Provisional Translation
| OTO No. | 441 | Classification | MHA-11 |
|---|---|---|---|
| Date of Acceptance | January 7, 1991 | Ministry/Agency Receiving Complaint | Economic Planning Agency |
| Responsible Ministries | Ministry of Home Affairs | Related Laws | Fire Service Law |
| Complainant | US firm | Exporting Countries | USA |
| Subject | Regarding pressure vessel test for industrial chemical blowing agents for rubber and plastics under the annexed table of the Fire Service Law: 1. Review on the domestic maker's test results. 2. Abolishment or improvement of the pressure vessel test. |
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| Details of Measures | 1. The Fire Defense Agency makes use of a "Hazardous Materials Database" to streamline and standardize its assessment of hazardous materials. Business operators wishing to register a substance for the database should submit the test results performed in accordance with the Fire Service Law to the Fire Defense Agency. After examining the data, the Agency will record the data in its database and will issue "Registration Certificate" to be used in simplifying formalities under the Fire Service Law. Because the substances at issue (OBSH [oxybis benzenesulfonyl hydrazide] and ADCA [azodicarbonamide]) both fall under the "self-reactive materials" heading under 5th group hazardous materials as defined by section 7 of Article 2 of the Fire Service Law, as concerns the hazard of explosion or decomposition by heating they have to be evaluated by pressure-vessel tests and thermal analysis tests. Although Japanese manufacturers have submitted test data on OBSH and ADCA to the Fire Defense Agency, the Agency conducted confirming tests of the petitioner's product and others in connection with this petition. These tests indicated that, as had been indicated on the Japanese manufacturers' tests, that OBSH is a dangerous substance at 100 percent Curity but non dangerous at 95 percent Curity or less. However, for ADCA, which the Japanese manufacturers had indicated was a non-dangerous substance, it was found that this is a type-five dangerous substance at industrial purity, and ADCA was deleted from the Dangerous Substances Database as of April 30, 1991. All of this was explained. 2. In the pressure-container testing, the container is subjected to the same conditions in ten or more test repeats and the decision is then made on the basis of whether there is a 500r greater chance that the shatter plate will shatter. This is easily duplicated, and there are no plans to abandon this test at this time. It was also explained that the pressure-container testing is required for OBSH, ADCA, and other CBAs (chemical blowing agents) and that this is not required for only a few specific substances. |
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| Classification of Processing | 1. A 2. D |
Directions | 1. I-a 2. I-a |
| Remarks | 1. Improvement measures were taken on April 30, 1991. | ||