Ensuring the Safety of Chemical Substances

Goals and Achievements of Major Initiatives

  • Enhance functions of comprehensive chemical substance information management systems.
  • Continue to expand deployment of the Wercs and Atrion at DIC Group companies overseas.

Goals for fiscal year 2020
  • Continue working to create a new comprehensive global system for managing chemical substance information.
  • Deploy the Wercs at DIC Group companies in the Philippines.
Achievements in fiscal year 2020
  • Work proceeded toward the advance launch in Japan in 2021. A team was established at a Group company in the PRC to promote deployment in the PRC.
  • Preparations for deployment in the Philippines proceeded, but was not completed because of COVID-19.
Evaluation ★★★
Goals for fiscal year 2021
  • Launch the new comprehensive global chemical substance information management system in Japan.
  • Promote deployment of the Wercs and Atrion at DIC Group companies overseas.

  • Review efforts to comply with regulations in Japan.
  • Comply with regulations overseas.

Goals for fiscal year 2020
  • Commence review of business flow across sites.
  • Maintain status of chemical substances to which advance K-REACH registration applies and prepare to reregister existing chemical substances.
  • Promote compliance with Taiwan’s TCSCCA.
Achievements in fiscal year 2020
  • The review process was completed and a new business flow was drafted.
  • A process was established for maintaining advance K-REACH registration status and a policy was set regarding the consecutive reregistration of existing chemical substances.
  • Attention was focused on steps taken by local authorities.
Evaluation ★★★
★★★
★★★
Goals for fiscal year 2021
  • Verify new business flow and make necessary amendments.
  • Address revisions to China REACH.
  • Promote compliance with Taiwan’s TCSCCA.
  • Evaluations are based on self-evaluations of current progress.
    Key: ★★★ = Excellent; ★★ = Satisfactory; ★ = Still needs work

Policies and Organization

Basic Approach

The DIC Group continues working to provide appropriate information to stakeholders to ensure the appropriate handling of its products over their entire life cycle.

In 2002, countries and territories participating in the World Summit on Sustainable Development (WSSD) in Johannesburg, South Africa, including the United States, European Union member states and Japan, agreed on a goal for the management of chemical substances to minimize the impact thereof on human health and the environment by 2020. In 2015, the UN General Assembly set the SDGs, a collection of common goals designed as a blueprint for global society.
As a comprehensive chemicals manufacturer with operations around the world, the DIC Group created uniform standards for managing chemical substances that exceed legal and regulatory standards well before the WSSD. In line with its Environment, Safety and Health Policy (established in 1992), the Group views product stewardship* as the foundation of Responsible Care and works to provide stakeholders with information on the appropriate handling of its products over their entire life cycle. The Group has also promoted efforts to eliminate substances of high concern specified in the Montreal Protocol on Substances that Deplete the Ozone Layer, the Stockholm Convention on Persistent Organic Pollutants and the Rotterdam Convention on the Prior Informed Consent Procedure for Certain Hazardous Chemicals and Pesticides in International Trade, as well as to develop alternatives that exert less of an impact on the environment. To this end, the DIC Group has established bases in Greater China and the Asia–Pacific region, better positioning it to disseminate information to Group companies around the world.

  • Product stewardship is a philosophy that emphasizes assessing product-specific risks and sharing findings and information on appropriate handling with stakeholders with the aim of reducing

Managing Chemical Substances

01Changing Trends in Chemical Substance Management

In 2003, the UN Economic Commission for Europe (UNECE) issued the first edition of the GHS.*1 Many countries have since introduced the GHS, including Japan, which in 2006 compelled use of the system in the Industrial Safety and Health Act. As part of its efforts to ensure effective product stewardship, the foundation of Responsible Care, and to emphasize the management of chemical substances across its entire supply chain, DIC sought to respond to this development, as well as to provide customers with crucial hazard-related information. Concurrent with the enforcement of the act in 2006, the Company began providing GHS-compliant SDSs.*2 In 2009, DIC developed CIRIUS (Chemical Substance Information Comprehensive Management System), a proprietary system that centralizes the management of information on chemical substances in raw materials and products, as well as automatically checks various laws and regulations—including the Act on the Evaluation of Chemical Substances and Regulation of Their Manufacture, etc.—thereby facilitating swift responses to customers’ requests for information.
In 2013, DIC began using the Wercs, a global SDS and label creation system that facilitates the translation of data into 46 languages, for products destined for overseas markets. In 2015, the Company also began deploying the Wercs at overseas Group companies. At present, the system is in use at 23 companies in 11 countries and territories. The Sun Chemical Group has used Atrion International Inc.’s chemical substance information management system since 2006, enabling it to provide highly accurate information to its customers worldwide.
Recognizing the importance of specialized expertise in the area of chemical substance management, DIC has trained employees in the manufacture, import and handling of chemical substances in accordance with applicable laws and regulations since 2000. In 2007, the Company introduced a proprietary licensing system designed to maintain and enhance the skills of its in-house chemical substance management experts.

