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Adrian Robinson, Managing Director, PIB Risk Management reminds business owners that any employees working with di-isocyanates are required to have completed specific training by 24th August 2023.
Under the regulations1, anyone whose work involves use of di-isocyanates either on their own or where the chemical is part of another substance or mixture (except when in very low concentrations), is required to have completed specific training.
Di-isocyanates are a family of chemicals that can be found in many applications including paints, adhesives, spray foams, sealants, inks and are used in the manufacture of certain rigid and flexible foams. Within the automotive sector, they can be found in paints, coatings and some glues.
The di-isocyanate regulation takes a different approach from the Control of Substances Hazardous to Health (COSHH) Regulations. Where COSHH requires employers to provide suitable and sufficient information, instruction and training, the new regulation sets out a specific syllabus that the training must cover and also requires that training is renewed every 5 years.
The regulations also require suppliers of relevant substances/mixtures to include a statement that “As from 24 August 2023 adequate training is required before industrial or professional use”.
What training is required?
Exactly what level of training is required will depend on the way the substance is used:
General training for all industrial and professional use of di-isocyanates and substances/mixtures that contain di-isocyanates.
Intermediate training for anyone who sprays substances/mixtures in a ventilated booth, or applies them by dipping, pouring, brush or roller, carries out cleaning and handling of waste materials, or handles open containers at ambient temperatures.
Advanced training for more hazardous uses of these chemicals including spraying in the open air with only limited or natural ventilation, high energy spraying, carrying out maintenance and repair of equipment which uses these substances, or handling open containers at temperatures over 45°C.
To find out whether your employees need this training you should check whether substances you use contain di-isocyanates. This information can be found in the safety data sheet for each product and may also be on product packaging.
For further guidance on the regulations or the level of training required, please contact Adrian Robinson:
Tel: 07753 984433
1 Although the UK is no longer a member of the European Union, EU legislation as it applied to the UK on 31 December 2020 has been retained in UK law as a form of domestic legislation known as ‘retained EU legislation’. Full details of the legislation can be found on the Legislation.gov website at: https://www.legislation.gov.uk/eur/2020/1149/2020-08-03