FINAL 2018 AFIRM Toolkit 2018 English

Apparel and Footwear International RSL Management Group
CHEMISTRY
TM
TOOLKIT
Version 03 | November 2018
AFIRM Chemistry Toolkit | November 2018
Table of Contents
AFIRM Mission.......................................................................................... 3 Special Thanks

AFIRM Vision............................................................................................. 3
Policy Statement and Uses of This Chemistry Toolkit............................ 3 AFIRM Chemistry Toolkit task force for 2018:
1. Introduction........................................................................................... 4 Stella Chern, Drew DuBois, Frederic Felipe, Avery Linderman,

Joy Marsalla, John Moraes, Phil Paterson, Sonam Priya,
2. Restricted Substances Lists................................................................ 5 Mike Schaadt, Libby Sommer, Felicity Tapsell, and Han Zhang
3. Where Are the Risks?............................................................................ 6 Phylmar staff members: Nathaniel Sponsler and Elena Slagle
4. Educating the Supply Chain................................................................. 9 Outside contributor: Cenira Cristine Verona
5. RSL Testing......................................................................................... 11
6. RSL Implementation............................................................................ 12 AFIRM Chemistry Toolkit task force for 2011:
Appendix A. Brand Strategy for RSL Management.............................. 13 Arun Upadhyay, Andy Chen, Frank Kempe, Frank Opdenacker,
Kitty Man, Mary Grim, Nathaniel Sponsler, and Ylva Holmquist
Appendix B. Model RSL Testing Program for Brands........................... 16
Phylmar staff members: Elizabeth Treanor, Eric Rozance, and
Appendix C. RSL Failure Resolution Form............................................ 19 Paige Stump
Appendix D. Examples of RSL Failures & Corrective Actions.............. 20 Outside contributors: Ben Mead, Dieter Sedlak, and Jane Murphy
Appendix E. Best Practices for Screen-Printing
Applications & Finishing......................................................................... 31
Appendix F. Benefits of Water-based Polyurethane............................. 32
Appendix G. Detailed Chemical Guidance Document.......................... 33
Appendix H. Safety Data Sheets............................................................ 34
Appendix I. Online Resources................................................................ 36
Appendix J. Glossary of Terms.............................................................. 40
Apparel and Footwear International RSL Management (AFIRM) Group is the author of this work.
You may reuse or adapt this work, but we ask that you provide attribution to AFIRM Group as a courtesy.
2
AFIRM Mission
AFIRM is the Apparel and Footwear International RSL Management (AFIRM) Working Group, established in 2004. AFIRM’s mission is “to reduce the use
and impact of harmful substances in the apparel and footwear supply chain.” AFIRM’s purpose is to provide a forum to advance the global management of
restricted substances in apparel and footwear, communicate information about chemical management to the supply chain, discuss concerns, and exchange
ideas for improving chemical management.
AFIRM Vision
AFIRM continues to be a recognized global center of excellence, providing resources to enable continuous advancement of chemical management best
practices. We do this based on transparency, science, and collaboration with relevant industries and experts to build safer and more sustainable chemistry
within the apparel and footwear supply chains. It is understood that in adopting this vision, AFIRM’s mission, objectives, and projects will continue to be
product-focused or RSL-related.
Policy Statement and Uses of This Chemistry Toolkit

Apparel and Footwear International RSL Management (AFIRM) Working Group has developed this Chemistry Toolkit as part of its mission “to reduce the use
and impact of harmful substances in the apparel and footwear supply chain.”
This Chemistry Toolkit provides an overview of basic information on how to begin to implement an RSL program, which is a highly customized process that
depends on many factors, including the products being produced and where they are sold.
Many brands also have implementation guidelines, and suppliers must follow those guidelines, where available. The reader should not rely on this document
to address specific questions that apply to a particular set of facts: All questions should be directed to the specific brand company whose products are at issue.
There is no warranty, express or implied, as to the completeness or utility of the information in this document, including, without limitation, that the information
contained herein will be error free. In addition, AFIRM assumes no liability of any kind whatsoever resulting from the use of or reliance upon the contents of
this document.
For more information about AFIRM, visit www.afirm-group.com.
3
1. Introduction
In response to feedback from the global supply chain, Apparel and Footwear International RSL Management
Working Group (AFIRM Group) has updated this Chemistry Toolkit as part of our ongoing mission “to reduce the
use and impact of harmful substances in the apparel and footwear supply chain.”
Definition of “Restricted Substances” Why Substances Are Restricted AFIRM Chemistry Toolkit Overview
Restricted substances are chemicals and Substances are restricted for many reasons. This Chemistry Toolkit focuses on the needs
other substances the use and/or presence Some substances are restricted due to of brands, suppliers, and upstream vendors—
of which has been banned or otherwise concern for the environment, while others are including raw material and chemical suppliers,
restricted by a brand. restricted due to health and safety concerns mills, dye houses, trim and packaging
for workers or consumers. Some are suppliers, screen-printers, factories, and other
Typically, a restricted substance must be restricted by legislation. business entities involved in the manufacture
absent from a finished product or present of apparel and footwear finished goods.
below maximum allowable levels. Substances are restricted in different ways.
As noted above, some substances are Notable additions to this update of the
Restricted substances may be restricted banned from use during the manufacturing Toolkit include an extensive Chemical
across many industries, across one industry, process or banned from finished products Guidance Document (Appendix H) and RSL
or in certain products or inputs. entirely. Other substances might be banned if Corrective Action Examples (Appendix D).
they are present above certain concentration Both references provide specific technical
Please see Appendix J for a glossary of limits or if they leach a certain amount from a information to help eliminate or reduce
other relevant terms. finished product under predefined conditions. restricted substances in finished goods
to meet brand requirements for restricted
In each case, a substance restriction is substances.
usually accompanied by a test method that
brands and suppliers can use to verify if a While this Toolkit is primarily focused on
chemical is present and, if so, to ensure eliminating restricted substances from
the chemical is below the restricted level. finished products, extensive information
about chemical discharge into wastewater,
air emissions, and solid waste is available in
Appendix H.
AFIRM Welcomes Your Feedback to Inform Future Toolkit Updates
The AFIRM training committee made a concerted effort to update this 2018 Chemistry Toolkit. Our aim is
n their journeys toward chemical
to make it as reader-friendly and useful as possible for brands beginning
compliance as well as for suppliers educating themselves on these topics. Reach out to us with suggestions
for topics to include in future updates as well as feedback regarding content you found unnecessary.
Your comments will help us improve the Toolkit to meet your needs! Contact: nsponsler@phylmar.com
4
2. Restricted Substances Lists

The purpose of a restricted substances list (RSL) is to reduce the use of hazardous substances in the footwear and
apparel supply chain. This includes certain accessories and equipment that fall within the scope of the AFIRM RSL.
Brands publish RSLs to ensure that suppliers and vendors—as well as internal corporate employees—are aware of
and can follow their restricted substance requirements.
Why RSLs Are Important for Suppliers

The AFIRM RSL and brand-specific RSLs requirements of markets where products
clearly set forth for suppliers those chemicals are distributed or sold, and industry best
that are restricted. practices. If a brand has an RSL, it is essential
to follow its RSL.
When placing orders, AFIRM brands will
make it clear to suppliers that compliance Because individual brand RSLs vary, it
with their RSL is required. It is expected is critical to check with your customer to Apparel and Footwear International RSL Management Group
that all footwear, apparel, accessories, and ensure that you are using the correct list. If a
RESTRICTED
SUBSTANCES
equipment comply with the requirements of customer does not have an RSL, the AFIRM
the RSL on an on-going basis. RSL is a good place to start.
AFIRM recommends that suppliers understand The AFIRM RSL lists substances currently LIST
Version 03 | 2018
the purpose of an RSL and develop their own subject to legislated limits around the world,
programs to ensure they comply with as well as limits based on best practices in the
their customers’ RSL requirements. apparel and footwear industries. New for 2018
• Updates to Test Methods and Limits
• Chemical Information Sheets:
Best Practices for Chemical Management
A brand RSL is typically based on The AFIRM RSL is available at http://afirm-

• Reporting Limits for Data Capture
and Harmonization
environmental and health and safety risk group.com/afirm-rsl/. Its policy has been
assessments, current and anticipated legal adopted by many brands—both AFIRM
members as well as non-members.
Manufacturing Restricted Substances Lists

In addition to RSL requirements, brands often have a policy of adherence to a manufacturing restricted
substances list (MRSL). MRSLs cover all input chemistries and place restrictions on substances used in the
manufacture of goods. This should not be confused with an RSL, which restricts chemistries at the product level.
5
3. Where Are the Risks?

