The Register and Manifest of Hazardous Chemicals are two separate documents specified by Australian Work Health and Safety (WHS) Regulations. If your workplace is required to hold either of these documents you must also make sure they are both kept up-to-date. While this blog explains the requirements of the WHS Regulations (to help you meet your safety obligations and avoid up to $30,000 in fines) we also emphasise that an update to either document probably indicates a change to the chemical hazards on the job site — which affects the level of risk to your workers.
Keeping your REGISTER of Hazardous Chemicals Updated
“A person conducting a business or undertaking at a workplace must ensure that … the register is maintained to ensure the information in the register is up to date.” Section 346 Model WHS Regulation
The Register of Hazardous Chemicals is a simple list of all the hazardous chemicals used, stored, or handled at your worksite. The Register must also contain the current Safety Data Sheet (SDS) for each of the chemicals. The primary purpose of the Register is for staff (who are using the chemicals or exposed to chemical hazards) to have ready access to safety, handling, and first aid information.
To keep the register up-to-date you’ll need to amend the document whenever:
New chemicals are introduced to the job site.
Chemicals are permanently discontinued.
Safety Data Sheets (SDSs) have been amended or updated by the manufacturer or supplier.
When updating your Register make sure the changes are reflected everywhere the Register is stored — eg, check that electronic updates to Register on the company intranet are reflected to individual workstations and ALL hard copy Registers are properly updated.
New Chemicals at the job site
Whenever new chemicals are introduced to the worksite you must do more than update the list of chemical names on the register: you’ll also need to obtain the SDS for the chemical and review any physical or health hazards. Could the new chemical react dangerously with any of the substances you already have at the job site?
At the same time you need to make sure your staff are aware that new chemicals are present onsite and understand the way they could affect their own health and safety. New chemicals at the workplace may also trigger:
Changes to your safety inductions
Alterations to operations manuals and job sequences
New locations for the Register
Additional signage or placards
The need to have a Manifest of Hazardous Chemicals
WORKPLACE EXAMPLE: your organisation wants to manufacture a new product which requires a flammable liquid (which is also corrosive) as part of the production process. The chemical has never used at the worksite before. Once it has been safely introduced to the workplace (SDS obtained, risk assessments conducted and control measures introduced, storage and decanting locations determined, staff training and PPE issued) the Register will also need to be updated.
Don’t keep obsolete chemicals listed on your Register of hazardous chemicals, if you stop using a substance (and it is completely removed from the worksite) it should be deleted from the Register. You’ll delete the name of the chemical from the master list and remove copies of the Safety Data Sheet. Hazardous substances used periodically or seasonally (even if not onsite) can stay on the Register.
WORKPLACE EXAMPLE: Your organisation decides to outsource the cleaning of the offices and administration buildings. Cleaning is carried out when the premises are closed and the cleaning company use their own chemicals which are stored offsite. The cleaning chemicals originally used by in-house staff (after they are completely removed from site) can be deleted from the Register.
Updating Safety Data Sheets (SDS)
The Register must have a current SDS for each of the hazardous chemicals, so if information on an SDS changes you will need to replace the copy kept in the Register. You should be aware that manufacturers are required by law to update an SDS:
If new information emerges about the chemical (often from scientific research projects).
When changes are made to the formulation (mix of chemical ingredients).
Every five years (from original preparation date or the last revision date).
We suggest recording the issue/amendment date of each SDS on the Register master list which you can quickly review during periodic audits and site inspections. Using the advanced search feature on the Hazardous Chemical Information System (HCIS) (which can display search results for chemicals based on their last review date) is an effective way of ensuring your Register is always up-to-date.
IMPORTANT: Changes to the SDS will almost always affect the chemical hazards at the workplace.
How to update your MANIFEST of Hazardous Chemicals
“A person conducting a business or undertaking at a workplace must …amend the manifest as soon as practicable if the type or quantity of hazardous chemicals changes; or there is a significant change in the information required to be recorded in the manifest.” Section 347 WHS Regulations
The Manifest of Hazardous Chemicals is required if your workplace exceeds threshold limits (defined in the WHS Regulation). It’s primary purpose is to notify emergency crews (responding to fires, chemical emergencies or other dangerous events) of chemical hazards and the quantities of Dangerous Goods kept onsite. Because the Manifest also includes a site map (drawn to scale) you’ll also need to update your Manifest if the site map changes in any way.
Updating important information
Amend the Manifest when changes are made to reportable information. Some examples include:
A change in management or site ownership.
After hours contact details are updated.
Renovations or construction change the physical layout of the work site.
Damage from natural disaster (flood, cyclone) or emergency situation (fire, building collapse) alters the job site.
Council or a utility company change an access point or exit.
Changes to chemical quantities
Update your Manifest as soon as practicable if chemical quantities change. Remembering that these changes may increase the level of risk to your workers and your entire Emergency Plan may also require auditing. Examples include:
An increase or decrease to the quantities of Manifest chemicals (eg, flammable liquids, toxic gases, organic peroxides)
Changes to the way the chemicals are stored (eg, installation of bulk tanks)
Changes to Dangerous Goods in transit
Changes to manufacturing output and processing capacity
When you reissue your Manifest you’ll change the ‘Last amendment date’; notify emergency services (if there has been a significant change to the level of risk); and remove the old Manifest from designated storage area and replace with the new one.
TIP: Read our recent blog Does your workplace need a manifest of hazardous chemicals? for full details of how to prepare and implement a legally compliant Manifest.
The Register and Manifest of Hazardous Chemicals are both important documents that assist you in providing a safe workplace. For more information about minimising chemical risks and complying with WHS legislation, download our free eBook How to manage the risk of Hazardous Chemicals in the workplace by clicking on the image below: