Product Stewardship

With the adoption of specific goals at the WSSD*1 held in 2002, countries around the world are taking steps to reinforce related laws and regulations. This includes the establishment of REACH*2 regulations in Europe, Japan’s Act on the Evaluation of Chemical Substances and Regulation of Their Manufacture, etc., and the Toxic Substances Control Act*3 of the U.S. Under these circumstances, the need for companies to address and comply with more stringent laws and regulations and to voluntarily undertake the assessment and management of safety is becoming increasingly important in order to achieve WSSD goals. In its efforts to expand its business worldwide, the Mitsui Chemicals Group is working diligently to ascertain the latest trends in chemical management policies and to comply with the laws and regulations of each country on a timely basis. In addition to the above, the Group is also endeavoring to collaborate with and allocate responsibilities between companies along the supply chain complete an evaluation of risks for all of its products throughout the entire product life cycle from development to disposal by 2020. In this manner, the Mitsui Chemicals Group is protecting human health and the environment by engaging in proper management.

*1
WSSD:
The World Summit on Sustainable Development (WSSD) held in Johannesburg, South Africa. During the Summit, the WSSD goal of achieving, by 2020, the use and production of chemicals in ways that lead to the minimization of significant adverse effects on human health and the environment, using transparent science-based risk assessment procedures and science-based risk management procedures was adopted.
*2
REACH: Regulations relating to the registration, evaluation, authorization, and restriction of chemical substances.
*3
TSCA: The Toxic Substances Control Act.

Management System

Policy

The Mitsui Chemicals Group maintains a Responsible Care Policy that focuses on assessing the risks on people and the environment of its products throughout their entire lifecycles as well as ensuring human health and reducing the Group’s impact on the environment. In adopting this Policy, the Group is working to achieve the WSSD goal of minimizing the significant adverse effects imposed on human health and the environment by chemicals by 2020. Guided by its Responsible Care Policy, the Group has also put in place internal rules regarding environmental safety and quality management. These regulations help the Group traverse the increasingly stringent laws and regulations of each country and provide a roadmap for conducting surveys of products containing chemical substances, conveying information to stakeholders including customers, ensuring the health of consumers, customers, and employees, and reducing its environmental impact.

The Mitsui Chemicals Group is building the Product Stewardship framework which extends beyond the Chemicals Safety boundary of its six Responsible Care functional categories.

System and Responsible Officers

With the General Manager of the RC & Quality Assurance Division as the responsible officer, the RC & Quality Assurance Division puts in place the Product Stewardship Strategy. The results of Product Stewardship are reported and reviewed by the Responsible Care Committee. The findings of the Committee are then reflected in plans for the next fiscal year after taking into consideration the concerns and requirements of society as well as changes in the environment. This includes the latest trends in government policy as well as laws and regulations as they relate to chemical substances.
In addition, the RC & Quality Assurance Division collaborates with the departments concerned including the R&D laboratory, business divisions, and Works to collect information concerning products containing chemical substances, conducting risk assessments of products, addressing laws and regulations relating to chemicals, and preparing product SDS and labels that comply with regulations. Based on the results of these endeavors, the general managers of business divisions and general managers of each Works oversee chemical safety across the full gamut of operations from the sourcing of raw materials to shipment at their respective locations of responsibility.
Each of the aforementioned measures are implemented at each of product development prior to market release, market development, and raw materials procurements stages. Moreover, these measures are taken at other stages of the Group’s operations. This includes any change in raw materials or equipment after a product has been released, when exporting to a new country, and sale as a result of new application.

SDS: Safety Data Sheet.

Monitoring Methods

The General Manager of the RC & Quality Assurance Division undertakes a detailed confirmation of progress by major theme of the Product Stewardship Strategy at monthly reporting meetings.

The RC & Quality Assurance Division takes both exhaustive and comprehensive steps to ensure that it fully grasps the annual submission requirements prescribed under Japan’s Act on the Evaluation of Chemical Substances and Regulation of Their Manufacture, etc. as well as the application and submission requirements associated with efforts to reinforce the European REACH and other regulations. Thereafter, the Division undertakes the necessary collation of information for each category and puts in place a Group-wide plan to ensure that requirements are met. In order to advise the rest of the organization and to provide support, meetings are held to provide officers in charge of Responsible Care with the appropriate information. Among a host of endeavors, the Division makes full use of the gate check function of the chemical product safety information system (SAP–EHS). This helps in preventing the termination of export activities when the necessary registration requirements of each country have not been completed, and avoiding the manufacture of products in excess of approved limits.
A risk assessment that takes into consideration the impact on human health and the environment is undertaken for new products up to their market release and in accordance with any change in management after each product launch. In the event that the necessary low level of risk cannot be confirmed, a product safety meeting is held chaired either by the responsible director in charge of the RC & Quality Assurance Division or the General Manager of the RC & Quality Assurance Division. The goal of the meeting to decision whether or not a product will be released and if so under what terms and conditions.

