What is the self-directed management of chemical substances — SDS, risk assessment, and appointing a manager

In short: The self-directed management of chemical substances shifts the emphasis from "individual regulation," where the state sets concrete methods per substance, to "self-directed management," where the employer chooses exposure-prevention measures based on its own risk assessment. From April 1, 2024, establishments that manufacture, handle, or supply risk-assessment target substances must appoint a chemical substances manager (Article 12-5 of the Industrial Safety and Health Regulations) and, as needed, a protective-equipment use manager (Article 12-6). There is no exclusion by industry or size.

For staff who handle hygiene management and labor matters at establishments dealing with chemicals — manufacturing, dry cleaning, food service, cleaning, and the like — this article organizes, from a Shakai Hoken Roumushi's viewpoint, the idea of self-directed management of chemicals and the duties to appoint a chemical substances manager and a protective-equipment use manager, to use SDSs and labels, and to carry out risk assessment (RA). For points outside a Shakai Hoken Roumushi's work — such as creating SDSs or specialist measurement — we make clear whom to assign them to.

What is the idea of the self-directed management of chemicals?

Traditionally, chemical-substance measures centered on "individual regulation," where the state set concrete methods for specific substances in ordinances — "handle this substance this way." But only a small part of the chemicals used in Japan was covered by individual regulation, and many occupational accidents arose from unregulated substances.

So the 2022 amendment of the Industrial Safety and Health laws and regulations broadened coverage to substances whose hazards are confirmed, and moved the center of gravity toward "self-directed management," where the employer performs risk assessment (investigation of danger or harmfulness) and, based on the result, itself chooses and carries out measures to prevent exposure. The relevant amending ordinance was promulgated on May 31, 2022, with part effective April 1, 2023 and part effective April 1, 2024.

The pillars of this shift are broadly three.

Pillar	Basis	Content
Conveying information	Industrial Safety and Health Act Article 57 (labeling), Article 57-2 (document delivery)	Labeling on containers/packaging, and notification via an SDS (safety data sheet) of components, hazards, handling precautions, etc.
Assessing risk	Industrial Safety and Health Act Article 57-3, paragraph 1	Investigate the danger or harmfulness of substances specified by Cabinet Order and notification-target substances (risk assessment)
Structure and measures	Industrial Safety and Health Regulations Articles 12-5 and 12-6, etc.	Appoint a chemical substances manager and a protective-equipment use manager; keep exposure to a minimum

How far have the risk-assessment target substances expanded?

The duty to perform risk assessment, under Article 57-3, paragraph 1, covers "the substances specified by Cabinet Order under Article 57, paragraph 1" and "notification-target substances" (together, risk-assessment target substances). With the shift to self-directed management, these target substances have been expanded in stages, adding in turn substances whose hazards are confirmed under the international GHS classification.

The target substances have been added year by year, with further additions in April 2026. For added substances, a transitional measure that defers the application of labeling and the like for a set period may be provided. What became covered and when, and the current target list, change with each revision, so check the exact substance names and counts against the MHLW's latest target-substance list (e.g., the Workplace Safety and Health site). This article does not present any specific substance count as confirmed information.

Whether a substance you handle is a risk-assessment target substance is first checked against the SDS and label of the product you purchased. If it is a target substance, risk assessment and, based on the result, measures to keep exposure to a minimum are in principle required. For substances with a concentration reference value, exposure at indoor workplaces must be kept at or below that value.

Who appoints the chemical substances manager and the protective-equipment use manager?

From April 1, 2024, establishments that manufacture, handle, or supply risk-assessment target substances must appoint a chemical substances manager. There is no exclusion by industry or by establishment size, so small establishments are also covered (establishments handling only consumer products, and the like, are outside the scope).

