Companies that handle hazardous chemicals or other high-risk processes may be legally required to maintain an exposure register. The register must document which employees have been exposed to dangerous substances and may be of crucial importance if illness develops many years later.
Here, we examine the purpose of an exposure register, the relevant legal obligations, and how companies can ensure compliant registration and documentation practices.
What is an exposure register?
An exposure register should document employees’ potential and actual exposure, including accidents, spills and other incidents that may have led to contact with hazardous substances. This may be in connection with hazardous substances or processes related to:
Chemicals (carcinogenic, mutagenic and toxic to reproduction)
Asbestos
Mining work
Biological material
Radiation
Keep in mind that only certain chemicals are relevant for inclusion in the exposure register.
The exposure register is an important tool for identifying and monitoring exposure to hazardous factors. Because illnesses resulting from such exposure often develop over a long period, sometimes many years after the exposure occurred, it is essential to record incidents continuously and as early as possible.
An exposure register can help to:
Monitor employees’ health over time
Provide a basis for health surveillance and support risk assessments
Ensure documentation if illness develops several years after exposure
Who may be exposed?
Several occupational groups that may be exposed to hazardous substances and processes.
Typical examples are:
Employees in industry (chemical industry, metal production, welding and woodworking)
Employees in construction (demolition, remediation, work with asbestos and concrete dust)
Healthcare and laboratory workers (radiation, chemicals and infectious agents)
Employees in renovation and waste management (biological material and hazardous waste)
Employees in mines and tunnels (dust, gases and explosives residues)
Employees within energy and research (radioactive material and ionising radiation)
What must an exposure register contain?
The content of an exposure register may vary. The information that must be recorded depends on the type of exposure involved – for example chemicals (CMR substances), asbestos, biological agents, mining work, or ionising radiation.
The purpose of the register is to ensure traceable and verifiable documentation over time. The regulations therefore set clear requirements regarding the information that must be included. It is also specified that the register must not contain health data beyond what is authorised by the legislation.
Although the details vary depending on the type of exposure, an exposure register will typically include:
The employee’s name and national identification number
The work carried out
The substance, material, or process to which the employee has been exposed
The period and duration of the exposure
Any measurement results or assessments of exposure levels
The date of registration
An exposure register must only contain the information required by the regulations. It must not function as a medical record.
Documentation and storage requirements
The register must be kept for a very long time, often between 40 and 60 years, depending on the type of exposure. The information must be available for as long as the employee is alive, and can be decisive in documenting occupational diseases and any compensation cases.
Individual employees have the right to access their own registrations. In addition, the register must be available to relevant personnel, for example the occupational health services, safety representatives, the working environment committee and any other persons working with HSE in the company.
Who is responsible for the register?
Both employer and employee have certain responsibilities, but it is the employer who has the main responsibility for creating and maintaining the exposure register.
Employee’s responsibility
Follow the company’s routines and guidelines in connection with registration
Report accidents, exposures or other situations that may have led to contact with hazardous substances
Participate in necessary training and help ensure that the information recorded is correct
The employer’s responsibility
Establish routines and guidelines for exposure registration
Provide training on how employees should report
Thoroughly document and retain records for a sufficient period of time
Ensure that the register is used
Ensure that employees have access to their own registrations
Common challenges
Inadequate reporting and follow-up
Many companies find that employees do not report exposures, either because the incident is perceived as minor, the routines are unclear, or because it is simply forgotten. This is often linked to a lack of training in chemical safety and understanding of the risk. In addition, many companies are unsure when they are actually required by law to keep an exposure register.
Difficulty storing registrations over a longer period of time
As some types of exposure require the register to be kept for up to 60 years, it requires good routines for both storage and for safeguarding privacy (GDPR). As long as the employee is alive, it should be possible to document any exposure, especially if there is a risk of cancer. As there are no specific requirements for how records are kept, many companies lack good enough routines to handle this.
A well-maintained exposure register is an important tool for both the employee and the employer. It contributes to prevention, follow-up and documentation, especially because health damage often only becomes apparent many years after exposure. Digital HSE and chemical systems can help companies identify chemicals that are subject to registration, carry out the actual registration and ensure safe storage of the information.
How should companies handle and store chemicals that can be used to make explosives? What do the regulations require – and which substances are covered?
