PART 2: BANNED/RESTRICTED SUBSTANCES

Revised 10.01.2014

Environmental responsibility is a fundamental part of our approach to corporate Social

Responsibility. We recognise that our business has many environmental and social
impacts. Some of these are associated with the activities of our suppliers.

We want to promote more sustainable practices within our own operations and where
possible influence you as our Supplier to improve the environmental standards in the
Supply Chain.
It is mandatory that effluent is controlled to Local and National in-country regulations at all
sites involved in the manufacture of fabric & garments for David Howard (UK) Ltd including
sub-contracted units, for example Laundry Facilities.

Storage and handling of dyes and chemicals must be made the subject of high standards of
industrial hygiene and safe working practices, the objective being to prevent or to reduce
to an absolute minimum, the exposure to the workforce and the associated health risks.
Exposure can occur through Skin Absorption, Contact with the Eyes, Ingestion or
Inhalation.

Working procedures should be established to avoid exposure by all these routes. As far as
possible, this should be achieved by engineering means such as containment and/or
effective ventilation, including the use of dust free or liquid products.
Protective clothing & headgear, where applicable, should always be worn i.e. gloves,
goggles or face masks.

No smoking, drinking or eating is allowed in areas where chemicals are handled.

There is a number of substances that David Howard does not allow or only allow a
restricted amount to be present in any of their products, be it in the fabric, trims,
accessories, packaging, garment processing etc.

For a list of these banned/restricted substances on fabrics please see the David Howard
Fabric Assurance Manual.

For banned/restricted substances on accessories, trims, interlining, packaging and in

garment processing please see below:

a. Formaldehyde

Formaldehyde is a volatile organic compound that can be found in dyeing and printing
for fixation (e.g. easy care finish), preservation of dyes and prints, tanned leather,
interlinings, bonded fabrics and for anti-shrinking treatments. In larger quantities, it can
cause allergy, skin and respiratory tract irritations and is a suspected carcinogen. It can
be present in 2 forms: free on the surface (to determine the level of Formaldehyde
present in the fabric or garment to give an indication on the risk of handling the
product), or released in a vapour form (to determine the level of Formaldehyde given
David Howard Safety Policy –Part2: Banned/Restricted Substances Page 1 of 17
 off by the fabric into the atmosphere to give an indication as to the risk of respiratory
problems).

Any items for David Howard should not exceed the following levels:

Free formaldehyde – 30ppm

Released formaldehyde – 75ppm

Alternatives:
Use pure finishes where possible. In the case of applications such as flock or appliqué
then formaldehyde containing agents should be avoided. Where this is not possible the
above standards must apply to be included as part of (and not separate from) the
whole sample test result (i.e. base material plus application together must not exceed
above values).

b. Nickel

All components used in David Howard orders must be nickel free.

Nickel is an allergenic, can cause contact dermatitis and suspected to be carcinogenic. It

is a silver white metal that is added to or plated on other metals to improve the
hardness of alloys and corrosion resistance properties, particularly associated with a
bright metal finish. These are often present in accessories for garments, such as zips,
buttons and rivets as well as earrings, bracelets, zippers, watches, studs, rivets, belt
buckles etc.

c. Phthalates

All products supplied to or for David Howard orders must be phthalate free.

Phthalates are plasticisers that are used to soften PVC, which can be used in computers,
paints, printing inks, adhesives, in plastisol prints, cosmetics, footwear, stationary,
clothing, accessories, toys and many packaging operations.

Phthalates can migrate into the body, if they come into contact with saliva/sweat and
are suspected to be an endocrine disruptor and carcinogens and are known to disturb
the endocrine system.
For a list of prohibited phthalates see below:

Substance CAS No

1 Di-Iso-Nonyl Phthalate (DINP) 28553-12-0

2 Di-Ethyl-Hexyl Phthalate (DEHP) 117-81-7

3 Di-N-Octyl Phthalate (DNOP) 117-84-0

4 Di-Iso-Decyl Phthalate (DIDP) 26761-40-0

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 5 Butyl Benzyl Phthalate (BBP) 85-68-7

6 Di Butyl Phthalate (DBP) 84-74-2

Alternatives:
Di- (isononyl) - cyclohexan -1,2-dicarboxylate (DINCH)
Adipates (DEHA)
Citrates (ATBC)

d. Cadmium

All products supplied to or for David Howard orders must be cadmium free.

