How can I know which training (level 1,2 or 3) may staff must have ?
On the platform you will be requested to answer some questions which will direct you to the right training path meaning Level I,II or III and you will also have the choice to follow your specific training web-based, virtual or F2F via entitled inhous trainers or trainer institutes.
Are we in charge to do trainings to all our workers or is it enough that managers/leaders are trained. E.g. production of repolymerized Diisocyanates,
Yes, everybody handling diisocyanates has to receive a training.
Who is responsible for paying the training the supplier or the customer?
It is in the responsibility of the employer for his employees.
How long will an online training - e. g. the module A+B+C for industrial users - take (closer to 30 min or to 3 hours)?
Depends on the format of training Face to Face or Virtual Classroom.
Does the use of Primers with brush / dauber refer to level B?
Yes level 2.
Passing the level 3 of the training includes level 1 and 2. Always the highest necessary level has to be passed, lower levels will be included?
Is using of PU foam cans to be defined as spraying? There fore training level C?
This is not a spray foam application.
Many ambient systems have exotherms during cure (often > 45oC) - are these considered ambient or high temp?
Above 45 C is considered high temperature.
How will it be for research groups working in several different segments - will training for each and every module need to be given?
Yes, there is a defined learning path for R & D personnel. Level 1 Training.
Products containing Monomedic DiIsocyanates were already labeled as carcinogenic. Hazard statement H351 etc.. in safety data sheet. Is there any additional evidence to make necessary a training on it? There is a label requirement for all products on the new REACH restriction by February 2022
In the case of products made with monomer free technology, is the training necessary?
If the content of Diisocyanates is less then 0,1% no training is required.
Can you please advice in the case of DIY retailers (free level service) the foams with >0,1% diiso, should be locked, and someone have to confirm if the end user have a valid training?
The REACH restriction on Diisocyanates applies to industry and professionals, but not to end consumers.
Is the training requirements only focussed for manufacturers of isocyanates or the industry who procure it and develop?
Every employee using or handling Diisocyanates that fall under the REACH regulation needs to participate in training.
Is this training relevant to the retail channels since professionals often times shop in the retail big box stores...
Training is not required for end consumers. If professionals buy products at retailors which are also accessible to end consumers no training is required.
What about our employees who carry out practical training, or employees from R&D or the production line. Are they to be trained too?
If they work with Diisocyanates, yes.
Does R&D personnel have to do the training? Are there modules for that?
Yes, there is a defined learning path for R & D personnel.
Article 3(23) of the REACH Regulation defines scientific research and development as “any scientific experimentation, analysis or chemical research carried out under controlled conditions in a volume less than one tonne per year”.
To further clarify the exemption (within Article 67(1) of the REACH Regulation, manufacture, placing on the market or use of a substance in scientific research and development (SRD) is exempted for restrictions), note that under the authorisation process the following Q&As (concerning the exemption in Article 56 for the use of Annex XIV substances in scientific research and development) has been provided. The same approach can be broadly considered as applicable to restrictions.
Scientific experimentation, analysis or chemical research in universities and secondary schools, conducted by students, may fall within the exemption, if they are carried out under controlled conditions, in a volume less than one tonne per year. In other words, if the volume of a substance used in scientific experimentation, analysis or chemical research is less than one tonne per year and it is used under controlled conditions, restrictions do not apply to that use.
Training can be provided in a traditional classroom environment, a virtual classroom (webinar) setting, or on-line. A learning portal is being built for on-line training, where employees can subscribe to a training that meets their needs. Suppliers of diisocyanate-containing products have established training courses that will be available in all EU languages.
It is the employer's responsibility to ensure that his workers are well educated. He must show that his staff were qualified upon request from a competent authority. Untrained employees are not allowed to use these products by their employers.
From February 24th, 2022on you will find a mandatory hint on the label of the product : “As from 24 August 2023 adequate training is required before industrial or professional use”. This phrase is not needed for products containing less than 0.1 percent diisocyanates; they are beyond the scope of the REACH legislation. See also this info.