Weston RSL (Restricted Substance List)
Weston RSL (Restricted Substance List)
We at Weston are always looking to improve and evolve as we grow. While Snowboards, Skis, and Apparel can seem harmless, there is a lot that goes on behind the scenes to create these products. It is our responsibility to understand these processes to ensure that they don’t create unnecessary harm to the local community or people involved with the production of these products. We are working with our suppliers to implement our RSL in order to ensure that the chemicals associated with the production of these products are safe for those using them, or are handled in a manner that makes them safe. Many of these chemicals are not currently relevant to products or implemented production practices we’re using, but we want to set a strong foundation as we look to expand into new product spaces.
Toxic Substances Control Act (TSCA)
The following are banned under the TSCA:
- “PCBs: Congress singled out PCBs in 1976 by implementing a phased ban on the manufacture, processing, use and distribution in commerce of PCBs and requiring EPA to promulgate PCB disposal regulations.
- Asbestos: In 1986, Congress enacted the Asbestos Hazard Emergency Response Act (AHERA) and amended the act in 1990 to modify EPA’s school asbestos remediation program.
- Radon: Radon received special attention in 1988 when Congress set as a long-term national goal that indoor radon levels are not to exceed outside ambient levels.
- Lead: In 1992, Congress enacted TSCA Title IV to create a national program to achieve the national goal of eliminating lead-based paint hazards from housing as expeditiously as possible. In 2007, Congress enacted TSCA Title V, authorizing EPA to establish a state grant program to provide technical assistance on EPA environmental programs for schools and to implement school environmental health programs. Title V also requires EPA to develop guidance addressing, among other things, school siting.
- Formaldehyde: Title VI of TSCA, the Formaldehyde Standards for Composite Wood Products Act, establishes limits for formaldehyde emissions from composite wood products: hardwood plywood, medium-density fiberboard, and particleboard. EPA has been directed by Congress to promulgate final regulations implementing the Act by January 1, 2013.
- Mercury: Title I of TSCA also prohibits the sale, distribution, or transfer of elemental mercury by Federal agencies.”
Per the following: https://www.epa.gov/enforcement/toxic-substances-control-act-tsca-and-federal-facilities
Under the overhauled TSCA in 2016, the EPA was also required to select an additional 10 chemicals that have potential to be dangerous and to conduct risk evaluations.
- Carbon tetrachloride
- Cyclic aliphatic bromides cluster (HBCD)
- DCM (Methylene chloride)
- NMP (N-methylpyrrolidone)
- Pigment violet 29
- Perc (Tetrachloroethylene)
- TCE (Trichloroethylene)
PROPOSITION 65 OF THE SAFE DRINKING WATER AND TOXIC ENFORCEMENT ACT OF 1986
The California Safe Drinking Water and Toxic Enforcement Act of 1986 (Proposition 65), requires manufactures and businesses to label products that contain one or more substance(s) known to the state of California to cause cancer, birth defects, or other reproductive harm. Consumers may initiate legal action against a manufacturer or business that fails to provide such warning.
None of the products and packaging supplied to Weston shall contain any chemical(s) listed on the Proposition 65 list. In the event that a Proposition 65 chemical(s) is present in a product or packaging, the supplier shall notify Weston prior to production and with sufficient lead-time in order to comply with the applicable labeling requirements of the law and reasonably meet the target date for product launch to market. The supplier will also commit to removing said chemical(s) from our supply chain, manufacturing processes, products, and packaging supplied to Weston as soon as reasonably achievable.
The Consumer Product Safety Act (CPSA), The Consumer Product Safety Improvement Act (CPSIA), and The Canadian Consumer Product Safety Act (CCPSA)
Products and packaging that are provided to Weston shall comply with the applicable requirements of CPSA, CPSIA, and CCSPA. This includes but is not limited to the furnishing of third party analytical testing reports for lead in children’s products. Note that CPSIA requires third party analytical testing for Lead, Phthalates, and Flammability in children’s products.
