Frequently asked questions

Click on a subject to see the answer.

I have concluded all action points from the self-inspection. Do I have to do anything else?

Yes you must also ensure that the current situation has been assessed. If there are changes in your company, you must immediately check to ensure the measures regarding the hazardous substances are still adequate. Run through the self-inspection steps again and you will pick up on the appropriate action points.

Changes could include:

  • You recruit new employees.
  • Your company engages self-employed workers or temporary employees.
  • You replace a hazardous substance in the production process.
  • You start making a new product.
  • You introduce new management measures or a new production process.
  • The SDS for a hazardous substance is reviewed.
  • The exposure limits for a substance are amended.
  • A substance is added to the list of CMR substances.
  • A substance is added to the authorisation or restriction list.

Check the safety situation in your company at least once a year. Check whether the carcinogenic, mutagenic or reprotoxic substances could be replaced by non-hazardous substances or a less hazardous alternative.

Which substances fall under REACH?

Most substances fall under REACH. There are a few exceptions, such as radioactive substances and waste. But be careful! These substances could be hazardous according to the H&S legislation. Which REACH obligations apply depends on how hazardous a substance is and how much of this substance you make, blend, import, process, transport or use.

Would you like to check what you should do? Then go to the RIVM website Chemische stoffen goed geregeld!

What does REACH have to do with H&S?

There is a significant relationship between REACH and your H&S policy. An important aspect of REACH is the expertise on the hazardous characteristics of substances, the management of the risks and the corresponding communication in the chain. Without this information, you will not be able to implement and maintain effective H&S policy for hazardous substances. But there are also differences. For example, REACH sometimes excludes some substances or small quantities of specific substances from the obligations, while the H&S policy sets out that you must effectively manage exposure to all hazardous substances. Read the REACH and H&S manual.

What are hazardous substances?

Substances, mixtures or solutions are hazardous if they could damage the health of your employees and/or can reduce safety in the event of incidental or long-term exposure.

With hazard label
Many hazardous substances are immediately recognisable as a result of a hazard label. You see - for example - a flame, exclamation mark or skull on the label. This symbol is also given on the Safety Data Sheet (SDS). Every hazard label refers to a specific, hazardous property. On the website of CLP/EU-GHS you can find more information about the meanings of the symbols. The explanation of the labels is set out in the European CLP regulations (Classification, Labelling and Packaging of chemicals), also called the EU-GHS.

Without hazard label
Not all hazardous substances carry a label. Some substances are only created during the work processes. This could include welding fumes or diesel engine emissions. Certain natural substances, such as quartz or wood dust can also be dangerous.

Do I also have to inventory substances for household use?

Only if you use these substances professionally. This could include sodium hypochlorite in the cleaning industry. However, the sink unblocker that you have in the kitchen does not to be included in the inventory.

Do I also have to assess hazardous substances with which my employees do not come into contact?

No, that's not necessary. If the substances are packed properly and the packaging stays closed, your employees are not exposed to the substances. Assessment is not required. You must inventory the substances however. You must also indicate the hazardous properties of the substances.

These details can be used for the incident plan that you must draw up. If there is a fire or another incident, your employees will then run the risk of exposure. In the incident plan, you set out what you do to exposure limit exposure during the incident.

If there is very little exposure
Some substances are used by your company but not on a daily basis, e.g. only for maintenance tasks. Your employees will come into contact with them every now and then. That is why you must inventory and assess these substances.

We are a wholesaler and process hazardous substances. Do I also have to determine exposure limits?

No, that's not necessary. If the substances are packed properly and the packaging stays closed, your employees are not exposed to the substances. The exposure will then remain under the exposure limit at all times. You must inventory the substances however. You must state the hazardous properties of the substances.

These details are used for the incident plan that you must draw up. If there is a fire or another incident, your employees will then run the risk of exposure. In the incident plan, you set out what you do to exposure limit exposure during a incident.

Do I have to assess the substances from the technical service?

Yes. You must assess all hazardous substances that are used within your company. So, also the substances that are not directly involved with your company?s main activities. You can be pragmatic about this. For example, by carrying out a group or cluster assessment. This means that you first inventory which substances are used by the technical service. Then you determine which substance poses the biggest risks (due to its hazardous properties or for another reason, for example: application in large quantities, under high pressure or at a high temperature). You assess the exposure level for this substance and then take measures for protecting your employees accordingly. The idea is that you then protect your employees sufficiently against the other substances.

Tip: do you still have substances that you no longer use? Dispose of these right away, then you no longer need to assess them.

