OekoTex on the BMS mud pants test
The findings obtained in the Oko-Test test for the parameters examined for the mud pants do not give rise to any complaints with regard to your STANDARD 100 by OEKO-TEX® certification in accordance with product class I for this article!
Dear Mr. Schröder,
We have looked through the test data sheets sent to us by Öko-Test and also read the article “Test mud pants” in the April 2017 issue of the Öko-Test magazine.
The nature of the article does not surprise us, as Öko-Test has been doing this for many years, even decades.
A lot of things are put forward, the subjunctive is used again and again, or assumptions are made, and in our opinion the consumer and the companies are very often left in the dark. With very few exceptions, it is not possible to determine which materials were actually tested and findings for the article are listed in the table "purely" qualitatively (i.e. without specifying the actual concentration). In our opinion, this gives the consumer the impression that these "pollutants" listed qualitatively, as mentioned, refer to the entire article - i.e. the mud pants as a whole. Ultimately, it remains unclear what was actually tested. In some cases, terms such as "significantly increased content" or "pollutant cocktail" are written, which then suggest a high concentration to the consumer, since they are not familiar with information (which is given as a legend in the small print) such as lag/kg and certainly not what this means analytically and where the limits of analytical detection lie. However, we assume that the Öko-Test magazine will continue to do this and will claim and claim it for itself within the framework of its journalistic freedom.
We would like to stress that the OEKO-TEX® community cannot identify with this type of publication in any way and we consider it to be unreliable and unfair.
Of course, the Öko-Test magazine is free to set its own rules and requirements for its evaluation; however, in our opinion, the way in which this is handled and how products are thereby - in our opinion - unfairly denigrated is to be criticized.
First of all:
The findings obtained in the Oko-Test study for the parameters examined for the mud pants do not give rise to any complaints with regard to your STANDARD 100 by OEKO-TEX® certification in accordance with product class I (baby and toddler articles) for this article!
Very good results were achieved for both polycyclic aromatic hydrocarbons (PAHs) and dibutyltin and triphenyl phosphate, which in our opinion do not lead to any complaints, even under "complaints" of preventive consumer protection. More on the concentrations found and the points “optical brighteners” and “halogenoorganic compounds” below.
At the end of this letter you will find a summary of the evaluation, but first we would like to comment in more detail on the points that were criticized and faulted in your mud pants, as you have requested.
As you have already noticed, the Öko-Test magazine likes to send results and values to the manufacturers and prefers to do so in µg/kg, especially when there are “highly elevated levels” of trace concentrations. Examples: results for PAHs or dibutyltin. As already mentioned: the consumer is generally not informed of the actual findings and will not normally read or really understand the legends.
First, a brief explanation of how concentrations are related using a general example: 100µg/kg=0.1 mg/kg=0.0001 g/kg=0.0001 g/1000g
What does a finding of 112 ~g/kg of dibutyltin mean, for example? This is exactly the amount that Öko-Test found in your article. Which material was tested (main material, reflective strips, etc.) is not stated, neither to you nor in the article in the magazine.
112 µg dibutyltin based on 1 kg of test material
= 0.000112 g dibutyltin based on 1 kg of test material
= in other words: 1000 g of test material contains 0.000112 g of the substance dibutyltin
If you consider that the European Community has set a limit for dibutyltin in products of 1000 mg/kg = 1 g /kg (= 0.1 %) based on tin in the European legislation "REACH", Regulation (EC) No. 1907/2006, Annex 17, the extremely different dimensions become immediately apparent without further explanation. However, it should also be noted that the OEKO-TEX® Community considers this limit to be far too high (see later limit in STANDARD 100 by OEKO-TEX®).
If you then know that with very good analytical devices available today you can measure down to a maximum of around 25 - 40 µg/kg (analytical detection capability), the result for your “pants” (whichever soft part was examined) appears in a completely different light.
In our opinion, we are therefore in the trace range. In our opinion, the limit value of 1.0 mg/kg (1000 times stricter than legally required) set for dibutyltin in the STANDARD 100 by OEKO-TEX® for product class I, appendix 4, ensures a high and effective level of consumer health protection. With a result of 0.112 mg/kg, it is far below this.
The results for polycyclic aromatic hydrocarbons (PAHs) are similar; again, it is completely unclear which material was examined (main product, small accessories?), but at least the article in the magazine states that there are traces. 140 µg/kg phenanthrene = 0.140 mg/kg phenanthrene 230.2 µg/kg total of other PAHs that are not even specified = 0.2302 mg/kg
If we now take into account that the Committee for Product Safety (AfPS) has set a limit of quantification of 0.2 mg/kg (= 200 µg/kg) for the testing and evaluation of PAHs when awarding the GS mark and has set individual limit values for various PAHs of < 0.5 mg/kg (=< 500 µg/kg) for products in category 2 (other products with foreseeable skin contact longer than 30 seconds = longer-term skin contact) and a total limit value of < 10 mg/kg (= < 10000 µg/kg) for the total of 18 PAHs and the European Community in the European Regulation (EC) No. 1907/2006 (REACH) in Annex XVII for toys and articles for infants and young children has set individual limit values of 0.5 mg/kg (= 500µg/kg) for plastic and rubber components for various PAHs, the findings on your trousers (for whatever component) can be viewed in a new light and it can be assumed with a very clear conscience that there is no health risk for the consumer.
In the STANDARD 100 by OEKO-TEX®, product class I, with which your mud trousers were awarded after successful testing, the requirements of the European chemicals regulation REACH are not only covered, they even go beyond them. In addition, the requirements in the STANDARD 100 by OEKO-TEX® do not only apply to plastic and rubber components.
The test also detected 27 mg/kg of triphenyl phosphate, but again it is not possible to say which material this was in. Triphenyl phosphate can be used as a flame retardant and also as a plasticizer. In our opinion, it cannot have been used as a flame retardant; the concentration determined is far too low for that. The finding could have come from the PUR coating, the reflective material or from adhesive/sealing materials or welding materials. Nevertheless, the concentration of 27 mg/kg is to be classified as low; even under the Öko-Test assessment criteria (see legend on page 63: “More than 10 and up to 1000 mg/kg triphenyl phosphate lead to a downgrade of one grade each”); here the determined value of 27 mg/kg is in the extremely low range. If one considers that the European Chemicals Agency ECHA classifies triphenyl phosphate as hazardous to the environment/water (as does the renowned Römpp — Chemistry Encyclopedia), but that there are currently no further classifications with hazard symbols with regard to a health risk for consumers, and that the substance is not included in the REACH SVHC candidate list (Substances of Very High Concern) (e.g. with regard to the assessment according to Annex XIV/REACH; authorization), it is surprising that a concentration of 27 mg/kg, which is classified as low for this substance, is used to downgrade it with regard to health aspects. The mere statement that it is an organophosphorus compound is, in our opinion, not a sufficient argument in this concentration range. With regard to the water hazard, we believe it should also be noted that this finding was obtained under laboratory conditions by extraction, very probably using organic solvents. Only a small amount of release through wearing or washing is to be expected. Triphenyl phosphate is practically insoluble in water.