  • The GHS was formally adopted by the UN in 2003 to facilitate the uniform global classifi cation and labeling of hazard information for chemicals.
  • SDSs contain information on the hazards of chemicals to ensure their safe handling.
The DIC Group’s Comprehensive Global Chemical Substance Information Management Systems

02Principal Initiatives in Fiscal Year 2020

Laws and regulations governing chemical substances are updated every year. In fiscal year 2020, the DIC Group took steps to address revisions to the PRC’s Measures for Environmental Administration of New Chemical Substances (China REACH), applied for inclusion in Vietnam’s updated National Chemical Inventory (NCI) and completed advance registration under Turkey’s KKDIK Regulation (KKDIK is an acronym consisting of the fi rst letter of each word in “registration, evaluation, authorization and restriction” in Turkish), otherwise known as Turkish REACH. At the same time, the Group collaborated with pertinent departments in Japan and overseas to gather information and formulate measures in a timely manner in response to developments surrounding the United Kingdom’s withdrawal from the European Union, the Republic of Korea (ROK)’s Occupational Safety and Health Act and Taiwan’s Toxic and Chemical Substances of Concern Control Act (TCSCCA).
In the area of systems for managing chemical substance information, the Group continued to promote the Global Chemical Information Project (GCIP), the objective of which is to build a new global system for managing chemical substance information. This new system will integrate CIRIUS and the Wercs, facilitating the swift provision of consistent, accurate information to customers across the DIC Group and improving the ability of Group companies in the PRC and the Asia– Pacifi c region to ensure legal and regulatory compliance. The Group’s aim is to begin deploying this system globally in fiscal year 2024.

VOICE

We participate in industry association activities and were involved in the revision of Japan’s chemical substance law.

Group Manager, Chemical Management Group, Responsible Care Department Shinobu Yamaguchi

The Responsible Care Department plays an active role in the JCIA and on behalf of DIC, a core member, we were involved in the revision of the Act on the Evaluation of Chemical Substances and Regulation of Their Manufacture, etc. Throughout this process, we struggled to cope with differences of opinion arising from the diverse perspectives of pertinent ministries, including the Ministry of Economy, Trade and Industry (METI). The situation was similar within the JCIA, with the views of individuals diverging depending on the company they represent, so it took a lot of time and effort to get everyone on the same page regarding revisions.
Efforts to meet the WSSD goal for chemical substance management will conclude in 2020. Nonetheless, initiatives aimed achieving the SDGs will continue until 2030 and discussions have already begun with the aim of developing a vision for as far in the future as 2050. As a company that handles chemical substances, we pledge to never lose sight of the need to act in a responsible manner to ensure that DIC Group can continue to play a central role in the JCIA in the years ahead.

Group Manager, Chemical Management Group, Responsible Care Department Shinobu Yamaguchi

03Efforts Going Forward

Promoting the Creation of a New Comprehensive Global System for Managing Chemical Substance Information

Guided by its DIC111 medium-term management plan, one theme of which is to reengineer business processes, DIC will continue to advance the creation of a new global chemical substance information management system that integrates CIRIUS and the Wercs with the goal of beginning to use the new system—dubbed Chemicals Information Global Network Access System (CIGNAS)—in fiscal year 2024. The Company is also pushing ahead with the creation of an information management framework to ensure the effective management of information using the new system.
Given the recent tightening of laws and regulations governing chemical substances, the scope of related information that must be managed has expanded and the demands on individuals responsible have become signifi cantly greater and more complex. Requests from customers to conduct research on chemical substances are also expanding, underscoring the importance of ensuring an appropriate global response to changing circumstances. Having conducted a preliminary study in recent years, the Responsible Care Department reached the conclusion that the optimal approach was to strengthen existing systems to create a new global chemical substance information management system and to establish a new information management framework, prompting it to embark on this process. DIC plans to launch CIGNAS fi rst in Japan in fiscal year 2021 before gradually expanding deployment to Group companies overseas.

