Policy Textile Metal Contamination Standard

Transcription

1 Policy Textile Metal Contamination Standard Date: 23 rd January 2013 QUALITY DEPARTMENT For clarification of any Kmart Standards, contact: Kmart Quality Team 690 Springvale Road Mulgrave Victoria 3170 Australia Tel: (03) Policy - Textile Metal Contamination (V ) Q U A L I T Y

2 Table of Contents Introduction... 3 Vendor s Responsibilities... 3 Kmart: Incident Response... 4 Sewing Needle Control Process... 5 Broken Needle Process... 5 Sewing Machine Needles and Consumable Production equipment Process... 6 Distribution and Transaction Records for Needles and Consumables... 7 Metal Contamination (other than Sewing Needles)... 8 Trims and Components... 8 Other metal contaminants... 8 Products with metallic components... 9 Footwear... 9 Footwear: No Tack Policy... 9 Metal Detectors and Processes Requirements for the use of metal detectors: Metal Detector Calibration & Maintenance Calibration Maintenance Appendix 1: Broken Needle Register or amended for consumables records Appendix 2: Broken Needle images Appendix 3: Sharp Objects Appendix 4: Metal Detector Activity Log Appendix 5: Calibration records Policy - Textile Metal Contamination (V ) Page 2 of 16

3 Introduction The purpose of needle and metal contamination processes in the manufacture of textile and footwear goods is to minimise the risk of metal contaminants that can potentially cause harm to Kmart customers. Products covered by this Policy (hereafter referred to as Products) include but are not limited to: ALL Apparel (including outerwear and underwear for all departments, childrens, womens and mens), Home Textiles (bedding, bed linen, cushions etc), Accessories, bags (handbags, luggage etc), soft accessories (hats, scarves etc) Toy Textiles (play costumes, soft-filled plush items), Footwear Other product groups especially in general merchandise may use sections within this policy as they can be similar manufacturing practises. These will be highlighted within specific product standards. Vendor s Responsibilities Kmart Vendors are responsible to make sure their manufacturing facilities are operating to good manufacturing practices [GMP] appropriate to the products produced and are capable in meeting Kmart s metal contamination policy at all times. It is envisaged the vendor will maintain audit controls relating to this policy. Both the vendor s audit records and the factory s GMP controls are to be made available for Kmart s supplier audit processes and final inspection process. All production facilities used for producing Products must have processes in place that cover all areas of possible metal contamination. The processes or procedures that must be in place are: 1. Sewing Needle Replacement Process 2. Broken Needle Process 3. Metal Contamination Control Points (other than Machine Sewing Needles) 4. Metal Detector Processes: Standards for operation and maintenance All of these processes help to eliminate the possible risk of metal contamination to our customers. Trims and fasteners used within textile products and footwear can include metal components (e.g. zippers, studs, buttons, embellishments). Wherever possible, non-ferrous 1 trims should be selected as this allows the metal detection process to be effective. An example of this is using non-ferrous trims, plastic zips etc. Where the use of metal trims is necessary, attachment of such trims should occur in the latest possible stage of production. It is an expectation that metal detection processing occurs just prior to the attachment of metallic trims to ensure that the risk of metal contamination is minimal. Our expectation is that vendors ensure that all facilities have metal contamination processes in place. Our expectation is that both overseas and local vendors and manufacturers have clear documented processes that include our requirements and are available for audit when and where required. 1 Non Ferrous: Not composed of or containing iron and alloys that do not contain an appreciable amount of iron. Policy - Textile Metal Contamination (V ) Page 3 of 16