Any product provided to Weston containing a biocide or pesticide shall comply with the EU Biocidal Products Rule and U.S. Environmental Protection Agency (“EPA”) regulations. These substance(s) must be approved for use by the European Chemicals Agency and the U.S. EPA prior to production. Products and their packaging shall be labeled in accordance to these regulations including a claim of the biocidal product (“anti-stink,” “antimicrobial,” etc.) and the name of the biocide. The manufacturer of the biocide shall provide all accurate and necessary information in order to meet these labeling requirements.
THE REGISTRATION, EVALUATION, AUTHORIZATION, AND RESTRICTION OF CHEMICALS (“REACH”), REGULATION
EC NO 1907/2006
None of the products and packaging materials supplied to Weston shall contain SVHC candidate(s) in excess of 0.1%, substances restricted in articles, or substances that are subject to authorization under REACH. Suppliers shall commit to comply with this and all future SVHC candidates added to this regulation, and will immediately inform Weston in the event that an SVHC is present in excess of 0.1% in an article supplied to Weston.
GSPI Six Classes of Harmful Chemicals
Similar to the TSCA, the Green Science Policy Institute has developed and published a list of six specific classes of substances that pose potentially serious harm to consumers. These categories cover a wide variety of industries, but we have chosen to follow this as it has relevance to hardgood production that other apparel-focused groups may miss. These chemicals, as detailed on their website, are:
- PFAs - Per- and polyfluoroalkyl substances (PFAS) are chemicals that contain bonds between carbon and multiple fluorine atoms. These strong carbon-fluorine bonds give PFAS useful chemical properties for making products oil-, stain-, and water-repellent, or non-stick. These same carbon-fluorine bonds also make PFAS extremely resistant to breakdown.
- Antimicrobials - Antimicrobials are chemicals added to products with the intention of killing or inhibiting the growth of microbes. Unfortunately, for most uses they provide no benefit to consumers and may cause health harm. Some antimicrobials may disrupt hormone function, and some are associated with developmental and reproductive effects, allergen sensitivity, and antibiotic resistance
- Flame Retardants - Flame retardant chemicals are added to products including furniture foam, electronics, children’s products, and building insulation to meet flammability standards. Unfortunately, these standards are often poor predictors of real-life fire risks and lead to the unnecessary use of these toxic chemicals.
- Bisphenols & Phthalates - Bisphenols and phthalates are chemicals that have many uses, including making plastics stronger or more flexible. Even at low levels, bisphenols and phthalates can mimic or block hormones, disrupting vital body systems in humans and wildlife.
- Certain Solvents - Solvents are a diverse class of chemicals that are used to dissolve or disperse other substances. Chlorinated solvents are slow to break down in water and soil, posing a threat to groundwater aquifers and ecosystems.
- Certain Metals - Mercury, arsenic, cadmium, and lead are elements that occur naturally in the earth’s crust. Mining and smelting, fossil fuel combustion, industrial processes, and their use in products have led to widespread environmental contamination and human exposure to harmful metals.
For additional information, see - https://greensciencepolicy.org/harmful-chemicals/
As one of the benchmarks for the industry, we will work to follow the established bluesign® RSL, which limits the use of toxic chemicals in a variety of products relevant to the Outdoor Industry. This is an apparel-focused approach, but has a high level of detail and guidance within this space. More information, along with a continuously updated list of these chemicals, can be found at:
Resources and References
bluesign® Restricted Substances List (RSL) Consumer Safety Limits - https://www.bluesign.com/downloads/rsl/2021/bluesign-rsl-v11.0.pdf
REI Sustainable Chemistry Guide & Restricted Substances List (RSL) -
The Burton Corporation Supply Chain Sustainability Policies and Standards -
Nidecker Group Chemical Policy & Restricted Substances List (RSL) -
OIA Chemical Management Toolkit -
Green Science Policy Institute Six Classes of Harmful Chemicals
Apparel and Footwear International RSL Management Group