VOICE

We are working to improve customer confidence by promoting legal and regulatory compliance initiatives.

Corporate ESH Department, DIC (China) Co., Ltd. Meijing Chen

I am in charge of the GCIP at DIC (China). In fiscal year 2020, we explained the GCIP’s plan for deploying CIGNAS and the Wercs in 2022 to local Group companies (16 production facilities) on an individual basis. We are currently analyzing the documentation of each of these companies with the objective of creating an operations manual for chemical substance information management going forward.
As a legal and regulatory officer responsible for helping ensure compliance with laws and regulations governing chemical substances overseas, I gather information on laws and regulations in countries other than Japan and formulate Groupwide policies to guide the development and implementation of responses by individual companies. I try to explain complex laws and regulations, as well as to suggest appropriate responses, as simply and clearly as possible to help deepen employees’ understanding. We believe that this approach is important to gaining the confidence and trust of customers and society at large. We will continue to promote a variety of related initiatives that contribute to increased trust in the DIC Group.

Corporate ESH Department, DIC (China) Co., Ltd. Meijing Chen

Creating the CIGNAS Global Chemical Substance Information Management System

Starting Up a New Project

In July 2019, DIC inaugurated a project to oversee the creation a new global chemical substance information management system and established a project team consisting of representatives from departments well versed in chemical substance management who were invited to play a role in creating the new system. In addition to system design and development, the project team reviewed and standardized procedures to be used globally for gathering information to ensure smooth operations. From October through December 2019, team members visited 11 overseas Group companies in three countries to learn about their procedures for managing chemical substances, and reflected findings in the items to be considered as part of the project. In addition, these inquiries underscored the team’s understanding that Group companies were also anxious for a chemical substance information management system.
In fiscal year 2021, DIC will launch CIGNAS in Japan, as well as commence full-scale preparations for deployment in the PRC in 2022. The Company will also look at alternative approaches to giving presentations at DIC Group companies in Taiwan and the Asia–Pacific region, which had originally been scheduled for 2020 but were canceled as a consequence of COVID-19.

Designing and Developing a New Global System

DIC is applying capabilities, experience and expertise accumulated in the design, development and operation of CIRIUS and the Wercs to designing and developing its new global system. The Company also recognizes that a unified global system for managing chemical substance information will enhance its operational efficiency and thus create a framework for data integration with its SAP system.
Individual divisions and departments make use of chemical substance information in its particular work. Accordingly, the system will be used not only by experts in the management of chemical substances but also by diverse other employees across the global DIC Group. The Group is thus aware of the importance of designing the interface so that even non-experts can easily extract and use essential information. The new system will store confidential information on, among others, the chemical composition of products and raw materials. For this reason, and because of the wide range of individuals using the system, meticulous attention to security is a key consideration in system design and development.

A Global Information Management Framework

Techniques used to manage chemical substance information vary greatly depending on country/territory and site, as does the quality of management. Given the expected further tightening of laws and regulations governing chemical substances and the increasing number and changing nature of substances used, implementing an organized global approach is essential. One of the ways the DIC Group is addressing this challenge is through the creation of a new global system. The Group recognizes that introducing a new system is only part of the solution, and so it has also commenced efforts to establish a new information management framework to support administration of the new system after creation and deployment. By the time the new system goes into operation, the Group will have implemented the new framework in the PRC and the Asia–Pacific region, as well as in Japan, its principal operating base, leveraging know-how accumulated in Japan to integrate information management, thereby ensuring consistent quality, securing compliance and strengthening governance. In fiscal year 2019, the Chemical Substance Information Management Group was established at DIC’s corporate headquarters in Tokyo to oversee this process. In April 2020, the Group also began promoting initiatives in Shanghai.

Complying with Laws and Regulations

01Complying with Laws and Regulations in Japan

DIC recognizes legal and regulatory compliance as central to risk management. In Japan, this includes fulfilling without exception obligations related to the reporting of new chemical substances set forth in the Act on the Evaluation of Chemical Substances and Regulation of Their Manufacture, etc., and the Industrial Health and Safety Act, and to the keeping of records on manufacturing, importing and sales laid out in the Poisonous and Deleterious Substances Control Act. To enhance the reliability of its compliance efforts, the Group has implemented diverse measures, from collecting and analyzing information to formulating guidelines, promoting awareness among Group companies and customers and integrating management using CIRIUS.
The Food Sanitation Act, which was amended in fiscal year 2018, stipulates the adoption of a Positive List (PL) system, which allows only substances that have been evaluated for safety to be used in utensils, containers and packaging for food. DIC manufactures a wide range of polymers, including polystyrene, inks and other raw materials used in food packaging. Accordingly, the Company is proceeding with efforts to gather information and gain authorization in cooperation with pertinent industry organizations. There were no violations of domestic laws requiring the registration or reporting of chemical substances by the Group in Japan in fiscal year 2020.

