v. Jörg Palmersheim, Secretary General ISOPA

1. PUR-SEKTIONENS
ÅRSMØDE
OG
TEMADAG
Sinatur Hotel, Storebælt, Nyborg
Jörg Palmersheim – Secretary General ISOPA
5/23/2017 Restriction Dossier on Diisocyanates 1
ISOPA’s perspektiver på restriktionsprojektet

2. ISOPA Member Companies
5/23/2017 Restriction Dossier on Diisocyanates 2

3. ALIPA Member Companies
Coating
Industry
Adhesives
Industry
Elastomers
Industry
5/23/2017 Restriction Dossier on Diisocyanates 3

4. June
2013
German REACH CA (BAuA) intending to propose TDI for adding to the
candidate list for eventual authorisation. CA investigation on expert level
started. Positive evaluation of TDI by Polish CA.
Nov
2013
German REACH CA concluded change of position and started to develop
opinion of RMOA as the appropriate regulatory action.
Oct
2016
Start of the official legislatory process under REACH for restriction proposals
May
2014
ISOPA & ALIPA decided on a joint project of both associations (PSSF) and
decided to involve Downstream Associations (PU Exchange Panel) for
efficient facilitation of the cross value chain activities.
Oct
2015
ECHA published ROI of German CA to officially start the work on the dossier.
Chronology of discussion on Diisocyanates
in Germany
5/23/2017 Restriction Dossier on Diisocyanates 4
March
2017
Dossier has been called conform by ECHA

5. Development
Restriction Dossier
12 months
Legislative Process
18-24 Monate
Enforce-
ment
2016 - 2018/19Oct 15 – Oct 16
2019/
2020
expected timeline
Legislative process within REACH (assumption)
1. Dossier conformity
2. Public Consultation:
22. März – 22. Sept 2017
3. Assessment and improvement of the dossier by ECHA comittees 2017
4. Final dossier drafting and decision by EU COM, EU Parliament and
Council in 2018/2019
5. Publication of the final restriction
(addtitive to Annex XVII, REACH Regulation)
in official journal of EU 2018/2019
Public Consultation
22.3. – 22.9.2017
Mai 2017 │ REACH Restriktion & Diisocyanate 5
Timeline Regulatory Process

6. Possible timeline
66/25/2015 Jörg Palmersheim – SG ISOPA & ALIPA
1 Jan
Legislation
would start
Proposed Transition Period
incl Training Material, certified
trainers, training institute
infrastructure
and all workers trained
Jan 2020 – Dec 2026
2017
31 Dec
All workers
trained
1 Jan
Legislation
enforced
2020 2026 2027

7. • Which substances are affected ?
The cumulative concentration of monomeric Diisocyanate in the
substance or the mixture is more than 0,1 % by weight.
• Who is affected ?
Industrial and Professional users of diisocyanates or mixtures
containing diisocyanates
• What is the nature of the restriction ?
The proposal limits the use of diisocyanates in industrial and
professional applications to those cases where a combination of
technical and organizational measure as well as a minimum
standardized training package have been implemented
Proposal for restriction on Diisocyanates
5/23/2017 Restriction Dossier on Diisocyanates 7

8. • Co-operate with BAuA to enable BAuA to develop a
pragmatic, credible and reliable mandatory product
stewardship program (as REACH restriction) with exemptions
where appropriate and applicable.
• Objective to minimize additional and unnecessary burdens for
the industry
• Advocacy efforts bundled under the umbrella of the project
“Product Stewardship for a sustainable future” of ISOPA &
ALIPA.
• Involve Downstream Associations by moderating a PU
exchange panel
Industry advocacy strategy
5/23/2017 Restriction Dossier on Diisocyanates 8

9. Note: There are industry sector without associations or diisocyanate users which are not organized
PU Exchange Panel
German and European Associations teamed up
5/23/2017 Restriction Dossier on Diisocyanates 9

10. Measures and Training
5/23/2017 Restriction Dossier on Diisocyanates 10
Single Task at the
workplace
Dermal Exposure +
Inhalation Exposure
= Assessment
Measure Group
1,2 or 3
Route of Exposure Exposure Stage Probability of Exposure
Dermal Exposure
1 Potential skin contact rare, small areas and immediately
appropriately removed
e.g. splashes
2 Potential repeated short term skin contact (max 4*15 min per 8 hr
shift)
3 Potential repeated prolonged skin contact (more than 60 min per 8
hr shift)
Inhalation Exposure
1 Low vapour formation
2 Moderate vapour and/or aerosol formation
3 High vapour and/or aerosol formation

11. 11
Measure Group 1
 Loading/Unloading Trucks
 Pumping /Loading using closed systems
 Application of Sealants and adhesives
 Handling cold fibers and composite materials after
manufacturing
 Polyurethane operation with dedicated closed machinery, like
foaming, adhesives, sealants, elastomers
 Working in a laboratory
Training & Measures
5/23/2017 Restriction Dossier on Diisocyanates

12. 12
Measure Group 2
 Handling open mixtures at ambient temp. (incl. foam tunnels)
 Handling incompletely cured articles
(e.g. freshly cured, still warm)
 Spraying in a ventilated booth
 Application by roller or brush
 Application by dipping and pouring
 Handling oligomers after manufacturing
 Foundry applications
 Mechanical post treatment (e.g. cutting) of not fully cured
articles
 Cleaning and waste
 Maintenance and repair that needs access to equipment
 Change Management
Training & Measures
5/23/2017 Restriction Dossier on Diisocyanates

13. 13
Measure Group 3
 Open handling of warm or hot formulations (>45 C)
 Spraying in open air, with limited or only natural
ventilation (includes large industry working halls)
 Spraying with high energy (e.g. foams, elastomers)
Training & Measures
5/23/2017 Restriction Dossier on Diisocyanates

14. Measure Group 1
Training
(Workers)
Evaluation
Measure Group 3
Training
(Workers)
Measure Group 2
Training
(Workers)
Training
Content
MG1
Training
Content
MG2
Measure Group 1
Training
(Workers)
Training
Content
MG3
LEVEL 1 & 2 TRAINING
CONTENT
+ 8 h
Evaluation
Evaluation
The current proposal for training / to be repeated every 4 years
14
Training & Measures
Web based training
or 4 h F2F
+ 4 h
5/23/2017 Restriction Dossier on Diisocyanates

15.  Development of the training material by manufacturers of
diisocyantes in cooperation with Downstream sectors
 EU wide certification system
 Training can be provided
internally
external training institutes
authorities
e-learning or class room training
 Industrial users may use the train-the-trainer principle
 The training will be certified in each single member state
 The user has the obligation to ensure employees have been
trainined
Mai 2017 │ REACH Restriktion & Diisocyanate 15
Training & Measures
To do`s & open questions

16. 5/23/2017 Restriction Dossier on Diisocyanates 16
Thank you & Time for questions

17. External document disclaimer
While ISOPA and its members as well as ALIPA and its members
make every effort to present accurate and reliable information in
utmost good faith on the basis of the best information currently
available, it is to be relied upon at the user’s own risk. No
representations or warranties are made with regard to its
completeness, accuracy or reliability and no liability will be
accepted by ISOPA or ALIPA nor any company participating in
ISOPA and ALIPA for damages of any nature whatsoever resulting
from the use of or reliance on the information.
5/23/2017
Disclaimer
Restriction Dossier on Diisocyanates 17