Effort for the maintenance of a hazardous substances register

If a company uses hazardous substances, these must be documented and managed in a hazardous substances register. The Hazardous Substances Ordinance [1] states that the employer must keep this register, must note certain information and refer to documents, for example the safety data sheet. More modern hazardous substance registers often already contain the operating instructions for the hazardous substance. Of course, one must not only create the register, but keep it up to date too. Today I would like to discuss what the maintenance of a hazardous substance register means.

Maintaining a hazardous substances register with Excel

There are different ways to keep a hazardous substances register. In companies where there are only a few hazardous substances, an Excel spreadsheet is often sufficient. You could enter the necessary information here. Of course, this also means that the person in charge has to take care of (and remember) himself that changes might occur. For example, a change in the classification of the hazardous substance may mean that the register needs to get an update. Other changes, for example changes in the operating instructions, may also result.

Maintaining a hazardous substances register with a software

If you use a larger number of hazardous substances, Excel is usually no longer suitable. The overview is lost and, at the latest when updating, another way is necessary. Hazardous substance software, for example our GefStoff-Profi, is a good choice. But even here, it needs time to keep the hazardous substances and the hazardous substances register up to date. I will now show you what the maintenance of the hazardous substances directory means for a hazardous substances directory, using approx. 100 hazardous substances as an example.

What needs to be done at all?

First, of course, you have to identify which hazardous substances need an udate at all. With GefStoff-Profi you can use a query for this and contact the supplier of the hazardous substance if the safety data sheet is older than a period you have chosen. Let’s assume that about 1/3 of the hazardous substances need annual updates. If you receive a new SDS, you must enter it into GeSi³. With our online tool SDScheck® (currently only available in German) you can do this automatically, no typing is necessary. Nevertheless, this requires a certain amount of time; on average, approx. 10 minutes are necessary per SDS to upload, compare and import it. For 33 hazardous substances, this means an effort of 5.5 hours. And there may also be other changes, for example in the location reference of the hazardous substances. If the hazardous substance is now also used in other locations, they are relevant for the register as well.

Updating the operating instructions

In addition to maintaining the list of hazardous substances, further adjustments may also be necessary, for example in the operating instructions. However, updating the hazardous substance does not always lead to the need to update the relevant operating instructions. Let’s assume that this is necessary for half of the hazardous substances, i.e. for 16 of them. With GeSi³ you can update the operating instructions automatically from the hazardous substance, but you still have to rework some points and create a version. This results in a time expenditure of about 10 minutes per operating instruction, i.e. a total of 2.5 hours. In addition, for these 16 hazardous substances, one must also check again for any changes in the hazardous substance risk assessment. This requires another 2.5 hours in total. For the hazardous substances for which nothing has changed, and no update is necessary, it still takes some time to check this. Let’s assume 3 minutes per hazardous substance (45 minutes in total).

Updating the intranet portal

With our tool for creating an intranet portal, you can make your hazardous substances directory available to your employees. Depending on the configuration, they have access to the hazardous substance information, the safety data sheet and the operating instructions. Of course, you have to keep this up to date. With a larger database, this can also take longer due to the large amount of data, let’s assume half an hour’s time.

Maintenance of a hazardous substances register – Conclusion

With all the steps in this way, you will need about 2 days to maintain a list of hazardous substances. Normally, this is hardly ever done in one go, so let’s assume that you need a week to keep updating steps in between. Using a Software does not mean that you no longer have to invest time in maintaining your directory. However, the time you need is considerably less through automation in comparison to an Excel solution or other “manual” directories.

[1]        Ordinance on Protection against Hazardous Substances (GefStoffV), as of 07/2021