First Aid Kit Requirements in Malaysia: Workplace Compliance Guide (2026)

A first aid kit is the most universally present piece of safety equipment in Malaysian workplaces, and one of the most frequently non-compliant. A box that is physically present but stocked with the wrong items, that has not been replenished since it was last used, or that workers cannot locate during an actual emergency does not meet the legal requirement, regardless of how it looks during a routine walkthrough.

The legal basis for workplace first aid in Malaysia is often misquoted, including in earlier guidance published on this site. There is no standalone “First Aid Regulations 2004.” The obligation comes from Section 25 of the Factories and Machinery Act 1967 and Regulation 38 of the Factories and Machinery (Safety, Health and Welfare) Regulations 1970, read together with the general welfare duty in Section 15(1) of the Occupational Safety and Health Act 1994 (OSHA 1994). The Department of Occupational Safety and Health (DOSH) then translates those legal provisions into practical detail through its Guidelines on First-Aid in the Workplace, a technical guidance document, not a regulation in its own right, though DOSH inspectors use it as the working reference during inspections.

This guide sets out what the law and DOSH guidance actually require: how many first aiders you need, what has to be in the box, when a dedicated first aid room becomes mandatory, how records must be kept, and where the regulatory minimum falls short of what specific hazard environments actually need.

Why First Aid Provision Fails Compliance More Often Than Other Safety Equipment

First aid kits fail inspection for reasons that have nothing to do with the initial purchase. A kit bought correctly on day one degrades through ordinary use: dressings get used and not replaced, gloves run out, saline expires quietly on a shelf, and the person originally assigned to check the box changes roles without a handover. Because the kit is rarely opened outside of an actual injury, these gaps go unnoticed until the moment they matter most, or until a DOSH inspection finds an empty compartment where a sterile dressing should be.

The second common failure is treating the regulatory minimum as the ceiling rather than the floor. The content list prescribed by DOSH guidance is written for general wound care across a generic workplace. A chemical plant, a construction site, and an office do not have the same injury profile, and a kit that satisfies the letter of the guideline can still leave a workforce under-prepared for the injuries its actual hazards are most likely to produce.

The Legal Framework for Workplace First Aid in Malaysia

Factories and Machinery Act 1967 and the Safety, Health and Welfare Regulations 1970

Section 25 of the Factories and Machinery Act 1967 (Act 139) and Regulation 38 of the Factories and Machinery (Safety, Health and Welfare) Regulations 1970 set out the occupier’s core first aid obligations for factory workplaces: providing and maintaining a first aid box or cupboard to the prescribed standard and ensuring it is readily accessible at all times; assigning responsibility for the box to a named responsible person, who must be proficient in first aid treatment if the factory employs more than 20 people; and providing and maintaining a dedicated first aid room where more than 150 people are employed. The Factories and Machinery (Repeal) Act 2022 took effect on 1 June 2024, but its subsidiary regulations, including the 1970 Safety, Health and Welfare Regulations, remain in force pending replacement OSHA subsidiary legislation, and DOSH continues to apply them as the operative standard.

Occupational Safety and Health Act 1994

Section 15(1) of OSHA 1994 requires every employer and self-employed person to ensure, so far as is practicable, the safety, health and welfare at work of their employees. First aid provision sits under the welfare component of this general duty, which is why OSHA 1994 is the applicable legal basis for workplaces outside the factory definition, including offices, warehouses, retail premises, and service businesses that the 1970 Regulations do not directly cover. Following the Occupational Safety and Health (Amendment) Act 2022, which came into force on 1 June 2024, penalties for breaching the general duty, including inadequate first aid provision, rose to a maximum fine of RM500,000, imprisonment of up to two years, or both.

The DOSH Guidelines on First-Aid in the Workplace

DOSH’s Guidelines on First-Aid in the Workplace (2nd Edition, 2004, reference JKKP: GP(I) 06/2004) is the practical reference that translates the legal provisions above into specific numbers: how many first aiders per workforce size, what the first aid box should contain, when a first aid room is required, and how records should be kept. It is a guideline rather than a standalone regulation, but DOSH inspectors apply it directly during workplace inspections, and most of the specific figures employers rely on for compliance planning, including the tables in this guide, come from this document rather than from the Act or Regulations themselves.

