CHRA Malaysia: Chemical Health Risk Assessment Requirements & USECHH Compliance Guide 2026

Disclaimer: This article provides general guidance based on the Occupational Safety and Health (Use and Standards of Exposure of Chemicals Hazardous to Health) Regulations 2000 and official DOSH information as of February 2026. Regulations may be amended. Always verify current requirements with DOSH or qualified professionals before making compliance decisions.

Your factory uses solvents, adhesives, cleaning agents, or any industrial chemicals. Under Malaysian law, you're required to assess the health risks those chemicals pose to every exposed worker. That assessment is called a CHRA.

A CHRA (Chemical Health Risk Assessment) is mandatory for every workplace in Malaysia that uses, handles, stores, or transports chemicals hazardous to health. No CHRA means fines up to RM500,000.

This guide covers:

• What CHRA is and why it's legally required
• The USECHH Regulations 2000 framework
• Who must conduct a CHRA (and who qualifies as an assessor)
• The step-by-step CHRA process
• Employer obligations after receiving the CHRA report
• Penalties for non-compliance under OSHA 1994 (Amendment 2022)
• How CHRA connects to your insurance programme

What Is CHRA?

CHRA stands for Chemical Health Risk Assessment. It's a systematic evaluation of the health risks to employees arising from exposure to chemicals hazardous to health at the workplace. The assessment identifies which chemicals are present, how workers are exposed, and what controls are needed to reduce exposure to safe levels.

CHRA is not optional. It's mandated under Regulation 9 of the Occupational Safety and Health (Use and Standards of Exposure of Chemicals Hazardous to Health) Regulations 2000, commonly known as the USECHH Regulations.

CHRA Component	What It Involves	Why It Matters
Chemical inventory	Complete list of all chemicals used, handled, stored, or transported	You can't assess risks you don't know about
Hazard identification	Review Safety Data Sheets (SDS), classify chemicals by hazard type	Determines which chemicals are hazardous to health
Exposure assessment	Air monitoring, personal sampling, job observations	Measures actual exposure levels against permissible limits (PEL/STEL)
Risk characterisation	Compare exposure levels to USECHH Permissible Exposure Limits	Determines if current controls are adequate
Control recommendations	Engineering controls, admin controls, PPE requirements	Employer must implement within 1 month of receiving report

The USECHH Regulations 2000: Legal Framework

The USECHH Regulations 2000 (Use and Standards of Exposure of Chemicals Hazardous to Health) form the legal backbone of chemical safety in Malaysian workplaces. They sit under the Occupational Safety and Health Act 1994 (OSHA 1994) and apply to every workplace where chemicals hazardous to health are used.

Regulation	Requirement	Who It Applies To
Regulation 9	Employer must conduct CHRA before exposing employees to chemicals	All employers using chemicals hazardous to health
Regulation 10	CHRA must be conducted by a DOSH-registered assessor	Assessors must hold valid DOSH registration
Regulation 11	Chemical Register must be maintained	All workplaces with chemicals
Regulation 14	Employer must implement CHRA recommendations within 1 month	All employers who receive a CHRA report
Regulation 16	Medical surveillance for exposed employees	Employees exposed above action levels
Regulation 17	Information, instruction, and training on chemical hazards	All employees exposed to chemicals
Regulation 22	CHRA must be reassessed every 5 years minimum	Ongoing requirement

"Chemicals hazardous to health" is broader than you think. It includes any chemical classified as toxic, harmful, corrosive, irritant, sensitising, carcinogenic, mutagenic, or teratogenic. This covers common industrial substances like solvents (toluene, xylene), adhesives, paints, cleaning agents, acids, alkalis, dusts, fumes, and gases.

Who Must Conduct a CHRA?

Every employer who uses, handles, stores, or transports chemicals hazardous to health at their workplace. In practice, this means almost every factory, laboratory, and industrial facility in Malaysia.

