GAO
United States Government Accountabilit
y
Office
Report to Congressional Committees
FORMALDEHYDE IN
TEXTILES
While Levels in
Clothing Generally
Appear to Be Low,
Allergic Contact
Dermatitis Is a Health
Issue for Some People
August 2010
GAO-10-875
What GAO Found
United States Government Accountability Office
Why GAO Did This Study
Highlights
Accountability Integrity Reliability
Au
g
ust 2010
FORMALDEHYDE IN TEXTILES
While Levels in Clothing Generally Appear to Be Low,
Allergic Contact Dermatitis Is a Health Issue for Some
People
Highlights of GAO-10-875, a report to
congressional committees
Formaldehyde—one of the most
widely produced chemicals in the
world—is used in many products,
including disinfectants, pressed-
wood, and clothing and other
textiles. Exposure to this chemical,
which has been linked to adverse
health effects for more than 30 years,
typically occurs through inhalation
and dermal (skin) contact.
Formaldehyde can be used to
enhance wrinkle resistance in some
clothing and textiles, especially those
made of cotton. The Consumer
Product Safety Commission
reviewed formaldehyde in clothing in
the 1980s and determined that the
levels found did not pose a public
health concern. At that time, most
clothing sold in the United States
was made here—but the market has
changed such that most U.S. clothing
is now made in other countries. This
market change has raised anew
questions about the levels of
formaldehyde in clothing.
In response to a mandate in the
Consumer Product Safety
Improvement Act of 2008, this report
provides information on what is
known about (1) the health risks of
exposure to formaldehyde,
particularly from clothing, and (2)
the levels of formaldehyde in
clothing sold in the United States.
GAO analyzed government reviews
and the medical literature, as well as
studies on levels of formaldehyde in
clothing, and had a sample of 180
textiles—primarily clothing—tested
for formaldehyde by an accredited
laboratory. While illustrative of
formaldehyde levels that may be
found in clothing, the test results
from GAO’s sample cannot be
projected to all clothing sold in the
United States. This report contains
no recommendations.
The potential health risks associated with formaldehyde
v
ary, depending
largely on the means of exposure (e.g., inhalation or dermal contact), the
concentration of the formaldehyde, and the duration of exposure. Inhaled
formaldehyde may cause such effects as nausea, exacerbation of asthma, and
cellular changes that may lead to the development of tumors. In fact,
comprehensive reviews by the Department of Health and Human Services, the
Environmental Protection Agency, and the World Health Organization have
found that chronic inhalation exposure to formaldehyde may cause cancer.
However, the health risk of greatest concern associated with formaldehyde in
clothing—allergic contact dermatitis—stems from dermal exposure. A form
of eczema, allergic contact dermatitis affects the immune system and
produces reactions characterized by rashes, blisters, and flaky, dry skin that
can itch or burn. Another potential health effect from dermal exposure to
formaldehyde—irritant contact dermatitis—is also a form of eczema and has
similar symptoms; however, this condition does not affect the immune
system. Avoiding clothing containing formaldehyde is typically effective at
preventing allergic and irritant contact dermatitis and relieving symptoms, but
doing so can be difficult as clothing labels do not identify items treated with
or containing formaldehyde. Washing clothing before it is worn often reduces
formaldehyde levels but is not always successful. In some cases, avoiding or
relieving allergic contact dermatitis requires more drastic measures, such as
taking medications with potentially serious side effects. Finally, consumers
may also experience dermal exposure to formaldehyde by using some
cosmetics and skin care products, such as shampoos and sunscreens that
contain formaldehyde.
Comprehensive data on formaldehyde levels in clothing sold in the United
States are not publicly available. While formaldehyde levels in clothing are not
regulated in the United States, the apparel industry reports that 13 countries
have laws or regulations that limit formaldehyde levels in clothing. Most of the
180 items GAO had tested had formaldehyde levels that were below the most
stringent of these industry-identified regulatory limits. GAO’s test results are
similar to those of recent studies of formaldehyde levels in clothing by the
European Union, New Zealand, and Australia—that is, most items were found
to meet the most stringent limits. Moreover, government studies we reviewed
showed a decline in the formaldehyde levels in clothing since the 1980s, and
the levels reported in these studies are generally consistent with the decline in
levels reported in the medical literature. This decline is associated with the
development and use of low-formaldehyde technologies (resins) in
manufacturing clothing, which has been encouraged by such factors as the
identification of formaldehyde as a probable human carcinogen via inhalation;
the promulgation of federal regulations protecting workers from inhalation
exposure to
formaldehyde; and limits on formaldehyde levels that some U.S.
retailers have established for clothing they sell.
View GAO-10-875 or key components.
For more information, contact John B.
Stephenson at (202) 512-3841 or
Page i GAO-10-875
Contents
Letter 1
Background 4
Formaldehyde Poses Different Health Risks Depending on the
Type and Extent of Exposure 8
While Comprehensive Data Are Not Available, Recent Studies
Suggest That Formaldehyde Levels in Clothing Are Generally
Low and Have Declined over Time 14
Agency Comments and Our Evaluation 22
Appendix I Government Reviews of the General Health Effects
of Exposure to Formaldehyde and Medical Literature
on the Health Effects of Formaldehyde in Textiles
24
Appendix II Objectives, Scope, and Methodology 29
Appendix III Voluntary Labeling Programs 34
Appendix IV Top Ten Exporters of Clothing to the United States
in 2008 35
Appendix V Results of Formaldehyde Tests for a Sample of
Clothing and Bed Linens Sold in the United States 36
Appendix VI GAO Contact and Staff Acknowledgments 48
Tables
Table 1: Ten Items Sold in the United States That Exceeded the
Most Stringent Regulatory Standards for Formaldehyde
Identified by the American Apparel and Footwear
Association 15
Formaldehyde in Textiles
Table 2: Levels of Formaldehyde in Clothing and Other Textiles
Reported in Government Studies, 1984-2010 17
Table 3: Formaldehyde Limits Set by 14 U.S. Retailers for Clothing
and Bed Linens 21
Table 4: Examples of Voluntary Labeling Programs 34
Table 5: Information on Items Sold in the United States and Tested
for Formaldehyde Levels, 2010 36
Abbreviations
AATCC test American Association of Textile Chemists and Colorists
112 test
CPSC Consumer Product Safety Commission
DMDHEU dimethylol dihydroxy ethylene urea
EPA Environmental Protection Agency
HHS Department of Health and Human Services
IARC International Agency for Research on Cancer
ISO International Organization for Standardization
Japanese test Japanese Law 112 test
OSHA Occupational Safety and Health Administration
USDA Department of Agriculture
WHO World Health Organization
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Page ii GAO-10-875 Formaldehyde in Textiles
Page 1 GAO-10-875
United States Government Accountability Office
Washington, DC 20548
August 13, 2010
The Honorable Jay Rockefeller
Chairman
The Honorable Kay Bailey Hutchison
Ranking Member
Committee on Commerce, Science
and Transportation
United States Senate
The Honorable Henry A. Waxman
Chairman
The Honorable Joe Barton
Ranking Member
Committee on Energy and Commerce
House of Representatives
Formaldehyde is a colorless, pungent-smelling chemical well known for its
use as a preservative and disinfectant in laboratories and mortuaries but is
also widely used in consumer products such as pressed-wood products,
glues and adhesives, cosmetics, and clothing and other textiles. Some
clothing—generally garments made of cotton and other natural fibers—is
treated with resins
1
containing formaldehyde primarily to enhance wrinkle
resistance. Formaldehyde is toxic and has been linked to serious adverse
health effects, including cancer, and some federal agencies have
regulations that limit human exposure, which occurs primarily through
inhalation and dermal (skin) contact. Regarding inhalation exposure, the
Environmental Protection Agency (EPA) regulates formaldehyde
emissions to the ambient air from both industrial sources and vehicles
under the Clean Air Act, and the Department of Labor’s Occupational
Safety and Health Administration (OSHA) has standards in place that limit
employee exposure to formaldehyde emissions in the workplace.
Regarding dermal exposure to textiles, formaldehyde levels in clothing
and other textiles that come into contact with the skin are not regulated.
The Consumer Product Safety Commission (CPSC), which is charged with
protecting the public from unreasonable risks of serious injury or death
1
In this report, the term “resin” encompasses both the older resin technologies that may
release high levels of formaldehyde and the more recent cross-linking agents that may
release little to no formaldehyde.
Formaldehyde in Textiles
from consumer products, including clothing, reviewed formaldehyde in
clothing sold in the United States in the 1980s and found that
formaldehyde levels were sufficiently low so as not to be a public health
concern.
2
At the time of the CPSC review, most textiles sold in the United States
were also manufactured in the United States. However, the market for
textiles has changed significantly in recent years, raising questions about
what the current levels of formaldehyde in clothing are. Currently, most
clothing sold in the United States is imported from other countries,
particularly from China, Vietnam, and other countries in Asia, as well as
from countries in Central America. In 2008, for example, nearly 35 percent
of clothing imported into the United States was manufactured in China, up
from about 6 percent in 2000. Moreover, in contrast with the United States,
some countries, including China, have established legal limits on the levels
of formaldehyde that clothing may contain. For example, China and Japan
have similar restrictions on levels of formaldehyde that may be contained
in infant and other clothing that comes into direct contact with the skin.
Further, the level of formaldehyde in clothing depends largely on the
variability in the way the manufacturing process is conducted. For
example, formaldehyde levels can vary among the same type and make of
clothing because of, among other things, differences in the type of resin
used and the ways it is applied.
Section 234 of the Consumer Product Safety Improvement Act of 2008
requires GAO to conduct a study on the use of formaldehyde in the
manufacturing of textiles and apparel.
3
This report provides information
on what is known about (1) the health risks from exposure to
formaldehyde, particularly from clothing, and (2) the levels of
formaldehyde found in clothing sold in the United States. To determine
what is known about the health risks from exposure to formaldehyde, we
analyzed comprehensive government reviews of the health effects of
exposure to formaldehyde and conducted a literature review of articles in
2
Formaldehyde is one of five substances CPSC has identified as a strong sensitizer—a
substance that can cause hypersensitivity through recurring contact—under the Federal
Hazardous Substances Act. Therefore, formaldehyde and any products containing 1
percent of formaldehyde or more (10,000 parts per million) are required to bear a warning
label. The 1 percent refers to the concentration of formaldehyde in solutions and products,
not in the air. This reporting level for formaldehyde far exceeds amounts likely to be found
in clothing.
3
Pub. L. No. 110-314, § 234 (2008).
Page 2 GAO-10-875 Formaldehyde in Textiles
medical, textile, and environmental journals and books published from
1980 through April 2010 (see app. I for more information on this
research).
4
To determine what is known about the levels of formaldehyde
found in clothing sold in the United States, we analyzed information about
(1) the use of formaldehyde-containing resins in clothing, (2)
formaldehyde levels in clothing reported in government studies, and (3)
relevant voluntary labeling programs, corporate limits, and regulatory
limits for formaldehyde levels in clothing in the United States and other
countries. Because of complexities in obtaining English translations of
formaldehyde laws and regulations in other countries and confirming their
application within the context of these countries’ legal systems, we relied
primarily on the American Apparel and Footwear Association for
information on formaldehyde limits set in other countries, including the
limits identified as the most stringent.
5
In addition, using an accredited
commercial laboratory, we tested a nonprobability sample
6
of 180 textile
items—primarily clothing (165) and some bed linens (15)—purchased
from selected U.S. retailers in six metropolitan areas: Boston, Chicago,
Dallas, Los Angeles, Seattle, and Washington, D.C. We selected low- or
moderately priced items. We compared our test results with the most
stringent regulatory limits for formaldehyde in clothing and other textiles
established in other countries, as identified by the American Apparel and
Footwear Association. The results from testing our nonprobability sample
are illustrative of formaldehyde levels that may be found in some clothing
and are not projectable to clothing sold in the United States in general.
Throughout our review, we consulted with CPSC on our methodology and
to obtain relevant background information stemming from the agency’s
mission to ensure consumer protection. Appendix II provides a more
detailed description of our scope and methodology. We conducted this
performance audit from September 2009 to August 2010 in accordance
with generally accepted government auditing standards. Those standards
require that we plan and perform the audit to obtain sufficient, appropriate
evidence to provide a reasonable basis for our findings and conclusions
based on our audit objectives. We believe that the evidence obtained
4
Most of the relevant articles identified from our literature review were from medical
journals or addressed medical issues, and in this report, we use the term “medical
literature” to refer to the articles.
5
American Apparel and Footwear Association, Restricted Substance List, Release 6 (2010).
6
A nonprobability sample is a sample in which some items in the population have no
chance, or an unknown chance, of being selected. Results from nonprobability samples
cannot be used to make inferences about a population.
Page 3 GAO-10-875 Formaldehyde in Textiles
provides a reasonable basis for our findings and conclusions based on our
audit objectives.
