Hazardous chemicals register: Create, manage and stay compliant

A hazardous chemicals register is the single source of truth for every hazardous substance on your worksite. Think of it as your go-to document for managing chemical risks and meeting your Work Health and Safety (WHS) legal duties. It’s a complete, organised list of chemicals and their dangers, ready to go when you need it most.

Why a Chemical Register is Non-Negotiable

A hazardous chemicals register is much more than a simple inventory list. It's the foundation of your site's safety management, giving you a clear and immediate picture of the chemical risks you're dealing with. In industries like construction and manufacturing, where new substances are constantly coming and going, this document is critical.

Imagine a site manager facing an unexpected spill or fire. They need fast, accurate information, and they need it now. A well-maintained register is the first place they'll look to understand what substances are involved, their specific hazards, and the immediate steps for containment and first aid. Without it, emergency response becomes guesswork, putting workers and first responders in serious danger.

The Legal and Practical Requirements

Keeping a hazardous chemicals register isn't just good practice; it's a legal obligation. In Australia, the model Work Health and Safety (WHS) Regulations are clear: every person conducting a business or undertaking (PCBU) must maintain an accessible register for all hazardous chemicals used, handled, or stored.

The numbers show just how high the stakes are, with chemical incidents contributing to over 5,700 serious injuries annually. Safe Work Australia's official guidance on hazardous chemical records lays out the expectations in detail.

This legal duty has practical implications for your day-to-day operations:

• Accessibility is Key: The register must be readily available to any worker who might be exposed to these substances, as well as to emergency services. This means it can't be locked away in an office, it needs to be where the work is happening.
• SDS is a Must: For every single chemical listed, a current Safety Data Sheet (SDS) must be included. The SDS is your detailed guide on hazards, handling, storage, and emergency procedures.
• Keep It Live: The register has to be a living document. It needs to be updated every time a new chemical arrives on-site or an existing one is removed.

To help clarify what needs to be tracked, here’s a quick summary.

Register Essentials at a Glance

This table helps you focus your efforts on the substances that pose a genuine risk, avoiding unnecessary paperwork.

Dispelling a Common Myth

A lot of businesses get bogged down thinking they need to list every single product, from window cleaner to whiteboard markers. That’s not the case. Your focus is specifically on chemicals classified as hazardous according to the Globally Harmonised System of Classification and Labelling of Chemicals (GHS).

Proper hazard identification is the first step, helping you concentrate your efforts where they matter most. The point of this process is to build solid chemical safety across your operation. The register isn't about ticking boxes; it's a practical tool for proactive risk management.

Building Your Register From the Ground Up

Creating a hazardous chemicals register can feel like a big task, but if you break it down into practical steps, it's manageable. The goal isn't to create a document that just sits on a shelf to tick a box; it's to build a reliable, living tool that actively keeps your team safe. It starts with getting your boots on the ground and doing a thorough check of your entire worksite.

Kicking Off Your Chemical Inventory

First, you need a complete inventory. This means a physical walk-through of every part of your site to find every hazardous chemical you have. Don't just glance in the main chemical store and call it a day, you have to be methodical.

If you're in a manufacturing plant, that means checking production lines, maintenance workshops, cleaning cupboards, and any small labs. For a construction site, you'll need to look inside shipping containers, vehicle toolboxes, temporary storage areas, and anywhere subcontractors might store their materials. You'll often find forgotten containers of adhesives, solvents, or paints tucked away in a corner.

As you go, make a list. For each chemical, write down:

• The product name, exactly as it appears on the label.
• The manufacturer or supplier.
• Where it’s located on site (be specific: "Bay 3, Shelf 2" or "Plumber's van").
• A rough estimate of the quantity you typically keep on hand.

This initial sweep is your foundation. It gives you a real-world picture of what's actually on your site, which can be very different from your purchasing records.

Gathering and Checking Your Safety Data Sheets

With your inventory list in hand, the next job is to get the Safety Data Sheet (SDS) for every single chemical. An SDS is a document from the manufacturer that gives you the details on a substance's identity, hazards, and how to handle it safely.

The easiest way to get an SDS is to ask your supplier for it when you buy the chemical, they are legally required to provide it. If you have products on-site without an SDS, you can usually find it on the manufacturer’s website or by calling their technical support.

A critical detail to check on every SDS is the issue date. Under Australian WHS Regulations, an SDS must be reviewed and re-issued by the manufacturer at least every five years. If you have an SDS older than that, it's out of date, and you need to get the latest version.

This simple cycle shows how vital the register is for managing the whole process.

It’s not just a static list; it’s an active tool for recording, managing, and responding to chemical risks on site.

Structuring Your Hazardous Chemicals Register

Now it's time to pull all this information together. You can start with a simple spreadsheet or use a dedicated digital system. The format isn't as important as the information it holds and how easily your team can access it.

