CHRA and Chemical Safety: Lessons from DOSH Enforcement Cases

Start with a clear chemical register and assessment

Two Perak notices illustrate the importance of basic chemical information. On 14 August 2019, a hotel operator was fined RM3,000 for failing to maintain a chemical register covering chemicals used in maintenance and swimming-pool activities. On 19 August 2019, a tyre-oil operator received fines of RM3,000 for the register and RM2,500 for failing to conduct CHRA.

The lesson extends beyond factories: identify chemicals wherever they are used, retain relevant safety data sheets and ensure the assessment reflects actual work activities.

Connect supplier information with workplace records

A supplier case decided on 4 April 2023 involved classification records for diethylene glycol and ethylene glycol, together with national-language labelling and safety data sheet requirements; the total fine was RM10,000.

A Selangor statement dated 26 October 2023 described six chemical-management offences totalling RM26,000, covering classification, inventory submission, labels, safety data sheets, the workplace register and CHRA. A further case decided on 13 December 2023 resulted in RM33,000 across four offences involving inventory submission, classification records, the register and CHRA. Duplicate posters and statements in the folder refer to the same cases and are combined here.

Follow assessment findings through to control and monitoring

In Perak on 7 August 2019, a manufacturer was fined RM3,500 for failing to carry out the annual examination and testing of a dust-collection control system identified in its CHRA. The work involved cutting, painting and sanding. In Johor on 26 August 2019, another manufacturer was fined RM8,000 for failing to conduct chemical exposure monitoring recommended by its assessment.

A Perak case dated 4 January 2019 also highlighted medical removal protection after an occupational health doctor's recommendation, resulting in a RM4,500 fine. These examples connect the assessment to engineering-control performance, exposure evidence and occupational health follow-up.

Include safe work procedures and workplace oversight

The folder also contains related safety cases beyond CHRA. A metal-cutting explosion on 23 February 2024 caused two worker deaths; the employer was fined RM30,000 on 7 November 2024 for failing to provide a safe system of work.

In another case, decided on 17 February 2025 following an incident on 15 November 2023, nitrogen-tank work was associated with failures in safe work procedures, workplace inspections and safety committee meetings. The combined fines were RM45,000. These notices reinforce the need to translate risk findings into procedures, supervision and regular review.

For official background, refer to DOSH chemical management information.

Source: DOSH/JKKP enforcement notices and supporting materials supplied in the corresponding topic folder. Repeated images of the same case are consolidated. Dates and fines describe the historical cases shown, rather than current maximum penalties.