Hazardous substances in your risk inventory (RI&E): what Dutch law requires

The Risk Inventory and Evaluation (RI&E) is mandatory for every employer under the Dutch Working Conditions Act (Arbowet). If you work with hazardous substances, the Working Conditions Decree (Arbobesluit, chapter 4) adds requirements: a further, specific assessment of the risks of those substances.

What is the 'further inventory'?

The general RI&E maps risks at a high level. For hazardous substances that is not enough. The further inventory calls for an assessment per substance and per exposure situation: which substances, in which tasks, via which routes (inhalation, skin), in what quantities and for how long.

The goal is not a pile of SDSs, but a substantiated judgement of the risk at each workplace — and the controls that go with it.

From hazard to control

1. Inventory the substances. Start with the Safety Data Sheets. The hazard classification (H-statements), physical state and occupational exposure limits are the basis.

2. Assess the exposure. Combine the hazard with how the substance is actually handled. A hazardous substance in a closed system carries a different risk than the same substance in an open process.

3. Choose controls by the hierarchy of control. The order is fixed in law: source measures (elimination, substitution) before engineering controls, before organisational measures, with PPE as the last resort — not the starting point.

4. Record and repeat. Controls must be documented, communicated (for example via a workplace instruction card) and reviewed periodically.

Stricter rules for CMR substances

Carcinogenic, mutagenic and reprotoxic (CMR) substances carry extra obligations, including a duty to substitute where technically feasible and an exposure register (Arbobesluit art. 4.13). Keep these substances tracked separately.

Common mistakes

A frequent shortcoming is an RI&E that stops at collecting SDSs, without translating them into real-world risk and concrete controls. Traceability is often missing too: in an inspection you must be able to show how you reached your conclusion.

How Chemspark helps

Chemspark makes the step from SDS to assessment: for each component it runs a qualitative risk assessment for inhalation, skin and fire & explosion, with a traceable rationale. CMR substances are recognised automatically and placed in a separate register. That lets you build the further inventory of your RI&E in a structured, demonstrable way.