Polyurethane products are widely used in manufacturing, construction, maintenance and assembly. Some adhesives, foams, coatings, sealants and reactive systems may contain diisocyanates, which are important polyurethane raw materials but can also create significant occupational health risks if exposure is not properly controlled.
For industrial and professional use in the EU, the key legal reference is Commission Regulation (EU) 2020/1149, which added Entry 74 on diisocyanates to Annex XVII of REACH. Since 24 August 2023, products containing diisocyanates at a combined concentration of 0.1% by weight or more may only be used industrially or professionally if the user has successfully completed the required training before use.
Key takeaways
- The relevant EU restriction is Commission Regulation (EU) 2020/1149.
- The 0.1% threshold does not mean an automatic ban. At or above this concentration, industrial and professional users must complete appropriate training before use.
- The training requirement has applied since 24 August 2023.
- The required training level depends on the way the product is handled and the expected skin or inhalation exposure.
- The employer or self-employed user must document successful completion of training.
- Training must be renewed at least every five years.
- Product-specific safety measures must always be based on the current label, Safety Data Sheet (SDS), workplace risk assessment and the actual application method.
What are diisocyanates and where can they be found?
Diisocyanates are reactive substances used in the manufacture of many polyurethane materials. Depending on the formulation, they may be present in products such as:
- polyurethane adhesives,
- one- and two-component PU foams,
- protective coatings,
- elastomer systems,
- some sealants and reactive resins.
Not every polyurethane product is automatically subject to the REACH training requirement. The decisive factors are the concentration of diisocyanates in the substance or mixture and whether the product is being used in an industrial or professional context.
What changed under REACH?
Commission Regulation (EU) 2020/1149 amended Annex XVII to REACH by introducing Entry 74 for diisocyanates. The restriction covers diisocyanates on their own, as constituents of other substances, and in mixtures for industrial and professional uses.
| Requirement | What it means in practice |
|---|---|
| 24 February 2022 | Products placed on the market for industrial or professional use at or above the 0.1% threshold must meet the supply and labelling conditions set out in Entry 74. |
| 24 August 2023 | Industrial or professional users must have successfully completed the required training before using products covered by the restriction. |
| 0.1% by weight | The threshold applies to diisocyanates individually and in combination. |
| Training documentation | The employer or self-employed user must document successful completion of the training. |
| Renewal | Training must be renewed at least every five years. |
Who needs diisocyanate training?
For the purpose of REACH Entry 74, an industrial or professional user includes a worker or self-employed person who handles diisocyanates, a substance containing them, or a mixture containing them, as well as a person supervising those tasks.
Where the combined diisocyanate concentration is 0.1% by weight or more, the employer or self-employed user must ensure that the affected person has successfully completed the required training before using the product.
If the concentration is below 0.1%, this specific REACH training condition does not apply. That does not remove other obligations arising from the SDS, CLP classification, occupational exposure rules or workplace risk assessment.
What level of training is required?
The regulation does not define one identical course for every application. It sets a minimum general level and additional content for uses associated with greater dermal or inhalation exposure.
| Training level | Typical situations covered by the regulation | Examples of subjects |
|---|---|---|
| General training | Required for all industrial and professional uses covered by the restriction. | Diisocyanate chemistry, toxicity hazards, exposure routes, sensitisation, hygiene, PPE, ventilation, cleaning, spills, waste and protection of bystanders. |
| Intermediate training | Examples include handling open mixtures at ambient temperature, roller or brush application, dipping, pouring, cleaning and waste, and comparable exposure scenarios. | Additional application-specific behaviour, handling, ventilation and exposure-control measures. |
| Advanced training | Examples include open handling of warm or hot formulations above 45 °C, spraying in open air or with limited ventilation, high-energy spraying and comparable higher-exposure uses. | More advanced exposure-control measures appropriate to the specific process. |
The training must be conducted by an occupational safety and health expert with appropriate competence. Suppliers must make training material and courses available in the official language or languages of the Member State where the product is supplied, and the training should take account of the characteristics of the products concerned.
Why is exposure to diisocyanates a health concern?
The restriction was introduced primarily because occupational exposure to diisocyanates can contribute to respiratory and dermal health effects, including sensitisation and occupational asthma. Exposure may occur through inhalation and skin contact, depending on the product and process.
Risk can change significantly with the application method. Spraying, heating, handling open mixtures or working with incompletely cured materials may create a different exposure profile from applying a closed cartridge system at room temperature.
