Hazardous chemicals register

Slide 1

Hello. I’m Grant Hastie, the Chief Safety Advisor for hazardous chemicals in Workplace Health and Safety Queensland.

I am going to talk about how to create a hazardous chemicals register for your workplace. Under work health and safety laws, any workplace that stores, handles and uses hazardous chemicals must have a hazardous chemicals register.

Slide 2

In this presentation I am going to talk about:

1. what is a hazardous chemical under the work health and safety laws
2. how to establish and maintain a hazardous chemicals register and
3. what exemptions apply.

Slide 3

Keep your workers safe by knowing what chemicals are at your workplace and the harm they could cause.
It is important to understand what is a hazardous chemical as defined under the work health and safety laws so you know:

1. if a register is required and
2. what needs to be in your register.

The term hazardous chemical captures those chemicals that can cause harm to workers and other people, during storage, handling or use.

The work health and safety legislation uses the Globally Harmonised System of Classification and Labelling of Chemicals - known as the ‘GHS’ to determine what is hazardous.

The GHS provides the criteria to classify chemicals and identify its hazards and the relevant health and safety information to be included in the product’s safety data sheet, and container labels.

Slide 4

The safety data sheet, or SDS, is an important information source for managing the risks associated with the use of hazardous chemicals in workplaces.

The SDS contains key health and safety information like the chemical’s hazardous properties such as its flammability or reactivity or toxicity for example, as well as providing information on cleaning up spills, providing first aid, firefighting, and storage incompatibilities. This information is used to inform risk management processes.

The format and content for a compliant hazardous chemical product SDS is set out in the Preparation of safety data sheets for hazardous chemicals code of practice 2021 (PDF, 1.03 MB) .

Manufacturers and importers of hazardous chemicals are required to provide current information to workplaces about the hazardous chemical in the form of an SDS.

Slide 5

A hazardous chemicals register is important so you can manage the risks. You need to know:

1. what is stored, used and handled at the workplace
2. the harm the chemical could cause and
3. how to store, handle or use the hazardous chemical safely.

The register plays an important role to ensure you can easily access health and safety information and keep track of hazardous chemicals at the workplace.

You will use the information found in the register to conduct your risk assessment which leads to implementing control measures to protect workers and others from harm.

If you have hazardous chemicals at your workplace and don’t have a register, you can be fined.

Slide 6

What is a hazardous chemical register?

The register is a list of product names along with a copy of the compliant SDS.

The manufacturer or supplier of the hazardous chemical must provide you with an SDS that meets the requirements set out in the SDS Code.

Under certain circumstances there may be an exemption or exclusion for a hazardous chemical or its SDS. In these cases, the products do not need to be included on the register.

I will run though some example exclusions in more detail shortly.

Slide 7

You can use the Safe Work Australia template to develop a register that you can tailor to your needs. The register can be used to record other useful information such as the issue date of the SDS, the name of the manufacturer, the associated risk assessment reference or the storage location.

Including the additional information is up to you, however the minimum requirement is to have the list of product names and the SDS for each product.

You can find a copy of the register template on our website.

Slide 8

There are four easy steps to creating your register.

Start by making a list of all the hazardous chemicals in your workplace – Do a survey and include full and partially full containers. You may find them across your workplace… in workshops, chemical store rooms, warehouses, laboratories, gas stores and manufacturing areas. Containers may be relatively small packages measured in millilitres up to bulk containers holding thousands of litres.

Slide 9

You may choose to keep the list as a hard copy and attach the SDS. This may be practical if you only have a few products.

For a mobile workforce, or large workplace with different work areas and many hazardous chemicals, consider using a computer database as a practical solution.

Slide 10

Now that you have your list, you will need to make sure you have an SDS for each chemical as Step 2 of the process.
So how do you get the SDS? Contact the supplier or manufacturer/importer of the hazardous chemical who should provide you with the current compliant SDS.

Something to note: An overseas version of an SDS, without review against WHS laws, may not be compliant. It must meet the definition according to WHS laws and be compliant with the SDS Code of Practice like having Australian contact details for example.

Slide 11

Step 3. Create a system to keep your register up to date.