Role	Basis	Who/when appoints	Main duties
Chemical substances manager	Industrial Safety and Health Regulations Article 12-5	The employer, per establishment, within 14 days of the appointment trigger arising (not per task)	Checking labels/SDSs; managing the conduct of risk assessment and the recording/retention of results; managing exposure-prevention measures; managing communication/education to relevant workers
Protective-equipment use manager	Industrial Safety and Health Regulations Article 12-6	The employer, when having workers use protective equipment based on the risk-assessment result	Selecting effective protective equipment, managing its use, and maintaining it

The chemical substances manager is in principle appointed from among the workers at the establishment. At establishments that manufacture chemicals, there is a qualification requirement — such as having completed a specialist course set by the Minister of Health, Labour and Welfare. At non-manufacturing establishments there is no statutory qualification requirement, but attending a course to carry out the duties is recommended. Who may be appointed, and which course is needed, should be checked according to the establishment's category.

What should an establishment do with SDS checks and labeling?

Conveying information is the starting point of self-directed management. What an establishment does differs by its position.

• An establishment that buys and uses chemicals: check the SDS and label of the product you purchased, and grasp the substances, hazards, handling precautions, and first-aid measures it contains. Because an SDS is a basic document for risk assessment, organize and store it and make it available at any time to the workers who handle the substance. When decanting into another container, apply the necessary indication to that container too.
• An establishment that supplies chemicals to others (manufacturers, sellers, etc.): apply labeling on containers/packaging (Article 57) and give notification via an SDS (Article 57-2). When the SDS content changes, make an effort to notify promptly. Creating and providing the SDS itself is the work of the manufacturer/supplier, not of a Shakai Hoken Roumushi.

The information grasped from labels and SDSs feeds into risk assessment, the design of work procedures and the choice of protective equipment, and worker education. At workplaces handling chemicals, the safety and health structure is often reviewed together with hot-environment work and health management; see also what the worksite must do under the mandatory workplace heatstroke measures (effective June 2025) and how far are periodic health checkups the company's obligation.

What are the steps to build a self-directed management structure?

Building the structure is easier to organize in the following order.

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1. Inventory the chemicals you handle: take stock of the products you purchase, use, or manufacture at the establishment, and gather each one's SDS and label.
2. Check whether they are risk-assessment target substances: based on the SDSs, confirm whether they are target substances. If there is a target substance, the duty to appoint a chemical substances manager arises.
3. Appoint a chemical substances manager: per establishment, within 14 days of the trigger. A manufacturing establishment confirms the qualification requirement.
4. Perform risk assessment: investigate the danger/harmfulness of the target substances, and record and retain the result. Based on the result, consider measures to keep exposure to a minimum (changing work methods, local exhaust, use of protective equipment, etc.).
5. Arrange protective equipment and education: if you have workers use protective equipment, appoint a protective-equipment use manager, and arrange work procedures and worker education. Reviewing internal safety and health rules together with from how many employees are work rules mandatory, and what is not stabilizes operation.

Working-environment measurement and specialist measurement of individual workers' exposure concentrations are the domain of a working-environment measurement expert and specialist bodies. For evaluating health effects or whether checkups are needed, consult an occupational physician or specialist body. If a health impairment from chemicals arises in the course of work, the flow of the workers' accident insurance claim and the worker casualty report is summarized in when an employee is injured at work, what does the company do?.

四葉社会保険労務士事務所 can advise on maintaining the safety and health structure including appointing a chemical substances manager and a protective-equipment use manager, reviewing the work rules and safety and health management regulations, and how to carry out worker education. Consultation is free; fees are in the fee schedule, and frequently asked questions in the FAQ.

Frequently asked questions

Q. What is the self-directed management of chemicals?
A. It is the idea of moving the center of gravity from individual regulation, where the state sets concrete methods per substance, to self-directed management, where the employer chooses exposure-prevention measures based on its own risk assessment. It stems from the 2022 amendment of the Industrial Safety and Health laws and regulations; the relevant amending ordinance was promulgated on May 31, 2022, with part effective April 1, 2023 and part effective April 1, 2024.

