Three Bond Technical News
Issued January 1, 2002

58

MSDS and Environmental Regulations
Introduction ________________________________________________
Chemical substances are in use in a wide variety of applications, and the number of chemical
substances used in Japanese industry is now said to have exceeded 50,000.
The author is in charge of a wide range of duties such as preparing MSDS for Three Bond products,
overseeing compliance with regulations for overseas transportation and export trading management of
hazardous products, supervising handling of hazardous and toxic materials, waste treatment, safety
and sanitation in the workplace, and verifying compliance with the ISO 14001 standard in Three Bond.
In recent years, efforts have been made in Japan to promote the self-management of chemical
substances by the companies that handle them, including the enactment of the Law Concerning
Reporting etc. and the regulations for Releases to the Environment of Specific Chemical Substancesand Promoting Improvements in Their Management (the Chemical Substance Management Law, forshort, or the PRTR Law) that was previously unheard in Japan, as well as major revisions to theguidelines for MSDS documentation. Summaries of these efforts are picked up in this issue as for thereferences to the efforts for chemical substance management in the workplace.
The number of chemical substances available on the market continues to increase, and regulations
are also constantly changed in order to accommodate this growth. The present state of theseregulations will be described here. The contents of this issue relate primarily to our main products(sealants, adhesives, rust-inhibiting lubricants) and the main materials for our products (epoxy, acrylic,and silicone), and will address the practical problems and questions actually reported when ourcustomers handle these chemical substances.
Taking this opportunity, I would like to inform to our customers that Three Bond has acquired ISO
14001 certification and is working aggressively to find alternative substances that decreases impact tothe environment.

Contents
Introduction................................................................. 1
1. The MSDS ............................................................. 2
1-1. History of MSDS ........................................... 2
1-2. Major modifications in the revised guidelines ...... 2
1-3. The three major laws related to the MSDS .... 3
2. The PRTR Law ...................................................... 3
2-1. The aim of the PRTR Law ............................ 3
2-2. Classifications and pertinent standards ofchemical substances targeted by the PRTR Law .... 3

2-3. Reporting of emissions volume, etc. as specified by the
PRTR Law and actions by the government ................4
2-4. Volumes of release and transfer ...................4
2-5. Flow Chart for Determining Reporting Criteria .....5
2-6. Calculation method .......................................5
2-7. Examples ......................................................5
3. Industrial Safety and Health Law ...........................8
4. Poisonous and Deleterious Substances Control Law ....8
5. Events of the past year ..........................................9
6. Conclusion ...........................................................10

1

1.

The MSDS

1-1. History of MSDS
As most of you already know, MSDS stands forMaterial Safety Data Sheet. Some countries havepassed MSDS legislation more than five years ago.
Following is the history that MSDS was legislated
in Japan.
Table 1: History of MSDS legislation
Establishment of the "Guidelines for MSDS
August 1992 Documentation" (launch of MSDS as an administrative
directive)
Feb. 2000
Establishment of JIS Z 7250
Apr. 2000
Legislation under the Industrial Safety and Health Law
Legislation under the Law of Pollutant Release andApr. 2001
Transfer Register (PRTR Law) and the Poisonous andDeleterious Substances Control Law
Publication of the revised edition of the documentation
Oct. 2001
guidelines

Under the auspices of three ministries, theMinistry of Health and Welfare, the Ministry ofInternational Trade and Industry, and the Ministryof Labour, the Japan Chemical Industry Association(JCIA) formulated the "Guidelines for MSDS
Documentation," which characterized MSDS
documentation as an administrative directive, not as
legislation.
Later, with the constitution of JIS Z 7250 (2000
edition: MSDS for chemical products - Part 1:
Content and order of sections), MSDS
documentation became law under the Industrial
Safety and Health Law, the Law of Pollutant
Release and Transfer Register (PRTR Law), and the
Poisonous and Deleterious Substances Control Law.
The current revision was also made under thethree ministries mentioned above, and businesses in
the chemical industry are expected to follow theserevised guidelines in their MSDS preparations.
The following government offices of the three
ministries were involved.
Chemical Substance Safety Office of the
Evaluation and Licensing Division of thePharmaceutical and Food Safety Bureau of the
Ministry of Health, Labour and Welfare
Chemical Risk Assessment Office of theIndustrial Safety and Health Dept. of theLabour Standards Bureau of the Ministry of
Health, Labour and Welfare
Chemical Management Policy Division of
the Manufacturing Industries Bureau of the
Ministry of Economy, Trade and Industry
Environmental Health and Safety Division of theEnvironmental Health Department of the Ministryof the Environment

2

1-2.

