Hazardous chemicals register: what you need (AU workshops and sites)
What regulation 346 of the WHS Regulations requires in a hazardous chemicals register, what goes on it, what's exempt, the 5-year SDS review, and register vs manifest, for Australian workshops, fab shops and trades.
If your workshop, fab shop or site uses, handles or stores hazardous chemicals, the WHS Regulations say you must keep a hazardous chemicals register. That covers more than most people think: thinners, two-pack paint, galv spray, anti-spatter, brake cleaner, degreasers, acetylene and LPG cylinders, and pickling paste all usually carry hazard classifications.
The short answer
- The rule is regulation 346 of the model Work Health and Safety Regulations. Queensland, NSW, WA, SA, Tas, NT and the ACT have adopted the model WHS laws, and the register rule sits at the same regulation number. Victoria has its own OHS Regulations, so check WorkSafe Victoria if you're there.
- The register is a list of the hazardous chemicals used, handled or stored at the workplace, plus the current safety data sheet (SDS) for each one.
- It must be kept up to date: add products when they come in, take them off when you stop using them.
- It must be readily accessible to workers who use, handle or store the chemicals and to anyone else likely to be affected, including emergency services.
- The maximum penalties in the NSW version of reg 346 are 73 penalty units for an individual and 364 for a body corporate for not keeping the register, so it's worth getting right.
What goes on the register
At minimum: the product name of each hazardous chemical and its current SDS. Safe Work Australia says the register should be easy to use and available at any time. Most shops add a few columns that make it actually useful on the floor:
- Where it's stored (cabinet, bay, ute) and the largest quantity you normally keep
- What it's used for
- Signal word (Danger or Warning) and the hazard classes from section 2 of the SDS
- Dangerous goods class and UN number from section 14 of the SDS, if it has one
- The SDS issue or review date, and where the SDS is kept (folder, tablet, QR code)
- Whether a risk assessment and correct labelling are done
What doesn't need to go on it
According to Safe Work Australia, you don't need to list chemicals that aren't classified as hazardous, hazardous chemicals bought or used as consumer products where you don't need to obtain an SDS, or chemicals in transit that are unopened, unused and stored for 5 days or less (unless they're at your site in large amounts or frequently).
The consumer product catch: a can of WD-40 from the hardware store used the way a household would use it may be a consumer product. The same chemical bought in a 20 L drum and used all day on the shop floor generally isn't treated the same way. If you're not sure, get the SDS and put it on the register.
SDS: getting the right one and keeping it current
- You must get the SDS from the Australian manufacturer, importer or supplier no later than when the chemical first arrives, and before it's used. Safe Work Australia's code of practice says a third-party SDS on its own isn't enough.
- Manufacturers and importers must review each SDS at least every 5 years. The review date is usually in section 16. If the SDS in your folder is more than 5 years old, ask the supplier for the current one.
- When a supplier sends an amended SDS, swap it in and keep the register entry pointing at the new version.
Register vs manifest vs placards
The register applies to every workplace with hazardous chemicals. A manifest and outer placards are extra requirements that only kick in when you store large quantities above the thresholds in Schedule 11 of the WHS Regulations. Most small fab shops and trade workshops won't hit manifest quantities, but sites with bulk fuel, large LPG or big paint stores might, so check the Schedule 11 tables or ask your regulator.
Questions the other guides don't answer
Do I need one if I'm a sole trader working out of a ute?
The duty sits with the person conducting a business or undertaking (PCBU) at a workplace, and a ute or mobile workshop can be a workplace. If you carry hazardous chemicals for work, keeping a simple register with the SDSs on your phone or in the glovebox is the low-effort way to be covered.
Can the register be digital?
The rule is that it's readily accessible to workers and anyone likely to be affected. A spreadsheet plus PDFs on a shared tablet can work, but if the tablet is flat or locked during a spill, it isn't accessible. Many regulators suggest a printed backup near the store.
How often should I check it?
The law says "kept up to date", not a fixed interval. A practical routine is: update it every time a new product arrives or one is retired, and do a quick monthly walk-around of the chemical store to catch products nobody added.
What about gas cylinders?
Oxygen, acetylene, argon mixes and LPG are hazardous chemicals (and dangerous goods). They belong on the register with their SDSs like anything else.
Quick answers
Is a hazardous chemicals register a legal requirement in Australia?
Yes, in states and territories that use the model WHS laws (including QLD, NSW and WA), regulation 346 requires a PCBU to prepare and keep up to date a register of hazardous chemicals used, handled or stored at the workplace. Victoria has its own OHS rules.
What must a hazardous chemicals register include?
A list of the hazardous chemicals used, handled or stored at the workplace and the current safety data sheet (SDS) for each one.
How old can a safety data sheet be?
Manufacturers and importers must review an SDS at least every 5 years. If yours is older than that, ask the supplier for the current version.
Do consumer products need to be on the register?
Not if they're consumer products used in a way that means you don't need to get an SDS under the WHS Regulations. Products used in workplace quantities or ways generally should be listed.
Sources
- Safe Work Australia – Hazardous chemicals register
- Safe Work Australia – Model Code of Practice: Managing risks of hazardous chemicals in the workplace (PDF)
- Safe Work Australia – Preparing safety data sheets (5-year review)
- AustLII – Work Health and Safety Regulation (NSW) reg 346 Hazardous chemicals register
- WorkSafe Queensland – Hazardous chemicals
Related guides
- SWMS for high risk construction work, explained
- Toolbox talk topics for trades and fabrication
- Site induction checklist for construction sites
General information only, summarised from the official sources above as at the review date. It isn't legal, WHS or engineering advice. Rules change and your situation may differ, so check the source or ask a professional.