In the apparel and footwear supply chain, there are certain types of fibers and materials that are more likely
to contain restricted substances. Many brands require testing of products prior to shipment to assure that the
shipment does not contain articles not in compliance with their RSLs. (See Section 5 of this Toolkit for more
information on testing and see Appendix B for a model testing program.)
Understanding Chemical Risks Figure 1. Understanding Chemical Risks
The AFIRM RSL includes a risk matrix that

indicates which substances are likely to INVENTORY ALL CHEMICALS AND INPUTS
be found in materials typically used in the USED IN YOUR FACILITY
manufacture of apparel, footwear, certain • Chemicals
accessories, and equipment. This is a good • Components
• Raw materials
starting point for understanding chemical risks
in the supply chain. GATHER DATA REVIEW ALL DATA AGAINST THE BRAND
• Safety data sheets (SDSs) RSL AND MRSL
The flowchart in Figure 1 will help suppliers • Certificates
review production methods and ensure that • Use AFIRM Chemical Information
• Test reports
Sheets (find links in Table 1) for guidance
they meet brand RSL requirements. on where restricted substances are
Notes:
SDSs may not reflect the presence of restricted likely to be found.
substances. Chemicals that are compliant with a
manufacturing restricted substances list (MRSL), such
as the Zero Discharge of Hazardous Chemicals MRSL,
can help reduce the likelhood of an RSL failure.
Test reports are valid for one year from date of results.
CHANGE PROCESS CHEMICALS, ARE THERE RSL AND/OR MRSL ISSUES

AUXILIARIES, OR OTHER INPUTS BEFORE YES WITH THESE INPUTS THAT WILL CREATE
STARTING PRODUCTION NON-COMPLIANT FINISHED GOODS?
NO
1. FINALIZE CHEMICAL INPUTS

2. START PRODUCTION
6
AFIRM Chemical Information Sheets

Since 2017, AFIRM Group has published a Readers should not rely solely on these May 2017
series of Chemical Information Sheets. documents to address specific questions. All Best Practices for Chemical Management
Table 1, on the next page, provides links to questions should be directed to the specific Acetophenone and 2-Phenyl-2-Propanol
these publications in four languages. brand whose products are at issue.
Other Names Uses in the Supply Chain
There are few direct uses of acetophenone or 2-phenyl-2-
These documents serve as a single point of AFIRM assumes no liability of any kind
Acetophenone • Methyl phenyl ketone
• Acetylbenzene propanol in the supply chain. These two chemicals are
2-Phenyl- • 1-Hydroxycumene byproducts when a peroxide initiator called dicumyl peroxide
reference for the substances (or categories of whatsoever resulting from the use of
2-Propanol • Dimethylphenylmethanol (DCP) is used in ethyl-vinyl-acetate (EVA) foam production.
DCP initiates a cross-linking reaction in EVA foam by creating
peroxide radicals, and both acetophenone and 2-pheyl-2-
substances) in the AFIRM RSL. or reliance upon the contents of these

CAS Number Substance
propanol are potential endpoints for the radicals once they
98-86-2 Acetophenone have been deactivated.
documents.
617-94-7 2-Phenyl-2-Propanol Why Acetophenone and 2-Phenyl-2-Propanol
Are Restricted
Acetophenone has a sweet pungent odor of orange blossom
The sheets provide a brief background on

May Be Found In • Ethyl-vinyl-acetate (EVA) foams
produced with dicumyl peroxide as
or jasmine, with an odor threshold of about 0.83 milligrams
a cross-linking initiator per cubic meter (mg/m3).1 While these chemicals are not
where the substances are used in the supply www.afirm-group.com/chemical-information-

• Fragrances regulated in finished products at this time, AFIRM has
• Solvents voluntarily restricted acetophenone and 2-phenyl-2 propanol
• Cleaners due to the odor, which has prompted concern by some
chain, the reasons these substances are sheets

enforcement agencies.
• Acetophenone is classified as Acute Tox 4 - H302, Eye
Irrit. 2 - H319
restricted, as well as guidance on sourcing Sourcing Compliant Materials from Your Suppliers
• 2-Phenyl-2-propanol is not classified
compliant materials or safer alternatives. EVA polymers created using DCP as a cross linker may contain some level of acetophenone and 2-phenyl-2-propanol.
Engaging in a conversation with your material supplier to discuss this issue is the best way to procure materials with the
lowest levels of Acetophenone and 2-phenyl-2-propanol possible.
Sourcing Compliant Formulations from Your Chemical Suppliers

In this special case, there is no “compliant formulation” that can be sourced. Rather, to avoid the creation of acetophenone
and 2-phenyl-2-propanol, a different manufacturing approach that utilizes a cross-linking agent other than DCP would need
to be utilized. Caution should be used if an alternative to DCP is used, as some available alternatives are suspected of
creating more hazardous byproducts.
While it may be possible to reduce the amount of the byproducts with stringent processing controls, it is unlikely that a
complete absence of these two chemistries will be achieved when DCP is used.
Safer Alternatives
There are alternative recipes for creating EVA polymers that do not require DCP as a cross-linker, but each has the
potential to create other additional byproducts.
Resources
1
Acetophenone. U. S. Environmental Protection Agency. January 2000. Retrieved from
https://www.epa.gov/sites/production/files/2016-09/documents/acetophenone.pdf
7
Table 1. AFIRM Chemical Information Sheets
Substance Language Substance Language
Acetophenone and 2-Phenyl-2-Propanol Heavy Metals, Total
Alkylphenol Ethoxylates (NPEO, OPEO) Heavy Metals, Extractable
Alkylphenols (NP, OP) Heavy Metals, Chromium VI
Azo-amines Heavy Metals, Nickel Release
Bisphenol-A Monomers, Styrene and Vinyl Chloride
Chlorinated Paraffins, SCCP (C10-C13) and MCCP (C14-C17) N-Nitrosamines
Chlorophenols (Tri-, Tetra-, and Pentachlorophenols) Organotin Compounds
Chlororganic Carriers Ortho-phenylphenol (OPP)
Dimethylformamide (DMFa) Ozone-depleting Substances
Dimethylfumarate (DMFu) Perfluorinated and Polyfluorinated Chemicals (PFCs)
Dyes: Acid, Basic, Direct, Other, Navy Blue Pesticides, Agricultural
Dyes: Disperse Phthalates
Flame Retardants Polycyclic Aromatic Hydrocarbons (PAHs)
Fluorinated Greenhouse Gases Volatile Organic Compounds (VOCs)
Formaldehyde
8
4. Educating the Supply Chain

Implementing a robust RSL policy, shown in Figure 2, is a collaborative effort between brands and suppliers. Brands
are responsible for educating their contracted suppliers about their RSL requirements and procedures, including
clear testing protocols. Ideally, suppliers communicate brand RSL requirements along with real-time updates to
upstream vendors, keeping all links in the supply chain informed and compliant.
Figure 2. Implementing a Robust RSL Policy Across the Supply Chain
Communicates RSL Communicates RSL

policy and testing policy and testing
requirements requirements
Provides Provide UPSTREAM

BRAND certifications and SUPPLIER certifications and
test reports test reports VENDORS
Provides approvals, Provides approvals,

rejections, and updates rejections, and updates
as appropriate as appropriate
9
Communicating with Upstream Vendors

AFIRM suggests the following process for Use and encourage the use of chem-
2 4 Make an effort to understand chemistries
educating your own supply chain: istries from reputable manufacturers in use and where restricted substances
only. may be found in the apparel and footwear
Communicate all RSL and testing supply chain.
1
requirements to upstream vendors. Good resources include:
See Figure 1 and Table 1 above, as well
Ensure all subcontractors, accessory • Ecological Toxicological Association as Appendix G, for more specific technical
suppliers, dye mills, print mills, tanneries, of Dyestuffs www.etad.com information about where various restricted
chemical suppliers, etc. are aware of the substances are introduced during the
brand’s RSL requirements and have the • bluesign® www.bluesign.com manufacturing process.
latest version of the brand RSL on hand.
Appendix D provides examples of RSL
See Appendices A and B for tips on how Insist that chemical suppliers provide failures and the corrective actions taken
to establish a strategy for RSL management
3
safety data sheets (SDSs) for dyes and to remediate them.
as well as a testing program. textile auxiliaries.
SDSs may help reveal whether the materials

contain restricted substances.
See Appendix H for an overview and examples

of SDSs.
10
5. RSL Testing
Many brands have specific RSL testing requirements. If your customer does not have testing requirements, AFIRM
recommends that all suppliers develop a testing program of their own. Appendix B represents a brand testing
program, which is from the brand’s point of view and may be helpful in understanding testing issues. If your
customer does not have testing requirements, suppliers are encouraged to trust, but verify, that vendors are RSL-
compliant through a testing program.
Brand-approved Laboratories Criteria for Selecting a Laboratory • Are in-house protocols documented in
manuals? Are they available to customers?
Typically, brands have their own lists of If your customer does not have a list of
approved laboratories, and test samples approved laboratories, here are some • Has the lab ever been denied or lost
must be sent only to laboratories approved considerations to keep in mind when certification?
by the brand. choosing a laboratory for your own testing.
• Is a list of key scientists, including their
• Does the lab hold certifications or degrees, certifications, etc. available?
accreditations? From whom?
• Is a list of major on-site analytical equipment
(Accreditation is required by the U.S.
available?
Consumer Product Safety Improvement
Act, enacted 14 August 2008.) • Is a list of reference methods the lab
routinely performs available?
• Does the lab follow good laboratory
practices (GLPs) or ISO 17025 guidelines? • Is a list of sample handling and preparation
capabilities available?
• Does the lab have a quality policy statement
or other document stating general quality • Approximately how many analyses does the
procedures? lab conduct per month or year?
• What was the date and result of a recent • What percentage of the lab’s analyses are
external audit? Is a report available? subcontracted to a third party?
• Does the lab belong to a private quality • In what languages are reports available?
assurance organization?
• Are data processed by hand or computer?
• Does the lab regularly participate in any
round-robin or blind sample testing? • Does the lab have an automated laboratory
information management system (LIMS)?
• Is the lab open to a site visit or audit?
11
6. RSL Implementation
A well-governed RSL management program enables suppliers to meet various brand requirements and manage
chemical risks. AFIRM recommends the following steps to implement an effective RSL program.
Ensure internal governance and • Advise vendors of material-specific risks

