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Walk Arbowet Artikel 9 step by step.

The Nederlandse Arbeidsinspectie's recordability rules look superficially similar to OSHA 1904.7 — but the cascade is different. Arbowet Artikel 9 lid 1 triggers on severe outcomes (fatality, hospitalisation, amputation, loss of vision) regardless of days lost. Arbowet 9 lid 2 triggers on absence of more than 3 working days — strict greater-than, not the OSHA "days away from work" recordable-on-1 threshold. Arbobesluit 4.10b adds an occupational-disease branch the US side handles in a separate column. And there's no medical-treatment-only branch + no size or industry exemption: every employer, every outcome, walked the same way.

Walk through your case US OSHA 1904.7 walkthrough →

Why this matters

Arbowet 9 is shorter than OSHA 1904.7 — and that's exactly what trips people.

A US-trained EHS manager who lands at a Dutch plant brings the OSHA 1904.7 cascade with them: "Did the employee need medical treatment?" Under NL law, that's not the question. Arbowet 9 lid 1 records on outcomes that put the worker in serious medical danger (death, in-patient stay, amputation, eye-loss) regardless of whether they ended up missing a day. Arbowet 9 lid 2 records on lost time only when the absence runs more than 3 working days — a stitch + a same-day return is not Arbowet-recordable; three days off + return on day four is not Arbowet-recordable; four days off is.

The disease branch (Arbobesluit 4.10b) handles what the US side splits across columns N and M+1 of the Form 300 — skin disorders, respiratory conditions, poisoning, hearing loss, and "other occupational diseases" all trigger Dutch recording requirements even without an acute injury event. A noise-exposure hearing loss reported by a worker leaves a record in the Dutch system whether or not the worker missed a shift.

And there's no size exemption (OSHA 1904.1's ≤10 employee rule does not exist in Dutch law) and no industry exemption (OSHA 1904.2's Appendix A list does not exist either). Every Dutch employer records under the same cascade, period.

The cascade

How Arbowet 9 + Arbobesluit 4.10b actually decide.

  1. Work-related?

    If no, no Arbowet record. If unsure, hold the determination until the investigation closes — the Inspectie does not look kindly on misclassified "not work related" cases that later turn out to be work related.

  2. Severe outcome? (Arbowet 9 lid 1)

    Dodelijk (fatality) / ziekenhuisopname (hospitalisation) / amputatie or verlies van gezichtsvermogen (amputation or loss of eye). Any one triggers immediate notification to the Inspectie — phone the regional district office first, written submission follows on the ongevallenrapport (accident report).

  3. Occupational disease? (Arbobesluit 4.10b)

    Skin disorder, respiratory condition, poisoning, hearing loss, or other occupational disease — recordable per Arbobesluit 4.10b. Distinct entry on the company's recordable-incident register from the acute-injury entries.

  4. More than 3 working days off? (Arbowet 9 lid 2)

    Strict greater-than. Three days off = not recordable on this branch alone (could still be recordable on severe outcome or disease). Four working days off = recordable on this branch.

  5. Otherwise: not recordable.

    No severe outcome, no occupational disease, absence ≤ 3 working days: no Arbowet record. (Internal company records for the case still belong in the EHS system; the Arbowet rule above is about the regulatory recordable register.)

Common gotchas

The Dutch-specific rules that trip US-trained EHS managers.

  • No medical-treatment branch. A laceration that needed stitches + the worker came back the same day is not Arbowet-recordable. Same scenario under OSHA 1904.7(b)(5) is Recordable.
  • "Werkdagen" = working days, not calendar days. A weekend doesn't count toward the three-day threshold. An injury Friday + return on Wednesday is 3 working days off (Mon/Tue/Wed) = not recordable. Return on Thursday = 4 days = recordable.
  • Hospitalisation includes day-stays for observation. NL "ziekenhuisopname" is broader than the OSHA overnight-hospitalisation threshold; even an outpatient observation stay can trigger the record. Document the admission disposition + check with the treating hospital.
  • Disease branch is independent of the days-away branch. A noise-exposure hearing loss is recordable under Arbobesluit 4.10b regardless of whether the worker missed any days — the disease itself is the trigger.
  • Filing window for severe outcomes is "as soon as possible." No defined hour count in the rule; in practice the Inspectie expects a phone call within hours and the written ongevallenrapport follow-up within a day or two.

Walk your case through the cascade.

The interactive walkthrough asks four questions — work-relatedness, outcomes, days-away count (when applicable), and whether the case is an injury or an occupational disease — and produces the verdict with citations. Bilingual labels throughout.

Open the walkthrough NLA filing portal ↗

SE walks this same Arbowet 9 cascade for every customer incident at a Dutch establishment — with the bilingual citation trail attached, the ongevallenrapport renderer wired in, and the postcode-prefix district routing applied. See SE's multi-jurisdiction depth →

Companion tools: US OSHA 1904.7 walkthrough · Where do I report this? (jurisdiction finder) · OSHA Rate Calculator.