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
In managing chemical substances, systematization is essential because of the need for collecting and managing vast amounts of diverse information and making quick decisions. TOK has used a chemical substance management system since 2005 to collect and centrally manage substance and regulatory information. In 2022, TOK considered introducing a function to quickly determine compli ance with the environmental laws of different countries as part of further strengthening measures for environmental law compliance as well as to improve the efficiency of chemical substance investigations from 2023 onward. As the first stage in the subsequent func tional expansion in 2024, the company achieved automatic judgment at the time of shipment, leading to more efficient compliance with environmental laws. In the future, TOK will continue to promote information sharing and efficiency with related parties through further functional expansion in order to realize safer chemical substance management.
Continue to Strengthen and Operate Chemical Substance Management System
TOK is working to maintain and strengthen the system to properly share information on chemical substances throughout the supply chain as part of its product stewardship activities, a key pillar of Responsible Care. In compliance with international laws and regulations and in response to customer requirements, the company clarifies the management of chemical substances under the TOK Group Chemical Management Standards and uses the Standards as a means to properly share information on chemical substances within the supply chain. These standards cannot be set once and used forever without change but must be updated with the latest information according to the situation at hand.
In 2023, TOK drafted the eighth edition of the TOK Group Chemical Substance Management Standards as revised in 2022 and continues to obtain and manage the latest information on chemical substance regulations in each country. In addition, TOK will ensure that suppliers promptly update chemical substance information on raw materials 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 of 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 a system for complying with legal requirements, ascertaining the use of regulated substances under the REACH regulation*1 and laws governing conflict minerals,*2 and determining whether or not such substances may be used. Moreover, for chemical substances that are likely to be banned from the future tightening of regulations, TOK formulates reduction plans for all products and manages the progress of such plans so that the company can stop using such sub stances before the laws come into force.
(2) Procurement stage
In addition to the 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 these forms and pursues the correct identi fication of chemical substances contained in all raw materials.
(3) Development stage
For newly developed raw materials, in addition to the legal and regulatory information, TOK checks whether such raw materials contain chemical substances subject to the TOK Group Chemical Management Standards. Furthermore, the company performs similar checks for customer requirements for newly developed products and formulates a substitution plan in the event the specified standard is exceeded.
(4) Production stage
All raw materials used in the manufacture of 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 that risk level, and takes action to lower all risks. In this way, TOK maintains the proper work environment for all personnel.
(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 application in accor dance with the Chemical Substances Control Act*5 and the PRTR Act*6 of Japan and with all environmental laws and regu lations of importing countries. The company also enabled the issuance of SDS documents in accordance with current local laws and regulations using the SDS preparation system so that proper safety information will be shared with all users.
(6) Disposal stage
Waste from each site is thoroughly sorted by type and recycled and properly disposed of when necessary. For the contracted industrial waste disposal service providers, TOK provides information about the type of waste and handling precautions through 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 accredi tation 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 (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)
TOPICSInitiatives in Response to Global Environmental RegulationsIn 2022, PFHxS was newly added to Annex A (global ban) of the POPs Convention. The overall regulation of PFAS was also considered under the EU REACH Regulation and the United States TSCA. In this way, global regulation of persistent and highly accumulative chemical substances has proceeded in recent years. In Japan, major chemical substance management regulations have been revised one after another, such as the Industrial Safety and Health Act (addition of PFHxS and its salts as Class I Specified Chemical Substances) and the PRTR Act. TOK personnel need to properly disclose the information on the safety of chemical substances contained in all chemical products to customers and employees and to properly 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 TOK and other chemical manufacturers as well as a broad range of industries engaged in equipment, containers, and packaging materials. TOK complies with the regula tions and proactively provides information concerning safe handling through communication with industrial associations and regulatory authorities in order to minimize the impact of environmental regulations on production. Properly Comply with PCB Special Measures ActThe company has undertaken the proper storage and management of low-concentration PCBs* in accordance with the pre scribed storage standards for waste containing PCBs at three sites (TOK Technology Innovation Center (formerly the Sagami Operation Center), Sagami Operation Center, Shonan Operation Center, and Gotemba plant) while filing the necessary reports with the government in 2022. In 2023, TOK continued to dispose of electrical equipment and waste containing PCBs according to the roadmap the company created, which resulted in the completion of PCB-containing equipment disposal at the Gotemba plant. The company is also proceeding with the disposal of such equipment at other sites within the legally prescribed period (by 2027), and TOK will continue to formulate equipment renewal plans in consideration of avoiding disruptions to business activities while disposing of them in stages. Key initiatives Comprehensive inspection of labor accident risk at all TOK Group sites Basic Concept Data Section The TOK Group recognizes its social responsibility as a company that operates businesses, as well as a requirement from all stakeholders, to ensure the safety and health of workers who support supply chain sustainability. By providing a safe, comfortable workplace, TOK aims to improve employee engagement as a key strategy in the TOK Medium-Term Plan 2024 while fostering and setting in place a culture that emphasizes safety. Health and Safety System * Polychlorinated bipheny (PCB): A kind of organic compound; PCBs were formerly used for thermal media, insulating oils, coatings, and other applications because for the properties of heat resistance and electrical insulation. However, because of poor degradability and high toxicity, PCB production was discontinued in 1972. Nevertheless, little progress has been made on disposal, and the managers responsible for storage are required to place PCBs 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 529 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 Semtember 4, 2024
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.
Related Material Issue
