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NZ Tracked Hazardous Substances: Records and Transfers

September 29, 2026·11 min read

A hazardous substance can appear in the workplace inventory without being one of the highly hazardous substances that must be tracked. When tracking does apply, a simple stock count is not enough. The workplace needs a record that follows the substance while it is present, identifies who has responsibility and shows where it went when transferred, treated or disposed of. The transfer needs coordination with a receiving PCBU before the substance leaves.

New Zealand's Health and Safety at Work (Hazardous Substances) Regulations 2017 put tracking requirements in Part 19. WorkSafe's current tracking guidance explains the responsible person, record contents, access, transfer and retention. This guide gives a practical workflow for a PCBU that manages or controls a workplace holding a tracked substance. It does not classify a particular product or make a certified-handler determination. Those decisions require the product's actual classification and the current legal schedule.

The current legislation site identifies a consolidated version as at 30 July 2026 and notes an Arms Act 2026 amendment not yet incorporated. Explosive-specific classification and controls need a separate current check before publication or use. The workflow here stays with the general Part 19 record and transfer duties, without giving an explosive-specific answer.

Decide whether the substance is tracked

Start with the substance and its classification. Part 19 and Schedule 26 identify which hazardous substances are subject to tracking. WorkSafe describes examples among highly hazardous explosives, flammables, oxidisers, poisons and some vertebrate toxic agents, and points users to its hazardous-substances calculator. Those examples are not a rule that every product in a broad category is tracked. There are exclusions and substance-specific entries. Do not infer tracking from an alarming product name or a warehouse label alone.

Check the supplier information, current safety data sheet, relevant approvals and the actual Part 19 and Schedule 26 provisions. Use WorkSafe's tracking guide and calculator to identify the applicable control, then document the reason for the decision. If the classification or approval is unclear, resolve it before treating the substance as outside tracking. A team cannot maintain the right chain of custody if its starting list is guesswork.

Keep the general hazardous-substances inventory too. That inventory helps identify what is on site and assess applicable controls. A Part 19 tracking record is a more specific trail for designated substances. A single system may store both types of information, but a row in an inventory is not automatically a tracking record. Ask whether it identifies the competent person, exact location, movement, transfer and disposal history required for the tracked item.

Some substances may be treated or disposed of so they are no longer tracked. Do not mark them as “used up” merely because the current container looks empty. Record the actual treatment or disposal event and the quantity, then apply the relevant retention rule. For a substance moved to another workplace, record the destination and acceptance rather than deleting it from the stock list with no trail.

Identify the PCBU and competent person

WorkSafe says the business or undertaking with management or control of a workplace where the tracked substance is present is responsible for keeping its record. The record needs to identify a competent person in control of the substance. In WorkSafe's explanation, that can be a certified handler or someone who has received the information, training and instruction required to work with the substance. A certified-handler certificate is not universally required for every tracked substance or every task.

The PCBU should establish who actually has responsibility at each stage. A delivery arriving at a site, a substance kept in secure storage, an internal movement and a transfer to another workplace may involve different people. The named person must be able to exercise the relevant control, not merely appear on a form because they are the most senior manager. If a shift changes, the handover should preserve the trail and identify the next responsible person.

Evidence of training matters when the person relies on that route to competence. The WorkSafe tracking guidance says that transfer notification may need a copy of the certified-handler certificate or training record as applicable. Keep the evidence linked to the person and substance, but do not claim that a training record automatically proves all legal competence or replaces a separate certification where one is required.

If a workplace is controlled by more than one business in practice, coordinate who holds the Part 19 record and who can access it. The answer depends on management and control of the relevant workplace, not who ordered the product. A supplier's dispatch note is useful information but does not, by itself, fulfil the receiving workplace's tracking duties.

Build the live tracking record

Regulation 19.4 concerns the recording information. WorkSafe's record-content guidance lists the competent person's name, position, contact details and physical workplace address, the substance name and quantity, its exact location, transfers and disposal. If the competent person is a certified handler, relevant certificate details matter. Some vertebrate toxic agents require unique container identifiers. Check the actual product and applicable provision before selecting fields.

A practical record can have one enduring substance entry plus dated movement and disposition events. The enduring entry identifies the substance, classification basis, quantity received, container or batch identifier where useful, workplace and responsible person. Movement events show changes of location or custody. Transfer events identify the receiving PCBU, address, date and competent-person confirmation. Disposal or treatment events show how much left the tracked state, where, when and by what method.

Do not overwrite yesterday's location with today's location so that the earlier trail disappears. A record should explain where a substance was at a relevant time, not merely display its latest shelf. If an entry was wrong, make a visible correction with date and reason. That is good record practice and helps an inspector reconstruct the sequence. The regulation requires information; it does not prescribe one particular software event model.

Use identifiers carefully. A product name alone may be ambiguous if two similar containers are kept at different sites. A local container identifier can help distinguish them, but do not present every self-generated code as a statutory unique identifier. WorkSafe describes specific unique identifiers for certain vertebrate toxic agent containers. Keep those legal identifiers where applicable, and avoid inventing a general serial-number requirement for all tracked substances.

Test access before an inspector asks

The record must be useful at the workplace, not hidden in an archive. Regulation 19.5 concerns availability. WorkSafe says workers should be able to access tracking records readily and competent persons should understand them. Its guidance explains that a tracking record must let an inspector identify the recorded location within two minutes, then find the substance at that location within one hour or the shorter time specified in the emergency response plan.

