The ARIE regulation has been in force in the Netherlands since January 2023. Its purpose is to prevent major workplace accidents involving hazardous substances and protect employees’ safety. Employers bear most of the responsibility for achieving that goal. The Netherlands Labour Authority recently published a report on the implementation period and compliance with the regulation. Charlotte Kottier, MHC (Major Hazard Control) program manager, and Carlo de Deckere, coordinating MHC project manager, discuss the initial findings. The central theme: turning awareness into good habits.
The ARIE regulation (Additional Risk Inventory and Evaluation) is a requirement under occupational health and safety legislation for all companies in the Netherlands that work with large quantities of hazardous substances. The regulation focuses on managing the risk to employees of major accidents involving these substances. Companies themselves are responsible for notifying the authority if they are subject to ARIE. Whether that applies depends on both the quantities present and the hazards posed by the substances on site.
Carlo: “In practice, we find that knowing when ARIE applies is linked to a company’s experience in working with hazardous substances and managing the risk of a major accident. Some business owners have more experience than others in taking an analytical and systematic approach to these risks. That may also make them more aware of their obligations as a company subject to ARIE. Companies that use hazardous substances in their core processes, such as those in the chemical industry, are also aware of the requirements and have notified the authority. Companies where these substances are present as byproducts, such as those in the food processing industry, may not realize that ARIE applies to them.”
“Yet hazardous substances are widely used in the food industry,” Charlotte adds. “Think of chemical disinfectants used in all kinds of cleaning procedures, or a substance like ammonia in refrigeration and freezing systems. Ammonia, for example, is toxic and flammable.” Under the revised legislation, the ammonia threshold is strictly linked to 30% of the lower-tier Seveso threshold. Companies that previously fell just below the threshold now exceed it more readily. Certain flavorings and processing aids can also pose a fire hazard.
Carlo: “The pitfall is that people underestimate the hazards. They think, ‘Oh, we only use them occasionally. The risk isn’t that high.’ That can also make them less vigilant about preventing accidents.”
Charlotte: “The incident at Friesland Campina in Borculo is a good example of the type of accident we are talking about. Two hazardous substances were accidentally mixed together. That caused a massive explosion. The site was out of operation for months. Although major accidents are relatively rare, you have to consider these situations, even when they seem almost unimaginable. Accidents can happen when you least expect them. So ask yourself: ‘What if it does happen? How would we respond?’ The regulation sets out the steps you need to take to prevent major accidents involving hazardous substances and limit their consequences, such as developing a policy, drawing up scenarios, preparing and implementing an internal emergency plan, and so on.” Carlo: “Make no mistake: this can also involve much smaller incidents. An unintended, uncontrolled release of a quantity of a hazardous substance that exposes or could expose employees falls under the definition of a ‘major accident.’”
Charlotte: “Through our oversight, we want to give companies a wake-up call and raise awareness. The aim is to make sure companies fully understand that exposure to hazardous substances can cause serious health problems for their employees.”
Carlo: “To determine whether ARIE applies to you, you first need to know exactly which hazardous substances are used in your company, where they are stored, and the maximum quantities present in the installations. That information is sometimes missing. Companies also often fail to realize that a temporary spike in inventory or a change in CLP classification can suddenly put them above the thresholds. Or they overlook the aggregation rule. This is the sum of several smaller quantities of substances within the same risk category—for example, toxic substances—which can still push the total above the threshold.”
“All inspections are announced in advance, which makes them more effective,” Carlo begins. “It is important to mention that most companies are very cooperative. Inspections generally take place in a constructive atmosphere. After a cup of coffee and a chat, we go through the scenarios together. We focus on checking the procedures in place and the measures described. Are they complete, and are the relevant people aware of them? We carry out very focused inspections: on the shop floor, in the factory, at the installation. What scenarios could result in an uncontrolled release of the hazardous substance, putting employees at risk? What measures has the company taken to prevent hazards? Are the people working with these substances aware of those measures? When an inspector enters the plant with a scenario, it should lead them directly to the location it describes: straight to the equipment, machine, or cabinet where the hazardous substance is stored or could be released. In practice, we often see generic scenarios being used. Companies still have plenty of room for improvement here.”
