A Practical Guide to Your Hazardous Substance Register

Think of a hazardous substance register as the master inventory for your worksite. It's a live document that lists every hazardous chemical you have on-site, shows where to find them, and explains the specific risks they pose. It's your go-to guide for managing chemicals safely.

What Is a Hazardous Substance Register?

A hazardous substance register is a practical tool for managing chemical risks. This is more than just another piece of paperwork; it's the central hub of information for safety functions on any construction site or factory floor.

This register is the foundation of your chemical management system. Without one, you're unable to properly assess risks, plan for emergencies, or give your workers the right safety information when they need it.

The Core Purpose of a Register

The main job of the register is to give you clear, immediate answers about the chemicals being used and stored on your site. Having this single source of truth is vital for many day-to-day operations.

For starters, it's the jumping-off point for any risk assessment. When you know exactly what substances you have and the dangers they bring, you can start identifying potential hazards and putting the right control measures in place to protect your team.

It also plays a huge role in emergency preparedness. If a spill happens or a fire breaks out, emergency services need to know exactly what they're dealing with to respond safely and effectively. The register provides this information quickly, preventing a bad situation from becoming a catastrophe.

A hazardous substance register isn't just for compliance; it's a fundamental safety tool. It ensures everyone, from workers on the floor to first responders, has the information needed to handle chemicals safely and react correctly during an incident.

A Legal Requirement in Australia

Let's be clear: keeping a register isn't optional. Under Australia's Work Health and Safety (WHS) Act, all businesses are legally required to maintain a list of hazardous chemicals. This framework creates a consistent approach to chemical safety across the country.

The WHS Regulations go further, mandating that manufacturers and importers provide a Safety Data Sheet (SDS) for each substance, which must be reviewed and updated at least every five years. You can learn more about the official requirements for a hazardous chemical register directly from Safe Work Australia.

This legal duty means your register has to be accurate and accessible. It's one of the first things an inspector will ask for when they walk onto your site.

Below is an example of what a basic hazardous substance register template might look like.

This simple layout shows the non-negotiables: the product name, where it's kept, and confirmation that a current SDS is on hand.

Understanding Your Legal Obligations in Australia

In Australia, keeping a hazardous substance register is a legal requirement under the model Work Health and Safety (WHS) Regulations. These rules exist to make sure every business takes responsibility for the chemicals on its site, protecting workers, visitors, and emergency responders. If you handle, use, or store hazardous chemicals, this duty falls on you.

The responsibility lies with the Person Conducting a Business or Undertaking (PCBU). It’s a broad term, but it basically means if you're in charge of the workplace, whether you're an employer, a sole trader, or a large corporation, you're in charge of the register.

You have to actively keep the information accurate, up-to-date, and available to anyone who needs it. When a WHS inspector walks onto your site, the hazardous substance register will be one of the first things they ask to see.

Core Requirements You Must Meet

The model WHS Regulations are clear on what your register needs to do. It’s about providing clear, accurate information that people can find and understand quickly.

The absolute must-have is linking every chemical on your register to its current Safety Data Sheet (SDS). The SDS is a document from the supplier that details a chemical's hazards, safe handling instructions, and what to do in an emergency. Your register must confirm you have the SDS for every substance, and that it's no more than five years old.

Another key legal duty is making the register readily accessible. This applies to any worker who might be exposed to the substances, as well as to emergency services. This is a practical test.

• For your team: Someone on the factory floor shouldn't have to hunt down a manager to unlock an office just to check a chemical's details. They need to be able to find and consult the register easily.
• For emergency services: In a crisis, firefighters can't waste time searching for a folder. The register has to be in a known, easily reachable spot, like the site office or near the main entrance.

What Does "Readily Accessible" Really Mean?

The term "readily accessible" is intentionally practical. It means your register can't be locked away in a filing cabinet where only one person has the key. It needs to be where the work is happening.

On a busy construction site, this might be a clearly marked binder in the site foreman's office or a digital version on a tablet in the lunchroom. In a manufacturing plant, it could be a computer terminal on the workshop floor or physical copies kept in each area where chemicals are used.

The goal is to remove any barriers to information. If a worker has a question about a substance or if there's a spill, they need answers now. The accessibility of your register is a direct reflection of your safety obligations. For a deeper look into the broader framework, you can learn more about what is OHS WHS in our guide.

