First Aid Requirements Malaysia: OSHA 1994 Employer Obligations for Factories and Workplaces

A worker slices his hand on sheet metal. Blood is everywhere. Your supervisor runs to grab the first aid box and finds it locked in a cabinet with no key. The bandages inside expired two years ago. There are no trained first aiders on the floor. By the time someone drives the worker to a clinic, what should have been a minor cut has become a serious infection risk and a potential DOSH investigation.

This guide covers every first aid obligation Malaysian employers must meet, from first aid box contents to trained personnel ratios, and how your insurance coverage connects to first aid compliance.

This guide covers:

• Legal basis for first aid requirements under OSHA 1994 (and applicable FMA subsidiary regulations)
• First aid box contents and placement standards
• First aider training and ratio requirements
• First aid room requirements for larger workplaces
• Record-keeping obligations
• How WC and CGL insurance connect to first aid readiness
• Common compliance gaps and how to fix them

Legal Framework: Where First Aid Obligations Come From

First aid requirements for Malaysian workplaces don't come from a single law. They sit across multiple pieces of legislation, each covering different aspects of employer obligations.

Here's how the legal framework breaks down.

Legislation	Section	First Aid Requirement
OSHA 1994 (Act 514)	Section 15 — General duties of employers	Employer must provide and maintain a safe working environment, which includes adequate first aid arrangements
OSHA 1994 (Act 514)	Section 24 — Duties of employees	Employees must cooperate with employer on safety measures including first aid procedures
FMA 1967 (Act 139) — repealed 1 Jun 2024; subsidiary regulations remain applicable	Section 25 — First aid facilities	Every factory must provide and maintain first aid boxes with prescribed contents
FMA 1967 (Act 139) — repealed 1 Jun 2024; subsidiary regulations remain applicable	Section 25(2)	Factories with 100+ workers must maintain a first aid room with prescribed equipment
OSHA 1994 Amendment 2022 (Act A1648)	Enhanced penalties	Maximum penalties for employer duty failures increased from RM50,000 to RM500,000

The key point: first aid isn't optional or "nice to have." It's a statutory obligation under OSHA 1994 and applicable FMA subsidiary regulations (which remain in force pending new regulations under OSHA). Failure to provide adequate first aid facilities is a breach of employer duty that can trigger penalties, DOSH enforcement action, and complications with your insurance claims.

First Aid Box Requirements

Every workplace must have at least one first aid box that is clearly marked, easily accessible, and stocked with the right supplies. The box cannot be locked in a room that workers can't access. It must be available during all working hours, including overtime and night shifts.

How Many First Aid Boxes Do You Need?

The number of first aid boxes depends on the size of your workforce and the layout of your premises.

Number of Workers	Minimum First Aid Boxes	Notes
1–25	1	Must be within reasonable access
26–50	1	Larger box or additional supplies recommended
51–100	2	Distributed across work areas
101–200	3	Plus first aid room required
201+	1 per 100 workers	Additional boxes for isolated or high-risk areas

For multi-storey factories, you need at least one first aid box per floor. For sites with separate buildings or isolated work areas (such as boiler rooms, chemical stores, or loading bays), additional first aid boxes are needed regardless of headcount.

First Aid Box Contents

DOSH guidelines specify minimum contents for workplace first aid boxes. These aren't suggestions. During a DOSH inspection or audit, officers will check that your first aid boxes contain the required items and that nothing is expired.

Item	Quantity (Standard Box)	Purpose
Sterile adhesive dressings (plasters)	20 assorted	Minor cuts and abrasions
Sterile eye pads	2	Eye injuries and chemical splash
Triangular bandages	4	Slings and securing dressings
Sterile wound dressings (medium)	6	Larger wounds and lacerations
Sterile wound dressings (large)	2	Major wounds requiring pressure
Safety pins	6	Securing bandages
Disposable gloves (pairs)	4	Infection control
Crepe bandages	2	Sprains and support
Antiseptic wipes	10	Cleaning wounds
Scissors (blunt-ended)	1	Cutting bandages and dressings
Tweezers	1	Removing splinters or debris
First aid guidance card	1	Basic treatment instructions

Medication is not allowed in first aid boxes. No painkillers, no antibiotics, no medicated creams. First aid boxes are for immediate wound care only. If a worker needs medication, they must be referred to a medical professional.

Additional Requirements for High-Risk Workplaces

Factories handling chemicals, hot works, or hazardous materials need additional first aid supplies beyond the standard box.