USECHH Regulations 2000 and Chemical-Specific First Aid Information

Where a workplace uses chemicals classified as hazardous to health, the Use and Standards of Exposure of Chemicals Hazardous to Health (USECHH) Regulations 2000 require the current Chemical Safety Data Sheet (CSDS) for each such chemical to be kept in a conspicuous, accessible location close to where it is used. DOSH’s first aid guideline explicitly cross-references this requirement and recommends that first aiders working with hazardous chemicals receive specific training in decontamination and chemical poisoning management, beyond the standard first aid course.

Multi-Employer Worksites

On a worksite where employees of different employers work together, such as a construction site with multiple subcontractors, OSHA 1994 places the duty to provide adequate first aid provision on the principal employer. The relevant employers may instead agree in writing that one of them will provide the first aiders, boxes, room and equipment on behalf of all parties, provided the agreement is documented and a copy is kept by each employer involved. An informal understanding that “someone else will handle first aid” is not sufficient; DOSH expects a written arrangement.

The Four Components of Workplace First Aid

DOSH’s guideline frames workplace first aid around four components that should be planned together, not purchased in isolation: the first aider (the trained person), the first aid box (portable, immediate-response equipment), the first aid room (a dedicated space required above a certain workforce size), and first aid equipment more broadly, such as stretchers and oxygen where relevant. When deciding how much of each to provide, DOSH directs employers to weigh four factors: the type of industry, the number of workers, the number of shifts, and the location of the workplace relative to the nearest clinic or hospital. A remote site with a two-hour transfer time to the nearest hospital needs more first aid capability than an identical headcount in a city with a clinic next door, even though both might satisfy the same box-count formula.

How Many First Aiders Do You Need?

DOSH’s guideline sets out first aider numbers by hazard category, not a flat ratio applied to every workplace. This table reproduces the guideline’s general guide in full, since most secondary sources online simplify it into a single ratio that does not match what DOSH actually specifies.

Workplace Category

Notice the gap between the low-risk and high-risk columns: a 40-person office needs 2 first aiders, while a 40-person construction site or chemical plant needs 2 as well under the “1 per 20” rule, but a 100-person high-risk site needs 5 first aiders against just 2 for an equivalent low-risk office. Classifying your workplace correctly against this table, rather than defaulting to the low-risk column because it produces a smaller number, is the first place many employers under-provide.

Shift Work Coverage

Where a workplace operates a shift schedule, the first aider numbers above apply to every shift independently, not to the total workforce across a 24-hour period. A factory with sufficient first aiders on the day shift but none on the night shift is non-compliant during every hour the night shift operates unsupervised.

Selecting and Training First Aiders

DOSH recommends selecting candidates for first aid training who are physically fit, free from blood-borne infectious diseases such as Hepatitis B or HIV, and able to leave their normal duties immediately to respond to an emergency. Recognised training providers include institutions under the Ministry of Health, hospitals under the Ministry of Education, the National Institute of Occupational Safety and Health (NIOSH), the Malaysian Society for Traumatology and Emergency Medicine (MASTEM), the Malaysian Red Crescent Society, St John Ambulance Malaysia, and any organisation whose trainers were themselves trained by one of these bodies and approved by the DOSH Director General.

The standard course covers two parts: basic life support (the chain of survival, CPR technique, airway obstruction management, and recovery position) and first aid proper (patient assessment, spinal injury management, shock management, fracture management, and wound care), with theory and practical assessment at the end of each part. Refresher training on a recognised course is required once every three years, and the employer must keep a record of each first aider’s original training date and every subsequent refresher.