It is important to make sure your register and SDSs stay up to date. Make sure you add a new entry to the register when a new hazardous chemical is brought into the workplace or remove it from the register if the product has been removed and is no longer used.

Incorporate register management into your procurement procedures and carry out workplace audits to ensure all hazardous chemicals being used, stored or handled are on the register.

A compliant register means including current and compliant SDSs.

Slide 12

Manufacturers and importers are required to update SDSs at least every five years and may do more frequently, especially if new information about the hazardous chemical becomes available.

This could include:

1. new health hazard information
2. updates to first aid treatment
3. or updates to emergency response actions.

Implement a system in your workplace to ensure that the up-to-date SDS is obtained. For example, request an electronic copy of the SDS each time it is ordered or ask the supplier to advise you of the date or version number of the most recent SDS to crosscheck with your records.

This at least 5-yearly-review does not apply if the manufacturer or importer has not manufactured or imported the hazardous chemical in the past five years. So unless this circumstance applies, the SDS will be expected to be no more than five years old.

Slide 13

Step 4: Ensure your hazardous chemicals register is available to workers

You must make the register accessible to your workers or anyone else likely to be affected. This can be electronic, web based or hard copy.

You should also consider how this information can be accessed in an emergency situation if there is a power outage. Queensland Fire and Emergency Services attending an incident involving hazardous chemicals will often want access to the SDS and may have to isolate the power in order to safely manage an incident.

Slide 14

WHS laws are not designed to cover every chemical product or circumstance.

The focus in on chemicals that have potential to cause harm to workers and other people during the storage, handling and use of the chemical.

As mentioned earlier, when the WHS laws exclude or exempt a chemical from having a SDS, then it is not required to be included in the register.

Section 328 and Schedule 19 of the WHS Regulation provides more detailed information about what is excluded.

Slide 15

An example of an exemption is for consumer products that are used at the workplace in a way that is consistent with household use, in quantities consistent with household use, and is incidental to work activities.
For example, if you purchased fly spray from a retailer, it is a consumer product in the form of an aerosol can. Because it contains gas under pressure it is classifiable as a hazardous chemical and you can see health and safety warnings on the container.

However, if the way you use the spray in the workplace mimics how it would be used in the home it would be exempted from the register. This exemption would not apply if you used such products in larger quantities and more frequently as part of your job such as being a pest controller.

Slide 16

Another example exemption is for chemicals ‘in transit’. Products that are in the transport chain, are not being opened or used at the workplace and are not kept at the workplace for more than five days as they are moved on and transported elsewhere are also be exempted from the register. This exemption doesn’t apply if the same product is kept there all the time with containers coming and going as stock turning over, as the hazard remains for more than the conditional 5 day period.

Slide 17

Another SDS exemption is where a retailer is supplying consumer products to other premises without the retailer opening them.

This exemption would not apply if the retailer decants a product into a customer supplied container.

Slide 18

An example of this is illustrated in a short case study produced by Safe Work Australia about alcohol-based hand sanitiser. If you were using 500ml bottles of hand sanitiser in your workplace, this is considered a consumer product, and would therefore not need to be on the register.

However, if you purchased larger 5L containers, that you opened and used to fill smaller bottles, this is not consistent with household use so no longer meets the criteria for the exemption. The 5L product would require an SDS and needs to be on the register.

Slide 19

I hope that after listening to this presentation you feel more confident to prepare your hazardous chemicals register.
It’s an important part of managing risk, and penalties may apply if you do NOT have a compliant register for your hazardous chemicals.

Details about exemptions can be found in Section 328 and Schedule 19 of the Work Health and Safety Regulation.
To get started on your register, make a list of the hazardous chemicals in your workplace, make sure you have the current SDS for each chemical, create a system to keep your register up to date and make sure the register is available to workers.

Slide 20

Need more information?

Visit worksafe.qld.gov.au to find out more about hazardous chemical registers, SDS, what laws apply and to download an easy-to-use template.

Thank you for listening to this presentation. I hope this will help you create your hazardous chemicals register and assist you in creating a safe and healthy workplace.