Promotion of recycling, managing chemical substances,
and approaches toward energy saving.
Managing Chemical Substances
Management of chemical substances is a key priority for the Company from the perspective of social responsibility. In addition to observing all laws and regulations, our group-wide efforts ensure the correct management of chemical substances while we remain mindful of globally expanding environmental issues. To this end, we have defined the responsibility to local and international communities as one of the TOK Group Creeds, which break down the management principles, and have been working to reduce our impact on the environment, including combating global warming, managing chemical substances, effectively utilizing resources, and reducing waste, thereby gearing up our product stewardship activities.
Accurately Evaluated Chemical Substance Risks
in a Timely Fashion and Properly Managed These Risks
The risk management of chemical substances can be interpreted as risk management in each part of the supply chain. To this end, it is necessary to provide information in accordance with the flow of materials. In each of the development, manufacturing, sales, and disposal stages, TOK creates and implements procedures for complying with all laws and regulations and managing risks.
Regarding the risk management of chemical substances, our continued efforts culminated in the elimination of PFOA* in 2020. Through these efforts, we have eliminated PFOA and its salts. We will also eliminate the use of PFOA-related substances within 2021. (see page 108, TOPICS, “Response to the Revised Chemical Substances Control Law”)
* Perfluorooctanoic Acid
Maintain Upstream Management System
TOK is working to establish a system for properly conveying information on the chemical substances throughout the supply chain as part of its product stewardship activities, a key pillar of Responsible Care. Timeliness and the accuracy of information are vital when conveying such information about chemical substances. Upstream management is very important for the timely and accurate receipt of information about chemical substances from upstream suppliers. In addition to the information about chemical substances received from these suppliers, TOK must manage the latest information about chemical substance regulations in each country and then display the information in product safety data sheets (SDS) and labels to present its customers with accurate and relevant information about the chemical substances in a timely manner.
In 2020, we streamlined the internal information sharing process so that the timeliness of SDS information would not be compromised during the COVID-19 pandemic. On the other hand, we found problems with work efficiency and information security in the process of obtaining raw material information from suppliers. We will examine how to rationalize the operation of this process.
Risk management in each part of supply chain
(1) Obtaining information about revisions to laws and regulations and treaties
For the chemical substances handled by the TOK Group, we put in place a system for complying with legal requirements and ascertaining the use of regulated substances under laws and regulations and treaties that include chemical substance management laws and the regulations in each country, such as the REACH regulation*1 and laws governing conflict minerals,*2 and determining whether or not such substances may be used. Moreover, for high-risk chemical substances whose use will be prohibited in the future due to tighter regulations, we have proposed and are managing the progress of elimination plans for all products to ensure that the use of such substances is discontinued and inventories are disposed of prior to the implementation of the applicable laws and regulations.
(2) Development stage
For newly developed raw materials, in addition to the legal and regulatory information, we check to confirm whether they contain chemical substances identified in our own TOK Group Standards on Chemical Substances Management, which stipulate substances whose use is prohibited or should be eliminated. Moreover, we check the developed products with respect to customer’s requirements as well. If the specified substances exceed the levels in the TOK Group Standards on Chemical Substances Management, we propose an alternative plan and strive to eliminate them.
(3) Production stage
All raw materials used to manufacture products are subject to occupational health and safety risk assessments. The Company identifies hazardous factors in the production environment, clarifies the hazard level, implements measures to mitigate and eliminate the hazardous factors based on the risk level, and then takes action to lower the risk. In this way, TOK maintains the proper work environment for all employees.
(4) Sales stage
TOK has connected its ERP system, which manages product shipment volumes, and its chemicals and PRTR management system, which manages chemical substance composition, to create a framework for automatically calculating the volume of transferred chemical substances. With this framework, TOK can appropriately report chemical substance volumes and apply for their usage in accordance with the Chemical Substances Control Law*3 and the PRTR Law*4 in Japan, as well as the laws and regulations of the countries that import its products.
(5) Disposal stage
Waste from each site is thoroughly sorted by type and recycled, and properly disposed of when necessary. For industrial waste disposal service providers contracted to dispose of waste, we provide information about the type of waste and handling precautions through the Waste Data Sheets (WDS). The Company periodically visits al service providers for on-site audits and to ensure that all waste is being properly disposed of in accordance with the contractual agreements.