Together with the Norwegian Directorate for Civil Protection (DSB), we invite you to an informative webinar covering how to identify such substances, the requirements for storage, use, and reporting. Lastly, your responsibilities as a company.
The webinar is ideal for anyone working with chemical handling in industry, offshore, research, or other activities where such substances may be present. You will receive practical advice and guidance directly from the authorities, with the chance to ask questions along the way.
Topics include:
What is DSB’s role in the field of chemicals and explosives?
What is the background to, and content of, the regulation on explosives precursors?
Which substances are covered (list 1 and list 2)?
What are the requirements for storing and securing such chemicals?
Registration
Tuesday, June 10, 2025, 10:00 – 11:00
Sign up to gain a clear overview of how your company can comply with the regulations on explosives precursors.
The knowledge sector’s service provider, Sikt, is organized as a government agency under the Ministry of Education and Research. Sikt works to simplify the everyday lives of employees, researchers and students in the knowledge sector by offering stable and efficient shared services.
As a buyer of Workplace Safety, Sikt has contributed to delivering a user-friendly chemical inventory and an effective chemical management system to Norwegian colleges, universities and research institutes.
A chemical inventory for both staff and students
Workplace Safety is an advanced management system used by managers, HSE professionals, researchers, and laboratory staff. Since chemicals are central to both teaching and research, strict requirements apply to safety information, and must be readily available to everyone, both staff and students.
Workplace Safety meets these needs with access management and role customisation, ensuring each user only sees what’s relevant to them. The system provides quick, easy access to safety data sheets (SDS), solving a major challenge in the industry.
A partner for industry-aligned development
With flexibility in mind, Workplace Safety has been developed to easily adapt to the needs of different industries. Through collaboration with Sikt, which represents a broad and important sector, we gain unique insight into shared challenges in Norway.
Insights that lead to better solutions
This approach gives us valuable insight into the specific challenges and needs of the knowledge sector, helping us further develop the solution. By collaborating with a single representative of the entire sector, we gain depth and efficiency that strengthen our ability to deliver a chemical management system tailored to the needs of higher education and research.
– Sikt is an important partner in the further development of Workplace Safety, and we greatly appreciate working with key players in higher education, says Hans Kristian Brekken, product developer with technical responsibility for Workplace Safety.
Collaboration for common practices in the sector
Sikt works proactively on behalf of the company to ensure the best solutions. To achieve this, they have established a working committee consisting of professionals representing the sector. The committee works together to develop a common practice for the use of the chemical management system across the knowledge sector.
Targeted further development
Sikt is the purchaser and contract manager, drawing on expertise from universities and university colleges. This ensures comprehensive and targeted further development of the system.
– The knowledge sector places high demands on both the product and us as an organisation. This has given us a clear direction in our efforts to adapt Workplace Safety to the sector’s needs, says Brekken.
Large-scale implementation and migration of data
In 2024, several of Norway’s universities and university colleges implemented the chemical management system. The process involved migrating large volumes of data and many users, but close collaboration between the Workplace Safety team and the institutions ensured a smooth transition.
– We are pleased to have completed the migration from the old system to Workplace Safety in a safe and efficient way, says Ask Hide, Project Manager at Workplace Safety.
– This marks an important milestone in our joint efforts to strengthen the safety and efficiency of chemical handling across institutions.
Technical implementation and professional advice
Adapting Workplace Safety to a company’s work processes and routines requires thorough mapping and close collaboration.
– A successful implementation requires strong cooperation from both parties. Working closely with customers enabled us to ensure they fully benefit from the system’s capabilities, Hide explains.
The team used a proprietary migration tool to simplify the transfer of safety data sheets (SDS) and system structure. Role assignments were tailored to each company, ensuring users received the right information and access from day one.
– The projects have been extensive, but our main focus has been to deliver quality at all stages, both in terms of technical implementation and professional advice, emphasises Hide.
Pilot project and further roll-out
The pilot project involved leading institutions such as the University of Bergen (UiB), the Norwegian University of Science and Technology (NTNU), the University of Stavanger (UiS) and NORCE – Norwegian Research Center. These have now completed the transition to Workplace Safety. The roll-out to the rest of the sector is well underway and will continue with full force in 2025.
