Confined Space Requirements Malaysia: DOSH Regulations, Entry Permit & Safety Procedures

Disclaimer: This article provides general guidance based on the Industry Code of Practice for Safe Working in a Confined Space 2010 (ICOP 2010) and OSHA 1994 as of February 2026. Regulations may be amended. Always verify current requirements with DOSH or qualified professionals before making compliance decisions.

A maintenance worker enters a tank to clean residue. Within minutes, he collapses from hydrogen sulphide exposure. His colleague rushes in to help and also collapses. Two workers dead in under five minutes. This is not hypothetical. Confined space fatalities in Malaysia follow this exact pattern: the initial victim plus the would-be rescuer.

Confined space entry is one of the most lethal workplace activities. DOSH's ICOP 2010 exists to prevent these deaths through mandatory permits, atmospheric testing, and trained rescue teams.

This guide covers:

• What qualifies as a confined space under Malaysian regulations
• The entry permit system and when it's required
• Atmospheric testing requirements
• Certified personnel: who must be present and what qualifications they need
• Rescue and emergency procedures
• Employer obligations and penalties
• Insurance implications for confined space work

What Is a Confined Space?

Under DOSH's Industry Code of Practice for Safe Working in a Confined Space 2010 (ICOP 2010), a confined space is any enclosed or partially enclosed space that meets three criteria.

Criteria	Definition	Key Point
Not designed for continuous occupancy	The space was not intended for people to work in continuously	Doesn't have to be small; large tanks qualify
Limited entry or exit	Restricted means of entry/exit (manholes, hatches, small openings)	Difficulty getting in/out affects rescue capability
Hazardous atmosphere or other hazard	Risk of toxic gases, oxygen deficiency/enrichment, flammable vapours, engulfment	The atmosphere can change rapidly inside a confined space

Common Confined Spaces in Malaysian Industries

Industry	Typical Confined Spaces	Key Hazards
Oil and gas	Storage tanks, pressure vessels, pipelines, separators	H2S, hydrocarbon vapours, oxygen deficiency
Manufacturing	Mixing vessels, ovens, silos, hoppers, vats	Chemical residues, oxygen depletion, fumes
Construction	Manholes, tunnels, shafts, excavations, caissons	Oxygen deficiency, ground gas, water ingress
Utilities	Sewers, water treatment tanks, pump chambers	H2S, methane, oxygen deficiency, drowning
Power generation	Boiler drums, condensers, cooling towers, fuel tanks	Inert gas purging, residual chemicals, heat
Palm oil mills	Digesters, sterilizers, clarification tanks, effluent ponds	Methane, CO2, H2S, oxygen deficiency
Shipping and marine	Cargo holds, ballast tanks, chain lockers, void spaces	Oxygen depletion, toxic cargo residues

The Entry Permit System

No one enters a confined space without a valid entry permit. This is the core requirement of ICOP 2010. The permit-to-work (PTW) system ensures that every entry is planned, assessed, and controlled.

Permit Element	Requirement	Who Is Responsible
Risk assessment	Identify all hazards specific to the space and planned work	Entry Supervisor / SHO
Atmospheric testing	Test for oxygen, flammable gases, and toxic gases before and during entry	Authorised Gas Tester (AGT)
Isolation and lockout	Isolate all energy sources, pipelines, and electrical supplies	Maintenance / operations team
Ventilation	Provide mechanical ventilation to maintain safe atmosphere	Entry Supervisor
Personnel	Certified entrants, standby person, entry supervisor must be assigned	Employer
Rescue plan	Documented rescue procedure with equipment on standby	Entry Supervisor / Employer
Communication	Continuous communication between entrant and standby person	All personnel involved
Permit duration	Time-limited; must be renewed if work extends beyond permit period	Entry Supervisor

The permit is not paperwork. It's a safety gate. Each element on the permit must be physically verified before entry is allowed. If any condition changes during the work (atmospheric readings shift, new hazards identified), the permit is suspended and everyone exits immediately.

Atmospheric Testing: The Life-or-Death Check

Atmospheric testing is the single most important safety measure in confined space work. The atmosphere inside a confined space can kill within seconds.

