From which employee this starts to apply
RI&E sounds like something for a factory with forklifts. It is the risico-inventarisatie en -evaluatie, the risk inventory and evaluation in English, and it is the document the Dutch Labour Authority asks for first the moment they walk in.
The duty starts with your first employee. Article 5(1) of the Working Conditions Act says you record in writing what risks the work brings for your employees. There is no lower threshold of three or five people underneath it.
And it reaches further than people on an ordinary contract. Article 1 of the Act also counts anyone performing work under your authority without an employment contract as your employee. A BBL apprentice and an intern therefore count. Only people working as genuine volunteers fall outside.
For a salon that means: the day your first staff member starts, this duty comes into being. The same day as your registration with the Tax Administration and your pension obligation, which you will find in the guide on hiring your first employee.
The good news comes further down: with the free instrument published by the trade itself, this is an afternoon of work for a salon with one or two staff. The bad news is that not having it is directly finable.
The five duties side by side
Five things come into being with staff, and they get lumped together often.
| Duty | What it means | Basis |
|---|---|---|
| Written RI&E | Record what risks the work brings, including for special groups | Article 5(1) Working Conditions Act |
| Plan of action | Which measures you will take, with deadlines, forms part of the RI&E | Article 5(3) Working Conditions Act |
| Prevention officer | Compulsory; up to 25 employees you may be it yourself | Article 13(10) Working Conditions Act |
| Basic occupational health contract | Arrangements with an occupational health service or physician, for every employer, recorded in writing | Article 14(2) and 14(4) Working Conditions Act |
| Keeping it current | Update on new working methods, circumstances or experience | Article 5(4) Working Conditions Act |
The basic contract is the item salons skip most often, because a monthly fee hangs off it. It arranges among other things how everyone working with you can reach the company doctor, and that you have someone to call when absence starts. What happens once someone is off sick longer sits in the guide on sick pay rules for a small Dutch salon.
Prevention officer sounds heavier than it is. Article 13(10) says that at employers with no more than 25 employees the tasks may also be carried out by the employer personally, provided they have sufficient expertise, experience and equipment. For most salons the owner is the prevention officer.
Why your RI&E does not need expert review
This is the single biggest practical saving in the whole subject, and it is rarely mentioned.
In principle an RI&E has to be reviewed by a certified expert, and that costs money. The exceptions sit in article 14(12) of the Working Conditions Act, and it pays to read that text rather than a summary of it.
Part a covers an employer where paid work totals at most 40 hours a week across all staff together. Part b covers an employer with as a rule no more than 25 employees, and that one can go two ways: a model included in a collective agreement or in a regulation by a competent authority and carrying no obligation, or an instrument that has been notified to the minister or to a body the minister has designated.
For a salon with one to five staff that second route is the ordinary path. You use your own sector's notified instrument and the review requirement falls away. From 26 employees the exception no longer applies, but for a salon that is rare. If your collective agreement carries an RI&E model, that route works just as well.
Watch the term. The statute says notified, rie.nl says recognised, and that is trade shorthand for the same register. What matters is that the instrument is actually in that register, not that a trade body made it. A homemade checklist or a free template from a consultancy does not lift the review requirement.
Watch the scope too, because this is where summaries go wrong. The exemption applies only to the opening words and part a of the first paragraph: reviewing and advising on the RI&E. Your duty to take expert support on guiding sick employees and on occupational health examinations stays fully in place. Source: article 14 of the Working Conditions Act on wetten.overheid.nl, plus rie.nl and nlarbeidsinspectie.nl. Checked September 2026.
From 1 June 2026 a revised recognition procedure applies. Steunpunt RI&E grants the recognition after certified experts have reviewed a sector instrument, and existing recognitions stay valid until their agreed end date. The alternative procedure for sectors without collective bargaining parties has lapsed. So check in the register that the instrument you pick is currently recognised before you lean on it.
The free sector instrument for hairdressers
For hairdressers that instrument exists. It sits at rie.nl/instrumenten/kappers, is published by Branche Platform Kappers, is listed in the register as recognised, and is free.
You work through a questionnaire about your own salon. The topics are those of this trade rather than an office: physical strain from long standing and working overhead, skin strain from wet work and from colour and bleach, exposure to substances and to hair dust, ventilation, noise, workload and Saturday peaks, aggression at the desk, and the special position of young workers and pregnant staff.
That last point is not a formality in this trade. A salon with a seventeen-year-old BBL apprentice employs a young worker, and the Act asks for extra attention to that group. The same holds for a pregnant staff member working with colour.
Set aside an afternoon and involve your staff. Do not work through the questionnaire alone behind your laptop, because part of the answers sit with the people using the basin eight times a day. Half an hour with your team produces an RI&E that is accurate rather than one that has been filled in.
Save the result as a PDF and make sure your staff can reach it. The Act requires the RI&E to be accessible to employees.
Not a hair salon? Check whether your trade has an instrument
The list of sector instruments on rie.nl runs to more than two hundred entries. Pedicures have one, the Voetverzorgingsbedrijf instrument issued through ProVoet. For a beauty salon, a nail studio, a massage practice or a wellness business there is no instrument on that list. Checked September 2026.
Look at the registration and not at whether something exists. rie.nl marks the hairdressing instrument as approved and the foot care one not, and it is that registration that removes the review duty. An instrument that exists but is not in the register does nothing for article 14(12), so check its status there before you count on it.