To be compliant and useful, your hazardous chemicals register needs to have a few key columns. Here’s a basic structure that works for most businesses:

This layout ensures all the essential info is in one spot, making it easy for workers and emergency services to find what they need in a hurry.

Connecting Labels, Products, and the Register

The final piece is making sure there’s a clear link between the physical containers on your site and your new register. Every single container of a hazardous chemical must be clearly labelled. The label has to be in English and show the product identifier and a reference back to the SDS.

For instance, if a team member decants a solvent from a large drum into smaller, portable bottles for daily use, those smaller bottles must also be labelled with the product name and its main hazards. This is non-negotiable, it prevents someone from mistaking a dangerous chemical for something harmless. The name on the container has to match the name in your register exactly, so looking up the corresponding SDS in an emergency is fast and foolproof.

Real-World Example: Managing Subcontractors

Picture a busy commercial construction site with multiple trades working at once. The head contractor is ultimately responsible for the site register, but every subcontractor brings their own chemicals onto the project.

Here's how it should work: the site manager requires every subbie to provide a list of their hazardous chemicals and the matching SDSs before they start work. That information is then fed directly into the main site's hazardous chemicals register.

So, when the waterproofing team shows up with their sealants and primers, their product details are added, noting their location as "Waterproofing Contractor's Storage Cage, Basement Level 2." When the painters arrive with their thinners and paints, their products are added the same way. This creates a single, central source of truth for the entire project, giving the site manager total visibility of all chemical risks, no matter who owns them.

Using Your Register to Manage Real-World Risks

A hazardous chemicals register is more than a compliance document. Think of it as a live tool for actively managing risk on the ground. Once you have a complete inventory and the right Safety Data Sheets (SDS), the real work begins: connecting that information to your team's day-to-day activities. This is where a simple list becomes a practical safety system.

The data you've collected is the foundation of your risk assessments. A risk assessment isn't just a theoretical exercise. It’s about looking at a specific chemical, understanding its hazards from the SDS, and then thinking about how your team actually interacts with it during their shift.

From Hazard Information to Practical Controls

The SDS will list potential hazards in plain terms, 'causes severe skin burns' or 'highly flammable liquid and vapour'. Your job is to translate that language into practical controls that make sense in your workplace. Simply writing down 'use PPE' is a huge mistake and not good enough.

What you need is a structured approach that prioritises the most effective solutions first. This framework is known as the hierarchy of controls, and it’s your roadmap for managing risk properly. It forces you to start with the most protective measures before settling for less effective ones.

• Elimination: Can you get rid of the chemical entirely and use a different process? This is the best option.
• Substitution: If you can't eliminate it, can you swap it for a less hazardous substance?
• Engineering Controls: Can you physically change the workplace to isolate people from the hazard? Think ventilation systems or machine guarding.
• Administrative Controls: Can you change how people work? This includes procedures, specific training, and clear signage.
• Personal Protective Equipment (PPE): Can you protect the worker with specific gear?

PPE is always your last line of defence. It relies on a person to use it correctly every time, whereas an engineering control works in the background to keep everyone safe. You can find more information in our guide on implementing control measures for risks.

A Real-World Scenario in Metal Fabrication

Let's put this into practice. Imagine a metal fabrication workshop that uses a highly corrosive acid for cleaning welds. The SDS confirms it can cause severe chemical burns and respiratory irritation.

Here's how a risk assessment, documented right alongside the chemical entry in your register, might look:

• Hazard Identified: Corrosive acid (e.g., Hydrochloric Acid).
• Work Activity: Manual cleaning of steel components in an open dip tank.
• Associated Risk: Skin or eye contact causing severe burns; inhalation of fumes causing lung damage.

Now, we apply the hierarchy of controls to figure out the best actions.

The goal is to build layers of protection. If one control fails, another is there as a backup. Relying only on PPE is a recipe for disaster.

You should document these controls directly against the chemical in your register, creating a completely connected and traceable safety system.

Documenting Controls for Your Team

To make this practical for everyone on the floor, your hazardous chemicals register should clearly link to the specific controls for each substance.

Here's a look at how you could structure that information in a table for the acid cleaning example. This clarity gives your team clear instructions, moving beyond vague advice to provide specific, actionable controls that directly address the identified risks.

Practical Risk Control Examples

This level of detail ensures there's no confusion about what's required to do the job safely.

Linking Incidents Back to the Register

Your register also plays a critical role when things go wrong. If an incident like a chemical splash or a major spill occurs, the register is your first point of reference for emergency response information. But its job doesn't end there.

After the incident is managed, you must log what happened. That record should be linked directly back to the specific chemical in your register. Why? Because this creates a crucial feedback loop for future risk assessments. If you start noticing multiple small spills or near misses involving the same substance, it's a massive red flag that your current controls aren't working.