Formaldehyde—one of the most widely produced and used chemicals in
the world—is a water-soluble gas often used in a water-based solution
(aqueous form) as a disinfectant or tissue preservative. In terms of
toxicity, ingestion by an adult of as little as 1 ounce of a solution
containing 37 percent formaldehyde has been reported to be lethal.
7
Formaldehyde is also used in other forms, including resins, that combine
formaldehyde with other compounds. Aqueous formaldehyde and
products containing formaldehyde tend to emit some formaldehyde into
the air. Formaldehyde is also produced naturally in the environment and is
found in low levels in people and most living things. In addition,
formaldehyde is a by-product of combustion processes, such as wood
burning and cigarette smoking. When formaldehyde is exposed to air, it
begins to break down and dissipate.
Background
The Department of Health and Human Services (HHS) reports that average
levels of formaldehyde in outdoor air are often less than 0.01 parts of
formaldehyde per million parts of air, and the average levels in indoor air
in homes are often less than 0.04 parts per million.
8
Major sources of
formaldehyde in outdoor air are man-made, such as power plants,
manufacturing facilities, incinerators, and automobile exhaust.
Formaldehyde levels in outdoor air are often found to be higher near some
industry facilities and in heavily populated urban areas. In addition, people
exposed to formaldehyde at work—such as medical personnel,
embalmers, cabinetmakers, and textile plant employees—may be exposed
to higher levels of formaldehyde. In general, the highest levels of airborne
formaldehyde are detected indoors, where it can be released from various
building materials, consumer products, and tobacco smoke.
7
Medical Management Guidelines for Formaldehyde (Atlanta: U.S. Department of Health
and Human Services, Agency for Toxic Substances and Disease Registry, Feb. 7, 2008),
http://www.atsdr.cdc.gov/mhmi/mmg111.html (accessed Aug. 5, 2009).
8
U.S. Department of Health and Human Services, Public Health Service, National
Toxicology Program, Report on Carcinogens, Background Document for Formaldehyde
(Research Triangle Park, North Carolina, 2010).
Page 4 GAO-10-875 Formaldehyde in Textiles
Because formaldehyde is highly toxic, it is regulated by various federal
and state agencies to protect human health and the environment.
9
For
example, EPA lists formaldehyde as a hazardous air pollutant under the
Clean Air Act and as a hazardous waste under the Resource Conservation
and Recovery Act. Other agencies, such as OSHA and the Department of
Housing and Urban Development, regulate airborne formaldehyde
concentrations in the workplace and in manufactured homes, and the
Food and Drug Administration limits the food-related use of formaldehyde
to packaging components. In addition, California regulates formaldehyde
emissions from composite wood products to protect human health from
airborne exposure to formaldehyde.
10
According to an official from the
California Environmental Protection Agency, the agency found that
emissions from textiles commonly found in the home, such as draperies,
dissipate quickly, whereas emissions from composite wood products are
higher and remain relatively constant over time.
Formaldehyde-containing resins have been used in clothing and other
textiles since the mid-1920s primarily to impart durable press
characteristics to fabrics made from natural fibers, especially plant-based
fibers such as cotton.
11
These resins may also provide other easy-care
benefits, such as shrink resistance and color fastness.
12
The use of these
resins in cotton clothing and other textiles became more prevalent in the
1950s and 1960s to compete with the increased use of synthetic fabrics,
which often provided durable press characteristics. Under certain
9
In this report, we use the terms “toxic” and “highly toxic” as they are used by EPA’s Toxics
Release Inventory Program and HHS’s Agency for Toxic Substances and Disease Registry,
respectively.
10
EPA initiated an advanced notice of a proposed rulemaking in December 2008 indicating
that the agency intends to investigate whether and what type of federal regulation or other
action might be appropriate to protect against the risks posed by formaldehyde emitted
from composite and pressed-wood products. Furthermore, on July 7, 2010, the
Formaldehyde Standards for Composite Wood Act was signed into federal law. The new
law amends the Toxic Substances Control Act to establish standards for emissions of
formaldehyde from hardwood plywood, medium-density fiberboard, and particleboard.
EPA must promulgate regulations to implement the standards by January 2013.
11
In this report, “durable press” is used to encompass terms such as wrinkle resistant,
wrinkle free, noniron, no iron, and easy care. The durable press fabric characteristic
applies to items treated to retain their shape and pressed appearance after many uses,
washing, and tumble drying. All-synthetic fabrics, such as 100 percent polyester, are
inherently durable press and do not need to be treated.
12
Formaldehyde may also be used in binders for prints, in various coatings such as fire
retardant chemicals, and for other purposes.
Page 5 GAO-10-875 Formaldehyde in Textiles
conditions, formaldehyde-containing resins may chemically degrade and
release (off gas) free formaldehyde, including when exposed to high
temperature and humidity.
The level of formaldehyde in clothing identified by testing and the level of
formaldehyde that may be emitted by that clothing into the air will vary
under different conditions—especially heat and humidity—and the test
method used. Formaldehyde release mechanisms are numerous and
complex, and emissions of formaldehyde from fabrics are much lower
than the levels found in the fabrics by testing. Several analytical tests may
be used to identify the levels of formaldehyde in clothing and other
textiles. Test results are generally expressed as micrograms of
formaldehyde per gram of fabric—typically either as microgram per gram
or as parts per million.
The two analytical tests now commonly used in the textile industry to
identify levels of formaldehyde in clothing and textiles are the Japanese
Industrial Standard L 1041 test, also known as the Japanese Law 112 test
(Japanese test), and the American Association of Textile Chemists and
Colorists 112 test (AATCC test).
13
The Japanese test was developed to
measure the amount of formaldehyde that may be released by clothing and
other textiles that may come into contact with the skin, and the AATCC
test was developed to measure the amount of formaldehyde that may be
released from clothing and other textiles during extended storage or hot
and humid conditions.
14
Because of different testing specifications, as well
as variables related to the particular formaldehyde resins used,
formaldehyde levels measured by the two tests are not comparable, and
the results from the Japanese test cannot be used to predict what the
results would be under the AATCC test and vice versa.
15
Regarding the
tests performed on our sample of clothing and bed linens, the laboratory
13
The International Organization for Standardization (ISO) has equivalent tests: ISO 14184-1
Textiles—Determination of Formaldehyde—Part 1: Free and Hydrolyzed Formaldehyde
(Water Extraction Method), which is equivalent to the Japanese test; and ISO 14184-2
Textiles—Determination of Formaldehyde—Part 2: Released Formaldehyde (Vapour
Absorption Method), which is equivalent to the AATCC test.
14
Formaldehyde Release from Fabric, Determination of: Sealed Jar Method, AATCC Test
Method 112-2008.
15
In general, the AATCC test results in higher formaldehyde levels than the Japanese test—
except at low formaldehyde levels, such as 30 parts per million or less—although the
difference between the formaldehyde levels measured by the two tests depends, in part, on
the type of fabric and resin used.
Page 6 GAO-10-875 Formaldehyde in Textiles
tested all of them using the Japanese test and a subset of them using the
AATCC test. According to the American Apparel and Footwear
Association, the Japanese test is used to determine whether formaldehyde
levels in clothing are consistent with levels cited in international
regulations. In addition, most of the U.S. retailers that provided us with
information on internal corporate limits use the Japanese test or its
equivalent. Further, the Japanese test was more frequently used in the
studies we identified that conducted formaldehyde testing in clothing and
other textiles.
The American Apparel and Footwear Association has identified the most
stringent regulatory limits for formaldehyde in clothing and home textiles
in other countries for its members that may wish to sell their products
internationally.
16
The most stringent formaldehyde limits identified use the
Japanese (or equivalent) test as a basis for measurement and are
• not detectable (defined as less than 20 parts per million) for products
intended for children younger than 3 years of age,
• less than 75 parts per million for products that come into direct contact
with the skin for children who are 3 years of age and older and for adults,
and
• less than 300 parts per million for products that do not come into direct
contact with the skin—e.g., outerwear—for children who are 3 years of
age and older and for adults.
Some countries do not limit formaldehyde levels in clothing but require
disclosure in labels if formaldehyde levels exceed specified amounts.
17
Further, some countries and private entities offer “eco labels” for clothing
and other textiles, if their formaldehyde levels—as well as levels of other
chemicals—are within specified ranges. Appendix III provides more
16
In the Restricted Substance List, the American Apparel and Footwear Association, a
national trade association, provides information about the regulatory limits for various
substances in countries in which its members may operate. The Restricted Substance List
identifies Austria, China, Finland, France, Germany, Japan, Lithuania, the Netherlands,
New Zealand, Norway, Poland, Russia, and South Korea as countries that regulate
formaldehyde in apparel, home textiles, and footwear products.
17
Information on countries that require disclosure was compiled by the Hong Kong
Standards and Testing Centre, a laboratory that provides formaldehyde testing services
according to international standards and regulations.
Page 7 GAO-10-875 Formaldehyde in Textiles
information on voluntary labeling programs. Finally, while the United
States does not legally limit formaldehyde levels in clothing, some U.S.
retailers have set internal corporate limits on formaldehyde in clothing.
In the mid-1980s, most of the clothing sold in the United States was also
manufactured in the United States and its territories. However, imports of
clothing and other textiles from other countries now make up a majority
of U.S. sales. Although textile industries are dispersed throughout the
world, China is now the world’s largest producer and exporter of clothing
and textiles. Much of China’s growth occurred during the 10-year phaseout
of textile quotas under the 1995 World Trade Organization Agreement on
Textiles and Clothing, which was completed on January 1, 2005.
18
As of
2008, China accounted for the largest share of total U.S. clothing imports—
34.3 percent, an increase from 6.5 percent in 1999. Vietnam and
Bangladesh rank second and third at 6.7 percent and 6.3 percent,
respectively. Appendix IV provides additional information on the 10
countries that exported the most clothing to the United States in 2008.
Key government reviews on the health effects of exposure to
formaldehyde, including those conducted by EPA, HHS, and the World
Health Organization (WHO), have concluded that chronic inhalation
exposure to formaldehyde may cause cancer. Regarding exposure to
formaldehyde in clothing, the health risk of greatest concern identified in
key government reviews and in the medical literature is allergic contact
dermatitis.
Formaldehyde Poses
Different Health Risks
Depending on the
Type and Extent of
Exposure
Key Government Reviews
Have Concluded That
Chronic Inhalation
Exposure to
Formaldehyde May Cause
Cancer
The potential health risks from exposure to formaldehyde vary depending
on the means of exposure (inhalation, dermal, ingestion, or eye contact),
the concentration of formaldehyde, and the duration of exposure, among
other factors. Inhaled formaldehyde may cause such effects as (1)
discomfort or nausea stemming from the chemical’s pungent odor; (2)
irritation of the eyes, nose, and throat; (3) exacerbation of asthma; and (4)
changes at the cellular level that may lead to the development of tumors.
In fact, several comprehensive government reviews of the health risks of
18
Various international agreements (or quotas) capping textile and apparel imports into the
United States were put in place, in part, to attempt to curb the trend toward offshore
production, which many U.S. manufacturers were using in order to control costs. The
World Trade Organization agreement was put in place to lift these quotas.
Page 8 GAO-10-875 Formaldehyde in Textiles
exposure to formaldehyde have found that chronic inhalation exposure to
formaldehyde may cause cancer.
Concerns about the health risks of exposure to formaldehyde were
heightened in 1979 when the Chemical Industry Institute of Toxicology
19
reported that formaldehyde caused nasal cancer in laboratory rats. Since
then, government and industry entities have extensively studied the
potential human health risks of inhalation exposure to this commonly
used chemical. Concerns about formaldehyde are based on its cancer-
causing potential in humans as well as its irritant properties. Research
efforts on inhalation exposure have focused on indoor air levels of
formaldehyde, where concentrations are known to be higher, and in
particular on exposure in occupational settings. These research efforts
include long-term epidemiological studies conducted on workplace
exposure. For example, the largest study to date was conducted by the
National Cancer Institute, which has tracked close to 26,000 workers
employed in 10 different formaldehyde-producing or -using plants since
the 1960s; the latest update to this study was published in 2009. Similarly,
HHS’s National Institute for Occupational Safety and Health has studied
about 11,000 textile workers exposed to formaldehyde in the workplace.
These studies have suggested that formaldehyde exposure is associated
with nasopharyngeal cancer and possibly with cancers of the
hematopoietic and lymphatic systems, particularly myeloid leukemia.
20
Based on these and other studies, at least three government entities—EPA,
HHS, and WHO—have conducted comprehensive reviews of the health
effects of formaldehyde. For example, in 2005, the HHS’s National
Toxicology Program
21
concluded that chronically inhaled formaldehyde is
reasonably anticipated to be a human carcinogen; the agency is currently
considering upgrading this designation to “known to be a human
carcinogen.”
22
Similarly, beginning in 1987, EPA classified inhaled
19
This organization is now called the Hamner Institutes for Health Sciences.
