10.5 Personal Protective Equipment and Site Emergency Response
Key Takeaways
Section 24(1)(c) of OSHA 1994 requires every employee to wear or use at all times any protective equipment or clothing the employer provides to prevent risks; breach carries a fine of up to RM2,000, three months' imprisonment, or both.
Section 26 of OSHA 1994 forbids an employer to charge employees for anything done or provided under the Act or its regulations, including required PPE.
PPE is the last line of defence in DOSH's HIRARC 2008 hierarchy, and USECHH regulation 16 allows approved PPE only where other controls are impracticable, as an interim measure, or as a top-up.
CDM 2024 regulation 32 requires the construction work contractor to set up arrangements for foreseeable emergencies, including evacuation, make sure everyone is familiar with them, and test them at suitable intervals.
CDM 2024 regulation 33 requires enough emergency routes and exits leading to an identified safe area, marked with suitable signs, kept clear, and lit with emergency lighting where necessary.
PPE and the law
| Provision | What it says |
|---|---|
| OSHA section 15 | The employer's general duty includes safe systems of work and the information, instruction, training and supervision needed for safety. Providing suitable PPE where risks remain is part of this duty. |
| OSHA section 24(1)(c) | Every employee must wear or use at all times any protective equipment or clothing the employer provides to prevent risks. Penalty under section 24(2): up to RM2,000, three months, or both. |
| OSHA section 25 | Anyone who intentionally, recklessly or negligently interferes with or misuses anything provided for safety, such as removing guardrails or damaging harnesses, commits an offence: up to RM20,000, two years, or both. |
| OSHA section 26 | The employer must not charge employees for anything done or provided under the Act or regulations. Deducting the cost of required safety boots or helmets from wages is unlawful. |
| USECHH 2000 regulation 16 | Approved PPE is used only where other controls are impracticable, as an interim measure, or as a top-up. It must be suitable, fitted, issued, maintained and explained. |
| Noise Exposure Regulations 2019 regulation 7 | Hearing protectors must be suitable, maintained, available, give enough attenuation, and be approved by the Director General. |
| Confined space ICOP 2010 | Harnesses, retrieval lines and breathing apparatus for entry and rescue (Section 9.3). |
PPE in the hierarchy of control
HIRARC 2008 places PPE last, after elimination, substitution, engineering and administrative controls. The reasons:
- PPE protects only the wearer, and only when worn correctly.
- When it fails, for example through a poor fit, wrong filter or damaged lanyard, the worker is fully exposed, often without knowing it.
- It depends on behaviour, comfort and supervision every day.
- It can create new hazards: heat stress in impermeable suits, restricted vision from goggles, or isolation from warnings when wearing earmuffs.
In an exam answer or a HIRARC table, list PPE after higher-level controls, and say what type of PPE, not just "wear PPE".
Selecting construction PPE
| Hazard | PPE | Selection points |
|---|---|---|
| Falling objects, head impact | Safety helmet | Industrial safety helmet to a recognised standard (for example EN 397); chin strap at height or in wind; colour codes per site rules |
| Foot injury, nails, wet concrete | Safety footwear | Protective toe caps (EN ISO 20345 safety footwear has toe caps tested to 200 J); midsole penetration protection; Wellington boots for concreting |
| Being struck by vehicles | High-visibility clothing | Fluorescent background with retroreflective bands (EN ISO 20471 classes 1–3); class chosen for traffic speed and conditions |
| Flying particles, splashes, UV | Eye and face protection | Safety glasses for impact; goggles for dust and chemical splash; face shields for grinding; welding filters of the correct shade (Section 9.2) |
| Noise | Hearing protectors | DG-approved earplugs or earmuffs giving enough attenuation; compatible with helmets |
| Dust, fume, vapour, low oxygen | Respiratory protective equipment (RPE) | Chosen from the CHRA. Filtering facepieces (FFP2 or FFP3) for dusts such as silica; cartridge respirators for vapours; supplied-air or self-contained breathing apparatus for oxygen-deficient or IDLH atmospheres |
| Cuts, abrasion, chemicals, vibration | Gloves | Matched to the hazard: cut-resistant for steel and glass, chemical-resistant for solvents and cement, insulated for live electrical work by competent persons |
| Falls from height | Personal fall protection | Full-body harness, energy-absorbing lanyard or retractable device, anchor point and rescue plan (Section 4.3) |
| Drowning | Life jacket or buoyancy aid | Work over or next to water, such as bridge, marine and river works |
| Sun and heat | Sun protection | Helmet neck flaps, long sleeves, UV-filtering glasses (Section 10.1) |
Respirators only work if they seal. Tight-fitting respirators need a face-fit test and a clean-shaven seal area, and the wearer does a fit check each time they put one on. A dust mask does nothing against gases or low oxygen.
Making PPE work
- Assess the residual risk and specify PPE in the HIRARC, method statement and permit.
- Select suitable equipment: hazard, standard, size and fit, comfort in Malaysian heat, and compatibility (helmet with earmuffs, glasses with a respirator).
- Issue PPE free of charge (section 26), in enough sizes, and replace it when worn or damaged.
- Train workers in why it is needed, how to wear it, its limits, and how to check, clean and store it, in languages they understand.
- Inspect and maintain. Look at helmets for cracks, UV brittleness and impact damage; harnesses and lanyards for cuts, burns and deployed shock absorbers; and respirator filters for expiry. Remove damaged items from use. Follow the manufacturer's service life.
