PPE Requirements Malaysia 2026: Complete Employer Obligations Under OSHA 1994

Complete guide to PPE requirements under Malaysia's OSHA 1994 (as amended June 2024). Covers mandatory PPE categories, employer obligations under Section 15 and Section 26, employee duties, industry-specific requirements, and penalties for non-compliance.

PPE Requirements Malaysia 2026: Complete Employer Obligations Under OSHA 1994

Disclaimer: This article provides general guidance on PPE requirements under OSHA 1994 (Amendment 2022), DOSH guidelines, and relevant Malaysian standards. Regulations may be amended. Always verify current requirements with DOSH or qualified safety professionals.

Failing to provide proper Personal Protective Equipment carries penalties up to RM 500,000 and two years imprisonment under the amended OSHA 1994. Section 26 also makes it illegal to charge employees for PPE. These are not obscure technicalities. They are the provisions DOSH inspectors check during every workplace audit.

This guide covers the legal framework, the seven DOSH-approved PPE categories, industry-specific requirements for construction, manufacturing, and warehousing, employer obligations including training and maintenance, employee duties, the updated penalty structure, and the compliance gaps that most commonly trigger enforcement.

Legal Framework: Sections That Apply to PPE

Section Requirement Key Point
Section 15(1) Ensure safety, health, and welfare of all employees General duty. PPE is part of the safe system of work, as far as practicable.
Section 15(2)(c) Provide information, instruction, training, and supervision Includes training on correct PPE use, limitations, and maintenance.
Section 18B (New) Conduct risk assessment HIRARC determines which PPE is required for each activity and hazard.
Section 24(1)(c) Employees must wear PPE provided Employee has a corresponding duty. Penalty up to RM 2,000.
Section 25 Not to interfere with or misuse safety equipment Penalty up to RM 20,000 or 2 years imprisonment for deliberate interference.
Section 26 Duty not to charge employees for safety provisions PPE must be provided free. Includes replacement costs.

PPE is the last line of defence in the hierarchy of controls. DOSH expects employers to demonstrate that higher-level controls (elimination, substitution, engineering, administrative) have been considered first. If your HIRARC lists PPE as the only control for a hazard that could be addressed through engineering or elimination, expect audit questions.

The 7 DOSH-Approved PPE Categories

DOSH requires that PPE in seven regulated categories carry DOSH approval and SIRIM QAS certification. Using non-approved PPE is both a compliance failure and a potential basis for insurance claim complications.

PPE Category DOSH Reference Common Examples Approval Validity
Head protection JKKP HIE/12/2/7 Safety helmets, hard hats, bump caps 5 years
Eye protection JKKP HIE/12/2/3 Safety goggles, face shields, welding shields 5 years
Hearing protection JKKP HIE/12/2/2 Earplugs, earmuffs, canal caps 5 years
Respiratory protection JKKP HIE/12/2/1 Dust masks, N95 respirators, half-face respirators, SCBA 5 years
Hand protection JKKP HIE/12/2/4 Cut-resistant gloves, chemical-resistant gloves, heat-resistant gloves 5 years
Foot protection JKKP HIE/12/2/5 Safety boots, steel-toe shoes, anti-static footwear 5 years
Body protection JKKP HIE/12/2/6 Coveralls, high-visibility vests, chemical suits, flame-resistant clothing 5 years

Verify PPE approval status through the MySKUD system on the DOSH portal (mykkp.dosh.gov.my) before purchasing. Using imported PPE without DOSH approval and SIRIM certification is non-compliant regardless of the product's country of origin or the international certifications it carries.

Industry-Specific PPE Requirements

Construction Sites

Hazard Minimum PPE Required Standard Reference
Falling objects Safety helmet (Type 1 or Type 2) MS 574:2024
Falls from height Full body harness with shock-absorbing lanyard MS ISO 10333-1, EN 361
Flying debris Impact-rated safety goggles or face shield EN 166
Loud machinery (above 85 dB) Earplugs or earmuffs (NRR 25+) MS 2157
Puncture hazards Steel-toe, puncture-resistant boots EN ISO 20345
Traffic and visibility Class 2 or Class 3 high-visibility vest EN ISO 20471

