CANADIAN STANDARDS & TESTING REQUIREMENTS By REAAZ BUDDOO - - PowerPoint PPT Presentation

APPAREL & FOOTWEAR TRAINING CANADIAN STANDARDS & TESTING REQUIREMENTS

By REAAZ BUDDOO Intertek Canada – Consultancy Group

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The presentation is based on the best available information as of the date of this workshop. Legislation and related regulations will continue to evolve, therefore the information included in this presentation is subject to change. Intertek monitors legislation closely and will continue to provide recommendations and consultation based on the best available information.

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PURPOSE

Aim of this project is to contribute to the economic sustainability growth through expansion of Indonesian trade with Canada and the encouragement of Canadian investment in Indonesia through the Trade and Private Sector Assistance (TPSA). Among others, sectors targeted were apparel and footwear.

EXPLORE THE IMPORTANCE OF THE CANADIAN REGULATORY REQUIREMENTS OF APPAREL AND FOOTWEAR FOR IMPORTS INTO CANADA SCOPE

AGENDA

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Theoretical - Overview of Canada’s Consumer Product Safety Act (CCPSA) and testing requirements by Mr. Reaaz ( Intertek Canada Consultancy group) Hands-on analytical testing on both apparel and footwear by Mr. Arun (Intertek India) Hands-on training on physical test for apparel and footwear by Mr. Suresh (Intertek India)

Day - 1 Day - 4 Day – 2 & 3

Technical translation assistance – Intertek Indonesia

AGENDA

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WORKSHOP ITINENARY

Day 1

Monday May 7th 8h30 - 16h00 Federal and Provincial Regulatory requirements Coffee break @ 10h15 - 10h30 Lunch time @ 12h00 - 13h00 Coffee break @ 15h15 - 15h30

Day 2

Tuesday May 8th 8h30 - 17h00 Hands-on analytical testing Coffee break @ 10h00 - 10h15 Lunch time @ 12h00 - 13h00 Coffee break @ 15h00 - 15h15

Day 3

Wednesday May 9th 8h30 - 17h00 Hands-on analytical testing Coffee break @ 10h00 - 10h15 Lunch time @ 12h00 - 13h00 Coffee break @ 15h00 - 15h15 Thursday May 10th National Holiday - No training

Day 4

Friday May 11th 8h30 - 17h00 Hands-on training on physical test Coffee break @ 10h00 - 10h15 Lunch time @ 12h00 - 13h00 (+ Prayer time) Coffee break @ 15h00 - 15h15

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Source - http://m.veryicon.com/icons/flag/not-patriot/canada-flag.html

What do you know about Canada?

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Boundaries

Canada has chosen to divide its land into two different types of political divisions:

• PROVINCES
• TERRITORIES

Canada has 10 provinces (British Columbia, Alberta, Saskatchewan, Manitoba, Ontario, Quebec, Newfoundland and Labrador, Prince Edward Island, Nova Scotia, & New Brunswick) Canada has 3 territories (These are all located in the northern regions

• f Canada

USA is divided in States

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There are three levels of government in Canada - Federal, Provincial and Municipal - each with its own set of responsibilities and regulations

Source : http://discoveryportal.ontla.on.ca/en/teach-learn/youth/about-youth/canadas-three-levels-government

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Mis-perception

Commonly asked questions: Our product has been tested against USA requirements and comply. Why Canada needs additional testing? Some Canadian laws are mirrored to the USA requirements and some are just similar; not same. Ex: Same Phthalates test method are same globally, lab can just report the test result for Canada through document review Ex: Similar Flammability test applies to general textile however in USA this test specific to certain types of products.

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Federal Level

Health Canada is a Federal institution that administered the Canada Consumer Product Safety Act known as the CCPSA The new law applies to a wide variety of consumer products including children's products, household products and sporting goods, but excludes products like motor vehicles and their integral parts, food, drugs (including natural health products) and animals as these are regulated by other Canadian laws.

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Regulations under the CCPSA

• Administrative Monetary Penalties (Consumer Products)

Regulations (SOR/2013-101)

• Asbestos Products Regulations (SOR/2007-260)
• Candles Regulations (SOR/2011-18)
• Carbonated Beverage Glass Containers Regulations (SOR/80-

831)

• Carriages and Strollers Regulations (SOR/85-379)
• Children’s Jewelry Regulations (SOR/2011-19)
• Children’s Sleepwear Regulations (SOR/2011-15)
• Consumer Chemicals and Containers Regulations,2001

(SOR/2001-269)

• Consumer Products Containing Lead (Contact with Mouth)

Regulations (SOR/2010-273)

• Corded Window Covering Products Regulations (SOR/2009-

112)

• Cribs, Cradles and Bassinets Regulations (SOR/2010-261)
• Face Protectors for Ice Hockey and Box Lacrosse Players

Regulations (SOR/2011-20)

• Glass Doors and Enclosures Regulations (SOR/2009-110)
• Glazed Ceramics and Glassware Regulations (SOR/98-176)
• Hazardous Products (Carpet) Regulations (C.R.C., c. 923)
• Hazardous Products (Cellulose Insulation) Regulations

(SOR/79-732)

• Hazardous Products (Charcoal) Regulations (C.R.C., c. 924)
• Hazardous Products (Expansion Gates and Expandable

Enclosures) Regulations (SOR/90-39)

• Hazardous Products (Infant Feeding Bottle Nipples) Regulations

(SOR/84-271)

