SDS registers and hazardous chemicals: what a Victorian factory must keep

What must a Victorian factory keep for hazardous chemicals?

In Victoria, every workplace that uses or stores hazardous substances must keep a register listing each one, and hold a current safety data sheet (SDS) for it that workers can access. There is no minimum quantity threshold — a single drum of solvent counts. It is one of the first things a WorkSafe inspector asks to see.

In thirty years walking factory floors, the hazardous substances register is the record I most often find missing, out of date, or scattered across a supplier's old emails. It is also one of the easiest to fix. Here is what the law in Victoria actually requires, and how to get your register in order before anyone asks.

What is a hazardous substances register?

A hazardous substances register is a single, accessible list of every hazardous substance in your workplace, with the current safety data sheet for each one attached. Under WorkSafe Victoria guidance, employers must keep a register of all the hazardous substances in the workplace and make the current SDSs available to employees.

The register is not a filing formality. It is the master list your team, contractors and emergency services rely on to know what is on site, how it can harm someone, and what to do if it spills or someone is exposed.

What must a Victorian employer do?

WorkSafe Victoria sets out clear duties for employers who use or store hazardous substances. In plain terms, an employer must:

1. Keep a register of all the hazardous substances in the workplace.
2. Obtain a current SDS for each product and make it available to employees.
3. Never alter the information on an SDS.
4. Ensure containers of hazardous substances are correctly labelled.
5. Identify containers of waste.

These duties sit under the Occupational Health and Safety Act 2004 (Vic) and the Occupational Health and Safety Regulations 2017 (Vic), which set specific requirements for managing hazardous substances.

How current does a safety data sheet need to be?

An SDS must be current, not archived. Manufacturers and importers must review and revise each SDS as often as necessary, and at least every five years, so the information stays accurate. That means the SDS in your register should be no more than five years old and should match the product you actually hold.

A practical check: pull ten SDSs from your register at random. If any is undated, older than five years, or for a product you no longer stock, your register needs attention.

What makes a safety data sheet compliant?

Under WorkSafe Victoria guidance, a compliant SDS must be written in English, be legible, and include the following.

An SDS must include
Product identifier and chemical identity
Manufacturer or importer details
An emergency telephone number
Date of preparation or last review
Hazard identification, hazard and precautionary statements
Composition and hazardous ingredients
First aid measures
Firefighting and accidental release measures
Exposure controls, engineering controls and personal protection
Safe handling and storage information
Disposal considerations
Physical and chemical properties
Stability and reactivity information
Toxicological information and health effects

SDSs and labels in Australia follow the Globally Harmonized System of Classification and Labelling of Chemicals (GHS), an international system for hazard categories and warnings.

Who is responsible — you or your supplier?

Both, at different points. Manufacturers and importing suppliers must prepare an SDS for each product, give the current version to the workplaces that use or store it, and label the product consistent with the OHS Regulations 2017. Downstream suppliers must pass SDSs on to buyers — though this does not apply to retailers such as hardware stores.

As the employer and duty holder, you are responsible for collecting those SDSs, keeping them current in your register, and making them available on the floor. You cannot outsource that duty to a supplier.

What does an inspector actually check?

When a WorkSafe inspector looks at chemical management, they typically want to see the register itself, current SDSs that match the products on site, correct labelling on every container (including decanted and waste containers), and evidence that workers can actually get to the information. A register locked in a manager's office is not "available to employees."

The fastest way to fail is a container with no label, or an SDS that is a decade old. Both are visible in seconds and both are avoidable.

A simple way to stay audit-ready

Keeping a chemical register current is not hard, but it does need a system and someone who owns it. For a small manufacturer with no full-time safety manager, that is often where it slips. Having a safety practitioner review your register, close the gaps, and set a five-yearly SDS refresh keeps it defensible without becoming a second job.

If you want a second set of eyes on your chemical register and labelling before WorkSafe knocks, book a site assessment and we will walk your floor with you.

FAQ

Do I need a register if I only store a small amount of a chemical? Yes. WorkSafe Victoria guidance is to keep a register of all the hazardous substances in the workplace — there is no minimum quantity that exempts you. Even small amounts of a hazardous substance belong on the register with a current SDS.

How old can a safety data sheet be? An SDS should be current. Manufacturers and importers must review and revise each SDS at least every five years, so an SDS in your register that is older than five years should be replaced with the latest version from the supplier.

Can I edit an SDS to suit my site? No. Employers must not change the information on an SDS. If site-specific instructions are needed, add them in your own procedures or safe work instructions, and keep the supplier's SDS intact in the register.

This article is general information for Victorian manufacturers, not legal advice. Last updated: 23 July 2026.