[ JAMP Format ] 5. Procedures for Preparing MSDSplus

Transcription

1 [ JAMP Format ] 5. Procedures for Preparing MSDSplus 1

2 JAMP's methods to communicate information on chemical substances contained in products Information to be communicated To be communicated to Informati on level Standards MSDS (SDS) - Type/degree of hazard - Measures to prevent incidents - Mandatory composition on legal labeling - Voluntary composition on labeling - Persons involved in handling chemical substances - Level understandable and usable for the safety manager in downstream companies - Legislation/public standards in the distributed country MSDSplus - Information corresponding to legislation in major countries - Types/concentration of declarable composition - Managers of declarable chemical substances in downstream companies - Level understandable for relevant persons throughout the supply chain - Legislation/public standards in the countries for export agreed upon in the supply chain MSDSplus distributes legislation-related information not included in the distributed country's MSDS but necessary for global business. I will explain about MSDSplus. Issuance of MSDS is legislated in various countries to enable communication of information necessary to safely handle chemical substances. On the other hand, MSDSplus provided by JAMP is a format to communicate information on relevant legislation and the types and concentration of chemical substances that are covered in the legislation. By preparing MSDSplus and sending it to the supply chain, it distributes legislationrelated information not included in the country's MSDS but necessary for global business. 2

3 Overall Flow of MSDSplus Formulation (Example) for Panasonic Step 1. Confirm the chemical substance content information identified at your company Step 2. As necessary, collect information on chemical substance content of the raw material from the upstream supplier, and re-calculate the preparation composition (Cases where mixing and reaction exist in the own process) MSDS or SDS Raw material A + Raw material B Preparations C Step 3. Enter necessary items and substance information into the MSDSplus Input Support Tool Step 4. Export the XML using the MSDSplus Input Support Tool. Step 5. Submit the data to the Panasonic Group (Upload the XML to the GP-Web). The specific process of MSDSplus formulation is as follows. The overall process comprises Steps 1 through 5. First, check the chemical substance content information identified at your company. In step 2, collect the content information of chemical substances of raw materials from the upstream supplier, and re-calculate the composition of the preparation. This step is necessary when there is mixing or chemical reaction in your process. As the third step, enter necessary data and substance information to the MSDSplus Input Support Tool. Then, export an XML file using the MSDSplus Input Support Tool. Finally, upload the XML to the GP-Web as a submission to the Panasonic Group. 3

4 Step 1 Step 1. Confirm the chemical substance content information identified at your company Brominated flame Originally prepared: March 1, 2012 retardants - Specified brominated flame MSDS: Material Safety Data Sheet) [1. Chemical substance and company information] Product ABC ABS FRABS001 Manufacturer ABC Co., Ltd. Address YYY, XX City, Osaka Department in charge Telephone Number Facsimile Number retardants (PBB,PBDE, HBCDD etc.) Subject to legislation - Other brominated flame retardants Subject to management [2. Constituent, component information] Single product/mixture : Mixture Chemicals : Mixture consisting of acrylonitrile butadiene styrene polymer, brominated flame retardant and antinomy trioxide, and in some cases coloring agents Example of Flame-retardant resin by ABC Co., Ltd. Constituent specified in MSDS Constituent ABS resin Brominated flame retardant Antimony trioxide (Coloring agent) CAS No Unknown Unknown Content 65% 25% 3.0% 0-10% Constituent and content : (A) ABS resin 65% or more (B) Brominated flame retardant 25% or less (C) Antimony trioxide 3.0% (2.5% or less in metal antinomy conversion) (D) (coloring agent : titanium oxide, etc.) 0-10% Other constituents identified for content Acrylonitrile 1,3-butadiene % 0.001% Chemical formula : (A) [-(CH 2-CHCN) k-(ch 2CH=CHCH 2) l-(ch 2-CHC 6H 5) m-] n (B) Omitted (C) Sb 2O 3 (D) (Titanium oxide : TiO 2) Reference Number in : (Chemical Substances Control Law, Industrial Safety and Health Act) Gazetted List in Japan (A) (B) Already registered (C) (D) Already registered CAS No. : (A) (B) Already registered (C) (D) Already registered Although these are JAMP declarable substances, these are considered as residue from ABS polymerization, and fall under unintentional addition. Reporting is not necessary if the value is within the threshold (0.1 wt% is no threshold). I will use flame retardants as an example for specific explanation. We can see that this flame retardant contains ABS resin, brominated flame retardant, antimony trioxide, and titanium oxide as coloring agent. Also, assume that content of acrylonitrile and 1,3-butadiene have been indentified at your company, which were not described in the MSDS. From this information, prepare an MSDSplus. First of all, since the main constituent ABS resin and coloring agent titanium oxide are not subject to reporting, they do not need to be declared. The CAS number for antimony trioxide is specified, and is subject to the GADSL declarable substance. Reporting is required. As for brominated flame retardant where the CAS number is unknown, it is necessary to check whether it is subject to reporting. I will explain the details later. In addition, although acrylonitrile and 1,3-butadiene that are not described in the MSDS are JAMP declarable substances, they are considered as the residue from ABS polymerization, and therefore falls under unintentional addition. As is in this case, if the value is within the threshold or less than 0.1 wt%, reporting is unnecessary. So for this flame-retardant resin, there are two declarable substances. 4