• Hazardous Products (Kettles) Regulations (C.R.C., c. 927)
• Hazardous Products (Matches) Regulations (C.R.C., c. 929)
• Hazardous Products (Mattresses) Regulations (SOR/80-810)
• Hazardous Products (Pacifiers) Regulations (C.R.C., c. 930)
• Hazardous Products (Tents) Regulations (SOR/90-245)
• Ice Hockey Helmet Regulations (SOR/2011-21)
• Lighters Regulations (SOR/2008-231)
• Phthalates Regulations (SOR/2010-298)
• Playpens Regulations (C.R.C., c. 932)
• Residential Detectors Regulations (SOR/2009-193)
• Restraint Systems and Booster Seats for Motor Vehicles

Regulations (SOR/2011-16)

• Science Education Sets Regulations (C.R.C., c. 934)
• Surface Coating Materials Regulations (SOR/2005-109)
• Textile Flammability Regulations (SOR/2011-22)
• Toys Regulations (SOR/2011-17)

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Suppliers may voluntarily take corrective action to bring product into compliance or voluntarily recall product from the market Health Canada may order corrective action (stopping manufacturing, importing, selling or transportation) or order a product recall

Recall & Corrective Action

Example: Children's Pajama Sets sold at Mega Children's Wear

RECALLS

Hazard identified: Health Canada's sampling and evaluation program has determined that these products do not meet the flammability requirements for children's sleepwear under Canadian law. Loose-fitting children's sleepwear can contact ignition sources such as stove elements, candles, and matches more readily than tight-fitting sleepwear, and once ignited will burn rapidly, potentially resulting in severe burns to large areas of the child's body. For this reason, cotton is not permitted in loose-fitting sleepwear.

Recent testing by Health Canada has shown that one-third of samples tested were non-compliant

• Children’s sleepwear: Tight-fitting children’s sleepwear did not meet the

dimensional requirements in the Guidelines Must be tested to more stringent loose-fitting requirements

• Marabou and other feathers: Found on Halloween costumes, boas,

women’s lingerie and Christmas trees did not meet the flammability requirements

RECALLS

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http://www.healthycanadians.gc.ca/recall-alert-rappel-avis/search- recherche/simple?s=&plain_text=&f_mc=4&js_en=&page=5&_ga=2.37991459.149920497.1525199902-924508044.1517238632

RECALLS & ALERTS

CCPSA – KEY PROVISIONS

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Reporting of Incidents Preparing and Maintaining Documents Information on Product Safety General Prohibition Packaging and Labelling 1 5 4 3 2

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Reporting of Incidents The Act requires industry to provide information to Health Canada and to the product's supplier (if applicable) concerning consumer product safety incidents or product defects that result, or could reasonably be expected to result, in death or harmful health effects. This "early warning" provision also applies to inadequate labelling

• r instructions that could lead to the same results, and to recall
• rders or other corrective measures initiated in other jurisdictions

for human health or safety reasons.

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Preparing and Maintaining Documents

So that unsafe products can be traced back to their source, the CCPSA requires those who manufacture, import, advertise, sell or test consumer products for commercial purposes to prepare and maintain certain

• documents. Normally, these records would already be part of regular

business practice. For example, the CCPSA requires that a retailer document the name and address of the product's supplier, and the location and the period during which they sold the product (but not the name of the individual to whom the product was sold). These requirements are more detailed at higher levels of trade.

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Information on Product Safety Health Canada can require manufacturers or importers to provide

• r obtain safety information - including studies or tests - that

indicate whether a consumer product meets the requirements of the CCPSA.

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Normal Use and Foreseeable Misuse

Does the event indicate an unreasonable hazard posed by the normal or foreseeable use or misuse of the product? Was the product being used as originally intended? Consider foreseeable but unintended use of the product What constitutes normal or foreseeable use of a consumer product will depend on the particular product and circumstances surrounding the event

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General Prohibition

• Manufacturer and importers are prohibited from

manufacturing, importing, advertising or selling; and

• Any person is prohibited from knowingly advertising or

selling.... A consumer product that:

• is a danger to human health or safety;
• is the subject of a recall order, or is the subject of a voluntary

recall in Canada because the product is a danger to human health or safety; or

• is the subject of a measure that was ordered to be carried
• ut, but wasn’t

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Prohibition examples

Flame Retardants:

• TRIS (2-chloroethyl) phosphate (TCEP)
• Tris (2, 3 dibromopropyl) phosphate

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LABELLING REQUIREMENTS

The Federal Consumer Packaging and Labelling Act (CPLA) is the main statute governing the packaging and labelling of pre-packaged consumer products in Canada. The Canada Consumer Product Safety Act (CCPSA) sets out requirements for a wide range of consumer products (including children’s toys) that pose

• r reasonably pose a danger to human health and safety. The federal

Hazardous Products Act (HPA) governs labelling of industrial products that may be dangerous to users in the workplace. Provincial legislation (including Quebec’s Charter of the French Language) also stipulates additional packaging and labelling requirements for certain products.

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FEDERAL LABELLING REQUIREMENTS

Pre-packaged consumer products

The law prohibits packaging that directs the consumer to a false or misleading conclusion about the product. It also stipulates the following minimum requirements:

• 1. product identity: A pre-packaged product must be identified by its common or generic name or in terms of its function, in

both English and French, on the “principal display panel” – i.e., that part of the label that is principally displayed or visible to consumers under normal or customary conditions of sale or use.

