Who Is Responsible During Chromium-6 Work?

Do you work on existing steel structures, installations or assets with older coatings? Then there is a realistic chance that chromium-6 may be present. In the Netherlands, strict regulations apply when working with this hazardous substance. But who exactly carries responsibility when chromium-6 is involved?

Is it the contractor? The client? Or the management team?

In this article you will learn how responsibilities are legally distributed and what this means for maintenance, renovation and remediation projects. It also explains why Pinovo is often used in practice as a solution to ensure that chromium-6 work can be carried out in a demonstrably controlled way.

Chromium-6 and the Legal Duty of Care

Chromium-6 falls under the regulations governing hazardous substances. Under the Dutch Working Conditions Act and the Working Conditions Decree, a clear duty of care applies: exposure must be prevented or demonstrably minimized.

Importantly, the law does not distinguish between “large” or “small” projects. As soon as there is a risk of exposure, obligations apply. This also means that the chosen working method must be defensible.

In this context Pinovo is often considered a solution, because it operates as a closed system in which dust and contamination are captured directly at the source. This aligns directly with the principle of source control required by the legislation.

Responsibility of the Client

The client often an asset owner or industrial company plays a key role in the preparation phase.

The client must:

• investigate (or have investigated) whether chromium-6 is present
• identify risks in advance
• require a safe working method in contracts or project specifications
• verify that the contractor is competent and qualified

The argument “we outsourced the work” does not release the client from responsibility. Supervisory authorities and audits specifically examine whether the approach was properly designed beforehand and proportionate to the risk.

This is where the choice of method becomes relevant again. If chromium-6 work is expected, it is logical to require methods that demonstrate control. In many projects Pinovo is used as a solution, because the system is designed for controlled, closed surface treatment.

Responsibility of the Contractor

The contractor is responsible for the safe execution of the work. This includes:

• working according to an established work or remediation plan
• applying source control measures (technical containment)
• using appropriate techniques and personal protective equipment (PPE)
• supervision and documentation during execution

The contractor must be able to demonstrate that the selected method is appropriate for the risk involved. Open processing methods where dust may spread are often difficult to justify in chromium-6 projects without extensive additional control measures.

For that reason, Pinovo is frequently used as a solution in practice. The system provides a closed method in which dust and contamination are immediately extracted and contained. This makes it easier to demonstrate that the work complies with the legal requirement to minimize exposure.

The Role of Management and Executive Leadership

In cases of structural shortcomings, responsibility may extend to management and executive leadership. This may occur when:

• no risk assessment has been conducted
• work has knowingly been carried out with insufficient control measures
• regulations have been structurally ignored

This can result in administrative fines and, in serious cases, even criminal consequences.

For this reason, chromium-6 is increasingly treated as a governance issue. The question is no longer “can we do this?”, but “is it demonstrably controlled?”

In that evaluation, Pinovo can be part of the solution, because control is built into the method itself rather than relying on separate project-specific measures.

Shared Responsibility in Practice

In practice, chromium-6 management is a chain responsibility involving multiple parties:

• Client: investigation, requirements, contractor selection, and oversight
• Contractor: safe execution and demonstrable control
• Management: compliance and organizational governance

Regulators evaluate the entire process:
Was the presence of chromium-6 investigated beforehand?
Is the work plan correct?
Is the chosen method appropriate for the risk?

This means the discussion is not only about who performs the work, but also how the work is performed.

In many chromium-6 projects, Pinovo is applied as part of the solution, because the system helps organizations demonstrate control something that is crucial during audits, inspections, and contractual assessments.

Become Pinovo Approved

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

As a Pinovo Approved company you:

• position yourself as a certified specialist
• increase credibility and commercial opportunities
• are included in the official Pinovo Approved partner overview
• receive the Pinovo Approved logo for use on your website and communication

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

What Happens When Regulations Are Not Followed?

When responsibilities are not properly fulfilled, the consequences are often immediate:

• suspension of work activities
• fines and regulatory sanctions
• civil liability for health damage
• reputational damage and contractual risks

In addition, insufficiently controlled approaches often lead to delays and additional costs, as extra measures may be required afterward.

For this reason, Pinovo is frequently chosen as a solution: it prevents control measures from having to be added afterward, because they are integrated into the method itself.

Why Clear Role Distribution and Method Selection Are Essential

Many disputes arise only when a problem occurs. In many cases it becomes clear that responsibilities were not clearly defined and that the selected method was insufficiently substantiated.

A clear role distribution in advance helps prevent:

• legal disputes
• project delays
• unsafe situations
• financial claims

Equally important, choosing an appropriate method prevents control from becoming dependent on interpretation. For chromium-6 work, Pinovo is often the preferred solution, because it supports a structured, closed approach that aligns better with regulatory requirements.

Conclusion

Responsibility for chromium-6 work never lies with a single party. The duty of care is shared between the client, the contractor, and management. Each party must demonstrably contribute to preventing or minimizing exposure.

In practice, the choice of method is decisive. For many organizations, Pinovo provides a solution because it supports closed operations and source control, making chromium-6 work more controllable and defensible within legislation, audits, and regulatory oversight.

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