Mitsui Chemicals

Product Stewardship

With the adoption in 2002 of the WSSD*1 goals aiming “to minimize the negative impact of chemicals on people and the environment by the year 2020,” countries around the world have been taking steps to reinforce related laws and regulations. This includes the enactment of REACH*2 in Europe, Japan’s Act on the Evaluation of Chemical Substances and Regulation of Their Manufacture, etc., and revisions to the TSCA*3 of the U.S. Under these circumstances, the need for companies to address and comply with more stringent laws and regulations, voluntarily undertake safety assessment and risk management, and convey information throughout the supply chain is becoming increasingly important in order to achieve WSSD goals.

*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

In preparation for the WSSD 2020 goals, 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 the health and safety of all persons and reducing the environmental impact of those products. 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 grasp the latest trends in and 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.
In addition to the above, the Group is also endeavoring to complete an evaluation of risks for all of its products by 2020, along with working to convey this information to the customer and engaging in conversation with the customer, in order to contribute to the protection of human health and the environment.

System and Responsible Officers

The General Manager of the RC & Quality Assurance Division formulates 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 changes in the environment, including the concerns and requirements of society as well as the latest trends in government policy and laws and regulations as they relate to chemical substances.
Prior to market launch at the product development, market development, and raw materials procurement stages, the General Managers of the R&D laboratory, business divisions, and Works collect information concerning products containing chemical substances, conduct risk assessments of products, address laws and regulations relating to chemicals, and prepare product SDS* and labels. At the raw materials sourcing stage, the General Manager of the Purchasing Division acquires information relating to the chemical substances contained in the raw materials, the safety thereof, and applicable laws and regulations from the supplier. In this way, the general managers of business divisions and general managers of each Works oversee chemical safety across the full gamut from the sourcing of raw materials to shipment at their respective locations of responsibility. Throughout this process, judgements and assessments requiring expertise and scientific knowledge are requested to and made by the RC & Quality Assurance Division.
After market launch, the business divisions cooperate with each of the Works to manage the contained chemical substances regarding manufacturing and sales. In addition to preparing the product SDS and product labels, they also convey information to the customer and address compliance with laws and regulations. When raw materials, production formulations, and facilities are updated, when exporting to a new country, and when selling for a new application, they take necessary Change Control action (reconfirmation of management of chemical substances contained in the product, re-surveying product information, reassessment of product risks, and reconfirmation of regulatory compliance and standard compliance, etc.). During both the pre-market launch and post-market launch stages, any newly acquired product information is recorded in the chemical product safety information system to ensure that management, including addressing compliance with laws and regulations and the gate check during shipping, is more thorough.
These systems are subject to internal audits at the business divisions and Works, and are checked and reviewed during the chemical product safety management audit implemented by the General Manager of the RC & Quality Management Division. The results of these audits are then reflected in the Product Stewardship Strategy the following fiscal year.

*
SDS: Safety Data Sheet.

Product Stewardship Accountability Structure

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 new application and submission requirements associated with efforts to reinforce the European REACH and other regulations. Thereafter, the Division analyzes the Group-wide impact of each requirement 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 for handling these requirements, 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.

Goals and Results

KPI Scope of Compilation FY2017 FY2018 Medium to Long-term
Goals Results Level
Achieved
Goals Goals
Product risk assessment implementation rate Mitsui Chemicals, Inc. Complete assessment of high-priority products 36% Complete assessment of low-priority products At least 99%
(FY2020*1)
Provision ratio of the latest safety information for all products*2 Mitsui Chemicals, Inc. 100% 100% 100% 100%
(FY2025)
Number of legal and regulatory violations Mitsui Chemicals, Inc. 0 0 0
*1
The target year is set to 2020 in line with WSSD 2020 goals.
*2
Most recent SDS submission rate.

Review and Challenges

The Mitsui Chemicals Group has established targets for around 2020 as the medium-term Product Stewardship goals.

Targets for Mitsui Chemicals Group Product Stewardship 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.

Review and challenges for achieving target 1:

Challenge (1)Reinforce governance in a bid to fully comply with all newly enacted and amended laws
FY 2017results
  • We responded in a planned manner to newly implemented and revised laws relating to Group products. In particular, we responded to revisions to TSCA of the U.S. in cooperation with affiliates in the U.S.
  • In order to respond appropriately to the high pace of regulation reinforcement outside of Japan, we established a network that accurately collects information on local laws and regulations through legal and regulatory experts at affiliates in Europe, the U.S., and China.
FY 2018plan

Along with expanding this information collection network to Southeast Asia, we will work to build a system that addresses regulations throughout the entire Group.
Until now, food packaging materials were regulated under self-imposed positive list (PL) industry standards, but Japan is set to introduce a national PL system coinciding with the revisions to the Food Sanitation Act of Japan. In preparation for the start of this system, we are handling this situation in a planned manner in cooperation with industry associations.

Challenge (2)Thorough chemicals management after product release to market
FY 2017results
  • We revised the internal Group rules regarding the Change Control of products in order to reinforce the mechanism by which we ensure management of products and chemical substances contained in products in a continuous manner even after market launch.
FY 2018plan

We will engage in thorough management by instilling the revised rules for Change Control.

Challenge (3)Build a structure that properly conveys information that in turn complies with diversifying regulatory requirements
FY 2017results
  • We undertook the building of a structure designed to deploy the chemical product safety information system (SAP-EHS) to affiliates in order to share product information and safety information with affiliates.
FY 2018plan

We will further expand the functions of SAP-EHS to comply with chemSHERPA and other schemes used to convey information about chemical substances contained in products and will work to deploy this to affiliates.

Review and challenges for achieving target 2:

Challenge (1) Undertake risk assessments as well as risk management via the supply chain for all products
FY 2017results
  • We completed the assessments of high-priority products from among the Group products that underwent preliminary assessment and were specifically deemed to require priority assessment.
FY 2018plan

We will continue to assess low-priority products. Moreover, we will begin providing assessment results of high-priority products to customers.

Challenge (2) Business/product development that incorporates sound chemicals management perspectives
FY 2017results
  • We began an initiative to confirm risks regarding substances contained in products at an earlier stage of development in order to enable sustainable product development that is safer and more secure.
FY 2018plan

We aim to instill this initiative through e-learning, educational seminars, and other educational activities.

Challenge (3)Put in place a safety evaluation platform that engenders the confidence of society and acquire cutting-edge technologies
FY 2017results
  • External experts investigated Group animal testing facilities and confirmed that these facilities and their operations were appropriate.
  • In an effort to contribute to establishing the technologies for an alternative method to animal testing, we participated in activities to improve the precision of predicting irritation in the OECD QSAR toolbox and participated in the activities of the OECD guideline project for an alternative method for sensitivity testing. We presented the results for each at the Japanese Society for Alternatives to Animal Experiments.
FY 2018plan

In fiscal 2018, we will work to further increase the accuracy of the OECD QSAR toolbox and improve in vitro irritation testing to better advance animal testing alternatives.