MDI

= Methylenediphenyl Diisocyanate

Proposal for a decision of the European Parliament and of the Council amending Council Directive 76/769 as regards restrictions on the marketing and use of certain dangerous substances and preparations - Methylenediphenyl Diisocyanate / MDI

FEICA the European Adhesive & Sealant Manufacturing Association is a multinational association representing the European Adhesive and Sealant Industry. With the support of 15 national associations and several direct and affiliated members, FEICA coordinates, represents and advocates the common interests of our industry throughout Europe. In this regard FEICA aims at establishing a constructive dialogue with legislators in order to act as a reliable partner to resolve issues affecting the European Adhesive and Sealant Industry.

The adhesives and sealants sector represents six per cent of the market for MDI. The material is used in many performance critical bonding and sealing applications in some of Europe’s most important market sectors such as automotive, aerospace, building and construction. Its volume use is therefore in industrial and professional rather than consumer applications. Consumer use is largely confined to foam canisters of 450/750 ml capacity and for gap filling in general building. The consumer simply breaks the seal and depresses the button for dispensing through a straw into the void.

FEICA is deeply concerned about the situation with MDI. The proposal for a decision of the European Parliament and of the Council amending Council Directive 76/769 suggests new risk management measures for MDI in the consumer market and proposes a study to collect more data on possible cases of respiratory allergy due to products containing MDI.

Study protocol - Respiratory allergy

The Commission proposal calls for a study to collect more data on possible cases of respiratory allergy due to products containing MDI. In line with the ISOPA position, FEICA believes that existing data already shows that MDI can be safely handled in consumer applications.  However, if a study must be conducted for political reasons, FEICA would like to stress that only a balanced and scientifically sound study protocol will bring accurate results. Therefore, we offer to assist with scientific input and experiences from the market and hope that we can agree on a scientifically sound but practical solution.

As downstream users that sell directly to the consumer market our industry depends upon consumer satisfaction. We are committed to offering safe products and over the last 20 years have acquired considerable knowledge with MDI based preparations and how to handle them safely. MDI is a key substance for reactive adhesives and cannot be replaced easily; non isocyanate alternatives show significant limitations in the application. Furthermore, substitution with substances that are less well researched may result in unknown risks.

REACH

An exposure scenario for MDI containing products required under REACH will clearly show that with the appropriate risk management measures our products are safe to use. The current proposals are therefore premature and inappropriate at this time. The proposed risk management measures for MDI, adding gloves and labelling to the packaging (point 55, 4 a) and b) are sufficient to ensure consumer protection.

January 17^th 2008