5 Step 2 Step 2. As necessary, collect information on chemical substance content of the raw material from the upstream supplier, and re-calculate the preparation composition (cases where mixing and reaction exist in the own process) 1) Points to note in requesting chemical substance content information from upstream manufacturers - Once again, please reconfirm that you are not using any substances specified in the prohibited substances level 1 as specified in the Panasonic Chemical Substances Management Rank Guidelines. - Ensure that chemical substance content information is reported on a homogeneous material basis. - In MSDSplus and AIS, ensure that substances that require reporting under JIG, GADSL etc. are also reported. Ensure that all the chemical substances registered in the Input Support Tool are reported. (* If disclosure of all composition is requested by Panasonic, please urge upstream manufacturers to report all composition.) 2) Points to note in checking MSDSplus and AIS obtained from upstream manufacturers - Confirm that substances that require reporting under JIG, GADSL etc. are also listed. (* If disclosure of all composition is requested by Panasonic, please check that all the composition are reported.) - Confirm that the reported information lists not only substance names and/or groups, but also the CAS numbers of the reported chemical substances. e.g., "Lead compound" Not acceptable If a substance cannot be specified by MSDS Constituent specified in MSDS Constituent ABS resin Brominated flame retardant Antimony trioxide (Coloring agent) CAS No Unknown Unknown Content 65% 25% 3.0% 0-10% -Specified brominated flame retardants : Subject to legislation (PBB,PBDE, HBCDD etc.) - JAMP-SN0065 (PBB [group]) - JAMP-SN0066 (PBDE [group]) - CAS etc. (HBCDD) -Other brominated flame retardants : Subject to management - JAMP-SN0015 (Brominated frame retardants(bfrs) not restricted of their inclusion by regulations [group]) As step 2, collect the content information of chemical substances of raw materials from the upstream supplier, and re-calculate the composition of the preparation. This step is necessary when there is mixing or chemical reaction in your process. When requesting chemical substance content information to an upstream manufacturer, Once again, you should reconfirm that you are not using any substances specified in the prohibited substances level 1 as specified in the Panasonic Chemical Substances Management Rank Guidelines. Because substances that require reporting under GADSL and JIG have become mandatory from MSDSplus version 4, when you request upstream manufacturers to submit chemical substance content information, you should urge them once again to also report voluntary declarable substances in MSDSplus and AIS, such as substances that require reporting under JIG, GADSL etc. In other words, you should ensure that all the chemical substances registered in the Input Support Tool are reported. Ask the upstream manufacturers to report all the composition if you are asked by Panasonic to disclose all composition. You should confirm that the reported information lists not only substance names and/or groups, but also the CAS numbers of the reported chemical substances. Avoid reporting items as, for example, "a lead compound." If a substance cannot be specified by MSDS, such as the brominated flame retardant contained in the flame retardant resin, it is necessary to check detailed information. In the previous example, the substance name was not specified in MSDS, and the CAS number was also unknown. In such situation where a substance cannot be specified only by MSDS, check whether it falls under a brominated flame retardant subject to legislation. If it does, select JAMP-SN0065 (PBBs (group)) or JAMP-SN0066 (PBDEs (group)) and report. If it is an HBCDD, specify the CAS number and report. If the substance does not fall under specified brominated flame retardants subject to legislation, select JAMP-SN0015 (Brominated flame retardants (group) other than those regulated by law) and report. 5