Workplace Hazard	Additional First Aid Equipment	Regulatory Basis
Chemical handling (USECHH)	Emergency eyewash station, safety shower, chemical-specific antidotes as per SDS	USECHH Regulations 2000
Hot works (welding, cutting)	Burn dressings, cooling gel, sterile burn sheets	OSHA 1994 + DOSH guidelines
Confined spaces	Portable oxygen, resuscitation equipment, stretcher	Confined Spaces Regulations (ICOP)
Working at height	Spinal board, cervical collar, stretcher	DOSH guidelines on fall protection
Electrical work	AED (automated external defibrillator), burn dressings	Electricity Supply Act 1990

If your workplace handles chemicals regulated under CIMAH 1996, your emergency response plan must include specific first aid provisions for chemical exposure, including decontamination procedures.

Trained First Aiders: Who and How Many

Having a first aid box means nothing if nobody knows how to use it. OSHA 1994 requires employers to ensure that trained first aid personnel are available during all working hours.

First Aider Ratio Requirements

Number of Workers	Minimum First Aiders	Additional Notes
1–25 (low risk)	1 appointed person	Appointed person manages first aid box and calls for help
1–25 (high risk)	1 trained first aider	Must hold valid first aid certificate
26–50	2 trained first aiders	At least 1 available per shift
51–100	3 trained first aiders	Coverage for shift work and leave
101–200	4 trained first aiders	Plus occupational first aid attendant for first aid room
201+	1 per 50 workers	Consider dedicated first aid room staff

Shift coverage is non-negotiable. If your factory runs two or three shifts, you need trained first aiders available during every shift. Having all your first aiders on the day shift leaves your night shift workers without coverage, and that's a compliance gap DOSH inspectors will flag.

First Aid Training Requirements

Not just any training counts. First aiders must hold a valid first aid certificate from a DOSH-recognised training provider. The standard first aid training covers basic life support, wound management, fracture handling, and emergency response.

Training Aspect	Requirement
Training provider	Must be DOSH-recognised (St John Ambulance Malaysia, Malaysian Red Crescent Society, or DOSH-approved private providers)
Certificate validity	3 years from date of issue
Refresher training	Required before certificate expires; annual refresher recommended
Course duration	Typically 2–3 days (16–24 hours) for standard occupational first aid
Topics covered	CPR, wound care, fractures, burns, poisoning, shock management, casualty transport
Records	Employer must keep copies of all certificates and track expiry dates

The biggest mistake employers make? Sending someone for training once and forgetting about it. Three years later, the certificate has expired, the first aider has transferred to another department, and nobody on the floor is qualified. Set calendar reminders for certificate renewal at least 3 months before expiry.

First Aid Room Requirements

Factories with 100 or more workers are required under Section 25(2) of the former FMA 1967 to provide a dedicated first aid room. This provision remains applicable under the current regulatory framework pending new OSHA subsidiary regulations. The room must be properly equipped, clearly signposted, and accessible during all working hours.

First Aid Room Requirement	Details
Location	Ground floor, easily accessible from all work areas, near vehicle access for ambulance
Signage	White cross on green background, clearly visible from main walkways
Size	Sufficient to accommodate a couch/bed, work surface, and allow stretcher access
Couch/bed	At least 1 examination couch with clean linen, blanket, and pillow
Water supply	Clean running water, hand wash basin, soap, and disposable towels
Equipment	Stretcher, wheelchair, first aid supplies, waste bin with lid
Communication	Telephone or intercom to call emergency services
Lighting and ventilation	Adequate lighting for treatment, proper ventilation or air conditioning
Cleanliness	Must be kept clean and used exclusively for first aid purposes

The room cannot double as a storage area, prayer room, or break room. It must be used exclusively for first aid and medical treatment. DOSH inspectors will check whether the room is being used for its intended purpose.

Record-Keeping Obligations

Every first aid treatment administered at the workplace must be recorded. This isn't just good practice. It's a legal requirement that connects directly to your DOSH reporting obligations and Workmen Compensation claims.

Record Field	Details Required	Why It Matters
Date and time	When the incident occurred and when treatment was given	Establishes timeline for DOSH reports and insurance claims
Name of injured person	Full name and employee ID	Identifies the claimant for WC and PERKESO
Nature of injury	Description of injury type and body part affected	Supports NADOPOD reporting if injury escalates
How the injury occurred	Brief description of incident circumstances	Evidence for accident investigation
Treatment given	What first aid was administered	Shows employer took reasonable action
Name of first aider	Who provided treatment	Verifies qualified person administered aid
Referral	Whether person was sent to clinic/hospital	Triggers PERKESO notification if medical leave exceeds 4 days

Keep these records for at least 5 years. They become critical evidence if a minor injury develops into a long-term condition and the worker files a claim months or years later. Without records, you have no defence.

Connection Between First Aid and Insurance

First aid compliance directly affects two key insurance products: Workmen Compensation (WC) and Comprehensive General Liability (CGL). The relationship works in both directions. Compliance can strengthen your claims position, and non-compliance can weaken it.

