Chemicals Management

Basic ideas and policies

Resonac promotes compliance and product stewardship to provide all stakeholders with safety and security. We aim to create new value for the future by proactively identifying potential product risks and autonomously and independently managing them. We have also created a framework for continuously fostering and producing chemical management and safety assessment professionals, and we are pushing ahead with establishing the foundations for effectively implementing the aforementioned initiatives.

Promotion system

Resonac's chemical management administration organizations have established a global promotion system and are working to fulfill their missions and policies through continuous improvement by utilizing the PDCA cycle in regulatory compliance, risk management, global oversight, and safety assessment.

Strategies

1. 1. Reinforcement of global governance

   Through the establishment of a chemicals management network function, formulating Resonac group’s chemicals management rules, developing an integrated chemicals management system, and comprehensive collaboration via RHQs*, we aim to further enhance governance both domestically and internationally, and ensure comprehensive chemicals management compliance.

2. 2. Promotion of product stewardship

   We will provide sustainable value through safety and peace of mind that reassures our stakeholders by continuously performing chemical risk assessments, enhancing the level of product safety assessments, and expanding product-related safety information. Also, in material procurement activities, we promote the procurement of goods and services with less environmental impact based on the Resonac Group Green Procurement Guidelines.

   Related link

   • Green Procurement Guidelines
3. 3. Education/human resource development

   We will implement a chemicals management professional development program that focuses on e-learning and online seminars, enabling participants to take courses from any location and at any time, and fostering human interaction and specialized training within the Resonac Group.

• ※ RHQ=Regional Headquarters (regional oversight companies)

Targets

The following KPIs are being pursued as material issue KPIs.

• * The assessment was implemented by issuing a safety summary report for substances stipulated by the Company.

Enhancement of the chemicals management system

With the aim of establishing a chemical management system befitting a global top-class functional chemical manufacturer, we laid the groundwork for a global governance system in 2022 by determining which former domestic and overseas Showa Denko and Hitachi Chemical affiliates would be covered under chemical management and appointing personnel responsible for chemical management at each plant. To date, we have bolstered our chemical management system by preparing and issuing regulations for the new companies to constitute the basis for governance, conducting chemical management audits based on the integrated standards of both companies, providing various types of education, and launching a chemical management portal site that will serve as the foundation of a global communication hub.

In addition, we are continuing the efforts to improve chemical risk assessment at domestic plants that we started in 2020, and we are enhancing our company-wide chemical management system in terms of chemical risk assessments.

Compliance with chemical substance-related laws and regulations in Japan and abroad

Resonac is constantly monitoring developments in regulations governing chemical substances in Japan and overseas to ensure compliance with the laws and regulations of each country, and is actively working to ensure that its products, raw materials, and chemical substances remain compliant via its comprehensive chemical substance management system. For the manufacturing/export quantity control legally required in each country, we have linked the aggregation functions in this system with our core systems to ensure reliable and transparent aggregation for reporting to administrative agencies in Japan and overseas. Within the group, the head office and individual plants work closely together to share issues, information, etc., and prevent compliance violations.

• Laws and regulations in Japan: We are using the comprehensive chemical substance management system to foster compliance with laws and regulations, including the following, in a systematic manner: the Act on the Regulation of Manufacture and Evaluation of Chemical Substances; the Industrial Safety and Health Act; the Poisonous and Deleterious Substances Control Act; and the Act on Confirmation, etc. of Release Amounts of Specific Chemical Substances in the Environment and Promotion of Improvements to the Management Thereof. As for the Act on the Evaluation of Chemical Substances and Their Manufacture, etc., the Resonac applies the company-wide central management system and enhances compliance.
• Laws and regulations outside Japan: New laws and regulations are frequently established or existing ones revised in various countries and regions overseas, as seen in Europe (REACH: Registration, Evaluation, Authorisation and Restriction of CHemicals), the United States (TSCA: Toxic Substances Control Act), and Asia (China's new Chemical Substances Control Law, Korea’s Registration and Evaluation of Chemical Substances, etc.), and these laws and regulations are likely in future to be made stricter and broader in scope. We are monitoring revision trends using various information sources and databases and sharing information with local officials in the relevant countries to ensure appropriate and timely responses.

System for managing product safety and regulatory information

Resonac utilizes the "Comprehensive Management System for Chemical Substances" that it established as part of its basic infrastructure for chemical management.
This system consists mainly of databases of information on chemical substances relevant to chemical management and information on the laws and regulations governing chemical substances in each country, and it is equipped with functions to utilize such information/data in carrying out practical operations.