- Store PPE clean, dry and out of sunlight.
- Supervise and enforce. Make PPE mandatory in the site rules, check it at the gate and at work fronts, and correct people who do not wear it. Managers must set the example.
- Record issue, inspection, fit testing and training.
Emergency arrangements under CDM 2024
Regulation 32 (emergency procedures): where necessary for the safety or health of anyone on site, the construction work contractor must provide, maintain and implement suitable and sufficient arrangements for any foreseeable emergency, including evacuation of the site or any part of it. The arrangements take account of:
- (a) the type of work on site
- (b) the characteristics and size of the site, and the number and location of workplaces
- (c) the plant used
- (d) the number of people likely to be present
- (e) the physical and chemical properties of substances present or likely to be present
The contractor must make sure everyone covered is familiar with the arrangements, and that the arrangements are tested by being carried out at suitable intervals.
Regulation 33 (emergency routes and exits): provide enough suitable emergency routes and exits for people to reach a place of safety quickly. They must:
- lead as directly as possible to an identified safe area
- be marked with suitable signs
- be kept clear and free of obstruction, together with the traffic routes leading to them
- have emergency lighting where necessary
Breaching either regulation carries a fine of up to RM500,000, one year, or both.
Building a site emergency response plan
| Element | Content |
|---|---|
| Foreseeable emergencies | Fire, structural or scaffold collapse, crane failure, trench collapse, confined space incident, electrocution, fall or a worker suspended in a harness, chemical spill or gas leak, flood and storm, heat stroke and other medical emergencies |
| Alarm | How the alarm is raised and heard across the site, including noisy areas and upper floors |
| Roles | Emergency coordinator, wardens for each zone, first-aiders, trained rescue teams for height and confined space work, and someone to meet the emergency services at the gate |
| Contacts | 999 for police, ambulance and fire and rescue; the nearest hospital and its route; the principal contractor, utilities and DOSH |
| Routes and assembly | Escape routes from every floor and basement; assembly points away from crane and collapse zones; ways to count people using attendance records |
| Access | A clear route for ambulances and fire engines; gate keys; site maps at the guardhouse |
| Equipment | Fire extinguishers, first-aid boxes and stretchers, rescue kits for harness and confined space work, spill kits, emergency lighting |
| Drills and review | Regular evacuation drills and rescue exercises (regulation 32(3)), recorded and reviewed after each drill, incident and change of site layout |
| After the event | Care of casualties; preserving the scene; notifying DOSH under NADOPOD 2004 (Section 2.5); investigating |
First response to a casualty
First-aiders are trained on DOSH-recognised courses (Section 3.2). Every supervisor should know the basic sequence taught in first-aid courses, often summarised as DRSABCD:
- Danger: make the area safe for yourself, others and the casualty. Isolate electricity before touching someone in contact with a live conductor. Never enter a confined space to rescue without breathing apparatus and training.
- Response: check whether the casualty responds.
- Send for help: call 999 and the site first-aider, and tell the gate to guide the ambulance in.
- Airway: open the airway.
- Breathing: check for normal breathing.
- CPR: if the casualty is not breathing normally, start chest compressions and rescue breaths (30:2 for adults).
- Defibrillation: use an AED as soon as one is available.
Other points:
- Severe bleeding: apply firm direct pressure.
- Suspected spinal injury after a fall: do not move the casualty unless they are in danger.
- Burns: cool under clean running water straight away, for 20 minutes where possible.
- Chemical or cement in the eyes: rinse with clean water for as long as the SDS advises (typically at least 15 minutes) and seek medical help.
- Heat stroke: cool the casualty rapidly (Section 10.1).
- Suspended worker: rescue them quickly (Section 4.3).
Scenario: the gate check
At the morning gate check, the SSS finds:
- a new labour gang with helmets but no chin straps, about to work on the roof edge
- two workers in cotton face masks about to cut concrete blocks with a dry saw
- the subcontractor deducting RM40 from each worker's wages for safety boots
The SSS:
- Requires chin straps for work at height, and checks the roof's edge protection and the gang's rescue plan.
- Stops the dry cutting. The CHRA requires a wet-cut or extraction saw, plus FFP3 respirators that have been fit tested.
- Tells the subcontractor that section 26 forbids charging for PPE required under the Act, and has the deductions refunded.
- Adds the gang to the next induction, including the evacuation route and assembly point, and the next drill under regulation 32(3).
What does section 24(1)(c) of OSHA 1994 require of an employee in relation to protective equipment?
To wear or use at all times any PPE the employer provides to prevent risks
To buy their own PPE where the employer does not supply suitable equipment
To wear PPE only when the safety officer is on site
To decide whether the PPE is needed for each task
A subcontractor deducts the cost of required safety boots from workers' wages. Which provision of OSHA 1994 does this breach?
Section 24, the general duties of employees to cooperate with the employer
Section 27, which protects employees from victimisation for raising complaints
Section 26, the duty not to charge employees for things provided under the Act
Section 18B, the duty to carry out risk assessment
Under CDM 2024 regulation 33, which requirement applies to a construction site's emergency routes and exits?
Be approved in writing by the Fire and Rescue Department before use
Lead directly to an identified safe area, be signed and kept clear
Be provided only on sites with more than 150 workers
Be kept locked during working hours to stop unauthorised entry
Sections you finish are checked off in the contents.