Safety and Health Officer (SHO) Malaysia: Who Needs One, Qualifications & DOSH Registration

Disclaimer: This article provides general guidance based on OSHA 1994 (Act 514), the OSHA (Amendment) Act 2022, and the OSH (Safety and Health Officer) Regulations 1997. Regulations may be amended. Always verify current requirements with DOSH.

The penalty for failing to appoint a Safety and Health Officer when legally required increased from RM 5,000 to RM 50,000 under the OSHA Amendment 2022. That is a tenfold increase, effective 1 June 2024. But the SHO requirement does not apply to every workplace. It depends on your industry classification and employee count at each site.

This guide covers who must appoint an SHO, the qualification pathways, DOSH Green Book registration, statutory duties, how the SHO role relates to the Safety Committee and the new Safety Coordinator requirement, the complete penalty structure, and what to look for when hiring.

SHO vs Safety Coordinator vs Site Safety Supervisor

Three different safety roles exist under Malaysian law. They have different legal bases, different qualification requirements, and apply to different workplaces. Confusing them is a common compliance error.

Role	Legal Basis	Required For	Qualifications
Safety and Health Officer (SHO)	Section 29 OSHA 1994, SHO Order 1997	Gazetted industries with 100+ employees at a single workplace	DOSH-registered with formal OSH qualifications (Green Book)
Safety and Health Coordinator	Section 29A OSHA (Amendment) 2022	Workplaces with 5+ employees not requiring an SHO	No formal qualification required
Site Safety Supervisor	FMA (BOWEC) Regulations	Construction sites	CIDB-registered, specific construction safety training

If your workplace requires an SHO, you do not need a separate Safety Coordinator. The SHO appointment satisfies the coordinator requirement. But you still need a Safety and Health Committee if you have 40 or more employees. These are independent requirements.

Who Must Appoint a Safety and Health Officer

The SHO Order 1997 specifies industry classes and employee thresholds. The requirement applies per workplace, not per company. A company with 80 employees at one factory and 80 at another does not need an SHO at either site if each is below the threshold.

Gazetted Industry Class	Employee Threshold
Manufacturing	100 or more at a single workplace
Mining and quarrying	100 or more
Construction	100 or more
Agriculture, forestry, and fishing	100 or more
Utilities (electricity, gas, water)	100 or more
Transport, storage, and communication	100 or more
Wholesale and retail trade	100 or more
Hotels and restaurants	100 or more
Finance, insurance, real estate, business services	100 or more

How to Count Employees

Include permanent employees, contract workers who work regularly on site, and temporary staff. Exclude workers at other locations. The count applies per workplace, not company-wide.

Which Safety Role Does Your Workplace Need?

Workforce Size	SHO?	Coordinator?	Committee?
Under 5 employees	No	No	No
5 to 39 employees	No	Yes	No
40 to 99 employees	No	Yes	Yes
100+ employees (gazetted industry)	Yes	No (SHO satisfies)	Yes
100+ employees (non-gazetted industry)	No	Yes	Yes

Qualification Pathways to Become an SHO

Pathway 1: DOSH-Recognised Diploma or Degree

Requirement	Details
Qualification	Diploma or Degree in Occupational Safety and Health from a DOSH-recognised institution
Experience	Not specified. Fresh graduates are eligible.
Additional training	None required beyond the recognised programme
Outcome	Direct eligibility for Green Book registration
Time to qualify	3 to 4 years (diploma or degree duration)
Typical cost	RM 30,000 to RM 80,000

Pathway 2: NIOSH SHO Course Plus Experience

Requirement	Details
Entry qualification	SPM/SPMV/MCE minimum Grade 3 in Bahasa Malaysia, English, and Mathematics; or STPM (Science); or any Diploma/Degree
Training	176-hour NIOSH SHO course (covers OSHA 1994, hazard identification, accident investigation, OSH management)
Examination	Pass NIOSH SHO examination
Experience	Minimum 3 years in OSH-related work
Verification	Interview and verification by DOSH
Outcome	Eligibility for Green Book registration after experience requirement met
Typical cost	RM 3,000 to RM 5,000 for the course

For career changers with existing qualifications in other fields, the NIOSH pathway offers a faster route to SHO registration if you can accumulate the required 3 years of OSH experience.

DOSH Registration: The Green Book

No person may legally function as an SHO without DOSH registration. The registration is documented through the "Green Book" which must be valid and current.

