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The chemical register audit checklist for small workshops

By SupplySafe Team Published Updated 8 min read

A chemical register audit comes down to four things: every hazardous chemical is listed, there’s a current Safety Data Sheet (SDS) for each one, the register is kept up to date, and workers and emergency services can get to it fast. The 12 checks below are the things an audit of your chemical register will look at, taken straight from the model WHS Regulations and Safe Work Australia’s Code of Practice, so you can find the gaps before anyone else does.

Grab a coffee, your phone and an afternoon. The one-page PDF above has the same 12 checks to tick off on a clipboard. Each legal check below links to the regulator’s own words. Regulation numbers are from the model WHS Regulations, which every state and territory except Victoria has implemented (some with local variations, so check with your regulator). There’s a Victoria note at the end.

What do you need before you start?

Have these handy:

New to chemical registers? Start with what a hazardous chemicals register must contain, then come back.

What does a chemical register audit check? The 12-point checklist

  1. Walk the floor and list every chemical. Bays, paint area, wash bay, storeroom, under benches, the service van. In a typical mechanical workshop that means things like brake cleaner, degreasers and parts-washer solvents, coolants, adhesives, sealants and two-part epoxies, aerosol paints and primers, fuels and oils. Write the product name exactly as it appears on the label. Safe Work Australia’s Code of Practice says the first step is identifying all the chemicals used, handled, stored or generated at your workplace “in consultation with workers”, so ask your techs what they reach for. One handy exclusion: Safe Work Australia lists fuel, oils or coolants in a container fitted to a vehicle, intended for its operation, among chemicals that don’t need an SDS. The drum on the shelf isn’t fitted to a vehicle.

  2. Work out which ones are hazardous. Look at the label and Section 2 of the SDS. A signal word like “Danger” or “Warning” and hazard pictograms are the giveaway. Safe Work Australia says you should only include chemicals classified as hazardous on your register.

  3. Treat the consumer-product exception with care. Regulation 344 has an exception for a consumer product where it’s reasonably foreseeable it will be used at the workplace only in quantities and a way consistent with household use, and incidental to the work. The Code’s example is “washing dishes in the lunchroom”. It also warns that domestic chemicals may present greater risks at work depending on how and how much they’re used, and says that if you’re using one “in a manner different to normal household use, you should obtain the SDS”. Even where the exception applies, regulation 344 still requires sufficient information about safe use, handling and storage to be readily accessible. If you’re unsure, get the SDS and list it.

  4. Get the current SDS for every hazardous product. Regulation 344 says the business must obtain the current SDS from the manufacturer, importer or supplier when the chemical is first supplied, or if that’s not possible, as soon as practicable and before it’s used. Regulation 339 says a supplier must provide the current SDS with the chemical on first supply, and again after the SDS is amended, but that duty doesn’t apply to consumer products or retailers. So if it came from a trade supplier, ask them. If it came over a shop counter, go to the manufacturer. Safe Work Australia says you can get an SDS from the manufacturer’s website, or from the manufacturer, supplier or importer if you ask. More on who owes what in SDS requirements for manufacturers.

  5. Match each SDS to its product. Section 1 of an SDS is Identification: the product identifier and chemical identity. Check the name matches the label on the shelf, not a similar product from the same range.

  6. Check every SDS review date. Safe Work Australia says every SDS must list the date it was last reviewed and updated, usually in Section 16, and manufacturers must review each SDS at least once every five years. WorkSafe Victoria’s guide suggests contacting the manufacturer, importer or supplier if the SDS you have is more than five years old. That’s a good habit anywhere. Not sure which date to read? See which SDS date matters and how long an SDS is valid.

  7. Check two-part kits have every SDS. Epoxies, fillers and some paint systems come as Part A and Part B (sometimes more). In practice, each part often has its own SDS. Make sure you have every one, not just the resin.