Outlook for Principal Initiatives in Fiscal Year 2021

The PRTR Law is scheduled for revision in fiscal year 2021. This will result in emphasis being placed on efforts to minimize risks associated with the handling of chemical substances over the entire life cycle of products, with standards for assessing the amount of substances present in the environment shifting from manufacturing and import volume to release amount. Substances in the register are also expected to be revised. DIC will take active steps to comply with the revised PRTR Law, as well as to provide basic PRTR information to customers. The Company will also promote the creation and distribution of SDSs that comply with JIS Z 7253, the Japanese Industrial Standards (JIS) standard for hazard communication for GHS-compliant labeling and SDSs. DIC will also take decisive steps to address the WSSD goal that supersedes the goal for 2020, which was expected to be discussed at the International Conference on Chemicals Management (ICCM) but was delayed due to the pandemic, paying close attention to how the new goal is reflected in policies, laws and regulations.

VOICE

DIC and Sun Chemical are collaborating to promote a chemical substance management project.

Director Global Regulatory, Sun Chemical Corporation Robert Kendrick

DIC and Sun Chemical are engaged in a project to identify the criteria needed, and the framework required, for an undertaking to support a global chemical communication management system. This project seeks to define specific chemical criteria that must be utilized to assure compliance with regulations anywhere in the world. The project will involve developing an SAP integration IT platform that is seamlessly accessible by global beneficiaries. This will require an IT investment platform designed to uniformly characterize the chemical composition and safety risk of purchased materials and manufactured commercial products; a system, process, tools and discipline to continuously identify and maintain material characteristic consistencies with both chemical data and system deliverables, such as SDSs and labels; and robust support for new and onerous chemical control regulations (i.e., the U.S. EPA TSCA reset, K-REACH and Global GHS) and to accommodate international language requirements. Our objective is to provide leverage to help establish material fitness guidance with global customers and brand owners and, ultimately, to create a platform to support technological innovation and assist in the coordination of global procurement activities.

Director Global Regulatory, Sun Chemical Corporation Robert Kendrick

02Complying with Overseas Laws and Regulations

Recent years have brought the establishment and amendment of major laws and regulations governing chemical substances across East Asia. Key examples include revisions to the ROK’s K-REACH legislation in fiscal year 2019 and the PRC’s China REACH legislation in fiscal year 2020. Other countries that currently do not have chemical substance registration systems, including Thailand, Vietnam, Turkey, Russia and Eurasian Economic Community member countries, are also moving in this direction.
Deployment of the GHS has been made mandatory in most countries, with latecomer India now taking steps toward enacting a law obliging GHS compliance. DIC gathers the latest information on chemical substances in overseas markets through local consultants, as well as through its global network, which includes Sun Chemical and other DIC Group companies, ensuring its ability to respond effectively to revisions to laws and regulations and to provide information to Group companies and customers. As a leading member of the JCIA working group charged with collecting Japanese companies’ opinions and proposals regarding the enactment and revision of laws and regulations, DIC conducts dialogue with government authorities, playing a leading role in ensuring the legal and regulatory compliance of JCIA member countries. There were no violations of overseas laws requiring the registration or reporting of chemical substances by the DIC Group in Japan in fiscal year 2020.

Outlook for Principal Initiatives in Fiscal Year 2021

The revised China REACH, which will come into effect in fiscal year 2021, is expected to compel a major overhaul of the DIC Group’s system for managing chemical substances subsequent to registration. Accordingly, the Group will respond swiftly as necessary. The Group will also press ahead with preparations to reregister existing chemical substances as required by K-REACH and Taiwan’s TCSCCA legislation, which began in fiscal year 2020.
The DIC Group will continue to gather information and take steps to register chemical substances to ensure compliance with newly introduced registration systems in other countries and territories. Additionally, the Group will keep abreast of developments surrounding India’s move to mandate GHS compliance and will submit opinions and proposals through the JCIA.

