DIISOCYANATES: NEXT DEADLINE AUGUST 2023
Given the diffusion and extensive use of products containing diisocyanates in our sector, we deem it appropriate to recall that by 24 August 2023, users of these products must have attended a specific training course according to the type of activity.
With this in-depth analysis, we will see what the training obligations are and on whom they fall.
DUTIES OF REGULATION (EU) 2020/1149 ON TRAINING
Regulation (EU) 2020/1149 first of all placed restrictions, starting from 24 February 2022, on the marketing of diisocyanates as such or as constituents of other substances or in mixtures for industrial and professional uses.
08/24/2023 is the deadline to be able to use and handle all products that contain a monomer diisocyanate concentration higher than 0.1% (Regulation (EU) 2020/1149)
The Regulation also provides that “industrial and professional users”, who will continue to use diisocyanates in concentrations higher than 0.1% by weight for industrial and professional purposes, follow adequate training by 24 August 2023.
We recall that industrial and professional users are defined by Regulation (EU) 2020/1149 and are workers and self-employed workers who handle diisocyanates as such, as constituents of other substances or mixtures for industrial and professional uses or are in charge of supervising these tasks.
TRAINING ON THE USE OF DIISOCYANATES
Therefore, by 24 August 2023, all industrial and professional users must have successfully completed training on the safe use of diisocyanates in concentrations above 0.1% by weight in order to continue handling them.
The training must take into account the specificity of the products used, their composition, packaging and design and the teacher must be an expert in occupational health and safety, with skills acquired through relevant professional training.
The employer or self-employed person must ensure that industrial or professional users have successfully completed the training. Even the suppliers of diisocyanates, again for the provisions of Regulation (EU) 2020/1149, must ensure that the recipient of the substances or mixtures has the information on the training requirements by the industrial or professional user on the safe use of diisocyanates before their use.
TRAINING CONTENT
The training is structured on three levels and deals with topics that gradually become broader and more in-depth as the complexity of the work performed increases:
Basic training: it is aimed at workers who, in various ways, use diisocyanates (for industrial and professional uses) in concentrations higher than 0.1%.
Intermediate training: it is aimed at those who handle mixtures outdoors at room temperature (including tunnels for the production of foam); carry out spray applications in a ventilated booth, application with a roller, application with a brush, application by immersion or pouring; carry out mechanical treatments of not fully cured items that are no longer hot; carry out cleaning and waste; any other use with a similar exposure to the previous ones by dermal and/or inhalation.
Advanced training: aimed at those who manipulate incompletely reacted articles; foundry applications; maintenance and repairs for which access to equipment is required; outdoor handling of hot or boiling formulations (>45°C); spray application outdoors, with limited or exclusively natural ventilation and high pressure spray application; any other use with a similar exposure to the previous ones by dermal and/or inhalation.
DURATION AND FREQUENCY OF THE TRAINING
Regulation (EU) 2020/1149 has indicated that training must be renewed every five years but does not specify the duration of courses on diisocyanates.
