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2. Dec 2021 | Legislation

A safe future for polyurethane products

Isabelle Alenus, Feica

On 4 August 2020, a new restriction on diisocyanates under REACH was adopted by the European authorities, targeting respiratory and dermal sensitisation potentially caused by diisocyanates.
Professional and industrial users of diisocyanates will be responsible for seeing to the completion of training for themselves and their employees.
Image source: qimono - Pixabay (symbol image).

REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) is a regulation of the European Union, adopted to improve the protection of human health and the environment from risks that can be posed by chemicals, while enhancing the competitiveness of the EU chemicals industry.

Polyurethane (PU) adhesives and sealants are safe for use in numerous products in a multitude of industries, such as automotive, furniture, construction, and packaging. The production of polyurethanes requires aromatic or aliphatic diisocyanates. These are safe when used in accordance with established safety measures. In the PU production process, the diisocyanates, reacting with polyols are in fact used up so that they do not exist in the finished polyurethane products. The restriction does not ban the use of polyurethane adhesives and sealants, but establishes training requirements for their safe use. PU adhesives and sealants will therefore continue to be widely used because of their versatility in a variety of applications and as there are no other technologies existing that can produce products with all the properties that PU has.             

REACH Regulation EC/1907/2006 addresses the production and use of chemical substances, and their potential impacts on both human health and the environment. The 4 August 2020 restriction under REACH specifies the need for training and labelling requirements for industrial or professional users of diisocyanates (individually or in combinations) with a monomeric concentration greater than 0.1 % by weight. The restriction applies to any activity where exposure to diisocyanates may occur. It does not apply to PU products used by consumers. A separate restriction regarding consumer products has already been implemented.        

Mandatory training requirements

Professional and industrial users of diisocyanates will be responsible for seeing to the completion of training for themselves and their employees. Managers, too, will 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 suppliers regarding the receipt of the information is required. Distributors must convey to their customers information received from suppliers.

Training and certification, which involves passing an examination, must have been completed by 24 August 2023. Records of the training given to employees must be maintained by employers. Every five years, renewal of the training will be necessary.  There are three levels of training corresponding to the different levels of risk. Each individual’s required training content, then, will depend upon the level of risk to which they are exposed.      

New PU training platform

FEICA, in coordination with the European Diisocyanate & Polyol Producers Association (ISOPA), the European Aliphatic Isocyanates Producer Association (ALIPA), and several other industries in the polyurethane industry, has been working hard to organise a comprehensive training programme to ensure the safe use of diisocyanates for producers and professional users all over Europe. In this way, FEICA also ensures that all end users of PU containing adhesives and sealants across Europe continue to handle diisocyanates safely. A training platform was launched in English in November 2021. From 1 December it will be available in German.

The platform will be accessible across the EU, and all training material will also be made available in every EU language by the middle of 2022. A voucher for free training for all end users of European PU adhesives and sealants is available on www.feica.eu. In addition, the training material will be available for individual classroom training.

Labelling Obligations

Effective 24 February 2022, a sentence/label must appear on products to be used industrially or professionally having a total monomeric concentration greater than 0.1 % by weight. The sentence could read: “As of 24 August 2023, adequate training is required before industrial or professional use of this product.” The 4 August 2020 restriction under REACH does not give additional information regarding the specifics of the label (e.g. size, location, or language). We strongly encourage all parties concerned to begin making provisions for the labelling as soon as possible and to check the FEICA website regularly for updates.

PU information webpage for the adhesives and sealants

To facilitate adhesive and sealant companies to comply with the information provision requirement, an information webpage has been created to provide users with additional information on the training. The webpage will be updated on a regular basis and can be accessed via www.feica.eu/PUinfo. A link to this webpage (or QR code) may be added to adhesives and sealants labels to guide users to the training platform.   

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