First Aid Box: Design, Location and Contents

Design and Placement

A compliant first aid box must be made of sturdy, portable material so it can be carried to the site of an incident rather than requiring the casualty to be brought to it, and must be clearly marked and placed in a well-illuminated, identifiable, accessible location. Where a workplace covers a large area, DOSH expects multiple boxes distributed so that every work area has reasonable access, and multi-storey premises need at least one box per floor. The box should be kept secured, with the key held by the responsible person and available throughout all working hours under Regulation 38(iii) of the 1970 Regulations, and every employee should be told where each box is located, not left to find out during an emergency.

Recommended Contents of a First Aid Box

DOSH’s guideline (Appendix 4) sets out the recommended contents for a standard workplace first aid box. This is the list DOSH inspectors reference, and it is worth stocking exactly rather than an approximation of it.

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What Must Never Go in a First Aid Box

DOSH guidance is explicit that a first aid box should not contain oral medication of any kind beyond what is strictly required for first aid treatment itself. Painkillers, antibiotics, and medicated creams are not first aid box contents; a worker who needs medication should be referred to a doctor or clinic, not self-treated from the workplace kit.

Signage

First aid box and first aid room locations should be identifiable at a glance. Malaysian workplaces generally use the MS ISO 7010 E003 symbol, a white cross on a green background, which should be visible from the approach to the location and, where lighting may be poor during an emergency, backed by illuminated or photoluminescent signage.

First Aid Room Requirements

A dedicated first aid room is required under DOSH’s guideline where more than 150 people are employed at the workplace. Some secondary sources, including the earlier version of this article, cite a 100-worker threshold; the current DOSH guideline document itself states 150, and that is the figure used here. If your existing safety documentation references 100 workers, it is worth checking which figure your DOSH area office is currently applying and updating your internal threshold accordingly, since erring toward the more conservative 100-worker trigger is not a compliance risk, only erring the other way is.

Design and Location

The room needs to be large enough for a couch plus room to move around it, fitted with emergency lighting, floors and ceilings in materials that do not collect dust and are easy to clean, non-slip flooring, and privacy (obscured windows where necessary) with a comfortable temperature and humidity. When choosing where to site it, DOSH directs attention to proximity to a shower for cleaning or decontamination, proximity to lifts and passageways wide enough for a stretcher or wheelchair, accessibility from work areas, and accessibility from the car park so an injured person can be transferred to an ambulance without delay.

Recommended First Aid Room Facilities

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A first aid room that has been repurposed as overflow storage, a prayer room, or a break area during quiet periods is a common finding during DOSH inspections. The room must be usable for its intended purpose at the moment it is needed, which means it cannot be treated as flexible space.

Record-Keeping: Treatment Records and Retention

Every casualty treated by a first aider should be logged, covering the immediate treatment given, details of the incident and the work process involved, the nature of the injury or illness, any referral made (ambulance, clinic, hospital), and the subsequent management of the case. If the incident involved a chemical, the relevant CSDS should be attached to the record. The employer must retain these records for five years. Beyond satisfying DOSH, this record is often the only contemporaneous evidence available if a seemingly minor injury develops into a longer-term claim months or years later.

Workplace-Specific First Aid Provision Beyond the Minimum

The DOSH-prescribed box and the standard first aider ratios are a regulatory floor written for general wound care. Malaysian workplaces with specific hazard profiles need to build on top of that floor, not stop at it.

Environment

Special First Aid Requirements

DOSH’s guideline also covers scenarios that fall outside routine day-to-day first aid. Workplaces with a potential for mass casualties should pre-position equipment such as stretchers, wheelchairs, sheets and blankets, and plan a safe evacuation and treatment area in advance rather than improvising one during an actual incident. Where a first aider might be exposed to blood or body fluids while treating a casualty, protective clothing and equipment should be provided, properly stored, and checked regularly, and DOSH specifically recommends Hepatitis B immunisation for first aiders as a precaution. Universal Precautions, treating all blood and body fluids as potentially infectious, should be applied by default, and any surfaces or skin contaminated during treatment should be washed with soap and water and disinfected as soon as possible afterward.