Manufacturing and Factories

Work Activity PPE Requirements
Machine operation Safety glasses, steel-toe boots, close-fitting clothing (no loose sleeves or jewellery)
Chemical handling Chemical-resistant gloves, splash goggles, chemical apron, appropriate respirator per SDS
Welding Welding helmet (auto-darkening or fixed shade), leather welding gloves, flame-resistant coveralls
Material handling Cut-resistant gloves, safety footwear, back support if manual lifting involved
Confined space entry SCBA or air-line respirator, gas detector, retrieval harness, communication device

Warehousing and Logistics

Area PPE Requirements
General warehouse Safety footwear, high-visibility vest
Forklift operation area Safety helmet (for ride-on types), seat belt, high-visibility vest
Cold storage Insulated clothing, thermal gloves, slip-resistant boots
Loading dock High-visibility vest, hard hat, steel-toe boots
Chemical storage area As per SDS requirements: typically chemical gloves and splash goggles minimum

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Employer Obligations: What You Must Do

Obligation What This Means Evidence Required
Select appropriate PPE based on hazard assessment PPE must match the specific hazards identified in your HIRARC, not a generic checklist HIRARC entries specifying PPE by activity and hazard
Provide properly fitted equipment PPE must fit the individual worker. Respirators require fit testing. Fit testing records (respirators), size allocation records
Provide PPE free of charge Section 26: Cannot charge employees for PPE, including replacement costs Procurement records showing company-funded PPE
Train workers on PPE use Training on inspection, donning/doffing, limitations, maintenance, and when to request replacement Training records with dates, content, trainer credentials, attendance signatures
Replace damaged or expired PPE Replacement when damaged, worn, expired, contaminated, or no longer fits properly Replacement request log, disposal records
Ensure compatibility Multiple PPE items must work together (e.g., earmuffs under hard hat, goggles with respirator) Compatibility assessment documented
Enforce PPE use Supervisors must monitor and enforce PPE compliance; non-compliance must be addressed Spot check records, disciplinary records for non-compliance

Employee Duties Under Section 24

Employee Duty Section Penalty
Take reasonable care for own safety and others 24(1)(a) RM 2,000 or 3 months imprisonment
Cooperate with employer on safety requirements 24(1)(b) RM 2,000 or 3 months imprisonment
Wear or use PPE provided at all times 24(1)(c) RM 2,000 or 3 months imprisonment
Comply with safety instructions 24(1)(d) RM 2,000 or 3 months imprisonment
Not to interfere with or misuse safety equipment Section 25 RM 20,000 or 2 years imprisonment

When an employee refuses to wear PPE, the employer must: document the refusal, explain the legal requirement and consequences, remove the worker from hazardous work until they comply, and take disciplinary action per company policies. Never allow hazardous work to proceed without required PPE.

PPE Replacement Schedule

PPE Item Typical Replacement Interval Immediate Replacement Triggers
Safety helmet 2 to 5 years (per manufacturer) Any impact, visible cracks, UV degradation, chinstrap failure
Safety glasses / goggles When damaged or vision-impaired Scratched lenses, broken frames, impact damage
Hearing protection Single-use: per shift. Reusable: per manufacturer Degraded foam, cracked muffs, broken headband
Respirator cartridges Per manufacturer exposure hours or chemical type Breakthrough (smell detected), damage, moisture saturation
Work gloves When worn through or degraded Cuts, holes, loss of grip, chemical contamination
Safety boots 6 to 12 months (heavy use) or per manufacturer Sole separation, exposed steel toe, worn tread, water ingress
Fall arrest harness Per manufacturer (typically 5 years from first use) Any fall arrest event, visible wear on webbing, damaged D-ring or buckle

Common PPE Compliance Failures

Mistake Why It Fails Audit How to Fix
Using non-DOSH-approved PPE Non-compliant regardless of quality or international certification Check MySKUD portal before purchasing. Verify DOSH approval mark on product.
No fit testing for respirators Ill-fitting respirator provides no protection Implement annual fit testing programme for all respirator users.
Charging employees for PPE Violates Section 26. Includes deducting replacement costs from wages. Review payroll practices. Absorb all PPE costs including replacements.
Training happens but is not documented Cannot prove training occurred during DOSH audit Create sign-off sheets for every training session. Keep records minimum 5 years.
No replacement programme Workers using damaged or expired PPE Include PPE replacement in annual budget. Maintain stock of common sizes.
PPE provided but not enforced Workers not wearing PPE despite it being available Train supervisors to monitor and enforce. Implement spot checks with records.
Generic PPE for all tasks One-size-fits-all approach does not match specific hazards Conduct task-specific hazard assessment. Select PPE per activity and hazard type.