Cadmium is commonly used in the industry as pigment, dye, paint stabiliser and plating
for functional and decorative purposes. Therefore it may be found in a variety of
products including packaging, plastics, paint, plastisol printed areas, PVC, PU, coated or
laminated fabrics, toys, batteries, furniture, apparel and clothing accessories, such as
buttons, zips etc.

e. Chlorinated Organic Dye Carriers (Chlorinated Benzenes and chlorinated toluenes)

These can affect the nervous system and might have an irritating effect on skin and
mucous membranes and are therefore prohibited in David Howard products. Dye
carriers can be based on trichloro benzene, biphenyl phenol, orthophenyl phenol &
halogenated aromatic hydrocarbons.

Used as carriers in the dyeing process of polyester or wool/polyester fibres. They can
dye at boil to cut costs.

Alternatives:
High temperature dyeing of polyester by aqueous or continuous dyeing techniques only
should be used. Use only permitted dyestuffs. Substitute chlorinated carriers with
toxicologically acceptable carriers such as Carboxylic Acid Esters.

f. Organo Tin Compounds/Alkyl Tin Compounds – TBT, TPT and DBT

Organo Tin Compounds must not be present in any David Howard products.

Tributyl Tin (TBT) Triphenyl Tin (TPT) is used for anti-microbial finishing and in some
printing inks. For textile product it is used for preventing the bacterial degradation of
sweat and unpleasant odours in socks, shoes and sport clothing. It is a catalyst and
stabiliser for PVC and PU, used in coated or laminated fabrics e.g. imitation leather,
bags, shoes.

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 High concentrations of these compounds are repro-toxic. They are persistent organic
pollutants (POP), causing immense damage to water supplies and aquatic species and
absorbed through the skin may affect the nervous system.

Dibutyltin (DBT) is another Organotin with various applications, such as intermediate

for stabilisers of PVC, a catalyst for electrodeposition paints, a catalyst for various types
of polyurethanes and as a catalyst for esterification.
For a list of Organo Tin compounds see below:

Substance CAS No

1 Tributyltin (TBT) 56573-85-4

2 Triphenyltin (TPhT) 668-34-8

3 Tripropyltin (TPT)

4 Trioctyltin (TOT)

5 Trichlohexyltin (TCyHT)

6 Dibutyltin (DBT)

7 Monobutyltin (MBT)

8 Dioctyltin (DOT)

Alternatives:
Seek advice from chemical supplier.

g. PCBs & Polychlorinated Terphenyls (PCTs)

PCBs and PCTs must not be present in any David Howard products.

Chlorinated organic carriers such as PCB and PCT are mainly used as pesticides but also
as softeners, carriers and flame retardants. They are large, stable molecules that can
easily accumulate in organisms and environment. They can affect liver, hormone,
immune and nervous system.

Alternatives:
Modern processing techniques do not require use of PCBs.

h. Chlorinated Phenols - PCP (Pentachlorophenol) and it’s salts and esters (TeCP and
OPP)

Chlorinated Phenols are chemical compounds that include PCP and TeCP.
Orthochlorophenol, Pentachlorophenol (PCP), Penatachlorophenol & TeCP should be
avoided in the production, storage or transportation of any product. It is used as an
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 antifungal agent in leather/textiles e.g. heavy duty cotton and can also be used as
preservative in sizing agents/adhesives and printing pastes.

They are bio-accumulative, if persistent in the environment they can be harmful to

human health and toxic to the aquatic environment and can cause allergy and be
cancer inducing.

Like most chlorinated compounds they degrade to dioxins on combustion. Dioxins are
one of the most toxic non degradable substances around.

David Howard requests that their concentration in any product should be nil.

Anything treated with PCP must be disposed of by methods other than burning.