Achievements and Reviews

The results of Product Stewardship are reported and reviewed at each Responsible Care Committee meeting. The results of each review are reflected in plans for the next fiscal year after taking into account the interest and requirements of society as well as changes in the environment.

The Mitsui Chemicals Group did not violate any newly enacted or amended laws in fiscal 2016. Over and above these newly enacted and amended laws relating to chemical products, food packaging, the environment, and other issues in Japan and overseas, we recognize that many countries are currently in the progress of reinforcing controls on products after their registration and market release. As a result, we have formulated plans to build a chemicals management framework that is capable of addressing these increasingly stringent controls from fiscal 2017.

Furthermore, we have incorporated Product Stewardship as a target item in efforts to pursue thorough safety, high quality, and fairness across the entire supply chain, an environmental and social target under the Long-term Business Plan. We have also set the goals of a product risk assessment implementation rate of 99% or more (by fiscal 2020) while continuing the provision ratio of the latest safety information for all products at 100% as KPIs.

Goals and Results

Goals for Fiscal 2016

  • Undertake a response to the chemical regulations of each country in order to ensure the smooth running of our business
  • Strengthen assessment technologies in order to accelerate priority businesses
  • Promote risk assessment and risk management based on Product Stewardship

Fiscal 2016 Results and Assessment

Level achieved: A

  • Undertook a response to the chemical regulations of each country in order to ensure the smooth running of our business
    We are systematically complying with all of the newly enacted and amended laws of each country with respect to our products. In particular, we have address the requirements of newly enacted laws in South Korea and Thailand in fiscal 2016.
    In order to more easily ascertain the laws and regulations of each country, companies within the Mitsui Chemicals Group have set up and are operating a system that ensure the sharing of information.
  • Strengthened assessment technologies in order to accelerate priority businesses
    For animal testing that is conducted in-house or on a contract basis, the Mitsui Chemicals Group has put in place a policy that is based on the 3R principles of replacement, reduction, and refinement. This naturally includes efforts to identify alternative means to animal testing. Steps have also been taken to strengthen the monitoring functions of the Institutional Animal Care and Use Committee.
    Moreover, and in the new business domain, every effort is being made to investigate risk assessment methods based on related application legislation in the U.S. and Europe. Preparations to ensure compliance have been completed.
  • Promoted risk assessment and risk management based on Product Stewardship
    The Mitsui Chemicals Group implemented qualitative evaluations of all products and selected those products requiring detailed evaluation on a priority basis.
    Evaluations are currently in progress based on overall plans.

Priorities for Fiscal 2017

The Mitsui Chemicals Group has identified two medium-term Product Stewardship targets for around 2020.

Target 1:

The Mitsui Chemicals Group will continue to ensure that it complies with all statutory and regulatory requirements in an exhaustive and comprehensive manner. Measures will be put in place to prevent any violation with respect to the Group’s manufacturing and shipping activities.

Target 2

Mitsui Chemicals’ safety evaluations with garner the confidence of society; as an integral element in the value chain, the Company will work toward sustainable development and provide increasingly safe products.

With an eye to 2020, the Mitsui Chemicals Group has identified the following priorities for fiscal 2017.

Fiscal 2017 targets aimed at achieving target 1:

  • Reinforce governance in a bid to fully comply with all newly enacted and amended laws
  • Adhere strictly to a policy of chemical substance management after product have been released to the market
  • Build a structure that properly conveys information that in turn complies with diversifying regulatory requirements

Fiscal 2017 targets aimed at achieving target 2:

  • Undertake risk assessments as well as risk management via the supply chain for all products
  • Expand business and development products from the perspective of sound chemicals management
  • Put in place a safety evaluation platform that engenders the confidence of society and acquire cutting-edge technologies

* Levels of achievement based on self-assessment: A: 95% or more, B: 70% or more and less than 95%, C: less than 70%