Japan Soap and Detergent Association (JSDA)

June 2009


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No. 30 (June 2009)

Inside of this issue
1.Review of Designated Chemical Substances in Chemical Control Law - Review of Designated Chemical Substances and Ideal Way of Chemical Management
2.Correlation Exists between Surfactant Concentration and BOD in the River (Summary of the 10-year JSDA environmental water monitoring survey)
3.Reduce More - How we should deal with the demand which is getting more stringent? Activity of JSDA Container and Packaging Waste Management Technical Committee

1.Review of Designated Chemical Substances in Chemical Control Law

Review of Designated Chemical Substances and Ideal Way of Chemical Management

Hisashi Fujisawa
, Associate Director, Chemical Control Division, Manufacturing Industry Bureau, METI

1) Direction of the Chemical Control Law review

photo Joint sessions of METI and Ministry of Environment (ME) for the Chemical Control Law review had been held since February, 2007, and an official report was submitted in August.
In this report, it was concluded that maintaining current regulatory system is appropriate, because 1) manufacturers are promoting self-control via development of their management plan according to the chemical management self-control guide, 2) the system established by "Act on Pollutant Release and Transfer Register (PRTR Law)" has proven effective to some extent in reducing negative environmental impact of designated chemical substances, as it requires manufacturers to keep the record of usage for the past 5 years, and 3) the MSDS (Material Safety Data Sheet) system is working and playing a role to promote exchanging technical information among manufacturers.
Provided above as a background, the report further recommended 1) reviewing current list of designated chemical substances based on up-to-date technical information, and 2) reviewing the technical information disclosure system.

2) Chronological details and outline of the designated chemical substances review

Addition and deletion of chemicals in Class I and II Designated Chemical Substances were discussed in four joint meetings of the committee of METI, ME and Ministry of Health, Labor and Welfare (MHLW), conducted from October, 2007 to June, 2008.
It was decided in the meetings 1) that current criteria for each hazardous property and the threshold amount discharged to and remained in the environment be continuously used for the designation, while adding new criteria applied to the GHS (Globally Harmonized System) classification, and 2) that reproductive toxicity and germ cell mutagenicity be newly added to the decision for Class I Designated Chemical Substances.
Original candidates, which were considered to be newly added to either Class I or II Designated Chemical Substances, counted 270 chemicals. However, the number of candidates was eventually reduced to 217, accepting technical arguments such as "solubility must be taken into account for the final toxicity judgment against aquatic life", "chemicals, of which the influence to aquatic life is not understood due to high volatility, must be excluded", etc.
Finally, 28 chemicals were deleted from Class I Designated Chemical Substances, and 57 chemicals were deleted from Class II Designated Chemical Substances. Also, some chemicals were replaced from Class I to Class II Designated Chemical Substances, and vice versa. As a result, the number of chemicals in Class I Designated Chemical Substances became 462 (354 previously), and the number of chemicals in Class II Designated Chemical Substances became 100 (81 previously).

3) Criteria of the designated chemical substances review

The following toxicity items and the criteria set for each item when the system was originally established were continuously adopted to the evaluation. Then, each chemical was put into either Class I or II Designated Chemical Substances, if at least one hazardous property of the chemical meets the criteria.

1. Carcinogenicity
2. Mutagenicity
3. Oral chronic toxicity
4. Inhalation chronic toxicity
5. Inhalation chronic toxicity obtained according to workplace environmental exposure level
6. Reproductive and developmental toxicity
7. Sensitization
8. Ecotoxicity
9. Ozone-layer depleting substance

4) Surfactant designated in and excluded from the list

Four surfactants were newly added to Class I Designated Chemical Substances only from the ecotoxicity point of view.
Besides, sodium stearate and sodium oleate that are key ingredients of soap had remained in the candidate list for discussion until the third meeting, but later, they were removed from the list based on specialists’ judgment as outside of the ecotoxicity criteria.

5) Actions to the risk and remaining issues

Chemical Control Law is a regulation not to restrict discharge or usage of chemicals, but to reduce the total amount of discharge via self-control by manufacturers. In other words, it does not mean that chemicals listed in Class I or II Designated Chemical Substances are harmful or should not be used. It is important to understand that the objective is to appropriately manage chemicals with correct understanding of the risk.
For instance, WHO recently approved the use of DDT in a certain region, because complete prohibition of the use was proven to lead an increase of death by malaria.
There are no no-risk chemicals. There is always a reason why a certain material is used. It is therefore necessary to consider it in a balance of profit and risk, rather than simply reacting such that the chemical has to be prohibited or has to be stopped using.
There are three types of risk in the environmental risk assessment, i.e. real image of the risk, regulatory risk and anxiety that consumers hold. The last one is taken sometimes far greater than the actual risk and tends to get public attention more greatly.
It seems that anxiety that consumers hold could affect even the policy decision in the country, now-a-days. In such a case, it is essential to disclose the risk information that each manufacturer has. However, the situation differs case by case, and what is difficult is that there are no uniform answers on the action to be taken.
photoWe'd like to continuously think how we can make consumers correctly understand the risk from the scientific point of view.