Alternatives:
Seek supplier advice. Use should not be required if long term storage is not
needed.

i. Prohibited Colourants

Azo Dye ‘Blue Colourant’

The azo dye ‘blue colourant’ (ELINCS No 405-665-4), known by the trade name ‘Navy
blue 018112’ or ‘Navy 018112’, used for colouring textiles and leather must not be used
in any products for David Howard. It has got a high aquatic toxicity and reaches the
environment via waste water from the dyeing processes.

Azo Dyes

Azo Dyes are a group of synthetic dyestuffs based on nitrogen. They are suitable for all
natural and synthetic textile fibres used in textiles (dyed, printed and white) and leather
products including clothing, bedding, towels, leather gloves, toys, yarns and fabrics
intended for final use by the consumer. They get into the product through the
colouration process, especially printing or dyeing.

Azo Dyes can break down and produce aromatic amines that have been found to be
carcinogenic and allergic and pose a risk to workers and consumers, which is why David
Howard does not allow the use of them in any of their products.

Suppliers must be able to certify the absence of banned azo dyes. Adequate
alternatives exist without restricting the colour palette.
For a list of aromatic amines please see below:

CAS No Index No EC No Substance

1 92-67-1 612-072-00-6 202-177-1 4-amino biphenyl

2 92-87-5 612-042-00-2 202-199-1 Benzidine

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 3 95-69-2 202-441-6 4-chloro-o-toluidine

4 91-59-8 612-022-00-3 202-080-4 2-naphthylamine

5 97-56-3 611-006-00-3 202-591-2 o-aminoazotoluene

6 99-55-8 202-765-8 4-nitro-o-toluidine

7 106-47-8 203-401-0 4-chloroaniline

8 615-05-4 210-406-1 4-methoxy-m-

phenylenediamine

9 101-77-9 612-051-00-1 202-974-4 4,4’-

diaminodiphenylmethane

10 91-94-1 612-068-00-4 202-109-0 3,3’-dichlorobenzidine

11 119-90-4 612-036-00-X 204-355-4 3,3’-dimethoxybenzidine

12 119-93-7 612-041-00-7 204-358-0 3,3’-dimethylbenzidine

13 838-88-0 612-085-00-7 212-658-8 3,3-dimethyl-4,4’-

diaminobiphenylmethane

14 120-71-8 204-419-1 p-cresidine

15 101-14-4 612-078-00-9 202-918-9 4,4’-methylene-bis-(2-

chloro-aniline)

16 101-80-4 202-977-0 4,4’-oxydianiline

17 139-65-1 205-370-9 4,4’-thiodianiline

18 95-53-4 612-091-00-X 202-429-0 o-toluidine

19 95-80-7 612-099-00-3 202-453-1 4-methyl-m-

phenylenediamine

20 137-17-7 205-282-0 2,4,5-trimethylaniline

21 90-04-0 612-035-00-4 201-963-1 o-anisidine

22 60-09-3 611-008-00-4 200-453-6 4-amino azobenzene

23 95-68-1 2,4-xylidene

24 87-62-7 2,6-xylidene

Alternatives:
There is no reason for the prohibited products to restrict colour palettes as
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 adequate alternatives exist. Use only permitted dyestuffs.

Carcinogenic Disperse Dyes

These are commonly used to dye polyester, acetate and nylon, also used to colour
plastic jewellery and PVC/PES film and found in printing. They can cause cancer and
allergies.

The dyestuffs in the following table are classified as carcinogenic or allergenic and must
not be used for David Howard product:
CI generic name Cas No

1 CI Acid Red 26 3761-53-3

2 CI Basic Red 9 569-61-9

3 CI Direct Black 38 1937-37-7

4 CI Direct Blue 6 2602-46-2

5 CI Direct Red 28 573-58-0

6 CI Disperse Blue 1 2475-45-8

7 CI Disperse Yellow 3 2832-40-8

8 CI Basic Violet 14 632-99-5

9 CI Disperse Orange 11 82-28-0

10 Direct Brown 6 2602-46-2

11 Direct Brown 95 16071-86-6

12 Michlers Base 101-61-1

13 C I Basic Violet 3 548-62-9

14 C I Basic Blue 26 2850-56-5

15 C I Solvent Blue 4 6786-83-0

Allergenic Disperse Dyes

These are commonly used to dye polyester, acetate and nylon and can cause
dermatitis.

