How to prepare and implement a register of hazardous chemicals

Dec 26, 2018 Posted by Walter Ingles

If your workplace uses or handles hazardous chemicals you are legally required by Australian WHS Regulations to keep a register of hazardous chemicals on the job site. This blog will teach you how to prepare and install a register of hazardous chemicals that complies with the law.

IMPORTANT: A hazardous chemical register is an essential requirement under the law and you can face penalties of up to $30,000 for not having the correct documents in place.

What is a Register of Hazardous Chemicals?

A Register of Hazardous Chemicals is a list of the names of the all hazardous chemicals kept at the workplace. The register must also contain the current Safety Data Sheet (SDS) for each of the chemicals and be easily accessible to any workers, or contractors likely to be exposed to the chemical hazards. It should also be accessible to emergency responders.

10 common MISTAKES that are made when implementing a hazardous chemical register

  1. Having Safety Data Sheets in the register that are more than 5 years old

  2. Keeping the register locked in a manager’s office

  3. Not removing the details of a substance that is no longer used on the worksite

  4. Storing the register on a password protected PC that is only accessible when the WHS Safety Manager is on shift

  5. Downloading generic Safety Data Sheets (SDSs) from the internet rather than getting the official SDS issued by the manufacturer or supplier

  6. Listing consumer products that aren’t required to be on the register (eg, a staff member’s personal deodorant)

  7. Not updating the register when a new chemical is introduced to the workplace

  8. Putting hard copy SDSs in thin plastic sleeves that quickly deteriorate outdoors or in a heavy industrial environment

  9. Not having the register where the chemicals are actually being used (eg, forklift drivers who load and unload chemicals need to quickly access the register)

  10. Not training your staff about chemical hazards and how to read and use a Safety Data Sheet

IMPORTANT:  The WHS Regulations require that ‘sufficient information about the safe use, handling and storage of the hazardous chemical is readily accessible to any worker at the workplace; any emergency service worker, or anyone else who is likely to be exposed to hazardous chemicals at the workplace.

Obtaining Safety Data Sheets (SDS)s

Safety Data Sheets are an essential part of your hazardous chemical register because they contain vital information about:

  • The chemical properties of hazardous substance

  • The hazard class assigned by the GHS

  • Health hazards, acute adverse health conditions, and chronic illnesses caused by the chemicals

  • Safe handling and storage instructions

  • Recommended personal protective equipment (PPE)

  • First aid and emergency responses

  • The impact on physical property and the environment.

The first job in obtaining these Safety Data Sheets and creating your hazardous chemical register is to conduct a walk-around of the worksite and physically locate all the chemicals. You might have already done this during your risk identification and assessment processes, but if you haven’t consider printing out a site map and walking around with the staff or contractors assigned to each work area.

Next you will create a Master List of the chemical names (using Word tables or Excel spreadsheets is ideal) and begin collating the SDSs you have for each of the chemicals. You can also include additional information in your register eg, the location onsite where the chemical is used/stored; name of the manufacturer/supplier, and the issue date of the SDS.

Chemical manufacturers and importers are required to update the SDS for their chemicals at least once every five years, or if changes to manufacturing processes (or scientific research) alters the risks and hazards of the chemical. You are required by law to have the current SDS for every chemical, so if any of them are more than 5 years old you immediately know there is a problem.

SDSs should only be obtained from the actual supplier, importer or manufacturer of the chemicals because the chemical properties of a substance can vary (even between batches) enough to increase or reduce the health and physical hazards of a chemical.

IMPORTANT: Never use a generic SDS or something  you have downloaded from the internet from another supplier’s website. It could cost someone their eyesight or their life.

Implementing your chemical register

Once you have created your register you need to create an accessible (and safe) space in relevant work areas where staff and other personnel can easily use it. We recommend having your master register stored electronically on the company intranet and hard copies available in locations where the chemicals are actually being used.

Using an electronic register

If you decide to use an electronic register of hazardous chemicals please ensure:

  • That staff can physically access the computer terminals (eg they aren’t kept in a locked office); know the required passwords, and have sufficient IT knowledge to use the system correctly.

  • Computers or individual workstations are operational and kept updated so they don’t lock up or freeze when staff need to quickly locate an SDS or chemical hazard information

  • An exact copy of the original Safety Data Sheets (eg, PDF) is used and available in a resolution that is perfectly visible.

  • Mechanisms are in place so the register is still accessible during maintenance shutdowns, blackouts, and power outages.

  • The register is regularly updated as new chemicals are introduced or obsolete chemicals removed from the workplace.

Using a hard-copy register

When using a hard copy paper register we suggest you:

  • Keep your register in a dedicated document box or tube that protects paper SDSs and the Master List of chemicals from dust, vermin, and the weather.

  • Have you register on hand in work areas where chemicals are used and stored by fixing your document box/tube to the exterior of forklifts;  HAZCHEM stores; and other operating plant.

  • Don’t store documents printed with inkjet printers or on thermal paper that might cause the printed information to fade or disappear.

  • Make sure the printed documents are perfectly clear and easy to read — not faint, light or with lines through the text.

  • Check the documents periodically and replace with new printouts if they become faded or damaged.

  • Make sure your staff and contractors know where to find the register and are trained to put SDS back in their containers or document box after being used.

  • Conduct regular audits to make sure SDSs haven’t been misplaced or removed from the register and any new/unused chemicals are added (or removed).

IMPORTANT: Don’t confuse a Register of Hazardous Chemicals with a Manifest of Hazardous Chemicals, these are two different documents and have two distinct purposes. There are different legal requirements for their preparation and implementation in the workplace.

Next Steps

To learn more about controlling the chemical hazards at your workplace, why not download our  free eBook How to manage the risk of Hazardous Chemicals in the workplace. Its’ written in clear, easy-to-understand text and teaches you how to implement a chemical risk management methodology. You’ll also gain valuable knowledge about safety inspections and audits.

  How to manage the risk of hazardous chemicals in the workplace

Walter Ingles

Walter Ingles Compliance Specialist

Walter is STOREMASTA’s Dangerous Goods Adviser. He loves helping businesses reduce the risk that Dangerous Goods pose upon their employees, property and the environment through safe and compliant dangerous goods storage solutions.

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