Common Mistakes in Workplace First Aid Programmes

• Classifying a high-risk workplace under the low-risk first aider table. A construction site or chemical plant assessed as “office-equivalent” risk will be significantly under-resourced on first aiders.
• No first aider on the night or weekend shift. The ratio requirement applies per shift, not as a daily average.
• First aid room used for storage or breaks. DOSH inspectors check whether the room is actually available for first aid at the moment of inspection.
• Expired consumables left in the box. Saline, sterile dressings and other consumables carry use-by dates that need active tracking, not a once-a-year glance.
• First aid certificates lapsing unnoticed. The three-year refresher requirement is easy to miss without a tracked renewal date per first aider.
• Locked box with no accessible key. Regulation 38(iii) requires the key to be held by a responsible person available throughout working hours, not left in an office that is empty during the relevant shift.
• Treating the standard box as sufficient for the actual hazard. A chemical site, an electrical hazard site, or a working-at-heights site needs additional provision beyond the generic DOSH content list.
• No written agreement on a multi-employer site. Assuming another contractor is “handling first aid” without a documented agreement leaves the principal employer exposed if nobody actually is.

First Aid Provision by Industry

Industry

Choosing a First Aid and Emergency Response Supplier in Malaysia

When sourcing first aid kits and related emergency equipment for a Malaysian workplace, it is worth confirming a few things with your supplier before ordering: that the box contents match the DOSH-recommended list rather than a generic import, that hazard-specific add-ons (burn dressings, spinal immobilisation, chemical decontamination items) are available rather than only the base box, that individual item replenishment is available so a used dressing does not require buying a whole new kit, and that the supplier can advise on eyewash and shower provision where chemical handling is involved, since this equipment has its own placement and flow-rate requirements that a first aid box supplier does not always understand.

Haisar’s Emergency Response Support in Malaysia

Haisar Supply and Services supplies emergency response and first aid-adjacent equipment for workplaces and project sites across Johor and peninsular Malaysia, with particular depth in eyewash stations, emergency showers, and spill containment equipment, including portable and plumbed eyewash units, wall- and floor-mounted combination eyewash and shower stations, and oil, chemical and universal spill kits across multiple volumes. For chemical handling areas specifically, this range covers the eyewash and decontamination provision that a standard first aid box cannot, and pairs directly with the guidance in this article on 10-second eyewash access and CSDS placement.

If your requirement includes DOSH-content first aid boxes, first aid room fit-out, or AED units, our team can source and quote these alongside our existing emergency response range as part of a combined project list. Sharing your workforce size, hazard classification (low or high risk under the DOSH table above), and site layout lets us help you specify the right mix of boxes, room equipment, and eyewash/shower provision rather than a generic quote.

A workplace building out its first aid and emergency response programme typically also needs to review safety signage for first aid box and room locations, fire safety equipment where burns and evacuation overlap with first aid planning, and fall protection equipment on sites where spinal and trauma first aid provision is a specific concern. Facilities with electrical hazard exposure should also see our guide to electrical safety PPE, since AED provision and electrical PPE programmes are typically planned together.

First Aid Compliance Checklist

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Frequently Asked Questions

Is there really an “Occupational Safety and Health (First Aid) Regulations 2004” in Malaysia?

No. This is a common misstatement, including in earlier versions of this article. The 2004 document is DOSH’s Guidelines on First-Aid in the Workplace (2nd Edition), a technical guideline, not a standalone regulation. The binding legal obligations come from Section 25 of the Factories and Machinery Act 1967, Regulation 38 of the Factories and Machinery (Safety, Health and Welfare) Regulations 1970, and Section 15(1) of OSHA 1994.

How many first aid boxes does my workplace need?

DOSH does not prescribe a single fixed ratio; the requirement is that boxes be distributed so every work area has reasonable, prompt access, with at least one box per floor in multi-storey premises and additional boxes for isolated or high-risk areas regardless of headcount.

How many trained first aiders do I need?