1 4 Adopt best practices and work on
communication. and basic chemical legislation. continuous improvement.
(See the AFIRM RSL and Chemical
• Develop and publish a company policy, Information Sheets.) • Track emerging legislation and industry
including steps for implementation. (See standards, and perform ongoing risk
Appendix A.) • Establish a strong due-diligence procedure assessments of your supply chain and
to track, gather, and follow up with all operations.
• Ensure commitment from internal stake- vendors on a regular basis.
holders and the senior management team. • Identify the most relevant requirements from
• Stop conducting business with suppliers customers or industry standards, and adopt
• Assign responsibility to a department that do not comply with your standards. them as your own.
or a staff member, and ensure strong
governance. • Develop strong internal capacity,
governance, and processes for controlling
• Perform a risk assessment of your 3 Set up a testing system for monitoring chemical risks in your supply chain and
compliance with RSL requirements.
operations to identify areas of exposure production, incorporating a chemical
to risk. • Follow customer chemical test program policy, due-diligence testing, and strong
at specified laboratories closely, or management of incoming materials and
• Set an implementation schedule and train chemicals to ensure compliance to the RSL.
communicate testing needs to laboratories
internal staff. (See Appendix A.)
based on needs of customers or risk. (See
the Risk Matrix in the AFIRM RSL.) • Adopt industry-aligned MRSL standards
Best practice: Track emerging legislation in manufacturing to support compliance of
and industry standards, and align internal products to the RSL.
• Set up a system for how often finished
policies and standards with the most stringent
products or materials are tested for
regulations and best practices.
restricted substances. Self-testing of
materials will enable stronger performance
in customers testing programs.
Communicate your requirements to
2
production facilities and material suppliers. Best practice: Set up strong internal
management systems controlling incoming
• Send brand RSLs and testing materials are meeting the RSL, and incoming
requirements to downstream vendors chemicals are meeting MRSL standards,
and collect confirmation that they have including self-testing of incoming materials and
read, understood, and can meet these chemicals as additional due-diligence.
requirements.
12
Appendix A. Figure 3. Implementing a Robust RSL Policy
Brand Strategy for 1

ADOPT AN RSL POLICY Short-term goals
RSL Management
Long-term goals
Appendix A outlines a path for
brands commencing robust 2 3
RSL compliance programs. FINISHED-GOODS MATERIAL SUPPLIER &
FACTORY MANAGEMENT VENDOR MANAGEMENT
Figure 3 shows each step, with
corresponding best practices for
managing a program described 4
in text. AFIRM strongly suggests MATERIAL TESTING POLICY
that brands build compliance with
RSL requirements into the buying 5
process so that it is an integral part PRODUCTS FOR
of sourcing decisions. ADDITIONAL SCRUTINY
1 Adopt an RSL Policy 6

CHEMICAL TESTING OF MATERIALS AND/OR PRODUCTS
The AFIRM RSL is a good starting point for
brands beginning a journey into compliance.
However, it is not the only policy, and it is
important for a brand to adopt a policy that
appropriately covers it range of products.
Compliant Non-compliant
At the start of the journey, describe your materials and products materials and products
overall management strategy to minimize RSL
risk and identify short- and long-term goals.
Examples of these goals are outlined on the
7
next page. RSL DATA MANAGEMENT SYSTEM
8
CORRECTIVE ACTIONS
9
REVISE AND UPDATE THE RSL POLICY
13
Examples of short-term goals: 3 Material Supplier & Vendor Management 5 Products for Additional Scrutiny
• Identify RSL risk by materials. (See Risk from vendors can vary greatly. Your RSL You may have high-volume products, products
Section 3 and Appendices B and D.) management strategy should include verifying for kids, or products that come into direct
vendors’ understanding of and commitment contact with the skin.
• Set up the RSL risk control strategy. to global standards regarding restricted
substances. Globally recognized vendors See Appendix B, Figure 7, for more details
• Develop tracking report/system for tend to have this knowledge, and non-global about performing additional testing on these
strengthening RSL risk management. vendors may also have this knowledge products.
through their efforts. Also consider supplier
• Report all RSL test results to management
and product track records of RSL compliance,
on a monthly basis.
analyses, as well as passes and failures. Chemical Testing of Materials
6
and/or Products
Examples of long-term goals:
Formulate your management strategy to
minimize risk from vendors: The best way to manage the RSL is to employ
• Create an evaluation system to track factory
staff with in-depth knowledge about product
and vendor compliance (i.e. a scorecard).
• Do you classify vendors by RSL risk? chemistry. Learning the processes and
• Use the result of evaluation for future chemicals used by vendors is an important
• How do you define high-risk and low-risk factor to understand product chemistry. This
sourcing decisions.
vendors? can be achieved either by studying the SDSs
• Share the RSL database with vendors. of materials or by speaking to suppliers and
• How do you ensure that new vendors
visiting their factories. (See Appendix H for
understand and meet RSL requirements?
examples and an explanation of SDSs.)
2 Finished Goods Factory Management
Chemical testing is another tool to better
Identify your factory locations and ensure 4 Material Testing Policy understand product chemistry. A thorough
you have a list that includes: knowledge of the chemistry of the
List the material suppliers that your finished manufacturing process is also necessary to
• Factory name goods factories use and the materials they identify additional RSL risks that might be
supply. Determine if any of these materials introduced during manufacture.
• Location pose an increased risk. For example:
Any testing should prioritize components that
• Factory RSL contact name • High-risk materials might include leather, pose the highest risk. (See Section 3 and
synthetic leather, TPU, metal, injection, ink, Appendix D.) If required, chemical testing of
• Factory RSL project team—the staff and paint. components and products is preferable to
members responsible for RSL compliance testing upstream materials.
• High-risk colors may include fluorescent
colors, black-colored items, or items with a
metallic finish.
• Items that come in direct contact with the

skin can also be classified as high risk.
14
7 RSL Data Management System 8 Corrective Action 9 Update and Revise the RSL Policy
RSL testing as described by the AFIRM group Though we would like to eliminate all risks, we Worldwide legislation is constantly changing.
covers approximately 300 chemistries across recognize that there will be some component It is important to revise your policy on a
12 product types. Not all tests are appropriate failures. The cause(s) of individual failures yearly basis. AFIRM updates the AFIRM RSL
for all material types. However, even with a can be many and varied. Root-cause analysis in January each year, for example. The data
small sub-set of analytes being tested, there should be performed to determine how to best gathered in the previous years’ testing can be
will eventually be a large set of data for your reduce risk of RSL violations. See Appendix C used to inform updates to the policy as well.
brand. for a failure resolution form useful for recording For example, shifting focus onto materials your
and retaining this information for future supply chain is struggling to meet the policy
A robust data-management system is reference and to provide to brand customers. on and moving focus away from lower risk
essential for brands to have a state-of-the-art materials in your supply chain.
compliance program. Formulate a corrective action plan that works
best for non-compliance issues. Important
Such a system will allow a brand to: things to do immediately:
• More closely assess their own supply chain • Stop all further production of the non-
with respect to product types. compliant material/product.
• Pinpoint reliable and unreliable suppliers. • Assess scope of the problem and the
current location of the non-compliant
• Identify analytes of high concern in different material.
materials.
• Work with the vendor/supplier to ensure
• Prove compliance to appropriate legislators. they do not ship non-complaint material.
• Effectively track failure resolutions and Follow-up actions can include:
corrective actions.
• Understanding the root cause of the
• Be transparent with vendors and suppliers. problem.
• Putting systems in place to make sure the

issue does not arise again.
• Increased monitoring of the vendor/supplier

with the issue.
15
Appendix B. Model RSL Testing Program for Brands

This appendix provides an example of what a brand’s testing program might look like. It is included to help suppliers
understand the kind of testing requirements they can expect from customers and how to design their own internal
testing protocols to meet them. Please note that no two brands have the same protocols and you should always
check with your customer to make sure you fully understand their requirements.
1 Aim 3 Scope 4 Introduction
To ensure chemical compliance and the This testing program applies to all brand As part of their responsibilities, it is important
safety of finished goods. finished goods, including clothing, that brands perform a degree of analytical
accessories, jewelry, footwear, sport testing to monitor and prove product and
equipment, packaging, etc. supplier performance. Auditing suppliers and
2 Objective setting specifications alone is insufficient to
The protocol also covers products not ensure products are legal and safe.
All finished goods must be reviewed according branded but for which the brands have
to an agreed-upon testing program to ensure legal responsibility. Analytical testing is not designed as a tool
that they are safe and legal. to manage quality, although the information
gathered from this testing may be used to
monitor this indirectly.
Figure 4. Procedure for Product Surveillance • This product data will be used to ensure its
chemical compliance and safety
IDENTIFY PRODUCT Refer to Figures 5 and 6 • This product data could be used as part
AND SUPPLIER of their defense to prove compliance when
challenged by trading standards / courts /
media / consumer groups / NGOs.
IDENTIFY TESTS Refer to Figure 7
• Test results will be used internally to
PASS: RECORD RESULT IN demonstrate that management processes
YOUR INFORMATION SYSTEM are in place and operating correctly.
4. PRODUCT TO
SEND
REVIEW TEST REPORT
LAB FOR TESTING
OUT OF SPECIFICATION (OOS): 5 Procedure
RECORD RESULT IN OOS TRACKER
AND INVESTIGATE Figure 4 outlines an example of a general,
high-level procedure for product surveillance.
Details on the first two steps are found in
following sections.
16
6 Risk Assessment 7 Tips for Deciding What to Test • Supplier has historically performed well in
testing (e.g. no fail results in the past 12
Understanding the chemical risks in your All new suppliers should be deemed high risk months).
supply chain, processes, and product is and subject to a high-frequency testing until a
critical in making good and appropriate level of confidence is established. • Supplier has historically performed well in
decisions. (See Understanding Chemical the chemical aspects of quality, process,
Risks on page 7). Low-frequency testing can be implemented environment, and social audits.
for all suppliers who have, at a minimum, met
It is important to know the composition of the following requirements:
your products in order to adapt your testing
protocol. For example: • Supplier has a chemical management
system in place (e.g. policy, internal control
• Leather components could contain plan, collection of certificates, training, etc.)
Chromium VI, Short-chain Chlorinated and has been certified by bluesign® or
Paraffins, Azo Dyes, or Formaldehyde ZDHC on that topic.
• Some leathers have a PVC coating; they