Carlo: “Many companies use consultancies to implement the ARIE regulation. These firms provide templates, which then need to be tailored to the company’s operations and processes. I don’t know whether it’s a lack of time or understanding, but this tailoring is sometimes inadequate. Simply having the scenarios on file does not mean everything is in order. As an employer, you still have to put in a substantial amount of effort yourself. An outside consultancy will never know as much about your installations as the operators who work on and with them every day. No one knows your company’s processes better than they do. So involve them in developing the scenarios.”
“I completely understand why companies hire a consultancy,” Charlotte responds. “Many business owners think, ‘What do I have to deal with now?’ Still, I firmly believe that employers should do this for more than just legal compliance. The fundamental principle should be that your employees’ safety comes first. I believe in that wholeheartedly! Getting this right is part of being a good employer. Implementing the ARIE regulation is also about safeguarding the continuity of your business. If you approach implementation properly, it helps keep your business running reliably.”
“Good scenarios address the parts of installations that pose significant risks,” Carlo explains. “They also describe possible causes of hazards and risks. Think of corrosion, erosion, vibration, and external loads, damage caused by overpressure and/or underpressure, and the human errors that can occur during operation or maintenance. For each scenario, you need to specify how likely it is to occur, what the consequences would be if something went wrong, and what measures have been taken to prevent accidents. What do you do if a pipe ruptures or a valve fails in the refrigeration system? Putting these scenarios and plans into practice helps employees better understand what working with hazardous substances involves. I’m not saying they should be afraid of them, but they do need a very clear understanding of the inherent hazards.”
“The regulation also requires you to make sure that you and your employees stay vigilant once those measures are in place. Does everyone understand why they need to wear certain PPE (personal protective equipment), such as a face shield when adding more of a chemical? During an inspection, I heard an employee say that he never uses one. His reason was that he already wears safety glasses. It is true that those glasses protect the eyes. But they do not protect the rest of your face if your skin comes into contact with a substance that is corrosive to skin! So you need to maintain the measures you have put in place, keep your people informed, train them, and continue providing refresher training.”
Carlo: “Yes, that is a requirement under the ARIE regulation. Fortunately, we have seen companies reporting these incidents more often in recent years. When an accident is reported to us, we investigate it as the Netherlands Labour Authority, even if no one has been injured. Companies are also required under ARIE to investigate accidents and near misses themselves. This is part of the safety management system they are required to have. We can also request and assess those internal investigations. We are a regulatory authority. Where necessary, we will of course take enforcement action. If a company fails to report an accident and we find out later, we can impose a fine directly. Those fines are substantial. But we don’t lead with threats of fines.”
“Absolutely not!” Charlotte agrees emphatically. “The main purpose of the reporting requirement is to make companies aware of the hazards and ensure they do everything possible to avoid them. That is exactly why it is important to report everything, including minor incidents. We can learn from each other. What if the incident had been bigger? What would the impact have been then? Would you have needed different measures? With that possibility in mind, do you need to change your organizational practices and/or protocols? Organizations need to make this way of thinking about scenarios and safety part of their everyday practices.”
“I hope companies will embrace the regulation because they truly believe in its purpose,” she concludes passionately. “Ultimately, all of us—the Netherlands Labour Authority and employers alike—want people to return home safe and healthy at the end of their workday. That is in all of our interests!”
The report ‘ARIE Implementation Report 2023–2025’ can be downloaded from the Netherlands Labour Authority’s website.
Nlarbeidsinspectie.nl
Photos: ©Louis Meulstee Visuals
Source: Vakblad Voedingsindustrie 2026
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