How First Aid Affects WC Claims

Scenario	Without Proper First Aid	With Proper First Aid
Minor cut on production line	Untreated cut becomes infected, worker hospitalised for 2 weeks. WC claim for medical + temporary disablement.	Trained first aider cleans and dresses wound. Worker returns to work same day. No WC claim needed.
Chemical splash to eyes	No eyewash station. Worker suffers permanent vision damage. WC claim for permanent partial disablement.	Immediate eyewash within 10 seconds. Damage minimised. WC claim for minor treatment only.
Worker collapses from heat stroke	Nobody knows what to do. Delayed response leads to organ damage. WC claim for permanent disablement or death.	First aider initiates cooling protocol, calls ambulance. Worker recovers fully. WC claim for medical treatment only.
Cardiac arrest on site	No AED, no CPR knowledge. Worker dies before ambulance arrives. Death benefit claim.	AED deployed within 3 minutes, CPR administered. Worker survives. WC claim for medical treatment.

The pattern is clear. Quick, competent first aid reduces injury severity, which directly reduces the size of WC claims. Lower claims mean better loss ratios, which translates to more favourable premium rates at renewal.

How First Aid Affects CGL Exposure

CGL covers third-party injuries at your premises. If a visitor, contractor, or delivery driver is injured at your factory and you can't provide adequate first aid, the injury may worsen and the third party has stronger grounds for a liability claim.

Your CGL policy will still respond to valid claims. But if DOSH finds that your first aid facilities were non-compliant at the time of the incident, it creates a regulatory breach that can complicate your defence. It can also lead to separate penalties under OSHA 1994, on top of the liability claim.

Insurance Premium Impact

First Aid Factor	Impact on Insurance
Trained first aiders at required ratios	Demonstrates proactive risk management; may support favourable underwriting
First aid records showing declining injuries	Evidence of improving safety culture; supports claims for lower premiums
AED and advanced equipment	Reduces maximum severity exposure; relevant for WC underwriting
No first aid programme	Higher claims frequency and severity; premium loading at renewal
DOSH enforcement notice for first aid gaps	Red flag for insurers; may affect renewal terms or trigger survey requirement

Common First Aid Compliance Gaps

After years of helping Malaysian factories with risk assessments, these are the first aid gaps that show up again and again. Most aren't deliberate violations. They happen because first aid gets treated as a one-time setup rather than an ongoing programme.

Common Gap	Why It Happens	How to Fix It
Expired supplies in first aid box	Nobody assigned to check regularly	Monthly inspection with checklist, assign specific person per box
First aider certificate expired	No tracking system for expiry dates	Maintain register with expiry dates, set 3-month advance reminders
No first aider on night shift	All trained first aiders work day shift	Train first aiders across all shifts; include in shift planning
First aid room used as storage	Space pressure in factory	Clear the room; it's a legal requirement, not negotiable
No first aid records kept	First aiders treat and forget	Provide standardised logbook at each first aid station
Workers don't know where first aid box is	No induction training or signage	Include first aid locations in induction, post directional signs
No eyewash station near chemicals	Assumed general first aid box was enough	Install plumbed or portable eyewash within 10-second walking distance

First Aid Compliance Checklist

Use this checklist to assess your workplace's first aid readiness. If you're scoring less than 80%, you have compliance gaps that need immediate attention.

Item	Status
First aid boxes provided at required ratio (1 per 25–50 workers)	☐
All first aid boxes stocked with prescribed contents	☐
No expired items in any first aid box	☐
First aid boxes clearly marked and easily accessible	☐
Trained first aiders at required ratio with valid certificates	☐
First aider coverage on all shifts (including night and weekend)	☐
First aid certificate expiry dates tracked and renewal scheduled	☐
First aid room provided (if 100+ workers)	☐
First aid room used exclusively for first aid (not storage)	☐
Emergency eyewash stations near chemical handling areas	☐
First aid treatment logbook maintained and up to date	☐
All workers know first aid box locations (covered in induction)	☐
Emergency numbers posted at all first aid stations	☐
Monthly inspection schedule for all first aid boxes	☐
First aid provisions included in Emergency Response Plan	☐

Penalties for Non-Compliance

Since the OSHA 1994 Amendment 2022 (Act A1648) took effect on 1 June 2024, the penalties for failing to meet employer safety obligations have increased significantly.

Offence	Maximum Penalty	Section
Failure to provide safe workplace (includes first aid)	Fine up to RM500,000 or imprisonment up to 2 years or both	Section 15, OSHA 1994
Failure to provide first aid facilities in factory	Now falls under OSHA 1994 employer duties (FMA 1967 repealed 1 Jun 2024). Fine up to RM500,000	Section 15, OSHA 1994 (formerly Section 25, FMA 1967)
Failure to comply with improvement notice	Fine up to RM50,000 or imprisonment up to 1 year or both	Section 48, OSHA 1994
Failure to comply with prohibition notice	Fine up to RM100,000 or imprisonment up to 2 years or both	Section 49, OSHA 1994

But penalties aren't the real risk. The real risk is what happens when an injury occurs and your first aid programme was deficient. A worker who could have been treated on site ends up hospitalised. A minor chemical splash that should have been flushed in 10 seconds leads to permanent eye damage. These outcomes generate WC claims, civil lawsuits, and DOSH investigations that cost far more than any fine.

