A Directive, Not a Purchase Order
On 19 October 2026 the Council of the EU adopted the sixth revision of the Carcinogens, Mutagens and Reprotoxic Substances Directive, after Parliament approved it by 499 votes to 49. It sets binding exposure limits for cobalt and its inorganic compounds, certain polycyclic aromatic hydrocarbon mixtures, 1,4-dioxane and isoprene, and brings welding fume containing category 1A or 1B CMR substances into Annex I. There is no single limit for welding fume; the Commission must judge whether substance-specific values are needed.
Nothing changes on a plant floor yet: entry into force follows publication in the Official Journal by 20 days, member states then have two years to transpose, with six- and seven-year transitions for cobalt and PAHs counted from entry into force. A 2025 Commission assessment placed more than 2.6 million EU workers in contact with at least one substance covered.
Last Resort, Still a Control
Gloves and boots still come after substitution, enclosure, extraction and reorganisation of work. What is new is an obligation to select equipment correctly, fit it to the wearer and maintain it under the PPE Directive, plus a right for workers who wear it to regular breaks in an area free of contamination risk, with duration and frequency set by the risk assessment. Training must also explain residual risk: staying below a limit does not remove it.
That changes the arithmetic of a shift. A break is a doff and a redon, so a worker taking three breaks in eight hours does not wear one pair for eight hours: they must survive four donning cycles, four cuff adjustments and four chances to catch a gauntlet on a glovebox port. Boots face a harder test: a rest area is only clean if there is a line to cross. Buyers should ask what that line is: a bench, a boot-change trough, a disposable overshoe, a separate clean-side floor.
Fit, Records and Four Barriers
Individually fitted means the size range covers the crew, not the catalogue. Hand length and breadth vary independently, and a boot that is right in length but narrow across the metatarsal turns every break into a struggle. Maintenance is the other auditable item: reusable gloves and boots need a written inspection and decontamination routine, a shelf-life date and retirement criteria a supervisor can apply without a lab.
The new limits also reshuffle glove selection. 1,4-dioxane is water-miscible and carries a skin notation, with an eight-hour limit of 7.3 mg/m³, a 15-minute value of 73 mg/m³ and a biological limit of 45 mg HEAA per gram of creatinine; a solvent that crosses skin rewards a laminate film over thin nitrile. Isoprene, at 8.5 mg/m³ over eight hours, is a small volatile monomer boiling near 34°C and the feedstock for synthetic polyisoprene, so the same substance sits upstream of the gloves worn downstream.
Cobalt compounds are dust and fume problems, at 0.01 mg/m³ inhalable and 0.0025 mg/m³ respirable as cobalt once the transition ends; the route into the body is often the cuff, the wrist and the inside of a boot rather than the palm. PAHs, under a seven-year transition that also reaches carbon and graphite manufacturers, are lipophilic: they soak into leather and stay, making a leather boot a reservoir instead of a barrier. Welding fume ties the argument to the gauntlet, which collects fume and passes it on.
What Belongs in the Specification
Buyers should map each substance to a named glove and boot, attach the permeation report behind that choice, and write the doff-and-break routine into the same document. Compliance dates will be national; the evidence will not.