could also contain Lead, Cadmium and
Phthalates Figure 5. Supplier Risk Assessment
• Some leathers have a PU coating; they
could also contain Organotins and DMFa IS THIS A NEW SUPPLIER?
(as well as DMFu for PU-coated natural
leathers)
SUPPLIER IS SUBJECT TO
DOES THIS SUPPLIER HAVE A HISTORY OF
To create your own testing protocol, HIGH-FREQUENCY TESTING
POOR PERFORMANCE?
you need to:
• Testing history includes out of specification (OOS) reports
• Decide what kind of testing is required for • Does not have a chemicals management program in place
each supplier (see Figure 5). • Chemistry-related issues during quality, social, process, and
environmental audits
• Decide what testing is required for each • Product issues
product (see Figure 6 on the next page).
• Identify any chemical and physical testing DOES THIS SUPPLIER HAVE A HISTORY OF
required (see Figure 7 on the next page). GOOD PERFORMANCE?
• Testing history of pass results; no OOS reports LOW-FREQUENCY TESTING
• Chemicals management program in place
• No chemistry-related issues during quality, social, process,
and environmental audits
17
• All products classified as toys (items Figure 6. Product Risk Assessment

designed for use in play for children 14
years old or younger) should be tested as
IS THE PRODUCT A PERMANENT BRAND OFFERING?
such according to existing international
standards (e.g., dressing up out-fits/ TEST EVERY 12 MONTHS OR
disguise costumes, soft toys). It also YES UPON ANY CHANGE TO MATERIALS
IS THE PRODUCT A STRATEGIC BRAND OFFERING?
applies to products that are not specifically OR PROCESSES
sold as toys but have an obvious play value. • Baby • Iconic product
• Toys • High-volume sales
Note: This is not exclusively a chemical • Food contact
requirement, but can encompass several
product safety requirements. NO
• All infant, baby, and children’s products
are considered high risk and frequency
TEST ACCORDING TO
of testing should reflect this as well
SUPPLIER FREQUENCY
as children’s specific chemical limits, DETERMINED IN FIGURE 5
restrictions, or bans.
• All continuity products (permanent

offer) should be tested once per year Figure 7. Testing Risk Assessment
or whenever changes to materials or
processes are made.
DOES THE PRODUCT LEGALLY REQUIRE TEST FOR FLAME RETARDANTS
FLAMMABILITY TESTING? Halogenated Antimony Trioxide
• In addition to chemical testing, all products
with a promotional claim on its function
should be tested to prove the claim. This DOES THE PRODUCT MAKE ANY CLAIMS? FOR EXAMPLE: TEST FOR PERFORMANCE
is not a chemical requirement, but is worth • Stain-resistant • Antipill
noting to prove compliance. For example: PFCs FOR STAIN RESISTANCE &
• Windproof • Easycare WATER REPELLENCY
• Nightwear flammability • Waterproof, water-resistant, FORMALDEHYDE FOR EASYCARE
showerproof
• Stain resistant
• Waterproof / water resistant
WHAT IS THE COMPOSITION OF ALL COMPONENTS?
• Non-iron FOR EXAMPLE:
• Cotton • Polyurethane (PU) TEST ACCORDING TO
RSL RISK MATRIX
• Leather • Rubber
• Polyester • Metal
• Polyvinyl Chloride (PVC)
DO YOU FORESEE SPECIFIC ISSUES REGARDING THIS ADD SPECIFIC TESTS

PRODUCT OR SUPPLIER? TO YOUR CONTROL PLAN
18
Appendix C. Figure 8. Example of a Failure Resolution Form
Failure Resolution Form RSL

SUBMISSION RSL Failure Resolution Form (FRF)
ID Fields marked with * are required
PRODUCT
A failure resolution form
(of failed
(FRF) is a
useful tool for collecting, organizing, Which Brand was the sample tested for Product type
and retaining information about
Lab where sample was tested Lab reference #
RSL failures to submit to your brand
customers or for your own records. Sample Submitter Information
Vendor Code Factory Name* Factory Code Sample Submitter Company* Sample Submitter Contact Name*
There are a variety of tools
available to define, analyze, solve, Sample Submitter Contact Info (phone/fax/email)*
and prevent any future instances Vendor Information

of the problem. One such tool
Vendor Name* Vendor Code
is 8D. Further information on 8D
Material or
Item
methodology can be found at
Date Material Sample Information
a Number https://quality-one.com/8d/.
Made Date Sample Submitted Material or Product Name* Material Type*
*
Material Number or Product Code (or SKU) Date Material Made
GCW# GCW & Color Color Name 1* Color Code 1*
Color Code 2 number) Description

2 Sample Type* ○ Production-quality material ○ Research & development material ○ Finished product
Retest Follow up actions

⃝
Yes RSL Submission ID: How much material is affected by this failure?
⃝No
Where is the affected material now?
Describe your immediate next steps (for example)

• material on hold.
• material will be dropped.
• formal root cause analysis to be performed.
Please list any additional corrective and preventitive actions:
Name of the person filling this form* Date*
19
Appendix D. Examples of RSL Failures and Corrective Actions

This appendix draws content from a slide deck of actual RSL failures, with the corrective actions taken to resolve
them. It includes recommendations for preventing the failures from happening again. Please note that this
information is meant to provide high-level examples of where specific chemistry failures may be found in a range of
product categories. This will not provide detailed guidance on how to avoid all such issues in the future. There are
two valuable resources in this regard: AFIRM Chemical Information Sheets and Appendix G—Detailed Chemical
Guidance Document.
Table of Contents
Substance Page Numbers
APEOs 21
Azo Dyes 22
Disperse Dyes 22
Chlorinated Phenols 23
Formaldehyde 24
Heavy Metals 26
Organotin Compounds 28
Perfluorinated and Polyfluorinated Chemicals (PFCs) 28
Phthalates 29
Polycyclic Aromatic Hydrocarbons (PAHs) 29
Volatile Organic Compounds (VOCs) 30
20
Alkylphenol Ethoxylates (APEOs)
FABRIC SHOE INSOLE LEATHER BAG
Problem Problem Problem
APEOs were found on fabric in excess of APEO was detected in an insole board. NPEO was detected in a pigskin handbag.
the RSL limit.
APEOs occur in many steps of the production NPEOs are usually associated with
Many scouring agents, which are used to process, as they are commonly found in degreasing agents.
remove oils and fats from textiles, contain surfactant-based chemistries.
APEOs as a surfactant.
Contamination from APEOs can be a Root Cause
There are many alternatives currently common problem.
• Due to a ban on raw material products from
available without APEOs.
Japan, supplier had switched to a new
Corrective Actions degreasing agent for leather. This formula
Corrective Actions was found to contain NPEOs.
• Vendor sourced an APEO alternative scour
• Vendor sourced an APEO-alternative scour agent with no cost increase.
agent, with no cost increase. Corrective Action
• Brand communicated concern about APEOs
• Brand communicated concern about APEOs with vendor. • Using the ZDHC chemical gateway, the
to vendor. supplier found a decreasing agent that
complied with the ZDHC MRSL and did not
contain NPEOs.
21
Azo Dyes Disperse Dyes
DRAWCORD WOVEN LABEL

Problem Problem
Cord supplier used a dyestuff that Restricted disperse dye was found in a
contained prohibited Azo Dyes in a corded woven label.
children’s sweater.
Restricted disperse dyes are used in polyester
dyeing and can cause allergic reactions.
Corrective Actions
• Product was not sold.