While the Work Health and Safety framework applies across Australia, remember that small variations can exist between states and territories. Always check with your local WHS regulator for any specific rules in your area. It can also be useful to see how similar principles are applied elsewhere, for instance by looking at the UK hazardous waste disposal regulations.

How to Build Your Hazardous Substance Register

Building a hazardous substance register is about creating a living document that gives you a clear picture of what’s on your site, where it is, and how to handle it safely. The process starts with a systematic sweep of your entire workplace to make sure nothing gets missed.

Start with a full "chemical walkthrough." This means physically walking through every part of your worksite, from the main workshop and storage sheds to the site offices and even the back of work vehicles. The goal is to spot and list every substance that could pose a risk.

Be thorough. Check every cabinet, look on every shelf, and check every corner. It's easy to overlook chemicals used for maintenance or cleaning, but they're just as important as the materials used in your core operations.

Sourcing and Managing Safety Data Sheets

Once you have your list of chemicals, the next step is to get the Safety Data Sheet (SDS) for every single one. The SDS is the official instruction manual for a chemical. It’s provided by the supplier and details all the hazards, safe handling instructions, and emergency procedures.

You must have a current SDS for every chemical on your register. Under Australian WHS law, a supplier must review and re-issue their SDSs at least every five years. If you have an SDS that’s older than that, it’s out of date, and you need to get a new one.

The easiest way to get an up-to-date SDS is to just ask your supplier. They are legally required to provide you with the latest version. Once you have them, keep them organised. That could be a clearly labelled binder on-site or a digital folder that everyone who needs it can access instantly.

The infographic below breaks down the basic legal duties you have when it comes to managing your hazardous substance documentation.

As you can see, it comes down to three core steps: create the register, attach the correct SDS to each item, and make sure it’s easy for your team to find and use.

What Information Must Your Register Contain?

A simple list of names is a start, but a compliant and useful register needs more detail. The Australian approach to chemical management relies on clear documentation. At a minimum, your register must include the chemical’s name and have a current SDS for every hazardous substance listed.

You don’t need to go overboard. You can generally exclude non-hazardous chemicals or substances that are just in transit and stored unopened for five days or less. Standard consumer products used in the same way you’d use them at home are also typically exempt. For more detail, you can find information on what to include in chemical registers.

To turn your register from a simple list into a useful safety tool, it’s best practice to capture a few key data points for each substance.

The table below outlines the essential fields your register should have, plus a few extras that can make a real difference in managing your site safety.

Essential Data for Your Hazardous Substance Register

By capturing this level of detail, you create a central source of information that helps everyone from your workers to emergency services understand the risks and how to manage them.

Example Register Entry

Let’s see what this looks like for a common substance found on many sites: welding gas.

A solid entry in your register would look something like this:

Product Name: Argoweld 5 (Welding Gas)
Supplier: BOC Gas
Current SDS on File: Yes (Dated 15/01/2023)
Location(s) of Use/Storage: Workshop Bay 3; Gas Cylinder Store
Maximum Quantity On-Site: 4 x G-size cylinders

This entry tells you everything you need to know in a few seconds. You know the exact product, who it’s from, and that the safety info is current. Most importantly, you know exactly where to find it and how much is there, which is critical information for your team and any emergency responders. This makes a hazardous substance register a genuine asset for site safety.

Keeping Your Register Accurate and Up to Date

A hazardous substance register isn’t a ‘set and forget’ document. Its value depends on its accuracy; an outdated register is a safety risk. The key to keeping it current is building simple, consistent processes into your daily operations, not scrambling to fix it once a year.

The moment a new chemical arrives on site, a process needs to kick in. The best practice is to enforce one simple rule: no new chemical gets used until it's on the register.

This creates a foolproof system. When a delivery arrives, the person receiving it knows to immediately update the register and file the new Safety Data Sheet (SDS) before that substance is moved into storage. This small step prevents unregistered chemicals from entering your workflow.

Managing New and Removed Substances

A good system for adding new substances should be straightforward, ensuring everything is properly documented from day one.