• 2. net quantity: Every pre-packaged product must contain a declaration of the net quantity of the product, in both English and

French, on the principal display panel of the label stated in terms of numerical count or metric units, as applicable. Net quantity may also be stated in non-metric units of measurement provided that both units are grouped together. we’ve got you covered in Canada

• 3. dealer’s name and place of business: The packaging is required to state the name and principal place of business of the

dealer in either English or French and this need not appear on the principal display panel of the label. Pre-packaged products that have been imported require additional labelling disclosure. The label of such products must bear one of three alternative declarations:

• a. name and address of the Canadian dealer of the product, preceded by the phrase “imported by” or “imported for”;
• b. name and address of the Canadian dealer together with a statement, immediately

adjacent, of the country of origin of the product; or

• c. name and address of the dealer outside Canada who either originally manufactured the product or exported it into Canada

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TEXTILE LABELLING REQUIREMENTS

A number or regulations govern different product attributes and the manner in which apparel products are sold in the marketplace. The major labeling issues are:

• Fiber Content labelling
• Care Labelling
• Dealer Identity and
• Country of Origin
• Other regulations

Most labelling issues are handled by the Competition Bureau, and are part of the Textile Labelling Act and related regulations. The exception to this is Country of Origin which is handled primarily by the Canadian Border Services Agency in conjunction with the Competition Bureau. Provincial Regulations Upholstered and Stuffed Articles must carry appropriate labeling in order to be sold in Quebec, Ontario and Manitoba. Products of this sort that are sold in Canada are registered according to the following provincial regulations:

• Ontario
• Quebec
• Manitoba

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TEXTILE LABELLING REQUIREMENTS - Frequent Asked Questions (FAQs)

http://www.apparel.ca/labelling_faq.html

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No specific certification requirements for laboratories Testing should be to the Canadian requirements for the consumer product as described in regulations, policies and guidelines Testing should be conducted on a representative sample of the product available in the Canadian market Testing should be carried out at laboratories that have demonstrated competency in that testing area, preferably through accreditation to ISO/IEC 17025

LAB CERTIFICATION

CANADIAN APPAREL REGULATIONS

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Flammability Hazards Chemical Hazards Other Considerations

1 3 2

Textile Requirements in Canada

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Labelling

Children’s sleepwear (in sizes up to and including 14X)

Children’s Sleepwear Regulations

Cribs, cradles and bassinets

Cribs, Cradles and Bassinets Regulations

Playpens

Playpens Regulations

Expansion gates and expandable closures for children

Expansion Gates and Expandable Enclosures Regulations

Dolls, plush toys and soft toys

Toys Regulations

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FLAMMABILITY HAZARDS

Tents

Tents Regulations

Carpets and Rugs

Textile Floor Coverings Regulations

Mattresses

Mattresses Regulations

Bedding + General textile products

Textile Flammability Regulations

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FLAMMABILITY HAZARDS conti……

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Textile Flammability Regulations

Apply to consumer products composed of textile fibers, such as:

• Fabric (yard goods)
• Drapery
• Clothing (other than children’s sleepwear)
• Bedding

“Textile fiber” is defined as any natural or manufactured matter that is capable of being made into a yarn or fabric and, without limiting the generality of the foregoing, includes human hair, kapok, feathers and down and animal hair or fur that has been removed from an animal skin. (Textile Labelling Act)

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TEST METHOD

For General Textile Products, Bedding, Tight-fitting Children’s Sleepwear: Standard: Canadian General Standards Board standard CAN/CGSB 4.2 NO. 27.5 entitled Textile Test Methods -Flame Resistance -45˚ Angle Test -One Second Flame Impingement, as amended from time to time

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Equipment

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Required Flame Spread Time

For General Textile Products, Bedding, Tight-fitting Children’s Sleepwear: General textile products >3.5 seconds if the product does not have a raised fiber surface >4 seconds if the product has a raised fiber surface and exhibits ignition or fusion of its base fibers (i.e. base burn) Bedding >7 seconds if the product does not have a raised fiber surface OR if the product has a raised fiber surface and exhibits ignition or fusion of its base fibers (i.e. base burn) Tight-fitting children’s sleepwear >7 seconds for products with or without a raised fiber surface AND irrespective

• f base burn

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Children’s Sleepwear Regulations

• Children’s Sleepwear: Flammability Requirement Guidelines explain the

requirements for sleepwear subject to the Children’s Sleepwear Regulations

• Any garment that is likely to be used by children for sleeping or activities

related to going to bed is considered to be children’s sleepwear, even if it is not labeled as sleepwear.

• Tight-fitting children’s sleepwear: any children’s sleepwear in sizes up to and

including 14X other than loose-fitting children’s sleepwear including sleepwear designed for infants weighing up to 7 kg, sleepwear designed for hospital use, polo pajama's and sleepers

• Loose-fitting children’s sleepwear: children’s nightgowns, nightshirts, dressing

gowns, bathrobes, housecoats, robes, pajama's and baby-doll pajama's in sizes up to and including 14X, excluding tight-fitting children’s sleepwear

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Tight-fitting Children’s Sleepwear

• Tight-fitting children’s sleepwear that is made of the following fabric is likely

to be compliant: cotton, cotton/polyester blends, polyester, acrylic, nylon, silk, rayon, acetate

• Tight-fitting children’s sleepwear that does not meet dimensional or design

criteria set out in the Children’s Sleepwear Flammability Requirement Guidelines must comply with the flammability requirements for loose-fitting children’s sleepwear.

