What Is a Chemical Register and Do I Need One? A Plain-English Guide for Australian Business
- OHS News
- 1 day ago
- 5 min read
Quick question to start. How many chemicals are in your workplace right now?
If your honest answer is "not many, we don't really use chemicals," that is the assumption worth testing. Most small businesses have more hazardous chemicals on site than they think. The spray bottles under the sink, the degreaser in the shed, the aerosols on the shelf, the fuel for the mower, the pool chlorine, the adhesives, the paint. If a product carries a hazard pictogram on its label, the law treats it as a hazardous chemical, and that brings a few duties with it.
Here is the plain-English version of what those duties are, who they apply to, and how to get on top of them without turning it into a week of paperwork.
What counts as a hazardous chemical
A hazardous chemical is any substance, mixture or article that meets the criteria for a hazard class under the Globally Harmonised System of Classification and Labelling of Chemicals (the GHS). In practice, you do not need to memorise the classification rules. The label does the work for you. If the container shows a hazard pictogram (the red diamond symbols), a signal word like "Danger" or "Warning," and hazard statements such as "causes serious eye irritation" or "flammable liquid and vapour," it is a hazardous chemical.
Australia moved to GHS Revision 7 for workplace hazardous chemicals, and it has been mandatory since 1 January 2023 (Western Australia followed on 31 March 2023). So labels and Safety Data Sheets should now reflect GHS 7 formatting. If you are looking at packaging with old-style labelling and no pictograms, that is a sign the product, or your stock of it, is old.
This matters for the obvious chemical-heavy businesses (cleaners, mechanics, farmers, manufacturers, hairdressers), but it also catches cafes, offices and retail shops. A commercial kitchen degreaser and an industrial sanitiser are hazardous chemicals just as much as anything in a workshop.
The duty holder is the PCBU
Under Australian WHS law, the duty sits with the Person Conducting a Business or Undertaking, the PCBU. That covers sole traders, partnerships and companies of any size. If you run the business, the chemical duties are yours, and they apply whether you have fifty workers or none. The duty also extends to protecting other people affected by your work, which includes customers and visitors who could be exposed.
The three things the law actually expects
Strip away the jargon and the requirements come down to three things.
1. A chemical register
Under the model WHS Regulations, if you use, handle or store hazardous chemicals, you must keep a register. A chemical register is simply a list of every hazardous chemical at the workplace, with the current Safety Data Sheet for each one attached or filed alongside it. The register has to be readily accessible to any worker who could be exposed. That last part is the bit people miss. A register locked in the manager's office, or sitting on a drive nobody can find, is not readily accessible. It needs to be where your workers actually are.
2. Current Safety Data Sheets
A Safety Data Sheet (SDS) is the document that tells you what a chemical is, what it can do to you, how to store and handle it, and what to do in a spill or a first aid situation. The manufacturer or importer prepares it, and they must review it at least once every five years. That gives you a simple test for your own records. If an SDS is more than five years old, it is out of date and you need the current version.
This is where a lot of small businesses come unstuck. They built an SDS folder once, often years ago, and never touched it again. Here is what actually matters: an SDS folder is only useful if it is current and complete. Getting fresh copies is usually a two-minute job, since suppliers must provide them and most have them available to download.
3. Safe handling, storage and disposal
A register and a stack of SDS are the paperwork. The point of them is to drive safe handling. That means a short risk assessment for how each chemical is used, stored and disposed of, and the controls that follow. Incompatible chemicals stored apart (acids away from bases, oxidisers away from fuels), spill kits where they are needed, ventilation, the right PPE, and clear labelling on any decanted containers. A decanted spray bottle with no label is a common and avoidable hazard.
"But we only use a few cleaning products"
This is the most common pushback, and it deserves a straight answer. The volume does not change the duty. A small cleaning business or a cafe that stores a handful of hazardous products still needs a register, current SDS, and safe handling for those products. The list might be short, which actually makes the job easier, not optional.
There is a separate set of rules for businesses that store hazardous chemicals above certain quantity thresholds (manifest quantities), which can trigger placarding, a manifest, and notifying the regulator. Most small businesses sit well under those thresholds, so the register, SDS and safe-handling basics are the part that applies to you. If you store chemicals in bulk, check the thresholds for your state.
Three things to do this week
Do a walk-through. Go through every cupboard, store room, shed and work vehicle and write down every product that carries a hazard label. Be thorough. The forgotten tin at the back of the shed is exactly the one that causes trouble.
Get current SDS for each product. Download them from the supplier or manufacturer website, or request them. Check the date. Anything older than five years gets replaced with the current version.
Build one accessible register. Put the list and the SDS together in a single place your workers can reach, on site or on a device they actually use. Then set a reminder to review it, for example whenever you bring in a new product.
How this fits into a WHS Management System
A chemical register is one piece of a larger picture. On its own it tells you what you have. A WHS Management System connects it to the rest: the chemical management procedure that says how products are approved, stored and disposed of, the risk assessment forms, the labelling and decanting rules, the spill response, and the toolbox talks that make sure workers know how to handle what they are using.
For most small Australian businesses, you do not need a consultant or a subscription platform to get this right. You need the documents built for your industry, ready to fill in and use. The register tells you what is in the building. The system tells everyone what to do about it.
Make a start
If your chemical records are missing, scattered, or years out of date, this week's free Chemical Register gives you the format to get everything in one place.
For the full chemical management procedure, the risk assessment forms, and a complete WHS Management System built for your industry and aligned to Australian regulations, take a look here.
Everything OHS has helped more than 12,000 Australian businesses get their WHS documentation sorted since 2008, with 60+ five-star Google reviews along the way. Industry-specific documents, one-off price, no subscription.
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