1. Quarantine Upon Arrival: Don't let new chemicals go straight into the main storeroom. Set up a designated holding area where deliveries wait to be processed.
2. Verify the SDS: Check that the supplier has provided a current SDS (less than five years old). If it’s missing or outdated, contact them immediately.
3. Update the Register: Add all the required information for the new substance to your register before it’s released for use.
4. Label and Store: Once it's documented, make sure the container is properly labelled and move it to its assigned storage spot.

This process eliminates gaps in your records and makes certain that your workers always have the correct safety info before they handle a new product.

Just as important is managing what leaves your site. When a chemical is used up or disposed of, it needs to come off the register. Keeping substances listed that aren't there anymore clutters your records and gives a false picture of the risks on site.

An accurate hazardous substance register reflects the reality of your worksite today, not last month. It must track the lifecycle of every chemical, from arrival to final disposal.

The Importance of a Regular Review Cycle

Even with great daily processes, you still need to conduct regular, full-scale reviews. Think of it as a stocktake for your chemicals. This formal check ensures that small errors haven’t appeared over time and that your register remains a reliable source of information.

At a minimum, you should perform a complete review of your hazardous substance register at least once a year. Many businesses, especially those on dynamic sites where chemicals change frequently, find a six-month cycle works better.

During your review, you need to physically verify several key details against what’s actually on your site.

• Check for Expired SDSs: Go through every entry and check the issue date on its SDS. If any are getting close to the five-year mark, it’s time to get updated versions from your suppliers.
• Verify Quantities: Compare the maximum quantities listed in your register with what you can see in the store. This check makes sure you haven't exceeded safe storage limits.
• Look for Missing Chemicals: Walk the site with your register in hand. Are there any chemicals in storage or being used that are not on your list? This is a common blind spot, especially with cleaning or maintenance products.
• Confirm Locations: Make sure the storage and use locations you have listed are still correct. Operations change, and the register must reflect where chemicals are actually found in an emergency.

Managing Registers for Multiple Sites and Contractors

As your business grows, so does its complexity. Keeping a single hazardous substance register accurate for one site is tough enough. Managing it across multiple factories or construction sites is a bigger challenge, especially when each location has its own team and inventory.

Then you add contractors. Every time a subcontractor walks onto your site, whether it’s a plumber with sealant or a crew with solvents, they bring their own chemicals. If you're not tracking those substances, your hazardous substance register has a massive blind spot.

Handling Multiple Work Locations

When you're running more than one site, the goal is consistency. You need a single, standard format for your register so that anyone, from a site manager to a WHS inspector, can understand it at a glance, no matter which location they’re at.

A centralised digital system is the most practical way to tackle this. It lets you maintain a master hazardous substance register that can be filtered by location. The local site manager is then responsible for keeping their section of the register updated with only the chemicals physically present on their site.

This approach gives head office the complete picture they need while allowing individual sites to manage their day-to-day inventory. Most importantly, it stops each location from inventing its own system.

Controlling Contractor Chemicals

Here’s a critical point: you are legally responsible for all hazardous chemicals on your worksite, regardless of who brought them in. This means you must have a solid process for managing substances used by contractors before they start work. Leaving this to chance is a serious compliance failure.

The most effective way to manage this is through a strict pre-start approval process. No contractor should be permitted to begin work until you have reviewed and approved the chemicals they intend to use. This gives you total visibility and control.

This isn't about creating red tape; it's about fulfilling your legal duty of care. You have to know what substances are being introduced to your environment to assess the risks they pose to everyone on site, including your own employees. A robust contractor management system is essential for getting this right.

Contractor Chemical Approval Checklist

Putting a simple, mandatory checklist in place is a practical way to manage this process. Before any subcontractor sets foot on your site to work, they must provide the following for your review and approval.

• A Complete Chemical List: The contractor needs to give you a full list of every hazardous substance they plan to bring on-site.
• Current Safety Data Sheets (SDS): For every chemical on that list, they must provide a current SDS that is less than five years old.
• Planned Quantities: You need to know how much of each substance they will have on-site at any one time.
• Proposed Storage: The contractor must tell you exactly where and how they plan to store their chemicals safely.
• Risk Assessment: They should provide their own risk assessment for the chemicals they’re using, which you can then review against your site’s standards.

