Blog For workshops

Hazardous chemical register requirements: what must it contain?

The hazardous chemical register requirements come down to two things: a list of the hazardous chemicals used, handled or stored at your workplace, and the current Safety Data Sheet (SDS) for each one (Safe Work Australia). The register has to be kept at the workplace, kept up to date, and be readily accessible to workers and anyone else likely to be affected.

That’s the legal core. Quantities, locations, dates and hazard classes are all useful, but they’re good practice rather than law. Here’s how it breaks down, with the regulator’s own words linked so you can check us.

Chemical register, SDS register or hazardous substance register: what’s the difference?

Mostly the name. People search for “chemical register”, “SDS register” (formerly MSDS register) and “hazardous substance register”, the term you’ll still hear in Victoria, whose regulations talk about hazardous substances. The model Work Health and Safety (WHS) Regulations call it a hazardous chemicals register, and Safe Work Australia describes it this way:

A hazardous chemicals register is a list of hazardous chemicals at your workplace, accompanied by the current safety data sheet (SDS) for each of those chemicals.

So it’s both: the list and the sheets. A tidy spreadsheet with the SDS in a dusty folder elsewhere is only half the job.

It’s also not a manifest. Safe Work Australia’s fact sheet explains that a manifest is only required where hazardous chemicals that are dangerous goods exceed set threshold quantities, and it’s intended mainly for emergency services. A register applies to any amount.

What are the SDS register requirements under regulation 346?

Regulation 346 of the model WHS Regulations says the person conducting a business or undertaking (PCBU) at a workplace must make sure the register is:

  1. prepared and kept at the workplace
  2. maintained so the information in it is up to date
  3. readily accessible to workers involved in using, handling or storing a hazardous chemical, and to anyone else likely to be affected by a hazardous chemical at the workplace.

And regulation 346(2) says what goes in it:

(a) a list of hazardous chemicals used, handled or stored; and (b) the current safety data sheet for each hazardous chemical listed.

That’s it. The regulation doesn’t list columns.

Up to date means two things

First, the list. Safe Work Australia’s code of practice says the register “must be updated as new hazardous chemicals are introduced to the workplace or when the use of a particular hazardous chemical is discontinued.”

Second, the sheets. The register needs the current SDS, and manufacturers and importers must review their SDS at least once every five years and amend them whenever necessary (regulation 330). The register fact sheet puts it plainly: “you will need to obtain a new SDS from the chemical supplier periodically to ensure you have the most up-to-date and current SDS.” Our guide to how long an SDS is valid covers the five-year rule.

Readily accessible means usable

Safe Work Australia’s register page says your register must “be easy to use” and “be available for workers and emergency services at any time.”

It doesn’t have to be paper. The register fact sheet says registers and SDS “may be kept electronically (for example on an intranet) provided workers have ready access to a computer. Otherwise, a hard copy should be kept in the location where chemicals are mostly used.” More on that in electronic SDS and QR codes.

What can you leave off the register?

Regulation 346 doesn’t apply to a hazardous chemical that is:

  • In transit, unless there’s a significant or frequent presence of it at the workplace. “In transit” means in containers not opened at the workplace, not used there, and kept there for no more than 5 consecutive days.
  • A consumer product you don’t need an SDS for under regulation 344. That’s the household-use exception: 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. Check 3 of our chemical register audit checklist covers when to be careful with it.

Safe Work Australia also says: “You should only include chemicals classified as hazardous chemicals on your register.”

One catch. Leaving something off the register doesn’t leave it off your radar. Safe Work Australia is clear that “Whether in the register or not, you must make safety information about the chemical available to everyone in your workplace.”

What does Safe Work Australia’s own guidance add?

A few useful extras:

  • Only the names are mandatory in its template. Its register template says: “Of the information in the template below, only the chemical names are mandatory.” The other columns are suggestions, and it invites you to add things like the date chemicals arrived on site, your own product codes, hazard information (such as GHS and Dangerous Goods classes) and the intended use.
  • Check your local rules. It says you “should also check with your WHS regulator for other requirements specific to your state or territory.”
  • Shared sites count. Its fact sheet gives the example of an office where contract cleaners store their chemicals on site. The office still needs those chemicals and their current SDS on its register, so others have the information if there’s a spill.
  • Big quantities may need more. If you store hazardous chemicals in large quantities, you may also need a manifest and placards.