VOICE

We gather information on laws and regulations governing chemical substances overseas with the aim of increasing public trust in the DIC Group.

Manager, Chemical Management Group, Responsible Care Department, DIC Corporation Masato Inoue

In recent years, countries and territories around the world have taken steps to establish new or strengthen existing chemicals-related laws and regulations. Companies’ responses have necessarily expanded and become increasingly complex. The DIC Group, which continues to broaden its global presence, deals with a bewildering range of laws and regulations. Ensuring unfailing compliance wherever it has operations is essential for the Group to fulfill its responsibilities as a corporate citizen.
As a legal and regulatory officer responsible for helping ensure compliance with laws and regulations governing chemical substances overseas, I gather information on laws and regulations in countries other than Japan and formulate Groupwide policies to guide the development and implementation of responses by individual companies. I try to explain complex laws and regulations, as well as to suggest appropriate responses, as simply and clearly as possible to help deepen employees’ understanding. We believe that this approach is important to gaining the confidence and trust of customers and society at large. We will continue to promote a variety of related initiatives that contribute to increased trust in the DIC Group.

Manager, Chemical Management Group, Responsible Care Department, DIC Corporation Masato Inoue

We are working to properly understand and comply with diverse laws and regulations.

Import Control Team, DIC Korea Corp. Gu Gyo-ok

DIC Korea sells products imported from other DIC Group companies. Given the increasingly diverse and specialized chemical substance laws and regulations that importers in the ROK must comply with, including K-REACH, in fiscal year 2019 we established the Import Control Team to oversee related efforts. As a part of this team, I am responsible for making certain that the chemicals we import comply with applicable laws and regulations, as well as for assisting customers in this market to do the same. Correctly understanding and implementing a wide range of laws and regulations is the team’s fundamental and most important job, and our ability to work closely with related parties to respond in a timely manner is directly linked to the Group’s profitability. We also believe it is important to inform local customers about DIC’s policy regarding managing the safety of chemicals so that they can feel secure purchasing DIC Group products. Going forward, we will continue to hone our ability to ensure legal and regulatory compliance.

Import Control Team, DIC Korea Corp. Gu Gyo-ok

Training and Systems

In line with the principles of product stewardship, DIC recognizes the importance of greater employee awareness and knowledge to ongoing efforts to improve the safety of chemicals and manufactured products. The Company places considerable importance on training for individuals involved in the manufacture, import and handling of chemical substances in accordance with applicable laws and regulations and endeavors to improve employees’ awareness and knowledge of applicable laws and regulations in Japan and overseas, which it provides through its program to foster experts and its proprietary licensing system.

Fostering Experts

As a comprehensive global chemicals manufacturer, DIC recognizes legal and regulatory compliance as central to risk management and promotes training designed to foster experts in this area. The Company began offering an entry-level course on laws and regulations governing chemical substances in fiscal year 2014. By providing in-depth training annually to a limited number of individuals, DIC has succeeded in raising awareness of compliance across its entire labor force. A cumulative total of 204 individuals have taken part in this training to date.
Beginning in fiscal year 2021, DIC will switch to an online format to make it easier for employees in the target group—mainly employees at sites with technical departments— to participate in training. The Company is also currently working to redesign courses and prepare study materials to facilitate the creation of a practical program focused on various chemicals-related laws and regulations and a high-level program that will impart advanced knowledge about key laws and regulations such as the Act on the Evaluation of Chemical Substances and Regulation of Their Manufacture, etc., and the Poisonous and Deleterious Substances Control Act in Japan.

Licensing System in Japan

Under its proprietary licensing system, DIC provides mandatory specialized training for individuals in Japan engaged in the export and import of chemical substances and issues licenses to employees who have completed training and passed in-house examinations. Licenses are valid for two or three years, depending on the particular business. Training for individuals involved in exporting and importing chemical substances focuses on the Foreign Exchange and Foreign Trade Act, while that for individuals involved exclusively in importing centers on the Act on the Evaluation of Chemical Substances and Regulation of Their Manufacture, etc., the Industrial Health and Safety Act and the Poisonous and Deleterious Substances Control Act. To renew a license, an employee must once again go through training and pass the in-house examination. In fiscal year 2020, training was not provided because of COVID-19. Accordingly, the number of employees holding licenses was unchanged from fiscal year 2019.

