Product Safety and Chemical Management
Each division of the Kuraray Group aims to ensure product safety in its day-to-day new product development and revisions of management (e.g. assessment of the safety and function of products where changes in raw materials and changes in production equipment and conditions are made). They do this by conducting assessments using various risk assessment methods and making improvements and realizing product safety and quality guarantee for the delivery to customers.
A committee centering on the Corporate Sustainability Division is organized in accordance with the "Rule for Assessment Committee on Crucial Matter" to study products that require a company-wide study of safety and to verify product safety before developing and marketing. The products to be studied include those that are ingested in the body, that are for medical use, and that use nanomaterials. In fiscal 2021, regarding issues in the development or commercialization of products specified by these Rules, the Committee consisting of internal experts continued having discussions about the security and safety of customers, employees and consumers who handle the products, and an impact on the environment.
The Kuraray Group supplies customers, employees and consumers with these products that have passed an appropriate safety measure taken by the Committee where risk assessment and safety is discussed for individual division-specific issues.
Against the backdrop of global initiatives such as the Strategic Approach to International Chemicals Management (SAICM) and the Sustainable Development Goals (SDGs), laws and regulations concerning chemicals have been revised in each country. To respond to these changes in the business environment in recent years, we are taking a range of measures in anticipation of a post-SAICM framework.
Kuraray Group internal regulations stipulate that the Group's chemical substance management is overseen by the officer in charge of the Corporate Sustainability Division. The Corporate Sustainability Division, as a corporate organization, works to continuously improve the chemical substance management system throughout the Group. Each business division, based on its thorough knowledge of products, is responsible for confirming safety, ensuring compliance with laws and regulations, and communicating information on chemical substances in the supply chain. This is done in accordance with the product's intended use and customer requirements. Our business divisions and the Corporate Sustainability Division coordinate to ensure that our customers can use our products safely.
Compliance with Laws and Regulations, Provision of Information
The Kuraray Group in Japan has internal regulations for all chemical products provided outside the Company (including in-house transactions in cases where logistics is outsourced) requiring the provision of Safety Data Sheets (SDSs)1). Since 2017, we have subscribed to Verisk 3E's Global Incident Response Hotline Service. Our product SDSs for overseas customers include a 24-hour, multilingual phone number in case of emergency, in case of accidents or inquiries about our products overseas. In addition, when transporting chemical products with specific properties or hazards, we issue Yellow Cards2), which we provide to logistics companies.
Responding to Changes in Legislation
Below are some examples of measures implemented in fiscal 2021 in response to chemical-related laws. We will continue to make efforts to properly comply with regulations on chemicals in Japan and overseas.
From January 2021, molded products containing more than 0.1w% of SVHC3) are required to be registered in the SCIP4) database. Our European subsidiary has registered the relevant products.
UK REACH came into effect following the UK's exit from the EU at the end of 2020. For products containing chemical substances that are exported to the UK and for which our European company is registered to EU REACH as an importer or as an only representative (OR), we submitted a Downstream User Import Notification (DUIN) to the competent authorities by the deadline of October 27, 2021 via ORs, etc. that we newly arranged for UK REACH.
In accordance with the Law Concerning Registration and Evaluation of Chemical Substances (Chemical Evaluation Law), we completed registration of chemical substances whose production or import volume exceeds 1,000 tons per year by the deadline of the end of 2021. In addition, under the SDS submission system newly enforced by the Industrial Safety and Health Act, we established a new system within the Kuraray Group that enables us to register SDSs with our South Korea Group company as the agent. We have begun registration of the SDSs to be submitted.
To respond to the National Chemical Inventory (NCI) notification, we provided, through our Vietnam Group company, information on chemical substances contained in our products that are distributed in Vietnam.
An increasing number of situations require action outside Japan. These include procedures for complying with overseas laws and regulations or registering products manufactured at overseas sites. We work with product stewardship managers and regulatory affairs staff at our overseas Group companies to collect information on the status of revisions to and application of chemicals-related laws and regulations in each country, sharing and reviewing this information as appropriate. The aim of this system is to enable the entire Group to respond efficiently and reliably.
We have established a Chemical Substance Management Liaison Meeting as a forum for sharing information between the Corporate Sustainability Division and business divisions (chemical substance management managers, persons in charge, etc.). The meeting was held four times in Japan during fiscal 2021. The meeting deepens participants’ knowledge of domestic chemical regulations such as the Law Concerning the Evaluation of Chemical Substances and Regulation of Their Manufacture, etc. It also informs and educates them about revisions to overseas chemical regulations and our specific responses to such revisions. In fiscal 2021, two similar meetings were held for overseas locations.
In addition, since fiscal 2021, we have been using webcasts of the Chemical Risk Forum hosted by the Japan Chemical Industry Association. This provides an opportunity for staff to learn about the latest trends in risk assessment and laws and regulations, which are important elements of chemical substance management. Because the course can be taken via the Internet, it is attended by a wide range of Group personnel, including not only those responsible for chemical substance management in the business divisions but also those in charge at business sites.
Chemical Management System
The Kuraray Group in Japan has introduced IT tools to manage chemical substances. We have linked chemical substance information on raw materials and products registered in the in-house database to external databases that contain information on laws and regulations and on safety information of chemical substances. In this way, we have established a system to facilitate the acquisition of information on laws and regulations pertaining to use and on hazards and the preparation of SDSs, thereby supplying necessary information to the customers.
- 1)SDS: Safety Data Sheet. Documents containing information about the properties and hazards of chemical substances.
- 2)Yellow Card: An emergency contact card that describes the steps to be taken by lorry drivers,firefighters, police, and other relevant personnel in case of an accident during transport of chemicals or high-pressure gas.
- 3)SVHC: Substance of Very High Concern. Candidate substances for Annex 14 "Substances subject to authorization" in the Regulation on the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH)
- 4)SCIP: Substances of Concern In articles as such or in complex objects (Products). Database established based on the European Waste Framework Directive”
Targets and Results in Product Safety and Chemical Management
|Improve information sharing among divisions to support our goal of preventing serious accidents caused by products and eliminating of serious accidents and violations.||In order to improve employee awareness of product safety and chemical management, we have regularly held liaison meetings between the corporate and business divisions to familiarize employees with internal rules and educate them about laws and regulations. We have also gathered information on complaints from customers and shared this information at the liaison meetings to promote horizontal deployment.
There were no serious accidents or violations in fiscal 2021. There was one incident that could have led to an accident, but repairs are being made to prevent accidents from occurring.