Major modifications in the revised
guidelines
The revised guidelines have articulated thatMSDS shall be prepared in accordance with the
PRTR Law, the Industrial Safety and Health Law,
the Poisonous and Deleterious Substances Control
Law, and JIS Z 7250, as well as with the 1992
guidelines concerning information disclosure. The
previous format will remain valid to the end of Dec.
2004.
For details, refer to the "Oct. 2001 Guidelines for
MSDS Documentation (revised edition)" issued by
the Japanese Standards Association. Here, several
major revised points will be described.
(1) In JIS Z 7250, the items were classified into thefollowing categories.
Requisite items to be filled in
Items to be filled in if information is available
Items to be filled in if relevant(2) Methods for describing items concerning
confidential business information have been
defined and clarified.
(3) New items, such as the most significant hazard
and summary of potential emergency situations,have been added.
More minor modifications include the following:• Change to the item (section) under which the UN(United Nations) number is given• Horizontal lines (ruled lines) formerly placed
between items are now omitted to facilitate
conversion into electronic data files.
• Only the 16 major item headings will benumbered, and numberings for minor items will
not be permitted.
• The "product name," "company name,""registration no.," "date," and "page/total page"
shall be entered on each page.
* Though not a modification, the minor item
"classification name" is still included, and the relevant
requirements and classification name are written as"classification according to Japanese criteria."
This is because the MSD must comply with thenotification by the Ministry of Labour entitled"Guidelines Concerning the Labeling of Hazardous
Identification, etc. of Chemical Substances (July 1,1992)," and notification by the Ministry of Healthand Welfare and the Ministry of International Tradeand Industry entitled "Guidelines Concerning the
Safety of Chemical Substances (March 26, 1993),"
which remain currently in effect.

1-3. The three major laws related to the MSDS
As shown in the diagram below, a total of over
1,000 chemical substances are targeted by threelaws, which are the PRTR Law, the Industrial
Safety and Health Law, and the Poisonous andDeleterious Substances Control Law. The total mayvary depending on how substances are counted,
since, for example, an entire group of metalcompounds is counted as a single substance andisomers are not treated separately under the
Industrial Safety and Health Law.
Total 653

Total 446
143
PRTR Law
203

Industrial Safety
and Health Law
392

59
41

59

Poisonous and Deleterious
Substances Control Law
189
Total 348

Figure 1: Designated chemical substances for the MSDS 1)
The substances designated in these laws can beeasily searched in the "List of Designated Chemical
Substances for MSDS Reporting in Japan for the
Industrial Safety and Health Law, the PRTR Law,
and the Poisonous and Deleterious Substances
Control Law" compiled by the Japan Chemical
Industry Ecology-Toxicology & Information Center(JETOC). The list is also available in Excel format
to facilitate search using the CAS No. (registration
number within the Chemical Abstracts Service, inwhich a single number corresponds to a single
substance). The list can be found at
http://www.jetoc.or.jp.

2.

The PRTR Law

The PRTR Law (Law of Pollutant Release andTransfer Register) is officially designated as the"Law Concerning Reporting, etc. of Releases to theEnvironment of Specific Chemical Substances andPromoting Improvements in Their Management,"
and is referred to as the "Chemical SubstanceManagement Law" for short.
Unlike past environmental pollution accidents
with only localized effects, environmental pollution
currently occurs on a global scale, as seen in thecurrent damage to the ozone layers, and actions
taken after the discovery of current effects are often
too late. Thus, legislative actions are now being
implemented as preventive measures. Though the
PRTR Law represents a recent development inJapan, the concept was introduced more than five
years ago in the U.S. as the Toxic Release Inventory(TRI) program, and has since then been