  8. Confirm your register exists and is current. Regulation 346 says you must prepare and keep a register of hazardous chemicals at the workplace, keep it up to date, and include a list of the hazardous chemicals plus the current SDS for each. The Code adds that it must be updated as new hazardous chemicals come in or when you stop using one. Cross the register against your list from step 1.

  9. Test that the SDS are readily accessible. Regulation 344 says the current SDS must be readily accessible to workers who use, handle or store the chemical, and to emergency service workers or anyone else likely to be exposed. Safe Work Australia says your register must “be available for workers and emergency services at any time.” Try it: ask an apprentice to find the brake cleaner SDS and time them. If your SDS are electronic, the Code says a backup means of providing them should also be in place. See electronic SDS registers and QR codes.

  10. Tell everyone where to find the SDS. The Code is direct: “You must ensure that all workers likely to be exposed to the hazardous chemical know how to find the SDS.” Cover it at induction, at a toolbox talk, and with a sign where the register lives.

  11. Check decanted labels and chemical storage. Regulation 342 says chemicals transferred or decanted from the original container at the workplace must be correctly labelled. Spray bottles of degreaser count. The Code says a container of unknown contents should be marked (for example “Caution—do not use: unknown substance”) and stored in isolation until identified. For storage, Section 7 of each SDS covers handling and storage, and Safe Work Australia says incompatible chemicals should be stored well away from each other.

  12. Set a recurring register review. WorkSafe Victoria’s guide suggests keeping the register current through your purchasing process, checking purchase records, regular or scheduled reviews, walking the workplace, and contacting manufacturers to check SDS are current. Pick a rhythm that suits your shop, put it in the calendar, and add a rule: no new chemical goes on the shelf until its SDS is on the register.

What are the workshop SDS requirements in Victoria?

Victoria hasn’t implemented the model WHS laws. It runs under the Occupational Health and Safety Regulations 2017, so the regulation numbers above don’t apply there. The substance is very similar, though. WorkSafe Victoria says employers must keep a register of all hazardous substances in the workplace, have the current SDS for them and make them available to employees, not change the information on an SDS, and ensure supplied containers are labelled. Employers must also make sure employees, contractors and emergency services personnel have access to the SDS. WorkSafe’s step-by-step guide includes a chemicals register template too.

How do you make the next audit easier?

SupplySafe registers are grouped by brand, flag “A newer revision is available” when the manufacturer revises a sheet, and count review-due from the revision date on the sheet, with two-part kits held as one line carrying each part’s SDS. If a product is missing, tell us via Help and we chase the manufacturer. See SupplySafe for workshops.

Frequently asked questions

What does a chemical register audit look at?
The duties in the model WHS Regulations: a register of every hazardous chemical with the current SDS for each, kept up to date (regulation 346), current SDS obtained and readily accessible to workers and emergency services (regulation 344), and correctly labelled decanted containers (regulation 342).
What should I do with an SDS that's more than five years old?
Manufacturers must review each SDS at least once every five years. WorkSafe Victoria's guide suggests contacting the manufacturer, importer or supplier if the SDS you have is more than five years old.
Who must be able to get to the SDS in a workshop?
Regulation 344 says the current SDS must be readily accessible to workers who use, handle or store the chemical, and to emergency service workers or anyone else likely to be exposed. Safe Work Australia says the register must be available for workers and emergency services at any time.
Do consumer products used in a workshop need an SDS?
Regulation 344 has an exception for a consumer product used only in quantities and a way consistent with household use, and incidental to the work. The Code of Practice says that if you use one in a manner different to normal household use, you should obtain the SDS.
Does fuel in a vehicle need an SDS?
No. Safe Work Australia lists fuel, oils or coolants in a container fitted to a vehicle, intended for its operation, among chemicals that don't need an SDS. A drum of the same product on the shelf isn't fitted to a vehicle.

Sources

This article is general information, not legal advice. It quotes and links the regulator's own wording; check the source and your state or territory regulator for anything that applies to your workplace. SupplySafe distributes Safety Data Sheets and does not author, edit or certify them. Rules change: see What's changing for dated, official updates.

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