Preparing for a hazardous substances inspection: getting your dossier in order

An inspector from the Dutch Labour Inspectorate (Nederlandse Arbeidsinspectie) may visit by appointment, but can also turn up unannounced. If you work with hazardous substances, that is not the moment to go hunting for sheets and assessments. Being prepared means your dossier is in order: up to date, traceable and easy to find. This checklist helps you get there.

What the Labour Inspectorate checks for hazardous substances

The inspector checks whether you know and control the risks of hazardous substances — and whether you can demonstrate it. In practice that comes down to a few fixed elements: current safety data sheets (SDSs), an RI&E with a further inventory for hazardous substances, an overview of the substances present (the hazardous-substances register), and controls chosen demonstrably by the hierarchy of control. The inspector also looks at whether exposure has been assessed and whether staff on the floor know how to work with the substances safely — for example via a workplace instruction card.

Is a hazardous-substances register mandatory?

Yes. The Dutch Working Conditions Act (Arbowet) requires every employer to map the risks of the work, and the Working Conditions Decree (Arbobesluit, chapter 4) adds requirements for hazardous substances. An up-to-date overview of the hazardous substances at your workplace — which substances are present, with which hazards and in what quantities — is the foundation of that. Without the register you cannot assess exposure or substantiate your controls. Carcinogenic, mutagenic and reprotoxic (CMR) substances carry stricter requirements on top of that, including extra requirements for the RI&E (Arbobesluit art. 4.13) and a list of exposed workers (art. 4.15).

How to prepare

1. Make sure your SDSs are complete and current. Every hazardous substance needs a recent safety data sheet in your dossier. Expired or missing sheets are a classic sticking point in an inspection.

2. Make the further inventory traceable. Show, per substance and per task, what the risk is and why. A pile of SDSs is not yet a risk assessment.

3. Record your controls by the hierarchy of control. Source measures (elimination, substitution) come before engineering controls, which come before organisational measures, with PPE as the last resort. Note which control you chose and why.

4. Keep CMR substances tracked separately. Record where and how staff are exposed, and show that you have considered substitution.

5. Keep the work instructions on the floor. A workplace instruction card translates the assessment into concrete arrangements for whoever handles the substance.

6. Keep everything central and findable. In an inspection you want to show the right sheet, the assessment and the control at a glance — not dig through scattered folders.

Common mistakes

The most common shortcoming is a dossier that stops at collecting SDSs, without translating them into real-world risk and concrete controls. Traceability is often missing too: you must be able to show how you reached your conclusion. And expired SDSs remain a recurring issue — a sheet from years ago does not always cover the current situation.

How Chemspark helps

Chemspark brings your hazardous-substances dossier together in one place. From each SDS it takes the hazards, the composition and the exposure limits. You answer a short screening per product about how it is used. From that, Chemspark sets the risk level for inhalation, skin and fire & explosion, with a traceable rationale. Where a quantitative assessment is recommended, you calculate exposure per component. The register and the workplace instruction cards build on that. Chemspark recognises CMR substances by their H-statements and by components on the SZW list. You record the CMR registration under the product's screening, and the CMR register quick report puts it all in one overview. The named list of exposed workers stays in your own records. Workplace observations and the final judgement stay human work: you do them yourself or with your own expert, and on request Chemspark can support you with expertise. So in an inspection you are not searching, and you can show how you reached your conclusions.