A REGISTER of Hazardous Chemicals and a MANIFEST of Hazardous Chemicals are two different documents (that serve different functions) but both are required by the Australian WHS Regulations. This blog explains both documents: what they are; how to determine if you need one (or both); and instructions for preparing and storing the documents correctly.
IMPORTANT: You can be fined up to $30,000 for not having the correct Register or Manifest of Hazardous Chemicals. Many workplaces will require both.
Register of hazardous chemicals
A register of hazardous chemicals is a list of all the hazardous chemicals held at the workplace (as well as the most recent Safety Data Sheet (SDS) for each of the substances). The register must be easily accessed by workers or anyone likely to be exposed to the hazards presented by the chemicals.
This register can be stored electronically on a intranet database accessible to workers through their individual workstations, but a hardcopy register kept in a sturdy (liquid-tight) document box is also acceptable. The main function of the register is to provide information about chemical hazards especially if workers need it in a hurry when responding to a first aid situation.
IMPORTANT: The WHS Regulation requires the Register to be kept up-to-date so it’s important to make sure you add new chemicals, delete anything you no longer use onsite, and always have the current SDS issued by the manufacturer/supplier.
Manifest of hazardous chemicals
When larger quantities of hazardous chemicals (which are also classified as Dangerous Goods) are kept at your worksite, you will need to prepare a Manifest of Hazardous Chemicals. This manifest is part of a mandatory Emergency Plan and is used to assist emergency service organisations and responders understand the chemical hazards and quantities of Dangerous Goods present at the workplace.
The following information must be included in the Manifest:
Name of the person conducting the business or undertaking.
Address of the workplace.
Date the manifest was prepared (or last amended).
Contact details of at least 2 people (business hours and after hours numbers) if there is a notifiable incident at the workplace.
Chemical name (proper shipping name and UN code) and quantity held onsite.
Hazard Class (including sub-classes of certain chemicals eg, flammable liquids).
A plan of the workplace drawn to scale with an indicator of true North. The site plan includes things like: entrances/exits; drainage points; the nature of adjoining sites; plus the location of bulk containers, toxic substances, explosives, and the manifest itself.
One of the most important elements of the Manifest is to ensure it is kept up-to-date and in an agreed location (immediately accessible by emergency response crews). We recommend a sturdy document box (that can protects important documents from dust, rain and vermin) in a distinguishing colour (eg red) and labeled MANIFEST.
IMPORTANT: The Manifest of Hazardous Chemicals does NOT require copies of the SDSs, don’t include them as it could slow down emergency services responding to a chemical emergency.
Register vs Manifest of hazardous chemicals comparative table
The following table compares the Register and the Manifest, please remember that the two documents are different and NOT interchangeable.
|When Required||For all hazardous chemicals kept onsite (except for goods in transit and consumer products)||When quantities of certain hazardous chemicals exceed threshold limits defined in the WHS Regulation.|
|Primary Function||So workers etc can easily find information about chemicals they use at the workplace (eg, first aid responses, safe storage, poisons information, PPE).||So emergency responders know the type of hazardous chemicals (and Dangerous Goods) they could encounter — where they are, their hazard class, and the quantities held onsite.|
|Mandatory Contents||Names of all the Hazardous Chemicals held onsite as well as copies of the Safety Data Sheets for each of the chemicals.||Name of the PCUB; address of the workplace; Date manifest was prepared or last updated; After house contact details for at least 2 people if there is a notifiable incident at the workplace; Chemical names and quantities held onsite; Hazard Classes; scaled plan of the workplace with an indicator of true North.|
|Location||Can be stored electronically or in hard copy — as long as the register is readily accessible to workers (or other people) exposed to the chemicals listed in the register (including emergency service crews).||Must be stored somewhere readily accessible to emergency responders (determined in agreement with the primary emergency service organisation).|
IMPORTANT: The WHS Regulation outlines the exact requirements of the Register and Manifest of Hazardous Chemicals including the information to be included, where they should be stored, and the threshold quantities.
Having a Register and a Manifest of Hazardous Chemicals is required by the WHS Regulation, but to fully comply with all your legal obligations you will also need to introduce a risk management methodology into your workplace to identify, assess and control all the chemical hazards. Download our free eBook How to manage the risk of Hazardous Chemicals in the workplace to learn how to get your worksite 100% compliant.