Two substances and two amended frameworks
Royal Decree 846/2026 was published on 23 October 2026 and entered into force the following day. It amends Royal Decrees 665/1997 and 374/2001. For lead and inorganic compounds, it reorganises provisions within the carcinogenic, mutagenic or reprotoxic-agent framework. For diisocyanates, it introduces binding airborne limits under the chemical-agent rules. The same indicator or a single date should not be applied to both without examining their respective provisions and transitional arrangements.
Lead: air and blood are different
The daily airborne limit for lead and its inorganic compounds is reduced to 0.03 mg/m³. The annex sets a biological value of 15 μg Pb per 100 ml of blood, while the transitional provision establishes 30 μg Pb per 100 ml until 31 December 2028. These are different measurements and cannot be converted into one another. Specific health-surveillance, previous-exposure and childbearing-age provisions also require individual professional interpretation rather than decisions based on this summary alone.
Diisocyanates: express results correctly
Limits are expressed as the NCO functional group, not an undifferentiated mass of any commercial mixture. Until 31 December 2028, the daily and short-term values are 10 and 20 μg NCO/m³, respectively. The subsequent regime specifies 6 and 12 μg NCO/m³. The rules identify skin contribution and skin and respiratory sensitisation. An airborne result below a limit does not by itself exclude all these risks or remove the need for suitable exposure controls.
What employers need to review
The inventory should identify affected products and processes, including maintenance, cleaning and mixing tasks. Assessment, measurement strategy, reports and control planning need the correct substance, unit, reference period and date. Information and training should be updated. The prevention service coordinates occupational hygiene with health surveillance without placing individual clinical results in operational documents accessible to people who do not have a legitimate need to see them.
Example: updating an exposure report
An earlier report compares a measurement with a historical value. Replacing one number is insufficient: check the sampled fraction, method, duration and representativeness for the task. For diisocyanates, confirm expression as NCO; for lead, distinguish airborne and biological information. This entry summarises regulatory changes and does not determine medical fitness or establish a safe exposure for an individual worker under particular personal or workplace circumstances.
