JP Industrial Safety and Health Act — Autonomous Management of Chemical Substances
ENFORCEMENT TIMELINE
Fully effective April 1, 2024 (phased application from 2023 to 2026)
Overview
Following amendments to the Order for Enforcement of the Industrial Safety and Health Act and related ministerial ordinances, Japan is moving away from uniform regulation under individual laws, such as the Ordinance on Prevention of Hazards Due to Specified Chemical Substances, toward a system of autonomous chemical substance management. Under this system, businesses are required to conduct their own risk assessments based on hazard information and to determine and implement exposure prevention measures. Key obligations include the mandatory appointment of a chemical substance manager and a protective equipment management officer at every business site handling substances subject to risk assessment; a substantial expansion in the number of substances subject to mandatory SDS provision, from around 900 to approximately 2,900 by 2026; the introduction of concentration standard values, such as an eight-hour time-weighted average, that must not be exceeded; and management obligations around the selection and use of protective equipment, including appointment of a protective equipment management officer.
Enforcement Timeline
July 2021: The Ministry of Health, Labour and Welfare publishes a report from its study group on the future of chemical substance management in the workplace.
May 2022: The amended government and ministerial ordinances are promulgated.
April 1, 2023: The amended act partially takes effect.
April 1, 2024: The new system of autonomous management takes full effect, including the mandatory appointment of chemical substance managers.
April 1, 2025: The expansion of the requirement for workers to use protective equipment, and the obligation to keep records of health examinations linked to risk assessments, are fully implemented.
Related Regulations / Topics
JP Industrial Safety and Health Act — Transition to Autonomous Chemical Management (2024 Reform Package)
This reform package sets out the full scope of Japan's shift away from a regulation-driven management model built on individual ordinances, such as the Ordinance on Prevention of Hazards Due to Specified Chemical Substances, toward a system of autonomous chemical substance management in which businesses assess and manage risks themselves.
JP Industrial Safety and Health Act — Expansion of Substances Subject to Mandatory Risk Assessment
Under amendments to the Industrial Safety and Health Act, the range of chemical substances subject to mandatory SDS provision, labeling, and risk assessment (Risk Assessment Target Substances) is being substantially expanded. The scope is being broadened in stages from around 700 substances to cover all substances confirmed to be hazardous under GHS classification criteria, ultimately reaching more than 2,900 substances.
JP SDS and Labeling System (Industrial Safety and Health Act / CSCL)
This system comprehensively covers the obligation to communicate hazard information for chemical substances contained in products, spanning multiple laws including the Industrial Safety and Health Act, the PRTR Act, and the Chemical Substances Control Law (CSCL). This includes the provision of safety data sheets (SDS) and the application of GHS hazard warning labels to containers and packaging. The obligation to provide an SDS applies whenever a substance determined to be hazardous, or a mixture containing such a substance above a certain concentration, is transferred or supplied to another party. The obligation to apply GHS warning labels applies whenever a covered substance is transferred, supplied, or stored within a business site in a container or package, requiring pictograms conveying the relevant hazard, including signal words and precautionary statements. The system also reflects coordination among the Industrial Safety and Health Act (worker protection), the CSCL (environmental and bioaccumulation risk), and the PRTR Act (environmental release management), each of which maintains its own list of designated substances, kept consistent with the JIS Z 7253 standard. In practice, this involves coordinating with supply chain data schemes such as chemSHERPA and managing the lead time required to reissue an SDS whenever a product's formulation changes.
Business Impact
Every factory or business site that handles chemical substances is required to submit a notification appointing a chemical substance manager and a protective equipment management officer, and to keep annual records of risk assessments conducted across the substances it handles, in preparation for external audits and guidance. Manufacturers and importers need to establish a system, such as an SDS distribution framework, that can promptly provide downstream supply chain partners with up-to-date SDS documents and labels based on accurate GHS classification.