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TEST METHOD

Test Standard: Flame Resistance Test (Vertical Char Test) in Schedule I of the Children’s Sleepwear Regulations

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TEST METHOD

Children's sleepwear that is loose fitting can contact ignition sources such as stove elements, candles, and matches more easily than tight-fitting sleepwear. Once ignited, the loose-fitting sleepwear can burn rapidly and cause severe burns to large areas of the child's body, resulting in shock and sometimes death. Required char length:

• Average char length for five specimens must not exceed 178 mm
• Not more than one specimen can have a char length equal to the full length of the specimen

(254 mm)

• Fabrics that are likely to be compliant: 100% polyester, 100% nylon, polyester/nylon blends.

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Cotton Nightgown

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Cotton Polo Pajama's

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Feather Test

The specimen must be 6 inches long, but it does not have to be a complete 2 inches wide, sometimes the feathers may be sandwiched in the holder and/or taped to secure the specimen in place As an alternative to regular frames, specimen frame, with fine supporting cross wires maybe used to support the specimen in place. The modified specimen holder consists of the holder described in subsection 1(4) of Toys regulation with the addition of 38-gauge (B & S) spring steel wire securely attached across its width at 1.27 cm (1/2 inch) intervals. This arrangement allows the calibrated flame to impinge at a point midway between the two lowest wires.

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Other Products

Mattresses

• CAN/CGSB-4.2 No.27.7-2013 (Cigarette test)Melting and charring of fabric + continuing combustion

Tents

• CPAI-84 (1995)Flammability requirements for flooring materials + wall and top materials

Exemptions do not apply

• Labelling

Carpets and Rugs

• CAN/CGSB-4.2 No. 27.6-2015 (methenamine burning tablet test)
• CAN/CGSB-4.2 No. 30.2-M90 (removal of FR treatments if applicable)
• CAN/CGSB-4.155-M88 (sampling plan; pass/fail criteria)

Dolls, Plush Toys, Soft Toys

• Section 32 and Schedules 5-7 of Toys Regulations

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Laundering procedure

Laundering

• CAN/CGSB 4.2 NO.58-2004
• 58°C - 62°C
• Normal Cycle (12 minutes)
• Tumble Dry

Dry cleaning

• CAN/CGSB 4.2 NO.30.3-94
• Commercial dry cleaning

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REPORT

Report the following information:

• Whether the fabric has a raised-fiber surface or a plain surface.
• The surface of the specimen tested.
• The direction of more rapid burning.
• The results obtained for each specimen tested
• The flame spread time for the sample, i.e. the average of the results to the nearest 0.1 s for

specimens that burned to the stop thread.

• For specimens having a raised-fiber surface (par. 6.11), report the following:
• Whether the base ignited or fused to the point of obvious damage (scorching or charring of the

underside) at locations other than the point of flame impingement.

• If the specimen ignited and the stop thread was severed but there was no fusing or charring of the

base fabric.

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Industry Guide to Flammability of Textile Products in Canada

https://www.canada.ca/en/health-canada/services/consumer-product-safety/reports- publications/industry-professionals/industry-guide-flammability-textile.html

CHEMICAL HAZARDS

CHEMICAL HAZARDS

Requirements to address chemical hazards for certain textile products:

• Consumer Products Containing Lead (Contact with Mouth)

Regulations

• Phthalates Regulations
• Children’s Sleepwear Regulations
• Expansion Gates and Expandable Enclosures Regulations
• Playpens Regulations
• Toys Regulations
• Surface Coating Materials Regulations

CHEMICAL HAZARDS

• Lead (90 mg/kg total limit):
• Applied paint on children’s textile products (fabric, zippers, snaps, etc.)
• Any products in contact with the mouth during normal use
• Phthalates (1,000 mg/kg limit for DEHP, DBP, BBP, DINP, DIDP or DNOP):
• Vinyl in child care articles (for children <4 years of age)
• Vinyl in toys (for children <14 years of age)
• Total mercury in surface coating materials must not be more than 10 mg/kg

FLAME RETARDANTS (FR)

• Children’s Sleepwear
• FR is not necessary to meet the flammability requirements compliance, this

can be achieved through proper fabric choice and design in accordance with the Children’s Sleepwear: Flammability Requirement Guidelines

• Any FR used must not be toxic
• Sleepwear treated with FR must have a permanent label that clearly and

legibly displays the presence of FR and care instructions

• All Apparel

TRIS (Tris (2,3 dibromopropyl) phosphate) is prohibited in apparel (item 10 of Schedule 2 to the CCPSA)

STRANGULATION AND DRAGGING HAZARDS

Drawstrings on children’s upper outerwear

Children’s upper outerwear in sizes Newborn to 12 must not have drawstrings in the hood and neck area.

In accordance with ASTM F1816-97, drawstrings at the waist and bottom of children’s upper outerwear in sizes 2T to 16 must:

• not exceed 75 mm in length outside the drawstring channel when the garment

is expanded to its fullest width;

• have no toggles, knots, or other attachments at the free ends; and
• be bartacked(i.e., stitched through the drawstring and channel, usually at the

back center of the channel), if the drawstring is one continuous string.

STRANGULATION AND DRAGGING HAZARDS - RECENT RECALL

Children's upper outerwear with drawstring in the hood and neck area Product description This recall involves children's outerwear with drawstring in the hood and neck area. Hazard identified Health Canada has determined that drawstrings on children's upper outerwear can become caught on playground equipment, fences, or other objects and result in strangulation, or in the case of a vehicle, the child being dragged. As of April 25, 2018, the company has received no reports of incidents or injuries in Canada.

