Tracking Hazardous Substances - September 2025

Tracking Hazardous Substances

By Damien Peden

Sep 5, 2025 · #Info

DISCLAIMER:

Please note that Linkup Paint Supplies does not provide legal advice. If you require specific advice or support in relation to compliance with HSNO you may need to engage a specialist consultant or technical advisor or seek your own legal advice.

The information outlined in the article below is deemed to be correct on the date of publishing.

How does this affect our customers?

If you have any products that fall under the classifications listed in 'Schedule 26' below, you must track them in accordance with the requirements set out in the Health and Safety at Work (Hazardous Substances) Regulations 2017 which are outlined below.

At the time of writing, Linkup Paint Supplies Hamilton has confirmed that we do not currently sell or stock any products that fall under the scope of the regulations concerning Tracking hazardous substances. However, we have implemented internal systems to proactively identify any such products should they enter our inventory in the future.

We strongly recommend using the Hazardous Substances Calculator to track your inventory, which will advise if any products on your site require tracking.

What WorkSafe Says

Some substances are so hazardous they must be tracked at all times. This means a record of what happens to them must be kept, from the date of their manufacture or importation into New Zealand, through to their end use or disposal.

Tracking highly hazardous substances helps ensure:

• that at all times, they are either under the control of a person with the appropriate training (a 'competent person'); or are appropriately secured.
• the location of the substance is known throughout its lifespan in New Zealand, including disposal, and a record of this is kept.

What substances need to be tracked?

Tracking is required for the most hazardous of substances (19.2/Schedule 26), such as explosive, highly flammable and oxidising substances, and some poisons. Embalming substances used in funeral homes, cyanide used in the metal industry and 1080 are some examples. The hazardous substances calculator will help you work out if any of your hazardous substances require tracking.

When does tracking start?

If the substance is manufactured in New Zealand, tracking starts at the premises where it was manufactured. If imported, tracking begins at the port where the substance enters the country. You are responsible for keeping tracking records from the time it comes into your possession (19.4).

Who is responsible for tracking?

The business or undertaking with management or control of a workplace where the tracked substance is present is responsible for keeping a record of it (19.4). This needs to include any transfer or disposal of it.

What information is required when transferring a tracked substance?

The Hazardous Substances Regulations prescribe rules that apply to the transfer of tracked substances.

A PCBU with management or control of a workplace ('PCBU A' - Linkup Paints) may only transfer a tracked substance to a PCBU with management or control of another workplace ('PCBU B' - Our Customer).

The rules include a requirement for written notification to be received by PCBU A (Linkup Paints) before the substance is transferred.

The written notification must:

• confirm that there is a competent person at the PCBU's (our customer) workplace available to receive, and who will accept responsibility for, the tracked substance
• confirm that the PCBU's (our customer) workplace has a hazardous substances location compliance certificate if required by Part 9, 10, 12 or 13 of the regulations.
• If the goods are to be held in transit, confirm that:
  • Any place where the goods are to be held in transit complies with Part 5 requirements; and
  • To the extent relevant, they meet the requirements for a transit depot specified in Part 10, 12 or 13.

To ensure these requirements are met, the written notification also needs to:

• identify PCBU B (our customer), including the PCBU's (our customer) legal and business name and street address
• identify the competent person and, if the PCBU (our customer) is an organisation, their position in the organisation
• confirm, on the PCBU's (our customer) letterhead, that the competent person either:
  • has a certified handler certificate; or
  • has received sufficient information, training, and instruction under regulation 4.5
• identify the person giving the notification and their position (if the PCBU is an organisation, this should be done by the supervisor or manager of the competent person)
• be signed and dated by the person giving the notification
• be accompanied by:
  • a copy of the certified handler certificate or training record (as applicable)
  • a copy of the hazardous substance location compliance certificate (if applicable)

What information is needed on a tracking record?

The PCBU of any place where a tracked substance is present must keep a record of the tracked substance. The record must contain (Schedule 27):

• The name, position and contact details of the competent person in control of the substance, including their physical workplace address.
• If the competent person is a certified handler the expiry date of the compliance certificate, along with the hazard classifications of, and each phase of the lifecycle of, the substances that person holds a compliance certificate for as a certified handler.
• The name and quantity of the substance.
• The exact location of the substance, and a record of it that an inspector can find in the required time.
• Details of any transfer of it to another place, including the name of the substance, date of transfer and the identity and address of the PCBU it is being transferred to.
• Details of the disposal of the substance. Disposal information must include how much of it was disposed of, and how, when and where it was disposed.
• The unique identifiers for the containers with VTAs containing certain active ingredients.

Records must be kept for 3 years after disposal of the tracked substance; or for 12 months after they are transferred (19.6).

What is a competent person?

If a substance requires tracking, a competent person needs to take responsibility for it from the time you receive it to the time it is transferred or disposed of.

A 'competent person' is either a certified handler or someone who has received the information, instruction and training required to work with the substance.

Who needs access to tracking records?

You need to make tracking records readily accessible to any worker and readily understandable by any competent person who handles the substance (19.5). This means they know where to find the record, can access it and that it uses commonly understood terminology.

A tracking record must enable an inspector to identify the location of a substance on a tracking record within two minutes, and then find the substance itself at that location within an hour (or the time specified on the emergency response plan, whichever is shorter).

What if the substance is moved elsewhere?

If you transfer the substance to another workplace, you must ensure that details of the transfer (name of the substance, identity and address of the PCBU with management or control of the workplace to which it is transferred, and the date of transfer) are recorded and obtain written confirmation that a competent person at the destination will accept responsibility for it. The record should include the competent person's details and must include the 'unique identifier' on the substance's container if it is a vertebrate toxic agent (19.7).