2. Correlation Exists between Surfactant Concentration and BOD in the River

Summary of the 10-year JSDA environmental water monitoring survey

Kazuaki Miura
, JSDA Human & Environmental Safety Technical Committee

1) Why does JSDA conduct the environmental water monitoring survey?

Human and Environmental Safety Technical Committee of JSDA has been conducting measurement of the surfactant concentration in the river since middle of 1990's. The survey began with a spot-base measurement, but it was extended to a monitoring survey about 10 years ago.
The reason why we continued the survey for such a long time is that it was publicly spread that surfactant has a negative impact on the environment, despite the fact that such a survey had never been conducted in the past.
It was anticipated along with the spread of synthetic detergent that the environmental safety of surfactant in detergent would be discussed sooner or later, as it was internationally recognized with conclusive data that surfactant has low human safety profile from rather early time. In order to prepare for the discussion in the foreseeable future, JSDA decided to conduct the monitoring survey, which was to evaluate the surfactant concentration and its effect in actual rivers.
This monitoring survey, conducted four times a year, measures the surfactant concentration at five points (later increased to seven) of four rivers (Tamagawa, Arakawa, Edogawa and Yodogawa), all of which flow through major cities in Japan (Tokyo and Osaka). We recently reported the result in the academic society, as the data from this survey were accumulated for ten years.

2) Ecological risk of surfactant is low.

Environmental water in Japan is classified as AA, A, B, C, etc. by required water quality for the purpose of use. Survey spots of the monitoring are chosen from a range of places classified as A (2nd class in drinking water service and 1st class for fishery) to places classified as C (3rd class for fishery).
Environmental impact is normally evaluated by the effect to the aquatic life, and a test method appropriate to evaluate it was chosen for the monitoring. The ecological risk was then assessed by comparing the highest level of surfactant concentration possibly observed in the river (95 percentile) with the concentration which is technically presumed no impact on the aquatic life (PNEC - Predicted No-Effect Concentration).
The survey result confirmed that the LAS, AE and AO concentration in these rivers was far below the PNEC concentration, as shown in Table 1.

Table 1: Ecological Risk Assessment for Surfactant

3) MBAS figures are declining thanks to the drainage spread.

Several indexes are used to evaluate the pollution status of environmental waters. Surfactant remaining in the river water has been paid attention since the time when so-called synthetic detergent became popularly used. Anionic surfactant is used in synthetic detergent and it has been measured as "Methylene Blue Active Substance (MBAS)" by using the chemical characteristics of forming its complex with methylene blue.
Yearly data on MBAS and BOD since 1963 at the Den-en Chofu dam of Tamagawa (Tama River) is shown in Fig. 1 as an easy-to-understand example instead of yearly data on actual LAS and AE concentration which are also available.

Figure. 1: Water Quality Progress at Den-en Chofu dam of Tamagawa

As shown, both MBAS and BOD are declining after the peak at the end of 1960's. This is attributed to the conversion from ABS to surfactant easier to degrade by the action of microorganism, such as LAS, and the spread of drainage. In more details, the amount of surfactant discharged to the aquatic environment like rivers decreased as it is degraded in the sewage plant, while surfactant in the river water, per se, is even degraded there.
The decline in BOD shows the spread of drainage well. The drainage coverage is expanding steadily, and it is clear that it greatly contributes to the water quality improvement in the public water such as rivers.

4) Correlation exists between BOD and the surfactant concentration.

The environmental risk in the survey areas can be determined based on the monitoring results; however, this is limited to the monitoring areas and cannot be applied to the other areas.
In order to assess the environmental risk at the national level, the surfactant concentration in all the river waters across the country should be measured and evaluated, but it is practically impossible to conduct a similar survey in various places all over the country.
As an alternative to the nationwide survey, we developed a method to predict the surfactant concentration by appropriately analyzing the data already available.
Through some scientific trials, we found that there is a certain correlation between BOD and LAS concentration as shown in Fig. 2, in which the data obtained from the survey are grouped by BOD level and statistically analyzed. This indicates that, using this correlation, it is possible to predict the proximity of surfactant concentration with the value of BOD.

