Entry 74: Diisocyanates restricted under REACH

The European Union (EU) has recently introduced a new restriction under the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) regulation for diisocyanates, which will come into effect on 24 August 2023 after a three-year transition period.The new restriction introduces minimum training requirements for workers handling diisocyanates and mixtures containing diisocyanates. The goal is to enhance and harmonize the level of protection of workers using diisocyanates across the EU.

Diisocyanates are essential building blocks of polyurethanes, a plastic material used in a multitude of everyday objects and applications. It can be tailored to be either rigid or flexible, and it is the material of choice for a broad range of end-user applications such as insulation (of buildings, refrigerators and freezers), adhesives, coatings, automotive parts, sportswear, bedding, and furniture. However, diisocyanates can cause occupational asthma among workers who deal with them. Therefore, this restriction is a very effective and efficient measure to enhance occupational health and safety.

The restriction on diisocyanates was proposed by the German Federal Institute for Occupational Safety and Health in 2016 and was reviewed by the European Chemicals Agency (ECHA), which found that mandatory training should also be an EU-wide risk management measure requirement to reduce occupational asthma cases among workers who deal with diisocyanates.

Condition of restriction

Diisocyanates, O = C=N-R-N = C=O, with R an aliphatic or aromatic hydrocarbon unit of unspecified length, shall not be used as substances on their own, as a constituent in other substances or in mixtures for industrial and professional use(s) after 24 August 2023, unless:

• a) The concentration of diisocyanates individually and in combination is less than 0,1 % by weight.
• b) 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).

Besides, beginning on February 24th, 2022, diisocyanates cannot be placed on the market as substances, constituents, or mixtures unless the concentration of diisocyanates individually or in combination is less than 0.1% by weight. Alternatively, suppliers can provide the recipient with information on the requirements outlined in point a). They must also include a statement on the packaging, which is clearly distinguishable from other labeling information, that reads: "As of August 24th, 2023, adequate training is required before industrial or professional use."

Training requirements

The restriction sets out minimum training requirements for industrial and professional users of diisocyanates and requires diisocyanate suppliers to provide training materials in the official language(s) of the Member State(s) where they supply the substance(s) or mixture(s).

It also mandates employers and self-employed workers to document the successful completion of the training, which must be renewed every five years. Moreover, the restriction requires Member States to report on the progress and impact of the restriction.