OTHER SAFETY CONSIDERATIONS

Complaints related to defects in textile products:

• detached parts (snaps, buttons, zippers, zipper pulls etc.) in

children’s products →choking hazard

• sharp points from broken parts →laceration hazard
• untrimmed and unraveled threads →suffocation hazard
• embedded broken needles and cutting blades →laceration

hazard

SUFFOCATION HAZARDS - RECENT RECALL

Product description This recall involves the Joe Fresh brand striped quilted baby jackets with the style code BBF5OT4316 located on an inner tag. Hazard identified The affected jackets can lose buttons when they are pulled by young children, posing a choking hazard. Health Canada has not received any reports of consumer incidents or injuries related to the use of the jacket in Canada.

SUFFOCATION HAZARDS - RECENT RECALL

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Mechanical Hazards

• Simulates reasonable foreseeable use of a toy by a child
• Drop test, push/pull test

Suffocation Hazards

• Flexible film bags 14 inches or larger in opening must bear the suffocation warning in both official languages
• Film must be at least 0.75 mil thick
• Toys large enough for a child to enter or be placed inside and can be closed by a lid or door must have

ventilation holes or openings of sufficient size on two or more sides PLASTIC BAGS CAN BE DANGEROUS. TO AVOID DANGER OF SUFFOCATION, KEEP THIS BAG AWAY FROM BABIES AND CHILDREN (ENGLISH) LES SACS DE PLASTIQUE PEUVENT ÊTRE DANGEREUX. POUR ÉVITER LE DANGER DE SUFFOCATION, NE LAISSEZ PAS CE SAC À LA PORTÉE DES BÉBÉS NI DES ENFANTS (FRENCH)

Toys Regulations- May apply to both apparel and footwear

The Regulations require that any product that is or is likely to be used by a child under three years of age must not have a small separable component or have a small component that can detach from the product with reasonably foreseeable use (Section 7 of the Toys Regulations) If a separable or detachable component can be totally enclosed in the small parts cylinder, as illustrated, using a force of 4.45 newton's (1 pound-force) or less, then the toy does not meet the requirement. SMALL PARTS

Regulation: Toys containing an embedded wire frame or structure must have the wire ends covered or turned in, such that no sharp points can become exposed with reasonably foreseeable

• use. (Section 9 of the Toys Regulations)

A wire frame or structure that is embedded in a toy must have its wire ends covered, turned in or turned back so that no sharp ends become exposed with reasonably foreseeable use of the toy. Test Method to check Sharp Points: M00.3 In Picture: A typical Sharp Point Tester

SHARP POINTS

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Product that is intended for use by a child (less than 14 years) in learning or play. Learning: Some formal or intended knowledge

• r skill should be gained or acquired by

children. Exemption: Functional Sharp Points like Needle

SHARP POINTS CONT…

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• 1. Identify and locate projections, corners and any

surface deformations on the product that are exposed and may present a hazardous sharp point.

• 2. Adjust the sharp point tester or other suitable test

device in accordance with the manufacturer's

• perating instructions.
• 3. Insert the test point of the product into the slot
• pening of the sharp point tester and apply a force

to the test point not exceeding 4.45 N (4.40 N ± 0.05 N). Care must be taken not to damage or deform the test point during application of the force.

• 4. Observe whether or not the indicator lamp lights

up.

SHARP POINT TEST METHOD

Regulation: Toys containing metal parts must be constructed so that there are no exposed sharp metal edges. (Section 8 of the Toys Regulations) Plastic toys and plastic parts of toys must not break with reasonably foreseeable use to expose sharp edges. (Section 10 of the Toys Regulations) A toy’s exposed metal edges must be folded back or sprayed with or dipped in paint or otherwise treated so that all sharpness and burrs are eliminated. A part of a toy that is made of plastic and that could, when broken, have exposed sharp edges must meet at least one of the following requirements: (a) it must be sufficiently thick to resist breakage with reasonably foreseeable use of the toy; or (b) it must be made of inherently tough materials, if the part is necessarily thin because of the toy’s function In Picture: A typical Sharp Edge Tester

SHARP EDGES

RSL TESTING- AN OVERVIEW

RESTRICTED SUBSTANCE TESTING

What is RSL? Why? How?

WHAT IS RSL ? RELEVANCE TO EUROPEAN REACH ANNEX. XVII

RSL RSL = Restricted Substance List which contains hazardous chemicals

RSL-WHY RESTRICTED?

Hazards: ▪ Environmental – industrial discharge ▪ Ecological safety ▪ Human health Restrictions by: ▪ Regulations ▪ Industry practices / standards ▪ Retailers/ Brand requirements

CHEMICALS INSIDE THE PRODUCTS

Fibre Oil Size Dyes Auxiliaries Print paste Pigment Plastic Metal Synthetic fibre Natural fibre Detergents Bleach Button Zipper Sequin Accessories Wet processing Spinning Knitting Weaving Washing Garment Red marked chemicals are source of restricted substances

WHAT IS RSL?

1.

• I am the next level (16pt)
• I am the next level (14pt)
• I am the next level (12pt)
• I am the next level (12pt)

WHY RESTRICTED?