Through this system, we manage information on chemical raw materials and our own products. The Chemical Management Department extensively researches and expertly evaluates toxicity and regulatory information for each chemical substance to ensure high quality. We also maintain the latest information by updating the database of countries’ chemical substance regulations in a timely manner and periodically reviewing the information to be included in the database. In addition, we have established linkages and mutually complementary ties between our in-house core system and safety data sheet (SDS) management database and our management system. We utilize the functions of this system, which is based on high-quality information and the latest regulatory information, to conduct efficient and effective legal compliance operations to ensure compliance.
For example, we have been able to appropriately respond to amendments to various countries’ laws by utilizing an extraction function that can easily list substances and products by various conditions, and we use the system to manage manufacturing/import volumes and notifications in Japan and overseas by linking the management system’s aggregation functions with the company’s core system. We also utilize the SDS preparation function to create and provide SDSs that comply with laws and regulations.

With laws and regulations related to chemical substances being enacted and revised around the world at an accelerating pace, we will continue to augment and expand this system not only to ensure our own compliance but also to fulfill our responsibilities as a link in our customers' business supply chains.

Collection and provision of product information

We prepare SDSs for our products based on the information contained in the Comprehensive Management System for Chemical Substances. For both domestic and overseas versions of SDSs, we collect information on the legal requirements of the countries involved, prepare SDSs in compliance with their laws and regulations and then provide these to customers after internal review and approval.
We completed the revision of our SDSs in accordance with the amended Cabinet Order on the Act on Confirmation, etc., of Release Amounts of Specific Chemical Substances in the Atmosphere and Promotion of Improvements to the Management Thereof (Chemical Substances Control Act) promulgated in October 2021, by the end of 2022.

As part of our efforts to promote product stewardship, we select chemical substances that we prioritize for assessment (substances subject to in-house priority assessments), conduct sequential risk assessments, and proactively disclose the results of these assessments to our stakeholders. In 2022, we continued to focus on risk assessment as we did last year, working with plants to improve risk assessment with the aim of making plants self-sustaining and self-driven. In particular, we conducted risk assessments for 36 substances subject to in-house priority assessment, achieving a 100% assessment implementation rate. We prepared a new safety summary document describing the results of these assessments and made it available on JCIA BIGDr, a portal site provided by the Japan Chemical Industry Association (JCIA) to support chemical substance risk assessments. As a result, we received the grand prize at the JIPS Awards* from JICA for the second consecutive year as the company publishing the largest number of new safety summaries. Active risk communication with parties inside and outside the company and increased willingness within the company to contribute through this initiative will be the driving force behind the promotion of product stewardship going forward. Our safety summaries are also available on our website.

• * Award presented by the Japan Chemical Industry Association (JCIA) to member companies that have made outstanding efforts in publishing safety summaries as part of their voluntary and autonomous approaches to chemical management

Risk management for nano-materials

Our company handles a large number of nanomaterials. In 2017 we put into operation a nanomaterial safety management system we had established to assess the risks of all nanomaterials handled as raw materials and as products, giving due consideration to the safety and health of workers and customers as well as the environment. Risk assessments and safety management of nanomaterials are conducted in accordance with the "Nanomaterial Safety Management Procedures”.
The Nanomaterial Safety Council, chaired by the director in charge of nanomaterials, periodically confirms that nanomaterials are being properly managed and submits requests to the Management Committee for decisions on whether to continue pursuing specific businesses or developing particular products.

Education

For chemicals management, it is important to provide individual employees, who support such management, with internal education so that they can acquire the knowledge necessary to ensure compliance and handle products in an appropriate manner.
Accordingly, the Resonac Group is working to enhance its internal educational program and build a systematic education system. The Group is providing employees with education on a continual basis to help them increase their sensitivity to, awareness of, and knowledge about the management of chemicals, thereby preventing noncompliance with regard to chemicals management.
As part of our in-house education program, for example, we hold seminars that provide overviews of chemical management and that discuss the Chemical Substances Control Act, the Industrial Safety and Health Law, the Poisonous and Deleterious Substances Control Act, overseas laws and regulations, transportation of hazardous materials, SDSs, and chemical substance risk assessments. We also seek to maximize learning opportunities by introducing external seminars, such as in-house streaming of the Japan Chemical Industry Association’s Chemical Risk Forum. In addition, we hold briefings for chemical substance management personnel at business units and plants to inform and educate them on legal and regulatory requirements as well as internal rules and regulations. By conducting all of these activities online, we have made it possible for many employees to improve their knowledge without location restrictions.

Consideration for animal testing in safety assessment

Various safety assessments are necessary to develop chemicals useful to society and to carry out appropriate chemical management. We actively utilize alternative methods to animal testing such as computerized toxicity prediction assessments (in silico) and alternative testing methods that use cultured cells and reagents (in vitro and in chemico). We also minimize the use of laboratory animals as much as possible by conducting safety evaluations using step-by-step approaches.

On the other hand, we use an external organization to conduct product safety evaluations using laboratory animals only for the purpose of providing socially useful, safe, healthy, and environmentally conscious products and conducting appropriate chemical product management in compliance with global regulatory requirements. In doing so, we respect the 3R principle in animal testing – replacement (use of alternative methods), reduction (reduction in the number of animals used) and refinement (reduction of suffering) – and outsource animal testing to external organizations that operate in accordance with the Act on the Welfare and Management of Animals.