6 Step 3 - Obtain the tool - for Panasonic Step 3. Enter necessary items and substance information into the MSDSplus Input Support Tool Get the MSDSplus Input Support Tool" from the JAMP website or the GP-Web manual download page. (JAMP website) (For Supplier) (For Panasonic internal use) (The image below is a sample of the GP-Web manual download page. Please access the website to check the actual page.) (1) (2) As procedure 3, enter necessary data and substance information to the MSDSplus Input Support Tool. First, get the MSDSplus Input Support Tool. Download it from the JAMP website or the GP-Web. 6

7 Step 3 - Start the tool - Step 3. Enter necessary items and substance information into the MSDSplus Input Support Tool 1. Start the MSDSplus Input Support Tool The MSDSplus Input Support Tool (1)" does not operate by itself. Make sure to place the "latest version of the external list (2)" in the same folder. [Excel 2002, 2003] Double click to start the tool. Enable Macros. (1) (2) [Excel 2007] (1) MSDSplus Input Support Tool : MSDSplus_input_support_{Version}.xls (2) External list : JAMP_MSDSplus_AIS_EXLIST_{revised date}.xls Updated version of the list is distributed Make sure to always use the latest version when revising the material/substance list. [Excel 2010] First, start the MSDSplus Input Support Tool. The MSDSplus Input Support Tool does not operate by itself. Therefore, make sure that the latest version of the "external list" is placed in the same folder. The external list is a list of selective items such as material, declarable substances or exemptions that the tool references in order to operate. Double click to start the Input Support Tool, and enable macros. The way to enable macros vary depending on the version of the Excel software. 7

8 Step 3 - Attentions regarding the external list - Step 3. Enter necessary items and substance information into the MSDSplus Input Support Tool 2. Attentions regarding the external list - Status confirmation of the "external list" will run when the tool is started in an internetaccessible condition. - If the external list is not the latest version, make sure to download the latest external list and replace the old version. - The external list itself does not operate alone. (*The excel sheet in the external list will not open by double-clicking since the contents are not disclosed.) Start the tool in an internetaccessible condition Download the latest version and replace the old list Download Latest version The external list is the latest version if this message appears. Replace Update the external list if an error message stating that the version is not the latest appears. Old ver. External list If you start the tool in a condition where it is accessible to the internet, the tool will access the JAMP website and check the version of the list. If an error message stating that your list is an older version, download the latest list and replace the older list placed in the same folder as the Input Support Tool. Please note that the external list does not operate by itself. It cannot be opened as a normal Excel sheet since it is protected to prevent tampering or degradation. 8

9 3. Select the Edit menu [Functional Option] Step 3 - Language settings - Step 3. Enter necessary items and substance information into the MSDSplus Input Support Tool - Language settings is available in the [Functional Option] sheet. The settings can be saved. Select from Japanese, English, or Chinese A sheet to edit MSDSplus will be displayed. General Information Composition Requester Information Functional Option Print When macros are enabled, a sheet for editing will be displayed. Language settings can be done in the "Functional Options" sheet. 9

10 Input Support Tool [General Information] Fields with the * symbol require entry. Step 3 - Enter necessary data - Step 3. Enter necessary items and substance information into the MSDSplus 1. Enter Company name/ item no. in alphanumeric characters For companies that do not have an official name in alphabetical characters: 1) Japanese: Enter in Romaji [E.g.] 日本化学電気工業株式会社 NIPPONKAGAKUDENKIKOUGYOU CO., LTD. or- NIPPONKAGAKUDENKIKOUGYOU KABUSHIKIKAISHA 2) Chinese: Enter in pinyin [E.g.] 上海化学电业有限公司 SHANGHAIHUAXUEDIANYE YOUXIANGONGSI 2. Select Declaration Concerning Substance Information (0 or 1) according to the content status First, enter the required information in the "General Information" sheet. The fields highlighted in orange, with a red star symbol are the required fields. Please enter issuing company item number in 1. Product information" and the company name in "2. Issuing company information" in alphanumerical characters. In Substance Information, select "Declaration Concerning Substance Information" according to the content status of the declarable substance. After entering the substance information, check the contents of the declaration and select the appropriate one. 10