How should products containing diisocyanates be handled safely?
There is no single PPE set or ventilation rule that is correct for every PU product. Safe use should be based on the current SDS, product label, workplace risk assessment and application method.
Control exposure at the source
- Use closed or lower-exposure application methods where technically possible.
- Provide suitable local extraction or general ventilation where required by the process and risk assessment.
- Avoid unnecessary heating, spraying or open handling if the process can be designed differently.
- Keep containers closed when they are not being used.
Select personal protective equipment from the SDS and risk assessment
The required glove material, eye or face protection and respiratory protective equipment depend on the specific formulation and exposure scenario. Do not select gloves or respirator filters solely from a generic blog recommendation. Check the current SDS, including glove compatibility and breakthrough information, and ensure respiratory protection is correctly selected, fitted and maintained where it is required.
Prevent secondary exposure
- Keep contaminated tools, wipes and work surfaces under control.
- Do not transfer contamination from gloves to handles, phones or shared equipment.
- Store workwear and contaminated materials according to site procedures.
- Protect other people who are not directly involved in the application.
What should be done in the event of exposure or a spill?
Emergency actions must follow the Safety Data Sheet for the specific product and the workplace emergency procedure. The team should know that procedure before an incident occurs.
- Skin contact: remove contaminated clothing as appropriate and follow the washing instructions in the SDS.
- Eye contact: rinse as directed by the SDS and obtain medical advice when required.
- Inhalation exposure: stop the exposure, move the affected person to fresh air if safe to do so, and follow the SDS and site medical procedure.
- Spill or leakage: isolate the area, prevent uncontrolled exposure and use the containment and clean-up method specified by the SDS and local procedure.
Storage and waste: follow the product documentation
Diisocyanate-containing products can differ substantially in storage temperature, moisture sensitivity, packaging and waste classification. For this reason, statements such as “always store in a cool, dry place away from heat” should not replace the manufacturer’s specific instructions.
In practice:
- store the product within the temperature range specified by the manufacturer,
- keep the original packaging correctly closed and protect it from incompatible conditions,
- control moisture exposure where required by the formulation,
- manage residues, contaminated packaging and clean-up waste according to the SDS and applicable waste rules.
Common mistakes in companies
- Treating every PU adhesive as an ordinary adhesive without checking the SDS or label.
- Assuming that 0.1% means a complete ban rather than a training threshold for industrial and professional use.
- Using outdated internal instructions.
- Completing a general course without checking whether the actual application requires intermediate or advanced training.
- Failing to document successful training or to plan the five-year renewal cycle.
- Selecting PPE by habit rather than from the SDS and risk assessment.
- Ignoring exposure created by spraying, heating, cleaning, waste handling or partially cured material.
- Having no written emergency procedure for spills or exposure.
A practical implementation checklist
- Inventory PU and reactive products used by the company.
- Check each current SDS and label for diisocyanates and the REACH training statement.
- Identify affected workers and supervisors.
- Classify the application method and determine the appropriate training level.
- Complete and document training before affected products are used.
- Verify engineering controls and PPE against the real process and SDS.
- Define procedures for application, cleaning, spills, exposure, storage and waste.
- Record the renewal date so training is repeated at least every five years.
- Reassess the process when the product, application method, temperature, equipment or ventilation changes.
FAQ: diisocyanates and PU products
Does every polyurethane product require diisocyanate training?
No. The REACH Entry 74 training requirement is linked to the concentration of diisocyanates and to industrial or professional use. Check the current label and SDS for the exact product.
What is the relevant concentration threshold?
The restriction uses a threshold of 0.1% by weight for diisocyanates individually and in combination.
Does 0.1% mean that the product is banned?
No. For industrial and professional uses at or above the threshold, use is permitted when the employer or self-employed person ensures that users have successfully completed the required training before use.
Since when has the training requirement applied?
Since 24 August 2023.
How often must the training be renewed?
The regulation requires renewal at least every five years.
Can the same basic course cover every application?
Not necessarily. The regulation requires additional training content for application methods associated with higher exposure, including certain open handling, spraying, heated formulations and comparable tasks.
Who is responsible for documenting the training?
The employer or self-employed user must document successful completion of the required training.
What should determine the PPE used?
The current SDS, workplace risk assessment and actual process conditions. Generic glove or respirator recommendations should not replace product-specific safety information.
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