Diisocyanate training: the long arm of Reach

Reach is the comprehensive regulatory framework dealing with the management and control of all chemical substances made or brought into the European Union. Reach is an acronym standing for registration, evaluation, authorisation and restriction of chemicals, so it’s fitting that the acronym implies comprehensiveness. And Reach has counterparts in other territories as well, such as Türkiye’s KKDİK, which are necessary for importing to the EU, as well as for aligning and embedding industrial safety standards globally. But what do the latest updates to the Reach regulations mean for the urethanes industry?

Reach is already 16 years old, but its most recent update included a 2023 compliance deadline for anyone working with diisocyanates. In particular, Entry 74 to Annex XVII of Reach forbids the use of diisocyanates on their own, as a constituent of other substances or mixtures (for concentrations of 0.1% or more) for industrial and professional use after 24 August 2023 – unless the users have successfully completed training on the safe use of diisocyanates prior to the use of the substances or mixtures.

Have you completed 
your training?
If you’re diligent enough to read Urethanes Technology International, then the answer is probably that you have indeed completed all appropriate training, even if you’ve managed to completely avoid hearing about the 2023 deadline, because the new training is very much like the old training. This is partly because it was developed in consultation with industry stakeholders who already use diisocyanates: people who are well aware of the cumulative risk to respiratory health posed by industrial exposure to these chemicals. But, as we discuss in this article, there are at least two good reasons to update your training: ensuring best practice and normalising international compliance

Isopa, the European trade association for producers of diisocyanates and polyols, is also the European Commission’s non-profit instrument for providing training on the safe handling of these chemicals. Isopa launched a digital training platform in October 2021, with English-language training to help companies across the EU ensure compliance with the new updates to Reach. “There was no blueprint for this,” said Brieuc Lits, public affairs and communications officer at Isopa. Multilingual rollout began in earnest, with commoner languages such as German being available already at the end of 2021. Isopa’s small (four, full-time equivalent) team managed translation into 26 languages with the help of contract consultants, as well as professional and volunteer translators, over the following year and a half. So, it’s been a rather busy summer at Isopa in 2023 – and summers in the EU are not normally known for their industriousness. Indeed, there was a considerable surge in registration for Isopa’s platform in the weeks immediately prior to the August Reach deadline, thanks to newly available translations into the EU’s least-spoken languages – more on this from the perspective of Finland below. 

That the number of platform sign-ups has already exceeded a hundred thousand is remarkable given that, despite its status as an EU-wide law, there is no central database to monitor compliance with Reach, and even counties normally at the vanguard of legislative bureaucracy lack their own national databases. This is surprising because it’s individual nations that are the competent authorities charged with enforcing Reach, which means they will be the ones administering fines to companies and individuals that do not comply with it. Fines for violating Reach vary from state to state but are generally of the order of tens or hundreds of thousands of euros, with notable outliers being Belgium (€1.1m), Hungary (€2m) and Slovakia (maximum just under €100m) for administrative violations. Other possible sanctions include a ban on sales, withdrawal from the market and destruction of stock. Criminal violations attract harsher penalties, including up to four years in prison.
So, either there is a strong EU-wide expectation that the urethanes industry always does the right thing and can regulate itself, or we are in a lag phase while the industry completes rollout of training, and regulatory teeth begin to sharpen at national level. Irrespective of possible punitive measures ahead, each member state of the EU is obliged to report the number of workers trained within their territory to the European Commission, so they will have to start tracking numbers sooner or later.

Arnaud Duvielguerbigny, secretary general of PU Europe, the trade body for rigid foam manufacturers, explained the significance of Reach and Isopa’s platform is that there is now a formal tool available to people handling diisocyanates, whereas, previously, on-site training had been handled by in-house environmental health and safety experts. The new platform “raises the bar, setting common standards” for multinationals; this ensures quality consistency across territories and could lead to greater harmonisation within the EU and worldwide. 

What does this mean for 
flexible foamers?
From the perspective of PU Europe, this means Reach will not push manufacturers to change their recipes – although the chain of responsibility now starts with suppliers, which give guidance to formulators, which in turn give guidance to spray foamers. The days of making do with poor ventilation in people’s houses should soon be over. 

Damir Andrašek, communications officer at Europur and Euromoulders, which focus on flexible foams, added that most consumer products use MDI, which is subject to Reach restriction 56, requiring specific labelling and the provision of personal protective equipment (PPE) at the point of sale. Reach does not seem to have pushed foamers towards considering non-isocyanate polyurethanes.

The view from Finland
Companies in territories outside the EU, such as Russia, Ukraine and Türkiye, have already assisted in translating Isopa’s training materials into their local languages, even though they are not formally obligated to follow Reach. But let’s take a look within the EU to see how Reach is unfurling in Finland.