Carcinogens or possible carcinogens e.g. Azo dyes( banned aromatic amines), Chromium VI, PCP, Nonylphenol… Allergens or may cause allergy e.g. Nickel, allergenic disperse dyes… Irritants e.g. Formaldehyde, Organic Solvents, Dimethylfumarate… Toxic to reproductive organs e.g. Organotins, Phthalates… Chronic illness e.g. Cadmium, Lead

HAZARDOUS SUBSTANCES REGULATIONS-GLOBAL OVERVIEW

Canada

Canada Consumer Product Safety Act(CCPSA)

EU/UK

REACH Biocidal Product Other EC Directives

Korea

KC Mark

Japan

Japan law 112 Consumer Product Safety Improvement Act(CPSIA) CA Prop 65 Washington CSPA TSCA Other state laws…

China

GB 18401

Vietnam

Circular No. 32/2009/TT-BCT

Taiwan

CNS 15290 CNS 15503

Indonesia

SNI 7617:2013

AZO DYES

What are they? Azo colorants are a class of synthetic dyes and pigments. Source: Azo dyes can be found in substrates such as textile fibres, leather, plastics, paper, mineral oils, foodstuffs and cosmetics. Concerns:

• Azo dyes may undergo reductive breakdown to carcinogenic* aromatic amines
• Carcinogenic aromatic amines are health-endangering materials with carcinogenic or mutagenic** properties

Legal Requirements: Annex XVII of EU REACH Regulation. Azo dyes have been restricted in the EU, China, Turkey and India since 2002. Limit : 30ppm (ppm = parts per million) The legal limit in China is 20 mg/kg. Test Methods : ➢ BS EN ISO 17234-1:2015 and ➢ BS EN ISO 17234-2:2011 (Leather) or equivalent ➢ BS EN 14362-1:2012 and ➢ BS EN 14362-3:2012 (Natural & Synthetic Textiles) Techniques: GC-MS/ HPLC-DAD

APEO’S

Source : The most important APEOs or alkyl phenol ethoxylates for the textile industry are NPEOs (Nonylphenol ethoxylates) and OPEOs (Octylphenol ethoxylates) due to their detergent properties. APEOs are usually present in detergents, cleaning agents , softener's, emulsifier as well as other chemicals used for textile or leather production. Test Methods : EN ISO 18218-1 : 2015 (leather) EN ISO 18254-1 : 2016 (textile) Technique: Solvent Extraction/ Analysis by LC-MS/MS Regulation: REACH, OEKO TEX 100, Others Limit Value : 1000 ppm(REACH) and 100 ppm buyer specific Problems : Nonylphenols are non-biodegradable, so they cause severe environmental problems when they are released into the environment as discharges or emissions. They are also endocrine disruptors (have adverse effects on hormones), and have had devastating effects on fish populations.

CHROMIUM VI

What is it? Chromium VI (Cr VI) is generated by oxidation of the unfixed Chromium III tanning agent used in leather tanning and chrome plating. Source: Chromium forms many colourful compounds used as pigments, and other compounds which may be used in dye fixatives. Chromium VI residues can occur in chrome tanned leather if the process is incorrectly controlled. Concerns:

• Chromium VI and Hexavalent Chromium compounds are known carcinogens
• Inhalation can cause ulcers and cancer of the nasal passages
• Skin contact can trigger dermatitis and ulcers
• Ingestion can cause kidney and liver damage
• Chromium VI can also be corrosive to skin and can cause allergic reactions

Legal Requirements: Annex XVII of EU REACH Regulation. Chromium VI has been restricted since 2014 and it was banned in 2015. Test Methods :

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BS EN ISO 17075 Technique: UV-Vis Spectrophotometer Limit Value : 3 ppm

FORMALDEHYDE

What is it? A gas that is formed at room temperature and occurs naturally in the environment. Source: Formaldehyde is found in treatments used in textile production mainly as anti-creasing and anti-shrinking agent. Concerns:

• Causes respiratory difficulty, eczema and sensitisation, skin allergy and mucous membrane irritations
• Carcinogenic: Linked to nasal lung cancer, brain cancer and leukaemia

Legal Requirements: Classified as carcinogenic under REACH in the EU and referenced in the Environmental Protection Act: 1990. Also restricted in other countries, such as Finland, Norway, Netherlands, Germany, and Denmark. Test Methods :

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EN ISO 17226-1:2008 (Leather)

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EN ISO 14184-1:2011 (Textile) Limits: Textile (Apparel, Footwear and Accessories):

• 16 mg/kg for under 36 months
• 75 mg/kg for items in direct skin contact
• 300 mg/kg for items not in skin contact

Textile (Home):

• 100 mg/kg in direct skin contact
• 150 mg/kg for items not in skin contact

Wood: 150 mg/kg

PH

What is it? pH measures the acidity or alkalinity of a substance. pH 1 is strongly acidic, pH 14 is strongly alkaline and pH 7 is neutral. Human skin is approximately pH 5.5 and extremes of pH can cause skin irritation or even irreparable damage. Source: Every substance on Earth has a pH value. Textile and leather production can result in extreme pH values if the products are not subsequently neutralised. It is important that fabrics are as close to neutral after the various bleaching, dyeing and finishing processes Concerns: Fabrics with extreme pH values can:

• Easily damage the skin
• Cause allergic reactions

Legal Requirements: There is no EU regulation for pH value; however, it has been regulated in Saudi Arabia, Egypt, Korea and China since 2010. Requirement: The pH value of applicable materials that are in direct contact with skin must be between 4.0 and 7.5.