I have a lot of hazardous substances. What do I do now?

If your company works with a large range of hazardous substances, you do not need to inventory and assess all of the substances in one go. Start with the substances that pose the greatest risk, such as carcinogenic and mutagenic substances and/or reprotoxic substances. Or with substances that are often used or those that can pose a big risk to health even at low doses. You set the order: which substance is most hazardous? Set out your choices and the issues you have taken into account. You must be able to justify your choices.

Clusters
You can also cluster substances together: substances that are very similar can be assessed as a cluster. You then establish, per cluster, which substance poses the biggest risk.

Priorities
A Control Banding system can be used to set priorities. On the basis of H-phrases (physical properties and health risks), you can make a division into hazard categories. The prioritisation takes place on the basis of these hazard categories and the workplace conditions. You thus create a distinction between (very) high risk substances, medium and low risk substances.

More information about prioritisation can be found:

Which details do I need to inventory?

A summary of these details can be found in Inventory - what and how?

How do I determine the exposure limit for a substance?

Read about it here: Hoe ga ik te werk bij het vaststellen van grenswaarden?

Where can I find details on a hazardous substance?

These details can be retrieved from the safety data sheet (SDS). With mixtures, you only note the components that are shown on the SDS. These components are important when assessing exposure.

Not received an SDS?
You should be able to obtain an SDS from the supplier of the substance. Do you not have an SDS for a particular substance? Then you must track down the information yourself. You can ask the supplier or manufacturer to provide the SDS, look on the internet or engage the help of a consultancy or your sector organisation.

Substances that are created during the work process
Substances can be released during work, such as welding fumes or respirable silica. You won't have an SDS for these. In this case: safety must be prioritised above all else. Take all possible measures to prevent damage to health. You can ask for information from your sector organisation, an Occupational Health and Safety Service or a labour hygienist.

Why does the SDS not include an exposure scenario?

This could be for various reasons:

  • Your substance or product does not have to have an exposure scenario in the SDS. According to the rules of REACH/CLP, an exposure scenario is only mandatory for hazardous substances that are produced or imported in large quantities (10 tons or more).
  • The manufacturer or importer has not yet registered the substance or product with ECHA. The end date for registration is May 2018.
What if my supplier does not provide an SDS even though he should?

You are responsible for a safe and healthy working environment in your company. This means that you are also responsible for collating the necessary information. Only then can you assess the risks and take the right measures for working with hazardous substances. So, even if you do not receive an SDS from your supplier, you are still responsible. The simplest way to collect the information is to ask for the SDS from your supplier.

How do I know that my supplier's SDS is ok?

Every SDS must fulfil the extensive Annex II of the REACH regulation. It is therefore difficult to quickly check whether the information in the SDS is correct. In order to assess whether the SDS is ok, you could use the VIB-check. If the SDS check demonstrates that the SDS is not correct, you can send the report onto your supplier with a request to improve the SDS.

Why don't all substances come with a SDS?

Your supplier must provide an SDS for substances and mixtures that:

  • are categorised according to the CLP as hazardous - these must be clearly labelled by means of hazard symbols on the packaging;
  • are persistent, bio-accumulative and toxic or very persistent and very bio-accumulative - these are substances that do not break down easily and could be hazardous to the environment;
  • are on the candidate list for authorisation.

In all other instances, an SDS is not mandatory. Sometimes the SDS must be available on request. For example, if a mixture is not categorised as hazardous, but does contain a component that is classified as hazardous according to the CLP. Many suppliers make safety information sheets or SDS's for all of their products whether or not they are classified as hazardous.

When can I use the kick-off value?

You can only use the kick-off exposure limits if you can find no other exposure limit for the substance. Hoe ga ik te werk bij het vaststellen van grenswaarden?

Which kick-off value can I use for exposure to particulates in the air?

Is there an H-phrase for this substance? Then you can determine a kick-off value for the substance at www.dohsbase.nl .

Is there no H-phrase for this substance and the substance has no specific properties? Consult an expert, such as a labour hygienist or someone of a similar level.

If a substance has no exposure limit, can I use the exposure limit for a substance with the same H-phrases (R-phrases) and a similar vapour pressure?

No, that's not permitted. Comparable substances can have various health effects.

If a mixture contains a small percentage of CMR substance, does this also count as a CMR substance?

This depends on the percentage. If a mixture contains a C, M or R component, and the concentration of this component is greater than or equal to the value in this table, the mixture constitutes a CM or R substance. NB: for CM substances, you must note more details in your inventory than for R substances!