implemented in the Netherlands, Canada, Britain,
and Australia.
Until now, efforts had focused on preventing
pollution by regulating emission standards by law
and requiring businesses to comply. The goal has
now moved a step higher, to the promotion ofmanagement of chemical substances by businesses
themselves. This is intended to heighten theenvironmental awareness of these businesses, and inturn to lead to voluntary measures to control thechemical substances they use (while of course also
remaining in compliance with applicable laws).
With this background established, let us move on
to a discussion of the actual PRTR Law.
2-1. The aim of the PRTR Law
The aim of this law is to promote voluntary
efforts, by these businesses that handle chemical
substances, to improve their methods of chemical
management, ultimately preventing damaging
environmental occurrences, by grasping quantity ofvarious poisonous chemicals released into theenvironment.
2-2. Classifications and pertinent standards ofchemical substances targeted by the PRTR Law
Chemical substances that are potentiallyhazardous to human health and the ecosystem arelisted as Class I Designated Chemical Substances(354 substances) and Class II Designated Chemical
Substances (81 substances). Hereafter, these will bereferred to as Class I and Class II substances. In
some cases, the difference between Class I andClass II substances has been misunderstood as adifference in the degree of harmfulness. In fact, it isgrouped by whether the substance exists in theenvironment or not, and by the difference inestimated exposure, if exists.
Businesses that supply products containing aClass I substance in proportions of 1% or greater(0.1% or greater for Specified Class I substanceswith known carcinogenic properties) must submit
an MSDS showing the concentration (with two
significant digits). Furthermore, as explained in the"Flow Chart for Determining Reporting Criteria,"
companies that operate any of the designatedbusinesses, have 21 or more regular employees, use
any of the designated products, and have annual
handling quantity of one ton or more (five tons ormore for the initial two years, 0.5 tons or more forSpecified Class I substances) is required to reporton the volume of release and transfer.
Companies that supply products containing aClass II substance in proportions of 1% or greater
must also submit an MSDS showing theconcentration (with two significant digits). For
Class II substances, the companies are not obliged
to report on the volume of release or transfer.

3

How PRTR Proceeds
Target chemical substances

Target businesses

Hazardous substances recognized to exist
continuously in the environment over aconsiderably wide area (specified by
Cabinet Order)

Manufacturers, etc. of target chemical
substance (businesses and scalespecified by Cabinet Order)
National
government: formulation andpublication of guidelines(guidelines to promote self-management ofbusinesses)

Estimation andreporting of volume of releaseand transfer into environment by thebusiness

Confidential business information to be submitted
directly to the national government

Target businesses:
submission of the Material Safety
Data Sheet (MSDS)(reporting via)
Prefectural government

National government: conversionof reported data into electronic files* To be submitted to the minister of thepresiding ministry. The ministers of
the Ministry of Economy, Trade andIndustry and the Ministry of theEnvironment will be in charge of
conversion into electronic data andcompilation.

National
government: estimation andcompilation of emission from homes,
farmland, and automobiles

Sent to the prefectural government

National government:
compilation and publication of reported
and estimated data

Prefectural government:
compilation and publication according
to regional demands
National government: disclosureof data on individual businesses uponrequestFigure 2: Outline of the PRTR Law 2)
2-3.

Reporting of emissions volume, etc. as
specified by the PRTR Law and actions
by the government(1) Reporting obligation
The relevant business must calculate the volumeof release and transfer as waste products into theenvironment of the designated chemical
substance for individual facilities and report thedata to the national government via theprefectural government.
(2) Actions by the government
The national government will compile the dataaccording to substance, category of business,and region. The government shall disclose theinformation submitted by individual businesses
upon request.
The details on methods of submission are
omitted here due to limitations of space.

42-4. Volumes of release and transfer
Since there may be some confusion regarding therelease and transfer of chemical substances, a briefsummary will be given here.
Release refers to the following four processes:a) Release into the atmosphereb) Discharge into public watersc) Release into soild) Bury in landfill
Transfer refers to the following two processes:a) transfer of wastewater into sewageb) removal as waste products from premises* Chemical substances that are discharged into
sewage and released into the rivers via
wastewater treatment facilities are to be includedin the transferred volume, and those that are
discharged directly into the rivers without
treatment should be included in the released
volume.

No

Yes
Do you produce 1.0 tons*1) or more of
the designated chemical substance(including by-products)?

No

Yes

Do any of the raw materials andresources handled by the facility
meet the product requirements
specified by Cabinet Order?

No

Yes

Do any of the raw materials andresources contain the designatedchemical substance in proportionsof 1%*2) by mass or greater?

No

Yes
Are the annual quantities of thedesignated substance handled by thefacility (total quantity of substanceproduced, used, or handled by othermeans) 1.0 tons or more*3)?

No

Yes

Yes

No

You are not required to report the quantities ofdesignated substances released or transferred.

