The Diisocyanate regulation is a REACH Regulation, which was published in the Official Journal of the European Union on 4th August 2020. REACH is an acronym referencing the Registration, Evaluation, and Authorisation of Chemicals. This regulation addresses industrial and professional use, targeting unsafe handling, whilst allowing adhesives and sealants to remain widely available. The regulation does not impact the DIY market.
This new requirement will apply to all professional and industrial users of these products. The products affected by this regulation should be labelled with the following 'As from 24 August 2023, adequate training is required before industrial or professional use' on the label.
Diisocyanates are used in polyurethane (PU) adhesives and sealants, and also happen to be classified as a potential human carcinogen - it is important that you are trained on proper use in addition to safety when using the applicable in a professional and/or industrial setting.
Additionally, all affected products MSDS will be changed to reflect this training requirement as well. Employers will have to keep records of certification for each member of staff using these products to prove in case of an inspection that staff have been trained and this will need to be renewed every five years.
If you or any of your staff use polyurethane (PU), adhesives and sealants containing DIISOCYANATES then training and certification will be required for all staff using these products by 24th August 2023 under REACH prior to the use of PU products containing diisocyanates.
Training is available in the form of e-learning for ease of use. Adhesive suppliers have no legal obligation to provide classroom training. E-learning is the preferred option. However, if local authorities deem e-learning to be inadmissible, the suppliers and their associations will support customers to find qualified trainers offering classroom training.
The regulation focuses on industrial and professional users of products containing monomeric diisocyanates, though the DIY market is not included. Many people have responsibility in enforcing this regulation both within and outside of your business - please see below.
Roles and Responsibilities
Supplier: The supplier's responsibility is to ensure labelling on their products has the correct text, and to update MSDS sheets with the correct information. They must also make training material available for specific products and staff.
Employer and/or End User Customer: An employer/end user customer must ensure training is delivered to all operatives using affected products by appropriate means (via online training or via expert) prior to product use. This training must be documented and reviewed at least every 5 years.
Operative: As an operative, it is imperative you complete training before using product.
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