NICKEL RELEASE

What is it? A metal commonly used in alloys, as a hardener and a colouring agent. Source: Nickel is used in the manufacturing of stainless steel, in nickel-plating and anti-corrosion plating for metals. Nickel can also be found in metal accessories, such as buttons, zips and rivets. Concerns:

• Nickel can trigger dermatitis, if in prolonged contact with skin*
• Prolonged nickel-exposure also has a detrimental effect on the central nervous system

Legal Requirements: Annex XVII of EU REACH Regulation. Nickel has been restricted since 2006. Test Methods :

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EN 1811 (Release of nickel of products prolong contact with skin)

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EN 12471 (Screening test for Nickel release (Qualitative).

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EN 12472 (Wear and corrosion test (preparatory test before performing nickel release test as per EN 1811) Limit Value : 0.5 µg/cm2/week (non body piercing) 0.2 µg/cm2/week (body piercing) *Prolonged contact with skin: 10 minutes on three or more occasions within two weeks, or 30 minutes on one or more occasions within one week.

PHTHALATES

What is it? Phthalates are chemical substances with plastifying properties added mainly to plastics and PVC to make them flexible They are substances which are added to soften plastic material (plasticizer) Mainly used as plasticisers to increase softness, flexibility & longevity by making the plastic more durable. Source: Phthalates can be found in softened plastics, especially PVC, plastisol prints, surface coatings Concerns:

• Risk to human health and environment
• Bio-accumulative*
• Endocrine disruptor**
• Carcinogenic

Legal Requirements: Annex XVII of EU REACH Regulation. Phthalates have been restricted since 2005. Test Methods :

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BS EN 14372:2011 (for polymers)

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ISO 14389:2014 (for textiles) Limit Value : 1000 ppm Within the EU, six phthalates are banned in toys and childcare articles that can be placed in the mouth, such as children's dinnerware sets.

LEAD

What is it? Lead is a heavy bluish –grey metal, naturally occurring in earth crust. Source:

• PVC, leather components of shoes for stabilization as heat and/or light stabilizers
• Paints, dyes, and glazes for a bright and vibrant colour

Concerns:

• A cumulative toxicant that affects multiple body systems
• Harmful to young children (profound and permanent adverse health effects, affecting the development of the brain and nervous

system)

• Harmful to adults (high blood pressure and kidney damage)
• Harmful to pregnant women (miscarriage, stillbirth, and low birth weight)

Legal Requirements: Annex XVII of EU REACH Regulation. Lead has been restricted since 2012. Test Methods :

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CPSC Method

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ISO 17072-2:2011 Limit Value : 100 ppm (substrate ), 90 ppm (for surface coating) Lead restrictions in the USA vary from those of the EU as follows:

• Children’s articles: Other substrates – 100 ppm
• Homewares: PVC – 200 ppm; Leather – 300 ppm; Leather exterior surface coating – 90 ppm;

CADMIUM

What is it? Cadmium is a naturally occurring toxic metal. Source: Cadmium compounds are commonly used as pigmentation (usually yellow and orange) in the plastics industry. They are also used as stabilisers in PU and PVC coatings. Cadmium can be found in surface coatings, buttons, buckles, jewellery and other plastic or metal garment and accessory components, as well as PU and PVC coated fabrics, coated leather, handbags and purses. Concerns:

• Cadmium is toxic to health by inhalation or ingestion: It can cause lung, liver and kidney damage.
• Cadmium accumulates in plants due to effluent, waste water or through the soil from products in landfill disposal.

Legal Requirements: Annex XVII of EU REACH Regulation. Cadmium has been restricted in metal articles since 2006. In 2011, that restriction was expanded to plastic items. Test Methods :

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EN 1122

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Microwave Digestion followed by ICP Limit Value : 100 ppm

EXTRACTABLE HEAVY METALS

What are they? Metallic elements of higher atomic mass that are toxic at low concentrations. Source: Heavy metals can be found in clothing, footwear, accessories and toys, including paints and surface coatings. Concerns: Some heavy metals are essential to bodily functions, but higher levels can alter metabolic processes and become toxic.

• Short term effects can range from skin irritation to vomiting
• High level exposure can cause anything from liver damage to renal failure

Legal Requirements: Extractable heavy metals have been restricted in the Toy Safety Directive since 2009. Although there is no EU regulation for clothing, footwear or accessories, extractable heavy metals have been restricted in countries, such as Indonesia and China since 2010. Test Method: ISO,DIN,ASTM,EN-71,CPSC,EPA,BS&IEC using UV-VIS, AAS, ICP-OES,XRF &ICP-MS

ALLERGENIC DISPERSE DYES

What are they Disperse dyes are generally water-insoluble colorants that are mainly use for coloring polyester, nylon and cellulose acetate textile fibers. Test Methods :

▪ DIN 54231:2005-11 ▪ BS EN ISO 16373-2:2014 (specific to textiles) ▪ Technique: LC-MS/MS

Limit Value :

▪ None-detected (detection limit 15ppm)

Concerns : Some disperse dyes have an allergenous (sensitising) potential to human skin and can be considered as a possible threat to health especially if the dyes exhibit poor perspiration fastness.

CARCINOGENIC DYES

Source : A small group of dyes have been identified as Carcinogenic dyes. These are generally present in textile & leather material . Test Methods : DIN 54231 Technique: HPLC-DAD/MS Regulation: REACH, OEKO TEX 100, others Limit Value : Not to be Used Problems :

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Carcinogens (cancer)

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Skin Disease

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Skin Allergy

DIMETHYL FUMARATE (DMF)

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Dimethyl fumarate is a substance used as a fungicide in leather products to prevent mould forming that may deteriorate leather, furniture, footwear during storage or transport in a humid climate .

