Product Safety and Chemicals 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 2022, 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. In addition, we have revised our regulations by reviewing the criteria for judging Product Liability-related accidents and reporting complains in order to respond more appropriately.
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.
In recent years, there have been calls for a new approach to chemicals management to minimize the negative effects of chemicals and to develop the chemical industry sustainably. The Chemicals Strategy for Sustainability, for example, was published as part of the European Green Deal. In light of efforts such as these around the world, we are working with overseas groups to collect information on the latest trends, comply with chemicals laws and regulations, and take various other actions to ensure accurate management throughout the Group.
The Kuraray Group internal regulations stipulate that the Group's chemicals 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 chemicals 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). Since 2017, we have subscribed to 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 Cards*, which we provide to logistics companies.
* Yellow Card: An emergency contact card that describes the steps to be taken by truck drivers, firefighters, police, and other relevant personnel in case of an accident during transport of chemicals or high-pressure gas.
Responding to Changes in Legislation
Below are major examples of measures implemented in fiscal 2022 in response to chemical-related laws. We will continue to make efforts to properly comply with regulations on chemicals in Japan and overseas.
The Industrial Safety and Health Act and the Act on the Assessment of Releases of Specified Chemical Substances in the Environment and the Promotion of Management Improvement (Chemical Substances Control Act) have been revised to add or change designated chemical substances that are required to be listed in the SDS. We are working on revisions so that they can be reflected in the SDS before they come into effect. In addition, we ensured that new chemical substances were filed in accordance with the Act on the Evaluation of Chemical Substances and Regulation of Their Manufacture, etc. (Chemical Substances Evaluation Act) and the Industrial Safety and Health Act, as well as filing manufacturing quantities, etc. in accordance with the Chemical Substances Evaluation Act.
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. Regarding other target substances, we have been conducting registration and application work sequentially since 2022. In addition, for registered chemical substances, we use the form required by law to provide appropriate information to customers. In addition, under the SDS submission system newly enforced by the Industrial Safety and Health Act in 2021, we established a new system within the Kuraray Group that enables us to register SDSs with our South Korea Group company as the agent, and continue to register the SDSs to be submitted.
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 are also working on global commonality of regulatory search tools and management tools, aiming at a system that enables the entire Group to respond efficiently and reliably.
We have established a Chemicals Management Liaison Meeting as a forum for sharing information between the Corporate Sustainability Division and business divisions (chemicals management managers, persons in charge, etc.). The meeting was held four times in Japan during fiscal 2022. In the meetings, participants deepen their knowledge of chemical regulations in Japan and overseas, including the Law Concerning the Evaluation of Chemical Substances and Regulation of Their Manufacture, etc. and the Industrial Safety and Health Law. The meeting also informs and educates them about new internal rules that incorporate voluntary management activities and specific response approaches. In fiscal 2022, two similar meetings were held online for overseas locations.
In addition, 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 chemicals 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 chemicals management in the business divisions but also those in charge at business sites.
Chemicals 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.