For a detailed breakdown of all OSHA 1994 penalties and fines, see our separate guide.

Integration with Emergency Response Plan

First aid doesn't operate in isolation. It's a key component of your workplace Emergency Response Plan (ERP). DOSH expects your ERP to clearly define first aid roles, responsibilities, and escalation procedures.

ERP Component	First Aid Integration
Emergency team structure	First aiders assigned by name and shift in the ERP document
Evacuation procedures	First aid assembly point identified; first aiders report to triage area
Chemical emergency	Specific decontamination and first aid procedures per SDS
Communication chain	First aider contacts ambulance, supervisor contacts management
Fire drill	First aiders check their zones for casualties during evacuation
Post-incident	First aider provides treatment log to SHO for accident reporting

If your workplace has a Safety and Health Officer (SHO), they should oversee the first aid programme as part of their wider safety management responsibilities.

FAQ

Is first aid training mandatory for Malaysian employers?

Yes. Under OSHA 1994, employers must ensure adequate first aid arrangements, which includes having trained first aiders. The former FMA 1967 (now repealed, with subsidiary regulations still applicable) specifically required factories to have first aid facilities and personnel. The exact number of trained first aiders depends on your workforce size and risk level.

How many first aid boxes does my factory need?

As a general guide, you need at least 1 first aid box per 25–50 workers. Multi-storey premises need at least 1 per floor. High-risk or isolated areas (boiler rooms, chemical stores, loading bays) need additional boxes regardless of headcount.

Can I put medication like paracetamol in the first aid box?

No. First aid boxes are for immediate wound care only. Medication including painkillers, antibiotics, and medicated creams are not permitted in first aid boxes. Workers needing medication must be referred to a medical professional.

How often should first aid boxes be inspected?

Monthly at minimum. Assign a specific person responsible for each first aid box. They should check stock levels, expiry dates, and cleanliness. Record the inspection date and any items replaced. After any use, the box should be restocked immediately.

When does my factory need a dedicated first aid room?

Under Section 25(2) of the former FMA 1967, factories with 100 or more workers must provide a dedicated first aid room. This requirement remains applicable under the current regulatory framework. The room must be on the ground floor, properly equipped with a couch, running water, and communication facilities, and used exclusively for first aid.

Does first aid compliance affect my insurance premiums?

Indirectly, yes. Proper first aid reduces injury severity, which lowers WC claim sizes and frequency. Better loss ratios lead to more favourable premium rates at renewal. A DOSH enforcement notice for first aid gaps can also raise red flags during underwriting.

Who are the approved first aid training providers in Malaysia?

DOSH recognises St John Ambulance Malaysia and the Malaysian Red Crescent Society as primary providers. There are also DOSH-approved private training providers. Always verify that your chosen provider is currently recognised by DOSH before enrolling staff.

How long is a first aid certificate valid?

Standard occupational first aid certificates are valid for 3 years. Employers must track expiry dates and arrange refresher training before certificates lapse. Annual refresher sessions are recommended even if the certificate hasn't expired.

What happens if a worker is injured and we don't have proper first aid?

Multiple consequences. The injury may escalate to a more serious condition, generating a larger WC claim. DOSH can issue an improvement or prohibition notice. You face penalties under OSHA 1994 of up to RM500,000. And if the injured party sues, the lack of first aid undermines your defence in court.

Do I need an AED (defibrillator) at my workplace?

There's no blanket legal requirement for AEDs in all Malaysian workplaces. But for higher-risk environments like manufacturing plants, construction sites, and facilities with electrical hazards, an AED is strongly recommended. It can mean the difference between life and death in a cardiac arrest, and demonstrates proactive safety management to insurers.

Foundation Conclusion

First aid compliance is one of the most cost-effective safety investments a Malaysian employer can make. The equipment costs are minimal. The training takes a few days. But the impact on injury outcomes, regulatory compliance, and insurance claims can be significant.

Proper first aid reduces the severity of workplace injuries, which directly reduces the cost and frequency of Workmen Compensation and CGL claims. It also demonstrates the kind of proactive risk management that insurers value during underwriting and renewal.

Talk to our risk specialists about aligning your first aid programme with the right insurance coverage

Disclaimer: This article provides general guidance based on current regulations and official agency information as of March 2026. Regulations may be amended. Always verify current requirements with the relevant agency or qualified professionals before making compliance decisions.