An OSH Coordinator is no longer an optional nice-to-have for Malaysian businesses; it is now a legal requirement for most small and medium enterprises (SMEs) across the country. Since the enforcement of the Occupational Safety and Health (Amendment) Act 2022 on 1 June 2024, thousands of employers who previously had no dedicated safety personnel are now required by law to appoint one. Yet many business owners still aren’t sure what the role actually involves, who is eligible to take it on, or what happens if they ignore the requirement altogether.
This article breaks down everything Malaysian employers need to know about the OSH Coordinator role, from the legal basis under Section 29A to who qualifies, what the job actually entails, and how to get compliant without unnecessary stress.
What Is an OSH Coordinator?
An OSH Coordinator (Occupational Safety and Health Coordinator) is an employee formally appointed by an employer to coordinate safety and health matters at the workplace. The role was first introduced by the Department of Occupational Safety and Health (DOSH/JKKP) as part of its Strategic Plan for Occupational Safety and Health in the Small and Medium Industries Sector, developed back in 2016 to improve OSH management specifically within the SME sector.
It’s important to understand what the role is not. The OSH Coordinator does not carry sole legal responsibility for workplace safety, that responsibility remains with the employer under the Occupational Safety and Health Act 1994 (OSHA 1994). Instead, the Coordinator’s function is exactly what the title suggests: to coordinate the practical, day-to-day implementation of safety measures, recordkeeping, and hazard management on the employer’s behalf.
The Legal Basis: Section 29A
The requirement for an OSH Coordinator is formally set out under Section 29A of the OSHA 1994, inserted by the Occupational Safety and Health (Amendment) Act 2022. The section states that an employer whose place of work does not fall under any class or description gazetted under subsection 29(1) must appoint one of his employees to act as an occupational safety and health coordinator, provided the employer has five or more employees at that place of work.
In plain terms: if your business is not in a gazetted high-risk category (the kind that requires a registered Safety and Health Officer, or SHO) and you employ five or more people, you are legally required to designate an OSH Coordinator.
Who Needs to Comply?
You are required to appoint an OSH Coordinator if:
- Your business employs five or more employees at a single place of work
- Your workplace is not listed under the gazetted classes requiring a Safety and Health Officer (SHO) under the Safety and Health Officer Order 1997
- You do not already have a registered SHO covering that workplace (an SHO appointment satisfies the coordinator requirement, since the SHO role is more extensive)
This distinction matters because the two requirements are separate. A gazetted high-risk factory with 100 or more employees typically needs a registered SHO. A regular office, retail outlet, service business, or smaller workshop with five or more staff, which makes up the vast majority of Malaysian SMEs; needs an OSH Coordinator instead. Since SMEs account for roughly 98.5% of all businesses in Malaysia, this amendment effectively brought formal safety obligations to a segment of the economy that, until 2024, had largely operated without any legally mandated safety personnel.
Separately, businesses with 40 or more employees are also required to establish a Safety and Health Committee, a distinct obligation that applies regardless of industry classification. A company can therefore have obligations to fulfil under both requirements simultaneously.
Why This Requirement Exists
The push behind Section 29A isn’t just administrative box-ticking. DOSH statistics from 2019 revealed 578 reported cases of death due to occupational accidents and diseases in Malaysia that year, and around 80% of those cases, over 460 workers, came from the SME sector specifically. That imbalance is precisely why DOSH’s strategic focus and eventually the legal reform targeted smaller businesses: they were disproportionately unsafe and disproportionately unregulated.
By requiring even modestly sized businesses to formally designate someone responsible for safety coordination, DOSH aims to close that gap, pushing basic hazard identification, incident reporting, and safety culture into workplaces where it previously didn’t exist in any structured form.
What Does an OSH Coordinator Actually Do?
The day-to-day scope of the role centres on a few core areas:
Hazard identification and risk assessment. The Coordinator assists in carrying out HIRARC (Hazard Identification, Risk Assessment and Risk Control), which is the standard risk assessment methodology expected by DOSH. These assessments must be properly documented, kept up to date, and acted upon, not filed away and forgotten.
OSH documentation and reporting. This includes maintaining safety records, incident and accident logs, and inspection checklists, as well as assisting the employer in reporting notifiable accidents, dangerous occurrences, occupational poisoning, and occupational diseases to DOSH through the relevant official forms (JKKP 6, JKKP 7, and JKKP 8).