Parameter	Safe Range	Danger Level	What Happens
Oxygen (O2)	19.5% - 23.5%	Below 16%: impaired judgement. Below 10%: unconsciousness and death	Oxygen can be displaced by inert gases or consumed by rusting, decomposition
Flammable gases	Below 10% of LEL	Above 10% LEL: entry not permitted without additional controls	Explosion or flash fire risk (methane, hydrogen, petrol vapour)
Hydrogen sulphide (H2S)	Below 10 ppm (PEL)	100 ppm: dangerous. 300+ ppm: rapidly fatal	Common in sewers, tanks, oil/gas. Deadens sense of smell at high concentration
Carbon monoxide (CO)	Below 25 ppm (PEL)	200 ppm: headache. 800+ ppm: unconsciousness	From engine exhaust, combustion, welding in confined areas

Testing order matters: Test for oxygen first, then flammable gases, then toxic gases. An oxygen-deficient atmosphere affects gas detector readings for other gases. Test at multiple levels (top, middle, bottom) because gases stratify by density.

Continuous monitoring during entry is mandatory. Conditions can change rapidly. A space that tested safe before entry can become deadly if residue is disturbed, ventilation fails, or adjacent processes introduce contaminants.

Certified Personnel Requirements

ICOP 2010 defines specific roles for confined space work. Each role requires specific DOSH-recognised certification.

Role	Certification Required	Key Responsibilities
Entry Supervisor	AESP + AGT + Entry Supervisor certification	Authorises entry, verifies all safety measures, can cancel permit at any time
Authorised Entrant	AESP (Authorised Entrant and Standby Person) certification	Enters the confined space; must know hazards, emergency procedures, and exit procedures
Standby Person	AESP certification	Stationed outside the confined space; maintains communication; summons rescue if needed; must never enter the space
Authorised Gas Tester (AGT)	AGT certification	Conducts and interprets atmospheric testing; certifies atmosphere is safe for entry

The standby person's role is critical. The most common confined space fatality pattern is the "rescuer death": an untrained person sees a colleague collapse and rushes in to help, only to be overcome themselves. The standby person's job is to summon professional rescue, not to enter the space. This single rule saves lives.

Rescue and Emergency Procedures

Every confined space entry must have a documented rescue plan before the first person enters. ICOP 2010 requires both self-rescue capability and external rescue arrangements.

Rescue Element	Requirement
Self-rescue equipment	Harness, lifeline, retrieval system at the entry point
SCBA / supplied air	Self-Contained Breathing Apparatus must be available for rescue team
Rescue team	Trained rescue team on standby (internal or external service provider)
First aid	Trained first aider and first aid equipment at the entry point
Communication with hospital	Nearest hospital identified; emergency transport arranged
Rescue drill	Practice rescue procedures regularly (at least annually)

Non-entry rescue is always preferred. Using a retrieval system (tripod with winch and harness) to extract a casualty without anyone else entering the space is the safest option. Entry-based rescue should only happen when non-entry methods aren't feasible.

Employer Obligations

Under OSHA 1994 and ICOP 2010, the employer bears the primary responsibility for confined space safety.

Obligation	What It Requires
Identify all confined spaces	Survey your workplace and inventory every confined space
Develop confined space entry programme	Written programme covering all ICOP 2010 requirements
Implement permit-to-work system	Documented PTW for every confined space entry
Provide certified personnel	Ensure all roles are filled by DOSH-certified workers
Provide equipment	Gas detectors, ventilation, PPE, rescue equipment, communication devices
Conduct HIRARC	Specific hazard assessment for each confined space and entry
Train all involved personnel	Regular training, drills, and refresher courses
Maintain records	Keep all permits, atmospheric test results, and training records

Penalties for Non-Compliance

Confined space violations fall under OSHA 1994, which was significantly amended in 2022. The penalties are severe because the consequences of non-compliance are often fatal.

Offence	Penalty
Failure to provide safe system of work (OSHA s.15)	Fine up to RM500,000 and/or imprisonment up to 2 years
Failure to comply with ICOP requirements	Fine up to RM500,000 and/or imprisonment up to 2 years
Confined space death due to employer negligence	Higher penalties; potential criminal prosecution under Penal Code
Failure to report workplace death/injury (OSHA s.32)	Fine up to RM500,000 and/or imprisonment up to 2 years

These are the post-OSHA 1994 (Amendment 2022) penalties, effective 1 June 2024. The maximum fine increased tenfold from the previous RM50,000.

Insurance Implications for Confined Space Work

Confined space incidents have major insurance implications. Here's how they connect to your coverage.