Registration Aspect	Details
Initial validity	3 years from registration date
Renewal requirement	Evidence of continuing education and training in the 3 years since last registration
Grounds for refusal	Failure to demonstrate continuing education in the past 3 years
Grounds for cancellation	Misconduct, breach of regulations, failure to perform statutory duties
Application submission	DOSH state office or Putrajaya headquarters with qualification certificates, experience evidence, training records

Start the renewal process at least 3 months before expiry. DOSH can refuse renewal if you cannot demonstrate continuing education. Plan annual OSH training throughout the 3-year period to ensure you have adequate evidence at renewal time.

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Statutory Duties of an SHO

The SHO role carries specific duties under Regulation 18 of the SHO Regulations 1997. These are not suggestions. They are statutory requirements that DOSH inspectors verify during workplace audits.

Duty	What This Involves
Advise employer on OSH measures	Recommend improvements to workplace safety and health practices
Ensure employer awareness	Keep employer informed of OSH requirements and regulatory changes
Plan and implement OSH programmes	Safety campaigns, hazard awareness programmes, safety culture initiatives
Inspect the workplace	Regular inspections to identify hazards and verify that controls are in place
Investigate accidents and incidents	Examine causes of accidents, near-misses, and occupational diseases
Report findings	Document and report inspection and investigation results to management
Collect and analyse safety data	Track accident statistics, trends, leading indicators
Conduct OSH training	Deliver or arrange safety training for employees at all levels
Assist with audits	Support internal and external OSH audits, prepare documentation
Be present during emergencies	Attend to emergency situations and coordinate emergency response

Monthly Reporting Requirement

Under Regulation 19, the SHO must submit a monthly report to the employer by the 10th day of each month covering: actions taken to comply with OSHA 1994, measures to maintain a safe workplace, accident and incident statistics, training conducted, and outstanding safety issues with recommendations.

This monthly reporting requirement creates an audit trail of OSH activities. Many employers miss this requirement, leaving themselves exposed during DOSH inspections when inspectors ask for evidence of systematic safety management.

SHO Exclusivity Requirement

Section 29(3) of OSHA 1994 requires the SHO to be employed "solely" to ensure compliance and promote safety. In practice, SHOs in smaller organisations often handle related functions such as environmental management or quality assurance. However, OSH duties must be the primary responsibility and must not be treated as a secondary add-on to another role.

SHO and the Safety Committee

If both an SHO and a Safety Committee exist at the workplace, the SHO automatically becomes the committee secretary under Regulation 6(2) of the Safety and Health Committee Regulations 1996.

SHO Function in Committee	Responsibilities
Meeting preparation	Prepare agenda, arrange logistics, distribute materials before meeting
Meeting documentation	Record minutes, document decisions, circulate within 7 days
Action follow-up	Track implementation of committee recommendations, report progress
Workplace inspections	Lead or participate in committee workplace inspections
Investigation reports	Prepare accident investigation reports for committee discussion
Information provision	Ensure committee has access to relevant OSH documents, statistics, and regulatory updates

Penalties for SHO Non-Compliance

Offence	Maximum Fine	Maximum Imprisonment
Failure to appoint SHO when required	RM 50,000 (increased from RM 5,000)	6 months
Acting as SHO without DOSH registration	RM 50,000	6 months
Failure to comply with SHO duties	RM 50,000	6 months
General employer duty breach (Section 15)	RM 500,000	2 years
Failure to comply with DOSH improvement notice	RM 500,000 + RM 2,000/day	2 years

Under Section 52, directors and managers face personal prosecution for company offences. If your factory is required to have an SHO and does not, the directors are personally liable unless they can prove due diligence. More on personal liability in our OSHA 1994 penalties guide.

Common Mistakes and How to Avoid Them

Mistake	Consequence	Prevention
Appointing an unregistered person as SHO	RM 50,000 fine. The person and the employer are both liable.	Verify Green Book before appointment. Request DOSH registration copy.
SHO has other primary duties with safety as secondary	DOSH may not accept the appointment as compliant	Ensure OSH is the SHO's primary job function, not an afterthought
Not replacing SHO when they leave the company	Non-compliance from the day the SHO departs	Have a succession plan. Notify DOSH of the change. Arrange interim coverage.
SHO registration allowed to lapse	Person cannot legally act as SHO. Employer is non-compliant.	Calendar reminders 6 months before expiry. Plan continuing education early.
No monthly reports from SHO	No audit trail. DOSH finding during inspection.	Use a monthly report template. Calendar reminder for the 10th of each month.
SHO not present at the workplace	Defeats the purpose of the appointment	Ensure adequate on-site coverage. SHO must be available during operations.