*1 REACH regulation: Registration, Evaluation, Authorization and Restriction of Chemicals; This is an EU regulation that manages the registration, evaluation, and accreditation of chemical substances through an integrated system.
*2 Conflict minerals: Refer to four types of minerals that include tin, tantalum, tungsten, and gold mined in the Democratic Republic of the Congo and adjoining countries experiencing armed conflicts. These minerals are regulated under the U.S. Dodd-Frank Act (financial regulatory reform act).
*3 Chemical Substances Control Law: Act on the Evaluation of Chemical Substances and Regulation of Their Manufacture, etc.
*4 PRTR Law: Act on Confirmation of Release Amounts of Specific Chemical Substances in the Environment and Promotion of Improvements to the Management Thereof
The Cabinet Order for Partial Revision of the Enforcement Order of the Act on the Evaluation of Chemical Substances and Regulation of Their Manufacture (Chemical Substances Control Law) was promulgated on April 21, 2021 (effective date: October 22, 2021). This Cabinet Order adds PFOA and its salts to the Class I Specified Chemical Substances under the Chemical Substances Control Law, following the listing of new substances subject to elimination at the Ninth Meeting of the Conference of Parties to the Stockholm Convention on Persistent Organic Pollutants (POPs) in May 2019. In 2022, PFOA-related substances will also be included into the Class I Specified Chemical Substances in 2022. PFOA, its salts, and PFOA-related substances had been commonly used for photoresists and anti-reflectives for semiconductor production until several years ago. However, the PFOA should be categorized as a persistent organic pollutant based on the review by the Persistent Organic Pollutants Review Committee under the Conference of Parties to the Stockholm Convention on POPs, and the Japanese government promulgated the Cabinet Order above.
For low-concentration PCBs,* we have undertaken proper storage and management in accordance with the prescribed storage standards for waste containing PCBs at three sites (Sagami Operation Center, Shonan Operation Center, and Gotemba plant), while also filing the necessary reports with the government. In 2020, we formulated a road map to dispose of all electrical substation facilities and related waste used and stored at all sites by the legally mandated deadline of 2027. The Company intends to dispose of this waste in stages by drawing up plans to update equipment in a way that does not interfere with the production activities at each site.
* Polychlorinated biphenyl (PCB): A kind of organic compound; PCB was formerly used for thermal media, insulating oils, coatings, and other applications because it excels in terms of heat resistance and electrical insulation. However, because of its poor degradability and high toxicity, PCB production was discontinued in 1972. Nevertheless, little progress has been made with regard to disposal, and the managers responsible for storage are required to place it under strictly controlled conditions.
Participation in chemSHERPA
In July 2017, TOK adopted the chemSHERPA information transfer schemes for chemical substances contained in products. Initially proposed by the Ministry of Economy, Trade and Industry, chemSHERPA was established with agreements of some electronics-related companies. The scheme aims to create a common format for accurately and efficiently conveying information about chemical substances contained in products from upstream to downstream operations. As the organization that manages chemSHERPA, JAMP*1 counts 455 companies*2 (including TOK) as members. Through this organization, TOK obtains the latest information about chemical substances and broader trends, which is used to further improve its management of chemical substances.
*1 Joint Article Management Promotion-consortium
*2 As of May 31, 2020
Responsible mineral procurement
We promotes responsible mineral procurement throughout the supply chain based on the spirit of coexistence and co-prosperity with our business partners, as well as laws, regulations and social norms.
Future Issues and Initiatives
As semiconductor demand has been rising more than ever, the supply-demand conditions have also become tight for certain chemicals used in semiconductor production. It may not be commonly known that this undersupply results not only from material procurement issues and under capacity at manufacturers but also from restrictions on the acceptable manufacture volume for new chemicals based on the volume reporting requirement stipulated by the Chemical Substances Control Law. In some cases, it takes about two years from reporting to permission when acceptable manufacture volumes can be changed. In our industry with technological innovation, it is difficult to forecast customer demand in advance and report planned changes in time. Our requirement for the coming years is to devise a system that enables adaptation to global changes.