It depends on whether your workplace is low-risk or high-risk under the DOSH guideline. Low-risk workplaces need 1 first aider under 20 workers, 2 for 21–150 workers, and 2 per additional 150 thereafter. High-risk workplaces need 1 per shift under 20 workers, and 1 per 20 workers or part thereof above that. Workplaces above 400 workers also need a registered nurse or medical assistant on site.

Can painkillers or other medication be kept in a first aid box?

No. DOSH guidance is explicit that first aid boxes should not contain oral medication beyond what is required for immediate first aid treatment. Workers needing medication should be referred to a doctor or clinic.

When is a dedicated first aid room legally required?

DOSH’s guideline states a first aid room is required where more than 150 people are employed at the workplace. Some other sources state 100 workers as the threshold; if your internal policy already uses 100, there is no compliance risk in continuing to do so, since it is more conservative than the guideline’s figure.

How often do first aiders need refresher training?

Once every three years on a recognised course, per DOSH guidance. Employers should keep a record of each first aider’s original and refresher training dates.

Which training providers does DOSH recognise for first aid courses?

Institutions under the Ministry of Health, hospitals under the Ministry of Education, NIOSH, the Malaysian Society for Traumatology and Emergency Medicine, the Malaysian Red Crescent Society, St John Ambulance Malaysia, and any organisation using trainers certified by one of these bodies and approved by the DOSH Director General.

Do I need an AED at my workplace?

There is no blanket legal requirement for every Malaysian workplace to have an AED. It is strongly advisable, and treated as best practice by DOSH’s wider guidance on first aid equipment, for workplaces with elevated cardiac-arrest risk, including sites with electrical hazards, manufacturing plants, and larger facilities generally, since survival from cardiac arrest depends heavily on time to defibrillation.

What should be recorded after a first aider treats an injury?

The treatment given, details of the incident and the work process involved, the nature of the injury, any referral made to a clinic or hospital, and the subsequent management of the case. The record must be kept for five years, and the relevant CSDS should be attached if a chemical was involved.

Who is responsible for first aid provision on a construction site with multiple contractors?

The principal employer, under OSHA 1994's general duty. Individual employers may agree in writing that one party will provide the first aiders, boxes, room and equipment on behalf of all of them, but this arrangement must be documented, with a copy held by each employer involved.

What is the difference between a first aid box, a first aid room, and first aid equipment?

DOSH treats these as three of the four components of workplace first aid (alongside the first aider). The box is portable and for immediate response; the room is a dedicated space required once a workplace exceeds 150 employees; equipment refers to broader items such as stretchers, spinal boards and oxygen that support first aid beyond what fits in a box.

Does chemical handling require anything beyond the standard first aid box?

Yes. Workplaces using hazardous chemicals need the current CSDS posted near the point of use under USECHH Regulations 2000, and DOSH recommends first aiders in these environments receive specific training in decontamination and chemical poisoning management. Emergency eyewash or shower provision within roughly ten seconds of travel is also expected wherever corrosive chemicals are regularly handled.

How long must first aid treatment records be kept?

Five years, per DOSH's guideline. This retention period matters beyond compliance, since it is often the only contemporaneous record available if an injury develops into a longer-term claim well after the original incident.

Conclusion

A compliant first aid programme in Malaysia is built on getting four things right together: the correct number of trained first aiders for your actual risk category and shift pattern, a box stocked to the DOSH-recommended list and genuinely accessible at all times, a dedicated first aid room once the workforce crosses 150 people, and records that are actually kept for the full five years. None of this is complicated on its own, but it degrades quietly if nobody owns it, which is why most first aid non-compliance findings are maintenance failures rather than initial planning failures.

If you're setting up or reviewing first aid and emergency response provision for a Malaysian workplace or project site, our team can help you match eyewash, shower, and spill response equipment to your hazard profile, and point you toward first aid box and AED sourcing as part of the same project. Request a quotation or send us your site details directly, and we'll help you work through what your workforce size and hazard category actually require.

Haisar Supply and Services Sdn Bhd (985158-T) | Kulai, Johor, Malaysia | www.haisar.com