From 24 August 2023, all workers (employed or self-employed), using mixtures containing diisocyanates (e.g. insulation and filler foams used in construction and vehicle repair), must undergo training. All employers must keep a record of successful completion and ensure its renewal every five years. The suppliers of these products must already ensure that the labelling includes the statement; “As from 24 August 2023 adequate training is required before industrial or professional use.” The suppliers, from the 24 August 2023, must check training information is available.
On 4 August 2020, a new restriction on diisocyanates was adopted in the EU under the REACH Regulation. This established training requirements prior to the use of products containing diisocyanates. The restriction aims to reduce the risk of respiratory and dermal sensitisation potentially caused by diisocyanates. All professional and industrial users of products containing diisocyanate at a concentration of 0.1% or more, e.g. polyurethane adhesives or sealants, must have successfully completed training on how to safely handle products containing diisocyanates by 24 August 2023. Their employer or the self-employed must ensure employees have successfully completed training as detailed within the conditions of the restriction, and that training is renewed at least every five years. Suppliers placing products containing diisocyanates on the market must ensure that the recipient is provided with training material and courses in the official language(s) of the Member State(s) where the substance(s) or mixture(s) are supplied. The training shall take into consideration the specificity of the products supplied, including composition, packaging, and design.
An industry-led comprehensive training programme is now available to ensure the safe use of diisocyanates for producers and professional users in the EU. The type of training required depends on the application and tasks carried out by employees. There are three different levels (General Training, Intermediate Training and Advanced Training), depending on the risk of exposure related to the task(s) performed by the user. A specific matrix is available to assist with identifying the correct type of training module(s). The training platform can be accessed via www.safeusediisocyanates.eu. Training is available in the form of e-learning for ease of use. Additionally, the material is available to organisations who want to provide their own in person training using suitably qualified occupational health and safety persons.
ISOPA, one of the training developers, are currently looking at expanding the list of certified external trainers to provide webinar and face-to-face training. They offer training by a master trainer for a fee during a three-day hybrid course to become a certified expert trainer for diisocyanates. If interested, please contact main@isopa.org. Holding a certification to prove successful completion of training will be mandatory for all professional and industrial users applying the product by 24 August 2023.
Details of this restriction can be found in all EU languages via EUR-Lex. If you have any questions in relation to your obligations under this restriction, please contact us at chemicals@hsa.ie
