Polyurethane Adhesives (PU)

REACH Restriction on Diisocyanates

Polyurethane (PU) adhesives and sealant products are versatile, innovative and safe. They are used in a wide variety of applications in construction, packaging, automotive, furniture, engineering, maritime, transportation and many other sectors. PU products are made by the reaction of diisocyanates and polyols. Because polyurethane chemistry is versatile, specialty adhesives and sealants can be produced with a wide range of chemical and physical properties. Polyurethane adhesives are used in shoe assembly, automotive interiors, windscreen bonding and textile lamination. Conveyor belts are generally sealed using polyurethane adhesives and polyurethane binders are mixed with wood chips to form chipboard. Polyurethane sealants are used in road repair, plumbing, construction and anywhere a high-strength, water-resistant seal is required. Polyurethane sealants provide excellent stress recovery to retain shape after bending or stretching, fast cure rates and even adhesion to unprimed concrete. Polyurethane adhesives and sealants can also be painted to match surrounding surfaces, though some binders cannot be painted.

What are Diisocyanates?

Since the late 1940s, diisocyanates, a family comprising versatile chemical building blocks, have been used to make polyurethane products such as rigid and flexible foams, coatings, adhesives, sealants and elastomers (CASE). Most of the products we rely on every day are developed because of diisocyanates. Diisocyanates used in polyurethane production are divided into two types: aromatic diisocyanates and aliphatic diisocyanates. There are two main aromatic diisocyanates: Toluene Diisocyanate (TDI) and Methylene Diphenyl Diisocyanate (MDI).

TDI is primarily used in the production of flexible foams.

*MDI, the second type of Diisocyanates (DII), comes in two forms; pure MDI and polymeric MDI (PMDI). • Pure MDI is used in the production of various polyurethane products such as coatings, adhesives, sealants and elastomers (CASE), such as paints, adhesives and weather-resistant materials. • PMDI is a versatile product used to produce a wide range of rigid, flexible, semi-rigid and polyisocyanurate and thermoset foams.

What Does a REACH Restriction Mean?

The REACH restriction on diisocyanates was adopted on 4 February 2020 during the REACH Committee and published on 4 August 2020. The restriction introduces new minimum training requirements for workers using diisocyanates and mixtures containing diisocyanates. The transition period during which the sector must prepare for training requirements is 3 years from the date of publication in the official European Journal and is effective from 24 August 2020. This means that all employees involved with products falling within the scope must be trained by 24 August 2023. This will apply to all professional and industrial users of products with total monomeric diisocyanate concentration >0.1%. Personnel must be trained and certified in how to safely use diisocyanate-containing products by 24 August 2023. Additionally, such products must carry a phrase on their labels from 24 February 2022 indicating the training requirement. Labels will contain the following information: "Adequate training required before industrial or professional use from 24 August 2023." FEICA (Association of the European Adhesive & Sealant Industry), in coordination with ISOPA (European Diisocyanate & Polyol Producers Association) and ALIPA (European Aliphatic Isocyanates Producer Association), which are industry associations of diisocyanate producers, is preparing training materials for use by its members and users of adhesives or sealants. These training materials are expected to be made available in February 2022 to ensure that all PU product users are trained and certified by 24 August 2023.

Scope of the Restriction

Under the New Restriction applicable in European Union member states, diisocyanate suppliers shall ensure that the recipient is provided with training materials and courses in the official language(s) of the Member State(s) to which the substance(s) or mixture(s) are supplied. The training will take into account the authenticity of the supplied products, including composition, packaging and design. • Training shall be conducted as classroom training/virtual classroom training, by a consultant or public authorities or as online training; • Training may be conducted through accredited trainers; • The user of diisocyanates – the user's employer or self-employed person – must document the completion of training; • Each employee must receive training every five years, with content and duration depending on the use of diisocyanates in connection with their specific task; • The transition period during which the industry must prepare for training requirements is 3 years from the date of publication in the official European Journal (24 August 2023); • Training must comply with provisions established by the relevant Member State in which the user operates. Member States may continue to apply their own requirements provided that the minimum requirements of the Restriction are met. • Training may be conducted in various forms, including off-site/on-site training courses, e-learning, and integration of training into product presentations; • Member States must report on the established training requirements, the number of reported cases of occupational asthma and occupational respiratory and skin diseases, any national occupational exposure limits and information on enforcement activities. Member companies of ISOPA and ALIPA and relevant downstream user trade associations are working together to develop the necessary training materials that will be available as soon as possible. Training Programme Diisocyanate producers have invested in the development of a comprehensive training materials package that we are preparing to make available following the entry into force of the REACH Restriction. ISOPA and ALIPA will work to educate the value chain on training requirements and the availability of training materials. FEICA will also work with Member States to ensure that training materials meet expectations and promote a harmonized approach across the EU.   FEICA plans to make online training available for ease of use. Additionally, the material will be made available for individual classroom training. It will be mandatory to have a certificate demonstrating participation in training, including a final examination for all professional and industrial users applying the product. The accepted legal text requires that training be provided by an Occupational Health and Safety specialist. Employers must keep records of training provided to their employees. Member States may add additional requirements beyond those defined in the REACH restriction. Further clarification is needed on how training will be implemented in each Member State.

Frequently Asked Questions *

Are diisocyanates safe? Like any substance, the use of diisocyanates is safe when chemicals are handled according to relevant risk management and safety measures. It is also important to emphasize that finished products contain virtually no diisocyanates. Diisocyanates are used only as reactive chemicals; they react with polyol to form the PU product and are consumed during the reaction. *What is respiratory sensitization? Sensitization means that after exposure, a person may become allergic to the substance. If sensitized, each time the person has renewed contact with the substance (even at very low concentrations), they may have a high allergic reaction leading to respiratory effects (e.g. asthma). Most individuals with asthma associated with diisocyanates show partial or complete recovery after exposure ceases. *I am a dealer/distributor. What do I need to do? Pass on the information you receive from your product supplier to your customers. *What about PU products for consumer use? The new regulation applies only to professionals and industry. A separate restriction for consumer use came into force a few years ago. *When will this regulation come into force? The new regulation was adopted on 4 August 2020 and came into force on 24 August 2020; this means that all PU product users must be trained and certified by 24 August 2023. *When should I update my packaging label? Legal requirements must appear on packaging from 24 February 2022. *Will PU adhesives and sealant products remain on the market? The restriction is not intended to limit product availability, but to prevent unsafe handling of diisocyanates. PU adhesives and sealants will be widely available because of their unique properties in many applications.

Sources: https://www.feica.eu/information-center/latest-news/a-safefuture-for-polyurethane-products https://app.croneri.co.uk/feature-articles/diisocyanates-andforthcoming-training-requirements?product=133%5D http://www.safeusediisocyanates.eu/diisocyanates-reach https://dii.americanchemistry.com/Diisocyanates-Explained/ https://polyurethane.americanchemistry.com/CASE/

  Prepared by: B. Serhat Cengiz