Yes

Does your entire business employ
21 or more regular employees?

Do any of the facilities meet the
special requirements stated in
conditions c) through f) of thehandled quantities?

Items to be determined
for the entire business
Items to be determined for individual facilities

No

Do you operate any ofthe designated businesses?

*1) Class I Designated Chemical
Substances specified by Cabinet
Order...0.5 tons
*2) Class I Designated Chemical
Substances specified by Cabinet
Order ... 0.1% by mass
*3) Five tons for the initial two years.
However, for Class I DesignatedChemical Substances specified by
Cabinet Order, 0.5 tons from thestart.

You are required to calculate and report the quantities ofdesignated substances released or transferred.

Figure 3: Flow Chart for Determining Reporting Criteria2)
2-5.

Flow Chart for Determining Reporting
Criteria
Potentially confusing elements of the flow chart
will be explained here.
If the total number of regular employees for theentire company is 21 or more, the business falls
under the category of a designated business.
Part-time employees are counted as regular
employees if their period of employment exceeds
two months.
The "product requirements specified by Cabinet
Order" in the flow chart refers to those products that
contain Class I substances in proportions of 1% or
greater (0.1% or greater in the case of Specified
Class I substances), and to which none of thefollowing conditions apply. The conditions are
summarized briefly here; refer to the text of the
Cabinet Order for details.
a) A product that keeps a form of solid during
handling and does not take a form of powder or
granular (example: metal sheets, tubes, etc.)b) A products in which the Class I substanceremains sealed during handling (dry-cellbatteries, etc.)c) Products supplied mainly for use in consumer
life (household cleaners, insecticides)d) Recyclable resources (metal scraps, waste cans,
etc.)* Some of these conditions may not apply to certain
products even if these products are solid.

Eyeglass lenses represent one such product, since
powdered material is produced when these are
grinded in order to insert into the frame.
2-6. Calculation method
There are four basic calculation methods.
(1) Mass balance calculation(2) Calculation based on actual measurements(3) Calculation using emission factors(4) Calculation using values of physical properties
In addition to these methods, you may also use
empirical values which are thought to result more
precise results.
2-7. Examples
Table 2 gives examples of substances contained incommonly available adhesives, though they may
not necessarily be contained in our products.
(1) Epoxy adhesives
Some epoxy adhesive compounds contain
Bisphenol-A-type epoxy resins (only in liquid form).
Not all of the Bisphenol-A-type epoxy resins aredesignated in the PRTR Law-only those in liquid
form with small molecular weights. Solid types
with large molecular weights are excluded from the
PRTR. Thus, even when a liquid product contains
large-molecular weight resins dissolved in
low-viscosity dilutants or solvents, it is not appliedby the PRTR Law.

5

Table 2: Actual examples
Types ofadhesives andingredients

Substances designated in PRTR
Chemical name,generic nameCabinetOrder No.

CAS No.

Bisphenol-A-type epoxy resin(liquid)I - 3025068-38-6

3-(3,4-dichlorophenyl)-1,1-dim
ethylurea (DCMU)

I - 129330-54-1

Precoat adhesives Bisphenol-A-type epoxy resin(epoxy type)(liquid)I - 3025068-38-6

Acrylic adhesives

Acrylic acidI-3

79-10-7

Methacrylic acidI - 31479-41-4

Epoxy adhesives

Silicone adhesives Silicone, the main constituent,is not a designated chemical
substance.
(However, some products use
toluene, etc. to dissolve thecatalytic agent, and thus are
categorized as designatedproducts.)−−

Conductive
adhesives

Silver powder

I - 647440-22-4

Nickel powder

I - 2317440-02-0

Solvent based
adhesives andcleaning solvents

TolueneI - 227

108-88-3

XylenesI - 631330-20-7

DichloromethaneI - 145

75-09-2

Trichloroethylene

I - 21179-01-6

Tetrachloroethylene

I - 200

127-18-4

Seizure-preventive Molybdenum disulfide
lubricant(molybdenum compounds)I - 3461317-33-5

Nonyl phenol

I - 24225154-52-3

Poly(oxyethylene) alkyl ether(alkyl C=12-15)

I - 307−

Poly(oxyethylene) octylphenylether

I - 3089036-19-5

Poly(oxyethylene)
nonylphenyl ether

I - 3099016-45-9

Inorganic filler

Asbestos

I - 261332-21-4

Colorants

Cadmium compounds

I - 60−

Hexavalent chromium
compoundsI - 69−bis (2-Etheylexyl) Phthalate(DEHP, DOP)

I - 272

117-81-7Di-n-Butyl Phthalate (DBP)

I - 270

84-74-2Anti-freeze

Ethylene glycol

I - 43

107-21-1

Rubber solvent

Benzene (impurity)

I - 299

71-43-2

Industrial-use
cleaners

Plasticizers* In the column for Cabinet Order No., "I" indicates that thesubstance is a Class I Designated Chemical Substance, and thenumber represents the Cabinet Order number.

