Two triggers
| Trigger | Where it is heard |
|---|---|
| Legislation changed | The tracking process: primary and secondary sources |
| The organisation changed | Nowhere — the organisation must notice it itself |
What “the organisation changed” means
- a new activity, a new line, new machinery,
- a new chemical coming into use,
- headcount crossing a threshold (committee, physician hours, team sizes),
- a change of hazard class,
- work in a new country, or a new customer contract.
Any of these can create a new duty; none of them sends you a letter.
Planned review
So alongside the two triggers, the register is also reviewed at planned intervals. The frequency follows how fast the organisation changes: for one that grows or switches work often, once a year is not enough.
Tie it to management of change
The most robust arrangement makes updating the register a step in management of change: when new equipment is commissioned, one of the questions asked is “does this create a new legal duty?”. The register then no longer depends on somebody remembering.
The record
Every review records the date, the reviewer and the outcome — even when nothing changed. A line saying “reviewed, no change” is very different from a gap showing nobody looked.