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Hazardous Substances - Documentation and Record Keeping

8 March 2018

Hazardous Substances - Documentation and Record Keeping

08/03/2018 by Andrew Saunders - Hazardous Substances SME
 

Documentation and Record Keeping Requirements under the new Health and Safety at Work (Hazardous Substances) Regulations 2017

The new Hazardous Substances Regulations specify specific documentation and record keeping requirements. You must maintain a current inventory of Hazardous Substances. This inventory must include the product name and UN number, the maximum amount on site, its location/s, any storage and segregation requirements and the SDS. It must be accessible after an evacuation of the site.  You will need to have an Emergency Response Plan for triggering volumes of a wide range of hazardous substances listed in Schedule 5 of the regulations'. You must maintain a record of application or use of 6.1A, 6.1B, 6.1C, 6.6A, 6.7A, 8.2A, 8.2B and some other specified substances. You are still required to track a number of hazardous substances. 

 

Table 4: Legislated compliance tools

Legislated tools

Records

Current under

HSNO

Tracking

 

Future under

HSWA

Inventory

Application

Tracking

 

What will this mean for you?

You will need to ensure your inventory of hazardous substances is up to date.  Some will require records of use or application, who used it and where. While there are fewer classes to formally track you will need to track most class 1 and class 3.1A, 3.2A, 4.1.2A, 4.1.2B, 4.1.3A, 4.2A, 4.3A, 5.1.1A, 5.2A, 5.2B, 6.1A and 6.1B substances. And some substances that triggered generic tracking requirements under HSNO, Hydrofluoric Acid in Pickling Paste for example, triggered by a 6.1C classification, are identified specifically as requiring tracking in the regulations. Your inventory may be used to identify the specific controls you will need to place on specific hazardous substances.

Your Emergency Response Plans will need to be drilled annually and records of the drills kept. It will no longer be acceptable to pass a fire drill or evacuation drill off as a drill responding to an emergency caused by the loss or accidental release of a hazardous substance.

All substances, including substances decanted and stored in another container, and waste material, needs to be appropriately labelled in English with the name, hazard statement and appropriate pictogram.