Product Safety and Chemicals Management
Product Safety
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 2023, 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 to the risk assessments conducted by each business unit, the Kuraray Group will continue to supply products with appropriate safety measure to employees and users of our products through deliberations by the Product Liability Review Committee for some of the target products.
Chemicals Management
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 our overseas groups to collect information on the latest trends, comply with chemicals laws and regulations, and take various other actions to ensure appropriate management throughout the Group.
Management System
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 in charge of each product 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
Providing 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). In addition, when transporting chemical products with specific properties or hazards, we issue Yellow Cards* and provide them to logistics companies.
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.
* 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
The following are examples of major measures responses to chemical-related laws implemented in 2023. We will continue to make efforts to properly comply with regulations on chemicals in Japan and overseas.
Japan
In accordance with the partial revisions under the Industrial Safety and Health Law (ISHL), Chemical Substance Managers were appointed in all business units in Japan that handle chemical substances to conduct risk assessments at work sites and take safety measures based on these assessments, as well as to establish a system to properly prepare and manage SDS. Appointed managers attend internal and external trainings that reflect the requirements of the law, and work to maintain the necessary competence. Under the ISHL, the designated chemical substances that must be listed on SDS have been revised to be added or changed. We are working to revise the SDS to reflect the revisions before they come into effect. We have also ensured that new chemical substances are notified to the Law Concerning the Evaluation of Chemical Substances and Regulation of Their Manufacture, etc. (Chemical Substances Control Law: CSCL) and the ISHL, as well as to the Law Concerning the Evaluation of Chemical Substances and Regulation of Their Manufacture and the quantity of manufacture, etc.
South Korea
In accordance with the Law Concerning Registration and Evaluation of Chemical Substances (K-REACH), we have established an agent (OR) in Korea to handle substances that require registration and reporting. In addition, we use the form required by the law for chemical substances that have already been registered, share information appropriately with our customers. We also work with our customers to manage actual quantities within the registered tonnage framework. Under the SDS submission system newly enforced by the Occupational Safety and Health Act (OSHA) since 2021, we established a new system within the Kuraray Group that enables us to register SDS with our South Korea Group company as the agent, and continue to register the SDS to be submitted.
Thailand
In accordance with the revision of the List 5.6 notification in Hazardous Substance Control Act of 2022, we notified the subject substances in 2023 in cooperation with our subsidiary, Kuraray(Thailand)Co., Ltd.
Global Collaboration
There are an increasing number of situations in which it is necessary to respond to laws and regulations outside Japan, such as compliance with overseas laws and regulations or registration of 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.
Education
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 five times in Japan during 2023. 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. Similar meetings were held for global sites in 2023, both online and face-to-face.
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, thereby deepening their understanding of chemicals management.
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.
In 2023, a global database was established to centrally manage product SDSs for the entire Kuraray Group. In addition to eliminating duplicate management between sites, this database enables all Kuraray Group sites to view and download the necessary product SDSs. This database also shares information with some of the Group's external websites, enabling us to promptly provide our customers with the latest versions of SDSs.