Diisocyanates – The regulation deadline is approaching

On 1^st January 2021, the EU REACH regulation was brought into UK law and, therefore, the EU restriction on diisocyanates was carried into UK legislation. Diisocyanates are a family of versatile building blocks used to make a range of polyurethane products used widely in the joinery sector, including paints, adhesives, spray foams, sealants, inks and rigid or flexible foams.

Under the regulations¹, from 24^th August 2023, anyone whose work involves use of diisocyanates, either on their own or where the chemical is part of another substance or mixture (except for when in very low concentrations), is required to have completed specific training.

Where an employee carries out work that may expose them to a hazardous substance the Control of Substances Hazardous to Health (COSHH) Regulations require their employer to provide suitable and sufficient information, instruction and training. While COSHH and supporting HSE guidance sets out in broad terms what that training should cover, they leave it to the employer to strike a balance between providing sufficient information for an employee to carry out their work safely and providing too much information that may be overburdening and confusing.

This diisocyanate regulation takes a different approach and sets out a specific syllabus that the training must cover and also requires that it is renewed every 5 years.

Safe use of diisocyanates general, intermediate and advanced training modules have now been added to the e-learning courses available to users of PIB’s xCenta, our online risk management software.

What training is required?

Exactly what level of training is required will depend on the way the substance is used:

• General training is required for all industrial and professional use of diisocyanates and substances / mixtures that contain diisocyanates.

• Intermediate training is also required for anyone who sprays substances / mixtures in a ventilated booth, or applies them by dipping, pouring, brush or roller, carries out cleaning and handling of waste materials, handles open containers (e.g. cans, bottles, barrels, troughs etc) at ambient temperatures, cuts or otherwise treats articles that are not fully cured, or similar uses.

• Advanced training is also required for more hazardous uses of these chemicals including spraying in the open air with only limited or natural ventilation, high energy spraying, carrying out maintenance and repair of equipment which uses these substances, handling open containers at temperatures over 45°C, use in foundries, handling incompletely cured articles and similar tasks.

Contact the experts:

To find out whether your employees need this training you should check whether substances you use contain diisocyanates. This information can be found in the safety data sheet for each product and may also be on product packaging. The regulations also require suppliers of relevant substances / mixtures to include a statement that “As from 24 August 2023 adequate training is required before industrial or professional use”.

For more information about xCenta speak  visit PIB Insurance website https://www.pib-riskmanagement.co.uk/xcenta

¹ Although the UK is no longer a member of the European Union, EU legislation as it applied to the UK on 31 December 2020 has been retained in UK law as a form of domestic legislation known as ‘retained EU legislation’. Full details of the legislation can be found on the Legislation.gov website at:  https://www.legislation.gov.uk/eur/2020/1149/2020-08-03