About half of the companies in the Netherlands that are required to have one do not have a risk inventory and evaluation. Research shows (in Dutch) that 70 per cent of these employers simply do not know about the obligation or find carrying it out too complicated. That is striking, because the RI&E has existed since 1 January 1994 and applies to every employer with staff, whatever the size of the company.
An RI&E is more than a legal tick in a box. It is the foundation of a healthy and safe company: a written overview of all the risks employees run on the floor, together with an action plan for controlling those risks. Arboportaal (in Dutch) explains that the obligation flows directly from article 5 of the Working Conditions Act and that the Netherlands Labour Authority actively checks whether companies have the document.
But drawing up a good RI&E is one thing. Knowing who may officially review it afterwards is another question, and one that causes confusion for many employers and HR professionals. In this article we set out step by step what an RI&E involves, when a review is compulsory and which certified experts, including the senior safety expert at Care Concern, which Dokter Beter works with, are authorised to carry that review out.
What exactly is an RI&E?
According to the Dutch government's business portal (in Dutch), an RI&E describes which risks and hazards exist in your company, which measures you have already taken and which groups of employees, such as pregnant workers or young people, need extra attention. The action plan is a fixed part of it: there you set out which steps you will take to control the risks found and when you will take them.
The RI&E must always be current. Does something change in your company, such as a reorganisation, new machinery, a move or altered working methods? Then you update the RI&E. That keeps the document a living instrument rather than a report that sits unchanged in a drawer for years.
When is a review compulsory?
The law prescribes (in Dutch) two situations in which you must have the RI&E reviewed by a certified core expert. The first is company size: as soon as you have more than 25 employees, counted against your actual headcount including agency workers, on-call workers and secondees, a review is compulsory without exception. A company with 18 permanent employees and 12 agency workers is already above that threshold.
The second situation concerns the method. Anyone who does not use a recognised sector instrument and draws up the RI&E themselves must always have it reviewed, even below the 25-employee threshold. If you do use an instrument recognised by the Labour Foundation (in Dutch) and have no more than 25 employees, you are exempt from the review requirement. There is also an exception for organisations where all employees together work no more than 40 hours a week.
Who may review the RI&E?
The Netherlands Labour Authority (in Dutch) is clear: you are required to have the RI&E and the action plan reviewed by a certified core expert, who assesses whether the RI&E is complete and reliable and writes advice to the employer. There are four recognised core experts who may carry out this review:
- The senior safety expert, who assesses machine safety, fire, noise and physical safety.
- The occupational hygienist, specialised in hazardous substances, physical strain and exposure to harmful environmental factors.
- The work and organisation expert, with expertise in psychosocial workload and organisational risks.
- The BIG-registered occupational physician, who assesses health aspects such as biological risks and preventive medical examinations.
A common misconception is that only a certified occupational health service as a whole may carry out the review. That is not so: independently established, certified core experts are also authorised. You as the employer are responsible for checking that the person carrying out the review really is certified.
System review and scope review: what changed in 2022?
Since 1 July 2022, tightened rules have applied to the way core experts review. The certification requirements have been adjusted (in Dutch) for the senior safety expert, the occupational hygienist and the work and organisation expert. They have to demonstrate mastery of two main tasks: reviewing the RI&E and advising on improvement measures.
In concrete terms this means that every core expert carries out a system review across the full breadth of working conditions: are all the statutorily required parts present and described? On top of that, the expert carries out a deeper scope review within their own field. This distinction matters (in Dutch): a core expert certified before 2022 is not automatically authorised for the scope review. So always check that the certificate is up to date.
In practice this means that at more complex companies with several risk domains, more than one core expert may be involved in the review. A manufacturer with both machine safety risks and exposure to hazardous substances would be wise to bring in a senior safety expert and an occupational hygienist.
A common mistake: not keeping the RI&E current
The most common mistake we come across is not the absence of an RI&E, but leaving it unchanged for years. The RI&E is not a one-off document. Research by the Labour Authority (in Dutch) shows that employers who work actively with the RI&E control risks better and see fewer people dropping out and fewer accidents. An outdated RI&E gives a false sense of safety and offers no protection during an inspection or after an incident.
Practical steps for a valid RI&E review
Do you want to be sure your RI&E is up to standard? Then take these steps:
- First map how many employees you actually have, including agency and on-call workers, to determine whether a review is compulsory.
- Check whether you are using a recognised sector instrument through rie.nl (in Dutch).
- For the review, bring in a certified core expert whose certificate you can inspect.
- Choose the right expert based on the risks in your company: physical safety calls for a senior safety expert, substances for an occupational hygienist.
- Update the RI&E at every relevant organisational change and record that in writing.
- Make sure employees can see the RI&E and involve the prevention officer actively in the process.
Through Care Concern, within the Arbo Concern group, we work with certified senior safety experts who can carry out both the system review and the scope review in the field of safety. We look not only at whether the document is correct, but also think along actively about realistic and workable improvements for your particular working situation.
An RI&E that sits unchanged in a drawer for years protects nobody, including your company.
An RI&E is a statutory obligation for almost every employer in the Netherlands, but its strength lies in practical execution: a current document, the right reviewer and an action plan that you actually carry out. Get that right and you build a safer workplace and stand firm during an inspection.
Key takeaways
- An RI&E is compulsory for every employer with staff and must contain a current action plan.
- A review by a certified core expert is compulsory if you have more than 25 employees, or if you do not use a recognised sector instrument.
- Four kinds of core expert are legally authorised to review: the senior safety expert, the occupational hygienist, the work and organisation expert and the BIG-registered occupational physician.
- Since 1 July 2022 a renewed certification scheme applies, with a system review across the full breadth and a deeper scope review per field.
- Choose the reviewer based on the risks in your company; with several types of risk, several core experts may be needed.
- Always check that the core expert holds a valid, current certificate, even when they work at a certified occupational health service.
- The senior safety experts at Care Concern are certified for both the system review and the scope review and support you from inventory through to advice.
Want to know whether your RI&E still measures up, or do you need a certified senior safety expert for the review? Get in touch with Dokter Beter; we are happy to think along without obligation.