Beginning in f iscal year 2021, DIC will continue to deepen the hierarchy of export licenses, and review the content of its training. In particular, the Company will establish a special qualification for individuals involved in the preparation of certificates of nonapplicability, an important part of export control. The Company is also currently creating a licensing system for employees who prepare certificates of origin, which have come to play a more important role in international free trade agreements in recent years with, among others, the signing of the Regional Comprehensive Economic Partnership (RCEP) and the coming into force of the UK–Japan Comprehensive Economic Partnership Agreement.

Training at Overseas Group Companies

The PRC has taken decisive steps to reinforce chemical substance management in that country, underscoring its increasing importance to business continuity. In fiscal year 2020, DIC (China)’s ESH Department provided training related to revised laws and regulations governing chemical substance management, which focused on laws and regulations scheduled for revision, notably China REACH, a set of nine compulsory national standards for VOCs, and the country’s Export Control Law. In that a single breach of any of these has the potential to negatively affect the entire DIC Group, the Group has promoted due diligence for all three since the public comment stage. Looking ahead, the Group will strive to improve chemical substance management through training focused on, among others, trends in related laws and regulations, using e-learning and other formats.

Presentation by Wendy Zhang of DIC (China)’s Corporate ESH Department on the pertinent Guobiao (GB) national standards

Presentation by Wendy Zhang of DIC (China)’s Corporate ESH Department on the pertinent Guobiao (GB) national standards

Explanation of changes to PRC laws and regulations for technical staff by Makoto Kosono (Changzhou Huari New Material)

Explanation of changes to PRC laws and regulations for technical staff by Makoto Kosono (Changzhou Huari New Material)

VOICE

I will continue to provide training aimed at ensuring legal compliance.

Manager, Chemical Management Group, Responsible Care Department, DIC Corporation Chisato Kuriyama

In recent years, with awareness of issues related to health and the environment, the drive to tighten chemicals-related legislation is gathering speed worldwide. This has led to the amendment of laws and regulations. For the DIC Group, which has operations worldwide, it is crucial that we ensure access to the latest legal and regulatory information and the ability to respond promptly and decisively. To this end, it is necessary that each employee has a proper grasp of laws and regulations and that pertinent information is shared among related departments.
In my capacity as a legal and regulatory officer, I will continue to promote training aimed at ensuring employees understand the relationship between DIC Group products and laws and regulations governing chemical substances that help ensure effective compliance.

Manager, Chemical Management Group, Responsible Care Department, DIC Corporation Chisato Kuriyama

We are working to expand legal compliance training.

Manager, Chemical Management Group, Responsible Care Department, DIC Corporation Hirofumi Higashino

In the modern world, legal and regulatory compliance is required across the board, from the manufacture and import of products through to sales, handling and export. A company that is unable to respond effectively cannot remain a going concern. Frameworks and systems designed to ensure compliance are important, but compliance cannot be achieved without the understanding of each and every employee of the DIC Group. The Group’s product portfolio is extensive, so the number of laws and regulations with which we must comply is considerable. We currently provide wide-ranging training regarding laws and regulations governing chemical substances. As one of the people in charge of this training, I will work to step up training to better respond to needs pertaining to employees and products to contribute to increasingly effective compliance.

Manager, Chemical Management Group, Responsible Care Department, DIC Corporation Hirofumi Higashino

I will continue working to enhance knowledge and understanding by providing ongoing training.

Regulation Control, Siam Chemical Industry Co.,Ltd. (SCI,Thailand) Monticha-Sudjai

As a legal and regulatory officer at Siam Chemical Industry in Thailand, I provide customer support and deal with government information requirements. Legal and regulatory officers are responsible for disseminating chemical substance information across the supply chain, which we do by making effective use of our hazardous substances management system. To this end, we have established a regulatory committee that meets monthly to deliberate legal and regulatory issues and provides SDSs that comply with the laws of different countries and territories. To improve the efficiency of this process, in 2014 Siam Chemical Industry introduced the Wercs. With the aim of maximizing the capabilities of the Wercs, in 2018 I was dispatched to Japan for advanced training in the use of the system, as well as in the use of an export management system that complies with Thailand’s new Trade Control on Weapons of Mass Destruction (TCWMD) Act, which will enter into force in 2020. I will capitalize on my newly acquired expertise to provide training for my colleagues at Siam Chemical Industry with the aim of enhancing knowledge and understanding.