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DMFu contain in little pouches are fixed inside furniture , footwear boxes for mould resistance.

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Strong skin sensitive .

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Biocide Directive 98/8/EC already banned the production of DMFu in EU. , EU Directive 2009 /251/EC , Reach annex XVII

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Limit : 0.1 mg/kg , Technique - GCMS

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Method : CEN ISO/TS 16186:2012 Solvent Extraction and GC-MS / LC-MS analysis

FLAME RETARDANTS

Main Use Flame retardants are chemicals used either to prevent something from catching fire or if a product is burning, to reduce the rate at which flames can spread. Concern Organophosphates are toxic & persistent in the environment

There are number of flame retardants that are restricted in use:

• TRIS,
• TEPA,
• PBB,
• Penta BDE
• Octa BDE

Limit: Prohibited Or 0.1%

Test Method: Solvent extraction followed by GC-MS/LC-MS

PFOA/PFOS

➢ PFOA- Perflourooctanoic acids ➢ PFOS- Perflourooctane Sulphonates ➢ Used as Stain, water & oil repellent agent ➢ Sources : Certain fluorocarbons used In textiles and apparel as a thick coating specially in rain coats, etc. ➢ Carcinogenic, Bio-accumulative, Limit: NMT 1microgram per cubic meter in textile and coated materials Technique: LC-MS/MS

CHLORINATED PHENOLS

Source : Group of chemicals Pentachlorophenol (PCP), Tetrachlorophenol (TeCP), Trichlorophenol (TCP) can be found in fungicides, insecticide, disinfectants and anti-fouling treatments in textile, leather & wood products. Test Methods :

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BS EN ISO 17070:2015 Limit Value : Textile 0.05 ppm / Leather 5 ppm Problems :

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Highly toxic & Carcinogenic when inhaled ingested or absorbed through the skin.

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Long term exposure effects could be reproductive , liver & kidney damage. Legislation - REACH Regulation (EC) No 1907/2006 Annex XVII，Former known as 1999/51/EC

SHORT CHAIN CHLORINATED PARAFFINS

What are they Substances made by chlorinating liquid paraffin or paraffin wax. SCCP widely used as flame retardants, plasticizer in rubber, paints,

• adhesives. Also used as fatting and softening agents in the leather industry.

Source : Fat liquoring in leathers. Flame retardant furnishings Test Methods : BS EN ISO 18219:2015 Limit Value : 1000 ppm Problems :

➢ SCCP may affect the kidney liver & thyroid gland and may cause cancer. ➢ Very toxic to aquatic organisms

POLYCYCLIC AROMATIC HYDROCARBONS

What are they PAH’s are a group of different chemicals that are formed during the incomplete burning of coal, oil and gas, waste and other substances. Source : PAHs are introduced into the environment mainly via natural and anthropogenic burning processes. They enter air as released from volcanoes, forest fires, residential wood burning and exhausts from cars. They can also enter surface water through discharges from industrial plants and wastewater treatment plants. Most PAH do not dissolve in Water. They stick to solid particles and settle to the bottoms of lakes or rivers. PAHs in soils also contaminate underground water. Test Methods :

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AfPS GS 2014:01 Limit Value : 10 ppm( Sum of all PAH’s) Problems :

➢ PAH are known for their carcinogenic & mutagenic properties.

ORGANOTIN COMPOUNDS

What are they A class of chemicals combining tin & organics such as butyl & phenyl group. Source : In textiles and apparel, organotins likeTBT, DBT, DOT, TPhT may be associated with plastics, inks, paints, and heat transfer material. Mostly they used as antifoulants in paints, but they can also be used as biocides (antibacterial) and / or heat stabilizer in plastics Test Methods :

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ISO/TS 16179: 2012 Limit Value : 0.5 & 1 ppm, Reach requirement 1000 ppm Problems :

➢ Highly toxic, endocrine disruptors, harmful to aquatic species.

CHLORINATED ORGANIC CARRIERS

Main Use Chlorinated Organic Carriers are used in batch dyeing of synthetic fibres, particularly polyester fibres, to promote the absorption and diffusion of disperse dyes into the fibre at relative low temperature. These carriers are also important for dyeing blended fibres of wool and polyester as wool cannot withstand dyeing at high temperature Source : Polyester – especially blends dyed at low temperatures in unpressurised dye vessels. Test Methods :

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DIN 54232 Technique : GC-MS Limit Value : 1 mg/kg Problems :

➢ Toxic, skin irritants, carcinogenic, skin contact.

BISPHENOL A

What is it Bisphenol A can be found in plastic materials such as Polycarbonate and epoxy resins. Where it can be found Containers used to store food and beverages such as water bottles, dental sealants , bottle tops, water supply lines. Problem Associated Toxic to reproduction Adverse effect on brain and prostate gland of infants and children, High blood pressure Test Method Solvent Extraction: LC-MS Limit Value: 0.2 ppm

RSL PREVENTIVE MEASURES

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Adopt a solid product safety compliance policy

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Educate supply chain about product safety compliance policy

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Conduct RSL awareness program within your processing unit like bleaching, dyeing, printing and finishing

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Implement a robust product safety testing program

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Poor Material/Chemical management/dye kitchen

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Monitor and control

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Collect and analyses MSDS, RSL test reports, certificates and take corrective actions

FOOTWEAR REGULATIONS

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There is no additional regulatory requirements for footwear: Product must comply to:

• Federal labelling requirement
• CCPSA
• Restricted Substances Limits (RSL)