20
The hematopoietic and lymphatic systems are, among other things, involved in the
production of blood and in the immune system function.
21
U.S. Department of Health and Human Services, Public Health Service, National
Toxicology Program, Report on Carcinogens, 11th Edition (Research Triangle Park, North
Carolina, 2005).
22
74 Fed. Reg. 67883 (Dec. 21, 2009).
Page 9 GAO-10-875 Formaldehyde in Textiles
formaldehyde as a probable human carcinogen
23
and in June 2010 released
a revised draft assessment classifying it as a known human carcinogen.
24
The draft EPA assessment is undergoing a review by the National
Academies,
25
one of several key steps the agency must take prior to
finalizing the assessment. In addition, in 2006, WHO’s International Agency
for Research on Cancer (IARC) reclassified formaldehyde from “probably
carcinogenic to humans,” a classification based on its 1995 assessment, to
“carcinogenic to humans.”
26
For the 2006 classification, IARC found
sufficient evidence that formaldehyde causes nasopharyngeal cancer in
humans, limited evidence for cancer of the nasal cavity and paranasal
sinuses, and strong but not sufficient evidence for leukemia. In 2009,
IARC’s Cancer Monograph Working Group determined on the basis of
additional epidemiological studies that there was sufficient evidence to
associate formaldehyde exposure with leukemia.
27
This finding will be
published in an upcoming IARC monograph.
Most studies supporting a link between exposure to formaldehyde and an
increased risk of cancer studied workers exposed to formaldehyde
occupationally, rather than people exposed to formaldehyde in consumer
products, although people may be exposed to formaldehyde in consumer
goods, such as pressed-wood products and textiles, that may “off gas”
formaldehyde indoors. While EPA is required to develop regulations
establishing standards for emissions of formaldehyde from hardwood
plywood, medium-density fiberboard, and particleboard under July 2010
amendments to the Toxic Substances Control Act, the comprehensive
23
EPA, Office of Pesticides and Toxic Substances, Assessment of Health Risks to Garment
Workers and Certain Home Residents From Exposure to Formaldehyde (Washington,
D.C., 1987); and Integrated Risk Information System, Formaldehyde (CASRN 50-00-0)
(Washington, D.C.: EPA), http://www.epa.gov/ncea/iris/subst/0419.htm (downloaded
Dec. 9, 2009).
24
EPA, IRIS Toxicological Review of Formaldehyde—Inhalation Assessment (External
Review Draft) (Washington, D.C., June 2010).
25
The National Academies comprises four organizations: the National Academy of Sciences,
the National Academy of Engineering, the Institute of Medicine, and the National Research
Council.
26
World Health Organization, International Agency for Research on Cancer, IARC
Monographs on the Evaluation of Carcinogenic Risks to Humans, Volume 88,
Formaldehyde, 2-Butoxyethanol and 1-tert-Butoxypropan-2-ol (Lyon, France, 2006).
27
Robert Baan et al. “A Review of Human Carcinogens—Part F: Chemical Agents and
Related Occupations,” The Lancet Oncology, vol. 10, issue 12 (2009).
Page 10 GAO-10-875 Formaldehyde in Textiles
government studies we reviewed do not indicate that formaldehyde levels
in clothing present an inhalation health risk to consumers.
The Health Risk of
Greatest Concern
Associated with Dermal
Exposure to
Formaldehyde in Clothing
Is Allergic Contact
Dermatitis
Regarding exposure to formaldehyde in clothing, CPSC officials said that,
on the basis of research the agency conducted in the 1980s,
28
(1) there
were no data indicating that formaldehyde in clothing and other textiles
could penetrate the skin and cause cancer and (2) levels of formaldehyde
found in clothing did not pose an acute or chronic health hazard to
consumers. As a result, CPSC concluded that a regulatory standard was
not needed for levels of formaldehyde in clothing and other textiles or for
emissions of formaldehyde from these items. Further, the United States
has no other legal limit on the level of formaldehyde that may be found in
clothing and other textiles.
Based on our review of the medical literature, the health risk of greatest
concern associated with formaldehyde in clothing—allergic contact
dermatitis—stems from dermal exposure.
29
A form of eczema, allergic
contact dermatitis produces reactions characterized by rashes,
discoloration (particularly redness), swelling, blisters, scaling, and flaky
dry skin that can itch or burn. These reactions are often very painful and
can last indefinitely if left untreated. The reactions can be exacerbated by
heat, humidity, friction, and perspiration and are usually worse where
clothing fits closely. In some cases, repeated scratching of the affected
area can lead to patches of tough, leathery skin. Allergic contact dermatitis
also affects the immune system. Another potential health effect from
dermal exposure to formaldehyde in clothing—irritant contact
dermatitis—is also a form of eczema and has similar symptoms; however,
this condition does not affect the immune system.
28
Department of Energy, Oak Ridge National Laboratory, Formaldehyde Release From
Durable-Press Apparel Textiles, Final Project Report to the U.S. Consumer Product Safety
Commission (Oak Ridge, Tennessee, 1985).
29
Dermal exposure occurs when skin comes in contact with free formaldehyde in textiles.
Formaldehyde in clothing may be either bound or free, and it is the skin contact with free
formaldehyde that is associated with the negative health effects. Free formaldehyde occurs
when there is an incomplete binding process between the formaldehyde-based resin and
the clothing fibers or when the resin decomposes. Unless otherwise noted in this report,
references to the health effects associated with formaldehyde in clothing or textiles refer to
free formaldehyde.
Page 11 GAO-10-875 Formaldehyde in Textiles
Formaldehyde is classified as a “strong sensitizer”—a substance that can
cause hypersensitivity through recurring or prolonged contact. According
to the medical literature, people with allergic contact dermatitis caused by
contact with formaldehyde in clothing have generally become
hypersensitive to the chemical through previous exposure. The test used
to determine whether an individual has allergic contact dermatitis does
not identify the level of formaldehyde in clothing that would trigger this
condition. Although the estimates vary widely, the medical literature
suggests that the amount of formaldehyde in clothing needed to trigger an
allergic contact dermatitis reaction in sensitized individuals can be as little
as 30 parts per million. The amount of formaldehyde in clothing that would
cause a reaction is an area needing further research, according to a 2009
medical journal article by experts on contact dermatitis.
30
Some of the medical literature has estimated the number of people with
allergic and irritant contact dermatitis caused by dermal exposure to
formaldehyde. This literature focuses on subpopulations of patients—
those with eczema—and therefore the results cannot be generalized to the
rest of the population. For example, one study reported that 9.2 percent of
patients suspected of having contact dermatitis tested positive to a
diagnostic skin test—called a patch test—that applied a 1 percent
formaldehyde solution to the skin to test for any dermal reaction. Other
studies estimate that between 1.2 percent and 2.3 percent of people with
eczema have dermatitis related to formaldehyde in their clothing. Some of
the medical literature suggests that allergic contact dermatitis may be
underreported because medical practitioners might not distinguish it from
cases of dermatitis with other causes, because of differences in how patch
testing is conducted to determine dermatitis, and because some
individuals may attempt to treat the condition themselves without seeking
medical attention or are reluctant to make the number of visits to the
doctor necessary to make a reliable diagnosis.
Avoiding clothing containing formaldehyde is typically effective at
preventing allergic or irritant contact dermatitis and at relieving
symptoms, but doing so may be difficult because labels for clothing sold in
the United States generally do not provide information on formaldehyde
content or on whether the clothing item was treated with formaldehyde.
30
Anton C. De Groot and Howard I. Maibach, “Does Allergic Contact Dermatitis from
Formaldehyde in Clothes Treated with Durable-Press Chemical Finishes Exist in the USA?”
Contact Dermatitis, vol. 62, no. 3 (2009).
Page 12 GAO-10-875 Formaldehyde in Textiles
One dermatologist with whom we spoke published an article that
identifies some clothing companies that report using little or no
formaldehyde in their clothing.
31
Also, a number of medical articles
recommend that patients allergic to formaldehyde wash articles of
clothing before wearing them to reduce the level of formaldehyde to which
they may be exposed. The success of this technique in limiting exposure to
formaldehyde in clothing may vary, however. For example, studies
conducted by the Department of Agriculture (USDA) Agricultural
Research Service report that the effect of laundering on formaldehyde
levels depends on the type of resin that is applied to the clothing as well as
on other factors, such as the alkalinity and hardness of the water and
whether bleach is used. Other studies report that while formaldehyde
levels may decline initially after washing, the levels may start increasing
again after multiple washes. One publication explains that while washing
clothing does remove some formaldehyde, levels may increase again over
time as the resin is broken down by, among other things, washing and
ironing.
32
Additionally, certain clothing items, such as hats, are generally
not washed before being worn.
In some cases, more drastic measures may be necessary to avoid allergic
contact dermatitis. Some researchers suggest that some patients may need
to change occupations or job responsibilities to avoid contact with
formaldehyde-containing products. If wearing clothing with formaldehyde
cannot be avoided, some researchers suggest wearing synthetic or silk
undergarments to act as a barrier between the skin and the clothing. When
avoidance is not feasible or does not sufficiently relieve symptoms for
those with allergic contact dermatitis, other treatment options include
strong oral or topical medications, including immunosuppressive agents
that may have serious side effects. Topical medications should be used
with caution because some of these medications may actually contain
formaldehyde, which could potentially perpetuate or worsen the reaction.
Finally, we note that consumers may also experience dermal exposure to
formaldehyde by using some cosmetics and skin care products, such as
some shampoos and sunscreens that contain formaldehyde.
31
Ryan M. Carlson, Mary C. Smith, and Susan T. Nedorost, “Diagnosis and Treatment of
Dermatitis Due to Formaldehyde Resins in Clothing,” Dermatitis, vol. 15, no. 4 (2004).
32
Etain Cronin, Contact Dermatitis (New York City: Churchill Livingstone, 1980).
Page 13 GAO-10-875 Formaldehyde in Textiles
In the absence of U.S. regulation of formaldehyde levels in clothing, and
associated compliance testing, comprehensive data on the levels of
formaldehyde in clothing sold in the United States are not publicly
available.
33
Tests conducted by an accredited commercial laboratory of
180 items we purchased in stores across the country indicate th
formaldehyde levels in most of the items are low or not detectable.
Moreover, these test results indicate that the levels of formaldehyde found
in most of these items would meet the most stringent regulatory standards
set by other countries as identified by the American Apparel and Footwear
Association: not detectable in clothing and other items for infants and
toddlers younger than 3 years of age and less than 75 parts per million for
clothing and other items that come into direct contact with the skin for
adults and for children 3 years of age and older.
at
34
However, 10 of the items
exceeded these limits, with formaldehyde levels ranging from 75.4 to 206.1
parts per million. As table 1 shows, nine of these items exceeded the limits
for adults and for children 3 years of age and older, and one item—a sheet
for a child’s crib—exceeded the limit for infants and toddlers younger than
3 years of age as well as that for adults and for children 3 years of age and
older. More than half of the items we had tested that exceeded these limits
were labeled as having fabric performance characteristics related to
durable press, which may indicate the use of resins that contain
formaldehyde and can alert consumers who wish to avoid formaldehyde in
clothing.
35
Both domestic and imported clothing and bed linens had
formaldehyde levels that exceeded the limits identified by the apparel
industry. Appendix V provides more complete information on the items we
had tested.
While Comprehensive
Data Are Not
Available, Recent
Studies Suggest That
Formaldehyde Levels
in Clothing Are
Generally Low and
Have Declined over
Time
33
While a national regulation of formaldehyde in clothing would not necessarily produce
comprehensive data on levels in clothing, such data are unlikely to be compiled without a
requirement to do so.
34
We considered all items in our sample to come into direct contact with the skin, although
some textile industry standards consider bed linens for older children and adults to be
subject to the formaldehyde limits applicable to items that do not come into direct contact
with the skin.
35
We are using “durable press” to include terms such as wrinkle resistant, wrinkle free,
noniron, no iron, and easy care.
Page 14 GAO-10-875 Formaldehyde in Textiles
Table 1: Ten Items Sold in the United States That Exceeded the Most Stringent Regulatory Standards for Formaldehyde
Identified by the American Apparel and Footwear Association
Item type
Fiber content
identified on label
Fabric performance
characteristic identified
on label or packaging
Country
identified on
label
Target customer
Formaldehyde
level in parts
per million
a
Dress shirt 100% cotton Wrinkle free China Men 206.1
Hat 100% cotton
exclusive of
decoration
None identified China Boys 3 years of age
and older
192.6
Bed linens (pillow cases) 60% cotton, 40%
polyester
Soft finish, easy care Bahrain Adults or children
3 years of age and
older
189.6
Khakis 100% cotton No iron, permanent crease India Men 169.6
Dress shirt 60% cotton, 40%
polyester
None identified China Boys 3 years of age
and older
95.1
Bed linens (pillow cases) 100% cotton Wrinkle free, easy care, no
ironing needed,
eco-friendly
USA; fabric
imported from
Pakistan
Adults or children
3 years of age and
older
93.8
Dress shirt 100% cotton Noniron Indonesia Men 92.6
Bed linens (pillow cases) 100% cotton Wrinkle free performance Pakistan Adults or children
3 years of age and
older
89.3
Bed linens (crib sheet) 100% cotton Preshrunk Thailand Infants/toddlers
b
85.4
U.S. military combat
uniform pants
50% cotton, 50%
nylon
None identified USA Women 75.4
Source: GAO analysis of information provided on items’ labels or packaging and test data from an accredited commercial laboratory.
a
These formaldehyde levels were determined using the Japanese test.
b
Infants/toddlers refers to children younger than 3 years of age.