Regulation Control, Siam Chemical Industry Co.,Ltd. (SCI,Thailand) Monticha-Sudjai

We are working to improve responsiveness to laws and regulations governing chemical substances.

Corporate ESH Specialist, DIC (China) Co., Ltd. Wenjing Zhang

I am in charge of responses to chemicals-related laws and regulations in the PRC. Operating in an increasingly harsh environment, we work continuously to improve compliance across all chemicals-related operations by promoting efforts aimed at reinforcing the chemical substance management capabilities of individual Group companies. We have also added content related to the management of hazardous chemicals to ESH audits to assess the chemical substance management capabilities of individual production facilities. I oversee training in the use of the Wercs and the BarTender labeling software, which we are using to ensure compliance in the area of materials safety data sheets (MSDS) and label production.
By auditing the efforts of trading companies in the PRC to handle hazardous chemicals, and by providing training on laws pertinent to chemical substances, we will continue working to raise employees’ awareness of laws and regulations governing chemical substances.

Corporate ESH Specialist, DIC (China) Co., Ltd. Wenjing Zhang

Assessing and Managing Risks

The DIC Group promotes efforts to manage product-specific ESH risks and share related information with stakeholders with the aim of reducing the impact of products over their entire life cycle—i.e., from the development of chemical substances through to procurement, production, transport, sales, use, and disposal or recycling.
The most important challenge in risk management is to assess risks in a manner that provides insight into trends related to, among others, the evolution of laws and regulations governing chemical substances and changing product life cycles. To accurately assess the risks associated with a product, it is crucial to secure information on the degree of exposure for people and the environment when the product is used, as well as to examine SDS and chemSHERPA hazard and toxicity information. To facilitate the more efficient gathering and dissemination of information necessary for the assessment of risks, the Group is currently promoting the creation of a new comprehensive global chemical substance information management system (for more information, please see page 106) and has formulated the DIC Sustainability Index (see page 54), and is working with technology, production and sales departments to enhance the accuracy of assessments. By thus ensuring the appropriate disclosure of information necessary to assess risks, the Group is confident that it will be able to provide a safer environment for the stakeholders using these products.
In developing new products, the DIC Group also promotes effective management by making use of the aforementioned two platforms, as well as evaluation sheets for environment-friendly products (see page 138), to assess hazard and toxicity risks, with the objective of providing ever-safer new products.

Socially Responsible Procurement

In line with the DIC Group Universal Purchasing Policy, DIC formulated the DIC Group Green Procurement Guidelines, which prohibit the procurement of materials containing hazardous substances in the seven categories below. The guidelines mandate the submission of a DIC Raw Materials Survey, an SDS and a chemSHERPA,* as well as a DIC Group Green Procurement Guidelines Survey, when purchasing raw materials, thereby creating a system for eliminating substances of concern. Submission of a Conflict Minerals Survey is also required.

  • Substances the production of which is prohibited, as outlined in Article 55 of Japan’s Industrial Health and Safety Act;
  • Substances designated as class-1 specified chemical substances in Japan’s Act on the Evaluation of Chemical Substances and Regulation of Their Manufacture, etc.;
  • Substances designated for monitoring under Japan’s Act on the Evaluation of Chemical Substances and Regulation of Their Manufacture, etc.;
  • Chemical substances the production of which is already prohibited, as detailed in Japan’s Act on the Protection of the Ozone Layer  Through the Control of Specified Substances and Other Measures (ozone-depleting substances listed in the Montreal Protocol);
  • Specified particulates denoted in Japan’s Air Pollution Control Act;
  • Specified poisonous substances indicated in Japan’s Poisonous and Deleterious Substances Control Act; and
  • Specified substances detailed in the Stockholm Convention on Persistent Organic Pollutants.
  • chemSHERPA is a scheme designed to facilitate the accurate and efficient sharing of information on chemical substances in products across the entire supply chain. DIC began using chemSHERPA in late fiscal year 2017.

Position on the Use of Animals in Testing

In line with the “3Rs” of animal use in research (“Replacement, Reduction, Refinement”), which are guidelines designed to ensure the more ethical use of animals in testing, the DIC Group actively promotes safe evaluation using quantitative structure–activity relationship (QSAR) models, which do not employ animals, and alternatives to animal testing.

Safe Product Transport

The DIC Group has created Yellow Cards containing simplified SDSs. This provides critical information to transport personnel, facilitating the appropriate responses in the unlikely event of an accident to protect the environment and ensure safety.