The values in this table come from the Preparations directive 1999/45/EC, Annex II part B, and from the CLP directive (EC) No. 1272/2008, Annex I.

H/R phrases

Non-gaseous preparations

(weight percentage)*

Gaseous preparations

(volume percentage)*

Concentration exposure limits *

in the mixture

H340 (M)

R46

0.1

0.1

0.1

H350 (C)

R45 R49

0.1

0.1

0.1

H360 (R)

R60 R61

0.5

0.2

0.3

H361 (R)

R63

5

1

3

H362 (R)

3


* The concentration exposure limits apply to solids, fluids (weight percentage) and gases (volume percentage).

How and what should I assess?

You must determine the nature, extent and duration of exposure for every hazardous substance with which employees could come into contact. This means:

  • the type of substance and the corresponding risk
  • how the employee comes into contact with the substance (airways, skin, eyes)
  • how severe exposure is (contact with high/low concentrations)
  • how long the exposure lasts

Various tools are available online in this context. See: Online hulpmiddelen om de blootstelling te beoordelen.

Does it make any difference whether I have the checks conducted by my own people or an Occupational Health and Safety Service?

That depends. If your own assessor is an expert at the same level as a labour hygienist, the inspector will not distinguish between your own assessment and the assessment of a labour hygienist. The inspector will always run through the same steps during a check. The inspector will take a random sample of a substantial number of substances and check:

  • whether the exposure level per task/process has been determined
  • whether the exposure has been checked to the exposure limit for the substance
  • whether the exposure has been established according to an accepted method
  • whether you have calculated the daily average for components that occur in multiple substances
  • whether you have taken account of combined exposure to substances that have more or less the same damaging effects
Do I have to inventory and assess the various components in a mixture separately?

Yes. Most substances that you work with, are made up of a mixture of various components. In that case, you must note every component separately:

  • the percentage of each component in the mixture
  • the exposure limit for that component
  • the exposure to this component for your employees

If an employee comes into contact with various substances, and these substances contain the same component, the total exposure per day (the daily average) must be below the exposure limit. You determine the daily average for exposure by adding up the components from the various substances. See for more information: Toetsen aan de grenswaarden.

How do I assess the combined exposure to various solvents?

Watch out for combined exposure to various solvents. These contain various components that have more or less the same damaging effect. The effect is cumulative. Even if exposure per component is lower than the exposure limit, the overall effect could damage the health of your employees. You can calculate whether the combined exposure exceeds the exposure limit but it is more practical to keep combined exposure to a minimum. If possible, replace hazardous substances with less hazardous substances and ensure effective personal protective equipment is provided.

Calculating combined exposure

  • For each component, calculate: the exposure divided by the exposure limit for this component.
  • Add up the results.

The result of this sum must be lower than 1. You must take measures if it is higher. In this case, your employees are taking an excessive health risk.

Need help with the calculations?
See Toetsen aan de grenswaarden.

Do I have to assess work in the fume cupboard?

Yes. You must include the work in the fume cupboard in your inventory and assessment of hazardous substances. When making the assessment, you can use a container measurement to estimate any exposure.

No two fume cupboards are the same. Make sure that the fume cupboard is suitable for the experiments you wish to conduct in it. Factors that determine the (inhalation) risk during an experiment in a fume cupboard are:

  • the quantities of substance being processed;
  • the volatility or distribution rate of the substance under the specific circumstances;
  • the nature of the processing (open or closed);
  • the toxicity of the substance;
  • the flammability and the explosive exposure limits of the substance.
We are a waste processing company. Do I have to inventory and assess the waste?

This does not have to be particularly detailed. But you must have an insight into the various types of substance that will be used. Make an inventory of this. On the basis of this knowledge, make sure your employees are adequately protected. Take structural measures to reduce exposure. And ensure that your employees are aware of the risks. Provide sufficient information!

Make sure there is an effective incident plan that is adapted to the hazards that are associated with fire, explosion or other emergency situations.

Follow instructions when storing hazardous substances too. Some substances cannot be stored together. See Opslag van verpakte gevaarlijke stoffen (PGS 15).

Which measures are suitable?

That varies, of course, per sector and per company. Is there a H&S catalogue for your sector? This often contains the measures for reducing exposure to hazardous substances. Always take the specific situation in your company into account. Assess whether the measures in the H&S catalogue are sufficiently effective for your situation. Click for a summary of the H&S catalogues.

Where can I find information and support?

