Isocyanates

On 4 August 2020, the European Union published the REACH Restriction on diisocyanates which introduced mandatory training requirements for workers using diisocyanates from 24 August 2023. The Restriction is set out in Annex XVII (74) to Regulation (EC) No 1907/2006 (REACH). 

Requirements: 

The Restriction establishes requirements for the use and placing on the market of diisocyanates as substances on their own, as a constituent in other substances or in mixtures for industrial and professional use(s) in concentrations above 0,1% by weight. The Restriction concerns all diisocyanates, aromatic and aliphatic, including substances, mixtures, polymers and prepolymers. Specifically, the Restriction establishes: 

• Minimum requirements for training to be provided to industrial and professional users without prejudice to stricter national obligations in the Member States. 
• Requirements for 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). 
• Obligation to include information on training requirements on the packaging by suppliers of diisocyanates by 24 February 2022. 
• Mandatory documentation by the employer or self-employed on the successful completion of the training, which must be renewed at least every five years. 
• Obligation for Member States to report on progress and impact of the Restriction. 

This Restriction refers to mandatory training in Europe, not on restricting products and/or applications. Outside of Europe, this EU Restriction does not apply, but the training content is relevant, meaning if interested, diisocyanates users outside of Europe can access the content. The legal text foresees three different levels of training (general, intermediate, and advanced) depending on the tasks done by employees. 

In Europe, training is available in all member state languages at:

www.safeusediisocyanates.eu

Outside the EU, training is available at:

https://safeusediisocyanates.com/

On 13th March 2024, the European Parliament and Council officially adopted new exposure limit values for diisocyanates: Directive (EU) 2024/869. This new Directive amended Directive 2004/37/EC of the European Parliament and of the Council and Council Directive 98/24/EC with regards the limit values for lead and its inorganic compounds and for diisocyanates. The Directive (EU) 2024/869 comes in addition to the already established mandatory training requirements for diisocyanates of 0.1% or higher by August 24, 2023, as stipulated in Annex XVII (74) to Regulation (EC) No 1907/2006 (REACH). 

What are Occupational Exposure Limits (OELs)? 

Occupational exposure limits (OELs) are regulatory values which indicate levels of exposure that are considered to be safe (health-based) for a chemical substance in the air of a workplace (Ref: Occupational exposure limits - ECHA) 

New Limit Values and Timelines: 

The EU binding OELs for Diisocyanates are being introduced in a two-step approach: a transitional limit until 2028, and a final limit thereafter: 

1. Transitional OELs (until December 31, 2028): 

Member States were required to transpose the Directive into national law by 9 April 2026 and bring into force appropriate laws to ensure compliance with the values set out below. 

• STEL: 20 μg NCO/m³ (≈5.8ppb) (0.02mg NCO/m³) (15-minute short-term value) 
• TWA: 10 µg NCO / m³ (≈3ppb) (0.01 mg NCO/m³) (8-hr time-weighted shift average value) 

The transition period will provide valuable time to reinforce these values at all levels of the polyurethane supply chain. 

2. Final OELs (from January 1, 2029): 

Below stated values should be fully adopted starting January 1, 2029: 

• TWA: 6 µg NCO / m³ (≈1.7ppb) (0.006 mg NCO/m³) (8-hr time-weighted shift average value) 
• STEL: 12μg NCO/m³ (≈3.5ppb) (0.012 mg NCO/m³) (15-minute short-term value) 

These new limits are intended to create legally binding, harmonized rules across all EU Member States. Employers are required to take measures to ensure that workers are not exposed to concentrations above these limits. Ensure that your organization reviews these new OEL requirements and plans compliance accordingly. 

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