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Safety data sheets and the chemical substances and SDS register: what really has to be under control

Controlling chemicals in a plant rests on three things: a complete register of the substances and mixtures actually in use, current safety data sheets supplied by vendors, and making that information available to workers at the point of use. A register without current sheets is a list of names; sheets without a register are a binder nobody opens.

Safety data sheets are rarely the problem in themselves. The problem is that nobody knows how many substances are really on site, who ordered them, or whether the sheet in the binder matches the version of the product standing in the store.

  • Chemical substances and SDS
  • SDS
  • Substance register
  • Exposure

Published: 2026-01-27 · Updated: 2026-11-01 · 9 min · Varilo deployment team

Safety specialist in a chemical store with GHS pictograms checking the chemical register and safety data sheets on a tablet in VIMS EHS
Safety specialist in a chemical store with GHS pictograms checking the chemical register and safety data sheets on a tablet in VIMS EHS

The register: where to start the inventory

A register is built from three sources at once, and none of them is sufficient alone. The first is purchasing — every chemical line item from the last twelve months. The second is a walk through stores and workstations: the cans, drums and bottles physically present. The third is a conversation with supervisors about products bought ad hoc, outside the procedure.

Comparing those three lists almost always shows a gap. Substances bought once and untouched for years take up space and need disposal; substances in use but absent from purchasing records mean an informal supply route runs alongside the procedure.

For each entry, keep a minimum set: trade name, manufacturer or supplier, purpose, place of use and storage, approximate quantity, the date of the safety data sheet and a responsible person. That is enough to answer most inspection questions without opening a binder.

Which SDS sections matter operationally

The sheet has sixteen sections, but the shop floor works with five. Section 2 covers hazards and hazard statements — this is where you check whether the substance is carcinogenic, mutagenic, toxic for reproduction or a strong sensitiser, because that changes health surveillance and register requirements.

Section 4 is first aid, content that must be available immediately rather than after a call to the office. Section 7 covers storage and incompatibilities, answering what must not stand next to what. Section 8 gives limit values and required personal protective equipment, and section 13 covers waste and residues.

The practical consequence is that a worker does not need to read the whole sheet. They need an extract of those sections at the workstation, with the full sheet available on demand — for example after scanning a code on the rack.

That extract becomes the workstation card: a single page with the GHS pictograms, the signal word, the key hazard and precautionary statements, the required protective equipment and first-aid rules. It is a document a worker reads in half a minute — unlike the sixteen pages of the full safety data sheet.

VIMS EHS — Example workstation card for a hazardous substance with GHS pictograms, hazard statements and personal protective equipment (Polish example)
An example workstation card (Polish): GHS pictograms, hazard statements, required PPE and first aid — an extract of the full safety data sheet, readable in half a minute.
VIMS EHS — The nine GHS/CLP hazard pictograms with explanations: flammable, oxidising, explosive, corrosive, gases under pressure, toxic, irritant, serious health hazard, environmental hazard
The nine GHS/CLP pictograms used on labels and in safety data sheets. They determine the content of the workstation card and the required protective measures.

Currency: how do you know a sheet is out of date

A sheet has no expiry date in the everyday sense, but it becomes outdated when the classification changes, the mixture composition changes, regulations change, or the supplier changes. The manufacturer must send an updated version to recipients, but in practice the new sheet lands in the purchasing inbox and stays there.

An effective mechanism is simple: at every delivery, the person receiving goods checks the sheet date and version on the packaging or documents against the version in the register. A mismatch creates a task for whoever owns chemicals.

The second mechanism is a periodic register review — quarterly for high-hazard substances, annually for the rest. The review also asks whether the substance is still used. Removing an entry matters as much as adding one.

From PDF to workstation card: the digital sheet workflow

In practice, most of the time goes not to reading sheets but to retyping them: copying hazard statements into the risk assessment, copying protective equipment into the workstation card, copying the name and supplier into the register. Every retyping is a chance for an error and one more document version to track.

In VIMS the workflow starts with uploading the safety data sheet PDF to the chemical substances and SDS register. The system reads the key data from the document — product name, manufacturer, pictograms, hazard and precautionary statements, required protective equipment — and transfers it to the substance record. From that data it generates a printable workstation card, and a QR code at the rack or workstation lets a worker open the full sheet on a phone.

When the supplier sends a new version, uploading it to the same record updates everything in one place: the register version, the workstation card and the content behind the QR code. No replacing pages in binders, no checking which copy on the floor is current.

VIMS EHS — Digital safety data sheet workflow: supplier PDF, import into the chemical substances and SDS register, substance register with sheet version, workstation card with QR code at the rack
The digital SDS workflow in VIMS: from the supplier's PDF, through the substance register, to the workstation card and a QR code at the rack (diagram in Polish).

Connecting chemicals to exposure and health surveillance

The chemical substances and SDS register is not a standalone document. Substance properties determine the scope of workplace exposure measurements, and those results shape the scope and frequency of health surveillance and the content of the risk assessment.

