EnvironmentChemical Management
1. Philosophy and Advancement Structure
Under its CSR advancement scheme, JSR Group advances measures pertaining to chemical management based on promotion items and concrete action plans founded on those items that are established by the Responsible Care Advancement Committee.
(1) Chemical Management Basic Policies
In light of recent global trends in chemical management, JSR has established the following three policies in its environment and safety management organization by which chemical management is implemented.
- 1. Instead of hazard-based management*1, we will endeavor to implement risk-based management*2.
- 2. We will strive to manage our entire supply chain by utilizing a globally standardized method.
- 3. We will strive to comply with regulations and promote self-motivated initiatives to ensure the safety of our products.
*1 Hazard-based management: Management based solely on the hazardous properties of substances
*2 Risk-based management: Management based on exposure to the hazardous properties of substances
(2) Chemical Management Advancement Structure
Overview of the advancement structure
JSR’s chemical management structure revolves around corporate department-driven domestic legal compliance and export compliance, as well as overseas chemical management by local subsidiaries. This has allowed us to pick up early on domestic and overseas environmental changes and trends toward stronger regulation and, thus, to develop and implement a planned response.
Furthermore, in order to bolster our chemical management structure and facilitate greater responsiveness in the face of accelerating regulatory strengthening, new legislation creation and other such developments overseas, in FY2019 we established a specialized Chemical Management Department within the Elastomer Business Division, which has experienced a particularly pronounced global expansion in its customer base. Also, an overseas law and regulation-related administrative structure has been set up which makes use of corporate departments to gather a broad spectrum of law and regulation-related information from industry groups and other sources, and this information is then shared in a timely manner throughout all of JSR, including Group companies and local subsidiaries.
At JSR, we will continue to develop structures and systems that allow us to flexibly respond to domestic and overseas trends, as well as business expansion.
2. Compliance
(1) Response to Chemical Product-related Domestic Laws and Regulations
In 2017, the Chemical Substances Control Act*3 was amended, and the revised portion of this Act which is concerned with the confirmation system used for low volume new chemical substances came into effect in 2019. With regard to the new requirements introduced by the revisions, e.g., that use certificates be submitted for each substance, JSR undertook advance preparations, in-house training and took other steps to ensure that there have been no problems with any of our applications since the revisions have gone into effect. In addition, we have made advance preparations and are systematic undertaking measures to ensure compliance with the amended Food Sanitation Act taking effect in 2020, the anticipated amendment of the Law concerning Pollutant Release and Transfer Register*4, and other legislative amendments.
*3 Act on the Regulation of Manufacture and Evaluation of Chemical Substances
*4 Act on Confirmation, etc. of Release Amounts of Specific Chemical Substances in the Environment and Promotion of Improvements to the Management Thereof
(2) GHS Compliance and Provision of SDS for All Products
1) GHS Compliance
GHS*5 is as an international standard for (a) classification of chemical products according to hazard and toxicity; (b) labeling on product packaging and containers; and (c) documentation and provision of details in the SDS*6.
In Japan, the Industrial Safety and Health Act and the Law concerning Pollutant Release and Transfer Register stipulate mandatory application of GHS to the labels and SDS of products containing GHS-designated chemical substances, with GHS classification stipulated under JIS Z 7252 and SDS and other communicated information stipulated under JIS Z 7253. At JSR, we perform GHS-based hazard and toxicity classification and create appropriate labels, as well as provide SDS, for all of our domestic products that contain applicable substances. We will also strive to ensure our compliance with laws concerning this matter that are being enacted in other countries.
*5 Globally Harmonized System of Classification and Labeling of Chemicals
*6 Safety Data Sheet: Documentation listing the names, respective hazards and toxicities, etc., of substances contained in chemical products in order to ensure their safe handling
2) Provision of SDS for All Products
JSR has voluntarily adopted a policy of providing customers with environmental and safety information by preparing SDS not only for those products which contain hazardous or toxic substances but for all products which contain polymers. All SDS prepared by JSR are in compliance with JIS Z 7253, Industrial Safety and Health Act, the Law concerning Pollutant Release and Transfer Register and the Poisonous and Deleterious Substances Control Act.
Furthermore, in order to provide customers with SDS that contain the most accurate information possible about each product, we were early adopters of an SDS electronic data management system which we have operated since its creation in 2002. This system includes user management, chemical substance database management, creation support, and publication (revision) history, and it allows us to accurately and quickly provide environmental and safety information related to JSR products.
(3) Education on Chemical Substance Regulations
JSR provides in-house training on chemical substance regulations in Japan and abroad. In FY2019, we held domestic law seminars on new chemical substance registration and the amended Chemical Substances Control Act, and we held foreign law seminars on the substance registration systems used in China, Korea and Taiwan. These seminars were held at the head office and business establishments, and Group companies were also invited. A total of 98 people participated.
3. Response to Overseas Regulations Concerning Exported Chemicals, etc.
Countries around the world have been strengthening their chemical products laws and regulations in advance of 2020, as this is the target year for meeting an international goal*7. Different countries have begun introducing new regulations, such as those requiring registration of existing chemical substances, following the EU’s enactment of the REACH Regulation in 2007, and JSR has been responding to each of these without omission in a manner that corresponds to business content and characteristics and local subsidiary systems. The legal and regulatory responses being undertaken by JSR for major production and import/export countries are detailed below; however, in addition to these, JSR is also ensuring compliance with the chemical product-related laws and regulations of numerous other countries, including those in ASEAN.