Root Cause
• Supplier integrated RSL-compliant dyestuff
• Label was from well-known compliant
from a quality chemical company with little
suppliers, and yarns were not dyed with
to no cost impact.
disperse dyes.
• RSL requirements were communicated to
• Backer to label was found to fail for dyes.
all suppliers.
Corrective Action
• Supplier changed backer and destroyed all

inventory of failed backer color.
Polye
ster S
hir t
22
Chlorinated Phenols (PCPs) (APEOs)
SHOE ADHESIVE PRINTED SILK FABRIC
Problem Problem
PCPs were detected in shoes. Chlorinated Phenol was detected on

printed silk fabric.
PCPs can be used as precursors in the
manufacturing process for adhesives. If this Chlorinated phenols can be used as anti-
process is not optimized, Phenols can be microbials in the guar gum thickeners used in
found as contaminants. They also can be silk production.
found as biocides in preservatives.
Corrective Action
Root Cause
• Printer switched from guar gum to alginate
• PCPs were found as contaminants in the thickener to avoid contamination problems.
adhesive used to manufacture the shoe.
Corrective Action
• Supplier worked with chemical supplier

to obtain a PCP-free adhesive that was
compliant with the ZDHC MRSL.
23
Formaldehyde (APEOs)
DISCHARGE SCREEN PRINT BASEBALL HAT WRINKLED-FINISH T-SHIRT

Discharge screen print failed RSL limit Backing fabric treated with resin stiffener Cotton t-shirt treated with resin stiffener
for Formaldehyde. failed the RSL limit for Formaldehyde. failed the RSL limit for Formaldehyde.
Many ink systems contain Formaldehyde Urea Formaldehyde resins are common Urea Formaldehyde resins are common
to break down the color of the garment- chemicals used in durable press resins. chemicals used in durable press resins to
dyed fabric. produce a wrinkled effect.
Corrective Actions
Root Cause Root Cause
• In the short term, caps were washed to
• Printer found ink system was using Zinc reduce the amount of Formaldehyde. • Wrinkle finish was originally cured for
Formaldehyde Sulfoxylate (ZFS) catalyst. too short a period of time and at a lower
• Backing fabric was replaced with passing temperature than recommended.
fabric for some of the hats.
Corrective Actions
• No process control could be established to Corrective Actions
• Printer worked with ink supplier to optimize prevent Formaldehyde failure; new material
printing concentrations and to find a was developed to meet standards. • In the short term, garments were washed
Formaldehyde-free catalyst system for to reduce the amount of Formaldehyde.
discharge prints. • Factory had not switched materials for all
customers, so contamination from drying • Processes were changed to improve
• Curing times units needed to be monitored. durability and RSL compliance
and temperatures
were kept • Conditions were carefully controlled to
consistent to manage finished product compliance.
meet RSL
requirements.
24
Formaldehyde (APEOs) (APEOs)
PIGMENT-PRINTED GARMENTS COTTON FABRIC LEATHER

Formaldehyde-releasing melamine resin Cotton fabric failed children’s Formaldehyde was found in a full-grain
failed the RSL limit for Formaldehyde. Formaldehyde standard. leather wallet.
Formaldehyde-releasing melamine resin is Urea Formaldehyde resins are common

commonly used as a crosslinker in pigment- chemicals used in durable press resins. Root Cause
printed garments.
• Formaldehyde was present in a re-tanning
Root Cause chemical without an intended chemical
Corrective Actions function.
• A typo found in the fabric batch formula
• Diisocycanate crosslinker was employed as caused the Formaldehyde concentration to
an alternative approach. exceed the RSL limit. Corrective Actions
• Measurements were taken to prevent • In the short term, the leather supplier
occupational hazards when utilizing Corrective Actions decreased the percent of Formaldehyde-
diisocyanate crosslinker alternatives: containing tanning chemical in the material
• Supplier changed quality control procedures formula to reduce Formaldehyde amount in
• Proper cure time, correct ratios, to review the formula before commencing finished products.
controlled printing conditions. production for future orders.
• Leather supplier found a Formaldehyde-
• Chemical supplier provided a • Testing for affected products was increased free chemical to replace the contaminated
Formaldehyde-free option, but EH&S during development and production. chemical in the re-tanning process.
needed to be considered for new
chemistries.
25
Heavy Metals (APEOs) (APEOs)
CADMIUM IN PVC PRODUCT LEAD IN INFANT SHOES LEAD IN PU-COATED FABRIC

Cadmium exceeded the RSL limit in Red paint on trim of an infant shoe Polyurethane (PU) coated fabric contained
Polyvinyl Chloride (PVC) product. contained Lead in excess of RSL limits. high levels of Lead.
PVC contains Heavy Metal stabilizers, such Lead, which is acutely toxic in high The presence of Lead could be due to its use
as Cadmium, and Phthalates for flexibility. concentrations, can be used as a pigment as a stabilizer or pigment; it is not likely caused
Cadmium may also be used in pigments. in paints. by contamination.
Corrective Actions Corrective Actions Corrective Actions

• PVC layer was substituted with a • In the short term, the brand recalled the • Increased testing of raw materials.
thermoplastic polyurethane (TPU). product.
• Brand gave RSL requirements to garment
• New material substitutes were investigated. • Factory began a more comprehensive factory and communicated requirements
testing program for sourced raw materials. with PU fabric vendor.
26
Heavy Metals (APEOs)
LEAD IN SOCK LINERS CHROMIUM IN WOOL & CHROMIUM (VI) IN LEATHER SHOES
NYLON FABRICS
Problem Problem
Problem
Lead was detected in the coating on the Chromium (VI) was detected in leather
top cover fabric of sock liners. Chromium was detected on wool and shoes above the RSL limit.
nylon fabrics.
Heavy metals, including lead, are often used in Chromium (III) can oxidize into Cr(VI) with
low-cost pigments and inks. Chromium can be used in metalized dyes. high temperatures, exposure to sunlight, and
low humidity.
Root Cause Root Cause

Root Cause
• Lead was used the heat transfer print on • Chemicals were tested and no metalized
the sock liner. dye was used. Mill had old non-compliant • Article was originally tested using an aging
fabric in the factory that was incorrectly sent prep. Sample was re-tested with out aging
for testing. prep and passed.
Corrective Actions
• Factories communicated brand Corrective Actions Corrective Action

requirements to downstream suppliers.
• Supplier • Conditions were monitored more closely to
• Products were strategically tested at all implemented a avoid Cr(VI) formation.
stages of production. better inventory
management
system, storing
non-compliant
materials in clearly
marked areas.
• Long term,
only compliant
materials should
be produced
to avoid
contamination
issues.
27
Heavy Metals Organotin Compounds Perfluorinated and Polyfluorinated

Chemicals (PFCs)
MERCURY IN HEAT TRANSFER FOIL SCREEN PRINT WATER-REPELLENT FABRIC
Printed heat transfer failed for mercury. Foil screen prints on children’s t-shirts PFOA was detected in a webbing fabric.
were found to contain Organotins.
Mercury can be used as a pigment but Long-chain Perfluorinated and Polyfluorinated
often contamination is the reason for Organotins are often used as heat stabilizers Chemicals (PFCs), such as PFOA, are used as
Mercury failures. in low-quality adhesives and prints used in cheaper alternatives to short-chain PFCs in
printing and transfer processes. Many non- DWR treatments. They can also be found as
Organotin alternatives exist. contaminants in short-chain PFC finishes.
Root Cause
• The source of mercury was a cleaning Root Cause Root Cause

solvent that contaminated a mixing beaker.
• The cheap adhesive used in the original • After checking the SDS, the supplier found
foil print contained Organotins as a heat PFOA was in the DWR finishing chemical
Corrective Actions stabilizer. formula.
• In the short term, the heat transfer supplier
eliminated the suspected cleaning agent. Corrective Action Corrective Action
• Processes were changed to mix inks in • Supplier used a higher quality adhesive that • Supplier substituted an MRSL-compliant
disposable mixing containers. had a non-Organotin heat stabilizer. alternative, which was free of long-chain
PFCs (PFOS / PFOA).
• Time frames were established for keeping
custom-mixed inks.
28
Phthalates tic Hydrocarbons Polycyclic Aromatic Hydrocarbons
SCREEN PRINTS PLASTIC SOLE RUBBER LOGO

In testing, screen-print inks containing PVC Company received consumer complaints Molded black rubber logo failed testing for
failed for DEHP (Phthalate). that flip-flop sandals had a sticky feeling Polycyclic Aromatic Hydrocarbons (PAHs).
and were removing finishes on wood floors.
Phthalates are often used to soften ink and PAHs can be found as a contaminant in
prevent cracking. There are many non- Plasticizers are commonly used in plastics carbon black and are sometimes used in
Phthalate plasticizers available. and foams to increase flexibility and improve rubber production.
performance. Many Phthalate-based
plasticizers have been banned. Suppliers
Root Cause can use safer alternatives such as Root Cause
Acetyltributylcitrate (ATBC).
• The spray adhesive used to hold the • Supplier found that Naphthenic oil was used
garment in place during printing contained to produce the rubber.
DEHP, contaminating the finished garment. Root Cause
• Manufacturer claimed to use ATBC as a Corrective Action

Corrective Actions plasticizer in the sole of the flip-flop, but
Supplier reformulated material and substituted
instead used TBC as a cheaper substitute.
• Printer substituted a different spray adhesive Naphthenic oil out of the formula.
TBC is known as a solvent that de-coats
to achieve compliance.
furniture.
• Supplier then looked to substitute a silicone-
based print for the PVC-based screen print. Corrective Action
• Brand communicated with manufacturers

that chemical substitutions should not be
made based on price alone without looking
at safety, quality, and performance impacts.
29
Volatile Organic Compounds Phthalates
SCREEN PRINT BLACK SOCKS

Problem Problem
Small amounts of Volatile Organic Consumers complained of a solvent smell

Compounds (VOCs) were detected in in cotton-rayon socks. Testing revealed
the ink at screen-print facility. they contained Dimethylformamide (DMFa)
and Methylene Chloride.
VOCs are often used in solvents for a variety
of manufacturing processes.
Root Cause
Root Cause • Supplier was lubricating the knitting yarn

with an unlabeled solvent with no SDS
• Printer investigated and discovered information. When the yarn was tested, it
contamination from its solvent supplier’s contained restricted VOCs.
recycling tanks.
Corrective Actions
Corrective Actions
• Production was stopped immediately.
• Tools were better handled, stored, and
sanitized to prevent contamination. • All current stock and shipments were
destroyed.
• The supplier switched to an RSL-

compliant lubricant.
!!!!
30
Appendix E. Best Practices for Screen-Printing Applications and Finishing

