Product Safety and Restricted Substances in Apparel | Subrata Das

Contents

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

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

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

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

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

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

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

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

Dr. Subrata Das