Medical Surveillance Malaysia: How to Set Up a USECHH Programme

What is medical surveillance, and what is a medical surveillance exam?

Medical surveillance is the monitoring of a worker to identify changes in health caused by exposure to chemicals hazardous to health at work (USECHH 2000, regulation 2). The exam is a clinical examination by a DOSH-registered occupational health doctor (OHD): history, physical examination and tests of the organs the chemical can affect.

When does your workplace need a medical surveillance programme?

When your chemical health risk assessment (CHRA) shows that health surveillance is necessary for employees exposed, or likely to be exposed, to chemicals hazardous to health (regulations 9(2)(i) and 27(1)). For Schedule II chemicals, the programme includes medical surveillance at intervals of not more than 12 months (regulation 27(3)).

Section 3.1.6 of the DOSH Guidelines on Medical Surveillance Programme at The Workplace 2023 lists the usual reasons:

• Air monitoring at or above half the 8-hour limit, or above a ceiling, maximum exposure or short-term limit.
• A chemical with a “skin” notation in USECHH Schedule I, with likely skin contact.
• Biological monitoring above the biological exposure limit (BEL).
• Health complaints that match the chemical’s known effects, where a valid test exists.

Schedule II lists 34 entries, including lead, mercury, cadmium, benzene, n-hexane, isocyanates, free crystalline silica, chromium compounds and pesticides. If your CHRA names one for a work unit, check its recommendation.

What is changing. From 15 October 2027, P.U. (A) 359/2026 prohibits benzene, carbon disulphide, carbon tetrachloride and n-hexane above set concentrations for cleaning and degreasing. Substitution can end a programme (Guidelines, 7.6), so plan any switch with your OHD.

What happens in a programme, and how often are workers examined?

The OHD reviews your CHRA and monitoring reports, then examines each worker in scope: a baseline before exposure, periodic examinations at least once in 12 months, a return-to-work check after any removal, and an exit examination. Three-monthly or six-monthly rounds are recommended when there are removals or health concerns.

Each examination covers history, a physical examination, target organ tests such as blood tests or spirometry where relevant, and fitness to wear a respirator. The OHD certifies each worker fit or not fit for that chemical (form USECHH 3). Samples go to a laboratory accredited by Standards Malaysia.

Some chemicals have their own timetable: for inorganic lead, the next blood lead test ranges from six months to six weeks, depending on the last result. A programme ends only on the OHD’s written justification.

Who does what in a medical surveillance programme?

The employer owns and pays for the programme. A DOSH-registered CHRA assessor decides whether it is needed, a registered hygiene technician measures exposure and a DOSH-registered OHD does the medical part. In an OSHMed programme, our partner clinic carries out the examinations and tests, samples go to an accredited laboratory, and we coordinate.

OSHMed Solutions Sdn Bhd (SSM 202001013523) is an occupational safety and health consultancy in Kajang, Selangor, serving employers nationwide. OSHMed is not a clinic and does not examine workers or run a laboratory. We build the worker list from your CHRA, schedule rounds around your shifts, keep the records and follow up retests. The medical part is done by a DOSH-registered occupational health doctor; examinations and tests are carried out and billed by our partner clinic, Nova Care Sdn Bhd, No. 32 Jalan Reko Sentral 4, Kajang. For noise-exposed workers, Nova Care is also a DOSH-approved audiometric testing centre (JKKP/2025/11-02/00027, valid until 11 February 2028). See our hearing conservation guide, the hearing conservation programme page and our services.

What happens when a worker's result is abnormal?

The OHD may recommend medical removal protection: the worker is moved away from the chemical while the cause is checked and controls improve. Regulation 28 makes removal the employer’s duty; the DOSH 2023 Guidelines say within one working day. The worker returns when a later examination is clear.

• Pregnant or breastfeeding employees must be kept from exposure once the OHD notifies you (regulation 28(2)).
• The OHD reports removals and abnormal results to DOSH on forms USECHH 5i and 5ii.
• Occupational poisoning or disease is reported to the nearest DOSH office within seven days (2004 notification regulations, regulation 7).
• A worker who becomes unwell after a chemical exposure needs medical help urgently; call 999 in an emergency.

Which forms and records does the law require?

The employer keeps each health surveillance record for 30 years from the last entry (regulation 27(4)), lets each worker see their own record after reasonable notice (regulation 27(6)) and shares anonymous collective results in training (regulation 22(2)(b)). The OHD records results on forms USECHH 1 to 5 and sends the summary to DOSH within 30 days.

How do you compare medical surveillance providers?

Compare quotes on the same scope. Ask each provider to name the OHD and registration number, list the chemicals and work units from your CHRA, state the tests per chemical under the DOSH 2023 Guidelines, name the accredited laboratory and confirm who sends the forms to DOSH.

• Registration: check the OHD in the myKKP competent person lookup and note the validity date. Medical surveillance by an unregistered person is an offence under section 31B of Act 514, with a fine of up to RM100,000.
• Scope and tests: exposed workers per work unit, the chemicals, and the tests each needs, which drive the cost.
• Follow-up: who sends USECHH 4 and 5, when you receive USECHH 2 and 3, and how removals and retests run.

Price follows scope: workers, chemicals, tests, frequency and follow-up. We prepare a written proposal for each programme; there is no public price list.

Before you decide: three common objections

Three objections often delay medical surveillance: the yearly check-up already covers it, protective equipment keeps exposure low, and nothing is needed until DOSH inspects. Each is checked below against USECHH 2000, Act 514 and the DOSH 2023 Guidelines.

"Our annual medical check-up already covers this."

A general check-up is not chemical-specific. Medical surveillance follows your CHRA, uses tests chosen for each chemical, is done by a DOSH-registered OHD and goes on the USECHH forms.

"Our workers wear protective equipment, so exposure is low."

Protective equipment is one control, and the OHD checks fitness to wear a respirator. The Guidelines say a programme should never stop where skin protection alone keeps the chemical from being absorbed.

"We will act when DOSH inspects."

USECHH has no penalty of its own, so section 51 of Act 514 applies: a fine of up to RM100,000, up to one year in prison or both, plus a fine of up to RM2,000 a day if the offence continues. Directors can be charged too (section 52).

Frequently asked questions

Your next step

Take your latest CHRA report, list the exposed workers per work unit, run the self-check above, then ask us for a written plan.

If the same workers face noise, plan audiometric testing alongside; see our hearing conservation guide.

Sources and references

Disclaimer: This article is general information for employers and is not legal advice. Requirements depend on your workplace, processes and the current law. For a decision on your premises, speak to a DOSH-registered competent person or contact DOSH (JKKP).