The following dyestuffs have been implicated in cases of contact dermatitis.

Their use is forbidden.

 CI Disperse Yellow 1, 3, 9, 23, 39, 49

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  CI Disperse Orange 1, 3, 76/37

 CI Disperse Brown 1

 CI Disperse Red 1, 11, 17

 CI Disperse Blue 1, 3, 7, 26, 35, 102, 106, 124

Suppliers must be able to certify the absence of banned dyestuff. Again adequate
alternatives exist without restricting the colour palette.

Alternatives:
There is no reason to restrict colour palettes as adequate alternatives of both the
Disperse Dyes & other colorants exist. Use only permitted dyestuffs.

j. Chromium (VI)

Chromium VI (hexavalent chromium) or its derivatives must not be present in any David
Howard products, as Chromium (VI) and compounds are classified as carcinogenic and
can cause allergic reactions, are bio accumulative, highly toxic as well as being
environmentally persistent.

It is found in dyes, pigments, dye additives, pre/after treatments in dyeing processes

particularly associated with the leather industry.

Alternatives:
Avoid 2 bath chrome tanning as it uses Chrome VI directly. Carefully control 1 bath
tanning to avoid the conversion from Chrome III to Chrome VI. Avoid strong alkaline
conditions (e.g. treatment with Ammonia before tanning and strong alkaline glues).
Careful selection of neutralizing agents (replace with reducing agents) and fat
liquoring agents.

k. Alkylphenols (APs) and Alkylphenol Ethoxylates (APEOs)

Alkylphenol Ethoxylates are a class of chemical which are used as non-ionic surfactants
with an emulsifying and dispersing action. They are considered to be harmful and toxic
to the environment and are possible endocrine disrupters.

The most common usage is in detergent products, scouring agents and emulsifying
agents in printing. The second most common use is in textile processing (in particular
with fibres such as linen and silk, whose naturally occurring gums and resins make them
difficult to wet out) where it is used in various textiles auxiliaries including wetting
agents and in the manufacture of water based pigment pastes to improve pigment
dispersion.

At the processing stage , approximately 50% of APEO are used as emulsifiers for
emulsion polymers based on styrol butadiene, Styrol acrylate, Pure acrylate or PVC
systems.
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 The range of products where APEO’s can be found includes plastic coating, paper
coating, textile coating, dispersion paints and varnishes, sealants and similar products.

The use of APs and APEOs specifically containing Octyl Phenols (OP), Nonylphenols and
Nonylphenol ethoxylates is prohibited in all areas of David Howard production.

Nonylphenol Ethoxylate (NPEO), Octylphenol and their Ethoxylates (Alkyl Ethoxylates)

David Howard does not accept the use of any of the above chemicals in the
production or processing of our goods.

Alternatives:
Alcohol ethoxylates are an acceptable alternative.

l. Fluorocarbons – PFOS, halides, amides and other derivatives

The use of fluorocarbons containing Perfluoro Octanoic Acid (PFOA) and Perfluoro
Octanyl Sulphonates (PFOS) are prohibited in David Howard products, as these are
persistent in the environment, possibly carcinogenic, bio-accumulative and harmful to
mammals. PFOS are found in coatings for fabrics to provide water or soiling repellency.

Alternatives:
Chemical suppliers are now able to offer adequate alternatives.

m. Flame Retardants

Flame retardants such as tris-(2,3,-dibromopropyl)-phosphate, polybromobiphenyles;

Polybrominatedbiphenols (PBB), Ttris-(aziridinyl)-phosphineoxide,
Pentabromodiphenylether (PentaBDE) and Octabromodiphenylether (OctaBDE) are not
allowed in David Howard products.

Flame retardants used in the manufacture of various items to inhibit or prevent

combustion and to reduce the flammability of a product, are chemicals causing allergic
reactions. They are carcinogenic, mutagenic, persistent organic pollutants, repro-toxic
and toxic. They are banned under the Dangerous Substances and Preparations (Safety)
Regulations 1980.