Promoting a safety culture. This covers implementing workplace safety policies, organising internal safety programs and briefings, and generally keeping OSH compliance visible and active rather than a once-a-year formality.
Ad hoc safety duties. Coordinators are also expected to handle safety-related tasks as they arise, at the request of the employer, rather than operating strictly from a fixed checklist.
Taken together, the role functions as the employer’s frontline point of contact for safety matters, someone who can speak to DOSH inspectors, keep records audit-ready, and flag emerging risks before they turn into incidents.
Who Can Become an OSH Coordinator?
DOSH has set specific eligibility criteria for the role. To qualify as an OSH Coordinator, an individual generally needs:
- Proof of employment, supported by the employer making the appointment
- A minimum SPM or SKM-level education
- Successful completion of the OSH Coordinator Training Program, run either directly by DOSH or by a training provider officially approved by DOSH
It’s worth noting that not every training provider is authorised to run this program; only centres that have met DOSH’s specific requirements and received formal registration are permitted to conduct it. Employers should verify a provider’s registration status before enrolling staff, since only training from an approved provider will satisfy the legal qualification requirement. It’s also worth noting that OSH Coordinator training is conducted as physical, in-person classes; DOSH does not recognise online-only delivery for this particular certification.
Once an employee completes the training and is certified, they are officially registered as a competent person on DOSH’s records, which also opens a potential career pathway within the broader OSH profession for employees who want to specialise further.
In July 2025, DOSH issued a circular directing all training providers to update and enhance the OSH Coordinator training module, aligning the syllabus with the repeal of the Factories and Machinery Act 1967 and subsequent OSHA 1994 amendments. This means the current version of the course reflects the most up-to-date legal and workplace safety requirements, something employers should keep in mind when comparing older training records against current standards.
What Happens If You Don’t Comply?
The penalties introduced under the 2022 amendment are substantial, reflecting a much more serious regulatory posture than before. Failing to appoint an OSH Coordinator when legally required is an offence punishable by a fine of up to RM50,000, imprisonment for up to six months, or both.
Beyond the direct legal exposure, there are practical consequences that often catch employers off guard. During DOSH inspections, officers routinely ask who is responsible for safety coordination, risk assessment, and follow-up actions on site. The absence of a properly appointed and trained OSH Coordinator frequently results in findings related to poor safety implementation generally, not simply a missing piece of paperwork. In other words, the gap tends to surface broader compliance weaknesses once an inspector starts asking questions.
There are also commercial knock-on effects. Increasingly, clients and larger contractors check vendor and supplier safety compliance as part of their own risk management before signing contracts. A business without a documented, trained OSH Coordinator can find itself excluded from tender processes or vendor lists entirely, regardless of the quality of its actual work.
Practical Steps Toward Compliance
For SMEs that haven’t yet appointed an OSH Coordinator, the path to compliance is fairly straightforward:
- Confirm whether the requirement applies to you. Count employees at each individual place of work (the threshold applies per workplace, not company-wide) and check whether your industry falls under a gazetted SHO category.
- Select a suitable employee who meets the minimum SPM/SKM education requirement and is willing to take on the coordination role.
- Enrol them in an OSH Coordinator Training Program run by a training provider registered and approved by DOSH, verify the provider’s registration number before booking.
- Formalise the appointment with proper documentation once training is complete.
- Set up basic OSH systems: HIRARC documentation, incident reporting templates, and a simple internal safety policy, so the Coordinator has a working framework from day one rather than starting from scratch.
Many employers are also able to claim training costs for this program through HRD Corp, which significantly lowers the actual cost of compliance for eligible businesses.
The Bigger Picture
The introduction of the OSH Coordinator requirement marks a genuine shift in how Malaysia approaches workplace safety at the SME level. For decades, formal safety obligations were largely the concern of large factories and gazetted high-risk industries, while the vast majority of smaller businesses operated with little to no structured safety oversight, despite accounting for the majority of workplace deaths. Section 29A closes much of that gap.
For business owners, the requirement is best viewed not as a compliance burden to be minimised, but as a relatively low-cost way to reduce real operational risk: fewer accidents, fewer disruptions, better standing during audits, and a stronger position when clients or partners ask about safety credentials. Appointing and training an OSH Coordinator is one of the most accessible steps a Malaysian SME can take toward both legal compliance and genuinely safer day-to-day operations.