Figure 2: Correlation between LAS Concentration and BODfigure2

BOD is measured in most municipalities in the country, and this means that it should be conceptually possible to conduct risk assessment using the surfactant concentration predicted from the BOD data of rivers across the country, where the surfactant concentration is not even actually measured. This finding may be broadly applied to various fields in the future.
As shown, BOD is less than 5mg/L in most rivers in Japan at present, and this leads us to conclude that the possibility (risk) that surfactant remaining in current environmental water in Japan harmfully affects the aquatic life is minimal. Regardless that it contains surfactant or not, it is anyway important that useless use of consumer goods, e.g. daily necessaries, should be restrained in order to keep the health of public water such as rivers, lakes and marshes.

3. Reduce More - How we should deal with the demand which is getting more stringent?

Activity of JSDA Container and Packaging Waste Management Technical Committee

Hiromi Yamamoto
Chairman, Container and Packaging Waste Management Technical Committee

photoContainer and Packaging Waste Management Technical Committee is a sub-committee of Environmental Committee of JSDA, and handles matters related to the container and packaging waste. This committee began its activity when “Law for Sorted Collection and Recycling of Containers and Packaging (Container and Packaging Recycling Law)” was enforced in full scale in 1997.

● Waste reduction effort has been promoted since 1995.
It was natural that excessive packaging caught public attention first, when the garbage issue was closed up socially in Japan. Because the container and packaging waste occupied 60% of total garbage, people focused on and criticized excessive packaging as major cause of the issue. Containers and packaging of soap and detergent usually consist of either paper or plastics. Technically speaking, paper containers and packaging are relatively easy to recycle, but the waste management of plastic containers is presumably a big issue.
Plastic containers are indispensable for soap and detergent products with liquid and sticky characteristics. JSDA concluded in 1995 that it is necessary to develop a countermeasure to decrease the total amount of plastics used in containers discharged to garbage, and, began to work from fact-finding on this issue.
It is publicly recognized that only JSDA among all industry associations in Japan has complete data on the material usage in the industry, of which each manufacturer provides to the association. Therefore, JSDA can show the actual reduction of plastic usage in the containers and packaging for the whole industry.
It is a favor of the effort of seniors in the industry association who initiated independent actions with foresight, ahead of the enactment of Container and Packaging Recycling Law. Current members of the technical committee have succeeded to this heritage, and keep making efforts to reduce the container and packaging waste.

● JSDA tries to reduce the waste with self-imposed action standard.
Approaches that have been adopted up to now to reduce the plastic container waste include; 1) making a container smaller by concentrating the product, and, as a result, reducing the total usage of plastics for the container, 2) developing a refillable or re-usable container, so that original container can be reused either completely or partly, and 3) reducing net weight of plastic usage of the container by reducing thickness of plastics as much as possible. Manufacturers in the industry have practiced these approaches to reduce the total amount of the plastic container waste.
The self-imposed action plan was settled in 2006, aiming at controlling the amount of the plastic container waste with a concrete numerical target. (Refer to the article in the next page.)

● Reduce More - Reduce by the gross
The manufacturer responsibility may be specified more clearly in the scheduled review of Container and Packaging Recycling Law in the near future. It is highly anticipated that the discussion moves to reducing more and reducing the total amount of waste by the gross in the future not to mention the grasp of actual amount of the total waste.
If the manufacturer cannot clearly show the reduction effort, it will be judged that the social responsibility is not fulfilled and the consequence would be an increase of the defrayal. Our challenge is to deal with social and official requirements that become severer.

● Plastic Usage Reduction in Containers per Unit Weight of Product


JSDA has continued an effort to understand the realities of plastic usage in containers for products in the entire industry since 1995, while each manufacturer in the association has been making efforts to reduce the plastic usage of their own products. JSDA published the self-imposed action plan in June, 2006, which required reducing 30% of the unit plastic usage per product by 2010 versus 1995 for eight main products categories (body shampoo, hand-washing laundry detergent, hair shampoo and conditioner, liquid laundry detergent, fabric softener, dish-washing detergent, hard-surface cleaner, and bleach and mold remover). The total plastic usage in these target product categories in 2007 was 63,700 tons, which increased by 5.6% versus previous year due mainly to an increase of total product shipment but decreased by 11.7% versus 1995.
Importantly, the unit plastic usage per product, i.e. target standard of JSDA's self-imposed action plan, was 58kg/ton in 2007, which was almost the same as the previous year and less by 31.8% versus 1995.
There are, however, some product categories which did not achieve the target, and we will continue our efforts towards complete achievement of our self-imposed standard in 2010.

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