Is a hazardous substances register mandatory?

Whether and how you have to keep one depends on your situation and the rules for your work. As an employer you do have to map the risks of substances and inform employees, and a register is the practical way to do that. Check the current requirements with the Netherlands Labour Authority or in the occupational health and safety catalogue of your sector.

What is the difference between SDS, VIB and MSDS?

They are names for the same type of document. VIB is the Dutch abbreviation for veiligheidsinformatieblad, SDS stands for Safety Data Sheet and is the international term. MSDS is the older name you still often come across, but SDS is the term in common use now.

What do you do if a supplier does not provide a safety data sheet?

Request it in writing and record the request. If no sheet arrives, consider another supplier or another product, and in the meantime do not use the substance without clear information on the hazards. Without a sheet you cannot properly assess the risks or instruct your employees well.

Hazardous substances register: SDS, labels, storage

What are hazardous substances in the workplace?

Hazardous substances are products that are harmful to people or the environment, or create a fire or explosion hazard. Think of paint, glue, solvents, cleaners, fuels, aerosols and gas cylinders. Even things you do not see as chemicals in your daily work can fall under it.

Do not forget the substances that arise during the work either, such as welding fumes, wood dust or dust from grinding and drilling. They have no label, but need the same attention in your risk assessment. The inventory of hazardous substances therefore belongs with your RI&E.

Step 1: make an inventory

Walk through all workplaces, warehouses, vehicles and storage rooms and write down what you find. Also ask employees what they use, because purchasing does not know everything. Record per product the details you will need later:

Product name and supplier
Where it is used and where it is kept
Approximate quantity and type of packaging
Who works with it and how often
Hazard marking on the label and the date of the current safety data sheet
An owner within the organisation who looks after the product

What is in a safety data sheet?

The safety data sheet (in Dutch VIB, in English SDS) is the supplier's reference document. Every sheet has the same structure of sixteen sections, covering among other things hazards, safe use and storage, protective equipment, first aid and fire. The sheet is the source for almost everything else you record in your register and instructions.

Professional users usually receive the sheet from the supplier. If you do not have it, ask for it. Do not just read it once, but derive concrete working agreements from it: which gloves, which ventilation, what to do in case of a spill. The sheet describes the substance, you translate it to your workplace.

How do you keep safety data sheets up to date?

Suppliers revise sheets when the composition, the classification or the legislation changes. A five-year-old sheet is therefore suspect. Agree that a new version is first assessed by a competent colleague before it replaces the old one, and keep the date and the name of the assessor.

Also schedule a fixed review moment at which you check per product whether the sheet is still the latest. If you no longer use a product, remove it from the register. Make sure employees can find the sheet quickly, also on site and in a language they understand.

Labels and pictograms: CLP in plain words

CLP is the European regulation on classifying, labelling and packaging substances and mixtures. The label shows the product name, a signal word (danger or warning), pictograms in a red-and-white diamond, hazard statements (H statements), precautionary statements (P statements) and the supplier's details.

The pictograms show at a glance what to watch out for: a flame for fire hazard, a symbol for corrosive substances, a skull for acute toxicity, an environment symbol for danger to water. If you pour a product into another bottle, label that container too. A nameless bottle is a classic source of accidents. Read the details at the RIVM or the Netherlands Labour Authority.

Storage: what you need to have in order

How you store depends on the substance, the quantity and your situation. Guidelines exist for packaged hazardous substances, in the Netherlands among others the PGS series, and sometimes a permit or notification is needed. Check what applies to you with your municipality or environmental agency. As general starting points:

Keep incompatible substances apart, for example flammable liquids not next to oxidising substances and acids not next to alkalis
Use suitable, lockable cabinets and spill trays for leaks
Keep only a small quantity at the workplace, the rest belongs in storage
Ensure ventilation, distance from ignition sources and clear escape routes
Always leave products in the original or properly labelled packaging
Check the storage periodically, for example at every workplace inspection

Instruction: who needs to know what?

Employees who work with hazardous substances must know what the product does, how to use it safely and what to do in an accident. A workplace instruction card (WIK in Dutch) summarises that on one page: hazards, protective equipment, safe working, first aid and what to do in case of a spill or fire.

Give the instruction before first use and repeat it periodically and after a change in product or working method. Record who was instructed and when. A short toolbox talk at the workplace often works better than a thick sheet, provided you check afterwards whether people apply it.

Substitution: first check whether it can be less hazardous

The best control measure is not using the hazardous product at all. Check whether you can replace it with a less harmful variant, for example a water-based instead of a solvent-based paint. If that does not work, adjust the process, for example with extraction, before you rely on protective equipment.

Protective equipment is the last resort. It only protects the wearer, must fit well and is not always used consistently. Record the weighing up: what was considered, what was chosen and why. That shows an auditor or inspector that you have taken it seriously.

Common mistakes

Most problems with substances are inconspicuous and therefore persistent. You spot them on every walk-round, if you consciously look for them. A short spot check with these points on the list quickly shows where you stand:

A register that was right at the time of the inventory and never updated afterwards
Safety data sheets that sit in a folder but are not available at the workplace
Decanted products without a label
Products nobody knows who uses and that stay on the shelf for years
Instruction that is not repeated or not recorded
Legal obligations around substances that nobody checks periodically

How BrydgeOne supports this

The substance register in the Hazardous substances module keeps track of all substances, from safety data sheet to storage and workplace. You work per language with one current, assessed SDS version, record use and exposure and publish workplace instruction cards. Employees find instructions in the employee app or via a QR code.

With Workplace inspections you check storage and workplace with your own checklists, in Training you record who has been instructed, and Compliance obligations helps you track and demonstrate laws and regulations around substances. That way register, checks, instruction and obligations sit in one environment.

Managing hazardous substances: register, safety data sheets and storage