Should I keep a hard copy of my hazardous chemical register? 

Oct 21, 2019 Posted by Walter Ingles

Keeping a Register of all the hazardous chemicals you use, store, and carry at the job site is an essential requirement under Australia WHS legislation. But many of our clients ask us — ‘which is best’ — hard copy (paper version) or electronic (on a computer)? In this blog we’ll look at the four essential areas to consider when choosing the best system for your Register of Hazardous Chemicals. But our preference is to have an electronic master-list with hard copies attached to aggregate quantities and individual safety cabinets. 

IMPORTANT: in Australia, failing to have a compliant Register of Hazardous Chemicals attracts penalties of up to $18,000. 


1. Compliance

Section 346 of Australian WHS Regulations requires you to keep a list of all the hazardous chemicals you keep onsite as well as a current copy of the Safety Data Sheet issued by the supplier of the chemicals. 

There is no specific requirement in the legislation for using either an electronic or hardcopy system, as long as the Register is: 

  • Kept up-to-date. 
  • Accessible to any workers using the chemicals 
  • Accessible to other people who are likely to be exposed or affected by the chemicals. 

At first glance, this requirement can seem tricky to implement — a full list containing the name of every chemical onsite (plus its Safety Data Sheet), and available to anyone and everyone who might come into contact with the chemicals. This is why we recommend using both an electronic as well as paper system. 


2. Efficiency

Begin by creating a master-list of every chemical carried on the job site, then collating the Safety Data Sheets — this could be as simple as an Excel spreadsheet or as sophisticated as a centralised database. According to the WHS Regulations, Safety Data Sheets must be updated at least once every 5 years, so make sure there is nothing more than 5 years old in the Register. 

Once your master-list is created it could be uploaded to the network server or intranet, where it can then be accessed at individual computer stations, tablets, or on a smartphone. Alternately, a hard copy Register could be broken down into individual work areas, placed in purpose-built document boxes and attached to equipment, machinery, and chemical safety cabinets. 

A critical part of managing the operations of any workplace or job site, is managing efficiencies so you don’t waste time and money duplicating documents and job tasks. The electronic register can be incredibly efficient — because once uploaded it can be updated electronically from a central point without the need to visit individual work areas, replacing documents and throwing away paperwork. 


3. Accessibility

But one of the biggest problems with electronic registers is they are not always accessible — which puts you in direct breach of the Regulations. The Register must be immediately accessible to anyone who could possibly be affected by the chemicals.  

This is an important time to remember the actual purpose of the Register — to provide critical safety and first aid information in case of an accidental spill, exposure incident, chemical burn or other injury. If your Register is only accessible electronically, could you encounter any of the following issues: 

  • Password protected workstation — would a visiting contractor or delivery driver know the password (or the steps) required to access the Register? What if the office was locked? 
  • Tablet — what if there is a WIFI or power outage, the tablet is LOWBAT, or left in a work vehicle? 
  • Smartphone — is it safe to use electronic devices in the proximity of flammable liquids or reactive chemicals? Is the screen large enough to accurately convey information during an emergency? Could a worker wearing gloves and bulky PPE be able to operate the gadget? 

Having a paper register in a sturdy document box means the safety information is immediately available to anyone present in the area. Safety Data Sheets can be laminated or kept in individual sleeves so they can be accessed and read even if the worker is wearing PPE and covered in chemicals. 


4. Durability

Your Register of Hazardous Chemicals also needs to be durable and accurate. You don’t want to be in an emergency situation and find that: 

Electronic Register 

  • Safety Data Sheets have been scanned incorrectly and there are pages missing — or upside down. 
  • Documents are blurred or unreadable due to low resolution copying. 
  • A software update is required before you can read the PDF Safety Data Sheet. 

Paper Register 

  • Pages are torn or crumpled. 
  • Paperwork has been damaged by water, dust, insects, or vermin. 
  • An SDS is missing because the last worker to access the Register did not return the Safety Data Sheets. 

No matter what system you use (paper — electronic) you will need to ensure there are supporting procedures to ensure that your Register of Hazardous Chemicals is always up-to-date, accurate, readable and accessible to anyone who might be affected by the chemicals. 

REMEMBER: STOREMASTA document boxes for your HAZCHEM Register are tough, durable, and made from corrosive-resistant materials. They keep out water, dust, pests and vermin. 


Next steps 

STOREMASTA has been leading Australian HAZCHEM safety and Dangerous Goods management for more than 30 years. We’ve used our years of experience and working in the field to develop chemical storage products and equipment that maximise human safety while ensuring your worksite is 100% compliant.  

And to keep giving back to our industry we regularly develop eBooks and Dangerous Goods safety guides which we provide to our customers and clients completely free. So for the next step in chemical safety and compliance we recommend downloading these popular eBooks: 

How to manage the risk of hazardous chemicals in the workplace

Walter Ingles

Walter Ingles Compliance Specialist

Walter is STOREMASTA’s Dangerous Goods Storage Specialist. He helps organisations reduce risk and improve efficiencies in the storage and management of dangerous goods and hazardous chemicals.

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