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Hazardous substances register or chemical register: which do you need?
If you’ve been asked for a “hazardous substances register”, a “dangerous goods register” or a “chemical register”, you’re probably being asked for the same thing: a list of every hazardous product on site with the current Safety Data Sheet (SDS) for each one. The names differ because the law changed, and because Victoria runs its own system.
This guide explains where each name comes from and what to keep, so you can answer an auditor, a client or a head office form without guessing.
Why are there so many names?
Before the harmonised work health and safety laws, Australian workplaces dealt with two separate sets of rules: hazardous substances (products that can harm health, such as solvents and isocyanates) and dangerous goods (products that are dangerous because of their physical properties, such as flammable liquids and gas cylinders). Each had its own register, its own paperwork and often its own regulator.
The model WHS Regulations combined both into one category: hazardous chemicals. Every state and territory except Victoria has implemented the model laws, some with local variations. Under those laws there is one register, described in regulation 346.
The old names stuck. Many safety templates, contractor prequalification forms and auditors still say “hazardous substances register”, and plenty of workshop folders still have “Dangerous Goods” on the spine.
What does the register need to contain under the model WHS laws?
Regulation 346 says the person conducting the business must 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 the hazardous chemicals, and
- the current SDS for each one.
It must also be readily accessible to workers who use, handle or store the chemicals and to anyone else likely to be affected. Safe Work Australia publishes a free hazardous chemicals register template if you’d like a starting layout.
There is a separate document, the manifest, which is only needed once you store certain hazardous chemicals above the manifest quantities in Schedule 11 (regulation 347). A small workshop with a few drums and a couple of gas bottles is often below those quantities, but check the schedule against what you actually store rather than assuming.
What about Victoria?
Victoria has not adopted the model WHS laws, so the older split survives there in a modernised form:
- Hazardous substances are covered by the Occupational Health and Safety Regulations 2017. WorkSafe Victoria’s compliance code for hazardous substances explains the duty to keep a register of hazardous substances, including the current SDS for each.
- Dangerous goods are covered by the Dangerous Goods (Storage and Handling) Regulations 2022, which came into effect on 26 November 2022. Above certain quantities there are extra duties, including notifying WorkSafe Victoria.
WorkSafe Victoria’s own hazardous substances page gives the practical summary: get the safety data sheets for all dangerous goods and hazardous substances at your workplace, and make sure employees can get to them.
So in Victoria, “hazardous substances register” is still the correct legal name. Elsewhere, it’s an older name for the register of hazardous chemicals.
Can one register cover everything?
In practice, yes, for most small workplaces. A product can be both a hazardous substance and a dangerous good (a solvent-based brake cleaner in an aerosol is a common example), and keeping two lists of the same product is a reliable way to let one of them go out of date.
A practical combined register has one row per product with:
- Product name, exactly as it appears on the SDS and label.
- Manufacturer or supplier.
- Where it’s stored and roughly how much you keep.
- Whether it’s classified as hazardous, as a dangerous good, or both (sections 2 and 14 of the SDS tell you).
- The current SDS, with its revision or issue date.
If you’re in Victoria or store dangerous goods in larger quantities, check with WorkSafe or your local regulator that your format covers every duty that applies to you.
What’s the fastest way to fix an old register?
Most out-of-date registers have the same problems: products no longer used are still listed, new products bought in the last year are missing, and the SDS on file is an old version. A walk-through with the register in hand fixes the first two. For the third, compare the revision date on each sheet with the one on the supplier’s website, and replace any that have moved on. Our chemical register audit checklist walks through the full set of checks.
How SupplySafe handles it
SupplySafe keeps one register per site, whatever you call it. Each product links to the SDS its manufacturer publishes, so when a newer sheet comes out your register updates without anyone downloading a PDF. Workers and emergency services can reach it from a QR code on the wall.
Starting from scratch? Our free hazardous chemical register template comes in Excel, PDF and CSV; Victorian workplaces can use the Victorian chemical register template. If you’ve been asked for a “hazardous materials register”, see hazardous materials register vs chemical register.
Frequently asked questions
- Is a hazardous substances register the same as a hazardous chemicals register?
- Outside Victoria, the model WHS Regulations replaced the older hazardous substances and dangerous goods rules with a single set of hazardous chemicals rules. Regulation 346 requires a register of hazardous chemicals with the current SDS for each one. Many people still call it a hazardous substances register.
- Does Victoria still use the term hazardous substances?
- Yes. Victoria has not adopted the model WHS laws. Its rules on hazardous substances sit in the Occupational Health and Safety Regulations 2017, and dangerous goods storage and handling sits in the Dangerous Goods (Storage and Handling) Regulations 2022.
- Can one register cover hazardous substances and dangerous goods?
- Many workplaces keep one combined list, with the current SDS for every product and a note of which ones are dangerous goods. Check with your regulator that a combined register covers everything required where you are.
Sources
- Safe Work Australia, Model WHS Regulations (regulations 346 and 347, Schedule 11; accessed 28 October 2026)
- Safe Work Australia, Hazardous chemicals register template (accessed 28 October 2026)
- Safe Work Australia, Model WHS laws (accessed 28 October 2026)
- WorkSafe Victoria, Hazardous substances (accessed 28 October 2026)
- WorkSafe Victoria, Compliance code: Hazardous substances (accessed 28 October 2026)
- Victorian Legislation, Occupational Health and Safety Regulations 2017 (accessed 28 October 2026)
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.