Comments for Annex XV restriction report

Substance name: Diisocyanates

EC Number: -

CAS Number: -

Scope:

1. Shall not be used as substances on their own, as a constituent in other substances or in mixtures for industrial and professional uses, unless
a) the cumulative concentration of diisocyanates in the substance or mixture is less than 0.1 % by weight, or
b) the substance or mixture in the form in which it is supplied to the user, including the combination of such substance or mixture, its packaging and any application aid is placed on the market in accordance with paragraph 2b), or
c) the employer or self-employed worker ensures that measures and trainings are taken prior to the use of the substances or mixtures in accordance with the provisions described in Appendix 13[1] (Trainings and Measures).

Member States may implement or continue to apply own provisions for the use of these substances and mixtures as long as the minimum requirements of Appendix Trainings and Measures are met. The employer or self-employed worker shall document the compliance to the requirements of Appendix 13 (Trainings and Measures). Proof of successful completion of a training according to Appendix 13 (Trainings and Measures) shall be recognised in all other Member States.

2. Shall not be placed on the market as substances on their own, as a constituent in other substances or in mixtures for industrial and professional uses, unless
a) the cumulative concentration of diisocyanates in the substance or mixture is less than 0.1 % by weight, or
b) the substance or mixture in the form in which it is supplied to the user, including the combination of such substance or mixture, its packaging and any application aid is compliant with Appendix 12 (Exemptions), or
c) the supplier ensures that the recipient of the substance or mixture is provided with information according to paragraph 3.

3. For the purpose of 2c) manufacturers and importers of diisocyanates on their own or as a constituent in other substances and importers of mixtures containing diisocyanates shall develop a set of teaching material in accordance with the provisions of Appendix 13 (Trainings and Measures) in an official language of the Member State where the substance or mixture is placed on the market before placing the substance or mixture on the market. They shall ensure that training courses based on the training material are available to the recipients of such substances or mixtures. They shall review and update the training material after a maximum of 8 years, or without delay if new information, which may affect the risk management measures, becomes available and inform the recipients accordingly.

Natural or legal persons formulating mixtures containing diisocyanates within the EU shall provide necessary information for the development of the teaching material upon request of their substance suppliers. All downstream users may be consulted for the purpose of the development and update of the teaching material.

[1] The texts of “Appendix Trainings and Measures” and “Appendix Exemptions” are two separate documents. A short summary can be found in A.2.2. Additional information can be found in Appendix 5 to the dossier. The document on Appendix 13 attached to this proposal contains elements that should be included in the final legal text of the Appendix.

Before you fill in the form, read the Public Consultation Guidance and the specific Information Note
as they explain both the process and the proposal itself.

Link to the Public Consultation Guidance
Link to the Information Note

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All non-confidential comments will be made publicly available once a month during the duration of
the public consultation.

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SECTION III. Non-confidential comments

It is possible to provide both general comments on the Annex XV restriction report subject to this Public Consultation and answers to the specific questions posed. In both cases, it is necessary to provide supporting evidence to allow ECHA’s Committees to take your comments into account. It is important not to leave the submission of any socio-economic information until the public consultation on SEACs opinion but already submit relevant comments at this stage.

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B) Specific information requests

Below, specific information can be provided on:

SPECIFIC QUESTION 1: What transition period do you consider to be appropriate to implement the measures specified in the restriction proposal and why? Please mention potential priorities in terms of application area or geographic regions.
* COMPULSORY FIELDS

SPECIFIC QUESTION 2: What approaches (in addition to those already mentioned in the dossier) would you propose to communicate the requirements of the restriction through the supply chain, to effectively inform all levels of downstream users about their duties (including SMEs and self-employed practitioners)?
* COMPULSORY FIELDS

SPECIFIC QUESTION 3: Could you give examples of training methods in the area of occupational health and safety which have proven to be particularly effective? Could you provide information on how the effectiveness of these methods has been assessed?
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SPECIFIC QUESTION 4: Do you have an information on a case(s) where respiratory or skin isocyanate-related symptoms were observed with a product containing less than 0.1% diisocyanates? Please provide as detailed case information as possible.
* COMPULSORY FIELDS

SPECIFIC QUESTION 5: How would the proposed training program affect your company (we are particularly interested in how this affects SMEs or self-employed persons)?
  1. what would be the most important cost to your company from the proposed training program – the €-cost of training, loss of employee time, else?
  2. would the training program benefit your company in other ways besides potential improvements in worker health, such as improved productivity/working methods?
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