If you do not have an in-house expert in hazardous substances, you can engage outside assistance. For example:

  • specialised agencies
  • Health and safety services with labour hygienists
  • sector organisations, such as ?Nederlandse Rubber-, Lijm- en Kunststofindustrie? (NRK) and the ?Vereniging van de Nederlandse Chemische Industrie? (VNCI)
  • professional associations, such as ?Nederlandse Vereniging voor Arbeidshygiëne? (NVVA) and the ?Nederlandse Vereniging voor Veiligheidskunde? (NVVK)

As the employer, you remain responsible for health and safety within your company!

Fine information online
You can, of course, find tips and practical examples on various websites. Sometimes you will have to pay for information. For example: Stoffenmanager® en de arbo-informatiebladen van de Sdu.

There is a lot of useful information on the internet but always check the source and the reliability of the information. Publications from other organisations are not checked by the Ministry for Social Affairs and Employment (SZW) Inspectorate.

Can I include the action points in my business file?

At the moment, you can only do so if you are affiliated to the NRK (Nederlandse rubber- en kunststofindustrie). This works as follows:

  • Log in on www.mijnondernemingsdossier.nl
  • Open self-inspectionfrom your company file. You will find it on the Measures tab, then under ?ARBO? (hazardous substances).
  • Go on to self-inspection.
  • After each step, you can send the action points to your company file.
The exposure scenario in the SDS does not fulfil the hierarchy of controls? What should I do?

You must always ensure that your measures follow the hierarchy of controls. So: first source measures, then technical and collective measures and then individual protection measures. You cannot simply take on the measures from the exposure scenario.

The exposure scenario is customised to an imaginary company. It does not consider, for example, that employees could be exposed to various hazardous substances on one day. And that does matter in terms of management measures. You must assess which measures are necessary and possible in your company.

If the exposure scenario says that I must use personal protective equipment, can I assume that I am fulfilling the hierarchy of controls?

No, not automatically. You must always check to ensure that your company is fulfilling the hierarchy of controls when following the exposure scenario. The circumstances and options for taking measures vary from company to company. Your supplier may not include the first step of the hierarchy of controls (replacement of the substance by a less hazardous substance) in his exposure scenario.

How do I determine the exposure limit for a mixture?

An exposure limit is rarely set for a mixture as a whole. Petrol is an example of a mixture with its own exposure limit, i.e. 240 mg/m³. In this case, you may check the exposure of your employees to this exposure limit.

Most mixtures do not have an exposure limit. In this instance, you must determine an exposure limit for each component.

Which tasks could lead to the release of carcinogenic or mutagenic substances?

During this work, there is a significant chance that CM substances will be released:

  • asbestos cleaning
  • welding work
  • metalwork and processing
  • processing stony materials (quartz)
  • processing hardwood
  • working with and processing chemical waste
  • working with and processing contaminated soil
  • tank cleaning
  • fire-fighting activities (soot, asbestos)
  • use of diesel engines

CM substances can also be released during other tasks. This depends, of course, on the substances and materials with which you are working.

Do I also have to inventory the substances that are released during work?

Yes, if your employee come into contact with it. In your inventory, you must set out all of the substances to which your employees are exposed.

This could include, for example, diesel engine emissions, respirable silica and welding fumes. There are no SDS?s for these substances and the substances have no H-phrases. However, you must record information about the exposure limits, the type of work and/or whether it is a carcinogenic, mutagenic and/or reprotoxic substance.

Which extra details do I have to record for CM substances?

These are extra details that you must note for CM substances:

  • the quantity of CM substances that you manufacture per year, use or have in stock. In litres, (kilo)grams, etc.
  • a list of all employees who are exposed to carcinogenic and/or mutagenic substances
  • for each C or M substance: why you use this substance and have not replaced it with a less damaging substance
  • the general, preventative measures that you take to prevent exposure
  • the personal protective equipment that your employees use
How can I recognise substances that are suspected of having carcinogenic or mutagenic properties?

You can recognise CM substances with these H-phrases:

H341: suspected of causing genetic defects
H351: suspected of causing cancer

Do I have to record extra details for CM substances? Does that also apply to substances that are suspected of having carcinogenic or mutagenic properties?

No. The legal obligations do not apply to these substances. It is, however, wise to indicate the suspected substances separately in your register. You can then find them easily if the situation changes. For example, if there are new rules for suspected CM substances, or if a suspected substance is permanently added to the list of carcinogenic substances.

You can recognise suspected CM substances by these H-phrases:

H341: Suspected of causing genetic defects
H351: Suspected of causing cancer

How do I register exposure to CM substances for employees?

