What Is a Chemical Register? UK Law and Best Practice
- A chemical register is a structured inventory of the substances and products held or used at a workplace, linked to locations, current SDS and relevant assessments.
- UK health and safety law does not generally prescribe one universal document called a chemical register, but employers still need reliable information to assess and control chemical risks.
- An SDS is not a COSHH assessment because it cannot describe the specific task, exposure, people, quantities and controls at an individual workplace.
- A useful chemical register records ownership and review status as well as product details, so missing SDS, reformulations and unassessed uses can be acted on.
A chemical register is a controlled inventory of chemical products and other relevant hazardous substances at a workplace. It usually links each item to its current Safety Data Sheet, location, use, hazards, responsible person and risk assessments. UK law does not generally prescribe one universal document called a “chemical register”, but employers still need enough reliable information to assess and control chemical risks.
What is a chemical register?
A chemical register records which chemicals and hazardous substances an organisation has, where they are and how they are managed. It gives safety teams a working view of substances across stores, laboratories, workshops, vehicles and other locations.
A spreadsheet can be a chemical register if it is complete, controlled and kept current. Specialist software can add permissions, version history, location records, reminders and links between products, SDS and assessments. The format matters less than whether the information is accurate and usable.
A chemical register is also called a chemical inventory, hazardous-substance register or COSHH inventory. Those names can describe slightly different scopes, so the organisation should define what its register includes.
Does UK law require a chemical register?
UK health and safety law does not generally require every employer to maintain a document with the exact title “chemical register”. However, several duties make an accurate inventory a practical foundation for compliance.
The HSE's COSHH guidance says employers must plan, manage and monitor substances hazardous to health. Employers need to identify harmful substances, assess the risk from the work and decide how exposure will be prevented or adequately controlled.
Employers with five or more employees must record the significant findings of their COSHH risk assessments. DSEAR similarly requires recorded significant findings for employers with five or more employees where dangerous substances create fire, explosion or related safety risks.
Suppliers must provide Safety Data Sheets in circumstances set by UK REACH. HSE explains that an SDS supports the employer's assessment but is not itself a risk assessment.
| Requirement or purpose | Is a document called a chemical register explicitly required? | How a register helps |
|---|---|---|
| COSHH risk assessment | Not generally by that name | Identifies substances, uses, SDS and assessment status |
| DSEAR risk assessment | Not generally by that name | Identifies flammables, gases, dusts and incompatible substances |
| SDS management | No universal register format | Shows whether a current supplier SDS is held and which products it covers |
| Emergency planning | Format depends on the site and risks | Provides locations, quantities and hazard information |
| Stock control and disposal | Usually a management choice | Finds duplicates, obsolete stock and unknown containers |
A register does not prove compliance by itself. It becomes useful when it drives assessments, controls, training, inspections and action.
Which substances should be included?
The register should include substances that are hazardous to health or safety, plus products and processes that need to be managed even when no supplier pictogram appears. The scope should reflect the workplace rather than just the purchasing catalogue.
Consider including:
- Purchased chemical products such as cleaners, adhesives, paints, fuels and laboratory reagents
- Process-generated substances such as dust, fume, vapour, mist and biological agents
- Waste chemicals and used oils
- Maintenance products and contractor-supplied substances
- Gases and aerosols
- Samples, intermediates and decanted products
- Products held in vehicles, cupboards and satellite stores
- Substances that are not classified as hazardous for supply but create risk because of how they are used
COSHH does not cover every hazardous material. Lead and asbestos, for example, are subject to their own specific regulations. They still need to be managed, and an organisation may choose to reference them in the same inventory while keeping the applicable assessment clear.
What information should a chemical register contain?
A useful chemical register combines product identity, document control, location and assessment status. Avoid collecting fields that nobody maintains, but include enough information to answer operational questions quickly.
| Field | Why it matters |
|---|---|
| Product name and manufacturer | Distinguishes similar products and links the correct SDS |
| Supplier and product code | Helps request updated information and avoid mistaken identity |
| SDS issue or revision date | Shows which document version is being used |
| Hazard classification and key H-statements | Supports initial screening and prioritisation |
| Physical form | Helps identify dust, splash, vapour and spill pathways |
| Location and approximate maximum quantity | Supports task assessment, storage planning and emergencies |
| Workplace use or activity | Connects the product to real exposure and process conditions |
| COSHH and DSEAR assessment status | Shows whether health and safety risks have been addressed |
| Storage or compatibility group | Supports segregation decisions |
| Responsible owner | Creates accountability for review and action |
| Last checked and next review | Makes data quality visible |
| Product status | Identifies active, quarantined, obsolete or awaiting-disposal stock |
The register should avoid copying every line of the SDS into a separate database. Store the source document, extract only the fields needed for management, and preserve the link to the correct version.
How do you build a chemical register?
Build a chemical register by surveying the workplace, matching products to current source information and assigning each item to an owner and assessment. Purchasing data alone is rarely enough because old, local and contractor stock may be missing.
