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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:

  • they are always under the control of a person with the appropriate training (a ‘competent person’); or appropriately secured at all times
  • 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, 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. An updated version of the Hazardous Substances Calculator will be available before December to work out if your hazardous substances requires tracking.


Who is responsible for tracking?

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


When does tracking start?

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


Who needs access to tracking records?

Under the new Hazardous Substances Regulations, you will need to make tracking records readily accessible to any worker and readily understandable by any competent person who handles the substance.  This means these people know where to find this record, can access it and that it uses commonly understood terminology.

An inspector must be able 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 is a competent person?

A competent person is either a certified handler or someone who has received the information, instruction and training required to work with the substance and has been given the responsibility of keeping control of it at a workplace.

If a substance requires tracking, it must be under the control of a competent person, or secured at all times. The competent person takes responsibility for it from the time you receive it to the time it is transferred or disposed of.


What if the substance is moved elsewhere?

If you transfer the substance elsewhere the competent person records the condition and circumstance of its transfer and obtains written confirmation that a competent person at the destination will accept responsibility for it. They will record this person’s details along with information on where it is going, and the ‘unique identifier’ on its container if it is a vertebrate toxic agent. Records must be kept for 12 months after it has been transferred to someone else.

You must ensure that any place the substance is held during transit to another workplace meets the relevant requirements of a transit depot.


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.


What information is needed on a tracking record?

Tracking records must contain:

  • 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 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 identity and address of where it is going, the competent person who will be in charge of it, and the unique identifier for its container, if required.
  • 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.


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.

Last updated 8 September 2017