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 (Arbobesluit art. 4.17), extra requirements for the RI&E (art. 4.13) and a list of exposed workers (art. 4.15). 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 helps you take the step from SDS to assessment. After a short screening per product, it uses your answers to set the risk level for inhalation, skin and fire & explosion, with a traceable rationale. Where needed, you calculate a quantitative estimate per component. Chemspark recognises CMR substances by their H-statements and by components on the SZW list. You record the CMR registration under the screening, and the CMR register quick report puts it all in one overview. That lets you build the further inventory of your RI&E in a structured, demonstrable way.