A hazardous substances register must be kept and maintained in every company that handles hazardous substances. In today’s blog, I would like to explain exactly what the hazardous substances register is and the reasons for creating a hazardous substances register.
What is a hazardous substances register?
In principle, the hazardous substance register lists all hazardous substances that occur in the company. In addition to information on the hazardous substance itself, it is also relevant at which location which quantities are used. As the name suggests, hazardous substances are listed – roughly speaking, substances that have at least one H-phrase. There are exceptions, for example, if the hazardous substance poses only a minor hazard. We will look at this topic in more detail in a later blog post.
Reason 1: Occupational health and safety
The hazardous substances register is relevant for occupational health and safety. The hazardous substances register is therefore usually also compiled by a hazardous substances officer. For occupational health and safety, the hazardous substances register provides an overview with information on which hazardous substances are used at which locations and in what quantities. The hazardous substance register is therefore the basis for further steps such as hazardous substance risk assessments or hazardous substance operating instructions. The hazardous substance register can also be used to quickly obtain information, for example on whether CMR substances are present at a particular location.
Reason 2: Legal background
The obligation to keep a register of hazardous substances arises from the Hazardous Substances Ordinance. [1] Section 6, paragraph 12 describes that the employer must keep a register with the following information:
- Designation of the hazardous substance
- Reference to the safety data sheet
- Classification of the hazardous substance or information on hazardous properties
- Quantity ranges of the hazardous substance
- Work areas
Furthermore, it is not enough to create this directory. All employees concerned must be able to access the information (with the exception of quantity ranges).
Administrative offense
The Hazardous Substances Ordinance states that it is an administrative offense under the Chemicals Act [2] if the list of hazardous substancesis notkept, not kept correctly or not kept completely. If, for example, this endangers the life or health of another person, this is even punishable under Section 27 of the Chemicals Act.
Conclusion
Both occupational health and safety and the actual legal anchoring lead to the obligation to create and maintain a hazardous substances register. If there are only very few hazardous substances in the company, an Excel spreadsheet is often sufficient. However, as soon as more hazardous substances are used or the hazardous substances change frequently, this is usually no longer sufficient and it is advisable to use software for this purpose. Are you also looking for a tool to manage your hazardous substances? You are welcome to test the SDBcheck® hazardous substance directory free of charge and without obligation. After importing your safety data sheets via SDBcheck®, you can add locations and quantities and thus create your own hazardous substance directory and keep it up to date.
[1] Ordinance on Protection against Hazardous Substances (GefStoffV), status 07/2021
[2] Chemicals Act (ChemG), as of 08/2021
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