What needs to be in an RI&E for a refrigeration company?

Every refrigeration and installation company with staff is legally required to have an RI&E. Yet it's often the document that ends up sitting in a folder somewhere until an auditor, the Arbeidsinspectie or an insurer asks for it. Below is what must legally be in it, which risks are specifically relevant to refrigeration engineering, and where companies most often get stuck.

What exactly is an RI&E?

RI&E stands for Risico-Inventarisatie en -Evaluatie (Risk Inventory and Evaluation). It is mandatory under article 5 of the Arbowet: every employer with staff must record in writing which health and safety risks the work involves, how serious those risks are, and what measures are taken to limit them. This applies regardless of company size — even a sole trader with one employee on the payroll cannot escape it.

By law, the RI&E consists of two parts that together form one document:

• The inventory: an overview of all occupational risks within the company, per role or work situation
• The plan of action: a concrete measure per risk, with a deadline and the name of who is responsible for carrying it out

Without a plan of action, the RI&E is not complete, even if the inventory is there.

What specifically needs to be in it?

For a refrigeration or installation company, this includes at least:

• Physical strain: lifting compressors, cylinders and equipment, working in awkward postures (crawl spaces, technical rooms, roof structures)
• Hazardous substances: refrigerants (exposure during leaks or draining off), soldering and welding fumes, cleaning agents
• Working at height: ladders, scaffolding, aerial work platforms for outdoor units and roof installations
• Pressure equipment: risks around refrigeration installations under pressure, including PED-related aspects — see also PED pressure equipment inspection for refrigeration installations
• Electrical safety: working on or near live installations
• Confined spaces: technical rooms, plant rooms with limited ventilation where refrigerant can accumulate
• Psychosocial workload (PSA): work pressure, aggression from customers, undesirable behaviour — this is a mandatory part of every RI&E, not just for office work
• Transport and equipment: company vehicles, tools, lifting aids

For each risk you assess: how many employees are exposed to this risk, how often/for how long, and how likely it is that something goes wrong. Based on that you determine the priority in the plan of action.

Sector RI&E: faster and often free

You don't have to start from scratch. For the installation sector there is a recognised sector RI&E tool (via Techniek Nederland/ArboTechniek, the tool is called CHEPP), and for companies under the cao Metaal & Techniek there is a comparable recognised tool via Metaalunie/OOM. A recognised sector RI&E is tailored to the risks that occur as standard in the sector, which considerably speeds up drawing it up. Check with your own trade association or membership which tool is available for your company and under what conditions (often free or at a reduced rate for members).

Does the RI&E need to be assessed?

This depends on company size:

• Companies with a maximum of 25 employees (in FTE, including temporary agency workers and on-call workers) that use a recognised sector RI&E do not need to have it assessed by a certified occupational health and safety core expert
• Companies with a total staffing of no more than 40 hours per week also fall under an exception
• In all other cases — and in any case above 25 employees — assessment by a certified occupational health and safety core expert or occupational health service is mandatory

Assessment is a separate step from drawing it up: an independent expert assesses whether the inventory is complete and whether the plan of action is adequate.

How often does the RI&E need to be updated?

The Arbowet does not prescribe a fixed validity period, but applies the principle that the RI&E must be "current". That means: with every relevant change in the company you need to check whether the RI&E still holds. Think of a new type of work (for example starting with heat pump installations), a relocation, new equipment, a different refrigerant, growth of the team, or a serious incident. An RI&E that is six months old can already be outdated if the work has changed during that period. As a rule of thumb, a periodic check every three years is often applied, but that does not release you from updating in between whenever there are changes.

Fines for a missing or incomplete RI&E

Since 2019, an inspector from the Nederlandse Arbeidsinspectie can impose a fine directly during a company visit if an RI&E or a plan of action is missing — without giving a warning first. Based on several sources describing the Arbeidsinspectie's fine system, roughly the following maximum amounts apply (scalable to company size, with a reduced rate for small companies):

• Missing RI&E: a fine of up to a few thousand euros, with a considerably lower amount for companies with fewer than five employees
• Missing plan of action (separate from an inventory that is present): also a separate fine
• An outdated RI&E that is no longer current: also finable, but for this a warning usually applies first — a direct fine without a warning only follows on a subsequent, repeated violation

Treat these amounts as indicative — the exact rates per fine category and company size are set out in the Arbeidsinspectie's own enforcement policy rules; check those directly if in doubt.

RI&E versus LMRA and toolbox meeting: not the same thing

A common mistake is confusing the RI&E with the daily safety check on the shop floor. The RI&E is a structural, company-wide document with all the theoretical risks. The LMRA (Last-Minute Risk Analysis) is a short check that a technician carries out just before starting a specific job, at the specific location at that moment — see LMRA template for refrigeration technicians. The toolbox meeting, in turn, is a periodic team discussion about a safety topic — see VCA toolbox meeting: is it mandatory and how often?. The RI&E is the foundation; LMRA and toolbox meetings are additions that respond on the shop floor to what the RI&E cannot foresee.

RI&E and STEK/VCA

During a STEK participant inspection, an up-to-date RI&E, with information and instruction, periodic workplace inspections, PPE and a record of accidents, is checked as standard — unless the company already holds a valid VCA certificate, in which case conformity on this point is assumed. See STEK audit: what does the auditor check during a participant inspection? for the full checklist. For companies that are both STEK- and BRL 100-certified, one up-to-date, well-substantiated RI&E is generally enough to satisfy both audits — provided the refrigeration-specific risks are explicitly included in it.

In practice: how do you get started?

• Ask your trade association (Techniek Nederland, Metaalunie, NVKL) whether a recognised sector RI&E is available for your type of company
• Go through the sector RI&E against your own situation: which risks do and don't apply to you
• Draw up a concrete measure per risk with a deadline and a responsible person — this is the plan of action
• Check whether you fall under the assessment obligation (above 25 FTE, or if you don't use a recognised sector RI&E)
• Schedule a moment to review the RI&E whenever there is a relevant change, and periodically regardless