At the time of writing, the majority of the companies that expressed an interest in joint purchasing of electronic substance files have been implemented.
Positive effects of digitalisation and automation
The implementation of Workplace Safety in the knowledge sector has demonstrated how targeted system adaptation can deliver clear benefits for both users and companies.
The system can be configured to reflect the company’s working methods, from simple routines to more complex processes. Through close collaboration with the institutions, we have developed workflows that make it easier to comply with legal requirements while ensuring chemical management is more transparent and user-friendly.
Odin Kvam, sector coordinator for the service and senior engineer at the University of Agder, shares his experiences:
– The transition to Workplace Safety gives us a tool that is flexible in meeting the many different ways chemicals are used in the higher education sector. The system integrates easily with the company’s organisation – without an extra login when students and employees visit the chemical inventory. Netpower provides continuous updates and improvements to keep Workplace Safety aligned with Norwegian and European regulations, and to further enhance user-friendliness in key functions such as the exposure register, substitution, and risk assessments.
Feedback that drives improvement
The implementation has generated a wealth of useful feedback, both praise and suggestions for improvement.
– We have worked closely with the companies in the sector to ensure a smooth transition to the new system. Feedback, both positive and critical, is valuable to us. The positive confirms that we are on the right track, while the critical ones provides insights we can use to make the solution even better. Our goal is to develop a system that really works for users in their everyday lives, says Hide.
– We look forward to continuing our collaboration with the Workplace Safety team at Netpower to meet future needs and ensure a safe working environment for both students and staff, Kvam concludes.
Are you unsure how to carry out good risk assessments of chemicals? Now is your chance to learn what you need!
Workplace Safety invites you to a practical and useful webinar where the Swedish Labor Inspection Authority’s occupational hygienist explains the requirements, shares good advice and answers relevant questions about the topic.
Date: Tuesday, February 11, 2025
Time: 10:00-10:45
What you get:
✅ Insight into the requirements for risk assessment of chemicals ✅ Specific guidance on what a risk assessment must contain ✅ Tips and tricks to make the process easier and more efficient
Who is it suitable for?
This webinar is suitable for managers, HSE managers or anyone who works with chemicals in the workplace.
The webinar is open to everyone and is especially relevant for companies that have hazardous chemicals in the workplace.
Feel free to share the registration page with others who you think might benefit from the webinar!
At Workplace Safety, we believe in practical, tailored training to ensure our customers make full use of the solution’s functionality.
Recently, we had the pleasure of hosting an in-person training day with Bamble municipality, which places a strong emphasis on safe and correct chemical handling across its departments.
This session proved to be a valuable arena for discussing their needs and adapting the system to the municipality’s specific requirements.
We share this experience to inspire other customers to consider investing in a training day.
Physical presence creates a stronger focus and commitment for both parties, offering benefits that go beyond digital meetings and giving participants a deeper understanding of the system.
A municipality with chemical management in focus
Bamble municipality in Telemark is a medium-sized municipality with just over 14,000 inhabitants. The municipality uses chemicals in a number of sectors, from municipal engineering and cleaning to nursing homes and schools.
With such diverse applications, it was important to provide training that addressed both administrative functions and specific workflows required when handling chemicals.
Bamble municipality is committed to safe and responsible chemical management and sought to strengthen competence around the statutory requirements that apply when working with chemicals. Therefore, the training also highlighted how Workplace Safety supports compliance through user-friendly workflows and continuous documentation of completed tasks.
Training and advice
The day began with a training session for administrator users, focusing on access management, advanced functionality, and best practices for structuring and managing the chemical inventory in Workplace Safety.
This gave Bamble municipality a clear understanding of the system’s capabilities, from standard setups to more advanced customisations. By sharing examples from other municipalities and public sector organisations using Workplace Safety, we were able to explore different approaches and solutions.
Next, we trained super-users in the most relevant modules, including risk assessment, substitution assessment, and exposure registration. The training combined theory with practical application with participants learning about regulations and obligations while working through case studies in the system. With demo access, they tested different features, getting hands-on experience, which is crucial to feel confident in the system.