In 2007, the European Union and New Zealand government conducted studies
of formaldehyde levels in clothing using methodologies similar to ours and
also found that most clothing items tested had levels of formaldehyde that
were low or not detectable.
36
,
37
Specifically, the European Union found that
36
European Commission Directorate General Joint Research Centre, Physical and Chemical
Exposure Unit, Chemical Release from Textiles, European Survey on the Release of
Formaldehyde from Textiles (Ispra, Italy, 2007).
37
Evaluation of Alleged Unacceptable Formaldehyde Levels in Clothing (Wellington, New
Zealand: New Zealand Ministry of Consumer Affairs, Oct. 17, 2007),
http://www.consumeraffairs.govt.nz/legislation-policy/policy-reports-and-papers/reports
(accessed Oct. 22, 2009). The New Zealand government also received information from four
retailers that tested 203 items. One item, a preproduction fabric, was found to be above the
acceptable level, which was defined by New Zealand to be 100 parts per million.
Page 15 GAO-10-875 Formaldehyde in Textiles
212 of 221 items tested either had formaldehyde levels below 75 parts per
million for adults and older children or levels that were not detectable for
infants. Of the 9 items that exceeded these levels, 5 were either dress shirts
labeled as “easy care” or T-shirts. Moreover, our analysis of the New Zealand
government study showed that 96 of 99 items tested had formaldehyde levels
below 75 parts per million; the 3 exceptions were men’s dress or casual pants.
A more limited study of 10 clothing items, conducted in 2007 by the Australian
government, reported that all 10 items had formaldehyde levels that were not
detectable.
38
These studies, as well as our own test results, provide important
data on levels of formaldehyde that may be found in clothing, but these data
cannot be projected to clothing in general.
Regarding the decline in levels of formaldehyde in clothing over time,
government studies we reviewed have reported decreasing levels since the
1960s. While researchers have used various test methods in the past,
which has limited comparisons of formaldehyde levels in clothing over
time, the available data on formaldehyde levels in items tested show a
decline over time. For example, the USDA Agricultural Research Service
reported that in the early 1960s formaldehyde levels in clothing were
found to be generally above 3,000 parts per million using the AATCC test.
39
However, tests conducted in the early 1980s by the textile industry showed
that formaldehyde levels in clothing were generally below 500 parts per
million using the AATCC test. Further, tests conducted by government
entities in Australia, Denmark, the European Union, Finland, New Zealand,
and the United States from 1984 to 2010—more often using the Japanese
test—show that the percentage of items with formaldehyde levels greater
than 100 parts per million has generally declined (see table 2). For
example, although in 1985 67 percent of items tested by CPSC
40
had levels
of formaldehyde above 100 parts per million using the Japanese test,
studies since 2003 have shown that 2 percent or less of the items tested
using the Japanese test had formaldehyde levels above 100 parts per
million. Similarly, the maximum formaldehyde level identified in any item
in each study has generally declined.
38
No Formaldehyde Found in Clothing, Australian Competition and Consumer
Commission, (October 17, 2007),
http://www.accc.gov.au/content/index.phtml?itemId=801314 (accessed Aug. 5, 2009).
39
B.A. Kottes Andrews, “Wrinkle Resistant Cotton and Formaldehyde Release,” Colourage
Annual (1995).
40
Formaldehyde Release from Durable-Press Apparel Textiles, Final Project Report to the
U.S. Consumer Product Safety Commission (1985).
Page 16 GAO-10-875 Formaldehyde in Textiles
Table 2: Levels of Formaldehyde in Clothing and Other Textiles Reported in Government Studies, 1984-2010
Percentage of items
tested with greater than
100 parts per million of
formaldehyde
Maximum level of
formaldehyde
identified in any item
(parts per million)
Source Year tested
Type of
items tested
Number of
items tested
Japanese
test
a
AATCC
test
a
Japanese
test
a
AATCC
test
a
CPSC
b
1984-1985 Clothing and
bed linens
12 67 92 736.6 2,897
Tampere Regional
Institute of
Occupational
Health, Finland
1986-1987 Clothing,
home textiles,
and cotton
fabrics
20 50 90 855 1,680
Tampere Regional
Institute of
Occupational
Health, Finland
1987-1994 Fabrics,
textiles
144 11
c
2,000
c
Finnish Customs
Laboratory
1988 Imported
textiles
2,719 12
c
2,200
c
Finnish Customs
Laboratory
1989 Imported
textiles
1,922 7
c
1,050
c
Finnish Customs
Laboratory
1990 Imported
textiles
1,547 11
c
1,500
c
Finnish Customs
Laboratory
1991 Imported
textiles
2,173 9
c
805
c
Finnish Customs
Laboratory
1992 Imported
textiles
1,407 10
c
1,319
c
Finnish Customs
Laboratory
1993 Imported
textiles
1,680 5
c
643
c
Danish Ministry of
Environment and
Energy
2003
d
Clothing and
home textiles
10 0
c
82
c
New Zealand
Ministry of
Consumer Affairs
2007 Clothing,
home textiles,
and footwear
99 2
c
250
c
Australian
Competition and
Consumer
Commission
2007 Clothing 10 0 0 Not
detectable
Not
detectable
European Union 2007 Clothing and
home textiles
221 items (Japanese
test); 127 items
(AATCC test)
1 9 162.5 397.3
GAO 2010 Clothing and
bed linens
180 items (Japanese
test); 21 items
(AATCC test)
2 10 206.1 550.7
Sources: Government-sponsored or -supported studies and GAO analysis of test data from an accredited commercial laboratory.
Page 17 GAO-10-875 Formaldehyde in Textiles
a
Or an equivalent test method.
b
CPSC-sponsored study tested a subset (12 items) of its full sample using the Japanese and AATCC
tests. The entire sample of 180 clothing and bed linens was tested using a proprietary method
developed by the Department of Energy’s Oak Ridge National Laboratory, which conducted the
testing. Based on this test method, 14 percent of the items had more than 100 parts per million of
formaldehyde, and the maximum formaldehyde level identified in an item was 940.2 parts per million.
c
Only the Japanese or Japanese-equivalent tests were used in this study.
d
This is the year the report was published.
The levels of formaldehyde found in the these studies are generally
consistent with information reported since the 1980s in the medical
literature and trade publications that documents a decline in formaldehyde
levels in clothing since that time. This decline is associated with the
development and use of low-formaldehyde resins in manufacturing
clothing, which has been encouraged by such key factors as the following:
(1) the identification of formaldehyde as a probable human carcinogen via
inhalation and the promulgation of regulations by OSHA to protect
workers, such as those in textile factories, from exposure to
formaldehyde; (2) legal limits on the levels of formaldehyde in clothing
and other textiles adopted in other countries; (3) limits on formaldehyde
levels that some U.S. retailers have established for clothing they sell; and
(4) the textile industry’s development of improved resins that provide
durable press characteristics but release less formaldehyde.
More specifically, as discussed earlier, formaldehyde was classified as a
probable human carcinogen in the 1980s based on animal and human
studies showing that airborne formaldehyde exposure is associated with
certain types of cancer. In 1987 and 1992, OSHA decreased the permissible
airborne exposure level of formaldehyde in the workplace. The current
OSHA regulation, among other things, limits airborne exposure to 0.75
parts of formaldehyde per million parts of air.
41
While this regulation
primarily addresses the airborne concentration of formaldehyde to which
workers—such as those in textile factories—may be exposed, several
41
The current OSHA regulation, among other things, limits airborne exposure to 0.75 parts
of formaldehyde per million parts of air over an 8-hour workday; sets a short-term
exposure limit of 2 parts of formaldehyde per million parts of air; and includes a hazard
communication requirement pertaining to formaldehyde gas, all mixtures or solutions
composed of greater than 0.1 percent formaldehyde (equivalent to 1,000 parts per million),
and materials capable of releasing formaldehyde into the air, under reasonably foreseeable
conditions of use, at concentrations reaching or exceeding 0.1 parts per million. The
National Institute for Occupational Safety and Health has established nonenforceable
guidelines for formaldehyde exposure and recommends an occupational exposure limit
over an 8-hour workday of 0.016 parts per million and a 15-minute ceiling of 0.1 parts per
million in the air.
Page 18 GAO-10-875 Formaldehyde in Textiles
government studies and the medical literature have noted that OSHA
regulations have encouraged lower formaldehyde levels in clothing and
other textiles. Information provided in a Finnish Regional Institute of
Occupational Health study illustrates the relationship between the levels
of formaldehyde being applied to textiles in the workplace and airborne
formaldehyde emissions in the factory. The Finnish study reported that
formaldehyde levels in textiles should be under 200 parts per million
42
to
ensure airborne formaldehyde emission levels in factories remain below 1
part per million under adverse conditions such as low ventilation and high
humidity.
43
Another factor that may have encouraged the use of lower levels of
formaldehyde in clothing is the adoption in other countries of legal limits
on formaldehyde in clothing and textiles and on the airborne levels of
formaldehyde in the workplace. For example, according to HHS’s National
Institute for Occupational Safety and Health, over 20 countries have
established occupational exposure limits to protect workers, including
those in the textile industry.
44
In addition, the European Union’s European
Scientific Committee on Occupational Exposure Limits has issued
provisional occupational exposure limits for formaldehyde. Further,
according to the American Apparel and Footwear Association, 13
countries regulate the level of formaldehyde in clothing.
45
Another factor
that may limit formaldehyde levels in clothing is the use of voluntary
labeling programs such as the Oeko-Tex® Standard 100 label.
46
Such labels
may be displayed by clothing and other textile items that meet certain
42
This formaldehyde level in textiles is based on the Japanese test.
43
Eero Priha, “Are Textile Formaldehyde Regulations Reasonable? Experiences from the
Finnish Textile and Clothing Industries,” Regulatory Toxicology and Pharmacology, 22,
243-249 (1995).
44
Department of Health and Human Services, National Institute for Occupational Safety and
Health, The Registry of Toxic Effects of Chemical Substances, No. LP8925000, CAS No.
50-00-0 (Washington, D.C., 2009).
45
The countries the American Apparel and Footwear Association identifies as having
regulatory standards for formaldehyde in clothing and other textiles are Austria, China,
Finland, France, Germany, Japan, Lithuania, the Netherlands, New Zealand, Norway,
Poland, Russia, and South Korea.
46
The Austrian Textile Research Institute and the German Research Institute Hohenstein
jointly developed the Oeko-Tex® Standard 100 in 1992. The International Oeko-Tex®
Association, which includes 14 textile research and test institutes in Europe and Japan, is
responsible for the independent tests for harmful substances according to Oeko-Tex®
Standard 100.
Page 19 GAO-10-875 Formaldehyde in Textiles
limits on formaldehyde and other substances. Appendix III provides more
information on voluntary labeling programs.
In addition, while there are no legal limits on the levels of formaldehyde in
clothing in the United States, some U.S. retailers have established their
own corporate limits on formaldehyde in clothing and bed linens. These
corporate formaldehyde limits are generally considered proprietary,
although some may be disclosed upon request. We obtained information
on corporate limits for formaldehyde in clothing established by 14 U.S.-
based retailers.
47
Many of these limits were set within the last 10 years,
although one was set as early as 1995. In some cases, the limits established
by retailers apply only to private store brands and not to national brands,
some of which may establish their own limits. Some of the 14 retailers told
us they review regulations adopted in other countries to inform their own
corporate limits or to comply with regulations in countries where they
operate.
Table 3 shows the corporate limits for formaldehyde in clothing and bed
linens sold in the United States that we obtained from 14 retailers. The
retailers’ limits vary both by age and item category. For example, a retailer
may have limits for clothing and bed linens for infants and toddlers but not
for clothing or bed linens for adults.
47
We requested information on corporate limits on formaldehyde in clothing and other
textiles, if any, from 16 publicly traded U.S.-based clothing retailers. One of the 14 retailers
responding reported that it had not established formaldehyde limits. For one of the two
retailers that did not respond, we were able to obtain, from its Web site, information about
the corporate limits it has established.