This process is what turns your hazardous chemicals register from a static document into a living safety tool. It helps you learn from mistakes and prevent them from happening again. Ignoring these trends only leads to bigger problems down the line.

In Australia, workplace chemical hazards are involved in 5,700 serious injuries and 28 fatalities each year as of 2024. These aren't just abstract figures; they represent real people, families, and businesses impacted by failures in managing chemical risks. By connecting every incident log back to your register, you create a system that constantly learns and improves.

Keeping Your Chemical Register Accurate and Up to Date

Building a hazardous chemicals register is just the first step. The real work is keeping it a live, accurate document. An outdated list isn't just a compliance headache; it's a safety risk that can lead to the wrong first aid response or workers being exposed to something dangerous.

Your workplace is always changing. New products arrive, old ones get used up, and suppliers are constantly tweaking their formulas. If your register doesn't keep pace, it quickly becomes useless.

Setting a Practical Review Schedule

This isn't a task you can do once and forget about. To stop your register from becoming irrelevant, you need a simple but consistent review schedule. For most manufacturing or construction sites, a quarterly review is a good rhythm, with a full audit at least once a year.

A regular check-in doesn't have to be a massive job. The goal is to catch changes as they happen.

Here’s a quick checklist for your reviews:

• Walk the Floor Again: Do a physical walkthrough. You'd be surprised what pops up. Check the maintenance sheds, look in the back of subcontractor vehicles, anywhere new chemicals might have appeared since your last check.
• Purge What's Gone: Are there chemicals listed that you no longer use? Get them off the register. A clean, relevant list is a useful list.
• Check Your SDS Versions: Spot-check a few Safety Data Sheets (SDS). Manufacturers have to review them every five years, so if you have a version from 2015, it's time to get the new one.

Staying on Top of Regulatory Changes

The rules around chemicals aren't set in stone. Government bodies regularly update classifications, and these changes directly impact your register. A big one on the horizon is the Australian Industrial Chemicals Introduction Scheme (AICIS), which is expanding its list of 'chemicals with high hazards for categorisation' by 118 items from September 1, 2025.

This isn't a minor tweak. It means importers and manufacturers have to be far more rigorous, and it starts an annual update process. Considering that data already shows 40% of chemical violations in 2024 were due to outdated categorisation, it's clear how critical this is. You can learn more about these regulatory shifts and what they mean for your business.

An outdated register isn’t just a paperwork problem. It’s a direct failure in your duty of care. When an inspector walks on-site, one of the first things they'll ask for is your register, and you can bet they will check if it matches what's physically present.

Training Your Team to Actually Use the Register

A perfect register that only the safety manager knows how to use is pointless. Your team is on the front line, handling these substances every day. They must know how to find the information they need, when they need it.

Keep the training simple and practical. Show them where the register is, whether it’s a binder in the site office or a link on their phone. Do a live run-through: find a specific chemical, open its SDS, and point out where to find the crucial stuff like first aid info and what PPE to wear. This simple act turns the register from a compliance document into a daily operational tool.

Preparing for a Safety Audit

Sooner or later, a safety regulator will visit. Being ready for an audit of your chemical register will make the whole experience less stressful. Inspectors are looking for proof of a living safety system, not just a dusty folder.

Here’s what they’ll almost certainly check:

1. Completeness: Is every hazardous chemical on site actually on the list?
2. Accessibility: Can a worker on the floor get to the register and its SDSs quickly?
3. Currency: Are the SDSs up to date (issued within the last five years)?
4. Accuracy: Does the info in the register, like quantities and locations, match what they can see?

Good record-keeping is your best friend here. Document your reviews. A simple log showing the date of each check-in and what you did (e.g., "Added new SDS for Acetone," "Removed discontinued product X") is solid proof that you have an active management process. For some substances like asbestos, you're legally required to keep records for decades, so make sure you know the specific rules for the chemicals you handle.

Moving Beyond Spreadsheets to a Digital System

For a long time, a spreadsheet or binder full of printed pages was the go-to for managing a hazardous chemicals register. For a tiny, static site, maybe that’s fine. But as soon as you add complexity like multiple work areas, rotating teams, or projects with subcontractors, that system starts to fall apart.

The headaches are probably familiar. You're chasing the latest version of a spreadsheet, wondering if the one on the shared drive is the same as the one someone printed out last week. Or worse, a worker on the floor needs urgent info about a spill, but the register is locked away in the site office fifty metres away. This isn't just inefficient; it’s a real risk.

Solving the Manual Update Nightmare

The biggest time sink with a manual system is keeping it current. Chasing down suppliers for new Safety Data Sheets (SDS), manually checking issue dates against the five-year rule, and then updating every copy of the register is a massive administrative burden.

