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One of the major changes brought about by Japan’s revised Industrial Safety and Health Law is that the number of chemicals subject to mandatory labeling has increased from 107 to 640. The current labeling standard requires listing of all hazardous ingredients (Article 6.2.6, JIS Z 7253:2012). The expansion in regulatory scope only serves to worsen existing problems associated with excessive information requirements for labeling of chemical labels and the difficulty in differentiating between essential information and less important information . Therefore, the new labeling rules based on the 2014 revision of ISHL set for implementation in 2016 will not require the disclosure of all the hazardous ingredients on chemical labels.
To help industry stakeholders better understand the intention of this revision and prepare compliant labels that can deliver the hazard information of chemicals to workers effectively, Japan Chemical Industry Association (JCIA) formulated Guidance for Label Preparation Based on the Revised Industrial Safety and Health Law. The contents include:
Chapter 1 Overview of the Guidance
1.1 Introduction of the revision to ISHL (promulgated on June 25, 2014)
1.2 Regulatory requirements industries need to know when preparing workplace labels
1.3 Conclusion of the study on label requirements of different countries
Chapter 2 Guidance on the specific method of preparing rationalized labels
2.1 Labeling of the ingredients
2.2 Selection of precautionary statements
2.3 Example of preparing a specific label
2.4 Case study 1. Mixed organic solvents
2.5 Case study 2. Chemicals with lower hazards
2.6 Reference) Labeling standards of different countries
2.7 Reference) About METI's GHS classification tool for mixtures
2.8 Reference) About CLP-Classification, Labeling and Packaging of Substances and Mixtures
2.9 Reference) Necessary contents on labels and the procedures of decision making, as specified in JIS Z 7253:2012
It should be noted the contents provided in the Guidance will only take effect from June 1, 2016, the same date when the revision to ISHL in terms of labeling requirement will enter into force. At present, labels prepared according to this Guidance may violate current regulations.
In addition, the examples shown in this Guidance are for reference only and may not take other regulations into consideration. In practice, stakeholders should also comply with Fire Service Law, Poisonous and Deleterious Substances Control Law, etc.