Page 20 GAO-10-875 Formaldehyde in Textiles
Table 3: Formaldehyde Limits Set by 14 U.S. Retailers for Clothing and Bed Linens
Number of retailers reporting formaldehyde limits, by category
Formaldehyde limits
a,b
Clothing for
infants/toddlers
Bed linens for
infants/toddlers
Clothing for
children
Bed linens
for children
Clothing
for adults
Bed linens
for adults
None 0 1 0 1 3 3
<250 parts per million 0 1 0 1 0 1
<200 parts per million
c
1 1 1 1 1 2
<150 parts per million 0 1 0 1 0 1
c
<100 parts per million 0 0 1 1 2 1
<75 parts per million 2 4 11
d
9
d
8
d
6
c
<20 parts per million 11
c
6
d
10 00
Number of retailers
reporting limits
14 14 14 14 14 14
Source: GAO analysis of data from 14 U.S. retailers.
Notes: Retailers’ age designations for infants/toddlers and children vary.
a
Unless otherwise noted, retailers reported using the Japanese test.
b
Formaldehyde limits for clothing are applicable to clothing that comes in direct contact with the skin.
c
One retailer determines compliance with this limit using the AATCC test.
d
Two retailers determine compliance with this limit using the AATCC test.
However, retailers may use their corporate limits more as guidelines than
as absolute compliance limits. For example, one retailer told us that when
its test results for formaldehyde content exceed corporate limits, the
company may conduct additional testing to determine the extent of the
problem to inform its response. In contrast, this retailer told us that if a
single sample exceeds a U.S. regulatory standard—for example, for lead in
clothing—the company rejects the entire shipment. Another retailer told
us the company complies with Japan’s formaldehyde limit—the most
stringent—when selling products in Japan but has established a less
stringent limit for clothing sold in the United States.
Finally, another factor that may have contributed to lower levels of
formaldehyde in clothing, according to government and trade publications,
is industry actions to address concerns about some formaldehyde-
containing resins. The older resins, such as urea formaldehyde and
melamine formaldehyde, impart durable press characteristics to clothing
but also tend to release more formaldehyde during the manufacture,
storage, retailing, and use of fabrics and clothing than newer resins
because they are less chemically stable. In addition, the older resins can
also stiffen fabric, degrade after repeated washing, damage fabrics if
chlorine bleach is used, and cause the fabrics to emit a noticeable odor.
Page 21 GAO-10-875 Formaldehyde in Textiles
The development and use of newer resins in clothing production to impart
durable press characteristics have addressed some of these issues as well
as reduced the level of formaldehyde in clothing. These newer resins, also
called cross-linking agents, became widely used in the 1980s. For example,
dimethylol dihydroxy ethylene urea (DMDHEU) and its derivatives are
reported to be the most commonly used resins today. Fabrics finished with
DMDHEU may release moderate amounts of formaldehyde but can be
modified to release low to ultra-low levels.
48
Newer resins that do not
contain formaldehyde have also been developed, but they are not as
widely used because of their higher cost; some may also have negative
effects on fabrics.
We provided a draft of this report to the Chairman, CPSC, for review and
comment. CPSC provided technical comments, which we have
incorporated, as appropriate.
Agency Comments
and Our Evaluation
We are sending copies of this report to the appropriate congressional
committees; the Chairman, CPSC; and other interested parties. The report
is also available at no charge on the GAO Web site at http:www.gao.gov.
48
According to medical literature, moderate amounts of formaldehyde are defined as
between 1,000 and 100 parts per million, while low and ultra-low levels are below 100 parts
per million, based on the AATCC test.
Page 22 GAO-10-875 Formaldehyde in Textiles
If you or your staff have any questions about this report, please contact me
at (202) 512-3841 or [email protected]. Contact points for our Offices
of Congressional Relations and Public Affairs may be found on the last
page of this report. GAO staff who made major contributions to this report
John B. Stephenson
are listed in appendix VI.
Director, Natural Resources
and Environment
Page 23 GAO-10-875 Formaldehyde in Textiles
Page 24 GAO-10-875
Appendix I: Government Reviews of the
General Health Effects of Exposure to
Formaldehyde and Medical Literature on the
Health Effects of Formaldehyde in Textiles
Appendix I: Government Reviews of the General Health
Effects of Exposure to Formaldehyde and Medical Literature
on the Health Effects of Formaldehyde in Textiles
Following is more detailed information on the sources we used in our
analysis to determine what is known about the health effects of exposure
to formaldehyde.
Aalto-Korte, K., R. Jolanki, and T. Estlander. “Formaldehyde-Negative
Allergic Contact Dermatitis from Melamine-Formaldehyde Resin.” Contact
Dermatitis, vol. 49, no. 4 (2003).
Andersen, Klaus E. and Howard I. Maibach. “Multiple Application Delayed
Onset Contact Urticaria: Possible Relation to Certain Unusual Formalin
and Textile Reactions?” Contact Dermatitis, vol. 10, no. 4 (1984).
Andersen, Klaus E. and Knud Hamann. “Cost Benefit of Patch Testing with
Textile Finish Resins.” Contact Dermatitis, vol. 8, no. 1 (1982).
Australia Department of Health and Ageing. National Industrial
Chemicals Notification and Assessment Scheme, Priority Existing
Chemical Assessment Report No. 28, Formaldehyde. Sydney, Australia,
2006.
Belsito, Donald V. “What’s New in Contact Dermatitis: Textile Dermatitis.”
American Journal of Contact Dermatitis, vol. 4, no. 4 (1993).
Bracamonte, B.G., F.J. Ortiz de Frutos, and L.I. Diez. “Occupational
Allergic Contact Dermatitis due to Formaldehyde and Textile Finish
Resins.” Contact Dermatitis, vol. 33, no. 2 (1995).
Carlson, Ryan M., Mary C. Smith, and Susan T. Nedorost. “Diagnosis and
Treatment of Dermatitis Due to Formaldehyde Resins in Clothing.”
Dermatitis, vol. 15, no. 4 (2004).
Cockayne, Sarah E., Andrew J.G. McDonagh, and David J. Gawkrodger.
“Occupational Allergic Contact Dermatitis from Formaldehyde Resin in
Clothing.” Contact Dermatitis, vol. 44, no. 2 (2001).
Cronin, Etain. Contact Dermatitis, New York City, New York: Churchill
Livingstone, 1980.
De Groot, Anton C., et al. “Formaldehyde-Releasers: Relationship to
Formaldehyde Contact Allergy. Formaldehyde-Releasers in Clothes:
Durable Press Chemical Finishes. Part 1.” Contact Dermatitis, vol. 62, no.
5 (2010).
Formaldehyde in Textiles
Appendix I: Government Reviews of the
General Health Effects of Exposure to
Formaldehyde and Medical Literature on the
Health Effects of Formaldehyde in Textiles
De Groot, Anton C. and Freddy Gerkens. “Contact Urticaria from a
Chemical Textile Finish.” Contact Dermatitis, vol. 20, no. 1 (1989).
De Groot, Anton C. and Howard I. Maibach. “Does Allergic Contact
Dermatitis from Formaldehyde in Clothes Treated with Durable-Press
Chemical Finishes Exist in the USA?” Contact Dermatitis, vol. 62, no. 3
(2009).
Donovan, Jeff and Sandy Skotnicki-Grant. “Allergic Contact Dermatitis
from Formaldehyde Textile Resins in Surgical Uniforms and Nonwoven
Textile Masks.” Dermatitis, vol. 18, no. 1 (2006).
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Formaldehyde. Canada, 2001.
Fowler, Joseph F. “Formaldehyde as a Textile Allergen.” In Textiles and
the Skin (Current Problems in Dermatology), vol. 31, edited by P. Elsner,
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Fowler, Joseph F. Jr., Steven M. Skinner, and Donald V. Belsito. “Allergic
Contact Dermatitis from Formaldehyde Resins in Permanent Press
Clothing: An Underdiagnosed Cause of Generalized Dermatitis.” Journal
of the American Academy of Dermatology, vol. 27, no. 6 (1992).
Geldof, B.A., I.D. Roesyanto, and Th. van Joost. “Clinical Aspects of Para-
Tertiary-Butylphenolformaldehyde Resin (PTBP-FR) Allergy.” Contact
Dermatitis, vol. 21, no. 5 (1989).
Hatch, Kathryn L. “Chemicals and Textiles Part II: Dermatological
Problems Related to Finishes.” Textile Research Journal, vol. 54, no. 11
(1984).
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Dermatitis.” Contact Dermatitis, vol. 14, no. 1 (1986).
Hatch, Kathryn L. and Howard I. Maibach. “Textile Dermatitis: An Update.”
Contact Dermatitis, vol. 32, no. 6 (1995).
Hatch, Kathryn L. and Howard I. Maibach. “Textile Dye Dermatitis.”
Journal of the American Academy of Dermatology, vol. 32, no. 4 (1995).
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Appendix I: Government Reviews of the
General Health Effects of Exposure to
Formaldehyde and Medical Literature on the
Health Effects of Formaldehyde in Textiles
Hegewald, Janice, et al. “Meteorological Conditions and the Diagnosis of
Occupationally Related Contact Sensitizations.” Scandinavian Journal of
Work, Environment & Health, vol. 34, no. 4 (2008).
Imbus, Harold R. “Clinical Evaluation of Patients with Complaints Related
to Formaldehyde Exposure.” Journal of Allergy and Clinical
Immunology, vol. 76, no. 6 (1985).
Iversen, Olav Hilmar. “Formaldehyde and Skin Carcinogenesis.”
Environment International, vol. 12, no. 5 (1986).
Lazarov, A. “Textile Dermatitis in Patients with Contact Sensitization in
Israel: a 4-Year Prospective Study.” Journal of the European Academy of
Dermatology and Venereology, vol. 18, no. 5 (2004).
Lazarov, A. and M. Cordoba. “Purpuric Contact Dermatitis in Patients with
Allergic Reaction to Textile Dyes and Resins.” Journal of the European
Academy of Dermatology and Venereology, vol. 14, no. 2 (2000).
Le Coz, Christophe-J. “Clothing.” In Textbook of Contact Dermatitis, 3rd
ed., edited by R.J.G. Rycroft, T. Menne, P.J. Frosch, and Jean-Pierre
Lepoittevin, 727-749. Berlin, Heidelberg, Germany: Springer, 2001.
Maibach, Howard. “Formaldehyde: Effects on Animal and Human Skin.” In
Formaldehyde Toxicity, edited by J.E. Gibson, 166-174. Washington, D.C.:
Hemisphere, 1983.
Marks, James G. Jr., et al. “North American Contact Dermatitis Group
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Permanent-Press Allergic Contact Dermatitis.” Contact Dermatitis, vol.
46, no. 1 (2002).
National Academy of Sciences, Committee on Toxicology, Board of
Toxicology and Environmental Health Hazards, Assembly of Life Sciences,
National Research Council. Formaldehyde—An Assessment of the Health
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General Health Effects of Exposure to
Formaldehyde and Medical Literature on the
Health Effects of Formaldehyde in Textiles
Nordman, Henrik, Helena Keskinen, and Matti Tuppurainen.
“Formaldehyde Asthma—Rare or Overlooked?” The Journal of Allergy
and Clinical Immunology, vol. 75, no. 1 (1985).
Organisation for Economic Co-operation and Development. SIDS Initial
Assessment Report for 14th SIAM, Formaldehyde (CAS No. 50-00-0).
Paris, France: United Nations Environment Programme Publications, 2002.
Reich, Hilary C. and Erin M. Warshaw. “Allergic Contact Dermatitis from
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Rietschel, Robert L. and Joseph F. Fowler, Jr. “Textile and Shoe
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Appendix I: Government Reviews of the
General Health Effects of Exposure to
Formaldehyde and Medical Literature on the
Health Effects of Formaldehyde in Textiles
U.S. Department of Health and Human Services, Agency for Toxic
Substances and Disease Registry. Toxicological Profile for Formaldehyde.
Atlanta, GA, 1999.
U.S. Department of Health and Human Services, Public Health Service,
National Toxicology Program. Report on Carcinogens, 11th Edition.
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National Toxicology Program. Report on Carcinogens, Background
Document for Formaldehyde. Research Triangle Park, NC, 2010.
U.S. Environmental Protection Agency. Integrated Risk Information
System, Formaldehyde (CASRN 50-00-0),
http://www.epa.gov/ncea/iris/subst/0419.htm.
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Formaldehyde—Inhalation Assessment (External Review Draft).
Washington, D.C., June 2010.
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Clothing-Related Skin Conditions. Report: 55-8-2001.
World Health Organization. Concise International Chemical Assessment
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Environment Programme, the International Labour Organization, and the
World Health Organization, 2002.
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IARC Monographs on the Evaluation of Carcinogenic Risks to Humans,
Volume 88, Formaldehyde, 2-Butoxyethanol and 1-tert-Butoxypropan-2-
ol. Lyon, France, 2006.