4 Kmart: Incident Response If metal contamination such as a broken needle, hand sewing needle, pins or sharp metal objects are found by our customers the, following will occur: One incident: All parties commence a detailed investigation with an objective of identifying the critical points of failure within the procedure or process. Based on outcomes of the review, courses of action may include: Vendor/factory to submit a full and complete Corrective Action Plan, to be approved by the relevant Product Technologist. Compliance retraining, typically through the use of third party services at vendor s/factory s expense A fine imposed on the vendor taking into account the scale of exercises and costs incurred by Kmart and KAS Two incidents within 18 months: All parties commence a detailed investigation with an objective of identifying the critical points of failure within the procedures or processes. Reference must be made back to the previously submitted/approved Corrective Action Plan. Based on outcomes of the review, courses of action may include: Vendor/factory to submit a full and complete corrective action plan, to be approved by the relevant Product Technologist. Compliance retraining, typically through the use of third party services at vendor s/factory s expense A fine levied on the vendor commensurate with the scale of exercises and costs incurred by Kmart and KAS A fine levied on the vendor as a penalty for a recurrent breach In the event that the second breach is attributed to systematic or deliberate departure from the Policy, the Vendor may be deregistered as a Kmart supplier Three incidents within 18 months: A third incident within an 18 month period will result in the vendors being immediately deregistered as a Kmart vendor. Policy - Textile Metal Contamination (V ) Page 4 of 16

5 Sewing Needle Control Process Broken Needle Process When needle breakage occurs in production, adequate controls must be in place to manage the exchange of broken needles with new needles and to prevent operators from substituting broken needles with non-approved needles. Monitoring and management of broken needles is to be tracked through the use of a Broken Needle Register. A Broken Needle Register would typically include the following information: Location / Sewing room Kmart style number Operator Details Machine Details Date, time, location Supervisor s signature. Action taken In the event of needle breakage 2, machinist/operator must: Locate all pieces of the broken needle Provide all pieces of the broken needle to the Supervisor in exchange for a new needle Upon receipt of the broken needle pieces from the machinist/operator, the supervisor must: Firstly confirm that all pieces of the broken needle have been provided by the machinist/operator Provide the machinist/operator with a replacement needle Log the details of the broken needle replacement into the Broken Needle Register, and Mount all of the pieces of the broken needle into the Broken Needle Register If the entire needle cannot be re-assembled: If fragments have been located but cannot be removed from the product, the affected product is to be isolated and destroyed. This should be marked into the Broken Needle Register If fragments cannot be located, all product from the bundle is to be isolated into the quarantine area. The bundle may pass through metal detection to locate the missing needle fragment, after which the bundle may be returned to production. Alternatively, the bundle may be destroyed. These records are to be kept in a secure location in the sewing area and made available upon request. All employees within the production environment are to be trained on the broken needle process. Training is to be documented and records maintained. If substantial broken needles are found during metal detection, it indicates that the Broken Needle Process control procedures are not effective and should be evaluated immediately. Production must stop until corrective action is instigated and is documented. 2 Refer to Appendix A and Appendix B for images of needle breakages and for format of a Broken Needle Register Policy - Textile Metal Contamination (V ) Page 5 of 16

6 Sewing Machine Needles and Consumable 3 Production equipment Process Sewing Machine Needles and consumables: Only needles and consumables that have been provided by the factory are permitted to be used in production. Factories should have a documented procedure that communicates this requirement to employees and includes procedures that enforce compliance with this requirement. The procedure must contain the elements below: All employees are to be trained in the sewing needle or consumable replacement procedures (including the Broken Needle Process). Training is to be documented and records are to be maintained. Only needles and consumables supplied by the manufacturing facility are to be used within the facility. No operator should be in possession of more needles or consumables than is required to operate his/her machine or if hand sewing, only the needle that is required to perform the task. New needles and consumables are to be issued only upon receipt of old needle or consumable, on a one for one replacement system. All spare needles or consumables are to be held by a supervisor (or other nominated person) in a secure location. Only supervisors are permitted to allocate / issue needles or consumables. Needle and consumable distribution records are to be documented and records are to be maintained. Sewing machine needles and consumables are to be checked regularly by a supervisor or designated sewing machine mechanic to ensure that they are in good working condition. Maintenance should be documented and records are to be maintained. Mechanics (A person who repairs and maintains machinery, namely sewing machines) should be aware of the needle and consumable replacement policy and ensure that no spare needles or consumables are left on the shop floor. The factory should conduct daily/weekly reviews of needle and consumable replacement records to identify needle replacement trends for: Machine operators Sewing machines Product types Needle types If substantial broken needles and consumables are found during metal detection, it indicates that the needle control procedures are not effective and should be evaluated immediately. Production must stop until corrective action is instigated and is documented. 3 Consumable: Items that are replaced regularly because they wear out or are broken examples of these are syringes, scissors, cutting blades, knitting needles. Policy - Textile Metal Contamination (V ) Page 6 of 16

