustry.org
Copyright ©2012 Outdoor Industry Association | All rights reserved.
19
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
outdoorindustry.org
Copyright ©2012 Outdoor Industry Association | All rights reserved.
20
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
Copyright ©2012 Outdoor Industry Association | All rights reserved.
21
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
Copyright ©2012 Outdoor Industry Association | All rights reserved.
22
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
Copyright ©2012 Outdoor Industry Association | All rights reserved.
23
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.
outdoorindustry.org
Copyright ©2012 Outdoor Industry Association | All rights reserved.
24
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
outdoorindustry.org
Copyright ©2012 Outdoor Industry Association | All rights reserved.
25
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
outdoorindustry.org
Copyright ©2012 Outdoor Industry Association | All rights reserved.
26
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
outdoorindustry.org
Copyright ©2012 Outdoor Industry Association | All rights reserved.
27
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
outdoorindustry.org
Copyright ©2012 Outdoor Industry Association | All rights reserved.
28
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
outdoorindustry.org
Copyright ©2012 Outdoor Industry Association | All rights reserved.
29
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)
outdoorindustry.org
Copyright ©2012 Outdoor Industry Association | All rights reserved.
30
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
outdoorindustry.org
Copyright ©2012 Outdoor Industry Association | All rights reserved.
31
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
outdoorindustry.org
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