Brand RSLs may restrict substances not subject to usage bans to certain concentrations in finished products.
These substances may be used, but appropriate steps must be taken to ensure that residual amounts or accidental
contaminants do not exceed documented limits. Solvents, for example, may be used with careful attention to drying/
curing times to greatly reduce or eliminate the amount remaining on the finished product. This appendix provides
general guidance on drying/curing best practices as well as examples of good and bad practices for maintaining
screen-print production areas.
Curing Overview • Calibrate the oven regularly and keep a RESOURCE: Best Practices for
calibration record. (Note: The digital display
Many applications and finishes require curing, attached to the oven should be confirmed Screen-Printing Applications &
such as resin finishing for a 3-D effect, easy- to represent the actual temperature in the Printing
care, or screen printing. “Curing” is not limited oven.)
to drying materials or garments, but involves This slide deck provides examples and
chemical reactions that begin at specific • If a conveyor belt oven is used in factories pictures of best and worst practices at screen-
temperatures and take time to complete. It located in colder climates, understand the print facilities.
is important to understand and control the temperature gradient at different parts of
curing temperature and duration to fully react the oven, as this may result in inconsistent
chemicals. quality or concentrations of residual
chemicals in the finished garments.
Information about appropriate curing
conditions can be obtained from chemical • Start the curing time requirement when the
suppliers. Improper or incomplete curing may garment surface temperature reaches the
lead to both chemical product safety (RSL) required curing temperature, not simply
and performance issues (e.g., losing the 3-D/ when the garment is placed in the oven.
easycare effect after a few home launderings).
Temperature checking stickers are available,
but these only record the highest temperature
Best Practices on the garment surface. There are also digital
devices that can check the garment surface
Suppliers working with resins, screen prints, or
temperature at regular time intervals. These
other applications that require curing should:
devices can give a more detailed profile of
• Request technical data sheets (TDSs) from garment surface temperature differences,
chemical suppliers and follow the listed which allows for better control of the curing
curing condition instructions. process.
• Document the finishing/screen-print

formulation and curing conditions.
31
Appendix F. Benefits of Water-based Polyurethane

This appendix briefly describes the development of water-based Polyurethane dispersions for use in apparel and
footwear products, along with the various benefits of transitioning to this technology.
Solvent-based Polyurethane Commonly used solvents in the production Polyurethane-Waterborne

of PU, synthetic PU-leather, and PU
Drawbacks coatings include N,N-dimethylformamide NMP-free Dispersions
(DMF), Toluene, N-Methylpyrrolidone
Solvent-based Polyurethane (PU) production Water-based PU is not a new technology, but
(NMP), Methyl Ethyl Ketone (MEK) and N,N-
involves the use of volatile organic solvents it has typically not been used in the apparel
dimethylacetamide (DMAC).
with links to reproductive toxicological issues. and footwear industry. New technology,
Most AFIRM companies restrict these however, has enabled the development of
The harmful properties of these solvents high-quality synthetic PU leather with minimal
substances in finished products, and they
make them the subject of regulatory use of volatile organic solvents. This synthetic
are a regular cause of RSL failures due to
action restricting their use and allowable leather can be used in footwear, apparel, and
improper drying/curing conditions during
concentrations in finished products. These accessories with minimal investments. A new
production. Improperly equipped and
substances are increasingly the target of foam generator is necessary, but traditional
incorrectly configured factories regularly
various authorities. equipment such as a coating line and mixing
release these solvents into the ambient air,
which harms factory workers directly and units can usually be left unchanged.
the environment generally. Residual amounts
Although water-based PU uses a dry process,
of these substances on finished products
it can be used in plants that currently use the
present consumer product safety issues for
wet process.
customers.
There are multiple benefits associated with
transitioning to water-based PU, including:
• Dramatic reduction of toxic solvent use

(worker/consumer/environmental safety)
• Reduced energy use (cost savings)
• Reduced use of solvents (cost saving as

prices for solvents are expected to go up)
• Reduced greenhouse gas (GHG) emissions
32
Appendix G. Detailed Chemical Guidance Document

This Chemical Guidance Document provides readers with a detailed overview of the types of chemicals used in
textile and leather goods manufacturing. It also offers information on many aspects of apparel manufacturing, from
raw materials to finishing and applications. It is best used as a reference for understanding particular aspects of
manufacturing and the chemical risks involved.
RESOURCE: Detailed Chemical

Guidance Document
The document is divided into sections with
a table of contents and index of chemicals
for easy reference and navigation. If viewed CHEMICAL GUIDANCE DOCUMENT
onscreen, it can be searched for specific Dr. Dieter Sedlak (Dipl. Chemc.)
terms using the Find (Ctrl-F) function in the

+49 (821) 56 97 96-10
d.sedlak@mts-germany.eu
PDF viewer. Table of Contents

Section Page #
1 Introduction ............................................................................................................................................ 6
1.1 Background on Textile Industry ................................................................................................................ 6
2 Textile Industry: Basic Raw Materials.................................................................................................... 14
2.1 Textile Raw Materials ............................................................................................................................. 14
2.2 Natural Fibers ......................................................................................................................................... 15

2.2.1 Wool .............................................................................................................................................. 15
2.2.2 Cotton............................................................................................................................................ 16
2.2.3 Silk ................................................................................................................................................. 19
2.2.4 Flax ................................................................................................................................................ 19
2.3 Man-Made Fibers.................................................................................................................................... 19

2.3.1 Polyester (PET, Polyethylene terephthalate) ................................................................................ 19
2.3.2 Polyamides (PA) ............................................................................................................................ 19
2.3.3 Polyacrylonitrile (PAN) .................................................................................................................. 20
2.3.4 Polypropylene (PP) ........................................................................................................................ 20
2.3.5 Polyurethane (PU) ......................................................................................................................... 21
2.3.6 Elastane (EL) .................................................................................................................................. 21
2.3.7 Viscose (CV) ................................................................................................................................... 21
2.3.8 Cupro (CU) ..................................................................................................................................... 21
2.3.9 Acetate (CA) .................................................................................................................................. 22
2.4 Preparation Systems ............................................................................................................................... 22

2.4.1 Drawing ......................................................................................................................................... 23
33
Appendix H. Safety Data Sheets

Safety data sheets (SDSs) were formerly known as material safety data sheets (MSDSs). SDSs provide valuable
information about a chemistry, which can be used to assess risk and establish controls to protect human health and
the environment. In addition, SDSs contain valuable regulatory and ingredient-level information to help suppliers
avoid restricted substances issues.
Safety Data Sheets Based On Limitations of Safety Data Sheets

Global Harmonized System Standards SDSs represent only the specific chemistry
SDSs can vary widely in format. AFIRM they were designed to describe. Therefore, an
advises suppliers to require high-quality SDSs SDS that represents a chemical used in the
from their chemical suppliers that use the manufacture of a product will not necessarily
Global Harmonized System (GHS). GHS is a apply to the final product itself.
widely accepted global standard managed
For example, an ink may be applied to change
by the United Nations that, when combined
the color of a shirt, but much of the chemicals
with local country regulations, offers the most
(by volume) of the ink may be washed
comprehensive information.
away or evaporated before the product is
For additional information, including examples ready for market. An additional caveat of an
of SDS files and in-depth documentation of SDS for chemical mixtures is that, in many
each SDS section, please visit the Outdoor circumstances, only chemicals present above
Industry Association website: https:// 1% (or 0.1% if the chemical is a carcinogen)
outdoorindustry.org/chemical-manuals/1/en/ are required to be disclosed. This can, in
topic/safety-data-sheets-sds effect, lead to an incomplete comprehension
of the risk associated with the use of a
particular chemical product. So, while an SDS
documents a chemistry chosen to create
a product, additional expertise is needed
to understand manufacturing processes to
accurately document chemicals that may be
present in a final product.
34
Important Sections Figure 9. Key Elements of a Safety Data Sheet
An SDS is often a dense document with

a wealth of information. However, there
are certain sections that need particular A
attention. These are highlighted in Figure 8.
A A version date within the last three years.
Contact information for the supplier in

B
case the reader has further questions
regarding the product.
Hazard statements to enable a rapid

C
assessment of the risks.
B
D Pictograms, which can be used in in-
house labelling to clearly communicate
risks to workers.
Component common name so that the

E D
chemical can be further researched.
F Concentration of each component,

C
which allows suppliers to determine
relative risk.
G CAS numbers of the chemical

components—useful for keeping up to
date with legislation related to the product.
H Hazards at a component level; used

with concentration to determine relative
risk.
E
Although SDSs can vary in format, AFIRM F
suppliers should require their chemical
suppliers to provide SDSs like the
preferred example here.
G H
35
Appendix I. Online Resources

