During an action day on March 26, 2025, in Rotterdam, the Risky Substances Supervision department of the Human Environment and Transport Inspectorate (ILT) conducted a total of 75 inspections. 51 violations were found, ranging from leaks and improper securing of cargo to lacking the proper training and mandatory certificates. 65 inspectors participated in the action day, supported by drone inspectors and sampling inspectors.
The ILT focuses its supervision on risky substances such as the transport of dangerous goods, high-risk companies, chemical risks, and genetically modified organisms. It also targets legionella prevention, the production and trade of chemical substances (REACH), biocides, and (precursors for) explosives.
Protection of People and Environment
“In a time when the environment is under pressure, innovations are rapid, and transport is increasing, living in a clean, safe, and healthy environment is not always a given. We ensure compliance with various (European) regulations for risky substances and products,” says department head Paul Weststeijn. “With dangerous substances, you expect great care from everyone who works with them. Small quantities can sometimes already be dangerous to people, animals, and the environment. Unfortunately, this action day shows once again that our supervision is urgently needed.”
Inland Waterway Inspections
The ILT conducted 11 inspections on the transport of dangerous goods via the inland waterway, where 9 violations were found and administrative enforcement was applied 3 times. For example, there was a skipper transporting 4 containers with dangerous goods on his dry cargo ship without an ADN certificate. A report was drawn up for this. The ADN certificate shows that a skipper knows the regulations for transporting dangerous goods over water. The 4 containers were removed from the ship by order of the ILT. Also, no safety advisor was appointed by the transporter. This advisor informs stakeholders, establishes procedures, and analyzes incidents. Finally, the crew had not followed ADN training.
Sea Transport Inspections
During the action day, 13 RoRo checks were carried out. RoRo stands for ‘Roll on-Roll off’; this involves loading trucks (trailers) onto a ship and rolling them off at the ships destination. The trailers must comply with dangerous goods legislation for sea transport. 4 violations were found, with 3 trailers being stopped. In 1 trailer with both dangerous and non-dangerous goods, the non-dangerous goods were not secured, and the dangerous goods lacked the required labels on the outside. Loose cargo can shift due to sea swell, causing damage to the dangerous goods cargo. This can lead to leaks, chemical reactions, and, for example, fires in batteries. In an incident, rescuers are also at great risk if it is not visible from the outside which dangerous goods are in the trailer.
Railway Inspections
At the Maasvlakte railway yard, 77 tank cars and 5 tracks were checked, but no violations were found. At the Botlek railway yard, the ILT encountered 6 tank cars with drip leaks. Earlier this month, the ILT had blocked these cars due to leakage. The ILT placed a dogstar (closure cap) on both sides of all these cars. Additionally, a tank car leaking ethanol was blocked by the inspection.
Drip leakage of dangerous goods is - aside from a legal violation - a risk to people, animals, and the environment. Depending on the substance properties, this can lead to physical complaints such as headaches, dizziness, and skin burns. For (very) flammable substances, there is also the danger of (pool) fires, which may radiate to other cars.
Aviation Inspections
The ILT visited 4 B-recognized holders, which are companies authorized to offer the transport of dangerous goods to airlines. 8 violations were found. For example, 3 of the 4 companies did not perform the mandatory incoming and outgoing air cargo checks. This poses the risk that goods not complying with regulations enter the supply chain. Or that it is unknown that the cargo contains dangerous goods. At all companies, the training program was not in order. If employees are not properly trained for the tasks and authorities they have, there is a risk of incorrect air transport of dangerous goods.
Road Transport Inspections
17 trucks were checked for the road transport of dangerous goods. 1 or more violations were found in 12 trucks. This resulted in 6 warnings and 6 reports. 5 violations involved the improper or incorrect securing of cargo (stowage). If a dangerous goods cargo is not properly secured, it can shift or fall. This can release the dangerous substance from the packaging, posing risks to the environment. In 1 case, it was found that a dangerous substance remained on the outside of the packaging. The packaging was not cleaned after filling. If this substance comes into contact with the skin or eyes, it can cause severe burns.
Other violations were found, including incorrect or incomplete filling of transport documents, incomplete safety equipment for the driver, an expired ADR certificate for transporting dangerous goods, and incorrect attachment of the orange board. All detected violations were corrected on the spot.
Explosives Inspections
The ILT conducted 3 checks on compliance with the Explosives Precursors Act. Precursors are raw materials for making explosives. Compliance with the rules is important to reduce the risk of precursors falling into the wrong hands. All 3 inspected companies did not adequately comply with the reporting and/or verification obligation. This can increase the risk of misuse.
Legionella Control
On the action day, 1 hotel in the area received a warning after a legionella inspection. In April 2024, this hotel was required to prepare a legally mandated legionella risk analysis, including adjustments to the drinking water installation. However, during the inspection, it was found that the adjustments had not yet been implemented. This may increase the risk of legionella contamination. The hotel must provide the ILT with an action plan to carry out the repairs within 1 week.
High-Risk Companies Inspections
On this day, the ILT inspected various small companies conducting loading and unloading activities with dangerous goods. The inspection was to see if these companies are aware of the legislation applicable to them. Experience shows that smaller companies are not always aware of the rules. However, no violations were found.
Additionally, an inspection was conducted with colleagues from the inland waterway team at a company in the Botlek where violations had been found earlier. Again, the ILT found multiple violations regarding ADR and IMDG (regulations for the transport of dangerous goods by road and sea, respectively). The internal procedures and work instructions regarding subsequent sea transport were found to be incomplete. This poses risks for (new) employees who do not know which procedures must be followed for the transport of dangerous goods by sea.