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.
Establish Chemical Substance Information Management System
To stringently control the different chemical substances handled within the TOK Group, the company started to operate a chemical substances management system in 2005 with which TOK performs the centralized management of chemical substances by collecting information on such substances and the diverse laws and regulations.
In 2022, the chemical substance management system was revised to strengthen the company’s response to international environmental laws and regulations. As a specific revision, a function was introduced to rapidly determine the applicability of laws and regulations in each country to the chemical substances handled by TOK. After full-scale operation in 2023 onward, the revised system will help to improve chemical substance research efficiency.
Continue to Strengthen and Operate Chemical Substance Management System
TOK is working to maintain and strengthen the system to properly convey information on chemical substances throughout the supply chain as part of its product stewardship activities, a key pillar of Responsible Care. In response to international laws and regulations and customer requirements, the company clarifies the chemical substances to be managed under the TOK Group Chemical Management Standards and uses them as a means for properly conveying information on chemical substances in the supply chain. It is impossible to permanently use these standards once established, but the Group needs to update them with the latest information of the time for proper operation.
In 2022, the TOK Group Chemical Management Standards were updated to Version 8 in order to incorporate the latest information on environmental laws and regulations in Japan and overseas and then revised the response forms for suppliers. In addition to these activities to collect and manage the latest information on international chemical substance regulations, TOK will promptly update chemical substance information on the raw materials received from suppliers and reflect that information into the SDS and labels of all products, thereby further providing timely and accurate chemical substance information to customers.
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.
(1) Obtaining information about revisions to laws, regulations, and treaties
For the chemical substances handled by the TOK Group, the company has in place a system for complying with legal requirements and ascertaining the use of regulated substances under such laws and regulations 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 because of tighter regulations, TOK proposed and is managing the progress of elimination plans for all products to ensure that the use of such substances is discontinued prior to the enforcement of the applicable laws and regulations.
(2) Procurement stage
In addition to SDS*3 for raw materials, TOK asks suppliers to submit the Warranty of Nonuse of Prohibited Substances to guarantee that the prohibited substances in the TOK Group Chemical Management Standards*4 are not contained in raw materials. TOK shares chemical substance information with suppliers based on the obtainment of these forms and pursues the correct identification of chemical substances contained in raw materials.
(3) Development stage
For newly developed raw materials, in addition to the legal and regulatory information, TOK checks whether they contain chemical substances subject to the TOK Group Chemical Management Standards. Furthermore, the company performs similar checks for customer requirements concerning newly developed products and formulate a substitution plan in the event of excess of a specified standard.
(4) Production stage
All raw materials used to manufacture products are subject to occupational health and safety risk assessments. TOK 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.
(5) Marketing stage
By linking the ERP system for managing product shipment volumes and the chemical substance management system that contains product composition data, the company automatically calculates the transfer volume of chemical substances, reports the proper volumes, and requests their applications in accordance with the Chemical Substances Control Act*5 and the PRTR Act*6 of Japan and with environmental laws and regulations of importing countries. The company also enabled the issuance of SDS documents in accordance with the current local laws and regulations using the SDS*3 preparation system, so that proper safety information will be provided to users.
(6) 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, TOK provides information about the type of waste and handling precautions through the Waste Data Sheets (WDS). The company periodically visits service providers for on-site audits 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 EU regulation manages the registration, evaluation, and accreditation of chemical substances through an integrated system with the aim of ensuring complete fulfillment of responsibility on the producers’ part, as well as thorough compliance with preventive principles.
*2 Conflict minerals: Four minerals (tin, tantalum, tungsten, and gold) produced in the Democratic Republic of the Congo and surrounding conflict zones; These minerals are regulated under the U.S. Dodd-Frank Act (financial regulation reform act). From the perspective of responsible mineral procurement, the TOK Group includes cobalt and mica in the scope of investigations, in addition to the four minerals above.
*3 SDS: Safety Data Sheet
*4 TOK Group Chemical Management Standards: Clarifies chemical substances to be managed in order to respond to international laws and regulations and customer requirements
*5 Chemical Substances Control Act: Act on the Evaluation of Chemical Substances and Regulation of Their Manufacture, etc. (Japan)
*6 PRTR Act: Act on Confirmation of Release Amounts of Specific Chemical Substances in the Environment and Promotion of Improvements to the Management Thereof (Japan
Initiatives in Response to Global Environmental Regulations
In 2022, PFHxS was newly added to Annex A (global ban) of the POPs Convention. The overall regulation of PFAS was also examined in the EU REACH Regulation and the United States TSCA. In this way, the global regulation on persistent and highly accumulative chemical substances proceeded in this year.
In Japan, major chemical substances management regulations have been amended one after another, such as the Industrial Safety and Health Act and the PRTR Act. TOK personnel need to properly disclose the information and safety of chemical substances contained in our chemical products to our customers and employees and to develop and manufacture beneficial chemical products while taking environmental considerations into account.
In particular, the PFAS restriction proposed by the EU in 2023 is targeted at a wide range of chemical substances and will affect not only TOK and other chemical manufacturers but also a broad range of industries engaged in equipment, containers, and packaging materials.
TOK not only complies with the regulations but also proactively provides information concerning safe handling through communication with industrial associations and regulatory authorities in order to minimize the impact of environmental regulations on our production.
Properly Comply with PCB Special Measures Act
For low-concentration PCBs, the company has 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 2022, TOK undertook activities to dispose of all electrical substation facilities and related waste used and stored at all sites by the legally mandated deadline of 2027, in accordance with the road map formulated in the previous year.
TOK will continue 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; PCBs were formerly used for thermal media, insulating oils, coatings, and other applications because they excel in terms of heat resistance and electrical insulation. However, because of poor degradability and high toxicity, PCB production was discontinued in 1972.
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 506 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 August 14, 2023
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
In the understanding of chemical substances management, a shift from hazard management to risk management is indispensable. TOK regards the enhancement and use of risk assessment as a key requirement. TOK also considers that the communication of risk information through supply chain leads to the matured chemical substances management throughout the entire supply chain in all industries. Under the concept of the material issue of supply chain sustainability, the Company strives to establish a system for the timely and proper communication of risk information.