If your trade is not listed, you use a general instrument. That is allowed and it beats having no RI&E, but it takes more work and it does not earn you the exemption. The questionnaire is not written for your trade, so you have to work out yourself that acrylic dust and the extraction above a nail table belong in it, or a massage therapist's working posture, or working with peels and equipment in a beauty salon. Without a registered instrument the second route under part b falls away, and only the 40 hours of paid work per week threshold is left.
Ergonomics is the first risk the Arbocatalogus names
Physical strain sits at the top for a reason. The Arbocatalogus Kappersbranche names it as the first risk, alongside hazardous substances and psychosocial load. The sector instrument asks about it separately too: prolonged standing and overhead work sit in the questionnaire as their own topic.
Ergonomics in a salon comes down to a few things you control yourself. That includes the working height of the chair and the wash basin, so a staff member is not working with raised shoulders all day, and alternating overhead cutting with work where the arms stay low, spread across the day instead of stacked back to back. Who runs the wash basin matters too, because that is where back and shoulder complaints in this trade most often start.
Do not expect a legal norm. No primary source sets a maximum for standing time or a prescribed working height for hairdressers, so do not treat any number you come across as a measured fact. What counts is that you name the risk in your RI&E and put a measure against it in your plan of action, with a name and a date, the same as your other risks.
The cheapest measure sits in the rota, not in new equipment. Alternate overhead work with cutting, share the wash basin across the team instead of leaving it to one person, and schedule a break on Saturday instead of running flat out. That is exactly where staff scheduling and health and safety duties meet, see the guide on staff scheduling for hair salons for how to build that rota in practice.
Write the agreement down, even a small one. An adjustable chair, a fixed switch point between overhead work and cutting, a rule for who runs the wash basin, that belongs in the plan of action just as much as the extraction above the colour bar.
The plan of action is where it goes wrong
An RI&E without a plan van aanpak, the plan of action in English, is half a document, and that is exactly what the Authority most often finds.
Article 5(3) says the plan of action forms part of the RI&E: which measures you will take for the risks you identified, and within what period. It is both, because a measure without a date is not a plan.
Keep it small and true. Four to eight lines is often enough for a salon. An adjustable chair for the staff member with back complaints, with a date. Gloves when rinsing colour, with a check moment. The extraction above the colour bar inspected, with a month against it. A second person in the salon on the late opening night.
Put a name and a date against every line. Run through the list twice a year and tick off what has happened. That ticking off is your evidence that you keep the document current, which is what article 5(4) asks: update as often as experience, changed working methods or changed circumstances give cause.
Concretely: a new staff member, a new colour line, a refit or a second chair is each a reason to pick the RI&E back up. The law sets no fixed interval, which tempts people into never doing it again.
What a fine actually costs at your company size
Scare figures of thousands of euros circulate around this subject. They are not invented, but they do not apply to a salon, and here is why.
The standard fines are 4,500 EUR for a missing RI&E and 3,000 EUR for a missing plan of action. Both are designated as directly finable offences, so no warning has to come first.
Those standard amounts are then scaled by company size under the Beleidsregel boeteoplegging arbeidsomstandighedenwetgeving. The standard amount belongs to a business of 500 employees or more, and smaller businesses pay a percentage of it.
| Number of employees | Percentage | No RI&E | No plan of action |
|---|---|---|---|
| Fewer than 5 | 10 percent | 450 EUR | 300 EUR |
| 5 to 9 | 20 percent | 900 EUR | 600 EUR |
| 10 to 39 | 30 percent | 1,350 EUR | 900 EUR |
| 40 to 99 | 50 percent | 2,250 EUR | 1,500 EUR |
So for a salon with three staff that has neither document, the total is 750 EUR. That is not a figure that pulls your business over, and it is also not a figure you want to pay for something that is free and takes an afternoon.
Two things weigh heavier than the fine itself. Where a document is incomplete, a warning or a formal demand comes first in principle, and you then get a deadline to put it right. And if something happens, a staff member with a back injury or a client with a reaction, a current RI&E with a plan of action is the document that shows you took your duties seriously. That touches your liability and your insurance, which comes up in the guide on insurance for a new Dutch salon and in the guide on handling client complaints.
You do not submit the RI&E as a matter of course, incidentally. The Labour Authority requests it only during a targeted inspection, with a deadline stated in the letter.
What to do this week
Day 1: check whether you have a basic contract with an occupational health service or physician. If not, get two quotes. This is the only item carrying a monthly fee.
Day 2: open rie.nl/instrumenten/kappers, confirm in the register that the instrument is recognised, and create an account.
Day 3: work through the questionnaire with your team present. Set aside an afternoon and answer the questions about the basin, the colour bar and the Saturday rush honestly.
Day 4: write your plan of action. Four to eight lines, each with a name and a date. Save the RI&E and the plan together as a PDF and put them somewhere your staff can reach.
Day 5: set two reminders in your diary. One in six months to tick off the plan of action, and one at every new hire or refit to pick the RI&E back up.
For that last part it helps that your scheduling is visible. In CelerBook every staff member sits in the diary with their own working hours, so you can see at a glance who is structurally alone in the salon on the late night and who is fully booked three Saturdays running. Those are exactly the two things a salon RI&E raises under workload and lone working. You can set a different duration per staff member for the same treatment, which helps you build a diary that is achievable rather than one that merely fits on paper. Confirmations go out by email. The first 5 appointments each month are free, then 0.25 EUR excluding VAT per completed appointment, capped at 30 EUR a month for a solo operator plus 5 EUR per additional active staff member. No contract. Try CelerBook for free.