In the RIE, you inventory the exposure to CM substances per department, function and/or task. These results can be linked to your personnel register. You can then ask the company doctor or Occupational Health and Safety Service to support you in this. Details, for example, could be included in the medical files of the exposed employees.

Do I have to record the extra details for CM substances, for CM substances that are released from work?

Yes, but it can be tricky to accurately determine the level of exposure. Choose a pragmatic approach:

Note which employee has had a role, in which period, that could have exposed him/her to CM substances. Link this information to the exposure details that are set out in the RI&.

This data can also be included in the medical files of exposed employees.

Why should I register which employees are exposed to CM substances?

These details are required if an employee becomes sick, in order to ascertain if there is a link between work and the sickness.

What estimation methods can I use to assess exposure?

There are various tools available online. See: Online tool for assessing exposure.

How I can assess the exposure with measurements?

Measuring and assessing exposure requires specialist knowledge. You must take account of many different factors. For example:

  • You must determine which substances must be measured for which employees and under what conditions.
  • Often, you must conduct measurements over several days in order to ensure that the situation is adequately managed. This is due to the fact that measurement results can vary widely as a result of changing circumstances.
  • The measurement method and assessment of the results must fulfil guideline NEN 689 (Workplace atmosphere: Guideline for assessing exposure to inhalation of hazardous substances for comparison with the air exposure limits and the measurement strategy) or the guideline from the association of Dutch and British labour hygienists.

The exposure must always be carried out the checked by an expert labour hygienist or similar.

Do I have to have the exposure assessment checked?

That depends. Was the assessment conducted by a certified expert? Then extra checking is not required.

Was the exposure assessment carried out by someone who is not certified to do so? Then the exposure assessment (on the basis of measurements and/or a quantitative estimation model) must be checked by an expert such as a labour hygienist or similar.

How do I use the exposure scenario in the SDS?

The exposure scenario, indicates which measures you must take in order to work safely with the product. A check of whether you fulfil these measures, however, is too exposure limited for a risk assessment. In the RI&E for hazardous substances, you must focus more specifically on your business conditions, such as the effectiveness of management measures, maintenance, etc.

You must also check whether your employees come into contact with multiple substances or mixtures on a daily basis. This combination of exposure must be assessed by you.

The management measures in the exposure scenario do not always follow the hierarchy of controls. Make sure that your management measures follow the hierarchy of controls. Sometimes, the exposure scenario works with other exposure limits, e.g. a DNEL, however, there could be a legal exposure limit for the substance in the Netherlands. You must check this yourself.

You must therefore draw up a risk assessment that applies to your situation. The details from the SDS provides valuable information for the risk assessment and for identifying health and safety measures.

For more information: Handreiking REACH en Arbo

Can I transfer the exposure scenario in the SDS to my company?

This is only possible if your company situation corresponds, in all aspects, with the exposure scenario in the SDS. For instance, size of the space, ventilation and extraction facilities, and so on. This is rarely the case.

My sector has developed a safe working method. Do I still have to assess exposure?

No, that's not necessary. If your working methods exactly match those in the safe working method in the H&S catalogue, you may assume that exposure is within the exposure limits.

What is a safe working method?

A 'ready to go? working method is one that is accurately defined and is valid for one sector, one process, task and/or population and one substance group whereby exposure is clearly below the exposure limit.

It could well be that your sector has developed a Safe working method; you should be able to find this in the H&S catalogue for your sector.

Do I have to carry out biological monitoring?

This in only mandatory for substances for which a statutory biological exposure limit has been established. You must give all employees who work with this type of substance the opportunity to have levels measured in the biological medium (e.g. blood, urine).

At the moment, there is only a statutory biological exposure limit for lead.

Some other substances have biological exposure limits that are not determined on a statutory basis. You can offer this as part of biological monitoring, to check exposure. This can be in addition to or instead of air measurements. Biological monitoring instead of air measurements can only be applied if there is a good relationship between measured biological values and exposure limits.

If biological monitoring is carried out correctly, it can provide an effective insight into the level of exposure. Biological monitoring is particularly useful for substances that are taken into the body via inhalation as well as via the skin..

How do I determine exposure to a mixture?

An exposure limit is rarely set for a mixture as a whole. Petrol is an example of a mixture with its own exposure limit, i.e. 240 mg/m³. In this case, you may check the exposure of your employees to this exposure limit.