Flame retardants may be found in the finishing or manufacturing process of apparel,

homewares, furniture, toys and electronic products.
For a list of flame retardants please see below:

Substance CAS No

1 Tris(2,3-dibromopropyl) 136-72-7
phosphate (TRIS)

2 Polybromobiphenyls (PBB’s) 59536-65-1

3 Tris-(aziridinyl)-phosphinoxide 5455-55-1

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 (TEPA)

4 Pentabromodiphenylether 32534-81-9
(pentaBDE)

5 Octabromodipehnylether 32534-81-9
(octaBDE)

6 Bis(2,3-dibromopropyl) 36711-31-6
phosphate

7 Diboron trioxide 1303-86-2

Alternatives:
Suppliers should be aware of continued progressing technology in this area and
should update themselves with their own suppliers in this respect.

n. Alkanes – Short Chain Chlorinated Paraffin’s (SCCP’s)

Short chain chlorinated paraffins are toxic to the environment and are prohibited for
the use in David Howard products.

They are often used as softeners on flame retardant treated fabrics. Also used as
degreasers and softeners for leather.

o. Biocides & Biocide Finishes

Biocides are harmful to health and the environment and are prohibited to be used in
David Howard products.

Biocides are often used to impart properties such as “antimicrobial” or “anti-odour” in

textile products.

Biocide finishes include Anti-allergy/bacterial/fungal/microbial finishes. As these can

contain harmful chemicals, biocide finishes are not allowed to be used on any David
Howard product.

Alternatives:
Seek advice from chemical supplier.

p. Triclosan

This is an active ingredient in antimicrobial finishes and is an environmental hazard.

David Howard will therefore not allow any Triclosan to be used on it’s products.

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 q. Yellowing

There has been a considerable increase in the use of phenol and aromatic amine
antioxidants and stabilisers. These compounds are now widely found in products such
as packaging, lubricants and foams.

The most commonly used is BHT (butylated hydroxyl tolulene).

All hangers, foam for hangers, tapes used for seams and packaging, silkknots etc. must be
BHT-free for David Howard products.

In urban areas and areas of high traffic density, atmospheric pollution from oxides of
nitrogen and anti-oxidants is known by various names: yellowing, warehouse yellowing
or elusive yellowing.

Practical steps for prevention:

 Don’t allow diesel-powered fork-lifts in the production or warehouse areas

 Exclude exhaust fumes from garment storage areas
 Avoid direct gas or oil heating systems
 Specify BHT-free polythene for packaging
 Specify BHT-free lubricants during manufacture
 Finish fabric on the acid side of neutral (pH 5.5-6.5), to avoid skin irritation and
burns.
r. Migration of certain elements

All metal and plastic components, prints and rubber badges to be used on product
designed for children under 3 years of age must meet the requirement of EN71 - Part 3
Migration of certain elements.

Add on components such as diamantes, sequins and heat sealed motifs on product
designed for all ages, which may become detached during wear must meet the
requirements of EN 71 - Part 3 Migration of certain elements.

David Howard will accept certification by the component or print supplier with regard
to the above, providing it has been carried out in the past 12 months. This should be
available for inspection if and when required.

s. Soluble/Extractable Heavy Metals

Heavy elements such as:

Antimony (Sb)
Arsenic (As)
Barium (Ba)
Cadmium (Cd)
Chromium (Cr)
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 Cobalt (Co)
Lead (Pb)
Mercury (Hg)
Selenium (Se)
Tin (Sn)

refer to any metallic chemical element that has a relatively high density and is toxic or
poisonous at low concentrations.

All heavy elements have a very negative effect on human health and are found in the
pre-processing or in some dyestuffs and chemicals, including printing inks and print
pastes, accessories for textiles and clothing (such as buttons, zips, clasps), paints, trims,
plastics and metal components.

From 20th July 2013 the number of heavy metals in toys will increase from 8 to 19.

Heavy metals should not be present in David Howard products.

Alternatives:

The use of fabrics, prints & finishes and accessories containing these metal elements
must be avoided.

t. Chloro-organic compounds/Volatile Organic Compounds (VOC’s)

Found as solvents in dyeing and printing, also finishing agents, flame retardants and
plasticizers, solvents for fats and oils used as stain removers and scouring assistants.

