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Japan's Ministry of Health, Labour and Welfare (MHLW) has amended the Enforcement Order of the Industrial Safety and Health Law (ISHL) on August 30, 2023 to broaden and revamp the listings of mandatory SDS and label substances under the ISHL.
Currently, the “substances that are subject to mandatory SDS and labelling requirements” are listed in Schedule 3 and Schedule 9 of the ISHL Enforcement Order. With the revision, chemical substances with any hazards officially classified by the Government before March 31, 2021 will be subject to the mandatory SDS and labeling requirements. These substances will be categorized into four categories, including:
l Category A: 33 elements and their compounds;
l Category B: Substances officially classified with GHS classifications as of March 31, 2021, excluding:
1) Substances listed in Schedule 3 (7 substances) of the ISHL Enforcement Order;
Chemical Name | CAS | |
1 | Dichlorobenzidine and its salts | 91-94-1, etc. |
2 | α-Naphthylamine and its salts | 134-32-7, etc. |
3 | Polychlorinated biphenyl (alias PCB) | ＊ |
4 | o-Tolidine and its salts | 119-93-7, etc. |
5 | Dianisidine and its salts | 119-90-4, etc. |
6 | Beryllium and its compounds | ＊ |
7 | Benzotrichloride | 98-07-7 |
2) Substances in category A; and
3) Substances that only pose a hazard to respiratory organs due to dust inhalation.
l Category C: Preparations containing substances in categories A and B, with thresholds set by the authority; and
l Category D: Preparations containing No.1~7 substances listed in Schedule 3 of the ISHL Enforcement Order.
Starting from April 1, 2025, Schedule 9 of the ISHL Enforcement Order will only contain the 33 elements and their compounds in Category A. Previously listed substances (627+234 substances) and additional substances (1,415 substances) assigned to the other categories were published via the revision of the Ordinance on Industrial Safety and Health on September 29, 2023. The additional substances will be subject to mandatory SDS and labelling requirements from April 1, 2025, of which 779 substances are granted a one-year grace period.
Furthermore, the amendment removes 7 substances from the current Schedule 9, reducing the number of “substances that are subject to mandatory SDS and labelling requirements” from 674 to 667, effective as of August 30, 2023. They are:
Chemical Name | CAS | |
1 | 3'-Isopropoxy-2-trifluoromethylbenzanilide (alias Flutolanil) | 66332-96-5 |
2 | Aluminum oxide | 1344-28-1 |
3 | Sodium dihydridobis(2-methoxyethanolato)aluminate | 22722-98-1 |
4 | Zinc stearate | 557-05-1 |
5 | 4,5,6,7-Tetrachloro-1,3-dihydrobenzo[c]furan-2-one; 4,5,6,7-Tetrachloro-(3H)-benzo[c]furan-2-one (alias Fthalide) | 27355-22-2 |
6 | Portlamd cement | 65997-15-1 |
7 | 2-Methyl-N-[3-(1-methylethoxy)phenyl]benzamide (alias Mepronil) | 55814-41-0 |
