Specific Initiatives for Chemicals Management

System for managing product safety and regulatory information
Collection and provision of product information to stakeholders
Compliance with chemical substance-related laws and regulations in Japan and abroad
Risk management for nano-materials
Consideration for animal testing in safety assessment

System for managing product safety and regulatory information

Resonac established the Comprehensive Management System for Chemical Substances as part of its basic infrastructure for chemical management. It uses the system to manage information about chemical materials and its own products. 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.

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 to stakeholders

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) enforced in April 2023 by the end of 2022. Moreover, based on the amended cabinet order and ministerial ordinance promulgated respectively in February and May 2022 on the Industrial Health and Safety Act, we are revising our SDSs and enhancing our information communication measures.
Also, 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 2023, we continued to focus on risk assessment as we did in the previous year to improve risk assessment results across the board. In particular, we conducted risk assessments for 21 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 became the company publishing the largest number of new safety summaries*1 and received the grand prize at the JIPS*2 Awards from JCIA for the third consecutive year from fiscal 2021. 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.

*1 Safety Summaries: Easy-to-understand summaries showing the risk assessment results of the chemicals manufactured and sold by the company and providing product profiles, characteristics, usage, impacts on people and the environment, recommended risk management measures, emergency contact information and others
*2 JIPS：Japan Initiative of Product Stewardship 、JIPS: The Japan Initiative of Product Stewardship (JIPS) is the Japanese version of the Global Product Strategy (GPS) for chemicals management. It is intended to prevent the occurrence of disasters and protect human health and the environment through the categorization of chemical harmfulness and the provision of related labels and safety sheets.

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, the United States (TSCA: Toxic Substances Control Act), and Asia (China's measures for the Environmental Management Registration of New Chemical Substances: MEE Order No. 12, 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. We will also appoint personnel in charge of chemicals management at each of the RHQs to enhance our global chemicals management based on collaboration with the regional headquarters.

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 CMEO/CQO, 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.

Consideration for animal testing in safety assessment

In our activities to supply socially useful, safe, healthy and environmentally conscious products, we proactively substitute animal testing with computerized toxicity prediction assessments (in silico) and tests that use cultured cells and reagents (in vitro and in chemico) as a step-by-step approach to conduct product safety assessments with the minimum use of laboratory animals.
To ensure compliance with global regulatory requirements, 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) when conducting product safety assessments using laboratory animals and outsource animal testing to external organizations that operate in accordance with the Act on the Welfare and Management of Animals.
Going forward, we will not use laboratory animals in principle unless it is required by law and will strictly manage animal testing by establishing an internal process to consider all possible alternatives.