These substances exist as liquid or gas and can affect the nervous system, with irritating
effects on skin and mucous membranes.

The above are banned in several EU countries and are banned to be used for any
products supplied to David Howard.

u. Persistent organic pollutants (POPs)

Persistent organic pollutants (such as polychlorinated naphthalenes (PCNs) and short
chain chlorinated paraffins (SCCPs) are organic compounds that are resistant to
environmental degradation through chemical, biological, and photolytic processes.
Because of this, they have been observed to persist in the environment, to be capable
of long-range transport, bio-accumulate in human and animal tissue, bio-magnify in
food chains, and to have potential significant impacts on human health and the
environment.

v. Solvent based pigment printing systems & Ozone depleting solvents

The use of solvent based pigment binder systems is prohibited and aqueous based
binder systems must be used instead.
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 Solvents are principally used as cleaning agents but are also found in other products
such as adhesives and dye carriers.

All processes where solvents are used must comply with the following criteria:

a) Authentic date & safety sheets must be available to all operatives. Due regard must
be paid to the health and safety of the operative when operating with solvents with
adequate ventilation, sufficient personal protective equipment and proper records
kept of operative exposures.

b) The solvent must be recoverable.

c) In the case of adhesives an aqueous based alternative should be used where

possible.

d) Spot stain removal should be done where possible using aqueous based agent.

Solvent operations should be minimised with no residual solvent left on the final
product. Extreme caution should be exercised when handling solvents with proper risk
assessment as to their usage undertaken.

In any event the use of ozone depleting solvents as defined in the Montreal protocol is
prohibited.

Alternatives:
Aqueous based binder systems & aqueous cleaning systems to be used.

w. Mothproofing Agents

The use of mothproofing agents in the production of clothing is prohibited.

Alternatives:
There is no alternative to moth proofing agents. Use of agents giving similar
properties is not necessary in a properly controlled production environment.

x. Organochloride Pesticides

Pesticides are used as a defence against insects etc during the cultivation of natural
fibres such as cotton, they may also be used to protect other products such as leather
or feathers.
Pesticides may harm the environment through soil, air or water pollution. Some
chlorinated pesticides may convert to dioxins which are extremely toxic.
The use of Pesticides in any products supplied to David Howard is prohibited.

Alternative:
Checks to be made with supplier as regulations are regularly changing.

y. Fungicides

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 Fungicides may be applied or inserted in products for protection against mould whilst in
transit.
Fungicides containing Dimethylfumarate can cause allergenic reactions when in contact
with the skin.

The use of Fungicides is prohibited in any products delivered to David Howard.

z. Latex

As natural rubber can cause allergic reactions in some people it is not allowed to be
used in any of David Howard’s products.

aa. Mercury (Hg)

Mercury is used in certain caustic soda processes in fabric/garment manufacture. It has

detrimental effects on the central nervous system and is an anticipated carcinogen.

Mercury containing products are prohibited and all caustic soda treatments must be
mercury free.

Alternatives:
Use of non Mercury containing products required.

bb. PVC (Polyvinyl Chloride)

PVC can be used in many areas such as coatings, accessories and zips. As PVC is closely
related to phthalates (for softening) and organotins (as stabiliser) the use of PVC is
prohibited.

Alternatives:
Non polyvinylchloride, Polyurethane or Acrylic containing products are readily
available.

cc. Chlorine Bleaches

The use of chlorine-containing bleaches should be avoided wherever possible or
practicable. In the bleaching and processing of fabric and garments, where there is a
choice, peroxide based bleaching systems are preferred.

dd. Potassium Permanganate

This is a purple chemical that is used as a bleaching agent and can be toxic, skin &
respiratory irritant, as well as a hazard to the environment. David Howard therefore
prohibits the use of this bleaching agent.

ee. Residual PH
Textile processing can use extremes of alkalinity and acidity. All finished products must
fall within an acceptable limit to avoid any skin irritation.
Upper Limit – pH 7.5
Lower Limit – pH 4.5

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 The preparation, dyeing and finishing of Textiles can involve the use of chemicals that
have high levels of acid and alkali. The final washing process is usually where the pH is
monitored and corrected.

ff. Dyestuff suppliers

It is strongly recommended that dyestuffs are only supplied by members of ETAD

(Ecological & Toxicological Association of Dyes & Organic Pigment Manufacturers).

