Chemicals legislation in the EU is a complex business, and the reclassification of MDI is no exception. It will have far-reaching consequences, but fewer than many in the industry feared.
Reclassification timeline
The implementation date for the revised classification of MDI – “limited evidence of carcinogenic effect” – is Dec. 1st, 2010. All mixtures containing > more than 1% MDI sold from that date onwards will have be labelled with R40 under DSD or H351 (“suspected of causing cancer”) under the EU Directive Classification, Labelling and Packaging of Substances and Mixtures (CLP).
Workplace health and safety
The reclassification of MDI will have no impact on workplace health and safety measures. Good practice still has to be maintained, e.g. the measures according to ISOPA’s Walk the Talk programme. Like all isocyanates, MDI is already subject to stringent Occupational Exposure Limits (OELs) and here there will be no further restrictions on MDI handling or use in professional and industrial applications. On the other hand, industrial users may have company-specific policies restricting the use of substances labelled as carcinogen, and consumer use may be affected by national restrictions. In Germany, for example, self-service sales of mixtures labelled with R40 will not be permitted to be sold to the general public unless an exemption is granted. An initiative to achieve such an exemption has been started by the German Adhesives Manufacturers Association (IVK).
Risk reduction measures
An EU Directive decrees that mixtures or preparations containing MDI in concentrations >= 0.1% may only be marketed to the general public after December 27th, 2010 if the packaging contains protective gloves and is marked with specific handling instructions.
For more information please contact ISOPA, the European Diisocyanate and Polyol Producers association.