Run a realistic retrieval test. Ask a person who did not create the record to find the current location of a named tracked substance. Can they access the record on the relevant shift? Does the stated location lead to the actual container? Is the competent person contact current? If a digital system is offline, is there an alternate method appropriate to the site's risk and emergency plan? The answer should be operational, not “the administrator can find it next week.”

Avoid recording a vague location such as “warehouse” when the substance is at a particular secure cabinet or designated area. Equally, do not post sensitive tracking details so openly that unauthorised people can locate a highly hazardous product. Design access so the workers and competent persons who need the information can get it while physical security remains effective.

Review record accuracy after delivery, relocation, shift change, transfer and disposal. A correct record at 9 a.m. can be wrong by midday if someone moves the container without updating it. Assign responsibility for each update. The tracking trail should match real custody, not a monthly inventory reconciliation completed after the substance has already gone.

Before transferring to another workplace

Transfer is not just a dispatch decision. Regulation 19.7 and WorkSafe's transfer guidance describe a written notification from the receiving PCBU before the tracked substance is transferred. It must confirm that a competent person is available to receive and accept responsibility and address a hazardous-substance location compliance certificate where required. Transit arrangements can also matter. Do not infer that the destination is ready because a purchase order has been raised.

Identify the receiving PCBU by legal and business name and street address, and identify the competent person and position. WorkSafe sets out further content and supporting evidence for the notification, including evidence of certification or training as applicable and any relevant location certificate. Use its current checklist for the actual transfer. A salesperson's informal message saying “send it over” does not establish all these matters.

At the sending workplace, verify that the notification is complete and applies to the substance and destination. Record the quantity and date leaving, recipient identity and address, and the person who accepted responsibility. If a carrier or transit depot is involved, check those arrangements separately. This guide does not decide dangerous-goods transport or transit-depot requirements. The Part 19 chain should not break while the product is between workplaces.

At the receiving workplace, create or update its record when the substance arrives. The sending workplace's record should show where it went. Neither side should silently transfer the item off one list and onto another without clear dates and identifiers. Resolve discrepancies in quantity, packaging or recipient before treating the handover as complete.

If the intended recipient changes at the last moment, pause and recheck the written notification. A competent person at the originally named site does not automatically cover a different location. A last-minute delivery diversion can change the relevant PCBU, certificate position and transit route. Record the actual destination and custody rather than forcing the paperwork to match the original plan.

Record treatment and disposal as actual events

When a tracked substance is disposed of or treated so it is no longer tracked, WorkSafe says the record should identify how much was involved and how, when and where it was disposed of or treated. A waste contractor collection note can support the trail, but the workplace record still needs to make the substance and event traceable. A container marked “empty” may need separate assessment if residue remains or the substance has merely moved to another vessel.

Keep the amount and method specific enough to reconcile with the preceding record. If five containers were held and only four were collected, the remaining one should still have a location and competent person. If the substance was neutralised or otherwise treated, record the process and evidence used to conclude it is no longer tracked. This guide does not certify the treatment or decide waste-law compliance.

Regulation 19.6 provides different retention periods after a tracked substance is no longer at the workplace. WorkSafe explains 12 months from transfer to another place and three years from treatment or disposal that ends tracking. These are not universal retention periods for all hazardous-substance records or all waste documents. Other legal, contractual or investigation-related duties may require separate retention.

Do not delete the live trail at the moment the substance leaves. Archive it with the transfer or disposal event and a calculated retention review date. If a notifiable incident or investigation is connected with the substance, preserve relevant material under the applicable process rather than relying on a routine deletion schedule. Keep the disposition clear so the site can explain why a substance no longer appears in current stock.

A monthly check that catches gaps

Select one tracked substance and walk its trail from receipt to present location or disposition. Compare the entry with the physical container, quantity, competent person and storage location. Check whether the record can be found quickly by someone other than its author. If it has left, inspect the written recipient confirmation or disposal details and the retention date. If a movement is missing, correct the record transparently and investigate how custody became uncertain.

This check does not turn the monthly interval into a legal rule. Frequency should reflect the substances, movements and risks at the actual workplace. A site with frequent transfers may need checks at each handover and more frequent reconciliation. A quiet site still needs immediate updates when a tracked substance moves. The monthly sample is merely one way to test whether the system works.

Do not mistake a clean spreadsheet for safe custody. The substance must be secured or under appropriate competent-person control, and the workplace must manage its other storage, emergency and training duties. The record supports those controls but cannot create them. Conversely, a secure cabinet with no usable record can leave the PCBU unable to show where the substance went or who accepted it.

For the broader New Zealand hazardous-substances regime, start with the live overview. This guide owns the narrower Part 19 tracking trail. If you want to evaluate Complys for your record workflow, ask to see the current New Zealand product and confirm the actual functions. No unverified chain-of-custody, automatic classification or competence-checking feature is assumed here.

Recheck this page when Part 19 or Schedule 26 changes, when the unincorporated Arms Act 2026 amendment is reconciled, when WorkSafe updates its tracking guidance, or when the proposed owner is compared with a newly published route. The practical test remains simple: can the PCBU say exactly which tracked substance it has, where it is, who controls it and what happened when it moved or left the tracking system?