7 Distribution and Transaction Records for Needles and Consumables Factories should maintain a log/register 4 that traces the movement of needles and consumables from time of receipt through till the needles and consumables end-life. The log/register should capture the flow of needles as they move from the supplies-store, are issued into production and as needles and consumables are removed from production (e.g. As broken or blunt needles). Records need to be consolidated on a regular basis to ensure there is a balance between needles being issued into production and those being withdrawn from production. An imbalance may indicate non-compliance with the sewing needle and consumables replacement process (ie. Operators using their own needles) or indicate that the exchange with broken/used needles is not being effectively managed. The consolidated records are to include: The number of and type of needles and consumables purchased The number of and type of needles and consumables issued and location to where they were issued. The number of worn needles and consumables returned The number of broken needles and consumables returned The number of needle fragments and consumables found by detector The number of missing needle fragments Number of needle and consumable incidents 5 or claims. 4 The log/register may actually be a series of different logs held in different production environments, but must be of a type that allows regular consolidation 5 Incidents: Metal contamination detected by retailer or consumer Policy - Textile Metal Contamination (V ) Page 7 of 16

8 Metal Contamination (other than Sewing Needles) Trims and Components Other metal objects that can present a metal contamination can be a result of trims that are attached to the final product such as: Rivets, poppers, snaps Zips and zip pullers Buttons, buckles, studs Badges, diamantes, chains Apart from sharp and pointy edge hazards created by accessory contaminants, these accessories can also create small part choking/ingestion hazards. Strict distribution & control processes must be employed to manage & monitor the use of these small accessories: For both manual and automated attachment processes. Please refer to the Apparel Snap Standard for guidance on the control of snaps/press-studs. Any fabric that is brushed must go through metal detection in the facility in which it is brushed. This mostly effects fabric mills and home textile vertical vendors where fabrics are brushed. Other metal contaminants Metal objects other than sewing needles can also pose a metal contamination concern6. Many metallic components and accessories occur within production, including: pins, staples, safety pins, knitting machine needles, linking pins, scissors, snippers, pincers, syringes nails, tacks, screws, knives and other cutting tools Such items have the potential to cause serious injury if they were to be either left in or attached to a product. All metal objects used within production must remain within controlled areas and must be accountable within shifts by their operators. There should be an allocation & control system for sharp metal tools used within a manufacturing area as with the consumable production equipment process. Wherever possible, manufacturers should eliminate the use of sharp metallic objects from the manufacturing process. Elimination techniques include: Adhesive labels for fault identification rather than pins. Clamps to hold fabric lies rather than lay pins or staples. Adhesive lay markers. Vacuum cutting tables. Scissors, clippers and knives are to be tied to the workstation or secured to the operator at all times to prevent potential loss within products. Only shift-authorised factory tools are to be used in the process areas. Pins and staples should also be removed from peripheral, non-production areas to prevent inadvertent contamination of products. This includes pins used for information boards. Razors should not be used as a cutting implement (e.g. for stripping binding). If this type of cutter is required then a modelling knife/scalpel with a secure blade should be used. Replacement cutters should be issued on a one for one basis and records maintained. 6 Refer Appendix 3 for examples Policy - Textile Metal Contamination (V ) Page 8 of 16