*7 WSSD 2020 Goal (long-term goal for chemical substances management that was adopted by the 2002 World Summit on Sustainable Development): Minimization of significant adverse effects on human health and the environment by 2020
(1) EU (REACH Regulation compliance)
The REACH*8 Regulation was enacted by the EU in June 2007. Under REACH, all chemical products whose total production or import volume within the EU is one ton or more must register safety testing results and other data for the chemical substances contained in them, regardless of whether they are new or existing substances.
In order to ensure there is no disruption to our EU product production or import, we not only regularly check whether or not the substances JSR utilizes require registration, we also prepare for likely usage restrictions arising from future substance evaluations by sharing information with development departments and taking other steps to anticipate risk once evaluations commence.
We have also finished implementation of necessary measures, such as REACH agent transfer, accompanying “BREXIT” in 2019. We are ensuring that we are in compliance with British laws and regulations by the time of Britain’s withdrawal from the EU at the end of 2020.
*8 Registration, Evaluation, Authorisation and Restriction of Chemicals
(2) United States
In the United States, new chemical substance reporting is overseen by the Environmental Protection Agency under the Toxic Substances Control Act (TSCA) and other related federal laws and regulations. JSR follows all applicable legal procedures with regard to the manufacture and importation within the United States of substances not included on the list of existing chemical substances. Also, in response to the amended TSCA which went into effect in 2016, we work in conjunction with our local subsidiaries to flexibly respond to the new legal requirements, as well as promote responsiveness to regulatory trends accompanying the start of risk assessment.
(3) China
In China, reporting of new chemical substances is governed by the Measures for Environmental Management of New Chemical Substances, which was enacted in 2010. Since the establishment of this law, JSR has followed all applicable legal procedures with regard to the importation within China of substances not included on the “Inventory of Existing Chemical Substances in China.” An amended version of this law will go into effect from January 2021, and we are working to ensure we are fully in compliance without any new chemical substance-related omissions.
(4) Korea
In Korea, reporting of new chemical substances is governed by the Korean REACH*9 Act and OSHA*10 Act. JSR anticipates and follows all applicable legal procedures with regard to the manufacture and importation within Korea of substances not included on the list of existing chemical substances. The Korean REACH Act underwent major revisions in 2019, and, as a result, it is now required that existing chemical substances produced or imported within Korea in quantities of one ton or more must be registered. Reporting had to be completed by June 2019, but because of timely coordination between our business departments and local subsidiaries, JSR was able to successfully complete registration within the short window allowed. We will continue to carefully and systematically handle any and all future phased registration operations.
*9 Act on Registration and Evaluation of Chemical Substances
*10 Occupational Safety and Health Act
(5) Taiwan
In Taiwan, a registration system was introduced based on the Toxic Chemical Substances Control Act*11 enacted in 2014. JSR follows all applicable legal procedures established in line with this new chemical substance registration system. Also, as part of efforts to update its existing chemical substances list, Taiwan has instituted “Existing Chemical Substance Nomination,” with the first designated target substances registration taking place in 2019. JSR’s compliance efforts have been primarily handled by our Taiwan subsidiary while working within a compliance framework appropriate to each business.
*11 (old) “Toxic Chemical Substances Control Act.” Amended in January 2019 to expand the scope of controlled chemical substances; the name was also changed to “Toxic and Concerned Chemical Substances Control Act” in order to reflect this expansion.
4. Chemical Management within Supply Chain Management
At JSR, we practice chemical management simultaneously with CSR procurement and green procurement/green purchasing as part of our supply chain management. In particular, from the standpoint of toxic chemicals management, we have introduced chemSHERPA as part of our green procurement practices, as it is the industry standard format for communicating toxic substances information, and this has helped ensure that we are able to smoothly and reliably relay information to suppliers and in-house handling departments, as well as to customers. Please refer to the following links for more information.
5. Industrial and International Measures
JSR is a member of the Japan Chemical Industry Association (JCIA) and contributes to its activities. JSR’s contribution includes participating in JCIA’s working groups, promoting activities of its Long-range Research Initiative (LRI)*12 as a voluntary effort by the chemical industry, and providing a part of research funding.
*12 LRI (Long-range Research Initiative):
The Long-range Research Initiative (LRI) is a long-term, international initiative supporting research into chemical substances that have an impact on the environment, safety and health. It was begun as a voluntary global research grant program initiative of the International Council of Chemical Associations (ICCA), and it is currently being advanced through the cooperative efforts of the chemical industries associations of Japan, the United States and the EU. In Japan, the Japan Chemical Industry Association (JCIA) is pursuing research into the following five topics: (1) development and evaluation of the new risk assessment method/development of methods for simple exposure evaluation and alternatives to using laboratory animals; (2) study on the safety of new chemical substances including nano materials; (3) study on the effects of chemical substances on children, the elderly, and gene disorders; (4) evaluation of the impact on ecosystems and the environment; and (5) other issues that require an emergency response.