11 Step 3 - Enter necessary data - Input Support Tool Also enter [Request Information] sheet when submitting to the Panasonic Group *Another way for entering is to upload to the GP-Web without entering requester information (in the form of self-registration), and then entering the "business unit code and business code item number" in the add delivery screen. for Panasonic Step 3. Enter necessary items and substance information into the MSDSplus 1. Requester's company name and Panasonic Business unit (E.g.: 000XXXXX) "Company name" and "Company ID/Entity ID" fields (Enter in single-byte characters) Enter of the Panasonic Business unit in this field may not be in compliance with the rules provided by JAMP, but please enter these fields for use on the GP-Web. Thank you for your cooperation. 2. Panasonic business unit's item number of the requested products Field "Requester Item Number 1" (Enter in single-byte characters) [Attention] Even if multiple relevant item numbers are entered in "Requester Item Number 2 to 6,",they will not be registered as individual data. (They will only be registered as reference data on the GP-Web.) When submitting to the Panasonic Group, please also enter [Requester Information] which is necessary for GP-Web upload, in addition to data required in the [General Information] sheet. There are three fields to enter. First, please enter the information on the Panasonic business unit that is the requester in the "company name" and "Panasonic business unit code" fields. Next, enter the Panasonic business unit item number for the product you are delivering in the "Requester Item Number 1" field. Please use single-byte characters. Also, please note that even if you enter multiple relevant product numbers in "Requester Item Number 2 to 6" and upload your data to the GP-Web, the numbers will not be registered as independent data items in the GP-Web. These three fields do not need to be entered when uploading new requests from the investigation reply screen on the GP-Web. 11

12 Step 3 - Enter composition chart- Step 3. Enter necessary items and substance information into the MSDSplus Input Support Tool [Composition] Even if a chemical substance is already registered in MSDS, please enter it in MSDSplus as well if it is a declarable substance. If any of the declarable substances present is potentially volatile and/or reactive, such properties must be noted in the remarks column. E.g. - Ink solvent; therefore volatile after printing - Changes to polymer after curing reaction of adhesive Enter the declarable substance information in the composition chart. Even if a chemical substance is already registered in MSDS, please enter it in MSDSplus as well, if it requires management. If any of the declarable substances present is volatile and/or reactive, such properties must be noted in the remarks column to provide information that is usable by the downstream user for chemical substance control. The form consists of chemical product information such as chemical substance or preparation, company information, declarable substance information in the product, and relevant standard information. 12

13 Step 3 - Enter composition chart- Step 3. Enter necessary items and substance information into the MSDSplus Input Support Tool Entry into the composition chart: Click select substance to display the substance selection screen (pop-up menu) [Composition] Enter declarable substance Enter maximum content Relevant standard fields will be automatically entered Attention when entering declarable substances (Details on next page) - Substances identified by a CAS No. Enter the CAS No. in the search field, and click "Search by CAS" - Substances unidentified by a CAS number and substances that are not broken down by individual CAS numbers Enter substance name or JAMP-SN (Substance Number) and search. When the substance name has been entered, the relevant standards will be automatically entered. Additions and changes can be made if the information on the internal substance list is insufficient. JAMP assigns a JAMP-SN (Substance Number) to some substances among the JAMP declarable substances: specifically, "substances unidentified by a CAS number" and "substances that are not broken down by individual CAS numbers (substances corresponding to a sub-group)." These substances are shown in JAMP Declarable Substance Reference List posted on the JAMP web pages for your confirmation and use. Also enter the maximum content. 13

14 Step 3 - Select substances - * Since some compounds have multiple names for the same CAS No., keep in mind to search by CAS No. using the correct CAS No. (E.g.) : Diantimony trioxide, Antimony trioxide, Antimony(III) oxide : Bis(2-ethylhexyl) phthalate, Di(2-ethylhexyl) phthalate, DEHP (3) Search substance (2) Click "Select" (4) Check search results (1) Click "Substance name cell" *Details of the substance (5) Click SELECT and copy the substance information *Relevant information on the substance including legislation First click the cell for "Substance name" and then click "Select" The Select Substance" screen will appear. Enter the substance name or CAS in the search box and click the appropriate search button. Of the substances listed at the center of the substance selection screen, the details and corresponding legislation information for those selected will be shown at the bottom. Check the search results, and click SELECT at the end. The substance information will be copied to the composition chart. The substance will be indicated in its English name. There is one thing to be careful of when searching a substance. Some compounds may have multiple names for the same CAS No. Even if a compound is included in the substance list, it may not show in the results if it is searched with a different name. Therefore, always keep in mind search by CAS No. using the correct CAS No. 14