Hiring an SHO: What Employers Should Look For

Criterion	How to Verify
Valid DOSH registration (Green Book)	Request copy and verify registration number with DOSH
Relevant industry experience	Employment history, reference checks with previous employers
Knowledge of your specific hazards	Interview questions, site walkthrough, technical discussion
Communication skills	Can they explain risks clearly to both workers and management?
Independence	Will they raise uncomfortable issues when safety is compromised?

SHO Salary Expectations in Malaysia

Experience Level	Typical Monthly Range (RM)
Entry level (new Green Book)	3,500 to 5,000
Mid-level (3 to 5 years)	5,000 to 8,000
Senior (10+ years)	8,000 to 15,000
Specialist industries (oil and gas, petrochemical)	12,000 to 25,000+

These are indicative ranges. Actual salaries depend on location, company size, industry risk profile, and specific role requirements.

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Frequently Asked Questions

What is the difference between an SHO and a Safety Coordinator?

An SHO is a DOSH-registered professional with formal qualifications, required in gazetted industries with 100 or more employees. A Safety Coordinator handles basic OSH coordination in workplaces with 5 or more employees that do not require an SHO. The SHO has more extensive duties, requires DOSH registration, and must hold formal OSH qualifications.

Can one SHO cover multiple sites?

The regulations require the SHO to be employed at "the place of work." If you have multiple sites each meeting the SHO threshold, each site technically needs its own SHO. One person covering multiple large sites dilutes effectiveness and may not satisfy the "solely employed" requirement under Section 29(3).

How long does it take to become a registered SHO?

Through the degree pathway: 3 to 4 years of study. Through NIOSH: the 176-hour course takes several weeks, but you then need 3 years of OSH experience before Green Book registration. Allow 4 to 6 years total from starting the NIOSH pathway to receiving the Green Book.

What happens if my SHO resigns?

You must appoint a replacement with valid DOSH registration. From the day the SHO departs until a replacement starts, you are technically non-compliant. Maintain relationships with OSH consultancies that can provide interim SHO coverage on a contract basis while you recruit a permanent replacement.

Can an SHO be outsourced?

The regulations require the SHO to be employed at the workplace. A consultant visiting periodically does not meet this requirement. Some companies use contract SHOs on full-time secondment, which may satisfy the requirement depending on the arrangement. Clarify with your state DOSH office if uncertain about your specific arrangement.

Do I need both an SHO and a Safety Committee?

Possibly. SHO appointment depends on industry classification and employee count. Committee formation depends on having 40 or more employees regardless of industry. A manufacturing plant with 150 employees needs both. An office with 50 employees needs a committee but not an SHO (though they need a Safety Coordinator under the 2022 amendments).

What qualifications count as continuing education for renewal?

DOSH accepts relevant OSH training, seminars, conferences, and workshops attended during the 3-year registration period. Keep certificates from all safety-related training. NIOSH and DOSH-organised programmes are accepted. Industry conferences with OSH content also count. Plan training throughout the period rather than cramming before renewal.

Can the SHO refuse to sign off on unsafe work?

The SHO's role is to advise the employer and ensure compliance. While they cannot unilaterally stop operations, they can refuse to falsify records, document their objections formally, escalate to the Safety Committee, and report to DOSH if the employer ignores serious hazards. Whistleblower protections under the amended OSHA provide some protection for SHOs who raise genuine safety concerns.

Is the SHO personally liable for workplace accidents?

The SHO can face personal liability if they fail to perform their statutory duties and this failure contributes to an incident. However, the primary duty holder is the employer. An SHO who documents hazards, makes recommendations, follows up on implementation, and maintains proper records has a strong due diligence defence. An SHO who ignores obvious hazards or falsifies inspection records does not.

What is the Green Book renewal process?

Submit the renewal application to DOSH before your registration expires, with evidence of continuing education and training in the 3 years since last registration. DOSH reviews and issues renewed registration for another 3 years. Start the renewal process at least 3 months before expiry to avoid gaps in registration that create compliance exposure.

A registered Safety and Health Officer brings professional expertise to managing workplace risks. The cost of appointing an SHO is far less than the cost of a serious accident, in terms of both human impact and the fines, compensation, and operational disruption that follow.

The RM 50,000 penalty for non-appointment reflects regulatory recognition that qualified safety oversight matters. But the real value of an SHO is not avoiding fines. It is the incidents that never happen because a competent professional was actively managing risks. For manufacturing plants, construction sites, and industrial operations in gazetted industries, getting the right person with valid registration is the first step. Giving them the authority and resources to do their job properly is what makes the real difference.