9 Cutting implements with disposable blades are not to be used within production unless there is no other option. When used, replacement blades should be issued on a one for one basis and records maintained. Any broken pieces from razors, blades or other cutting equipment must be accounted for in the same way as broken sewing machine needles. If metal fragments are regularly found during metal detection procedure, it indicates that processing equipment requires maintenance and should be investigated. Production must stop until corrective action is instigated and is documented. Products with metallic components Where iron / ferrous trims are used on products, metal detection is to take place before the trims are attached / added. This should be at the latest possible stage in the production process prior to their attachment. For products that cannot go through a metal detector (e.g. underwire bras) and product that has iron trims, the needle replacement, broken needle control and metal contamination processes must be vigilant and well documented. Metal detection is to take place prior to the metal component attachment. Additionally, 100% of these items must be manually checked in place of passing through a metal detector. All embroidered components must pass through metal detection prior to their transfer to the sewing section within production. Footwear Syringes: If there is no other option or alternative in the production process, then the syringe MUST be attached to the work station. Distribution of Syringes: The issuing of new & replacement syringes used within footwear manufacture must be controlled to the same standards of diligence as broken needles (e.g. one-for-one replacement, records maintained) In footwear: All uppers must go through a metal detector after stitching and before the application of any metal components All metal free and infant shoes must be put through metal detection before packing. All footwear must be packed immediately after metal detection and a stamp PMD (passed metal detection) must be on the carton. All footwear with metal components / accessories must have a 100% hand touch check prior to packing for sharp point and edges. Footwear: No Tack Policy Kmart has a No Tack Policy in regard to the attachment of insole to the last for all footwear manufacture. Other alternatives methods of attachment must be applied which are using a non-metallic procedure such as: elastic rubber band hot melt adhesive adhesive pads No footwear will be accepted if an insole tack or staple issue is found. Heavy penalties will be applied if such issues are identified. If the lasting process requires tacking to take place due to the design or the materials used, then an application for approval must be submitted and signed off by KAS QA. Policy - Textile Metal Contamination (V ) Page 9 of 16

10 Metal Detectors and Processes Metal detectors used within textile, footwear and apparel industries are engineered to detect ferrous or iron contaminants. The majority of possible hazardous contaminants within the textile environment are iron or ferrous based (e.g. sewing needles, teeth / bristle from brushing equipment). Metal detectors are unable to detect non-ferrous contaminants (e.g.. Aluminium, nickel). All Kmart products must pass through a metal detector. Requirements for the use of metal detectors: The following specifies the functionality of metal detectors and best-practices for use of metal detectors: Operational: Operators must wear metal free garments with no jewellery or accessories as this may affect detector readings. Operators must record details of all products passed through the metal detector. Refer to Appendix 4 for an example of an activity log. A stable, clean environment that does not interfere with the operations of the detector (e.g. no abnormal vibrations, free from metal clutter e.g. metal detector is to be metal free within a range of 1m in any direction) All metal contamination found is to be documented in a metal detection log, electronic data capture is the best method. If there is no electronic data capture, a manual log is to be used, detections logged and records maintained. An example of an activity log can be found in Appendix 4 Rejected product must be completely isolated / quarantined from the rest of the stock. This product is either destroyed or reworked. This is to be documented in the action taken section of the Metal Detector Activity Log. All reworked products must again pass through the metal detection process. Equipment: Tunnel conveyor metal detectors must be positioned in such a way that separates checked and unchecked product. There must be a physical barrier so that product has to be placed on the conveyor in order to complete the production process. An example of the physical barrier would at least 2m in height. Metal detectors are to be positioned so that there is a clear physical separation between the area where product has NOT gone through detection and where product HAS gone through metal detection. This physical separation or barrier shall allow for movement only in one direction. If a product fails metal detection it should be collated in a well-defined quarantine area for either re-work or to be destroyed. The aperture size of the metal detector must be applicable for the product (e.g. for apparel 100mm or higher; for pillows and quilts, a size applicable for the height of the product). When the aperture size is large, the sensitivity of the detector must be set to detect metal contamination Hand held metal detectors may be used alongside tunnel metal detectors, but not used in place of tunnel metal detectors. Use of hand held metal detectors is acceptable during the inline inspection process and to assist finding metal fragments in products identified through tunnel detectors. For example: Finding metal teeth in brushed fabrics as part of in-line procedures. Detecting sensitivity must be compatible with the product and the aperture size(e.g. 1.2mm iron ball sensitivity should replicate what is used in manufacture) for example 1.2mm sensitivity since sewing machine needles are this diameter in production and the aperture size is less than 50mm. Calibration standards must align with the recommended procedures as specified by the metal detector manufacturer: For both tunnel and hand-held devices. It is critical that operators do not tamper, fiddle or try to adjust the metal detector unless they are authorised. Constant speed horizontal conveyor belt, allowing good movement of product. Metal detectors must be fitted with an automatic stop system once metal is detected and must not be capable of automatically restarting. Policy - Textile Metal Contamination (V ) Page 10 of 16

