Check in this order. (a) Is this place of work on the 1997 SHO Order? If yes, appoint a Safety and Health Officer (SHO). (b) If not, and you employ five or more employees here, appoint an OSH Coordinator (occupational safety and health coordinator). (c) Already have an SHO here? Then section 29A is already met.
If your workplace needs an OSH Coordinator, MESH runs the DOSH-registered OSH-C course in KL and Penang. See dates and register: OSH Coordinator (OSH-C). If the 1997 Order catches your site, talk to us about SHO and compliance support via DOSH / JKKP compliance.
The Occupational Safety and Health (Amendment) Act 2022 (Act A1648) came into operation on 1 June 2024 (P.U.(B) 128/2024, dated 2 April 2024). The DOSH Act 514 reprint as at 1 June 2024 records the same commencement.
Two shifts matter here. Section 1 now applies the Act to all places of work throughout Malaysia (subject to the First Schedule), so offices, clinics, schools, and co-working spaces are in scope. The Amendment also inserted section 29A — the occupational safety and health coordinator duty for places of work that are not already required to appoint an SHO under section 29. Broader Amendment duties belong on a separate compliance checklist; this page covers only the OSH Coordinator versus SHO choice.
Section 29 of Act 514 applies only to classes or descriptions of places of work that the Minister specifies by order in the Gazette. The current list is the Occupational Safety and Health (Safety and Health Officer) Order 1997 [P.U.(A) 316/1997].
The duty sits on the place of work (and the activity run there), not on group headcount across every branch. Construction and engineering construction are triggered by total contract price, not by how many workers are on site.
| Place / activity (Order) | Trigger |
|---|---|
| Building operation | Total contract price of the project exceeds RM20 million |
| Work of engineering construction | Total contract price of the project exceeds RM20 million |
| Ship building | More than 100 employees at peak of the work |
| Gas processing or petrochemical | More than 100 employees |
| Chemical or allied industry | More than 100 employees |
| Boiler or pressure vessel manufacturing | More than 100 employees |
| Metal industry with canning, stamping, blanking, shearing or bending | More than 100 employees |
| Wood working with cutting, sawing, planning, moulding, sanding, peeling (or combination) | More than 100 employees |
| Cement manufacturing | More than 100 employees |
| Any other manufacturing not listed in the metal/wood/boiler/cement lines above | More than 500 employees |
Source: SHO Order 1997 PDF (DOSH).
Some guides say every 100-person workplace needs an SHO. That is not what the Order lists. An office, school, clinic, shop, or most service businesses with 80 or 200 staff is usually not on that list. A 120-person chemical plant is. A 120-person furniture retailer is not. A RM25 million building project is on the list even with a small headcount.
Under section 29(2), the occupier must appoint a person competent to act as SHO. Under section 29(3), that appointment is exclusive: ensure observance of the Act and promote safe conduct of work. Under section 29(4), one SHO covers only one place of work at a time, unless the Director General permits otherwise. For registration and detailed duties, use current DOSH / JKKP SHO materials and the Safety and Health Officer Regulations 1997 — this page does not restate those rules.
Section 29A fills the gap for places of work that are not in a class published under section 29(1). In plain words:
“One of his employees” usually means an existing supervisor, HR lead, or operations person — not a new hire created only for the title. The Act does not require a separate full-time OSH department for every five-person office.
MESH operating rule: one OSH Coordinator per company per location when that location has five or more employees. Section 29A requires one employee at a place of work with five or more employees where an SHO is not already required; the per-company-per-location practice is how MESH registers and advises clients (confirm against current DOSH registration guidance).
Safety and Health Officer (section 29). The Act’s purpose clause is short: appointed exclusively to ensure due observance of the Act and regulations, and to promote a safe conduct of work. Competency, registration (the Green Book pathway in practice), and the detailed duty list sit in the SHO Regulations 1997 and DOSH’s current SHO guidance — not in informal summaries.
Occupational safety and health coordinator (section 29A). The Act’s purpose is coordinating occupational safety and health issues at the place of work. Tasks commonly taught on DOSH-registered OSH-C courses — HIRARC support, workplace checks, assistance with JKKP 6/7/8 — are DOSH guidance / course outcomes, not extra words in section 29A. Confirm with the relevant DOSH state office and your training centre.
Neither role replaces the employer’s Part IV duties. Appointing a coordinator or an SHO does not shift legal responsibility away from the employer or occupier.
Yes, if the threshold applies — and it is a separate duty from sections 29 and 29A.
Under section 30, every employer must establish a safety and health committee at the place of work if forty or more persons are employed there, or if the Director General directs it. A 50-person office that is not on the 1997 Order needs an OSH Coordinator and a committee. It still does not need an SHO unless the Order catches the activity.
Committee composition and procedure are as prescribed. This page does not expand them. For broader support, see MESH DOSH / JKKP compliance.
The penalty bands in the Act are the same for both roles.
That is the statute — no invented prosecution counts. If you are unsure whether your activity sits on the Order, confirm the current Gazette text with the relevant DOSH state office before you choose a path.
If the decision path above points to an OSH Coordinator (not an SHO), work through these steps:
If your workplace needs an OSH Coordinator, MESH runs the DOSH-registered OSH-C course in KL and Penang. See dates and register: OSH Coordinator (OSH-C). If the 1997 Order catches your site, talk to us about SHO and compliance support.
Usually yes, if that office is a place of work with five or more employees and it is not a class listed in the 1997 SHO Order. Most ordinary offices are not on the Order, so section 29A applies.
No, not at that same place of work. Section 29A(3) deems an employer who has already appointed an SHO there to have complied with section 29A(1).
MESH operating rule: one OSH Coordinator per company per location when that location has five or more employees. Section 29A requires appointing one of the employer’s employees at such a place of work; it does not add “one company only” wording. Treat the per-company-per-location rule as MESH practice and confirm against current DOSH registration guidance.
Section 29(4) says a person shall be appointed as SHO for only one place of work at any one time, unless the Director General permits otherwise. Dual-site coverage needs that permission — do not assume it.
Usually no, unless the activity at that place of work is one of the classes in the 1997 Order (for example chemical or allied industry, or another listed manufacturing line). Ordinary trading, retail, or office headcount alone does not put you on the Order.
Yes. For building operation and work of engineering construction, the Order uses total contract price exceeding RM20 million, not staff count. A RM25 million project is above that threshold.
No. Section 29A requires the employer to appoint one of his employees as occupational safety and health coordinator. It does not name a course, exam, or certificate inside that section. In practice, DOSH’s path is training at a registered centre, then employer appointment and registration. Do not invent that “the Act requires a 3-day course.”
No. This is general educational guidance for Malaysian workplaces. Confirm the current Order, the Act reprint, and your facts with the relevant DOSH / JKKP state office or your legal adviser before relying on it for a specific appointment. Darshillan reviews MESH legal copy before publish; that does not turn this page into formal legal advice.
Sources: Act 514 reprint as at 1 June 2024 (DOSH) (ss.1, 29, 29A, 30); SHO Order 1997, P.U.(A) 316/1997 (DOSH); P.U.(B) 128/2024 (Act A1648 commencement 1 June 2024), as recorded on the DOSH reprint.
Disclaimer: General guidance only; not legal advice. Verify current Gazette orders and DOSH requirements for your place of work.