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Electronic SDS register: can a chemical register be electronic?

By SupplySafe Team Published Updated 8 min read

Yes. An electronic SDS register is allowed in Australia, so your Safety Data Sheets don’t have to live in a ring binder. Safe Work Australia’s Code of Practice says an SDS can be kept “as hard copy or in another format, including electronically”, as long as the people who need it can actually get to it.

That last bit is the whole game. An electronic register is only as good as the moment someone needs it: a splash in the eye, a spill on the floor, a fire crew at the roller door. Here’s what the regulator says, and how to make digital access (QR codes included) hold up in real life.

Is an electronic SDS register allowed?

Under regulation 344 of the model WHS Regulations, the business running the workplace must make sure the current SDS for each hazardous chemical is readily accessible to:

a worker who is involved in using, handling or storing the hazardous chemical at the workplace; and an emergency service worker, or anyone else, who is likely to be exposed to the hazardous chemical at the workplace.

The hazardous chemicals register has a matching rule. Regulation 346 says the register (a list of your hazardous chemicals plus the current SDS for each) must be readily accessible to workers who use, handle or store hazardous chemicals, and to anyone else likely to be affected. Safe Work Australia’s register page puts it plainly: your register must “be available for workers and emergency services at any time.” There’s more on that in what a hazardous chemicals register must contain.

Notice what’s missing. The regulations don’t say “paper”. The format question is covered in Safe Work Australia’s Model Code of Practice: Managing risks of hazardous chemicals in the workplace:

The SDS should be kept in a location near the work area where the substance is used—this may be as hard copy or in another format, including electronically.

The same Code adds two lines worth sticking above the bench:

You must ensure that all workers likely to be exposed to the hazardous chemical know how to find the SDS.

And on electronic databases, it says the database “should be readily available to workers, workers should know how to use it, and a backup means of providing the SDS should also be provided, for example as hard copies in a filing system.”

One caveat: a model Code of Practice only has legal effect once a state or territory approves it. Safe Work Australia suggests checking with your local WHS regulator.

What about “paper on request”?

You may have seen this line: “If you choose to put the SDS on your website, you must provide a paper version if someone asks for it.” It’s on Safe Work Australia’s Preparing safety data sheets page, and it’s aimed at manufacturers and importers, the people who write SDS. It’s about how they publish. For a workshop, the Code of Practice wording above is the guidance to follow.

So, do SDS need to be printed?

Not across the board. Electronic is fine under the Code, but it also expects a backup when your SDS live in an electronic system, with hard copies as its example. Treat the backup as part of the setup, not an optional extra.

What makes an online SDS register work in practice?

“Readily accessible” is the regulator’s phrase, and we’ll leave its legal meaning to them. In day-to-day terms, these are the things that make or break an online SDS register:

  • No login wall. If reading an SDS needs a password nobody remembers, that’s a barrier at the worst possible moment. Casuals, contractors and fire crews won’t have your login.
  • Works on any phone. Old or new, any brand, no app to install. A plain web page opens on anything with a browser.
  • The manufacturer’s current sheet, unaltered. Regulation 345 lets only the manufacturer or importer change an SDS (apart from attaching a clearly marked translation). WorkSafe Victoria’s guide says that where SDS are on a computerised database, you should make sure they represent the manufacturer’s or importer’s SDS, are up to date, aren’t altered, and that you can print a copy.
  • A plan for flat batteries and dead spots. Concrete walls, a back shed with no coverage, a phone left in the ute. That’s what the Code’s backup is for.
  • Everyone knows how. Show new starters on day one. The Code is clear that workers must know how to find the SDS.

SDS QR code posters: how do you run a QR code chemical register?

QR codes are a quick bridge from the wall to the sheet. Done well, a single SDS QR code poster turns your register into something anyone can open in seconds. Done badly, it’s a sticker that quietly stops working.

One QR per document, or one per site?

There are two common models.

One QR per document One QR per site
What it opens A single SDS The site’s register, then each current SDS
How many codes One per product One poster (a few copies if you like)
New product arrives Print and stick a new code Nothing to print
SDS gets revised Depends where the code points Nothing to print, if the link is permanent

Both can work. Per-document codes are handy right at the shelf. A per-site QR code chemical register is simpler to run: one poster, one place to look, and the register behind it does the heavy lifting.

It’s easy to make a QR code from the web address of a PDF file. That works on the day you print it. Then the manufacturer revises the SDS, renames the file or rebuilds their website. The old address may now show “page not found”, or worse, keep serving the old revision. The code on your wall looks perfectly fine. It just points at the wrong thing.

That’s practical reasoning, not a rule from the regulator. But the regulations ask for the current SDS, and a QR code is only as good as the address behind it. Point your code at a page whose address stays the same while the content behind it gets updated. Then test it.

Emergency services access

Regulation 344 names emergency service workers directly, and Safe Work Australia says the register must be available to emergency services at any time. Keep it simple for them: a code near the entry that opens without a login, and a backup they can find without hunting for you. If you store larger quantities of hazardous chemicals, you may also need a separate document called a manifest. Safe Work Australia’s register page links to the manifest requirements.

Printing and placement

  • Near the work. The Code says the SDS should be kept near the work area where the substance is used. Think chemical storage, the paint area, the wash bay, and the main entry.
  • Big and matte. A larger code scans from further back. Laminate it or use a sleeve, and keep it out of glare and direct sun.
  • Say what it is. A one-line label beats a mystery square: “Scan for Safety Data Sheets. No login needed.”
  • Test it. Scan with a few different phones after printing, then again every so often.
  • Show the backup. Add a line saying where the printed copies or other backup are kept.

Is it different in Victoria?

Victoria is the one jurisdiction that hasn’t implemented the model WHS laws. It runs under its own Occupational Health and Safety Regulations 2017, so the regulation numbers above don’t apply there. WorkSafe Victoria says employers using or storing hazardous substances or dangerous goods must ensure “their employees, contractors and emergency services personnel have access to the SDS.” Its step-by-step guide covers computerised SDS databases (the points in the list above) and suggests telling employees where SDS are kept and, where necessary, how to access them.

Where SupplySafe fits

SupplySafe gives each site one QR poster that opens a no-login view of the site’s register and the current SDS, and the code points to a permanent SupplySafe link, never the file, so the poster never needs reprinting when an SDS is replaced. Signed-in staff can also keep an offline copy for reading with no signal. See how SupplySafe works.

Frequently asked questions

Can an SDS register be electronic in Australia?
Yes. Safe Work Australia's Code of Practice says an SDS can be kept as hard copy or in another format, including electronically. The current SDS must still be readily accessible to the workers who use, handle or store the chemical and to emergency service workers.
Do SDS need to be printed?
Not as a blanket rule. The Code of Practice allows electronic SDS, but says that where SDS are kept in an electronic database, a backup means of providing them should also be provided, and gives hard copies in a filing system as its example.
Should an SDS QR code point straight at the PDF?
It's safer not to. A code made from a PDF file address can break, or keep showing an old revision, when the manufacturer revises the SDS, renames the file or rebuilds their website. Point the code at a page whose address stays the same while the content behind it is updated.
Do emergency services need access to the SDS register?
Yes. Regulation 344 of the model WHS Regulations names emergency service workers among the people the current SDS must be readily accessible to, and Safe Work Australia says the register must be available for workers and emergency services at any time.

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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