Of the Three Bond products, the following
product is not included among the targeted
products.
ThreeBond 2001, which is the primary agent of
two-part epoxy-compound resin adhesives, is aliquid. However, the Bisphenol-A-type epoxy resin
contained in the compound is not in liquid form,and does not fall under the category of designatedsubstances in the PRTR Law. Thus, ThreeBond
2001 is not subject to the PRTR Law.
(2) Precoat adhesives (epoxy type)Three Bond's encapsulates adhesives into
microcapsules and processes bolts with coating theadhesives. Microcapsules are broken and theadhesives are released to react and cure, when thebolt is tightened. This receives a favorable
evaluation on the advantages as it prevents

6

dispersion in coating volumes in the assembly fields,
and also keeps the workplace in clean.
For some of the products, the microcapsules
contain compounds of Bisphenol-A-type epoxy
resin. Bolts coated using such microcapsules do notcorrespond to solids as defined and excluded by the
PRTR Law, and these bolts are thus subject inprinciple to the PRTR Law. However, the results ofcalculation of concentrations of the resin in thebolts exclude these products from the PRTR Law.
The concentration is calculated by dividing themass of the Bisphenol-A-type epoxy resin by the
total mass of the coated bolt; in this case the resultis less than 1% (less than 0.1% in most cases); no
reporting obligations thus arise.
(3) Acrylic adhesives
Acrylic acid and methacrylic acid are sometimes
added to anaerobic sealants and ultraviolet-curing
adhesives, which are types of acrylic adhesives. The
two substances are significantly toxic, as shown by
the fact that products containing acrylic acid or
methacrylic acid in concentrations exceeding 10%
and 25%, respectively, are treated as deleterious
substances under the Poisonous and Deleterious
Substances Control Law. There are products on themarket having high concentrations of acrylic acidand methacrylic acid, but Three Bond is currently
directing its laboratory staff to refrain from
including the two substances in mixtures of
products currently being developed.
(4) Silicone adhesives
The main constituent, silicone, is not a designatedsubstance in the PRTR Law. However, toluene andother solvents added to dissolve the catalytic agent
may fall under the category of designatedsubstances, and the product may become subject to
the PRTR Law depending on concentration.
(5) Cleaners
Nonylphenol is a designated substance under the
PRTR Law. However, note that although a productmay not contain nonylphenol itself, it may contain asubstance that will decompose immediately after
release into the environment to produce
nonylphenol.
(6) Colorants
Some pigments contain cadmium, such as
cadmium yellow and cadmium red. Cadmium is aSpecified Class I substance, and products that
contain cadmium in proportions of 0.1% or greater
are subject to the PRTR Law.

Products that will be regarded as designated substances when calculating annually handled quantity
When calculating annually handled quantity, the total volume is determined for the (Specified) Class I
Designated Chemical Substance contained in the products (handled raw materials and resources), with a circle
placed to the right of the product names, handled at the business facility.
Waste products

Sludge, construction
scrap materials, etc.

Natural products

Mineral ores (onlyunprocessed ores)

Manufactured
products

Substances
containing
designatedsubstances inproportions of
1% by mass orgreater (0.1% or
greater for
carcinogenic
substances)

A substance that neither takes a non-solid form during handling at
the business facility (in other words, solid substances that are notconverted into any non-solid form by dissolution, etc. during thebusiness's handling processes, including post-shipping processes),
nor takes a powder or granular form (i.e., the product retains a
fixed shape)

Other

Tanks, assembly
parts, tubes,
boards, films,
cloths, threads,
paper, etc.

Products in which Class I DesignatedChemical Substances are handled
under sealed conditions
Other

Batteries,
condensers, etc.

