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In Dec 2016, Japanese Ministry of Health, Labor and Welfare (MHLW) entrusted Mitsubishi Chemical Techno-Research Corp to conduct a national survey on preparation of SDSs. The result of the survey was published at several workshops in February this year and revealed a lot of problems.
Over 1500 enterprises were investigated and 642 of them responded to the survey, including 266 manufacturers, 157 distributors and 219 downstream users. Three quarters of the respondents were SMEs. Downstream users are supposed to be able to obtain electronic or paper SDSs either from distributors or directly from the manufacturers, however, they have encountered many problems. Although all the manufacturers were able to keep electronic SDSs, some of them chose not to publish the SDSs on their company websites. Compounding this situation half of the distributors don’t have electronic SDSs for downstream users to download. The difficulties in obtaining SDSs poses serious risks in the circulation of hazardous substances.
Enterprises also expressed problems in creating SDSs. Major problems were:
It was difficult to create SDSs for mixtures due to the complexity of their hazard properties;
It was difficult to create SDSs for products with similar properties due to the huge workload;
There were difficulties in SDSs translation between Japanese and foreign languages;
Sometimes the products were too small to attach labels;
The related regulations were revised so frequently that companies felt unable to keep up with the revision to SDSs;
The redistribution of revised SDSs requires extensive resources.
Authorities addressed these problems at the workshops in February and gave some suggestions. For mixtures for which test data is not available, authorities recommended the application of bridging principles based on GHS requirements. For small products, authorities suggested that the suppliers pass the container and label to downstream users in one package. Authorities regarded the digitalization of the SDSs and labels as the primary goal. Enterprises were instructed to establish a SDS digital automatic distribution system. Once any SDS is revised, the system would forward the amended information to all related clients.
Under the current chemical management legal framework in Japan, there are 3 pieces of legislation that require SDSs for hazardous substances:
The Industrial Safety and Health Law (ISHL) requires labels and SDSs for 640 specified chemicals or products containing these chemicals with concentrations above threshold values.
The Law concerning Pollutant Release and Transfer Register (PRTR Law) requires SDSs for 462 Class 1 Designated Chemicals and 100 Class 2 Designated Chemicals and products containing these chemicals.
Poisonous and Deleterious Substance Control Act (PDSCL) requires SDSs for more than 480 poisonous and deleterious substances in the appendices to the law.