Most mixtures do not have an exposure limit. In this instance, you must assess the exposure of your employees per component. You check the exposure to the exposure limits for the various components. If the components have the same health effects (such as solvents), you must add up the exposure.

You can also assess exposure to a mixture on the basis of the most hazardous component. This is only an option if the choice of this component is carefully justified. This type of component is often referred to as a ?marker?. It always concerns the most hazardous component in the mixture.

Let a labour hygienist (or another expert of a similar level) assess which component is suitable. The expert must also take account of the risk of combined exposure.

What does 'technically feasible' mean in practice?

'Technically feasible? means: the facility, installation or machine can be purchased and used in your situation..

If a facility is available but only in a format that is not suitable for a specific situation and it cannot be made suitable, the facility does not apply to this situation.

Whether or not a facility is applicable, can vary according to the sector.

Is a facility technically feasible? Then you must apply it as quickly as possible.

What is the hierarchy of controls?

Read about it here: Hoe werkt de arbeidshygiënische strategie?

What are the common sense measures?

See the Checklist: Maatregelen met gezond verstand.

How do I know if my substance falls under the authorisation rules?

Check de autorisatielijst. The ECHA?s authorisation list, on their website, contains all of the substances for which you need authorisation. Without authorisation, you may not produce, use or process these substances.

The date on which the authorisation starts or started, is included in the column 'sunset date'.

Do I automatically get a new SDS from my supplier if the SDS changes?

In principle, the supplier of the product must take care of this. It is a good idea to make agreements with the supplier in this regard. You remain responsible for ensuring that you have the most up-to-date SDS's in your possession.

What should the inventory look like?

You may decide what is practical for you. There is no fixed format.

A few examples of an inventory list (also: substance register) can be found here:

Is it always necessary to determine a quantitative inhalatory exposure limit for every substance?

No, in certain circumstances that is not necessary. I.e. if there is no exposure because the substance properties or the working methods prevent this. For example:

  • hazardous substances that are processed without being removed from the outer packaging or poured out of the packaging
  • hazardous substances in a closed system without sampling or other process during which there could be exposure.

Are the health effects from a substance not yet known?
Then you must always treat the substance as if it is a very hazardous substance. And take the appropriate protective measures.

How do I treat substances from the Research & Development department?

In principle, the substances from Research & Development (R&D) must be processed exactly like other substances in your company. So:

  • conduct an inventory and record details
  • assess exposure
  • take measures to reduce exposure.

If there are few or no details
It is often the case that there are few or no details for R&D-substances, so it can be difficult to determine an exposure limit. In this case, you must always treat the substance as if it is a very hazardous substance. Take appropriate protective measures to prevent exposure or exposure limit as far as possible.

Do I have to record extra details for suspected CM substances?

No. The legal obligations do not apply to these substances. It is, however, wise to indicate the suspected substances separately in your inventory. You can then find them easily if the situation changes. For example, if there are new rules for suspected CM substances, or if a suspected substance is added into the list of carcinogenic substances.

You can recognise suspected CM substances by these H-phrases:

H341: Suspected of causing genetic defects
H351: Suspected of causing cancer

Which extra details do I have to record for reprotoxic substances (R)?

These are extra details that must be recorded for R-substances:

  • the quantity of R-substances that you can manufacture, use or hold in stock per year
  • the number of employees that can be exposed to the R-substances

These details must also be recorded for suspected R-substances (identified by H361).

Do I have to monitor employees who work alone?

In practice, it is not always possible to supervise employees who work on location. As an employer, you are responsible for maintaining a safe and healthy workplace for employees at one-person units and external locations. That is why you must understand the risks of that location. And which measures and facilities are needed in order to reduce the risks of working alone. These situations, in which employees work alone, must be indicated in the risk inventory and evaluation (RI&E).

Read more on this at arboportaal.

What is the difference between the two types of health check (PAGO and PMO)?

A PAGO (periodical H&S check-up) only focuses on the industrial risks that are set out in the risk inventory and evaluation (RI&E). A PMO (preventative medical check-up) focuses more precisely on the general health of your employees.

As an employer, you must offer a PAGO to your employees. The aim of the PAGO is to detect damage to health as a result of risks at work, at an early stage. The company doctor can provide advice on the content and frequency of the PAGO.

A PMO can provide input for the preventative health policy in your organisation. This is often offered in the context of sustainable employability. The PAGO could be part of a PMO.

Can I use the exposure limits from the SDS?

In principle yes, but the exposure limits of the SDS are not always accurate. Check the database van de SER to ensure that this is the exposure limit with the lowest health risk.