We also supported Bamble municipality in setting up its own exposure and risk assessment routines. Through practical exercises and guidance, the participants developed a solid understanding of how to establish these processes in Workplace Safety, providing a strong foundation for ongoing work and compliance with statutory requirements.
Workplace Safety is a user-friendly solution that is easy to implement, but for those who want to unlock its full potential, we recommend a thorough review with our experts.
Our training offers customers real value by demonstrating the full range of possibilities within the system. While Workplace Safety is highly flexible, its broad features can sometimes make it challenging to see the complete picture.
Through our training, administrators and super-users gain the insight needed to go beyond the standard setup. This enables them to customise the system, work more efficiently, and adapt chemical management to the specific needs of their business.
Our experience shows that training with physical presence gives participants a deeper understanding of Workplace Safety.
Many companies face challenges with internal adoption of chemical management systems and understanding of legal requirements. A training day with our experts can provide exactly what is needed to strengthen internal competence and ensure full benefits of the system – streamlining processes, improving workflows, and enhancing compliance.
We hope this inspires more organisations to invest in tailored training and build stronger chemical management skills in the workplace. The goal is to get people started, engaged, and confident, making chemical management both safe and straightforward.
Get in touch with us to discuss how we can organise a training program for your company!
Requirement for training in the use of the chemical inventory
According to the Regulations on the performance of work §2-4, the employer must ensure that employees have easy access to the chemical inventory and that relevant safety data sheets (SDS) are available in the workplace.
Providing thorough training for administrators and super-users helps lower the threshold for further training across the organisation.
Improved chemical safety with new hazard classes in the CLP regulations
In April 2023, updates to the EU CLP regulation (classification, labelling, and packaging) came into force. The update introduced new classifications of chemicals, with a focus on endocrine-disrupting properties and environmental risks, including bioaccumulative properties and potential water pollution.
Classification and labelling is a key tool for reducing risk in chemical use. Over time, it encourages the replacement of the most hazardous substances with safer alternatives.
The new hazard classes include:
Endocrine disrupting properties: Chemicals that affect the endocrine system, potentially causing health issues such as birth defects and development disorders in humans and wildlife.
Persistent, bioaccumulative and toxic properties (PBT and vPvB): Substances that break down slowly in the environment and build up in organisms and food chains.
Persistent, mobile and toxic properties (PMT and vPvM): Substances that combine high persistence with mobility, spreading rapidly in the environment, often through waterways.
Code
H-phrases
EUH380
May cause endocrine disruption in humans
EUH381
Suspected of causing endocrine disruption in humans
EUH430
Can cause endocrine disruption in the environment
EUH431
Suspected of causing endocrine disruption in the environment
EUH440
Accumulates in the environment and living organisms, including humans
EUH441
Highly accumulates in the environment and living organisms, including humans
EUH450
Can cause long-term and diffuse pollution of water resources
EUH451
Can cause very long-term and diffuse pollution of water resources
Significance of the changes
The new hazard classes strengthen the regulation of substances with these properties, ensuring that hazardous chemicals are handled in the same way as other serious hazards. This may results in stricter requirements for companies and limitations on how these substances can be used. The changes will also influence related legislation, including rules on biocides, pesticides, cosmetics, and occupational health and safety.
New obligations for companies
Chemical suppliers are now required to review their chemicals and determine whether they fall under the new hazard classes. If so, they must update their registrations with the European Chemicals Agency (ECHA) and ensure that everyone in the supply chain receives up-to-date safety information. For new substances, the rules apply from May 1, 2025, while existing substances have until November 2026. There are also transition periods in place for mixtures.
The introduction of the new hazard classes is an important step in strengthening the protection of health and the environment from hazardous chemicals. ECHA is updating its guidance to reflect these changes, and companies can follow the process and access resources directly on the ECHA website.
What does this mean for your chemical management?
Your company should ensure it has a clear overview of whether any products fall under the new chemical classifications. Contact the suppliers of your chemical products for updated information, and keep track of changes to the safety data sheets, especially if your company uses automatic updates in the chemical inventory.
If products are covered by the new classifications, a new risk assessment must be carried out. This includes evaluating whether additional protective measures are required to ensure that the use and storage of the substances remain at an acceptable risk level, in line with your company’s safety criteria.
Written by Hans Kristian Brekken, chemist and product developer at Workplace Safety.
