Product Safety

Basic Policy

The Global Framework on Chemicals (GFC) adopted in 2023 is a new framework for international management of chemicals targeting 2030. The purpose is to protect the environment and human health, and prevent or, where prevention is not feasible, minimize adverse effects from chemicals and waste.
Based on this GFC, Mitsubishi Chemical (MCC) strives to protect the health and safety of all people involved in our business activities and minimize environmental impact throughout the life cycle.

1. We analyze the impact of products we handle on health, safety, the environment, and other elements throughout the product lifecycle and engage in activities aimed at minimizing risk.
2. We comply with laws, regulations, agreements, and other rules relating to management of the chemicals we handle, and provide information for using the products safely.
3. We consistently check information on the safety of the raw materials used and support sustainable product development.

Management System and Rules

Mitsubishi Chemical (MCC) maintains a system, including internal rules and systematic checks, that ensures the rigorous product stewardship-based product safety in all its business domains.
To effectively utilize the favorable properties of its chemical raw materials, MCC seeks out, aggregates and shares within the company information on all substances related to its products, including that on chemical hazards, applicable domestic and international regulations, and the results of risk assessments. In addition, we have built a support structure to better enable the business domains to implement proper chemicals management.
Because chemical regulations vary by country and region, MCC has appointed persons responsible for overseeing Product Safety at the regional headquarters to reinforce the global management system.
We have laid out the essentials of product safety in our Product Safety Regulations. Furthermore, we have formulated guidelines and manuals that provide concrete methods for working within regulations, authoring and issuing SDSs^*1 and implementing voluntary chemicals management. These efforts help ensure proper management.

• *1Safety data sheet (SDS): A document for providing information on the properties, hazards and toxicity, safety measures and emergency responses concerning chemical substances when transferring or providing chemicals to other business entities.

Compliance with Product Safety Regulations

Japanese Laws and Regulations

MCC complies with wide-ranging laws concerning chemicals, including the Chemical Substances Control Law (CSCL), the Industrial Safety and Health Act’s requirements concerning filing new chemical substance notifications, and the Poisonous and Deleterious Substances Control Law’s requirements concerning the registration and management of manufacturing, importing and sale businesses as well as record maintenance. To ensure that such compliance is thorough and comprehensive, MCC has established internal rules and guidelines related to compliance with domestic laws and carries out centralized management using a database of notifications filed.
In fiscal 2023, we performed a risk assessment and coordinated with the relevant departments on building a framework for management by revising SDSs and appointing chemical substance managers due to the addition of Notifiable Substances for which delivering SDSs is required accompanying the revision of the Industrial Safety and Health Act.

Overseas Laws and Regulations

Countries around the world have established laws regulating chemicals aimed at accomplishing the United Nations 2030 Agenda for Sustainable Development.
To respond to such changes, we are working with the regional headquarters and overseas Group companies to collect the latest information on legal requirements in each region or location and develop a system to ensure a more accurate response to regulations.
The extension of registration deadlines originally scheduled in 2023 was announced and these will be extended in phases according to the tonnage range and hazard class, particularly for UK REACH^*2 and Turkey REACH (KKDIK)^*3, MCC revised its registration plans in line with the new deadlines to ensure a smooth registration process for UK REACH/KKDIK.

• *2UK REACH (UK registration, evaluation, authorisation and restriction of chemicals (REACH)): Regulations regarding the registration, evaluation, authorisation and restriction of chemical substances in the UK, which closely resembles EU REACH.
• *3KKDIK: Regulations regarding the registration, evaluation, authorisation and restriction of chemical substances in Turkey, which closely resemble EU REACH.

Voluntary Chemicals Management Initiatives

To prevent the theft and/or abuse of chemicals, MCC has established its own list of MCC voluntarily controlled chemicals, which includes voluntarily designated substances in addition to legally designated or restricted substances. We have established safety management guidelines for managing these substances at plants and laboratories, during logistics operations and during transfer to customers. In this way, we are working to reinforce the management of such substances.

Product Supply Chain Communication (SDS, etc.) and Risk Assessment Initiatives

MCC gathers information on hazardous properties and regulations relating to substances contained in chemicals to ensure that customers can handle and manage products safely. We provide information on product hazardous properties on SDSs in the GHS^*4 format required by each country, conduct risk assessments, and manage risks.

• *4Globally Harmonized System of Classification and Labelling of Chemicals (GHS): A system for classifying chemicals by the type and degree of their hazardous properties based on globally harmonized rules and communicating this information using labeling and the provision of SDSs.

In-house product safety training

In addition to basic chemicals management education, MCC hosts the Product Safety Seminar on a monthly basis at MCC Group headquarters. This seminar serves to teach employees, including Group company employees, about increasingly stringent regulations in and outside Japan and how to address them.

In fiscal 2023, a total of 3,092 employees participated in seminars on the topics of product risk assessment and autonomous management in response to revision of the Industrial Safety and Health Act, SDSs and labeling, transport of hazardous substances, and other topics. We also provided online education for the entire company, including plants and the R&D center, on the Poisonous and Deleterious Substances Control Law and held liaison meetings on specific topics, such as food container and packaging material regulations and chemical product regulations in certain countries. In addition, we provided basic training on relevant laws on 12 occasions at plants, our R&D center and Group companies, providing detailed, concrete guidance on working within laws. We have also established a system that enables employees to repeat training at any time, using the internal portal site.