Products that will be sold mainly
to general consumers (i.e.,
packaged in containers andlabeled for consumer use)
Other

Insecticides, insect
repellants, cleaners,
etc.

Recycled resources

Waste cans, metal
scrap, waste oils, etc.

Other (designatedproducts)

Chemical agents,
pigments, gasoline, highpressure gas, paint,
adhesives, solvents,
ingots, crude oil, coal,asbestos boards, etc.

Figure 4: Forms of products (handled raw materials and resources) regarded as designated substances2)(7) Inorganic fillers
Some epoxy resin adhesives contain asbestos(chrysotile). Additives mixed to prevent sagging ofadhesives are referred to as "thixotropic agents."
Asbestos was commonly used in the past due to its
superior properties as a thixotropic agent and to its
low cost.
Three Bond acquired ISO 14001 certification in
Jan. 2001 and is now aggressively promoting the
reduction of environmentally hazardous materials in
our products. The development of asbestos-free
products is an important part of this endeavor.
Taking this opportunity, Three Bond would ask ourcustomers to consider using available asbestos-freealternatives.
Zinc oxides are included among other inorganic
fillers added to adhesives, but these compounds are
not designated substances under the PRTR Law.
This is because zinc compounds included in the listof designated substances of the PRTR Law are
restricted to water-soluble compounds, and zincoxides are insoluble in water.
Benzene is another common additive, and is aSpecified Class I Designated Chemical Substance.
It is contained in gasoline in proportions of 0.1% or
greater, and may also be used in rubber solvents, etc.
as dilution solvents.
Hexavalent chromium is also categorized as aSpecified Class I Designated Chemical Substance.
Care must be taken when handling some types ofpaint or the like as these substances may containhexavalent chromium as a rust inhibiting pigment.
In particular, the reporting criteria for Specified
Class
I
DesignatedChemicalSubstance
concentration is 0.1%, an extremely low value, so
special care must be taken when handling products
containing Specified Class I substances.
"Solubility" is defined as the "ability to dissolve
in water of neutral pH at a proportion of 1% bymass or greater at ambient temperature."
Although it may be somewhat unrelated to the
topic of this section, it is worth mentioning
Bisphenol-A. In animal testing, it has been shownthat Bisphenol-A weakly imitates a certain female
hormone. However, the actual extent of its effect on
the ecosystem is still under discussion.
I have noticed that some people confuse theBisphenol-A-type epoxy resin contained in our
epoxy adhesive products with Bisphenol-A. It
should be stressed that Bisphenol-A is not an
intentional residue in Bisphenol-A-type epoxy resin
adhesives, and the residue amounts are significantly
trace (1 ppm or less in the Bisphenol-A-type epoxy
resin handled by our company).

7

3.

Industrial Safety and Health Law

The following two points in the MSDS
regulations are based on the Industrial Safety and
Health Law.
(1) Obligations of the seller or supplier of products
containing "substances subjected to notification"
to disclose information through MSDS, etc., andre-notification obligations after any
modifications(2) Obligations of businesses handling suchproducts to disseminate information on MSDS
to workers
Chemical substances subject to MSDS
regulations include the seven chemical substances
requiring manufacturing permits according to theIndustrial Safety and Health Law, as well as the 631
substances specified by Cabinet Order and theirassociated compounds. These 631 substances havebeen specified based on the recommendations onallowable limits given by the Japan Society for
Occupational Health and on the TLV (Threshold
Limit Value) data presented by the American
Conference of Governmental Industrial Hygienists(ACGIH).
Examples of products that will be exempt from
the MSDS regulations include the following.
• Products containing substances subject tonotification in concentrations less than 1%• Products supplied mainly to general consumers, such as:a) Pharmaceutical, quasi-drug, and cosmetic products
specified in the Pharmaceutical Affairs Lawb) Agrochemicals specified in the Agricultural
Chemicals Regulation Lawc) Products that remain in solid form at all times
during the handling of the product by the worker
and that take neither powder nor granular form.
d) Products in which the substance subject tonotification remains sealed• Waste products
Information should generally be provided in
paper or magnetic disc (floppy disk) form. However,if the receiving party approves, it may be provided
through fax, electronic mail, or publication on theInternet.
The term "water soluble" in the present Law
refers to the state in which less than 100 millilitersof water is required to dissolve 1 gram of thesubstance in question.
The term "urethane," substance #61 in the list of
substances subject to notification, refers to"carbamic acid ethyl," and so the "urethane" of oururethane adhesives does not fall under this category.
When substances subject to notification for whichisomers exist are listed simply as "propyl alcohol"and "hexane," then both the normal and branchingisomers should be regarded as specified substances.
In contrast to the PRTR Law, in which thequantities of metal compounds are converted intoquantities of elementary metal, the quantity of metalcompounds of substances subject to notification
under the Industrial Safety and Health Law are8