Only once you've gone through this information and are satisfied the risks are properly controlled should their chemicals be approved. Once they get the green light, these substances must be added to your site’s hazardous substance register for the duration of the project. This is the only way to ensure your register gives you a complete and accurate picture of every chemical hazard on your property.

Using Digital Tools to Manage Your Register

Spreadsheets are where most hazardous substance registers start. For a tiny operation, they might be fine. But they quickly become a headache, especially as you grow.

Trying to manually track SDS expiry dates, juggle different chemical lists across multiple sites, and chase down contractor paperwork over email is a recipe for a messy, error-prone system. This is where digital safety platforms come in, turning your register from a static document into a live, interactive safety tool.

These systems are built to automate the most painful parts of managing hazardous substances. Instead of manually chasing suppliers for a new Safety Data Sheet (SDS), a good digital platform flags expiring documents for you. Some can even automatically find the updated version from a central chemical database. That one feature alone can save countless admin hours and reduce the risk of having outdated information on file.

The real benefit of going digital is getting critical safety information into the hands of your team, right when and where they need it. A worker on the factory floor can scan a QR code on a chemical drum with their phone and instantly pull up the SDS, safe handling instructions, and required PPE. No more trekking back to the office to flip through a binder.

A Practical Digital Workflow

The workflow in a digital system is simple. Picture this: a new chemical arrives on site. Instead of starting a paper trail, the process looks more like this:

1. Scan the Product: A worker uses their phone or a tablet and scans the barcode or QR code on the new container.
2. Find the SDS: The system instantly searches a chemical database to find the latest, compliant SDS for that specific product.
3. Update the Register: With a couple of taps, the worker adds the chemical to that site’s register, logs the quantity, and notes where it’s being stored.

The whole thing takes a few minutes. Your site's hazardous substance register is updated in real time, making sure the information is always accurate and visible to everyone who needs it, from the site manager to the safety team at head office. For businesses looking into software options, you might consider how open-source form builder solutions could play a part in creating custom digital forms for this process.

By ditching paper and spreadsheets, you're not just making things more efficient. You're building a more reliable safety system that cuts down on human error and gives your team immediate access to the info they need to work safely.

Ultimately, purpose-built health and safety management software like https://safetyspace.co/health-and-safety-management-software is all about making compliance simpler and your data more accurate. These platforms create a single source of truth for your chemical inventory, automate the necessary updates, and can generate the compliance reports you need for an audit with just a few clicks. It frees your team up to spend less time on paperwork and more time focusing on safety on the ground.

Common Questions About Hazardous Substance Registers

Even with a solid system in place, some practical questions always come up when managing a hazardous substance register. Here are straight answers to the most common queries.

Do I Need to List Household Cleaning Products?

Generally, no. If you're using standard consumer cleaning products in the same way and quantity as you would at home, like a bottle of spray and wipe for the lunchroom, they are typically exempt.

However, the game changes the moment you start buying these products in bulk industrial sizes or using them for a commercial process. In those cases, they must be included on your register, and you need to have a current Safety Data Sheet (SDS) on hand for them.

How Often Should I Update My Register?

Think of it as a live document. You need to update your hazardous substance register immediately whenever a new chemical arrives on-site or when an old one is permanently removed. It has to accurately reflect what's in your inventory at any given time.

While the SDS for each chemical only needs a formal review every five years, your entire register needs a full check-up far more often. Best practice is to review it at least annually. This yearly check ensures all the details, like quantities and storage locations, are still correct.

What Is the Difference Between a Register and a Manifest?

It comes down to quantity.

A register is your complete inventory of all hazardous chemicals at a workplace, no matter how small the amount. A manifest, on the other hand, is a much more detailed document that’s only required when you store large quantities of dangerous goods above specific legal thresholds.

A manifest includes extra information like a detailed site plan and is specifically designed for emergency services. The key takeaway is this: if your quantities are high enough to require a manifest, you are also legally required to have a register. One doesn't replace the other.

Managing your hazardous substance register is a critical part of your WHS duties, but it doesn't have to be a painful admin task. Safety Space replaces clunky spreadsheets and outdated software with a simple, all-in-one platform that just works. Get real-time visibility, automate your SDS updates, and make compliance straightforward.

See how it works by booking a free demo.