Please visit the ETAD website at www.etad.com to find the latest information on an
ETAD members list.

gg. Uzbekistan Cotton

The use of organised and forced child labour is completely unacceptable and leads us to
conclude that whilst these practices persist in Uzbekistan that David Howard UK Ltd.
cannot support the use of cotton from Uzbekistan in our clothing.
We will require you, wherever possible, to identify the source of raw cotton used in
David Howard Clothing and document this.

In order to maintain a transparent supply chain for verification purposes we are

implementing the following requirements:

- You should maintain identification and/or verification records regarding the harvest
country (origin) of any cotton used in the production of David Howard merchandise.
- David Howard may perform random audits on fabric mills and/or supplier factories to
verify the origin (country of harvest) of cotton.
- If Uzbekistan harvested cotton is found in the David Howard supply chain, or you are
unable to appropriately demonstrate to David Howard’s satisfaction the country of
origin (harvest) for all cotton used in David Howard merchandise, we reserve the right
to refuse all impacted merchandise with no liability or obligation to the supplier.
- Suppliers should promptly notify David Howard of any difficulties in tracking or
questions as to country or origin for discussion.
- For all purposes, including all Wal-Mart supplier agreements, this requirement
concerning the origin of the cotton is a product specification of all purchase orders for
Wal-Mart merchandise containing cotton.

Additional information on the issues surrounding Uzbekistan cotton can be found on

the following website(s):

International Cotton Advisory Committee:

http://www.icac.org/delegates/memos/2008/aide_memoir_uzbekistan_april_2008.pdf

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 International Labour Organization:
http://www.ilo.org/public/english/region/eurpro/moscow/news/2008/0930.htm

Environmental Justice Foundation:

http://www.ejfoundation.org/page142.html

hh. Dimethyl Fumarate (DMF)

This is found as a fungicide on leather and textiles, paper, wood and anti-humidity bags.
As it can cause severe skin irritation plus other health hazards, Dimethyl Fumarate is
prohibited in any products/items supplied to David Howard.

ii. Polycyclic Aromatic Hydrocarbons (PAHs)

PAHs are considered to cause several health problems due to their carcinogenic and
genotoxic properties. PAHs are formed during the incomplete combustion of organic
materials such as wood, oil and animal fats. Rubber and plastics are at most risk of
containing PAHs.
PAHs are not allowed in any products/items supplied to David Howard.

Following is a list of PAH substances:

Ref. Substance CAS No.

1 Acenaphthene 82-32-9
2 Acenaphthylene 208-96-8
3 Anthracene 120-12-7
4 Benzo(a)anthracene 56-55-3
5 Benzo(b)fluoranthene 205-99-2
6 Benzo(j)fluoranthene 205-82-3
7 Benzo(k)fluoranthene 207-08-9
8 Benzo(ghi)perylene 191-24-2
9 Benzo(a)pyrene 50-32-8
10 Benzo(e)pyrene 192-97-2
11 Chrysene 219-01-9
12 Dibenzo(a,h)anthracene 53-70-3
13 Fluoranthene 206-44-0
14 Fluorene 86-73-7
15 Indeno(1,2,3-cd)pyrene 193-39-5
16 Naphthaline 91-20-3
17 Phenanthrene 85-01-8
18 Pyrene 129-00-0

David Howard Safety Policy –Part2: Banned/Restricted Substances Page 16 of 17

 Components

Components
Common banned/restricted

Wool & Silk

Cellulosics

Easy Care
Polyester
substances and where they are most

Finishes

Leather
Coated
Fabrics

Plastic
likely to be found

Metal
Prints
Azo Dyes X X X X

Allergenic Disperse Dyes X

Carcinogenic Disperse Dyes X

NPEO X X

Formaldehyde X X X X

PFOS X

Nickel X

Cadmium X X

Phthalates X

PCP X

Chromium (VI) X

David Howard Safety Policy –Part2: Banned/Restricted Substances Page 17 of 17