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Q.4 RFC Component v. Unit and 3rd party testing

 
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Eric H
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PostPosted: Sun Dec 21, 2008 10:47 am    Post subject: Q.4 RFC Component v. Unit and 3rd party testing Reply with quote

The table of contents for all the questions in the RFC, including an explanation of what an RFC is can be found at Introduction and Table of contents: RFC Component vs unit and 3rd party testing

This section deals with the fourth question which is:
Quote:
Assuming all component parts are compliant, what manufacturing processes and/or environmental conditions might introduce factors that would increase the risk of allowing non-compliant consumer products into the marketplace.


This is the fourth question
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Vesta
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PostPosted: Mon Dec 22, 2008 3:03 pm    Post subject: Reply with quote

In sewn products, I can't think of any. This question is probably best directed at toy makes who subject their products to heat or chemical or paint or anodizing processes during manufacturing. Right?
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Eric H
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PostPosted: Mon Dec 22, 2008 6:54 pm    Post subject: Reply with quote

What is in fusible? Does the heat change it? Ditto things like padding (shoulders/bras) ... um, nevermind, probably not relevant to kids wear.

IIRC, there is a section down near the end of CPSIA that deals with formaldehyde. Maybe it's not relevant now, but could be later. I was just reading that formaldehyde is a treatment for cotton, but subsequent washing may actually reduce it. On the other hand, seems like there are simple chemicals and processes that create formaldehyde, but I am officially in over my head on that subject.

What would cause the lead in crystals to come out of the crystal form and become soluble? (Jeez, can't we just ban crystals from kids' wear and be done with this topic?!)
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Esther
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PostPosted: Tue Dec 23, 2008 8:57 am    Post subject: Reply with quote

Quote:
What is in fusible? Does the heat change it? Ditto things like padding (shoulders/bras) ... um, nevermind, probably not relevant to kids wear.


Molded components. Maybe hats? Training bras? Insulated coats with foam liners. I saw a DE that did some kind of "flocked applique". Hand painted textiles. Heat-sealed appliques (a la some boy scout patches).
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Melissa McKeagney
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PostPosted: Sat Dec 27, 2008 7:00 am    Post subject: Reply with quote

One might have to test for phthalates in a product such as fusible interfacing, assuming that there is some kind of plastic that is used to create the part that sticks to the fabric when heated. However, heating that up should not significantly change the chemical make up of that product.

Additionally, if one is using an applique, or using interfacing in that applique, doesn't that become "inaccessible" as it is sandwiched between two fabrics? Even interfacing in a collar or button band would also be inaccessible because it is sewn into the facing.

Melissa
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Melissa McKeagney
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PostPosted: Sat Dec 27, 2008 7:06 am    Post subject: Reply with quote

Y'know Eric, if they really want to get into the formaldehyde issue, then we won't be able to purchase fabric from anywhere except maybe Europe. Formaldehyde, although probably not a good thing, preserves those little clothes coming over from China/India/Malaysia and keeps the from rotting and getting moth-eaten on the high seas. If the CPSC wants to really wreck the industry, that'd be a good way of doing it.

Formaldehyde is by far the number one reason why I wash everything before my daughter goes near it. Ironically, I don't worry about this with my own products (that pesky lead level of 0 parts per million notwithstanding).

Melissa
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Eric H
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PostPosted: Sat Dec 27, 2008 9:38 am    Post subject: Reply with quote

Formaldehyde isn't just used as a preservative. According to Cotton Fiber Chemistry and Technology, it is apparently used as a solvent and as one of the wrinkle-free treatments, and is a by-product of a treatment to make cotton flame resistant. Pretty useful stuff, eh? And one of the reasons why I always wince at the mention of "organic cotton", since (1) all cotton is by definition "organic", (2) organic (as it is meant in this context) only refers to the growing, not the processing, and (3) the greatest environmental load probably occurs in the processing. Processing requires stripping the waxy coating, dyeing, and finishing (for durability, stain- and wrinkle-resistance, etc.), and requires lots of heat, water, and chemicals.

When I attended that Cotton, Inc.-sponsored eco-textile seminar during Magic, this is one of the discussions that came up. Yeah, it's easy to say that these chemical treatments increase environmental loading, but if you can subsequently use milder detergents and cold water to wash, the clothing lasts longer, you don't have to use the energy required to run an iron, and it's flame-proof, the equation to calculate the total lifecycle cost becomes much more complicated. I thought this was a little self-serving on their part, but I haven't seen any research to take this on. In the end, it's consumer values that determine the utility of these treatments. If we didn't twitter away about how awful and wrinkled so-and-so's clothes always looked, maybe we could ditch both the iron and the wrinkle resistance. Until then, given the choice between spending time ironing clothes every week, or buying wrinkle-resistant clothes, most people are going to choose the latter.

Still, when it comes to it, I don't think we will be well-served to argue with CPSC over the usefulness/harmfulness ratio of formaldehyde. The testing and documentation regime may once again be a problem. And we will once again look to the mills to get on board with us to eliminate the problem at the source. The book linked above explores formaldehyde substitutes, and helping to develop treatments is one of Cotton, Inc.s missions.
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Melissa McKeagney
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PostPosted: Sat Dec 27, 2008 1:33 pm    Post subject: Reply with quote

I am always so impressed with your knowledge and understanding of these complex issues (and you make me laugh out loud, too). I didn't know about the use in wrinkle-free applications, so that was good to know. An alternative to formaldehyde would be great, but with anything that's new, it has to be proven first. I definitely don't want to give the CPSC any more ammo, but it looks like they are looking into it anyway.

It is always interesting when you get into debates about environmental impacts of various chemicals and sustainability. I used cloth diapers for my daughter for 2 years. Many people would question me as to my water use (from a well on my property) and detergents (that go into my septic tank and leach field) and wonder whether I was hurting the environment by all the washing. But they never gave much thought into what goes into producing a disposable diaper (plastics for one) or the amount of time it takes for such an item to break down in a landfill. We don't have water issues here in NH, and now I have some great cleaning rags for our household needs. But I digress...

Here is my answer to the fourth question:


There is no manufacturing process that has the possibility of introducing lead unless it involves introducing a new component that might contain lead, ie. solder. Simply heating, sewing, cutting, ironing, and the like, cannot change the chemical make up of the unit, and will not introduce lead if it doesn't exist.

If however during the process of manufacturing, an untested component is introduced such as solder or a surface coating, then that might change whether or not the unit is compliant. But, the fact remains that if all the components have been tested, then processing those components will not alter the chemical compounds significantly enough to pose any hazard.

My husband and I had a good laugh about this one this morning. He basically said that if there isn't any lead in the components, then short of having a nuclear reactor in your basement/manufacturing facility then nothing you do will change that fact!

Melissa
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