expressed as the total quantity of the compound.
Thus, this results in the inconvenient requirement toinclude both quantities (total and converted values)in the MSDS.
How high a concentration of a substance triggers
the MSDS documentation obligation? The criteria
in the PRTR Law were 1% for Class I substancesand 0.1% for Specified Class I substances. Under
the Industrial Safety and Health Law, the obligation
for notification arises when the substance iscontained in concentrations of 1% or greater.
Furthermore, according to the Industrial Safety
and Health Law, the concentration of the substanceshould be represented with accuracy of ± 5%, andnot in terms of two significant digits as in the PRTR
Law.

4.

Poisonous and Deleterious Substances Control Law

MSDS regulations were also made compulsory in
the Poisonous and Deleterious Substances Control
Law. The classifications of poisonous anddeleterious substances are as follows.
Poisonous substances: toxic substances
Deleterious substances: harmful substances
Specified poisons:
substances that are extremely toxic
There are 3 regulatory modes for deleterious
substances.
(1) Regulated by substance name only
Substances consisting of single substances suchas toluene, xylene, and methanol(2) Regulated by both substance name and concentration
Substances not subject to law unless containedin concentrations exceeding a threshold value(3) Regulation of all preparations containing the substance
Regardless of the concentration, all products
containing the substance as an intentional additive
are subject to law.
Three Bond markets a curing accelerant withmethanol concentration of 90% or greater, but it is
not categorized as a deleterious substance since it is
not a single-substance product. Would a cleaner
consisting of 50% toluene and 50% xylene (no suchproduct is in fact marketed by Three Bond), bothdeleterious substances, be categorized as adeleterious substance? No, it would not. Although it
seems illogical that a mixture of two deleterious
substances is not considered deleterious, this is how
such a product will be treated according to the law.
However, the above case only applies to substances
regulated by name only (Mode (1) above).
The adhesive power of some acrylic adhesives isenhanced by the addition of acrylic acid or
methacrylic acid. In such cases, concentrations ofacryl acid exceeding 10% or methacrylic acidexceeding 25% will be subject to this law.
Adhesives containing these additives in lower
concentrations are regarded as ordinary products.
Three Bond markets products containing these
additives, but all have concentrations of less thanseveral percent, and thus do not fall under the
category of deleterious substances.

Although "cyanide compounds" are listed as
deleterious substances, instant adhesives are notsubject to this law since they are included among"cyanoacrylic acid esters and preparations
containing them," which are exempt from this law.
Dicyandiamide, which is sometimes used as acuring agent for one-part epoxy resin, is also
included among "dicyandiamide and preparations
containing it," and is therefore also exempt fromthis law.
According to the MSDS regulations based on the
Poisonous and Deleterious Substances Control Law,
products that are mixtures of deleterious substancessuch as toluene, xylene, and methanol are notregarded as deleterious products. As stated above,
this is because only pure (single-substance)
products are considered deleterious; mixtures are
exempt.
However, the above case is true only under the
Poisonous and Deleterious Substances Control Law.
Under the PRTR Law and the Industrial Safety and
Health Law, all products containing toluene or
xylene in concentrations of 1% or greater are
subject to MSDS regulations. Methanol iscategorized as a designated substance under the
Industrial Safety and Health Law, and so
submission of the MSDS becomes compulsory.

5.