Page 28 GAO-10-875 Formaldehyde in Textiles
Appendix II: Objectives, Scope, and
Methodology
Page 29 GAO-10-875
Appendix II: Objectives, Scope, and
Methodology
Section 234 of the Consumer Product Safety Improvement Act of 2008
requires GAO to conduct a study on the use of formaldehyde in the
manufacturing of textiles and apparel.
1
This report provides information
on what is known about (1) the health risks from exposure to
formaldehyde, particularly from clothing, and (2) the levels of
formaldehyde found in clothing sold in the United States. Throughout our
review, we consulted with the Consumer Product Safety Commission
(CPSC) on our methodology and to obtain relevant background
information stemming from the agency’s mission to ensure consumer
protection.
To determine what is known about the health effects of exposure to
formaldehyde, particularly from clothing, we conducted literature reviews
on both the general health effects of formaldehyde and the health effects
of exposure to formaldehyde in clothing. For the general health effects, we
summarized the findings of several comprehensive government reviews,
including (1) the Health and Human Services’ (HHS) 2005 National
Toxicology Program report on carcinogens (currently being updated),
2
(2)
HHS’s Agency for Toxic Substances and Disease Registry 1999
toxicological profile for formaldehyde,
3
(3) the Environmental Protection
Agency’s (EPA) 1991 Integrated Risk Information System formaldehyde
assessment
4
and the 2010 draft update,
5
(4) the 2006 monograph on
formaldehyde prepared by the World Health Organization’s International
Agency for Research on Cancer,
6
and (5) the Organisation for Economic
1
Pub. L. No. 110-314, § 234 (2008).
2
U.S. Department of Health and Human Services, National Toxicology Program, Report on
Carcinogens, 11th Edition (Research Triangle Park, North Carolina, 2005).
3
U.S. Department of Health and Human Services, Public Health Service, Agency for Toxic
Substances and Disease Registry, Toxicological Profile for Formaldehyde (Atlanta,
Georgia, 1999).
4
Integrated Risk Information System, Formaldehyde (CASRN 50-00-0) (Washington,
D.C.: EPA), http://www.epa.gov/ncea/iris/subst/0419.htm (downloaded Dec. 9, 2009).
5
U.S. Environmental Protection Agency, External Review Draft: Toxicological Review of
Formaldehyde—Inhalation Assessment, in Support of Summary Information on the
Integrated Risk Information System, Volume I of IV (Washington, D.C., June 2010).
6
World Health Organization, International Agency for Research on Cancer, IARC
Monographs on the Evaluation of Carcinogenic Risks to Humans, Volume 88,
Formaldehyde, 2-Butoxyethanol and 1-tert-Butoxypropan-2-ol (Lyon, France, 2006).
Formaldehyde in Textiles
Appendix II: Objectives, Scope, and
Methodology
Co-operation and Development’s 2002 Screening Information Data Set for
formaldehyde.
7
To determine the health effects of exposure to formaldehyde in clothing,
we reviewed and summarized the findings of over 40 relevant articles
published from 1980 to April 2010 primarily in medical journals, but also in
textile industry and environmental journals and books. We targeted
reviews and meta-analyses, rather than individual studies, published in
English but also included articles presenting original research, such as
clinical studies. In addition, we interviewed and obtained studies from
medical professionals, officials from the Department of Agriculture
(USDA) and CPSC, and representatives from industry organizations such
as the American Apparel and Footwear Association, Cotton Incorporated,
and the Formaldehyde Council, Inc.
To determine what is known about the levels of formaldehyde found in
clothing sold in the United States, we analyzed information on
formaldehyde-containing resins and formaldehyde levels in clothing from
government studies, patent applications, and trade publications;
interviewed officials from government agencies including USDA’s
Agricultural Research Service, industry associations, retailers, testing
laboratories, and academia, as well the medical profession; and contracted
with an accredited commercial laboratory to test the formaldehyde levels
in a nonprobability sample
8
of 180 articles of clothing (165) and bed linens
(15).
For our nonprobability sample, we purchased clothing and bed linens from
10 national retailers, two military facilities, and a store selling children’s
scout uniforms. In March 2010, our staff purchased items in six major
metropolitan areas: Boston, Chicago, Dallas, Los Angeles, Seattle, and
Washington, D.C. Our sample was approximately evenly split by gender
and included items worn by adults and children. We purchased only items
that come into direct contact with the skin; we did not buy outerwear such
as jackets or coats. We used clothing sizes to determine whether clothing
was intended for children 3 years of age and older. We also considered
7
Organisation for Economic Co-operation and Development, SIDS Initial Assessment
Report for 14th SIAM, Formaldehyde (CAS No. 50-00-0) (Paris, France, 2002).
8
A nonprobability sample is a sample in which some items in the population have no
chance, or an unknown chance, of being selected. Results from nonprobability samples
cannot be used to make inferences about a population.
Page 30 GAO-10-875 Formaldehyde in Textiles
Appendix II: Objectives, Scope, and
Methodology
crib sheets and cloth diapers to be intended for use by infants and
toddlers. The results from testing our nonprobability sample are
illustrative of formaldehyde levels that may be found in some clothing and
are not projectable to clothing sold in the United States in general.
We selected items that were likely to contain formaldehyde, such as those
made from plant-based fibers, like cotton, that are likely to be treated for
durable press. Almost all of the items in the sample were made from 50
percent or more natural (mostly plant-based) fibers. About 76 percent of
the items were made from 90 percent or more cotton. About a fifth of the
items were labeled as being treated for durable press, including bed linens
and career apparel such as dress shirts. We also included some commonly
worn items, such as T-shirts and jeans, based on a review of Department
of Commerce data for volumes of clothing and bed linens imported or
produced in the United States. We selected low- or moderately priced
items. Most of the items in our sample were imported; however, we also
made an effort to ensure that about 10 percent of them were American
made.
An accredited commercial laboratory tested the items for formaldehyde.
The laboratory is accredited by, among others, the American Association
of Textile Chemists and Colorists and the American Association for
Laboratory Accreditation.
9
To prepare items for shipment, we placed each
one in its own zippered plastic bag shortly after its purchase to avoid
cross-contamination from other items or packaging materials. Samples
received by the laboratory were cut, weighed, and kept wrapped in foil
inside a plastic bag until the formaldehyde test was run.
The laboratory tested the items using two test methods commonly used by
the textile industry—the Japanese Industrial Standard L 1041 test, also
known as the Japanese Law 112 test (Japanese test), and the American
Association of Textile Chemists and Colorists 112 test (AATCC test).
Results from the Japanese test and the AATCC test are not comparable
because, for example, they use different testing specifications. The
procedure the laboratory used for the Japanese test included placing 1
gram of the sample in a stoppered flask with 100 mL of water and
immersing it in a bath of 40°C water for 1 hour. The procedure the
9
The American Association for Laboratory Accreditation bases its accreditation on the
International Organization for Standardization (ISO) 17025:2005, General requirements for
the competence of testing and calibration laboratories.
Page 31 GAO-10-875 Formaldehyde in Textiles
Appendix II: Objectives, Scope, and
Methodology
laboratory used for the AATCC test included suspending 1 gram of the
sample in a sealed jar above 50 mL of water. The jar was kept in an oven at
49°C for 20 hours and then cooled at room temperature for 30 minutes.
For both tests, an acetyl acetone reagent was added as the next step, and
the solution was heated at 40°C for 30 minutes and allowed to cool at
room temperature for 30 minutes. The laboratory ran quality control tests
for each batch of samples.
We had each of the 180 items tested using the Japanese test and a smaller
number using the AATCC test because most of the regulatory and
corporate formaldehyde limits we identified used the Japanese test or its
equivalent. According to the American Apparel and Footwear Association,
this test or its equivalent is used to determine whether formaldehyde
levels in clothing are consistent with levels cited in international
formaldehyde regulations, which we used as a basis of comparison for our
own test results. Also, the Japanese test was more frequently used in the
government studies we identified that conducted formaldehyde testing in
clothing and other textiles. In addition, most of the U.S. retailers that
provided us with information on internal corporate limits on formaldehyde
in clothing, and the voluntary labeling programs we identified, use the
Japanese test or its equivalent. We tested 21 of the 180 items using both
the Japanese test and the AATCC test. This latter test is used by some U.S.
retailers that have established corporate limits on formaldehyde and has
been used in some studies cited in government reviews, trade
publications, and the medical literature. The 21 items tested by both
methods were selected to include a similar mix of clothing and bed linens
as the overall sample.
If items contained more than one type of fabric that could potentially
contain varying levels of formaldehyde, the laboratory tested a composite
sample that included equal amounts of these fabrics. Decorative elements
that do not come into direct skin contact, such as sequins, were not
included as part of the composite. This composite approach would tend to
result in formaldehyde levels falling between the highest and lowest levels
in the different fabrics.
In addition, we contacted U.S.-based, publicly owned retailers to
determine if they have internal corporate limits for formaldehyde in
clothing. We contacted 16 retailers and received responses from 14, of
which 13 had limits. We also found information on the Internet on the
limits set by one of the two retailers that did not respond.
Page 32 GAO-10-875 Formaldehyde in Textiles
Appendix II: Objectives, Scope, and
Methodology
To identify regulatory and voluntary labeling programs that may be used in
other countries as well as relevant studies on the levels of formaldehyde in
clothing, we contacted government and European Union officials and
conducted Internet searches. We identified a number of countries that
have regulatory standards for formaldehyde in textiles as well as voluntary
labeling programs. Because of complexities in obtaining translations of
other countries’ formaldehyde laws and regulations into English and
confirming their application within the context of these countries’ legal
systems, we relied primarily on the American Apparel and Footwear
Association for information on formaldehyde limits set in other countries,
including the limits identified as the most stringent.
10
We obtained
information on international worker safety standards for formaldehyde
primarily from a report by HHS’s National Institute for Occupational
Safety and Health.
We conducted this performance audit from September 2009 to August 2010
in accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe that
the evidence obtained provides a reasonable basis for our findings and
conclusions based on our audit objectives.
10
American Apparel and Footwear Association, Restricted Substance List, Release 6 (2010).
Page 33 GAO-10-875 Formaldehyde in Textiles
Appendix III: Voluntary Labeling Programs
Appendix III: Voluntary Labeling Programs
Table 4 lists examples of voluntary labeling programs, which are primarily
used in other countries.
1
Clothing and other items meeting the specified
limits for formaldehyde and other substances would typically display a
label indicating their compliance. The formaldehyde limits in the table are
those applicable to clothing and other textiles that come into direct
contact with the skin.
Table 4: Examples of Voluntary Labeling Programs
Governing body Label name
Formaldehyde limit for
infants/toddlers,
a
in
parts per million
Formaldehyde limit for
children and adults, in
parts per million
Test method
specified (or
equivalent)
European Union European Ecolabel 20 30 Japanese test
Good Environmental Choice
Australia Ltd
Australian Ecolabel 30 30 Japanese or AATCC
tests
b
International Association for
Research and Testing in the
Field of Textile Ecology
Oeko-Tex® Standard
100
Not detectable
c
75 Japanese test
International Working Group
on Global Organic Textile
Standard
Global Organic Textile
Standard
Any level prohibited Any level prohibited Not specified
New Zealand Ecolabelling
Trust
Environmental Choice
New Zealand
30 30 Japanese test
Source: GAO analysis of voluntary labeling programs.
a
The transition from limits applicable to infants/toddlers to those for children and adults, where
applicable, is 3 years of age.
b
Or certified according to the most recent Oeko-Tex® Standard 100.
c
Formaldehyde limit listed as “not detectable” is 16 parts per million.
1
We have identified a few U.S.-based retailers that comply with some voluntary programs,
but they do not generally sell individual items that are labeled to indicate compliance.
Page 34 GAO-10-875 Formaldehyde in Textiles
Appendix IV: Top Ten Exporters of Clothing
to the United States in 2008
Appendix IV: Top Ten Exporters of Clothing
to the United States in 2008
Country Percentage of total U.S. imports
a
China 34.3
Vietnam 6.7
Bangladesh 6.3
Honduras 5.9
Indonesia 4.8
Mexico 4.6
Cambodia 3.9
India 3.9
El Salvador 3.7
Pakistan 3.1
Source: GAO analysis of the Department of Commerce Office for Textiles and Apparel data.
Notes: Data include all apparel imports under notional category 1.
a
By square meter equivalents.
Page 35 GAO-10-875 Formaldehyde in Textiles
Appendix V: Results of Formaldehyde Tests
for a Sample of Clothing and Bed Linens Sold
in the United States
Table 5 shows the results of tests we had performed on 180 items—165
articles of clothing and 15 bed linen items.
