DOSH Inspection Preparation: The Employer's Checklist

A DOSH inspector can arrive unannounced. Under section 15(1), every employer must ensure, so far as is practicable, the safety, health and welfare at work of all employees — and the inspector has the authority to issue immediate stop-work orders, compound offences, or recommend prosecution.

This checklist covers the 10 most common inspection failure points we see during pre-audit gap assessments.

Naja Safety runs pre-audit gap checks so you know what DOSH will ask before they arrive.

1. HIRARC Register

What inspectors look for: A current Hazard Identification, Risk Assessment, and Risk Control (HIRARC) register that covers all work activities, not just the obvious ones.

Common failure: Outdated HIRARC that does not reflect current processes, or generic templates copied from the internet.

Fix: Update your HIRARC annually or whenever processes change. Include control measures with responsible persons and deadlines.

2. Safety and Health Committee

Mandatory for: 40 or more persons employed, or where the Director General directs.

What inspectors check:

• Committee formation letter (signed by employer)
• Meeting minutes (quarterly minimum)
• Training certificates for committee members
• Inspection reports and action tracking

Common failure: Committee exists on paper but never meets, or members lack certified training. We deliver Safety Committee Training on-site.

3. First-Aiders and Emergency Response

Requirement: Low-risk sites: 1 first-aider for under 20 workers, 2 for 21–150, then 2 for every 150. High-risk sites (e.g. construction, chemical plants): 1 per shift for under 20, then 1 for every 20 workers. Over 400 workers: 2 per 150 plus a registered nurse or medical assistant. Retraining every 3 years. First-aid boxes must be stocked and accessible.

Common failure: First-aider certificates expired. No emergency response drill records. No written emergency procedure posted.

4. Machinery and Equipment Registers

Certain equipment — such as boilers, unfired pressure vessels, passenger lifts and cranes — requires a certificate of fitness. The Factories and Machinery Act 1967, which previously governed this, was repealed on 1 June 2024.

Common failure: Equipment operated without valid certificate of fitness, or annual inspection overdue.

5. Chemical Management (USECHH 2000)

If you handle scheduled chemicals:

• CHRA must be current and site-specific
• Safety Data Sheets (SDS) must be accessible to workers
• Chemical labels must be legible and in Malay/English
• LEV systems must have inspection records

Common failure: SDS stored in an office, not on the shop floor where workers can access them during a spill.

6. Noise Exposure (2019 Regulations)

The excessive noise threshold is 82 dB(A) under the OSH (Noise Exposure) Regulations 2019 [P.U.(A) 60/2019]. If your workplace exceeds this, you need:

• Noise risk assessment by a DOSH-registered assessor, reviewed at least every five years; annual audiometric testing where exposure exceeds the limit
• Hearing conservation programme
• Audiometric testing records
• PPE provision and training records

7. Training Records

Inspectors will ask for evidence that workers have been trained on:

• Safe work procedures for their specific tasks
• Emergency response (fire, chemical spill, evacuation)
• PPE selection, use, and maintenance

Common failure: Generic safety briefing with no attendance signatures or competency verification.

What Happens If You Fail?

• Immediate: Stop-work order, prohibition notice, or improvement notice
• Short-term: Compound (on-the-spot fine) or prosecution
• Corporate: For general duty breaches under ss.15–18A of the amended Act, fines can reach up to RM500,000

Pre-Audit Gap Assessment

We can help you prepare. Our pre-DOSH gap assessments identify compliance gaps before the inspector arrives. We provide a prioritised action plan with timelines, responsibilities, and documentation templates.

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