Industry	Common Chemicals Requiring CHRA	Typical Exposure Routes
Manufacturing (electronics)	Solvents, flux, etching chemicals, cleaning agents	Inhalation, skin absorption
Manufacturing (plastics/rubber)	Resins, catalysts, curing agents, mould release agents	Inhalation of fumes and vapours
Construction	Paints, thinners, epoxies, waterproofing chemicals, cement dust	Inhalation, skin contact
Food and beverage	Sanitisers, ammonia (refrigeration), cleaning chemicals	Inhalation, skin contact
Oil and gas	Benzene, H2S, drilling fluids, corrosion inhibitors	Inhalation (acute and chronic)
Warehousing and logistics	Fumigants, preservatives, stored chemicals	Inhalation during handling
Laboratories	Reagents, acids, bases, organic solvents	All routes (inhalation, skin, ingestion)

The catch: Even if you think your chemicals are "low risk," you still need a CHRA to prove it. DOSH doesn't accept self-assessment. The CHRA must be conducted by a DOSH-registered assessor, and the report must be kept on-site for inspection.

DOSH-Registered Assessors: Who Can Conduct CHRA?

You can't do a CHRA yourself. Regulation 10 requires the assessment to be conducted by a person registered with DOSH as a competent assessor.

Assessor Type	Qualification	Scope
Hygiene Technician	DOSH-registered, completed recognised training programme	Can conduct CHRA including air monitoring and sampling
Industrial Hygienist	DOSH-registered, higher qualification level	Full scope CHRA, complex assessments, medical surveillance oversight
Occupational Health Doctor	Registered medical practitioner with DOSH registration	Medical surveillance component, health monitoring

Verify your assessor's registration. Ask for their DOSH registration number before engaging them. An assessment conducted by an unregistered person is invalid, and you'll still be non-compliant even though you paid for the assessment.

The CHRA Process: Step by Step

Here's what happens during a CHRA, from start to finish.

Step	Activity	Your Responsibility
1. Preparation	Compile chemical inventory and obtain Safety Data Sheets (SDS) for all chemicals	Provide complete and accurate chemical list to assessor
2. Walk-through survey	Assessor visits workplace to observe chemical use, storage, and handling	Allow full access to all work areas and processes
3. Exposure monitoring	Air sampling, personal exposure monitoring during typical operations	Ensure normal operations during sampling (don't clean up specially)
4. Laboratory analysis	Samples analysed at accredited laboratory	Wait for results (typically 2-4 weeks)
5. Risk characterisation	Compare results against USECHH Permissible Exposure Limits (PEL)	Review results with assessor
6. Report	Assessor produces CHRA report with findings and recommendations	Receive, review, and keep on-site for DOSH inspection
7. Implementation	Implement recommended control measures	Must implement within 1 month of receiving report (Reg 14)

The 1-month deadline is the part most employers miss. Regulation 14(1) states that the employer must take actions to eliminate or reduce exposure within one month of receiving the CHRA report. Having a CHRA report on file is not enough. You must act on the recommendations.

When Must CHRA Be Conducted or Repeated?

Trigger	Requirement	Timeline
First CHRA	Before any work exposes employees to chemicals hazardous to health	Before operations commence
Periodic reassessment	Reassess even if no significant changes	Every 5 years minimum
New chemical introduced	Reassess for the new chemical	Before using the new chemical
Process change	Changes to processes, tasks, or chemical usage patterns	Before implementing the change
Employee health complaint	DOSH may require reassessment if workers report chemical-related health issues	As directed by DOSH
DOSH directive	DOSH inspector can require reassessment at any time	As specified in the directive

Running a factory with chemical exposure? Talk to Foundation about your liability insurance needs.

The Chemical Register: Your Foundation Document

Before the CHRA even begins, Regulation 11 requires you to maintain a Chemical Register. This is the baseline document for all chemical safety management.

