The Labour Inspectorate is at the door. Is your hazardous substance management in order?

Picture this: it is Tuesday morning, half past eight. An inspector from the Netherlands Labour Authority (Nederlandse Arbeidsinspectie) is at reception. She wants to see the risk assessment (RI&E), the part on hazardous substances, and the safety data sheets (SDSs) of a few products from the workshop.

Then the searching starts.

The SDSs sit in a binder from years ago. The substance register is a spreadsheet nobody updates anymore. And nobody has assessed how high the exposure to the substances in use is.

You may have collected the information once. But can you show what you did with it?

That is where substance management often gets stuck in practice. And it is exactly where an inspection makes painfully clear what is still missing.

No assessment? A fine may follow

Since 10 February 2022, the general obligations in article 4.2, paragraphs 1 to 5, of the Dutch Working Conditions Decree can be fined directly. A warning first is no longer always required. The government tightened this because a missing assessment of the risks of hazardous substances can have serious consequences for workers' health.

The base fine is €4,500 for companies with 500 or more employees. Smaller companies pay a percentage of this amount, depending on their number of employees. A company with 25 employees comes to €1,350 per violation, based on these base amounts.

Note: not every gap in the hazardous substances part leads to a direct fine automatically. It depends on the specific obligations and circumstances of the violation.

And the financial consequences need not stop at a single fine. When the assessment is missing, there may also be shortcomings in the measures chosen, the information given or the instructions on the shop floor. These are assessed separately.

Source: Staatscourant 2022, 3848.

The problem does not stop at the fine

A shortcoming that has been found still has to be fixed. And that takes time, especially when the basics are missing.

Think of:

• Building a substance register from dozens or hundreds of SDSs, including requesting missing or outdated documents.
• Assessing the exposure per product and application and deciding which measures are needed.
• Writing work instructions and labels that match the real use on the shop floor.
• Recording what was assessed, which measures were chosen and when a reassessment is due.

All of this has to happen while the business keeps running. Sometimes outside support is needed, while people inside still have to make time to supply information, make choices and check results.

The annoying part is that much of this work does not have to be new. A lot of the information is already in the SDSs. The challenge is to turn that information into a usable register, a well-founded risk assessment and clear instructions for employees.

Repeat violations can raise the stakes

If the same violation is found again within the legal period, fines can be considerably higher. Article 34 of the Dutch Working Conditions Act sets rules for repeat violations; the period and the increase depend on the circumstances and the type of violation.

For some violations, work can also be stopped. That can happen, for example, when the same violation is found again after an earlier warning, or when there is serious danger.

The practical lesson: waiting for an inspection to bring shortcomings to light is not a sensible way to organise substance management.

The biggest bill may come much later

The financial consequences are one side of the story. The main purpose of substance management is to prevent employees from becoming ill because of their work.

Each year, around 3,000 people in the Netherlands die because they were exposed to hazardous substances at work. According to the Dutch minister, about 80% of them have already retired at the time of death.

So the damage does not always show during employment. That is exactly why the risks are easily underestimated.

Employers are responsible for giving their employees a safe and healthy workplace. When work causes damage to health, employer's liability can also come into play. Article 7:658 of the Dutch Civil Code sets out the employer's duty of care.

An up-to-date collection of SDSs is not enough for that. You also need to be able to show that you assessed the risks and took suitable measures.

Source: Aanhangsel Handelingen 2025–2026, no. 1195.

Five parts you want in order

Good substance management is not an administrative exercise for the inspector. It should make sure you know which substances you use, which risks come with them and how you control them.

So go through these five parts.

1. Overview

Which hazardous products are used, at which locations, and are their SDSs current and complete?

2. Risk assessment

Which risks are there in the actual application? Think of exposure through inhalation and skin contact, but also of fire and explosion hazards. Sometimes a more detailed or quantitative assessment is needed.

3. Measures

Were measures chosen according to the hierarchy of controls? Measures at the source come first, followed by collective and organisational measures. Personal protective equipment is not automatically the first choice.

4. Instructions on the shop floor

Do employees know how to work safely with the products? Are the right workplace instruction cards and labels available and easy to understand?

5. Keeping it current

What happens when a new product is introduced or a supplier sends a changed SDS? Is it clear which assessment, measure or instruction needs another look?

If you can show these parts are under control, you stand stronger in an inspection and work steadily on preventing damage to health. Good records are a means to that end, not a goal in themselves.

From SDS to workplace: how Chemspark helps

For many small and medium-sized businesses, the challenge is not a lack of rules but the amount of work it takes to meet them. Information is spread over SDSs, spreadsheets and loose documents. Keeping it up to date takes time that is often not there.

Chemspark helps turn that information into joined-up substance management.

Register — Upload your SDSs and build a substance register, organised per location. Product details and hazard properties are taken from the documents, so you do not have to enter them again and again.

SDS check — Check SDSs on up to eleven points, including age and completeness. A request letter per supplier can be prepared when information is missing or a document needs to be requested.

Risk assessment — See per product the main points of attention and which next steps are needed. Chemspark guides you through the assessment; you check the outcomes and decide what fits your work situation.

Measures — Work on measures according to the hierarchy of controls, with attention to the actual application and exposure.

Workplace — Make workplace instruction cards and GHS labels from the available product information. Check them before you use them.

Legislation — Flag relevant substances using, among others, the Dutch SZW list, ZZS, SVHC and the REACH lists. CMR substances are flagged too.

Changes — See what needs another look when an SDS changes. That way you can check in a targeted way whether a risk assessment, instruction card or label needs updating.

Log — The log keeps track of who recorded what and when, so decisions and changes can be traced.

Chemspark takes the preparatory work off your hands, but does not replace expert judgement. The outcomes need to be checked and, where needed, completed with knowledge of the workplace, the quantities used, the way of working and the actual exposure.

That way you work not only on a complete register, but also on the steps that come after it.

Start with a single SDS

You do not have to overhaul your whole substance management at once.

Upload an SDS today in Chemspark's free SDS check. You see which information can be taken from the document and where the points of attention are. No account needed.

Want to go further? Create a free account and start your own substance register.

Check an SDS for free on chemspark.net.