The move, which comes under the EU’s REACH (Registration, Evaluation Authorisation and Restriction of Chemicals) programme aims to further improve safety behaviour of the workforce who handle di isocyanates in the European Union.
It was motivated by concerns within the German authorities that while industrial hygiene in the polyurethane sector has undertaken for decades voluntary product stewardship programmes with significant success there are still cases of occupational diseases.
Industry is strongly committed to safety at the workplace and therefore cooperates with the authorities, stressed Palmersheim. He added that the regulation is at an early stage of development.
The next step is to develop a concept outlining how it could work in practice for industrial users and professional users in all polyurethane sectors, he said.
In parallel, work is being done to try and identify uses which are intrinsically safe as product/use combinations. These exemptions need to be “defined as a kind of norm,” Palmersheim added.
German authorities have to provide the final dossier to the European Chemicals Agency (ECHA), which administers REACH, by October 2016, said Palmersheim. He added that at the earliest, it could become an annex to REACH “two or three 3 years” after that.
But the regulation would have to clear a number of hurdles before that can happen. The proposal will have to pass through a number of ECHA committees before it is presented to the European Commission.
During this process Member States will provide their input as well, especially as workplace safety is in the sovereignty of Member States. The European Commission will also be involved through the Directorates General for DG Growth and DG Employment, Palmersheim said.
At this stage it looks likely that training will be tailor-made to different roles within companies: “A manager who passes a lab or production site once a week, doesn’t need the same training as someone working eight hours/day at a foaming station,” Palmersheim explained.
Professional users in areas such as spray foam insulation, construction and automotive refinish, for example, could be a difficult group to reach, and innovative approaches could be needed, he added. “Webinars and e-learning could be used. These might be the smallest of SMEs down to 1,2 or 3 people, we are examining how to develop a process to train a large number of small groups like this,” he added.
It is likely that they will need to have a kind of a central institute they can go to once every four years to get a certificate of training, after an 8-hour course, Palmersheim suggested.
Palmersheim added that the process is quite complex, but there are many other substances that are the focus of the authorities and if this becomes a success story it might be of use for other materials.