Which Records Should I Keep for Pallet Racking to Comply with ARBO, BBL, WKB and Other Standards?
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Please note: this article discusses Dutch legislation and standards (the Arbowet, the Bbl, the Wkb, and NEN-EN standards). The information below applies to the Dutch situation and may not be directly applicable in other countries.
In relation to NEN-EN 15635, the Dutch Working Conditions Act (Arbowet), RI&E and the Wkb/Bbl
Introduction
Pallet racking in logistics environments is generally regarded as equipment, but it has structural characteristics that fall under building regulations. As a result, it does not fall exclusively under NEN-EN 15635, but also within the framework of the Buildings (Living Environment) Decree (Besluit bouwwerken leefomgeving, Bbl) and, in some municipalities, the Quality Assurance for Construction Act (Wet kwaliteitsborging voor het bouwen, Wkb). Finally, pallet racking is also regarded as work equipment within the meaning of Dutch occupational health and safety (ARBO) legislation, with associated inspection and maintenance obligations. Rack.Parts, incidentally, expects the Wkb to apply in the future to all warehouses where pallet racking is installed. For the PRSES (the person responsible for the safety of the storage systems, see this article), this means that record-keeping must substantiate both operational safety and structural compliance. The documentation must demonstrate that the system has been correctly designed, realized and managed throughout its entire service life.
Below we provide an overview of the areas to which record-keeping applies and which data, in our view, should be included in the documentation.
1. Initiation phase: starting points and risk analysis
- When: Before proceeding to the layout and purchase of racking
- Load data (weight, storage height, intensity of use)
- Logistics movements and type of internal transport
- Floor load and load-bearing capacity
- Building layout, escape routes and fire compartmentalization
- Risk inventory (collapse, collision, falling loads)
2. Design and specification phase
- Structural calculations in accordance with the relevant European standards (to be provided by the supplier)
- Load specifications and force distribution on the floor and structure (to be provided by the supplier, and to be signed off in writing by a structural engineering consultancy, or based on existing data on the warehouse floor)
- Technical drawings and layout (supplier)
- Anchoring plan and system configuration (supplier)
- Standard declarations and product specifications (supplier)
In our view, it is essential that design choices are traceable and verifiable. This means that the technical substantiation must be present in the documentation in full and in a way that can be checked.
3. Purchase and contract phase
- Contract documents and technical descriptions
- Supplier responsibilities (design, delivery, installation)
- Warranty terms and liabilities
- Maintenance and usage instructions
The documentation must provide insight into who is responsible for design, execution and quality assurance.
4. Installation and commissioning phase
- Assembly and installation reports
- Commissioning inspection and verification of design conformity
- Measurement reports (alignment and tolerances)
- Anchoring inspection
- As-built documentation
- Load capacity signs and markings
- Initial inspection (baseline measurement)
5. Usage and management phase
Inspections
- Daily and weekly visual checks by trained staff
- Periodic internal inspections by trained staff, together with the PRSES
- Annual inspections by experts
Damage management
- Registration and classification of damage
- Photo documentation
- Root cause analysis
Measures and changes
- Repair and replacement measures
- Temporary safety measures
- Changes in configuration or load
6. Relationship with the Arbowet and RI&E
The documentation as described above supports compliance with the Arbowet by demonstrating that risks are systematically controlled. In addition, it provides direct input for the RI&E, including substantiation of measures and residual risks.
7. Integration with the Wkb (if required) and the Bbl
| Component | PRSES documentation | Wkb/Bbl context |
|---|---|---|
| Design | Technical specifications | Structural safety |
| Realization | Assembly and commissioning | Quality assurance of execution |
| Use | Inspections and maintenance | Safe use of the building |
| Deviations | Damage and repair | Registration and follow-up |
8. Recommended documentation structure
- General project information and responsibilities
- Design documentation and calculations
- Contract and delivery documents
- Realization and commissioning documentation
- Inspections, maintenance and damage history
- Changes and reassessments
- Compliance and links to legislation
Conclusion
Record-keeping by the PRSES forms an essential part of both operational safety and legal compliance. The documentation acts as an integral tool in which the requirements from NEN-EN 15635, the Arbowet, the RI&E and the Wkb/Bbl come together.
A structured and complete set of documentation makes it possible to keep risks under control, safeguard responsibility and demonstrably comply with applicable regulations.
Want to know more? Feel free to contact us if you have any questions or would like to discuss this further.
