The restriction of diisocyanates under the EU REACH regulation, published in the EU Official Journal, introduces new minimum training requirements for employees handling diisocyanates and mixtures containing diisocyanates.
In August, the EU Commission finally published the restriction of diisocyanates in the Official Journal of the EU. According to this, qualified training in the handling of diisocyanates along the entire value chain in the PU industry will be mandatory in the future. The restriction regulates the placing on the market and handling of diisocyanates as independent substances, as a component of substances or in mixtures. Diisocyanates for industrial and commercial purposes are regulated at concentrations of more than 0.1 % by weight. The restriction provides for a transitional period until August 24, 2023. After this date, the training courses will become mandatory throughout Europe.
Content of the regulation
Specifically, the restriction regulates the following:
- the minimum training requirements for industrial and commercial users of diisocyanates (stricter national regulations of the Member States are not affected),
- the provision of training material in the official languages of the Member States by the respective diisocyanate suppliers,
- the obligation to include information on training requirements already on the packaging by suppliers of diisocyanates,
- the obligation of employers or self-employed persons to document the successful completion of the training,
- updating the required training every five years,
- the obligation for the Member States to report on the progress and effects of the restriction.
Application and restriction of diisocyanates in practice
Typical cases of handling diisocyanates are processing, spraying, various application types, post-treatment, cleaning, and waste handling. As part of the promotion of occupational health and safety when handling chemicals such as diisocyanates, the European REACH regulation (Registration, Evaluation, Authorisation, and Restriction of Chemicals) allows the manufacture, placing on the market or use of a potentially hazardous substance to be restricted or prohibited to protect human health and the environment. For diisocyanates, this restriction means that all employees who come into direct contact with the substances must be both informed and trained to manage the risks involved in handling the substances. Otherwise, handling is not permitted.
Industry collaboration for optimal employee protection:
The entire diisocyanates industry – from manufacturers, formulators/system houses, and machine manufacturers to processors – were involved in the process from the very beginning through their interest groups. National and European associations have worked closely together to compile and make relevant data and information available to the authorities. The development of a comprehensive package of training materials for the industrial and commercial value chain is imminent. The Specialist Association Foamed Plastics and Polyurethanes (FSK e.V.) is actively involved in this process at the European level with its processors’ specialist knowledge. Klaus Junginger, Managing Director of the FSK, sees an online platform’s development as the right and appropriate solution from his many years of experience. Last but not least, to ensure a consistently high level of training throughout Europe: “We are pleased to be involved in the successful implementation of the restriction and started developing training material several years ago. We understand qualified personnel as the key to every successful company. The continuous improvement of employee protection is, therefore, in the interest of our members. We, therefore, support the restriction proposal to the best of our ability and drive the implementation forward with our knowledge and expertise”.
The EU reach restriction procedure for diisocyanates was initiated by the German Federal Institute for Occupational Safety and Health (BAuA), which submitted a restriction proposal to the European Chemicals Agency (ECHA) in 2016. Within the framework of the European restriction procedure for substances, ECHA determined that mandatory training is the most appropriate, safest, and effective EU-wide risk management measure to reduce occupational asthma among employees exposed to diisocyanates. ECHA submitted the relevant restriction proposal to the Commission.
The FSK e.V. and its polyurethane processing members:
The Specialist Association Foamed Plastics and Polyurethanes e.V. (FSK), is an association of the plastics processing industry. It represents the interests of plastics processing companies at the national and the European level. Among its members are also manufacturers and processors from the polyurethane material sector. Together with polyols, diisocyanates are the essential building blocks of polyurethanes. It can be either rigid or flexible and offers various end-user applications such as insulation (of buildings, refrigerators, and freezers), adhesives, coatings, car parts, sportswear, beds, and furniture.
Further information on the Specialist Association Foamed Plastics and Polyurethanes e.V. (FSK), its members, materials, and products can be found at : www.fsk-vsv.de or by phone: + 49 (0) 711 993 751- 0.