Currently, one of the biggest talking points within the adhesives industry –spanning producers, suppliers, and applicators of industrial adhesives – is REACH Annex XVII. This EU-wide legislation is being updated to address a number of hazards and risks, one of which is the respiratory and dermal sensitization that can be caused by exposure to products containing diisocyanates, such as polyurethane (PUR) hot melt adhesives.
The focus of this restriction is ensuring that training is carried out before use – protecting operators from risks by giving them adequate training to help them avoid exposure.
At Henkel, as a leading supplier of PUR adhesives, we have naturally heard many questions about the new training requirement. How will it be implemented? What will the content of the training programs be? Does this training have to take place in-person, or can it be done via e-learning? What is the timeline for completing the training?
Of course, we’re working directly with customers to answer these questions and make sure they are prepared on a case-by-case basis. But hopefully in this article we can give some background, address the framework of the legislation, and offer a general outline of how to comply with the latest update to REACH Annex XVII.
REACH’s Role and Goals
REACH (Registration, Evaluation, Authorization and Restriction of Chemicals) is a European Union Regulation, whose main purpose is the protection of human health and environment against the risk that can be posed by certain chemicals. Its remit covers all chemical substances – not just for industrial processes, but also things we encounter as end-users, such as cleaning products, paints, furniture, electrical appliances, and so on.
As a result, the REACH regulation has an impact on a huge number of companies across Europe, all of which have to comply with its requirements. For a company like Henkel, that means identifying and managing the risks that are linked to the substances we manufacture and market in the EU. We need to ensure these substances are safely used, that we communicate safety information to end-users of our products, and that we substitute the most hazardous products with more suitable alternatives. In addition, we need to monitor our portfolio on an ongoing basis, to ensure we continue to meet new registration requirements – for example if we increase the volume we use of a particular chemical, or when more chemicals are added to ECHA’s Substances of Very High Concern list.
The good news is, at Henkel we have an entire team dedicated to this. Our experts maintain a close, constantly evolving knowledge of the regulatory landscape – a benefit we can pass on to customers.
What Does the New Legislation Mean?
There are two main aspects to Annex XVII, each with its own deadline for compliance.
Firstly, a certain level of operator training and certification must be completed before products containing diisocyanates can be safely handled. This needs to happen by 24 August 2023 for all professional and industrial users of any product containing more than 0.1% concentration of diisocyanate.
The other aspect is that, since February 2022, adhesives suppliers must ensure that the labels on impacted products include a phrase informing recipients that training must be provided before they use the product.
So, how do industrial users implement the required training? The good news is, they won’t need to produce the training materials themselves. A consortium of downstream user associations including FEICA – the industry body for adhesives and sealants – and diisocyanate manufacturers’ associations have jointly prepared training materials that can be used by professional entities within the adhesive and sealant industry. Training modules in English and German have been issued already and all other European languages are expected to become available by the end of May 2022.
The training takes a modular form, with organizations selecting modules depending on their professional or industrial use case and potential risk of exposure. The training has been made available in the form of e-learning, and is free of charge for our customers via a voucher code, which makes it easier – though some EU member states and companies may decide to adapt the materials for a classroom format.
The classroom training itself needs to be provided by an expert, whereas the e-learning already fulfills this requirement (but certain EU member states might not accept it). The employer has to keep records of the training and those who participated in it. At the end of the training, there is a mandatory final exam, followed by certification, keeping in mind that the training has to be repeated every 5 years.
How is Henkel Helping Ensure Compliance with the New Requirements?
Firstly, we have identified all the products that are ‘in scope’ and ensured that new labels were applied in a timely manner. We are also making plans to roll out the training via e-learning in our plants and to all employees exposed to diisocyanate-containing adhesives and sealants.
For our customers, we have created direct communications materials to help answer some of the most common questions. This is regularly updated as we receive more information on the training. We’ve also provided webinars to our internal stakeholders and even some customers who have asked for further details. Different customers have different needs, and therefore we provide flexibility to customers, between implementing the training requirements and discussing potential alternatives.
As the deadline approaches, we will continue to answer requests and queries, ensuring customers know what actions to take and are backed by needed support. Regulatory changes will always be a part of life as an adhesives manufacturer. We maintain the expertise and network to ensure a continued safe and successful work environment whenever the new regulations are introduced, and to help our customers do the same.