Eliisa Irpola is chief policy adviser, product safety, at the Chemical Industry Federation of Finland. Irpola said the Federation’s Reach-related work has so far mainly consisted of advocacy on the behalf of industry, checking Isopa’s Finnish translation, and discussion with authorities on the training in general. She suggested two corporate contacts who would have a clearer picture of things on the ground: Matti Junnila at Ravelast and Lilli Puntti at Kiilto.
The master-apprentice model of training that has been traditionally used in Finnish industry relied on experience and practical know-how, rather than institutional certification for knowledge validation and transmission. This means that, while managers may generally be highly educated, with master’s degrees in chemical engineering or management, and while they may have completed safety training and take safety extremely seriously, the diffusion of this knowledge through organisational channels to front-line workers has generally been behind the cutting edge of best practice.

Ravelast’s safety revolution
Finnish is a language with comparatively few speakers, so Isopa’s basic training – not the full range of 36 training options – was only available in Finnish just two weeks before the August Reach deadline. 

Junnila, a development manager at the company, explained that Ravelast had been monitoring the situation weekly and that managers had already completed training in English. Finland is a highly literate country where multilingualism is common and facility in English as the language of global popular culture is generally high. However, a significant portion of the 25-30 workers who handle diisocyanates at Ravelast do not speak English to a level sufficient to follow technical safety training; they needed it to be available in Finnish.

Junnila explained that having an international standard of safety training makes managers’ lives easier because the cultural change required to get everyone to the highest safety standards now carries the weight of European legislation. Even though managers at Ravelast had already completed the Isopa training in English, access to Finnish translation has added an additional level of institutional clout to their in-house directives. This has boosted worker safety because it has accelerated what Junnila calls the “cultural change” that has been going on in the industry since the respiratory risks of diisocyanates were first recognised.

Basic training is part of Ravelast onboarding, but now there is also a formal certification process. Ravelast’s suppliers are legally bound to ask whether they have completed the training, and the Finnish Safety and Chemicals Agency may also make checks in the future. Beyond formalising existing safety practices and building industry momentum away from generational bad habits, some new details have also filtered through thanks to Isopa’s training content. For example, did you know that the use of PPE provides an absolute limit on facial hair? When will hipsters catch a break?

Junnila credits Nantte Pennanen, sales director at Ravelast, as spearheading the adoption of better quality and management systems at Ravelast. In practice, this has included dealing with and reviewing all near-misses and other situations as they arise and drawing out implications and improvements continuously. A relatively flat organisational hierarchy enables quick decision-making and improvements, and Pennanen has also implemented a reward system for development suggestions and accident-free work. 

“Even a single accident can yield a high accident frequency, calculated relative to the number of absence days it causes,” said Pennanen. “In some years, the frequency had been nearly 300. So far in 2023, the frequency is zero, and we will continue to aim for that with continuous training and operational development.”

Kiilto leads the way
Lilli Puntti, head of product safety and sustainability at Kiilto, had a similar story of long-term preparedness. Updating information labels and training sales staff to understand what the safety information in the new labels means started two years ago. Puntti was one of the translators of the safety training materials, along with colleagues at paint companies Teknos and Tikkurila, which seems like a typically pragmatic Finnish solution to an information bottleneck. 

The thought of a “few months” of difficult translation work brings to mind the emblematic Finnish characteristic of sisu, often translated as “dogged determination”. Of course, opening up the flow of information during a regulatory transition is not just a matter of selfless public service; it also has the added benefit of positioning you as an authority in the field. Indeed, Puntti, as a certified Reach trainer, has already trained several hundred customers on-site and via Teams. This seems like a fantastic additional tool for customer relationship management and brand-building.

Puntti, too, recognised the cultural shift under way in industrial diisocyanate safety in Finland, although she noted people of all ages may bring outdated ideas and practices to the table, so, while the idea of a generational shift seems consistent with the master-apprentice training model, it’s important not to stereotype people by age. One powerful motivator for change is talking with workers and customers about how exposure risks are cumulative and how they don’t just affect them as individuals or their work colleagues. Puntti offered a stark warning: “If you don’t take care with diisocyanates, then you take it into your car or home to your family.”

Most of Kiilto’s employees were trained before the deadline, with just some exceptions due to summer holidays and sick leave. This means training all people in manufacturing, laboratories, warehouses, sales and leadership across six countries: more than 200 employees. Sales teams in different countries have been training via the platform in their local languages, with access coordinated by Puntti.

Editor’s note: Since the interview contained in this article was conducted, the number of trainees has risen significantly. Jörg Palmersheim, general secretary of Isopa, told the Polyurethanes Technical Conference in San Antonio, Texas, that “as of this morning, almost 560,000 people have been trained”.