Hazardous Substances Software

hazardous substances inventory New Zealand SDS access

Direct answer. A New Zealand PCBU that manages or controls a workplace generally needs an up-to-date inventory of hazardous substances used, handled, manufactured or stored there, including hazardous waste. For each substance, WorkSafe says the inventory must include its name and UN number if available, the maximum quantity likely at that workplace, location, specific storage or segregation requirements, and a current safety data sheet (SDS) or condensed key information from it. The inventory must be readily accessible to emergency-service workers, including after the workplace has been evacuated. Keep a separate inventory for each site rather than a single unlocated company list. WorkSafe: hazardous-substances inventory.

This is a site inventory and access guide, distinct from a general hazardous-substances risk assessment or a product comparison. The existing NZ hazardous-substances software page owns the commercial software query. This page does not assert that Complys automatically classifies chemicals, obtains SDSs, calculates thresholds or fulfils every hazardous-substance obligation.

Why an inventory is more than a chemical shopping list

WorkSafe says the inventory helps a PCBU understand what hazardous substances are on site, identify applicable controls and prepare emergency procedures. It also informs emergency responders, compliance certifiers and inspectors. A purchase list misses chemicals generated in a process, materials brought in by contractors, waste and substances moved between work areas. An SDS folder without location and maximum-quantity information is equally incomplete. WorkSafe inventory guidance.

Begin by walking the site with people who use and store the materials. Include stores, workshops, vehicles based at the site, production areas, cleaning cupboards, laboratories where the general exception does not apply, maintenance areas and hazardous waste. Reconcile deliveries with what is physically present. Ask contractors what they bring and where they keep it. A spreadsheet made at headquarters cannot substitute for the local check.

Fields that matter for each substance

WorkSafe lists the name and UN number if available; maximum amount likely on site; location; specific storage and segregation requirements; and current SDS or a condensed version of its key information. Include hazardous waste. Use the product identifier that a worker or responder can match to the container. Where multiple products have similar trade names, add enough detail to distinguish them. Do not invent a UN number where none applies. WorkSafe inventory guidance.

“Maximum amount likely” is not a daily stock tally. WorkSafe explains it represents a realistic site maximum. Update it when substances or their likely maximum amounts change. A temporary seasonal peak, new contract or bulk delivery may change the maximum even if the average is much lower. Keep location information specific enough to help emergency responders find the substance safely, while recognising that routine transfers may require a procedure for updating the location.

Record storage and segregation requirements that affect how the site is arranged. Do not treat the inventory as the technical assessment itself: it should point to the relevant safety information and controls, and a competent person should evaluate incompatibilities, thresholds and special requirements. A complete field in a database is not proof that a storage area is compliant.

SDS information and worker access are different questions

The inventory must include a current SDS or condensed key information from it, according to WorkSafe's inventory guidance. Check that the SDS belongs to the actual product in use and is current for its supplier and formulation. If a contractor swaps to a different product, the old sheet may be misleading. Review whether staff can find the full information needed for safe work even if the emergency inventory uses a condensed summary.

An electronic inventory can be readily accessible, but ask what happens during power loss, a locked device, loss of mobile signal, an account suspension or evacuation. WorkSafe defines “readily accessible” as capable of being accessed without difficulty in hard copy, electronic or another form; it specifically requires access for emergency-service workers during an emergency and after evacuation. WorkSafe inventory guidance. Test the actual route by which a responder would get it, including who can grant access outside normal hours. A document held only in a manager's password-protected inbox may fail that practical test.

One inventory per site

WorkSafe says each workplace managed or controlled by the PCBU needs its own inventory. A business with multiple branches can use a common system, but responders need the site-specific substances, quantities and locations. If the same product is at three sites, that is three different operational contexts, not one entry with a company total. Assign someone locally to report changes and someone with authority to review the implications. WorkSafe inventory guidance.

For example, two depots may each hold a cleaning solvent. One keeps small containers in a cabinet; the other receives drums and has a nearby workshop. Their maximum quantities, locations, emergency arrangements and applicable controls may differ. The shared product SDS can be referenced, but the inventory and site decision cannot be copied without checking.

When to update it

Update the inventory whenever a substance changes or the maximum quantity likely at the workplace changes. WorkSafe says an update should also trigger review of the measures used to manage the substances. Practical triggers include a new product, supplier or formulation; a changed delivery size; a moved store; a new waste stream; a contractor bringing substances on site; a changed process; or a spill or near miss that shows the entry was wrong. WorkSafe inventory guidance.

Use a straightforward change process: a worker reports the change, the inventory owner checks it, the competent person assesses any new controls, and the current version is made available where responders expect it. Keep enough version history to understand what changed, but make sure the emergency copy clearly shows the current position. An annual review is useful; it cannot replace an update triggered by a significant change tomorrow.

Exceptions require careful reading

WorkSafe says any quantity of a hazardous substance generally triggers the inventory requirement, but identifies exceptions. Consumer products used in quantities and ways consistent with household use are one. Transit depots have a different list requirement for goods in transit. Laboratories using hazardous substances for research and development, analytical testing or teaching have an inventory exception, although they may still need records for tracked or unapproved substances. WorkSafe inventory guidance.

Do not stretch these exceptions to an entire business without checking the activity and site. A depot doing additional storage or handling may face duties beyond its transit-list arrangement. A laboratory's exemption from this particular inventory does not mean it has no hazardous-substance, SDS or worker-safety obligations. If uncertain, check the current regulations and WorkSafe guidance for the specific substance and operation.

A practical audit trail

For each site, record the inventory owner, last physical check, source of each SDS, when the maximum amount or location was last reviewed, and how emergency access was tested. Sample entries against containers and waste areas. Reconcile differences and assign actions for missing or outdated information. If a substance is removed, confirm whether residual material or waste remains before deleting it. If the substance is renamed or reformulated, preserve enough history to trace earlier incidents while ensuring responders see the current hazard.

The WorkSafe hazardous-substances calculator can help identify requirements, but it cannot know what is actually on your site unless the input is accurate. Check current regulator material and seek competent advice for threshold, certification and storage decisions.

Common mistakes

Keeping one company-wide list with no site-specific location or maximum quantity.
Omitting hazardous waste, contractor materials or temporary peaks.
Treating an SDS library as the inventory itself.
Using an SDS for a similar but different formulation.
Storing the electronic list where emergency responders cannot retrieve it after evacuation.
Waiting for an annual review after a significant product or quantity change.
Assuming small quantities automatically remove the inventory duty.

Complys and the next step

The existing NZ hazardous-substances software page is the relevant commercial owner if the organisation is considering digital records. This guide does not claim Complys can classify substances, supply current SDSs, calculate legal thresholds, certify storage or guarantee access to emergency responders. Start with one site: compare the present containers and waste against its inventory, then test whether a person outside the building can retrieve the current information.

Primary sources

For the related Complys product, see Hazardous Substances Software. This guide is general information, not legal advice; verify current requirements against the official sources linked above.