Events of the past year

The most important topic for the author in termsof chemical management is the implementation of
the PRTR Law; in terms of preparation of theMSDS, the most important concern is probably theissuance of the revised guidelines for MSDS
documentation.
However, a number of additional importantdevelopments merit discussion here.
Modifications to the Fire Service Law
The following changes were made to the Fire
Service Law, with these changes to become
effective on June 1, 2002.
{ Setting of upper limit to the ignition point for Category-4
petrochemicals of Class-4 hazardous materials
Category-4 petrochemicals of the Class-4
hazardous materials under the Fire Service Law are
defined as liquids having ignition points of 200°C
or above. Previously, no upper limit had been set for
the ignition point, but now the ignition point range
is defined as 200°C or above and below 250°C.
Under the Fire Service Law, liquids having ignition
points of 250°C or above are not classified ashazardous materials, but as flammable liquids of thedesignated flammable substances.
Three Bond has several Category-4 petrochemical
products with ignition points of 250°C or above.
Thus, these products will now be classified as
flammable liquids of designated flammable
substances. However, since the change will not beeffective until June of this year (2002), changes tolabels and the like cannot be made before then, as
this would be in violation of the law. Until the dateof enforcement, these products will be labeledunder the present classification (Category-4
petrochemicals) with an appended note indicatingthat they are to be classified as flammable liquids ofdesignated flammable substances after June 1,
2002.
{ Change to the lower limit of the ignition points
for high ignition point hazardous materials
The lower limit of high ignition point hazardous
materials has been changed from 130°C to 1,000°C.
{ Hydroxylamine has been designated as a Class-5
hazardous material
Hydroxylamine and their salts, which became
focus of interest after an explosion and fire at ahydroxylamine-manufacturing factory in 2000, havenow been designated as Class-5 hazardous materials.
These substances are not used in any of our
products. Instructions on handling hydroxylamine
have also been appended to the Ordinance on Labor
Safety and Hygiene as of Nov. 16, 2001.
Laws relating to waste product treatment
and cleaning{ Confirmation of final disposal site
In many cases, industrial waste products areincinerated. When the incineration is commissioned
to outside businesses, the business that hasdischarged the waste product is obligated to confirm
not only the appropriateness of the incineration
facility (intermediate processing facility) but mustalso take steps to assure the proper disposal of ash
residues at the landfill (final disposal site). It is best
to confirm the final disposal site with one's owneyes, and so at Three Bond, the author has traveled
to Hokkaido to confirm the conditions of thecontrolled landfill site where ash residues are buried.
Although it is most important to confirm that thedisposal process is being conducted properly, it isalso important to keep records so that the act ofconfirmation may be verified during inspection byauthorities and during ISO 14001 investigation.
Indeed, when Three Bond was applying for ISO
14001 certification, inspectors asked questions
regarding the matter during the investigation. The
same questions were asked during an audit with aclient company. When visiting the final disposal site,
photographs should be taken to include the person
confirming the site, and these should be kept asrecords along with the pamphlets of the relevant
disposal site and business cards of those people met
at the site.
{ Changes to the manifest form
The industrial waste management (manifest) form
is now a size larger than before, and includes Form
E, corresponding to certification of the final
disposal site. Verification of that the disposal ofindustrial waste has been properly carried out can
only be made with a complete set of Forms A, B2,
D, and E after final disposal and following
confirmation of that the contents of the forms arefree of error.

96.

Conclusion

This issue has been written as a response to questions asked by our customers and salespersons and researchersin our company regarding the management of chemical substances. In some areas I may have gone into moredetail than necessary, while in others I must apologize for any insufficiency in the discussion due to limitations ofspace. I would ask readers to refer to websites maintained by the relevant agencies and to available specialized
literature to make up for these shortcomings.
Three Bond acquired ISO 14001 certification in Jan. 2001, and we believe that our social responsibilities havesince increased to a greater extent than ever before.
It seems that some companies take the stance that disclosure of component information of substances, whichhave not yet caused any problems in Japan, is not necessary. Our company, however, is aggressively expanding
business overseas and believes that hazard related information should be provided as thoroughly in Japan as inforeign countries. Even before the establishment of laws to regulate substances with strong toxicity, Three Bond
actively disclosed information designed to promote the use of protective gear among our customers in the courseof handling hazardous substances. Naturally we are also making vigorous efforts to develop safer alternative
products. Three Bond is also considering plans to revise the MSDS for our products according to the new
guidelines and to publicize these revisions on our website so that this information will be available to ourcustomers at all times.
It may be said that some people regard chemicals as synonymous with pollution and environmental destruction,
but without chemicals our society could not function as it does today. We offer our products with commitment and
pride and plan to do all that we can, in order to promote proper handling.
Masao Kitamura
Certified Measurer (concentration; noise and vibration)
Environmental Counselor (Business Department)
Research Management Division
Research Laboratory
Three Bond Co., Ltd.

1456 Hazama-cho, Hachioji-shi, Tokyo 193-8533, Japan
Tel: 81-426-61-1333

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