Which columns should a register have? (Good practice, not law)

The law asks for the list and the current SDS. Below is our suggestion for a register that works on a busy day, partly borrowed from Safe Work Australia’s template.

  • Product name, exactly as it appears on the label and the SDS, so anyone can match the can to the sheet
  • Manufacturer or importer, the business named in Section 1 of the SDS
  • SDS revision date, the date the sheet was last reviewed (every SDS must state it; see which SDS date matters)
  • Review due, five years on from that revision date
  • Location where it’s stored and used
  • Quantity or container size you usually hold
  • Hazard information, such as the GHS classification and Dangerous Goods class
  • What it’s used for in your workplace
  • Date added to the site
  • Register last reviewed on, and by whom

Keep the SDS itself attached to each line, or one tap away. A name on a list without its current sheet doesn’t meet regulation 346(2). Rather not start from scratch? Grab our free hazardous chemical register template.

What are the register rules in Victoria?

Victoria hasn’t adopted the model WHS laws. Its rules are in the Occupational Health and Safety Regulations 2017, which talk about “hazardous substances” rather than hazardous chemicals. WorkSafe Victoria’s hazardous substances compliance code sets out the register duty under regulation 162:

  • Employers must prepare and maintain a register for all hazardous substances supplied to the workplace. It must list their product identifiers and be accompanied by the SDS for each.
  • The register should be updated when new hazardous substances arrive, when use of one is discontinued, and when the manufacturer or supplier provides a revised SDS.
  • It must be readily accessible to any employee who may be exposed (r162(3)). The code says it needs to be kept in a central location with a readily accessible copy in each relevant work area, and that it “may also be computerised if employees know how to access and use the computerised system.”
  • Retailers don’t need a register for substances in consumer packages that are for retail sale and not opened on their premises (r162(4)).

The Victorian code is also direct about dates:

Employers need to ensure that all SDSs in the register or otherwise accessible at the premises have issue dates within the last five years.

If you also store dangerous goods, Victoria’s Dangerous Goods (Storage and Handling) Regulations 2012 require a register for those too. WorkSafe says one combined register is enough if all the dangerous goods at the premises are also hazardous substances. Its compliance code even includes a sample register to copy.

The bottom line

A list of what’s hazardous on site, the current SDS for every line, kept current and easy to reach. Nail that and the extra columns are a bonus.

SupplySafe for workshops gives each site a printable hazardous chemicals register (A4 and CSV), counts the review-due date from the revision date on each sheet, and flags “A newer revision is available” when the manufacturer publishes an update. One QR poster per site opens a no-login view of the register and the current SDS.

Frequently asked questions

Is a hazardous substance register the same as a hazardous chemicals register?
They do the same job. The model WHS Regulations call it a hazardous chemicals register. Victoria's Occupational Health and Safety Regulations 2017 talk about hazardous substances, and WorkSafe Victoria's compliance code requires a register of hazardous substances accompanied by the SDS for each.
What is a chemical register?
A hazardous chemicals register is a list of the hazardous chemicals used, handled or stored at your workplace, together with the current safety data sheet (SDS) for each one. It must be kept at the workplace, kept up to date and be readily accessible to workers and anyone else likely to be affected.
What are the SDS register requirements in Australia?
Under regulation 346 of the model WHS Regulations, the register must include a list of hazardous chemicals used, handled or stored and the current SDS for each one. Victoria has its own rules under the Occupational Health and Safety Regulations 2017, with a similar register duty in regulation 162.
Does a chemical register need particular columns?
No. The regulation doesn't list columns. Safe Work Australia's register template says only the chemical names are mandatory, and the other columns are suggestions.
Do consumer products have to go on the register?
Not always. The register duty doesn't apply to a consumer product you aren't required to get an SDS for, such as one used only in household quantities and in a household way, incidental to the work. Even then, Safe Work Australia says you must make safety information about the chemical available to everyone in your workplace.

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.