Site Safety Supervisor Under CDM 2024 Reg 39: What Principal Contractors Must Do
Every principal contractor must appoint a competent site safety supervisor. CDM 2024 made this a standalone duty with its own penalty. Here is what the regulation says, and how to comply.
Since 2024, Malaysia's Occupational Safety and Health (Construction Work Design and Management) Regulations — usually called CDM 2024 — have required every principal contractor to appoint a competent site safety supervisor (SSS). The requirement is not new in spirit, but CDM 2024 made it a specific duty with its own penalty, rather than a general expectation under the OSH Act.
What CDM reg 39 says
"Kontraktor prinsipal kerja pembinaan hendaklah melantik orang yang kompeten yang merupakan penyelia keselamatan tapak untuk membantunya dalam mematuhi kewajipan yang dikenakan ke atasnya oleh atau di bawah Peraturan-Peraturan ini."
CDM 2024 reg 39(1) — DOSH official PDF
Unofficial English summary: The principal contractor of a construction project shall appoint a competent person who is a site safety supervisor to assist him in complying with the obligations imposed on him by or under these Regulations.
Regulation 39(2) adds the penalty: a fine not exceeding RM50,000, imprisonment not exceeding six months, or both, for failure to appoint a site safety supervisor.
Who counts as "competent"?
CDM 2024 does not define "competent" in detail, but DOSH practice requires the SSS to have:
- Relevant construction safety experience (typically at least three years on site).
- Formal safety training (OSH coordinator, NIOSH, or equivalent).
- An understanding of the CDM regulations, hazard identification, and risk control methods.
The SSS does not replace the employer's overall safety duty. The principal contractor remains legally responsible for site safety; the SSS assists in discharging that duty.
What the SSS actually does on site
The SSS role is supervisory and advisory, not a line-management position. Typical responsibilities include:
- Daily site safety inspections and hazard identification.
- Coordinating toolbox talks and safety briefings for subcontractors.
- Ensuring that risk assessments (HIRARC) are in place for high-risk activities.
- Maintaining accident and incident records.
- Liaising with DOSH inspectors when they visit the site.
- Reporting notifiable accidents under NADOPOD 2004.
How Naja Safety helps
Naja Safety does not run SSS certification courses — those are delivered by DOSH-registered training centres. What we do is help principal contractors prepare for the SSS appointment and keep the site compliant once the supervisor is in place:
- We review your project plan and advise on the SSS scope of work.
- We help you draft the SSS appointment letter and define reporting lines.
- We deliver HIRARC, scaffold awareness, working at height, and emergency response training so the SSS has a compliant crew to supervise.
- We conduct safety audits that give the SSS (and you) an independent view of site risks before a DOSH inspection.
Related: Safety Officer & Site Safety Supervisor Supply — Naja arranges an SHO or SSS for your project and confirms who is available.