Chromium-6 and the Working Conditions Act: Obligations for Clients and Contractors

Do you work on maintenance, renovation, or remediation of industrial installations, steel structures, or infrastructure? Then there is a strong likelihood that you will encounter Chromium-6. This substance was widely used in protective coatings due to its excellent resistance to corrosion.

Today, Chromium-6 is recognized as a highly hazardous CMR substance. As a result, strict regulations apply in the Netherlands under the Working Conditions Act and the Working Conditions Decree (Arbobesluit).

For organizations operating in sectors such as Oil & Gas, Offshore Wind, Power Generation, Marine Maintenance, and the Chemical Industry, this means that both clients and contractors carry clear legal obligations. Not only execution matters, but also the choice of surface preparation method, especially when working in ATEX zones or environments requiring strict Health, Safety & Environment (HSE) control.

In practice, technologies such as Pinovo are increasingly considered. Pinovo combines dust free blasting, abrasive recycling, and closed-loop containment, enabling safer operations in ATEX Zone 1 and ATEX Zone 2 environments, without the need for a hot work permit.

Why Chromium-6 Falls Under the Working Conditions Act

Chromium-6 can be released during activities such as:

• Abrasive blasting
• Sanding and grinding
• Cutting coated materials
• Mechanical surface preparation

These activities are common in pipeline maintenance, infrastructure projects, offshore platforms, and petrochemical installations.

When coatings containing Chromium-6 are disturbed, fine particles may become airborne. These particles pose serious health risks, especially in confined environments such as confined space entry scenarios, where proper gas detectionand ventilation are critical.

Exposure can lead to severe conditions such as lung cancer and respiratory damage. Therefore, the Working Conditions Act requires organizations to prevent exposure or minimize it at the source.

This is why there is a shift from traditional open methods to dust free blasting technologies like Pinovo, where emissions are captured directly at the source and secondary containment becomes inherent to the process.

Obligations for Clients

Within Chromium-6 projects, the client typically an asset owner in sectors like Oil & Gas, Petrochemical Industry, or Power Generation plays a key role.

The client must:

• investigate whether Chromium-6 or even lead-based paint is present
• assess risks such as corrosion, coating failures, or corrosion under insulation (CUI)
• define safe working methods in project specifications
• verify contractor competence and certification

Outsourcing the work does not remove responsibility. Authorities assess whether the approach is proportionate to the risk, including the chosen surface preparation method.

In complex environments where downtime is costly and parallel working is required, clients increasingly choose solutions like Pinovo. The system enables maintenance without stopping operations, improving efficiency in maintenance and reducing lifecycle cost (LCC).

Responsibility of the Contractor

The contractor is responsible for safe execution, particularly in high-risk environments such as ATEX Zone 0, Zone 1, or Zone 2 areas.

This includes:

• working according to a defined work or remediation plan
• applying source control and intrinsic safety principles
• using appropriate PPE and safety systems
• ensuring compliance with standards such as ISO 12944, ISO 8501, and NORSOK M-501

The contractor must demonstrate that the selected method aligns with the risk profile.

Traditional open methods such as abrasive blasting or comparisons like hydroblasting vs. abrasive blasting often result in uncontrolled dust, especially when dealing with microplastics or contaminated coatings.

For this reason, closed systems such as Pinovo are increasingly used, particularly for:

• hot spot repairs
• rope access blasting
• work in sensitive environments

These systems allow operations to be classified as cold work vs. hot work, avoiding the need for hot work permits and reducing operational risk.

Become Pinovo Approved

Do you already work with Pinovo or plan to start using the system? Then Pinovo Approved is the way to distinguish your company to clients.

As a Pinovo Approved company you:

• Position yourself as a certified specialist
• Increase your credibility and commercial opportunities
• Are included in the official Pinovo Approved partner overview
• Receive the Pinovo Approved logo for your website and communication

Want to learn more about certification? Contact us for more information.

Source Control as a Core Principle

The Working Conditions Act follows the occupational hygiene strategy, prioritizing:

1. Source control
2. Collective protection
3. Personal protection

This makes technologies like Pinovo highly relevant. By combining dust free blasting, abrasive recycling, and closed containment, Pinovo prevents emission at the source.

This is particularly critical when addressing issues such as:

• pitting corrosion
• crevice corrosion
• galvanic corrosion
• erosion and flash rusting

What Happens When Regulations Are Not Followed?

Failure to comply may result in:

• work stoppages and increased downtime
• regulatory fines
• liability claims
• reputational damage

Additionally, inadequate control often leads to unexpected coating failures, rework, and increased lifecycle costs.

Collaboration Across the Supply Chain

Chromium-6 projects require alignment between:

Client

• risk assessment
• method selection

Contractor

• safe execution
• emission control

Management

• governance and compliance

Regulators assess the full picture: investigation, execution, and chosen method.

In complex industrial environments, Pinovo supports this process by enabling controlled, compliant, and efficient surface treatment, even in demanding sectors like offshore wind, pipelines, and petrochemical facilities.

Conclusion

Chromium-6 work is not just a technical challenge it is a control and compliance issue.

Organizations must demonstrate that risks are minimized, not assumed. This requires a shift toward technologies that integrate containment, safety, and efficiency into the process itself.

That is why solutions like Pinovo are increasingly adopted not only to improve safety, but to enable predictable, compliant, and efficient maintenance operations in modern industrial environments.