OSH Coordinator Requirement under the OSHA 1994 Amendment (Act A1648): A Guide for Employers

What changed with the OSHA 1994 amendment (Act A1648)?

The Occupational Safety and Health (Amendment) Act 2022 (Act A1648) came into force on 1 June 2024 (P.U. (B) 128/2024). It added duties for principals and a duty to conduct a risk assessment, gave employees the right to remove themselves from imminent danger, created the OSH coordinator role, and raised many penalties.

• Section 18A: principals must take practicable measures for the safety and health of contractors, subcontractors and their employees.
• Section 18B: every employer, self-employed person or principal must conduct a risk assessment and implement the controls it shows are needed.
• Section 26A: an employee who has informed the employer of an imminent danger may remove himself if the employer fails to act.
• Section 29A: OSH coordinator for places of work with five or more employees.
• Sections 31A and 31B: training courses by registered training providers, and listed activities only by registered competent persons.

Who must appoint an OSH coordinator?

Under section 29A(1), an employer whose place of work is not in a class gazetted under section 29(1) must appoint one of his employees as an OSH coordinator if he employs five or more employees at his place of work. Under section 29A(3), an employer who has appointed a safety and health officer is deemed to have complied.

In practice, this creates three situations. Workplaces in the gazetted classes must appoint a safety and health officer (SHO) under section 29. Other workplaces with five or more employees must appoint an OSH coordinator, unless they already have an SHO. Workplaces with fewer than five employees fall outside section 29A, but sections 15 and 18B still apply.

The Act counts employees “at his place of work”. If you run several sites, branches or project offices, or rely on contract and agency workers, confirm with DOSH how the count applies to your setup before deciding that a site is below five.

What does an OSH coordinator do, and what training is needed?

Section 29A(2) states that the coordinator is appointed to coordinate occupational safety and health issues at the place of work. DOSH guidance describes the OSH coordinator as a trained person, rather than a registered competent person, who has completed a course at a DOSH-recognised training centre.

• DOSH’s briefing to training centres describes a module of 11 topics, 21 learning hours over three days.
• Only participants who attend the full course are eligible to be appointed as an OSH coordinator, according to the DOSH conditions for recognised centres.
• Training centres enter participants into DOSH’s MyKKP system, but DOSH states that the MyKKP listing is not a certificate of competency; the centre’s attendance certificate is the main proof.
• DOSH publishes a list of recognised OSH coordinator training centres; check it before booking.

OSHMed is not on the DOSH list of OSH coordinator training centres, so we do not run the OSH-C course. Use the DOSH list of OSH coordinator training centres to choose a provider. OSHMed can then help with the technical assessments and training that your coordinator manages.

What other duties should your OSH coordinator track?

The coordinator is the natural owner of a compliance calendar. The biggest new item is the section 18B risk assessment, which often needs specialist assessments for noise, chemicals, ergonomics or indoor air, each with its own legal deadlines and registered assessors. Contractor safety, imminent danger procedures and the safety committee also belong on the list.

How can OSHMed help with the amendment?

OSHMed, an occupational safety and health consultancy and DOSH-registered training provider in Kajang, Selangor, helps employers with the technical side of section 18B. This includes:

• Scoping and coordinating workplace assessments such as NRA, CHRA and ERA.
• The DOSH-registered Ergonomic Trained Person course (MyKKP SL/22/22/181036), so your own staff can run initial ERA.
• In-house OSH training such as hearing conservation and basic occupational first aid.
• Medical surveillance and audiometric testing are arranged through approved centres and registered clinics; see workplace health.

Before you decide: three common objections

Three objections are common among smaller employers: the company is too small, existing staff can simply take the title, and risk assessment is only paperwork. Each is answered below against the wording of Act 514 as amended, so the decision is based on the law rather than assumptions.

"We are too small for this."

The OSH coordinator duty starts at five employees at a place of work. Below that, section 29A does not apply, but the general duty in section 15 and the risk assessment duty in section 18B still do.

"Our admin executive can just take the title."

The Act lets you appoint an existing employee; it does not require a new hire. DOSH guidance expects that employee to complete the full OSH coordinator course at a recognised centre before appointment.

"Risk assessment is just paperwork."

Section 18B requires you to implement the controls the assessment identifies, and breaches fall under the section 19 penalty of up to RM500,000. The value is in the actions, not the form.

Frequently asked questions

Your next step

Confirm the headcount at each place of work, appoint and train your OSH coordinator through a DOSH-recognised centre, and give that person a written risk assessment to coordinate.

If your risk assessment points to noise, chemicals or ergonomics, start with our guides on noise risk assessment, CHRA and ergonomic risk assessment.

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).