Q. Which establishments must appoint a chemical substances manager?
A. From April 1, 2024, establishments that manufacture, handle, or supply risk-assessment target substances appoint one per establishment (Article 12-5 of the Regulations). There is no exclusion by industry or size. Appoint within 14 days of the trigger; at establishments that manufacture chemicals, there is a qualification requirement such as completing a specialist course.

Q. When do you appoint a protective-equipment use manager?
A. When having workers use protective equipment based on the risk-assessment result, the employer appoints one (Article 12-6 of the Regulations). They select effective protective equipment, manage its use, and maintain it.

Q. Who creates the SDS? Does the Shakai Hoken Roumushi?
A. Creating and providing an SDS (safety data sheet) is done by the employer that manufactures, transfers, or supplies the chemical (the manufacturer/seller) (Article 57-2). It is not a Shakai Hoken Roumushi's work. An establishment that buys and uses chemicals checks the SDS and label it receives and uses them for risk assessment and education. Specialist measurement of the working environment is the work of a working-environment measurement expert.

Sources

• Industrial Safety and Health Act Article 57 (labeling etc.): a person who transfers/supplies, in a container or packaging, dangerous substances or certain health-impairment substances must indicate the name, effects on the body, handling precautions, etc.
• Industrial Safety and Health Act Article 57-2 (document delivery etc.): a person who transfers/supplies a notification-target substance must notify the counterparty, by document delivery or other method, of the name, components and their content, hazards, handling precautions, first-aid measures, etc. (SDS).
• Industrial Safety and Health Act Article 57-3, paragraph 1: the employer must investigate the danger or harmfulness of the substances specified by Cabinet Order under Article 57, paragraph 1 and of notification-target substances (risk-assessment target substances) — risk assessment. Paragraph 2 = measures based on the result (duty of effort).
• Industrial Safety and Health Regulations Article 12-5: appointment of a chemical substances manager. Establishments that manufacture/handle/supply risk-assessment target substances (no industry/size requirement) appoint one per establishment. Effective April 1, 2024.
• Industrial Safety and Health Regulations Article 12-6: appointment of a protective-equipment use manager, when having workers use protective equipment based on the risk-assessment result. Effective April 1, 2024.
• Relevant amending ordinance: the Ordinance Partially Amending the Industrial Safety and Health Regulations etc. (promulgated May 31, 2022); part effective April 1, 2023, part effective April 1, 2024.
• Risk-assessment target substances: expanded in stages by adding, in turn, substances whose hazards are confirmed under the GHS classification; further additions in April 2026. The exact substance names, counts, and application timing follow the MHLW published list (this article does not present any specific substance count as confirmed).
• MHLW: new regulation to prevent occupational accidents caused by chemical substances and the Workplace Safety and Health site. Accessed October 9, 2026.
• Business of a Shakai Hoken Roumushi: Article 2 of the Certified Social Insurance and Labor Consultant Act.

This article does not decide whom to consult. Maintaining the safety and health structure including appointing a chemical substances manager and a protective-equipment use manager, reviewing the work rules and safety and health management regulations, and how to carry out worker education are matters a Shakai Hoken Roumushi can help with. Creating and providing an SDS is the work of the chemical's manufacturer/supplier; working-environment measurement and specialist measurement of individual exposure are the work of a working-environment measurement expert; evaluating health effects is the work of an occupational physician or specialist body. The final judgment of whether a substance you handle is a risk-assessment target substance and how far measures are needed rests on the latest primary sources and confirmation with the competent Labour Standards Inspection Office and Prefectural Labour Bureau. If you consult 四葉社会保険労務士事務所, fees are in the fee schedule and frequently asked questions in the FAQ.

This article is general information. Individual judgments — such as whether a substance you handle is covered and how far measures are needed — are made by a qualified professional after a consultation, in light of the latest primary sources (the Ministry of Health, Labour and Welfare, etc.) and individual circumstances. Written by Joji Uramatsu (Shakai Hoken Roumushi, Gyoseishoshi, Registered Real Estate Transaction Specialist).