Penalty Structure for PPE Non-Compliance

Offence Previous Maximum Current Maximum (Post-June 2024)
Failure to ensure employee safety (Section 15) RM 50,000 RM 500,000 or 2 years imprisonment
General penalty (Section 51) RM 10,000 RM 100,000
Failure to comply with improvement notice RM 50,000 RM 500,000 + RM 2,000/day
Employee not wearing PPE (Section 24) RM 1,000 RM 2,000
Interfering with safety equipment (Section 25) RM 20,000 RM 20,000 or 2 years imprisonment

Personal liability extends to directors, managers, compliance officers, and anyone responsible for management under Section 52. If your factory is prosecuted for PPE failures and you are a director, you face the same penalty personally unless you can prove due diligence.

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Frequently Asked Questions

Is it legal to make employees pay for their own PPE in Malaysia?

No. Section 26 of OSHA 1994 explicitly prohibits charging employees for anything provided under the Act. This includes PPE purchase costs, replacement costs, and maintenance costs. Deducting PPE costs from employee wages is a violation of Section 26.

What PPE is mandatory for all workplaces?

There is no universal list. PPE requirements depend entirely on the hazards identified through your HIRARC assessment. A chemical factory needs different PPE from a data centre. The requirement is that PPE must match the specific hazards workers are exposed to in their tasks.

Can I use imported PPE without DOSH approval?

No. All seven regulated PPE categories must carry DOSH approval and SIRIM QAS certification regardless of the product's country of origin. Even PPE with CE marking, ANSI approval, or other international certifications must still be registered with DOSH. Verify through the MySKUD portal before purchasing.

How often should PPE be replaced?

Follow manufacturer recommendations for scheduled replacement. Safety helmets typically need replacement every 2 to 5 years depending on material and UV exposure. Replace any PPE immediately if it is damaged, fails inspection, reaches expiry date, is contaminated, or no longer fits properly.

What happens if an employee refuses to wear PPE?

Document the refusal. Explain the legal requirement and consequences (RM 2,000 fine for the employee under Section 24). Remove the worker from hazardous work until they comply. Take disciplinary action per company policy. Never allow hazardous work to proceed without required PPE, regardless of the reason for refusal.

Do contractors on my premises need to provide their own PPE?

This should be specified clearly in contracts. Under Section 18A of the amended OSHA, principals have duties toward contractors working under their direction. Many Malaysian factories provide consistent PPE to all workers on their premises to ensure compliance and compatibility. Whoever provides the PPE, it must meet DOSH approval standards.

What records must I keep for PPE compliance?

Training records (dates, content, trainer credentials, attendance signatures), respirator fit testing records, inspection and maintenance logs, replacement and disposal records. Maintain all records for a minimum of 5 years. DOSH inspectors will request these during audits, and they are also needed for insurance claims documentation.

Are there specific PPE requirements for working at height?

Fall arrest equipment is required above 2 metres where other controls are not feasible. This includes full body harness (MS ISO 10333-1 or EN 361), shock-absorbing lanyard or retractable lifeline, and certified anchor points. Workers need specific training on proper use, pre-use inspection, and limitations. Fall clearance calculation is mandatory before any harness work.

How does PPE compliance affect insurance claims?

During workmen compensation and CGL claims, loss adjusters review whether the employer provided and enforced appropriate PPE. Workers injured while not wearing required PPE may still receive compensation, but the employer's negligence in enforcement strengthens additional civil claims. Documented PPE training, provision records, and enforcement evidence protect your position during claims.

What does "as far as practicable" mean for PPE?

Courts consider the severity of the risk, the state of knowledge about the hazard, the availability of suitable control measures, and the cost relative to the risk. PPE is relatively low cost compared to most workplace risks, so the practicability defence rarely applies to PPE provision. DOSH expects PPE to be provided for all identified hazards where higher-level controls do not eliminate the risk entirely.

PPE is the last line of defence, not the first. But when it is needed, it must be the right PPE for the hazard, properly fitted to the worker, maintained in serviceable condition, and enforced through active supervision. The OSHA Amendment 2022 made the consequences of getting this wrong ten times more expensive than before.

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