11 Metal Detector Calibration & Maintenance Calibration Each metal detector requires a written calibration procedure, for that specific model, available within the working area. This should be kept with the calibration records. Metal detectors are to be calibrated at a minimum of: the beginning of each shift after any stoppage after maintenance. The start of each style Calibration is to be carried out by a trained, authorised person. Training should be conducted by the metal detector supplier. A 9 point process is to be used e.g. three point top (left, middle right), three point centre (left, middle right), three point bottom (left, middle right). Calibration records are to be maintained, they are to include: Date Time Product / style number manufactured at that date / time Outcome (this should state the result from all points) Corrective action required Signature of calibrator. Calibration records are to be checked daily by a supervisor. An example of calibration records can be found in appendix 5. If the detector fails a calibration check, all products in the previous lot or batch must be re-checked once the detector has been repaired. This must be recorded and corrective actions noted. Product between calibrations is to be held in a quarantine area until results of the last batch or lot are available and have been evaluated, there may be a need for this product to be re-checked. Maintenance All personnel involved in the use of metal detection units must be trained by the supplier of the units to understand the systems, the operation procedures and how to make or correct necessary adjustments. Records of training authorised operators and nominated persons responsible for the operation of the units need to be documented and kept. The metal detector unit must be serviced as specified in maintenance requirements from the supplier. Maintenance records must be documented and kept. Policy - Textile Metal Contamination (V ) Page 11 of 16

12 Appendix 1: Broken Needle Register or amended for consumables records NEEDLE BREAKAGE RECORD Location / Sewing room / Area: Kmart style No:.. Date Time Operator Name / Machinist No. Machine No. Needle Brand Type of Machine Supervisors Signature Needle **Attach all needle fragments below Action Taken 21/4/ am A Smith 5 Butterfly Coverstitch N Fung Full needle recovered, production continued 30/6/ am J Citizen 14 Schmetz Plain Machine N Fung Full needle recovered, production continued 30/6/ am J Citizen 14 Schmetz Plain machine N FUng Product destroyed, bundle placed in quarantine for destruction Policy - Textile Metal Contamination (V ) Page 12 of 16

13 Appendix 2: Broken Needle images Correct Intact Needle Correct Broken Needle All Parts Retrieved Incorrect Broken Needle Missing Parts Incorrect Broken Needle Missing Parts Policy - Textile Metal Contamination (V )

14 Appendix 3: Sharp Objects staples Pins Safety pins Single side razor Knitting machine needles (Loose) Utility knife Snippers (tied to work station) Scissors (tied to work station) Safety knife (box cutter) (tied to work station) Pliers (tied to work station) Scalpel (1 piece) Pincer (tied to work station) Nails Screws Knitting transfer tools(secured to work station) Syringe & needle Syringe Kimble gun (secured to work station) Policy - Textile Metal Contamination (V ) Page 14 of 16

15 Appendix 4: Metal Detector Activity Log METAL CONTAMINATION DETECTION LOG Location / sewing room / area:.. Kmart Style No:. Date Time Inspected Quantity Location of contaminant found Contaminant (Tape here) Operators signature Action taken Supervisor signature Date / Time Policy - Textile Metal Contamination (V ) Page 15 of 16

16 Appendix 5: Calibration records Date Time Style Position Operator s signature Supervisor Date Signature Policy - Textile Metal Contamination (V ) Page 16 of 16