Insurance Type	How Confined Space Work Connects	Risk Without Compliance
Workmen Compensation	Worker deaths/injuries in confined spaces are WC claims	Multiple fatality claims; employer faces common law liability beyond WC
CGL Insurance	Third-party injuries near confined space operations trigger CGL	Insurer may dispute claim if no permit system existed
CAR/EAR Insurance	Construction site confined space incidents during project works	Non-compliance weakens claims position

Compliance is your claims defence. If a confined space fatality occurs and you can demonstrate a compliant entry programme with valid permits, atmospheric testing records, and certified personnel, your insurance position is much stronger. Without compliance documentation, insurers may argue contributory negligence.

Managing high-risk operations? Talk to Foundation about your liability coverage.

Confined Space Entry Checklist

Item	Status Required
Confined space identified and classified	Completed and documented
Entry permit issued and signed	Valid, time-limited, posted at entry point
Atmospheric testing completed	O2, LEL, H2S, CO all within safe limits
Continuous gas monitoring in place	Personal gas detector on each entrant
All energy sources isolated and locked out	LOTO tags verified
Mechanical ventilation operating	Adequate airflow confirmed
Certified personnel in position	Entry Supervisor, AGT, Entrants, Standby Person all present with valid certs
Rescue equipment at entry point	Tripod/winch, SCBA, harnesses, lifelines ready
Communication system working	Tested between entrant and standby person
Emergency contacts and hospital identified	Posted at entry point

FAQ

What qualifies as a confined space in Malaysia?

Any enclosed or partially enclosed space that is not designed for continuous occupancy, has limited entry or exit, and has or may develop a hazardous atmosphere or other hazard. Common examples include tanks, vessels, silos, manholes, tunnels, and excavations deeper than 1.5 metres.

Is a permit required for every confined space entry?

Yes. Under ICOP 2010, a written entry permit is mandatory for every confined space entry. There are no exceptions. Even if you entered the same space yesterday, you need a fresh permit with new atmospheric test results for today's entry.

What certifications do workers need for confined space entry?

Workers entering a confined space need AESP (Authorised Entrant and Standby Person) certification from a DOSH-recognised training provider. The Entry Supervisor needs AESP + AGT (Authorised Gas Tester) + Entry Supervisor certification. The gas tester needs AGT certification.

How often must atmospheric testing be done?

Before entry (pre-entry testing) and continuously during entry using personal gas detectors. Pre-entry testing must be done by a certified AGT. If there's any interruption in entry (break, shift change), re-test before re-entering.

What should the standby person do if someone collapses inside?

The standby person must NOT enter the confined space. They must immediately: alert the Entry Supervisor, activate the rescue plan, call emergency services, attempt non-entry rescue using retrieval equipment if possible, and keep bystanders away. Entering to rescue is the most common cause of multiple fatalities in confined spaces.

Can I use a confined space without ventilation if the atmosphere tests safe?

ICOP 2010 strongly recommends mechanical ventilation for all confined space entries. Even if initial testing shows safe levels, conditions can change rapidly. Ventilation provides ongoing protection and is considered a minimum control measure for most entries.

What happens if DOSH investigates a confined space fatality?

DOSH will investigate the incident thoroughly. They'll check whether you had a written confined space programme, whether entry permits were issued, whether atmospheric testing was conducted by a certified AGT, whether certified personnel were present, and whether rescue procedures were in place. Non-compliance leads to prosecution under OSHA 1994.

How does confined space work affect my insurance premiums?

Insurers consider confined space work a high-risk activity. Having a documented compliance programme with ICOP 2010 demonstrates risk management, which can positively affect underwriting. Conversely, a confined space fatality with no compliance programme will affect your claims history and future premiums significantly.

Are excavations considered confined spaces?

Excavations can be classified as confined spaces if they meet the criteria: limited entry/exit and potential for hazardous atmosphere. Deep excavations (generally over 1.5 metres) with potential for ground gas accumulation or oxygen displacement should be treated as confined spaces with full ICOP 2010 requirements.

How long is the AESP certification valid?

AESP and AGT certifications are valid for 3 years. Workers must renew their certification before expiry through refresher training from DOSH-recognised providers. Using workers with expired certifications is a compliance violation.

Foundation Conclusion

Confined space work kills quickly and often claims multiple victims. The rules exist because the risks are real and predictable. A proper entry permit system with atmospheric testing, certified personnel, and rescue planning prevents the vast majority of confined space fatalities.

Foundation works with manufacturers, contractors, and industrial operators who perform confined space work. The liability exposure from these operations affects your CGL and Workmen Compensation programmes. Proper compliance strengthens both your safety record and your insurance position.

Talk to our risk specialists about high-risk operations coverage