Introducing a new substance should therefore raise three questions automatically: does the measurement list change, does the health surveillance referral for people at that workstation change, and does the risk assessment need review. If only one person's memory asks those questions, sooner or later one will be missed.

Glossary: SDS, MSDS, REACH, CLP, UFI, PCN and CMR

A safety data sheet (SDS, formerly MSDS) is the supplier's 16-section document required by Article 31 of REACH, in the official language of the country where the product is placed on the market. The supplier provides and updates it; the employer makes it available to workers.

CLP is the classification, labelling and packaging regulation: GHS pictograms, signal words and H (hazard) and P (precautionary) statements. The UFI (unique formula identifier) is a 16-character code on hazardous mixture labels linking the product to its PCN notification to poison centres via the ECHA portal; for industrial-use mixtures the UFI may appear in SDS section 1 instead of the label.

SDS vs workstation chemical card: the SDS is the supplier's document, while the workstation card is the plant's extract — hazards, protection, first aid and spill response in language workers understand. See the chemical register and SDS module.

CMR substances are carcinogenic, mutagenic or — after the EU amendment — reprotoxic. Work exposing staff to them requires a register of work and of exposed workers, kept for 40 years, and annual reporting to the sanitary inspectorate. Stricter measurement intervals are covered in the exposure measurements guide.

The most common inspection findings on chemicals

The most common is straightforward: the sheet is in a binder in the office and unavailable at the workstation. The second is a substance standing in the hall and missing from the register. The third is decanting into an unlabelled container — a frequent and risky shortcut when diluting cleaning agents.

The fourth concerns storage: incompatible substances kept together, no spill containment, no ventilation. The fifth is inconsistency between the chemical substances and SDS register, the risk assessment and health surveillance referrals — three documents describing three different realities.

A binder of sheets vs a digital chemical substances and SDS register

Both forms satisfy the requirement of access to the safety data sheet, but they differ in upkeep cost and resilience to errors.

AreaBinder and printoutsDigital register in VIMS
Sheet currencyThe new version reaches the office; the floor copy stays oldUploading a new version updates the register, the workstation card and the QR view
Access at the workstationA printout at the station or a walk to the officeA QR code at the rack — the full sheet on a phone in seconds
Workstation cardPrepared by hand, retyping statements and pictogramsGenerated from data read out of the SDS, one template for the whole plant
Link to risk assessment and health surveillanceManual retyping between documentsThe substance linked to the workstation, measurements and referrals
Register reviewCounting entries and checking dates by handA list with version dates and assigned owners, ready for review
Evidence for inspectionsBinders, signatures, printoutsVersion and change history in one place

Chemical management checklist

  • The register was built from purchasing, a walkthrough and supervisor input, not a single source.
  • Every entry has a safety data sheet with a date and version.
  • An extract of sections 2, 4, 7, 8 and 13 is available at the workstation.
  • Goods receipt includes checking the sheet version.
  • Incompatible substances are separated in storage.
  • No products are kept in unlabelled containers.
  • A new substance triggers a review of measurements, health surveillance and risk assessment.
  • Withdrawn substances have been removed from the register and disposed of.

Frequently asked questions

Does the safety data sheet have to be on paper?

What matters is unrestricted access for the worker at the place and time the substance is used. Electronic access meets that if a device is available at the workstation and works during a network outage — so for areas without coverage, leave a printed extract.

What if the supplier does not send an updated sheet?

Request the sheet in writing and record the date of the request. Until the current version arrives, work on the latest one held and note that in the register — the correspondence trail is evidence of due diligence.

Does every substance require exposure measurements?

No. The scope follows the properties of the agent, how and how often it is used, and the conditions at the workstation. A substance used once a year in a closed system and the same substance sprayed daily are two different situations.

How often should the register be reviewed?

Quarterly for the highest-hazard substances and wherever the product range changes often; annually for a stable set. New entries are added as they appear, regardless of the review cycle.

Must the safety data sheet be in the local language?

Yes. Under Article 31 of REACH the SDS must be in the official language of the country where the product is supplied — in Poland, Polish. Request it in writing if only a foreign version arrives.

What is a UFI code and where must it appear?

The UFI is a 16-character unique formula identifier linking a hazardous mixture to its PCN poison centre notification. It goes on the label; for industrial-use mixtures it may appear in SDS section 1 instead.

How does an SDS differ from a workstation chemical card?

The SDS is the supplier's 16-section document; the workstation card is the plant's short extract with hazards, protection, first aid and spill response, available at the workstation.

What are CMR substances and which registers are required?

Carcinogenic, mutagenic or reprotoxic substances. The employer keeps a register of work and of exposed workers for 40 years, measures more often and reports annually to the sanitary inspectorate.

Put chemicals into one register

We will show how VIMS connects the substance register, safety data sheets, exposure measurements and health surveillance into one consistent path.