Restricted Substance Lists & ChemSec – SIN List Zero Discharge of Hazardous Chemicals
http://chemsec.org/sin-list Programme
RSL Resources https://www.roadmaptozero.com
The SIN List is published by ChemSec and
AAFA Restricted Substance List used to identify hazardous chemicals under The Zero Discharge of Hazardous Chemicals
https://www.aafaglobal.org/AAFA/Solutions_ the definitions and standards used by REACH. (ZDHC) Programme aims to remove hazardous
Pages/Restricted_Substance_List This list is meant to provide a glimpse into chemicals in the textile, leather, and footwear
harmful chemicals that may be regulated in supply chain for the improvement of the
the future. environment and human health. Made up of
This RSL was created by a special working
a number of stakeholder brands, value chain
group of the American Apparel & Footwear
affiliates, and associates, ZDHC focuses on
Association’s (AAFA) Environmental Task Ecological Toxicological Association of Manufacturing Restricted Substances List
Force. The RSL is intended to provide apparel Dyestuffs (ETAD) (MRSL) guidance, wastewater quality, audit
and footwear companies with information http://etad.com/en protocol, and research to advance their mission.
related to regulations and laws that restrict
or ban certain chemicals and substances in An industry group with the operating goal of
finished home textile, apparel, and footwear being active wherever the safety of colorants ZDHC Manufacturing Restricted
products around the world. is discussed, to provide scientific know-how Substances List
so that any risk for customers as well as end https://www.roadmaptozero.com/programme/
users is minimized. manufacturing-restricted-substances-list-mrsl-
AFIRM Member Brands
conformity-guidance/
www.afirm-group.com/members/
OEKO-TEX® The ZDHC Programme created this MRSL
https://www.oeko-tex.com/en/business/ to target restricted chemicals during the
AFIRM Restricted Substances List
business_home/business_home.xhtml manufacturing stage. Instead of restricting
www.afirm-group.com/afirm-rsl/
chemicals at the finished product stage, the
OEKO-TEX® is an association of textile
This RSL was created by the Apparel & MRSL manages chemical input within man-
research and testing institutes that have
Footwear International RSL Management ufacturing facilities prevent any intentional use.
developed assessment standards in
Group (AFIRM). This RSL lists substances
manufacturing to certify entities in the areas
currently subject to legislated limits around
of chemicals management, environmental
the world, as well as limits based on best
performance, environmental management,
practices in the apparel and footwear
social responsibility, quality management,
industries.
and occupational health & safety.
bluesign®
https://www.bluesign.com/index.html
The bluesign® system aims to link all stages

of the manufacturing supply chain and remove
harmful chemicals through the use of input
technology.
36
Meeting Customer Needs for as accredited to test products to one or more Information on Registered Substances
of these children’s product safety rules, as https://echa.europa.eu/information-on-
Chemical Data: A Guidance Document identified in the accreditation scope for each chemicals/registered-substances
for Suppliers laboratory.
Here you can search in the ECHA database for
Green Chemistry and Commerce information on registered substances.
Council (GC3) Global Regulation & Chemical The information in the database was provided
https://greenchemistryandcommerce.org/
resources/gc3-publications
Resources by companies in their registration dossiers.
You can find a variety of information on the
European Chemicals Agency substances which companies manufacture
Business-to-business communication of
http://echa.europa.eu or import: their hazardous properties, their
chemical data, such as chemical identity
and health and safety impacts, along supply classification and labeling and how to use the
The European Chemicals Agency (ECHA) is an substances safely.
chains is critically important to product agency of the European Union that manages
manufacturers’ efforts to make informed the technical, scientific and administrative
decisions on the health and environmental aspects of the Registration, Evaluation, Consumer Product Safety
impacts of the products that they put on Authorisation and Restriction of Chemicals Improvement Act
the market. (REACH) system. www.cpsc.gov/en/Regulations-Laws--
Standards/Statutes/The-Consumer-Product-
Forward-looking companies working to bring Information about the following can be found Safety-Improvement-Act/
safer products to market need the active on ECHA website:
engagement of suppliers to provide relevant
chemical information. This document provides REACH Legislation Information. REACH is The Consumer Product Safety Improvement
tools and examples in support of improved the Regulation for Registration, Evaluation, Act (CPSIA) of 2008 is a U.S. law imposing
supply chain communication between Authorisation and Restriction of Chemicals. testing and documentation requirements,
suppliers and their customers, and in the It entered into force on 01 June 2007 to and sets new acceptable levels of several
development of more sustainable products. streamline and improve the former legislative substances. It imposes requirements on
framework on chemicals of the European manufacturers of apparel, shoes, personal
Union (EU). care products, accessories and jewelry,
Laboratory Resources home furnishings, bedding, toys, electronics
Substances of Very High Concern and video games, books, school supplies,
(SVHC). Substances that are included in educational materials and science kits.
List of CPSC-accepted Testing the Candidate List have been identified
Laboratories as Substances of Very High Concern.
https://www.cpsc.gov/cgi-bin/labsearch/ Substances on the Candidate List
may subsequently become subject to
To provide an up-to-date resource to find a
authorisation by decision of the European
reputable testing lab, the CPSC-accepted list
Commission. Substances are added to
of testing labs is a good place to start. This
the Candidate List by ECHA. The inclusion
is a list of entities that have been accredited
of a substance in the List may have legal
to assess conformity with children’s product
obligations on companies.
safety rules as required by the CPSIA. The
laboratories in this list have been accepted
37
U.S. Environmental Protection Agency California State Safer Consumer California Proposition 65 (Prop 65)
www.epa.gov Products Act http://oehha.ca.gov/prop65.html
Formerly Green Chemistry Initiative
The U.S. Environmental Protection Agency California Department of Toxic Proposition 65 is a California law intended
(EPA) is an agency of the United States federal Substance Control to eliminate exposures to those chemicals
government charged with protecting human www.dtsc.ca.gov/SCP/index.cfm identified as harmful to the environment and
health and the environment, by writing and the citizens of the State of California.
enforcing regulations based on laws passed California state government is developing an
by Congress. This agency administers laws alternative analysis framework to stimulate Proposition 65 regulates substances officially
such as the Clean Air Act (CAA), Clean Water the rapid acceleration of replacing harmful listed by California as causing cancer or
Act (CWA), Comprehensive Environmental chemicals and ingredients with safer birth defects or other reproductive harm
Response, Compensation and Liability alternatives in products sold in California. in two ways. The first regulatory arm of
Act (CERCLA or Superfund), Resource Work performed under this initiative will Proposition 65 prohibits businesses from
Conservation and Recovery Act (RCRA), and become regulation under California law. knowingly discharging listed substances
Toxic Substances Control Act (TSCA). into drinking water sources or onto land
California Department of Toxic where the substances can pass into drinking
Substance Control (DTSC) has released of water sources. The second regulatory arm
EPA Integrated Risk Information System an outline of the Draft Regulations for Safer of Proposition 65 prohibits businesses from
www.epa.gov/iris/index.html Products as a second step in identifying knowingly exposing individuals to listed
chemicals of concern and fostering the design substances without providing a clear and
The Integrated Risk Information System (IRIS) of safer products sold in California. reasonable warning.
is a human health assessment program that
evaluates quantitative and qualitative risk The outline proposes guidelines for scientific
information on effects that may result from and systematic prioritization of chemicals Washington State Children’s Safe
exposure to environmental contaminants. and products of concern, certification of Products Act
IRIS was initially developed for EPA staff in alternatives assessment and development of Washington Department of Ecology
response to a growing demand for consistent DTSC’s regulatory response. With this outline, https://ecology.wa.gov/Waste-Toxics/
information on substances for use in risk DTSC will continue its collaboration with all Reducing-toxic-chemicals/Childrens-Safe-
assessments, decision-making, and regulatory stakeholders, governmental agencies, and the Products-Act
activities. public to transform the outline into the Green
Chemistry Regulations for Safer Products. The As of August 2012, the Washington State Child
The information in IRIS is intended for those outline builds from the conceptual framework Safe Product Act (CPSA) requires apparel
without extensive training in toxicology, but completed in March of 2010. The next step is companies to report concentrations of 66
with some knowledge of health sciences. creating draft regulations based on the outline substances down to the component level of
and framework. The draft regulations will be children’s apparel and footwear products.
released in the very near future.
38
Chemical & Risk • BPD (Biocidal Products Directive) active Global Portal to Information on Chemical
substances listed in Annex I or IA of Substances
Assessment Resources Directive 98/8/EC or listed in the so-called www.echemportal.org/echemportal/page.
list of non-inclusions, action?pageID=0
Agency for Toxic Substances and
• PBT (Persistent, Bioaccumulative, and The eChemPortal provides free public access
Disease Registry
Toxic) or vPvB (very Persistent and very to information on the properties of chemicals:
www.atsdr.cdc.gov
Bioaccumulative),
• Physical chemical properties
The Agency for Toxic Substances and • CLP/GHS (Classification, Labelling and
Disease Registry (ATSDR), based in Atlanta, Packaging of substances and mixtures), • Ecotoxicity
Georgia, U.S.A., is a federal public health CLP implements the Globally harmonised
agency of the U.S. Department of Health and System (GHS), Regulation (EC) No • Environmental fate and behavior
Human Services. ATSDR serves the public 1272/2008,
by using the best science, taking responsive • Toxicity
public health actions, and providing health • Export and Import of Dangerous Chemicals
eChemPortal allows simultaneous searching
information to prevent harmful exposures and listed in Annex I of Regulation (EC) No
of reports and datasets by chemical name
diseases related to toxic substances. 689/2008,
and number, and by chemical property. Direct
• HPVCs (High Production Volume Chemicals) links to collections of chemical hazard and risk
European Chemical Substances and LPVCs (Low Production Volume information prepared for government chemical
Information System Chemicals), including EU Producers/ review programmes at national, regional,
https://echa.europa.eu/information-on- Importers lists and international levels can be obtained.
chemicals Classification results according to national/
• IUCLID Chemical Data Sheets, IUCLID regional hazard classification schemes
The European Chemical Substances Export Files, OECD-IUCLID Export Files, or to the Globally Harmonized System of
Information System (ESIS) is a publicly EUSES Export Files, Classification and Labelling of Chemicals
available IT system from the European (GHS) are provided when available.
Commission Institute for Health and Consumer • Priority Lists, Risk Assessment process
Protection Joint Research Center. ESIS and tracking system in relation to Council The eChemPortal is an effort of the
provides information on chemicals, related to: Regulation (EEC) Organisation for Economic Co-operation and
Development (OECD) in collaboration with the
• EINECS (European Inventory of Existing European Commission (EC), the European
Commercial Chemical Substances) O.J. C Chemicals Agency (ECHA), the United States,
146A, 15.6.1990, Canada, Japan, the International Council of
Chemical Associations (ICCA), the Business
• ELINCS (European List of Notified Chemical and Industry Advisory Committee (BIAC),
Substances) in support of Directive 92/32/ the World Health Organization’s (WHO)
EEC, the 7th amendment to Directive International Program on Chemical Safety
67/548/EEC, (IPCS), the United Nations Environment
Programme (UNEP) and environmental non-
• NLP (No-Longer Polymers), governmental organizations.
39
Appendix J. Glossary of Terms