Table 5: Information on Items Sold in the United States and Tested for Formaldehyde Levels, 2010
Formaldehyde level in
parts per million
b
Comparison to
most stringent
regulatory
standards for
formaldehyde
a
Item type
Fiber content
identified on
label
Fabric
performance
characteristic
identified on
label or
packaging
Country
identified on
label
Target
customer
Japanese test AATCC test
Exceeds
Dress shirt 100% cotton Wrinkle free China Men 206.1
c
Exceeds
Hat 100% cotton
exclusive of
decoration
None identified China Boys 3 years
of age and
older
192.6
c
Exceeds
Bed linens
(pillow cases)
60% cotton,
40% polyester
Soft finish, easy
care
Bahrain Adults or
children 3
years of age
and older
189.6 550.7
Exceeds
Khakis 100% cotton No iron,
permanent
crease
India Men 169.6
c
Exceeds
Dress shirt 60% cotton,
40% polyester
None identified China Boys 3 years
of age and
older
95.1
c
Exceeds
Bed linens
(pillow cases)
100% cotton Wrinkle free,
easy care, no
ironing needed,
eco-friendly
USA of fabric
imported from
Pakistan
Adults or
children 3
years of age
and older
93.8
c
Exceeds Dress shirt 100% cotton Noniron Indonesia Men 92.6
c
Exceeds Bed linens
(pillow cases)
100% cotton Wrinkle free
performance
Pakistan Adults or
children 3
years of age
and older
89.3
c
Exceeds Bed linens
(crib sheet)
100% cotton Preshrunk Thailand Infants/
toddlers
d
85.4
c
Exceeds U.S. military
combat
uniform pants
50% cotton,
50% nylon
None identified USA Women 75.4 205.5
Meets
Bed linens
(pillow cases)
100% cotton None identified China Adults or
children 3
years of age
and older
72.4
c
Meets
U.S. military
combat
uniform pants
50% cotton,
50% nylon
Insect repellent USA Men 71.0
c
Appendix V: Results of Formaldehyde Tests
for a Sample of Clothing and Bed Linens Sold
in the United States
Page 36 GAO-10-875 Formaldehyde in Textiles
Appendix V: Results of Formaldehyde Tests
for a Sample of Clothing and Bed Linens Sold
in the United States
Formaldehyde level in
parts per million
b
Comparison to
most stringent
regulatory
standards for
formaldehyde
a
Item type
Fiber content
identified on
label
Fabric
performance
characteristic
identified on
label or
packaging
Country
identified on
label
Target
customer
Japanese test AATCC test
Meets Dress shirt 100% cotton Noniron, stain
resistant
Indonesia Men 63.0
c
Meets U.S. military
combat
uniform shirt
50% cotton,
50% nylon
None identified USA Women 57.8
c
Meets Dress pants 100% cotton No iron,
permanent
crease
Vietnam Men 54.3
c
Meets Hat 79% cotton,
19% polyester,
2% other
None identified China Women 50.1
c
Meets Bed linens
(pillow cases)
100% cotton Wrinkle free,
bleach friendly
India Adults or
children 3
years of age
and older
47.9
c
Meets Khakis 100% cotton Wrinkle free,
easy care
Dominican
Republic
Boys 3 years
of age and
older
45.9
c
Meets Polo shirt 100% cotton Minimal
shrinkage, fade
and pill resistant,
nonroll collar
Pakistan Men 45.5
c
Meets T-shirt 100% cotton None identified USA Women 42.5 32.7
Meets Dress pants 100% worsted
wool
(polyester
lining)
Wrinkle and
stain resistant
Mexico Men 41.7
c
Meets Dress shirt 100% cotton Noniron, stain
resistant
Honduras Men 38.0
c
Meets Dress shirt 100% cotton Easy iron Bangladesh Men 37.2
c
Meets Bed linens
(sham)
60% cotton,
40% polyester
None identified Pakistan Boys 3 years
of age and
older
35.9
c
Meets Dress shirt 100% cotton Wrinkle resist Bangladesh Men 32.7
c
Meets Jeans 98% cotton,
2% spandex
None identified China Women 24.0
c
Meets Khakis 100% cotton Stain resistant,
wrinkle free
Assembled in
Nicaragua
Men 23.7 43.2
Meets Blouse 69% cotton,
27% nylon,
4% spandex
None identified China Women 23.5
c
Page 37 GAO-10-875 Formaldehyde in Textiles
Appendix V: Results of Formaldehyde Tests
for a Sample of Clothing and Bed Linens Sold
in the United States
Formaldehyde level in
parts per million
b
Comparison to
most stringent
regulatory
standards for
formaldehyde
a
Item type
Fiber content
identified on
label
Fabric
performance
characteristic
identified on
label or
packaging
Country
identified on
label
Target
customer
Japanese test AATCC test
Meets Dress shirt 60% cotton,
40% polyester
Easy care,
wrinkle resist
Bangladesh Men 22.5 33.1
Meets Hat 100% cotton None identified China Women 22.5
c
Meets Khakis 100% cotton No iron, wrinkle
free, easy care
Bangladesh Men 22.4
c
Meets Scout skirt 100% cotton None identified USA Girls 3 years
of age and
older
21.6
c
Meets Sweatpants 100% cotton None identified Honduras Men 21.0
c
Meets Khakis 97% cotton,
3% elastane
None identified India Women 20.5
c
Meets U.S. military
dress uniform
shirt
65% polyester,
35% cotton
None identified USA Women 20.3
c
Meets Pajamas 100% cotton None identified Thailand Infants/
toddlers
d
Not detectable 24.1
Meets Dress shirt 60% cotton,
40% polyester
Wrinkle free,
stain repellent
Vietnam Men Not detectable 21.8
Meets Dress pants 90% cotton,
10%
cashmere
None identified USA of
imported fabric
Boys 3 years
of age and
older
Not detectable 21.1
Meets Underwear 100% cotton None identified India Women Not detectable 14.0
Meets Bed linens
(crib sheet)
100% cotton
sateen
None identified China Infants/
toddlers
d
Not detectable 13.8
Meets Dress pants 100% cotton Shrink resistant,
wrinkle resistant,
stain repellant,
soil release
Vietnam Men Not detectable 11.1
Meets Dress 54% cotton,
45% polyester,
1% metallic.
Lining: 65%
polyester, 35%
cotton
None identified Bangladesh Girls 3 years
of age and
older
Not detectable 11.0
Meets Bed linens
(crib sheet)
100% cotton Easy care China Infants/
toddlers
d
Not detectable
c
Meets Cargo pants 100% cotton None identified Kenya Infants/
toddlers
d
Not detectable
c
Meets Cargo pants 100% cotton None identified Indonesia Infants/
toddlers
d
Not detectable
c
Page 38 GAO-10-875 Formaldehyde in Textiles
Appendix V: Results of Formaldehyde Tests
for a Sample of Clothing and Bed Linens Sold
in the United States
Formaldehyde level in
parts per million
b
Comparison to
most stringent
regulatory
standards for
formaldehyde
a
Item type
Fiber content
identified on
label
Fabric
performance
characteristic
identified on
label or
packaging
Country
identified on
label
Target
customer
Japanese test AATCC test
Meets Cloth diapers 100% cotton Extra absorbent
and quick drying
China Infants/
toddlers
d
Not detectable
c
Meets Cloth diapers 100% cotton Extra absorbent
and quick drying
China Infants/
toddlers
d
Not detectable
c
Meets Hat 100% cotton None identified China Infants/
toddlers
d
Not detectable
c
Meets Hat 100% cotton
exclusive of
decoration
None identified China Infants/
toddlers
d
Not detectable
c
Meets Jeans 100% cotton
exclusive of
decoration
None identified Indonesia Infants/
toddlers
d
Not detectable
c
Meets Jeans 99% cotton,
1% spandex
None identified Bangladesh Infants/
toddlers
d
Not detectable
c
Meets Pajamas 100% cotton None identified China Infants/
toddlers
d
Not detectable
c
Meets Pajamas 100% cotton None identified China Infants/
toddlers
d
Not detectable
c
Meets Pajamas 100% cotton
exclusive of
decoration
None identified China Infants/
toddlers
d
Not detectable
c
Meets Romper 100% combed
cotton
None identified USA Infants/
toddlers
d
Not detectable
c
Meets Romper 100% cotton None identified China Infants/
toddlers
d
Not detectable
c
Meets Romper 100% cotton None identified China Infants/
toddlers
d
Not detectable
c
Meets Romper 100% cotton None identified China Infants/
toddlers
d
Not detectable
c
Meets Set (dress
and leggings)
100% cotton None identified China Infants/
toddlers
d
Not detectable Not
detectable
Meets Set (romper,
pants, and
bib)
100%
cotton/80%
cotton, 20%
polyester
None identified China Infants/
toddlers
d
Not detectable
c
Meets Set (top and
bottom)
100% cotton None identified China Infants/
toddlers
d
Not detectable
c
Meets Set (top and
bottom)
100% cotton None identified Thailand Infants/
toddlers
d
Not detectable
c
Page 39 GAO-10-875 Formaldehyde in Textiles
Appendix V: Results of Formaldehyde Tests
for a Sample of Clothing and Bed Linens Sold
in the United States
Formaldehyde level in
parts per million
b
Comparison to
most stringent
regulatory
standards for
formaldehyde
a
Item type
Fiber content
identified on
label
Fabric
performance
characteristic
identified on
label or
packaging
Country
identified on
label
Target
customer
Japanese test AATCC test
Meets Set (top and
bottom)
Shell: 100%
cotton
exclusive of
decoration
None identified China Infants/
toddlers
d
Not detectable
c
Meets Set (tops and
bottom)
100% cotton None identified China Infants/
toddlers
d
Not detectable
c
Meets Socks 82% cotton,
15% nylon,
2% spandex,
1% rubber
None identified China Infants/
toddlers
d
Not detectable
c
Meets Sweatpants 100% cotton None identified Bangladesh Infants/
toddlers
d
Not detectable
c
Meets Sweatpants 100% cotton None identified China Infants/
toddlers
d
Not detectable
c
Meets T-shirt 100% cotton None identified China Infants/
toddlers
d
Not detectable
c
Meets T-shirt 100% cotton None identified El Salvador Infants/
toddlers
d
Not detectable
c
Meets T-shirt 100% cotton None identified Guatemala Infants/
toddlers
d
Not detectable
c
Meets T-shirt 100% cotton None identified Guatemala Infants/
toddlers
d
Not detectable
c
Meets T-shirt 100% cotton None identified Thailand Infants/
toddlers
d
Not detectable
c
Meets Bed linens
(pillow cases)
60% cotton,
40% polyester
None identified Pakistan Boys 3 years
of age and
older
Not detectable
c
Meets Cargo pants 100% cotton None identified Bangladesh Boys 3 years
of age and
older
Not detectable
c
Meets Dress pants 55% linen,
45% rayon
None identified China Boys 3 years
of age and
older
Not detectable
c
Meets Jeans 100% cotton None identified Bangladesh Boys 3 years
of age and
older
Not detectable
c
Meets Pajamas 100% cotton None identified China Boys 3 years
of age and
older
Not detectable
c
Meets Polo shirt 100% organic
cotton
None identified India Boys 3 years
of age and
older
Not detectable
c
Page 40 GAO-10-875 Formaldehyde in Textiles
Appendix V: Results of Formaldehyde Tests
for a Sample of Clothing and Bed Linens Sold
in the United States
Formaldehyde level in
parts per million
b
Comparison to
most stringent
regulatory
standards for
formaldehyde
a
Item type
Fiber content
identified on
label
Fabric
performance
characteristic
identified on
label or
packaging
Country
identified on
label
Target
customer
Japanese test AATCC test
Meets Polo shirt 60% cotton,
40% polyester
None identified Lesotho Boys 3 years
of age and
older
Not detectable
c
Meets Scout pants 67% cotton,
33% polyester
None identified USA Boys 3 years
of age and
older
Not detectable
c
Meets Scout shirt 67% cotton,
33% polyester
None identified Bangladesh Boys 3 years
of age and
older
Not detectable
c
Meets Sweatpants
(shorts)
100% cotton None identified Vietnam Boys 3 years
of age and
older
Not detectable
c
Meets T-shirt 100% cotton None identified Honduras Boys 3 years
of age and
older
Not detectable
c
Meets T-shirt 100% cotton None identified Honduras Boys 3 years
of age and
older
Not detectable
c
Meets Underwear 100% cotton None identified China Boys 3 years
of age and
older
Not detectable Not
detectable
Meets Bed linens
(pillow cases)
60% cotton,
40% polyester
None identified Pakistan Girls 3 years
of age and
older
Not detectable
c
Meets Blouse 100% cotton None identified China Girls 3 years
of age and
older
Not detectable
c
Meets Bra 95% cotton,
5% spandex
None identified Bangladesh Girls 3 years
of age and
older
Not detectable
c
Meets Bra 95% cotton,
5% spandex,
inner cup:
100%
polyester
(padded)
None identified China Girls 3 years
of age and
older
Not detectable
c
Meets Dress 100% cotton None identified Vietnam Girls 3 years
of age and
older
Not detectable
c
Page 41 GAO-10-875 Formaldehyde in Textiles
Appendix V: Results of Formaldehyde Tests
for a Sample of Clothing and Bed Linens Sold
in the United States
Formaldehyde level in
parts per million
b
Comparison to
most stringent
regulatory
standards for
formaldehyde
a
Item type
Fiber content
identified on
label
Fabric
performance
characteristic
identified on
label or
packaging
Country
identified on
label
Target
customer
Japanese test AATCC test
Meets Dress 100% cotton.