15 Step 4 - Error Check - Step 4. Export the XML using the MSDSplus Input Support Tool. Check for errors before exporting the XML. A completion message will appear if no errors are found Click to check for errors in the data input If no errors are found: [report] If errors are found: If error is found (e.g. incomplete entry), description of the error will be displayed. Before executing the "Export XML", click "Error Check" to find any missing entries or other errors. If any errors are found, a report sheet with the description of the errors will be displayed. Check the content and correct the errors to complete. 15

16 Step 4 -XMLExport- Step 4. Export the XML using the MSDSplus Input Support Tool. Export the data in XML format for data transmission. Click "Export XML" XML If errors are found: When errors are found in the data contents, an error message will appear by clicking "XML Export." Select "No" and correct the errors. Next, click "Export XML" and prepare an XML file. An error check will also run during this time, and an error message will appear if any errors are found. 16

17 Step 5 (For Submissions to the Panasonic Group only) for Panasonic Step 5. Submit the data to the Panasonic Group (Upload the XML to the GP-Web) GP-Web: Uploading of an XML file of MSDSplus GP-Web Survey reply data Purchases Level Components Material Chemical substance Supplier Upload XML MSDSplus The final step, in Step 5, upload the MSDSplus to the GP-Web to submit the MSDSplus to the Panasonic Group. For details, please see the GP- Web section in the e-learning. 17

18 Supplement: Using an existing XML file -Check version- -Before reading in an existing XML file, please confirm that it was formulated using the latest versions of the Substances List. - If the versions are obsolete, your company should request the reporting manufacturer to re-submit the data in the latest versions. [Explanation] [General Information] If an older version is indicated: The contents of the XML file must be checked before use. (The list needs to be updated based on the latest information on declarable materials and substances.) Before reading in an existing XML file, you should confirm that it was formulated using the latest versions of the "Substance List. When updating information, check the JAMP declarable substance list or instruction manual for updates and revisions, and see whether those updates affect the composition disclosure of your products. 18

19 Supplement: Using an existing XML file - Update material information - - Following revision of JAMP declarable substances, the originally declared substance is newly specified as a controlled substance or a Substance of Very High Concern (SVHC) under the REACH regulations, thereby causing a change in the applicable information of the control-applicable regulations. - When reading the MSDSplus or AIS that were produced by referring to the former control-applicable substance list, update the contents according to the latest list. [Composition] Click "Update Substance Info" - When MSDSplus or AIS need to be issued with the latest information based on the loaded information of MSDSplus or AIS, renew the information by selecting "Yes" and complete the report by adding the substance to be declared. * A substance not included in the old MSDSplus or AIS cannot be updated with the new list. When the JAMP declarable substances are revised, the originally declared substance is newly specified as a controlled substance or a Substance of Very High Concern (SVHC) under the REACH regulations, thereby causing a change in the applicable information of the control-applicable regulations. When reading the MSDSplus or AIS that were produced by referring to the former declarable substance list, update the contents according to the latest list. When MSDSplus or AIS need to be issued with the latest information based on the loaded information of MSDSplus or AIS, renew the information by selecting "Yes" and complete the report by adding the substance to be declared. Substances not included in the old MSDSplus or AIS cannot be updated. Substances which have newly become restricted need to be added by confirming the description in the JAMP declarable substance guideline or a reference list. 19

20 Supplement: Printing the entered information To print out the entered information: [General Information] and [Composition] sheets can be printed out together as a consolidated sheet. Click "print," and update the information for the [Print] sheet. (The information for the printed sheet will not be updated unless the [Print] button is clicked.) [General Information] Click "Print" [Composition] Information entered in the [General Information] and [Composition] sheets are copied to the [Print] sheet. To print out the information entered in the General Information and Composition sheets at once, the printing function can be used. When entry to both sheets are completed, click the print button on the General Information sheet, and the information will be copied to the Composition sheet. Please note that the information will not be copied unless you click the PRINT button. 20