What is a unique identifier?

Vertebrate Toxic Agents (VTAs) are required to be kept in a container labelled with a special serial number (unique identifier).

What if I dispose of it?

If you dispose of a substance or it has undergone treatment that results in it no longer being a tracked substance, you must record the details of how it was disposed of, as well as where, when and how much of it was disposed of. A record of this information must be kept for three years.

How long do I need to keep this record?

Tracking records must be kept for 12 months after the substance is transferred elsewhere, or for three years if the substance has been disposed of or treated to the point it is no longer a tracked substance (19.6).

Read the Regulations (Legislation) Read more on the WorkSafe website View the Toolbox Website

Schedule 26

Tracking of hazardous substances

Table 3

Hazardous substances that do not require tracking

1. Capsule containing 400-500 g/kg monensin sodium, HSNO approval number HSR002017
2. Liquid containing 50-70 g/L monensin sodium, HSNO approval number HSR002315
3. Solid containing 100-250 g/kg monensin sodium, HSNO approval number HSR002317
4. Solid containing 100-150 g/kg narasin, HSNO approval number HSR002021
5. Solid containing 75-95 g/kg narasin and 75-95 g/kg nicarbazin, HSNO approval number HSR002035
6. Solid containing 10-15% selenium and compounds, HSNO approval number HSR002377
7. OZ Foam Marine/Sika Boom, HSNO approval number HSR007613
8. Zinc powder pyrophoric, HSNO approval number HSR001477
9. VBPOC, HSNO approval number HSR000023
10. Petrol-ethanol blends containing 1-10% ethanol by volume, HSNO approval number HSR000073
11. Petrol (unleaded), HSNO approval number HRC000003
12. Aviation gasoline and racing gasoline, HSNO approval number HSR001442
13. Max Cl, HSNO approval number HSR000092
14. Interline 984 Part B, HSNO approval number HSR000127
15. 2-Propenoic acid, 2-methyl-, 2-propenyl ester, HSNO approval number HSR001394
16. Cobra, HSNO approval number HSR001672
17. FM003NC, HSNO approval number HSR002429
18. Iminoctadine, HSNO approval number HSR005098
19. Climax, HSNO approval number HSR007625
20. TNL2165, HSNO approval number HSR007654
21. TCNZ807, HSNO approval number HSR007841
22. E85, HSNO approval number HSR008039
23. CBPTT-99, HSNO approval number HSR100010
24. Rumensin Max, HSNO approval number HSR100500
25. QANZ1201, HSNO approval number HSR100701
26. Oxirane (chloromethyl), HSNO approval number HSR000977
27. Zinc powder or zinc dust, PG I, HSNO approval number HSR001301
28. Hydrobromic acid, 47-60% aqueous solution, HSNO approval number HSR001556
29. Hydrochloric acid, >25% aqueous solution, HSNO approval number HSR001557
30. Hydriodic acid, 57-67% aqueous solution, HSNO approval number HSR001560
31. A solid containing 900-1 000 g/kg alphachloralose (HSNO approval number HSR007750) mixed with food bait if—
    1. the food bait is bread, cereal, or peas; and
    2. after mixing or application—
       1. the amount of alphachloralose in the food bait does not exceed 100g of alphachloralose per kg on average for each batch of food bait; and
       2. the alphachloralose-containing bait is used within 24 hours of being prepared
32. A class 6.1B substance that is imported or manufactured for use as a veterinary medicine to which the Veterinary Medicine (Limited Pack Size, Finished Dose) Group Standard 2012 applies, HSNO approval number HSR100757
33. A class 6.1B substance that is imported or manufactured for use as a veterinary medicine and administered using a non-dispersive closed system application method specified in the Veterinary Medicines (Non-dispersive Closed System Application) Group Standard 2012, HSNO approval number HSR100758

View Schedule 26 (Legislation)

Schedule 27

Information to be included in record of tracked substance

Identity of competent person

1. The identity of a competent person who is in control of the tracked substance, including—
   1. the name of the person; and
   2. the position of the person within his or her organisation; and
   3. the physical address of that person's workplace; and
   4. (if applicable) the hazard classifications of, and each phase of the life cycle of, those substances for which that person has a compliance certificate as a certified handler and the date on which that compliance certificate lapses or must be renewed.

Substance information

2. The product name or chemical name of the tracked substance.
3. The total amount of the tracked substance that the competent person is in control of at any one time.

Location of tracked substance

4. The location of the tracked substance, with sufficient particularity to enable an inspector to—
   1. identify the exact location of the substance within 2 minutes of having obtained the record; and
   2. physically locate the substance or its container at the place described in the record within 1 hour of arriving at the place or within the time specified in any emergency response plan required under Part 5, whichever is the shorter.

Transfer to another place

5. If a tracked substance is transferred to another workplace in accordance with regulation 19.7,—
   1. the product name or chemical name of the substance transferred; and
   2. the identity and address of the PCBU with management and control of the workplace to which the tracked substance is transferred; and
   3. the date on which the transfer occurred.

Disposal of tracked substance

6. If a tracked substance has been disposed of,—
   1. the manner of the disposal; and
   2. the date on which the disposal occurred; and
   3. the amount of the substance disposed of; and
   4. the location where the substance was disposed of.

Unique identifier for container containing certain vertebrate toxic agents

7. In the case of a vertebrate toxic agent containing any of the following active ingredients, the unique identifier of the container that contains the agent:
   1. zinc phosphide (MZP):
   2. para-aminopropiophenone (PAPP):
   3. potassium cyanide:
   4. sodium cyanide:
   5. sodium fluoroacetate:
   6. yellow phosphorus:
   7. any other active ingredient specified in a relevant safe work instrument.

View Schedule 27 (Legislation)