1. Define the scope
Decide which sites, teams, vehicles, stores, processes and types of substances are included. Document how waste, samples, contractor products and process-generated hazards will be handled.
2. Survey every location
Inspect shelves, cupboards, benches, plant rooms, vehicles and waste areas. Record unknown or unlabelled containers as actions rather than guessing their contents.
3. Normalise product identity
Use the supplier's product name and code. Similar names can refer to different formulations, while one product may appear under inconsistent local names.
4. Obtain the correct SDS
Request the current SDS from the supplier where one should be provided. Match it using product identity, supplier and revision information, not a web search for a similarly named chemical.
5. Record use and quantity
Capture the activity, location, physical form, frequency and typical or maximum quantity. These details help prioritise assessment and storage decisions.
6. Link assessments and controls
Record whether the activity has a suitable COSHH assessment, whether DSEAR is relevant, and whether storage or emergency actions remain open. One product may need more than one assessment if tasks create materially different exposure scenarios.
7. Assign ownership and review
Give each record or location a responsible owner. Set review triggers and a proportionate schedule for physical stock checks.
Safe Foundry's chemical-safety features connect products, locations and documents, while the SDS-to-COSHH process shows how source information can feed a task-specific assessment.
How is a chemical register different from a COSHH assessment?
A chemical register identifies and tracks substances, while a COSHH assessment evaluates the risk from a particular work activity and specifies controls. Neither replaces the other.
| Chemical register | COSHH assessment |
|---|---|
| Answers “what do we have and where?” | Answers “how could this work harm health, and what controls are needed?” |
| Usually one record per product or substance | May require several assessments for different tasks or exposure scenarios |
| Links to an SDS and document version | Uses SDS information plus workplace-specific evidence |
| Supports prioritisation and oversight | Directs prevention, control, training and review |
An SDS adds the supplier's hazard information. The register makes that document findable. The assessment applies the information to the actual work.
How should supplier reformulations be managed?
A supplier reformulation should trigger an identity and assessment check, not a silent replacement of the old SDS. A familiar product name can continue while composition, classification or control advice changes.
When a new SDS arrives:
- Confirm the product and supplier identity.
- Record the new revision date and preserve the superseded document according to the organisation's retention policy.
- Compare classification, H-statements, composition ranges, exposure controls, storage advice and physical properties.
- Identify every location and assessment linked to that product.
- Review affected COSHH, DSEAR, storage and emergency arrangements.
- Inform workers where controls or instructions have changed.
Version history matters because it explains which information supported a past assessment. It also prevents a new document from being linked to stock that is actually an older formulation.
How long should chemical records and SDS be kept?
There is no single blanket retention period that applies to every chemical register, SDS and COSHH assessment. Retention should reflect the applicable regulation, exposure history, claims risk, document purpose and organisational policy.
Do not confuse general chemical records with COSHH health-surveillance records. HSE states that relevant health-surveillance records may need to be kept for 40 years, but that does not automatically impose a 40-year rule on every SDS or inventory entry.
Keep enough version history to show what substances were used, which information was available, what assessments applied and why controls changed. Seek competent advice where sector-specific or substance-specific rules apply.
How do you keep a chemical register accurate?
An accurate chemical register combines event-driven updates with periodic physical verification. A yearly review alone may leave incorrect data in place for months.
Use update triggers for:
- A new product, supplier or formulation
- A revised SDS or classification
- A change in task, quantity, location or storage
- New equipment, ventilation or PPE
- An incident, near miss or worker concern
- A product becoming obsolete or entering the waste stream
Regularly reconcile the register against purchasing, site inspections and disposal records. Track missing SDS, overdue assessments and unknown containers as visible actions. The help centre can support teams using the software to maintain those records.
A chemical register succeeds when a supervisor can answer, with evidence, what is present, where it is used, what could go wrong, which controls apply and what needs attention next.
Frequently asked questions
Does every workplace need a chemical register?
There is no single universal UK rule requiring every workplace to use a document with that exact name. A register is nevertheless a practical way to organise the substance information needed for risk assessment, control, training and emergency planning.
Is a list of Safety Data Sheets a chemical register?
Not by itself. A useful register links each product and SDS to where it is held, how it is used, the responsible person and the assessments or controls that apply.
Should non-hazardous products be included in a chemical register?
Include products that need to be managed for workplace safety or could become hazardous through the process, even if they do not carry a hazard pictogram. The scope should be defined and applied consistently.
How often should a chemical register be reviewed?
Use a risk-based schedule and update the register whenever products, suppliers, formulations, quantities, locations or work activities change. Regular physical checks help find stock that purchasing records miss.
Learn how to assess process-generated dust and fumes without an SDS by defining the process, exposure routes, evidence and practical controls.
How to Check an SDS Matches the Chemical You UseCheck that an SDS matches your chemical by comparing product identifiers, supplier, concentration, form, label classification and intended use.
COSHH Assessment Review Checklist for UK WorkplacesUse this COSHH assessment review checklist to compare records with current tasks, products, exposure routes, controls and workplace evidence.