Your Chemical Register must include:

• Product name: Commercial name of each chemical product
• Chemical composition: Active ingredients, CAS numbers
• Classification: Hazard classification per GHS/CLASS Regulations
• Quantity: Amount used, stored, and purchased annually
• Location: Where the chemical is used and stored
• Safety Data Sheet (SDS): Current SDS for each chemical product

DOSH inspectors check the Chemical Register first. If you can't produce an up-to-date register during an inspection, that's an immediate non-compliance finding. Keep it current whenever you introduce, remove, or change chemicals.

Employer Obligations After CHRA

Receiving the CHRA report is the beginning, not the end. Here's what you must do.

Obligation	Regulation	Deadline
Implement control measures recommended in CHRA report	Reg 14(1)	Within 1 month of receiving report
Provide information, instruction, and training to exposed employees	Reg 17	Before exposure and periodically
Arrange medical surveillance for employees above action levels	Reg 16	As recommended in CHRA report
Provide and maintain appropriate PPE	Reg 15	Immediately where exposure exceeds limits
Keep CHRA report accessible for DOSH inspection	Reg 9	Permanently (until superseded by new assessment)
Maintain records of exposure monitoring results	Reg 12	At least 30 years for carcinogens, 7 years for others

Hierarchy of Controls for Chemical Hazards

The CHRA report will recommend controls based on the hierarchy of controls. The most effective controls are at the top; PPE is the last resort.

Priority	Control Type	Example
1 (Most effective)	Elimination	Remove the hazardous chemical entirely from the process
2	Substitution	Replace with a less hazardous chemical (e.g., water-based instead of solvent-based)
3	Engineering controls	Local exhaust ventilation (LEV), enclosed processes, fume hoods
4	Administrative controls	Reduce exposure time, job rotation, standard operating procedures
5 (Last resort)	PPE	Respirators, chemical-resistant gloves, splash goggles, aprons

PPE alone is not acceptable. If your CHRA finds high exposure levels and your only control is "provide respirators," DOSH will not accept that. You must demonstrate that higher-level controls were considered first and explain why they're not feasible before relying on PPE.

Penalties for Non-Compliance

The OSHA 1994 (Amendment 2022), effective 1 June 2024, significantly increased penalties for regulatory breaches including USECHH violations.

Offence	Penalty
Failure to conduct CHRA	Fine up to RM500,000 and/or imprisonment up to 2 years
Failure to maintain Chemical Register	Fine up to RM500,000 and/or imprisonment up to 2 years
Failure to implement CHRA recommendations within 1 month	Fine up to RM500,000 and/or imprisonment up to 2 years
Failure to provide medical surveillance	Fine up to RM500,000 and/or imprisonment up to 2 years
General duty breach (OSHA Section 15)	Fine up to RM500,000 and/or imprisonment up to 2 years
Serious bodily injury or death from chemical exposure	Higher penalties, potential criminal prosecution

These are the post-amendment penalties. Before the 2022 amendment, maximum fines were RM50,000. The tenfold increase reflects how seriously DOSH now takes chemical health management violations.

CHRA and Your Insurance Programme

CHRA doesn't just affect compliance. It directly impacts your insurance coverage and claims.

Insurance Type	How CHRA Connects	Risk If No CHRA
CGL Insurance	Chemical spills affecting third parties trigger CGL claims	Insurer may argue contributory negligence if no CHRA existed
IAR Insurance	Chemical fires/explosions are common IAR claims; CHRA identifies fire/explosion risks	Underwriters may charge higher premiums or impose conditions
Workmen Compensation	Occupational diseases from chemical exposure are WC claims	Higher claims frequency; employer may face common law claims beyond WC

CHRA is evidence of reasonable care. If a chemical incident occurs and you have a valid CHRA with implemented recommendations, it demonstrates you took reasonable steps to manage the risk. Without a CHRA, you're exposed to both regulatory penalties and potentially increased insurance liability.

