New obligations for sale of Diisocyanate products from 24th August 2023
Mandatory Training requirements for Professional and industrial users of Diisocyanates
Diisocyanates are essential building blocks of polyurethanes, a plastic material used in a multitude of everyday objects and applications. It is the material of choice for a broad range of end-user applications such as insulation, adhesives, sealants and coatings.
The REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) Regulation EC/1907/2006 aims to improve the protection of human health and the environment from the risks that can be posed by chemicals, while enhancing the competitiveness of the EU chemicals industry. On the 4th August 2020 the EU adopted a new restriction (Entry 74 of REACH) Annex XVII) on the placing on the market and use of diisocyanates; which impacts professional and industrial users. All professional and industrial users of diisocyanates must undertake adequate training before use as from 24th August 2023. Substances restricted under Entry 74 of REACH.
Labelling & SDS Obligations
Products sold within the EU, including Ireland, with a total monomeric Diisocyanate, concentration greater than 0.1%, intended for professional or industrial use, must have the statement below on the product container label by 24th February 2022:
“As from 24th August 2023, adequate training is required before industrial or professional use of this product”.
This sentence should be visibly distinct from the rest of the label information and should appear in the `Other Information section` of the Safety Data Sheet.
Mandatory training requirements
Professional and industrial users of diisocyanates will be responsible for ensuring the undertaking and completion of training both for themselves and their employees. The training is mandatory and may be given online. Training and certification, which involves passing an examination, must be completed by 24 August 2023, or prior to use thereafter. Renewal of the training will be necessary every five years and records of the training given to employees must be maintained by employers. There are three levels of training corresponding to the different levels of risk. Each individual’s required training content will therefore depend upon the level of risk to which they are exposed.
Do Retailers have to inform their customers about training?
The legal text specifies that information on how to access the training courses should be communicated throughout the supply chain and it is the responsibility of the operators placing the substances and mixtures on the market to ensure that training courses are available to the recipients of such substances or mixtures.
The retailer should contact their supplier (distributor, formulator or importer) to help identify products affected by this restriction and feed that information downstream regards which product/s contain the substance and require training. While suppliers are responsible only for informing users of the need for the training, they are not responsible for training workers. No confirmation from the users to the retailers regarding the receipt of the information is required. Retailers must convey to their customers, information received from suppliers.
Do you need to train your sales, administrative and warehouse employees?
The Health and Safety Authority (HSA) recommend that retailers raise awareness on the requirement for training on this restriction with their sales staff. It is recommended that you compile an inventory of all Diisocyanate containing products that you sell along with details of the relevant training courses available to ensure that all sales staff are made aware of this labelling along with the provision of training materials requirements. The HSA would advise staff to inform professional/trade account holders of the training requirements prior to any future sale transactions. For further details and training options see here: Safe use of Diisocyanates - Homepage (safeusediisocyanates.eu).
For any queries relating to the safe supply, use and management of chemicals, you can contact the Health and Safety Authority - chemicals helpdesk on chemicals@hsa.ie or by calling 0818 289 389. Lines are open Monday to Friday between 9:00am and 3:00pm.
