The commercial vehicle is a workplace
Under Belgian law, any location where work is carried out qualifies as a workplace. This includes commercial vehicles. A delivery van, a service truck or a mobile workshop is subject to the same employer obligations as a fixed office or factory floor.
This principle is rooted in the EU Framework Directive on Safety and Health at Work (89/391/EEC), which requires employers to ensure the safety and health of workers in every aspect related to work. Belgium transposes this through the Codex over het welzijn op het werk (Code of Well-being at Work), a comprehensive set of regulations covering everything from risk assessment to first aid provision, hygiene and workplace design.
The Royal Decree on First Aid (KB Eerste Hulp) further specifies that employers must provide adequate first aid resources at every workplace. Since a commercial vehicle is legally a workplace, the vehicle itself must be equipped accordingly. There is no exemption for mobility, size or the nature of the work being performed.
For fleet operators, this means that every vehicle in the fleet carries the same legal obligations as a permanent site. Ignoring this does not reduce liability. It increases it.
What Belgian law requires for mobile workplaces
Belgian regulations impose several concrete obligations on employers operating mobile workplaces. These are not recommendations. They are legal requirements that apply regardless of fleet size.
First, employers must ensure that first aid supplies are accessible in every vehicle. The DIN 13164 standard is widely accepted by Belgian labour inspectors as meeting the required level of provision. A compliant kit must be complete, within expiration dates and stored in a fixed, known location. Read more about DIN 13164 requirements.
Second, where there is a risk of chemical splash or particulate exposure, eyewash facilities must be available. This applies to many trades: cleaning services, pest control, maintenance technicians and construction workers all face potential eye hazards. A sterile eyewash solution must be within reach. Read more about eyewash regulations.
Third, basic hygiene facilities must be provided. Workers need the ability to clean their hands during and after tasks. For mobile workplaces where running water is not available, soap and paper towels serve as the practical minimum.
Fourth, a risk assessment (risicoanalyse) must be conducted and documented for every work situation, including vehicle-based work. This assessment should identify the hazards specific to the mobile environment and specify the safety measures in place.
Fifth, employers must either designate a trained first aider or ensure that workers have received basic first aid training. Someone on site, or in the vehicle, needs to know how to use the equipment provided.
What inspectors look for
Belgian labour inspectors (Toezicht op het Welzijn op het Werk) conduct both scheduled and unannounced inspections. When they inspect a commercial vehicle, their checks are straightforward and practical.
They verify that first aid equipment is present and that it meets the required standard. They check whether all items are within their expiration dates. They confirm that the equipment is stored in a known, accessible location, not buried under tools or cargo.
Inspectors will also ask whether workers can identify the location of safety supplies and whether they know how to use them. A first aid kit that nobody can find, or that nobody knows how to open, does not meet the legal standard.
Non-compliance carries real consequences. Fines can be issued on the spot, and repeated violations lead to escalating penalties. More importantly, in the event of a workplace incident, non-compliance with safety regulations complicates insurance claims and significantly increases employer liability. A missing eyewash or an expired first aid kit can shift the legal burden directly onto the employer.
The challenge for fleet managers
For a company operating a single vehicle, maintaining compliance is manageable. For a fleet of 10, 50 or 200 vehicles, it becomes an operational challenge.
Each vehicle needs its own set of safety and hygiene equipment. Each piece of equipment has its own expiration dates, replacement cycles and storage requirements. First aid kits expire. Eyewash solutions have a shelf life. Soap runs out. Paper towels get used.
When these items come from different suppliers, fleet managers deal with multiple order processes, different delivery schedules and inconsistent product specifications. Tracking which vehicle has which items, what needs replacing and when, becomes a spreadsheet exercise that is easy to neglect.
Vehicle inspections add another layer. If safety equipment is mounted differently in every vehicle, or stored in different locations, inspectors and drivers both lose time searching. Consistency across the fleet is not just convenient. It is a compliance strategy.
The administrative burden of managing separate products from separate suppliers is one of the most common reasons that fleet compliance drifts over time. Nobody intends to let standards slip. It happens because the system is too fragmented to maintain reliably.
Simplifying compliance with a single solution
The most effective way to maintain safety compliance across a fleet is to standardise. One product, one mounting position, one reorder process, one inspection checklist.
The HYSAVER unit combines DIN 13164 first aid, eyewash, soap and paper towels in one compact unit, mounted in a fixed position inside the vehicle. This makes inspections faster, compliance easier to verify and reduces the risk of missing components.
At 40 x 60 x 25 cm and approximately 8 kg fully loaded, the unit fits standard vehicle racking and installs in 5 to 10 minutes using a mounting bracket with M6 stainless steel bolts. Every vehicle in the fleet gets the same equipment, in the same position, with the same refill process.
For fleet managers, this means one supplier, one inspection point per vehicle and one reorder cycle for all safety and hygiene consumables. For inspectors, it means everything is visible, accessible and verifiable in seconds.
Standardisation does not eliminate the need for diligence. Expiration dates still need monitoring, and used items still need replacing. But it removes the fragmentation that causes most compliance gaps in the first place.
Visit hysaver.com for more information about the HYSAVER unit and how it supports fleet compliance across Belgium and the EU.
Questions or interested in HYSAVER? Get in touch.
