Health and Safety Bulletin (August/2023)
Training requirements for diisocyanates under UK REACH regs
As of 24 August 2023, training is required for professional and industrial users of
polyurethane adhesives and sealant products within the EU and UK.
Suppliers must ensure that training relevant to the particular products they are supplying is
available, but suppliers do not necessarily need to deliver or pay for the training themselves.
The legal duty remains on employers to ensure that all users have successfully completed the
required training before using the substance.
The training requirements for diisocyanates comes from a restriction under UK REACH and
applies from 24th August 2023.
The diisocyanates restriction under EU REACH came into force before the end of the
implementation period (i.e. 31 December 2020) and therefore formed part of retained EU law
that applies in Great Britain (GB- England, Scotland and Wales) following the UK (fully)
leaving the EU.
This means that this restriction also applies under UK REACH. The conditions for the
diisocyanates restriction as it applies under UK REACH can be found under entry 74 of the
‘List of restrictions’, which can be accessed on HSE website here.
Training will need to be adequate, appropriate to the use of the substance (which includes any
specific circumstances as to where it is used, i.e., in Great Britain) and in line with the
restriction.
Training does not need to be done by a GB based company, it only needs to meet the training
requirements and be relevant for diisocyanates use in GB.
There is no requirement in the diisocyanates restriction for an accreditation or certification
scheme to be put in place for training users of the substance.
Any record that shows the user has successfully completed the required training before using
the substance will help demonstrate compliance. A certificate issued to the user after they
have successfully completed the required training is an example of this.
However, providing information, instruction and training is not a one-off exercise and should
be reviewed every 5 years and whenever significant changes are made to the type of work
carried out or to the work methods used.
Contact your chemical supplier to ensure that training relevant to the particular products they
are supplying is available
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Training requirements for diisocyanates under UK REACH regs