Mesh—100%
polyester,
exclusive of
decoration
None identified China Girls 3 years
of age and
older
Not detectable
c
Meets Dress pants 97% cotton,
3% spandex
None identified China Girls 3 years
of age and
older
Not detectable
c
Meets Jeans 56% ramie,
25% cotton,
18% polyester,
1% spandex
None identified China Girls 3 years
of age and
older
Not detectable Not
detectable
Meets Khakis 100% cotton None identified Bangladesh Girls 3 years
of age and
older
Not detectable
c
Meets Polo shirt 100% cotton
exclusive of
decoration
None identified Vietnam Girls 3 years
of age and
older
Not detectable
c
Meets Scout shirt 65% polyester,
35% cotton
None identified USA Girls 3 years
of age and
older
Not detectable
c
Meets T-shirt 100% cotton None identified Mexico of USA
Parts
Girls 3 years
of age and
older
Not detectable
c
Meets T-shirt 95% cotton,
5% spandex
None identified USA Girls 3 years
of age and
older
Not detectable
c
Meets Underwear 95% cotton,
5% spandex
None identified China Girls 3 years
of age and
older
Not detectable
c
Meets Bed linens
(fitted sheet)
100% cotton
exclusive of
decoration
None identified China Adults or
children 3
years of age
and older
Not detectable
c
Meets Bed linens
(flat sheet)
60% pima
cotton, 40%
polyester
Easy care China Adults or
children 3
years of age
and older
Not detectable
c
Meets Bed linens
(pillow cases)
100% cotton None identified China Adults or
children 3
years of age
and older
Not detectable
c
Page 42 GAO-10-875 Formaldehyde in Textiles
Appendix V: Results of Formaldehyde Tests
for a Sample of Clothing and Bed Linens Sold
in the United States
Formaldehyde level in
parts per million
b
Comparison to
most stringent
regulatory
standards for
formaldehyde
a
Item type
Fiber content
identified on
label
Fabric
performance
characteristic
identified on
label or
packaging
Country
identified on
label
Target
customer
Japanese test AATCC test
Meets Bed linens
(pillow cases)
60% cotton,
40% polyester
Easy care,
wrinkle resistant
China Adults or
children 3
years of age
and older
Not detectable
c
Meets Cargo pants 100% cotton None identified Egypt Men Not detectable
c
Meets Dress pants 100% wool None identified Vietnam Men Not detectable
c
Meets Dress pants 60% cotton,
40% polyester
Easy care Bangladesh Men Not detectable
c
Meets Dress pants Shell: 100%
cotton
None identified China Men Not detectable
c
Meets Dress shirt 100% cotton Easy iron Bangladesh Men Not detectable
c
Meets Dress shirt 100% cotton Easy care Bangladesh Men Not detectable
c
Meets Dress shirt 100% cotton None identified USA Men Not detectable
c
Meets Dress shirt 55% cotton,
45% polyester
Wrinkle free Vietnam Men Not detectable
c
Meets Dress shirt 60% cotton,
40% polyester
exclusive of
decoration
Easy care Bangladesh Men Not detectable
c
Meets Hat 100% cotton Moisture
management
China Men Not detectable
c
Meets Hat 100% cotton
exclusive of
decoration
None identified China Men Not detectable
c
Meets Hat 97% cotton,
3% P.U.
spandex
None identified Bangladesh Men Not detectable Not
detectable
Meets Jeans 100% Cotton None identified India Men Not detectable
c
Meets Jeans 100% cotton None identified Mexico Men Not detectable
c
Meets Jeans 100% cotton None identified Mexico Men Not detectable
c
Meets Khakis 100% combed
cotton
Wrinkle resistant Bangladesh Men Not detectable
c
Meets Khakis 100% combed
cotton
None identified USA Men Not detectable
c
Meets Khakis 100% cotton No iron, wrinkle
free, permanent
crease, polished
finish
Vietnam Men Not detectable
c
Page 43 GAO-10-875 Formaldehyde in Textiles
Appendix V: Results of Formaldehyde Tests
for a Sample of Clothing and Bed Linens Sold
in the United States
Formaldehyde level in
parts per million
b
Comparison to
most stringent
regulatory
standards for
formaldehyde
a
Item type
Fiber content
identified on
label
Fabric
performance
characteristic
identified on
label or
packaging
Country
identified on
label
Target
customer
Japanese test AATCC test
Meets Khakis 100% cotton Shrink resistant,
wrinkle resistant,
stain repellant,
soil release
Vietnam Men Not detectable
c
Meets Pajama pants 100% cotton None identified Cambodia Men Not detectable
c
Meets Polo shirt 100% cotton None identified India Men Not detectable
c
Meets Polo shirt 100% cotton
exclusive of
decoration
None identified India Men Not detectable
c
Meets Polo shirt 60% cotton,
40% polyester
Easy care Indonesia Men Not detectable
c
Meets Polo shirt 65% cotton,
35% polyester
Easy care,
wrinkle resistant,
super soft touch
China Men Not detectable
c
Meets Socks 84% cotton,
15% nylon,
1% spandex
None identified USA Men Not detectable
c
Meets Sweatpants
(shorts)
100% cotton None identified Honduras Men Not detectable
c
Meets T-shirt 100% cotton None identified China Men Not detectable
c
Meets T-shirt 100% cotton None identified Mexico Men Not detectable
c
Meets T-shirt 100% cotton None identified Pakistan Men Not detectable
c
Meets T-shirt 100% cotton None identified USA Men Not detectable
c
Meets U.S. military
combat
uniform shirt
50% cotton,
50% nylon
Insect repellent USA Men Not detectable
c
Meets U.S. military
dress uniform
shirt
75% polyester,
25% wool
None identified USA Men Not detectable
c
Meets Underwear 100% combed
cotton
Antimicrobial,
pre-shrunk
Bangladesh Men Not detectable
c
Meets Underwear 100% cotton None identified Bangladesh Men Not detectable
c
Meets Underwear 100% cotton None identified Honduras Men Not detectable
c
Meets Blouse 100% cotton None identified Indonesia Women Not detectable Not
detectable
Meets Blouse 65% cotton,
35% silk
None identified China Women Not detectable
c
Meets Blouse 68% cotton,
28% nylon,
4% spandex
None identified China Women Not detectable
c
Page 44 GAO-10-875 Formaldehyde in Textiles
Appendix V: Results of Formaldehyde Tests
for a Sample of Clothing and Bed Linens Sold
in the United States
Formaldehyde level in
parts per million
b
Comparison to
most stringent
regulatory
standards for
formaldehyde
a
Item type
Fiber content
identified on
label
Fabric
performance
characteristic
identified on
label or
packaging
Country
identified on
label
Target
customer
Japanese test AATCC test
Meets Bra 95% cotton,
5% lycra
None identified Bangladesh Women Not detectable
c
Meets Bra Body/cup:
80% nylon,
20% lycra.
Back lining:
84% polyester,
16% lycra
None identified China Women Not detectable Not
detectable
Meets Cargo pants 97% cotton,
3% spandex
None identified China Women Not detectable
c
Meets Cargo pants 98% cotton,
2% spandex
None identified Bangladesh Women Not detectable
c
Meets Dress 100% cotton None identified China Women Not detectable
c
Meets Dress 100% cotton None identified Indonesia Women Not detectable
c
Meets Dress pants 54% linen,
44% cotton,
2% spandex
None identified Vietnam Women Not detectable
c
Meets Dress pants 97% cotton,
3% spandex
None identified Vietnam Women Not detectable
c
Meets Dress pants 97% wool, 3%
spandex
None identified China Women Not detectable
c
Meets Dress pants 98% cotton,
2% spandex
None identified China Women Not detectable
c
Meets Dress shirt 100% cotton None identified Bangladesh Women Not detectable
c
Meets Dress shirt 100% cotton None identified Sri Lanka Women Not detectable
c
Meets Dress shirt 100% cotton None identified USA Women Not detectable
c
Meets Dress shirt 60% cotton,
37% polyester,
3% spandex
Easy care China Women Not detectable
c
Meets Dress shirt 96% cotton,
4% spandex
None identified Bangladesh Women Not detectable
c
Meets Dress shirt 96% cotton,
4% spandex
None identified China Women Not detectable Not
detectable
Meets Dress shirt 97% cotton,
3% spandex
None identified China Women Not detectable
c
Meets Dress shirt 97% cotton,
3% spandex
None identified China Women Not detectable
c
Meets Dress shirt 97% cotton,
3% spandex
None identified Indonesia Women Not detectable
c
Page 45 GAO-10-875 Formaldehyde in Textiles
Appendix V: Results of Formaldehyde Tests
for a Sample of Clothing and Bed Linens Sold
in the United States
Formaldehyde level in
parts per million
b
Comparison to
most stringent
regulatory
standards for
formaldehyde
a
Item type
Fiber content
identified on
label
Fabric
performance
characteristic
identified on
label or
packaging
Country
identified on
label
Target
customer
Japanese test AATCC test
Meets Dress skirt 71% polyester,
26% rayon,
3% spandex
Washable
stretch, minimum
care required
China Women Not detectable
c
Meets Dress skirt 97% cotton,
3% spandex
None identified Sri Lanka Women Not detectable Not
detectable
Meets Jeans 100% cotton None identified USA Women Not detectable
c
Meets Khakis 96% cotton,
4% spandex
None identified Indonesia Women Not detectable
c
Meets Khakis 97% cotton,
3% spandex
None identified Vietnam Women Not detectable
c
Meets Khakis 97% cotton,
3% spandex
None identified China Women Not detectable
c
Meets Khakis 98% cotton,
2% spandex
None identified China Women Not detectable
c
Meets Khakis 98% cotton,
2% spandex
None identified Vietnam Women Not detectable
c
Meets Polo shirt 100% organic
cotton
Soft hand, shrink
resistant
Vietnam Women Not detectable
c
Meets Polo shirt 95% pima
cotton, 5%
spandex
None identified Vietnam Women Not detectable
c
Meets Socks 76% cotton,
21% nylon,
3% lycra
None identified Pakistan Women Not detectable
c
Meets Socks 77% cotton,
18% polyester,
3% natural
latex rubber,
1% spandex
None identified USA Women Not detectable
c
Meets Sweatpants 85% cotton,
15% polyester
None identified Cambodia Women Not detectable
c
Meets Sweatpants 90% cotton,
10% spandex
None identified Bangladesh Women Not detectable
c
Meets T-shirt 100% cotton None identified Assembled in
Guatemala
Women Not detectable
c
Meets T-shirt 100% cotton None identified China Women Not detectable Not
detectable
Meets T-shirt 100% cotton Pre-shrunk Honduras Women Not detectable
c
Meets T-shirt 100% cotton None identified Thailand Women Not detectable
c
Page 46 GAO-10-875 Formaldehyde in Textiles
Appendix V: Results of Formaldehyde Tests
for a Sample of Clothing and Bed Linens Sold
in the United States
Formaldehyde level in
parts per million
b
Comparison to
most stringent
regulatory
standards for
formaldehyde
a
Item type
Fiber content
identified on
label
Fabric
performance
characteristic
identified on
label or
packaging
Country
identified on
label
Target
customer
Japanese test AATCC test
Meets Underwear 92% cotton,
8% spandex
None identified China Women Not detectable
c
Meets Underwear 95% cotton,
5% spandex
None identified Bangladesh Women Not detectable
c
Source: GAO analysis of information provided on items’ labels or packaging and test data from an accredited commercial laboratory.
a
As compared with the most stringent regulatory standards for formaldehyde identified by the
American Apparel and Footwear Association, Restricted Substance List, Release 6, 2010.
b
Formaldehyde levels listed as “not detectable” are below 20 parts per million for the Japanese test
and 10 parts per million for the AATCC test.
c
This item was tested only by the Japanese test.
d
Infants/toddlers refers to children younger than 3 years of age.
Page 47 GAO-10-875 Formaldehyde in Textiles
Appendix VI:
A
GAO Contact and Staff
cknowledgments
Page 48 GAO-10-875
Appendix VI: GAO Contact and Staff
Acknowledgments
John B. Stephenson, (202) 512-3841 or [email protected]
In addition to the contact named above, Christine Fishkin, Assistant
Director; Gezahegne Bekele; Mark Braza; Antoinette Capaccio; Keya
Chateauneuf; Nancy Crothers; Lorraine Ettaro; Melissa King; Nathan A.
Morris; and Ruth Solomon made key contributions to this report.
Formaldehyde in Textiles
GAO Contact
Staff
Acknowledgments
(361113)
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