A digital system changes this. Instead of you doing the chasing, the platform does it for you. Good digital registers connect to a central chemical database that automatically flags when a manufacturer issues an updated SDS. You get a notification, review the new document, and accept it with a click. Just that one feature can save hours of admin work and, more importantly, ensures your register is always compliant.

Real-Time Access Where It Matters Most

In an emergency, speed is everything. A digital register puts critical information directly into the hands of the people who need it, right on their phones or tablets. A worker can scan a QR code on a chemical container and instantly pull up the SDS, first aid information, and required PPE. No frantic calls to the office, no time wasted.

It isn't just for emergencies. It makes daily safety checks far more practical. A supervisor can walk through a work area, spot a new product, and add it to the register on the spot, snapping a photo of the label and uploading the SDS right from their device.

A register that isn't easily accessible to the entire workforce is just a document for the safety manager. A digital system makes it a live, practical tool for everyone on site.

Centralised Control for Multi-Site Operations

Managing chemical safety gets much harder when you oversee multiple sites. A manufacturing company with three different plants or a construction firm running five separate projects can't rely on individual spreadsheets. It’s a recipe for inconsistency and compliance gaps.

A digital platform provides a single source of truth. From one central dashboard, a safety manager can see the register for every location. This gives you:

• Company-Wide Visibility: Quickly see which sites are using specific high-risk chemicals.
• Standardised Procedures: Ensure all locations follow the same protocols for risk assessments and controls.
• Simplified Reporting: Pull compliance and inventory data for the entire organisation in seconds, not days.

This level of oversight is nearly impossible with a fragmented, paper-based approach. For businesses looking to scale their operations safely, a solid document management program isn't a luxury; it’s a necessity.

A Practical Scenario on a Construction Site

Picture a large construction project with dozens of subcontractors, plumbers, electricians, painters, and waterproofers, all bringing their own chemicals onto the site. The traditional approach is a chaotic mess of emails and paperwork that no one can keep up with.

With a digital system, the process is clean. The head contractor grants each subbie limited access to the site's digital platform. Before they even step on site, the waterproofing subcontractor is required to upload the SDS for their primers and membranes. The platform then alerts the site manager, who reviews and approves them.

Just like that, the information is instantly part of the master hazardous chemicals register for the entire project. When a safety inspector shows up, the site manager can show a complete, real-time list of every hazardous substance on site, who it belongs to, and where it's located. It creates clear accountability and makes sure everyone is working from the same, correct information. The benefits are obvious: less admin, better compliance, and much faster access to critical data when it counts.

Questions We Hear All The Time About Hazmat Registers

Even with a great system in place, managing a hazardous chemical register brings up some common questions. Here are the direct answers to the queries we see most often from teams on the ground in construction and manufacturing.

How Often Do I Really Need to Update My Register?

You should be updating your hazardous chemicals register any time a new substance arrives on site, when one is removed for good, or whenever a supplier pushes out an updated Safety Data Sheet (SDS).

While a full, formal review is required at least annually, we find that sites with high turnover of chemicals or contractors get more value from a quarterly check-in. The goal is simple: the register must always be an accurate reflection of what’s actually on your site, right now.

What's the Difference Between a Register and an SDS?

It's a common point of confusion, but the distinction is pretty straightforward.

Think of it like this: your hazardous chemicals register is the table of contents for every hazardous substance on your project. It’s the master list. The Safety Data Sheet (SDS), on the other hand, is the detailed chapter for a single chemical, covering its specific hazards, how to handle it, and what to do in an emergency. You need both to be compliant.

Do Subcontractors Need to Keep Their Own Register On-Site?

No, and this is a critical point. There should only be one master hazardous chemicals register for the entire worksite. The Principal Contractor (or PCBU) is ultimately responsible for maintaining it.

However, your subcontractors have a duty to give you a complete list of all hazardous chemicals they’re bringing to site, along with the current SDS for each one. This information must be logged in your central site register before they start any work.

A common mistake we see is letting subcontractors manage their own separate chemical lists. This creates dangerous information silos and serious compliance gaps. For a safe and legally sound site, all chemical data has to feed into one central, accessible register.

Can My Register Be Digital, or Does It Have to Be a Hard Copy?

A digital register is absolutely fine, and it's far more practical than a paper-based one for most modern sites.

The key legal requirement is that the register must be readily accessible to all workers who might be exposed to the chemicals, as well as any emergency services that might have to attend your site. A cloud-based system that anyone can pull up on a tablet or phone on the workshop floor almost always meets this requirement better than a binder that lives in a site office.

Managing your hazardous chemicals register doesn't have to be a constant paperwork battle. Safety Space replaces those clunky spreadsheets and outdated binders with a simple, all-in-one digital platform. You can keep your register live, make sure your SDSs are always current, and give your team instant access to the information they need, right from their phones.

See how you can simplify compliance and protect your team. Book a free demo of Safety Space to see how it works.