If you operate an SME in Malaysia, one common question is: Do we need an OSH Coordinator (OSH-C)? The answer depends on the number of employees at the workplace and whether the site falls into a category requiring a Safety and Health Officer (SHO).
Who must appoint an OSH Coordinator?
Section 29A(1) of the Occupational Safety and Health Act 1994 (Act 514) requires an employer to appoint one of its employees as an OSH Coordinator if it employs five or more employees at a workplace that is not within a gazetted class of workplace under Section 29(1). Section 29A(3) recognises an employer that has already appointed an SHO at that workplace as meeting the coordinator appointment requirement.
The threshold refers to employees at the place of work; assess each actual workplace and verify applicable circumstances rather than assuming a company-wide headcount answers every question.
OSH Coordinator versus Safety and Health Officer
An OSH Coordinator helps coordinate occupational safety and health matters at a workplace. A Safety and Health Officer is a different statutory role with specific appointment and registration requirements. An employee does not become a registered SHO merely by completing an OSH-C course.
Importantly, appointing a coordinator does not transfer the employer’s underlying duty to provide a safe and healthy workplace.
Practical responsibilities for an OSH Coordinator
The statute gives the OSH-C a coordinating purpose, while the employer must define actual duties appropriate to the site. A useful scope could include:
- Coordinating hazard reports, inspections and HIRARC reviews.
- Tracking corrective actions and escalating overdue high-risk items.
- Maintaining a practical record of safety briefings and workplace instruction.
- Helping to coordinate emergency arrangements and drills.
- Supporting incident information collection without prejudging causes.
- Reporting trends and barriers to management for decisions.
Five steps for an SME to implement the role
- Confirm applicability: Check headcount, workplace classification and existing SHO arrangements.
- Make a written appointment: Define the coordinator’s authority, reporting line and time allocation.
- Provide suitable learning: Select training that includes workplace examples and practical exercises.
- Create a small action register: Record risk, action, person responsible, due date and closure evidence.
- Review monthly: Ask management to resolve blocked actions and provide resources.
Common mistakes
The first is treating the appointment letter as the finished OSH system. The second is asking one employee to carry every safety duty without authority, budget or management support. The third is copying a generic HIRARC without examining actual jobs. The solution is a manageable routine: inspect, discuss, assign, verify and improve.
Frequently asked questions
Does a company with fewer than five workers have no OSH duties?
No. The Section 29A appointment threshold does not remove other applicable duties under the Act, including obligations relating to workplace safety and risk assessment.
Is OSH-C training the same as becoming a SHO?
No. The roles and legal requirements differ. Training supports capability but must not be misrepresented as SHO registration.
For employers building a functioning OSH-C programme, practical HIRARC and safety management training can be combined with workplace coaching. Discuss the site needs with Aswad Aziz.
Official reference
DOSH: Occupational Safety and Health Act 1994 (Act 514), particularly Sections 15, 18B, 29 and 29A. Check the latest gazetted provisions for your workplace.
General guidance, reviewed October 2026; not a replacement for a site-specific regulatory determination.

