My understanding about the recently introduced mandatory training for users of diisocyanates is that this is a requirement under EU-REACH, that has not been replicated in UK-REACH, and therefore does not apply (as a legal requirement) in Great Britain.

However, I have received a legislation update from a well-known provider of such things that describes the new requirements without any mention of where they are applicable to, giving the appearance that they apply to the UK.  It contrasts the new requirements, which are prescriptive as to the content of the training, with the COSHH Regulations, which are more general.  So clearly the authors have a UK context in mind.  Disappointingly, it does not name the legislation that has created this requirement, referring to it only as "the regulations".

Now before I write to the provider with my feedback, have I actually got this right and they have published something misleading, or have I got it wrong?

I am also confused by an article on the Environmental Protection (Plastic Plates etc. and Polystyrene Containers etc.) (England) Regs which are described in the same document.  The description states that "Businesses will need to have a strong plastic recycling plan in place".  I have looked at the text of these regs and it is all about banning the supply of certain single-use plastic items to end-users, seemingly having nothing to say about responsibilities to recycle.

Again, am I missing something here?

I would really love to hear that I have got both of these wrong so that I can trust the information source in future!

The REACH requirement is derived from EU 2020/1149 (3rd August 2020) which pre-dates the split.

This is the same legislation that required a warning be applied to labelling of products containing isocyanates at >0.1% w/w from 24th February 2022 stating training would be required from 24th August 2023.

Unlike the record of training for Professional users of Dichloromethane paint strippers the HSE have indicated no interest in monitoring the actual content of isocyanate training.

Nearly all suppliers of isocyanate mixtures (coatings, adhesives etc.) have reverted to an e-learning platform operated by ISOPA and ALIPA https://www.safeusediisocyanates.eu/

CAUTION: ensure you buy the vouchers first - they have minimal back room staff to deal with queries on a quick turn around

Originally Posted by: Roundtuit

The REACH requirement is derived from EU 2020/1149 (3rd August 2020) which pre-dates the split.

This is the same legislation that required a warning be applied to labelling of products containing isocyanates at >0.1% w/w from 24th February 2022 stating training would be required from 24th August 2023.

Unlike the record of training for Professional users of Dichloromethane paint strippers the HSE have indicated no interest in monitoring the actual content of isocyanate training.

Nearly all suppliers of isocyanate mixtures (coatings, adhesives etc.) have reverted to an e-learning platform operated by ISOPA and ALIPA https://www.safeusediisocyanates.eu/ retro bowl

CAUTION: ensure you buy the vouchers first - they have minimal back room staff to deal with queries on a quick turn around

Before reaching out to the provider, you may want to gather additional evidence to support your concerns, such as referring to official government sources or seeking clarification from legal experts familiar with the specific regulations in question

timothyferris REPORTED