The National Association of Shopfitters (NAS) has recently been contacted by members concerned around restrictions affecting the safe use of diisocyanates, which are scheduled to come into effect from 24 August 2023.
Diisocyanates are a key ingredient in the production of polyurethane foams, coatings, adhesives, sealants and other products. They are highly reactive and can cause skin and respiratory irritation, as well as allergies. Those are exposed to diisocyanates most frequently are the most likely to be affected.
Causing over 5,000 new occupational diseases in Europe in 2020, steps have been taken to regulate diisocyanate use. Those steps were later retained in British law under GB Retained: Regulation (EC) 1907/2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH). It is, however, only recently that the Regulations have been brought to the NAS’ attention and general awareness of the topic is low.
The Regulations
The Regulations say that diisocyanates shall not be used on their own, or in mixtures for industrial and professional use after 24 August 2023, unless:
- The concentration of diisocyanates is less than 0.1% by weight; or
- The employer ensures users have completed training on the safe use of diisocyanates before using products containing more than 0.1% of the chemical.
As such, if your business is using or producing products such as polyurethane foams, coatings, adhesives, sealants, you may need to take action to comply with the regulations.
How to prepare
The NAS recommends that businesses who use products such as polyurethane foams, coatings, adhesives, sealants, etc., swiftly take the following steps:
Firstly, examine the products you use. If the concentration of diisocynates in those products is greater than 0.1% by weight, then you will need to do one of the following:
- Consider using an alternative product which contains less than 0.1% diisocynates by weight; or
- Provide correct training to operatives using the products containing greater than 0.1% of diisocynates by weight.
Compliance
We have reached out to the Health and Safety Executive (HSE) for clarity on the subject and have been advised the following:
Suppliers [of polyurethane products] must ensure that training relevant to the particular products they are supplying is available, but suppliers do not necessarily need to deliver or pay for the training themselves. The legal duty remains on employers to ensure that all users have successfully completed the required training before using the substance.
There is no requirement in the diisocyanates restriction for an accreditation or certification scheme to be put in place for training users of the substance. Training will need to be adequate, appropriate to the use of the substance (which includes any specific circumstances as to where it is used, i.e., in Great Britain) and in line with the restriction.
Training
The level of training need can be assessed against this matrix (PDF).
E-Learning training can be purchased from safeusediisocyanates.eu. The cost per learner is 5 Euros per course, which will take between 45 and 120 minutes, depending on the level.
The NAS is exploring whether suitable training can be offered to our members for free via our EdApp platform. Further news on this topic will follow.