CHRA Compliance Checklist

Item	Status Required
Chemical Register maintained and up to date	Current, accessible at workplace
Safety Data Sheets (SDS) available for all chemicals	Current SDS in language workers understand
CHRA conducted by DOSH-registered assessor	Valid assessment, not more than 5 years old
CHRA report kept on-site	Accessible for DOSH inspection at any time
CHRA recommendations implemented	Within 1 month of receiving report
Employee training on chemical hazards completed	Records maintained, periodic refresher training
Medical surveillance arranged (if required)	For employees exposed above action levels
PPE provided and maintained	Appropriate to chemical hazards identified
Chemical labelling compliant with CLASS Regulations	GHS-compliant labels on all containers
Emergency procedures for chemical spills/exposure	Documented, trained, emergency equipment available

FAQ

What does CHRA stand for?

CHRA stands for Chemical Health Risk Assessment. It's a mandatory assessment under Malaysia's USECHH Regulations 2000 that evaluates the health risks to employees from exposure to chemicals hazardous to health at the workplace.

Is CHRA mandatory for all factories in Malaysia?

Yes, for any workplace that uses, handles, stores, or transports chemicals hazardous to health. This covers virtually all manufacturing factories, laboratories, and industrial facilities. Even if you only use cleaning chemicals, you may still need a CHRA.

How often must CHRA be repeated?

At minimum, every 5 years. But you must also reassess whenever new chemicals are introduced, processes change, or DOSH directs a reassessment. In practice, factories that frequently change their chemical inventory may need more frequent assessments.

Who can conduct a CHRA in Malaysia?

Only a DOSH-registered assessor: either a Hygiene Technician or an Industrial Hygienist registered with the Department of Occupational Safety and Health. You can't do it yourself, and assessments by unregistered persons are invalid.

How much does a CHRA cost?

Costs vary depending on the number of chemicals, the size of the facility, and the number of exposure groups. Small factories with a few chemicals may pay RM3,000-RM8,000. Large facilities with multiple production lines and dozens of chemicals can pay RM15,000-RM50,000 or more. Air sampling and laboratory analysis are the main cost drivers.

What happens if DOSH inspects and I don't have a CHRA?

DOSH can issue a notice of improvement or prohibition. Under the OSHA 1994 (Amendment 2022), you face fines up to RM500,000 and possible imprisonment up to 2 years. If a worker develops an occupational disease and no CHRA was conducted, the employer's legal and financial exposure increases significantly.

What is the difference between CHRA and HIRARC?

HIRARC (Hazard Identification, Risk Assessment, and Risk Control) is a general workplace risk assessment covering all types of hazards. CHRA is a specialised assessment focused specifically on chemical health hazards. HIRARC is required under OSHA 1994; CHRA is required under the USECHH Regulations 2000. You need both if your workplace has chemical hazards.

What are Permissible Exposure Limits (PEL)?

PELs are the maximum airborne concentrations of chemicals that workers can be exposed to over a specified time period. The USECHH Regulations set PELs for hundreds of chemicals. If your CHRA finds exposure above the PEL, immediate action is required. Short-Term Exposure Limits (STEL) also apply for peak exposure periods.

Does CHRA cover noise and ergonomic hazards?

No. CHRA is specifically for chemical health hazards. Noise assessments fall under the Occupational Safety and Health (Noise Exposure) Regulations 2019. Ergonomic hazards are addressed through HIRARC and the Industry Code of Practice on Indoor Air Quality.

What should I do if a worker reports symptoms from chemical exposure?

Remove the worker from exposure immediately. Provide medical attention. Report to DOSH if the condition is work-related. Review the CHRA to check if current controls are adequate. You may need to reassess the specific chemical or work area. Document everything for both compliance and insurance claim purposes.

Foundation Conclusion

CHRA is the cornerstone of chemical safety management in Malaysian workplaces. Without it, you're not just non-compliant; you're operating blind to risks that can injure workers, contaminate property, and expose your business to penalties and lawsuits.

Foundation works with manufacturing, construction, and industrial operations across Malaysia. Chemical risks directly affect your CGL, IAR, and Workmen Compensation insurance programmes. Proper CHRA compliance reduces your risk profile and strengthens your insurance position.

Talk to our risk specialists about chemical liability coverage