The EU Commission has published Regulation 2020/1449 in the Official Journal of the European Union and modified Annex XVII of REACH, which treats the limitations on diisocyanates. The Regulation took effect on August 24.
According to Paragraph 1, diisocyanates may not be used industrially or commercially as a chemical or an ingredient in other chemicals and mixtures in an individual or combined concentration of 0.1% by weight or more after August 24, 2023. Unless, the employer or self-employed ensures that industrial or professional user(s) have successfully completed training on the safe use of diisocyanates prior to the use of the substance(s) or mixture(s).
And according to Paragraph 2 of the Annex, diisocyanates (in the concentrations described in Paragraph 1) may not be marketed industrially or commercially as a chemical or an ingredient in other chemicals and mixtures after February 24, 2022. Unless, the supplier ensures that the recipient of the substance(s) or mixture(s) is provided with information on the requirements referred to in point (b) of paragraph 1 and the following statement is placed on the packaging, in a manner that is visibly distinct from the rest of the label information: “As from 24 August 2023 adequate training is required before industrial or professional use”.
Training must be repeated every four years.
The reason for the restrictions is the increase in work-related illnesses in people who deal with diisocyanates. The substance irritates the skin and, when inhaled, the respiratory system. According to information provided by the German Federal Institute of Occupational Safety and Health (Bundesanstalt für Arbeitsschutz und Arbeitsmedizin: BAuA), approximately 5,000 people develop asthma from their work because they come into contact with diisocyanates. See our posting: Restricts the Use of Diisocyanates.
The restrictions apply primarily to handling basic diisocyanates like MDI (methylene diphenyl diisocyanate), TDI (toluene diisocyanate), or HDI (hexamethylene diisocyanate). They also cover uses of two-component polyurethane (PU) systems and PU prepolymers because these products have a concentration of diisocyanate monomer greater than 0.1% by weight.
Products made of polyurethane hard form have developed a reputation as high-performance insulating chemicals. Between 2005 and 2018, their share of the entire insulation market rose from 4 to 10%. According to information provided by the Industrial Association for Polyurethane Rigid Foam (German only), the industry employed around 190,000 persons.
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