Do consumer products need to go on your chemical register?

Every workshop has them. The dishwashing liquid by the sink, the can of household spray lubricant in the drawer, the glass cleaner in the office. They’re hazardous chemicals on paper, and they came from the supermarket. Do they need a line on your hazardous chemicals register?

Sometimes no. But the exception is narrower than most people think, and it comes with a duty of its own. Here’s what the model Work Health and Safety (WHS) Regulations actually say.

What the register has to cover

Regulation 346 says a person conducting a business or undertaking must prepare and keep a register of hazardous chemicals “used, handled or stored at the workplace”, and keep it up to date. The register must include a list of those chemicals and the current Safety Data Sheet (SDS) for each one (Work Health and Safety Regulation 2011 (Qld), reg 346, which uses the model numbering).

That’s the starting point: if it’s a hazardous chemical and it’s at your workplace, it goes on, unless an exception applies. For the full picture, see what a hazardous chemicals register must contain.

The consumer product exception, word for word

Regulation 346(4)(b) says the register duty doesn’t apply if “the hazardous chemical is a consumer product and the person is not required to obtain a safety data sheet for the hazardous chemical under section 344.”

So the answer hangs on regulation 344, the rule about getting SDS. Regulation 344(4)(c) says the SDS duty doesn’t apply to a hazardous chemical that is a consumer product where it is “reasonably foreseeable that the hazardous chemical will be used at the workplace only”:

• “in quantities that are consistent with household use”; and
• “in a way that is consistent with household use”; and
• “incidental to the nature of the work carried out by a worker using the hazardous chemical.”

All three have to be true. Miss one and the product needs an SDS, and that means it needs a line on the register too.

Putting the three tests to work

Household quantities. A 500 mL bottle used now and then is household quantity. A 20 L drum, or a carton of aerosols worked through each month, isn’t.

Household way. Wiping down a kitchen bench with a spray cleaner is a household way to use it. Using the same cleaner in a parts washer, heating it, mixing it with something else or spraying it all day in a booth isn’t.

Incidental to the work. This is the one that trips workshops up. If a worker’s job is cleaning, detailing or maintenance, the cleaning chemicals they use aren’t incidental. They’re the job. A product that is incidental in the office kitchen can be core to the work in the wash bay.

The test is about the use, not the label or the shop it came from. The same can of spray lubricant can sit inside the exception in the office drawer and outside it on the service bench.

A quick sort for the shelf

Walk the site and put each “supermarket” product into one of two piles.

Likely inside the exception (still check the three tests):

• Dishwashing liquid and hand soap in the staff kitchen
• A household glass cleaner used on the office windows
• A small can of air freshener in the bathroom

Likely outside it, so register and SDS:

• Anything bought in trade sizes or bulk
• Consumer-labelled products used as a routine part of the work, such as degreasers, solvents, brake cleaners and aerosol paints on the workshop floor
• Products used in a non-household way, such as decanted, heated, mixed or sprayed in volume
• Anything a worker uses for most of a shift

If you’re unsure which pile something belongs in, putting it on the register is the cautious choice. Safe Work Australia also notes that “You should only include chemicals classified as hazardous chemicals on your register” (Safe Work Australia, Hazardous chemicals register), so a product that isn’t classified as hazardous doesn’t need a line at all.

The duty that still applies

Leaving a product off the register doesn’t end the job. Regulation 344(5) says that in these circumstances you “must ensure that sufficient information about the safe use, handling and storage of the hazardous chemical is readily accessible” to workers and to emergency service workers, or anyone else likely to be exposed.

Safe Work Australia says the same thing more simply: “Whether in the register or not, you must make safety information about the chemical available to everyone in your workplace” (Safe Work Australia).

In practice, the label is often where that information lives, so keep products in their original containers with the labels readable. Decanting a household product into an unmarked spray bottle loses the information you’re relying on.

Retailers have a separate rule

If your business sells consumer products, regulation 344(4)(b) has a separate exception for retailers. It covers consumer products intended for supply to other premises and not intended to be opened on your premises. Opened stock, testers and anything used in-store are a different matter. If you’re also a workshop, the shop shelf and the workshop floor can need different answers.

Victoria words it differently

Victoria runs its own Occupational Health and Safety Regulations 2017, with different numbering. WorkSafe Victoria’s compliance code notes that retailers don’t need a register for substances in consumer packages that are for retail sale and not opened on their premises (r162(4)) (WorkSafe Victoria, Compliance code: Hazardous substances). If you’re in Victoria, read the Victorian chemical register guide for how the rules line up.

The short version

• A consumer product can stay off the register only when it’s used in household quantities, in a household way, and incidentally to the work.
• Trade use, bulk quantities or core-of-the-job use means it needs an SDS and a register line.
• Either way, safety information must be readily accessible, so keep labels intact.

The chemical register audit checklist covers this as one of its checks. And when a product does go on, SupplySafe keeps the current SDS for each line from the manufacturer, so your register stays current without the chasing.

Frequently asked questions

Do consumer products need to be on a hazardous chemicals register?

Not always. Under the model WHS Regulations, the register duty doesn't apply to a consumer product when you aren't required to obtain an SDS for it. That's when it's reasonably foreseeable the product will be used at work only in household quantities, in a household way, and incidental to the work.

Does a hardware store product count as a consumer product?

Where you bought it isn't the test. What matters is how much you use and how you use it. A tin of degreaser used the way a household would use it may fall in the exception. The same product used by the drum, or as a core part of the job, doesn't.

If a consumer product is off the register, do I still need safety information?

Yes. Regulation 344(5) says that in these circumstances you must ensure sufficient information about safe use, handling and storage is readily accessible to workers and emergency service workers. Safe Work Australia puts it plainly: whether in the register or not, you must make safety information about the chemical available.

Sources

• Queensland Government, Work Health and Safety Regulation 2011 (Qld), current in-force version: regulations 344 and 346 (uses the model WHS Regulations numbering; accessed 2 November 2026)
• Safe Work Australia, Hazardous chemicals register (accessed 2 November 2026)
• Safe Work Australia, Model WHS laws (accessed 2 November 2026)
• WorkSafe Victoria, Compliance code: Hazardous substances (accessed 2 November 2026)