Article. An object that is given a special Chemical substance. A chemical element Manufacturing restricted substances list
shape, surface, or design during production, and its compounds with constant composition (MRSL). An MRSL establishes concentration
which determines its function to a greater and properties. It is defined by the CAS limits for substances in chemical formulations
degree than it does its chemical composition number. used within manufacturing facilities. MRSL
(fibers, textile fabrics, buttons, zippers, etc.). limits are designed to eliminate the possibility
of intentional use of restricted substances
Globally Harmonised System of by addressing process chemicals used to
Bioaccumulative. Substances that cannot Classification and Labelling of Chemicals produce materials, but that may not end up
be eliminated by living organisms and tend to (GHS). GHS is a technical approach in the finished product.
bioaccumulate, which means they become developed to define the specific hazards of
more concentrated throughout the food chain. each chemical, to create classification criteria
Concentrations of these substances can reach using available data on the chemicals and Material safety data sheet (MSDS). A form
levels that are harmful to human health or the their already defined hazards, and to organize containing data regarding the properties of a
environment. and facilitate the communication of hazard particular substance. The exact format of an
information on labels and SDSs MSDS can vary from source to source within
a country depending on how specific the
Carcinogenic. A carcinogenic substance is national requirement is. The MSDS has now
one where a relationship has been established Limit of detection (LOD). A value 1x to been replaced by a standardized SDS.
between exposure to the substance and 4x above the MDL, analyzed to verify the
human cancer. calculated MDL is within reason. This is
variable across labs. Method detection limit (MDL). A
mathematically derived limit based on
CAS. CAS registry numbers are unique several replicates of a sample at a specific
numerical identifiers for chemical elements, Limit of quantitation (LOQ). LOQ (also known concentration. Designed to avoid false
compounds, polymers, biological sequences, as PQL) is the limit at which the test method negatives, but prone to false positives
mixtures, and alloys. Chemical Abstracts is reproduceable and robust, with analyte (because data is inaccurate at this level).
Service (CAS), a division of the American recovery within a defined window. Samples This is variable across labs.
Chemical Society, assigns these identifiers to must be analyzed and meet recovery limits
every chemical that has been described in the (such as 70% to 130% of true value). This is
literature. The intention is to make database variable across labs. Preservative. A chemical substance
searches more convenient, as chemicals used to preserve organic materials from
often have many names. Almost all molecule decomposition or fermentation.
databases allow searching by CAS number. Limit value. The maximum amount of
chemical substances permitted in articles.
40
REACH. The European Union’s regulation handling or working with that substance in a Usage ban. For several chemical substances
concerning the Registration, Evaluation, safe manner, and includes information such or substance groups a usage ban may be
Authorization and Restriction of Chemicals as physical data, toxicity, health effects, first defined. For these substances or substance
aims to improve the protection of human aid, reactivity, storage, disposal, protective groups intentional use in manufacturing
health and the environment through the equipment, and spill handling procedures. of articles is prohibited. That means that
better and earlier identification of the intrinsic The SDS is made up of sixteen sections, and chemical products (e.g. colorants or textile
properties of chemical substances and each section includes specific information auxiliaries) used for manufacturing of
‘articles’. REACH regulation must be met for all using a standardized classification method. articles must not intentionally contain these
articles entering the EU. Additional information This standardized method has replaced the substances or substance groups. The aim
can be found at www.echa.europa.eu. “MSDS”. See Appendix I for examples and of a usage ban is to avoid release of harmful
explanation of an SDS substances to the environment and to avoid
occurrence in the manufactured article by
Reporting limit. The AFIRM RSL uses applying the precautionary principle.
reporting limits—arbitrary limits set by the Solvent. A substance that could dissolve
Laboratory Technical Advisory Committee— other substances, such as oils, or in which
based on the LOQ across laboratories. another substance is dissolved, forming a Volatile. A substance is considered volatile
Reporting limits are useful for AFIRM brands, solution. if it has a low boiling point at normal
enabling them to capture data below a atmospheric pressure. Volatile chemicals
regulated limit, but not collect data down (e.g. Formaldehyde) can cross-contaminate
to the detection limit and encounter false Substances of very high concern (SVHCs). products because they can more easily
positives or inaccurate data. SVHCs are identified in REACH, which calls vaporize and travel.
for the progressive substitution of the most
potentially dangerous chemicals (referred to as
Restricted substances list (RSL). Defines “SVHCs”) when suitable alternatives have been Zero Discharge of Hazardous Chemicals
those chemicals that are restricted or banned identified. (ZDHC) Programme. ZDHC Foundation
from finished products. oversees the ZDHC Programme. Their aim
is to advance towards zero discharge of
Technical data sheet (TDS). Documentation hazardous chemicals in the textile, leather,
Safety data sheet (SDS). An SDS is provided provided by chemical manufacturers and footwear value chain to improve the
by the chemical manufacturer containing containing a detailed technical description of a environment and peoples’ well-being. The
safety data relating to the properties of a chemical substance, along with specific areas programme includes an industry-aligned
particular substance. It is an important and scope of use. MRSL, Wastewater Guidelines, and a Gateway
component of product stewardship and for the distribution of chemical and wastewater
workplace safety, intended to provide workers quality data.
and emergency personnel with procedures for
41
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Apparel and Footwear International RSL Management Group

AFIRM Mission.......................................................................................... 3 Special Thanks

1. Introduction........................................................................................... 4 Stella Chern, Drew DuBois, Frederic Felipe, Avery Linderman,

4. Educating the Supply Chain................................................................. 9 Outside contributor: Cenira Cristine Verona

6. RSL Implementation............................................................................ 12 AFIRM Chemistry Toolkit task force for 2011:

Appendix F. Benefits of Water-based Polyurethane............................. 32

Appendix G. Detailed Chemical Guidance Document.......................... 33

Appendix H. Safety Data Sheets............................................................ 34

Appendix I. Online Resources................................................................ 36

Appendix J. Glossary of Terms.............................................................. 40

Policy Statement and Uses of This Chemistry Toolkit

For more information about AFIRM, visit www.afirm-group.com.

2. Restricted Substances Lists

Why RSLs Are Important for Suppliers

A brand RSL is typically based on The AFIRM RSL is available at http://afirm-

Manufacturing Restricted Substances Lists

3. Where Are the Risks?

Understanding Chemical Risks Figure 1. Understanding Chemical Risks

The AFIRM RSL includes a risk matrix that

CHANGE PROCESS CHEMICALS, ARE THERE RSL AND/OR MRSL ISSUES

1. FINALIZE CHEMICAL INPUTS

AFIRM Chemical Information Sheets

substances) in the AFIRM RSL. or reliance upon the contents of these

The sheets provide a brief background on

where the substances are used in the supply www.afirm-group.com/chemical-information-

chain, the reasons these substances are sheets

Sourcing Compliant Formulations from Your Chemical Suppliers

Table 1. AFIRM Chemical Information Sheets

Substance Language Substance Language

Acetophenone and 2-Phenyl-2-Propanol Heavy Metals, Total

Alkylphenol Ethoxylates (NPEO, OPEO) Heavy Metals, Extractable

Alkylphenols (NP, OP) Heavy Metals, Chromium VI

Azo-amines Heavy Metals, Nickel Release

Bisphenol-A Monomers, Styrene and Vinyl Chloride

Chlorinated Paraffins, SCCP (C10-C13) and MCCP (C14-C17) N-Nitrosamines

Chlorophenols (Tri-, Tetra-, and Pentachlorophenols) Organotin Compounds

Chlororganic Carriers Ortho-phenylphenol (OPP)

Dimethylformamide (DMFa) Ozone-depleting Substances

Dimethylfumarate (DMFu) Perfluorinated and Polyfluorinated Chemicals (PFCs)

Dyes: Acid, Basic, Direct, Other, Navy Blue Pesticides, Agricultural

Dyes: Disperse Phthalates

Flame Retardants Polycyclic Aromatic Hydrocarbons (PAHs)

Fluorinated Greenhouse Gases Volatile Organic Compounds (VOCs)

4. Educating the Supply Chain

Figure 2. Implementing a Robust RSL Policy Across the Supply Chain

Communicates RSL Communicates RSL

Provides Provide UPSTREAM

Provides approvals, Provides approvals,

Communicating with Upstream Vendors

SDSs may help reveal whether the materials

See Appendix H for an overview and examples

Ensure internal governance and • Advise vendors of material-specific risks

Appendix A. Figure 3. Implementing a Robust RSL Policy

Brand Strategy for 1

1 Adopt an RSL Policy 6

• Items that come in direct contact with the

• Putting systems in place to make sure the

• Increased monitoring of the vendor/supplier

Appendix B. Model RSL Testing Program for Brands

1 Aim 3 Scope 4 Introduction

• Some leathers have a PVC coating; they

• All products classified as toys (items Figure 6. Product Risk Assessment

• All continuity products (permanent

DO YOU FORESEE SPECIFIC ISSUES REGARDING THIS ADD SPECIFIC TESTS