Does CDM 2024 Apply to All Construction Projects?

This is another question I hear very often from contractors and project teams.

A lot of people still assume CDM only applies to mega projects, high-rise buildings, MRT projects, or government developments.

But after reading the CDM Regulation carefully, the answer is actually very clear:

Yes — CDM 2024 applies to almost all construction projects.

And honestly, this is where many smaller contractors may get caught off guard.

According to the FAQ, the regulation applies from the conceptual design stage all the way until handover to the client. It also continues during renovation, repair, maintenance, cleaning, and even demolition works throughout the life of the structure.

That means CDM is not limited to “new construction projects” only.

For example:

• Office renovation works

• House extension projects

• Roof repair works

• Factory maintenance shutdowns

• Mechanical and electrical replacement works

• Building refurbishment

• Demolition activities

• Structural upgrading works

All of these can fall under CDM requirements.

Personally, I think this is one of the biggest misconceptions in the industry right now.

Many small contractors still believe safety regulations only become “serious” when dealing with large-scale projects. But under CDM, even smaller domestic projects can carry legal safety responsibilities.

The FAQ specifically mentions that domestic construction works such as house extensions and private home repairs are also covered under the regulation.

That is actually a very important point.

Because some of the worst safety practices often happen in smaller projects where there is less supervision, weaker planning, and limited safety management systems.

I’ve personally seen smaller renovation projects with:

• Unsafe roof work

• Improper scaffolding

• Exposed electrical cables

• No edge protection

• Poor housekeeping

• No proper work coordination

And many people wrongly assume DOSH requirements do not apply because the project is “small.”

But CDM changes that mindset completely.

Another thing many people overlook is that CDM applies throughout the entire project lifecycle — not just during active construction.

The FAQ explains that maintenance, repair, and post-construction works are also included because risks continue even after project completion.

Honestly, this makes a lot of sense.

A poorly designed building can continue creating safety risks for maintenance workers for the next 20 or 30 years.

For example:

• Unsafe rooftop access

• Difficult façade cleaning access

• Poor plant room layout

• No permanent lifeline system

• Unsafe maintenance platforms

These are problems that may not appear during construction, but they become major hazards later during building operation and maintenance.

That is why CDM pushes project stakeholders to think beyond immediate construction activities.

Personally, I think this wider scope is one of the strongest parts of the regulation because it forces the industry to stop seeing safety as “temporary site compliance.”

Instead, safety becomes part of the building’s entire lifecycle.

What Is Considered “Construction Work” Under CDM 2024?

Honestly, this is one area where many people underestimate the regulation.

When most people hear the term “construction work,” they usually imagine activities like building structures, concreting, excavation, scaffolding, or crane lifting.

But after reading the DOSH FAQ, the definition under CDM 2024 is actually much broader than that.

The regulation defines construction work as not only construction of buildings and civil engineering works, but also many related activities throughout the lifecycle of a structure.

This includes:

• Construction works

• Alteration works

• Conversion works

• Fitting out activities

• Commissioning works

• Renovation works

• Repair works

• Maintenance works

• Cleaning involving hazardous processes

• Decommissioning

• Demolition

• Dismantling

• Excavation

• Site preparation

• Installation of prefabricated structures

• Mechanical and electrical installations

Personally, I think this wider definition is very important because the industry often separates “maintenance work” from “construction work,” even though the risks are sometimes exactly the same.

For example:
A maintenance worker replacing rooftop equipment may still face:

• Work at height risks

• Falling object hazards

• Electrical exposure

• Confined space hazards

• Heat stress

• Manual handling risks

The fact that it is called “maintenance” does not make it safer.

That is probably why CDM intentionally uses a very wide definition.

Another interesting thing mentioned in the FAQ is that even cleaning activities can fall under construction work if they involve hazardous processes such as:

• High-pressure water jetting

• Abrasive cleaning

• Corrosive substances

• Toxic chemicals

Honestly, many contractors may overlook this completely.

I’ve seen projects where cleaning activities are subcontracted without proper risk assessments because people assume it is “simple work.” But once hazardous chemicals, confined spaces, or pressure systems are involved, the risk level changes entirely.

The FAQ also explains that installation and maintenance of fixed services are included under construction work. This covers:

• Mechanical systems

• Electrical systems

• Gas systems

• Compressed air systems

• Hydraulic systems

• Telecommunications

• Computer-related services

That means many M&E contractors now fall directly under CDM obligations as well. Personally, I think this broader scope reflects the reality of modern construction projects. Construction today is no longer just “brick and concrete work.” Modern projects involve integrated systems, specialized contractors, complex installations, maintenance planning, and long-term operational risks. One important exception mentioned in the FAQ is that mineral exploration and extraction activities are excluded from CDM construction work definitions. But outside of that, most physical project-related activities involving structures will likely fall under CDM. And honestly, that is probably the main message DOSH is trying to send:

If the work creates construction-related safety and health risks, there is a high chance CDM responsibilities apply.

Who Is Considered the “Client” Under CDM 2024?

Honestly, this is probably one of the most important concepts in the entire CDM regulation.

Under the old mindset in construction, many people viewed the client as someone who only pays for the project and waits for completion. Safety responsibilities were usually pushed down to the contractor, SHO, or site team.

But CDM 2024 changes that completely.

According to the DOSH FAQ, the “client” refers to any principal or person for whom the construction project is being carried out. In simple terms, the client is basically the project owner or the party initiating the project.

And the definition is actually very wide.

The FAQ explains that a client can be:

• A developer

• A company

• A homeowner

• A land owner

• A government agency

• A local authority (PBT)

• A consortium

• A corporation

• A self-employed individual

• A state or federal government body

Personally, I think many organizations still do not realize they now carry direct legal responsibilities under CDM.

The FAQ also explains how DOSH identifies a client in practical terms. Usually, the client is the party that:

• Decides what will be built

• Determines where and when work starts

• Approves project execution

• Leads project procurement

• Appoints the project team

• Engages consultants and contractors

When you look at it that way, it makes sense why DOSH places major responsibilities on the client.

Because honestly, clients influence almost everything in a project.

If a client pushes unrealistic timelines, contractors may rush work.

If budgets are too low, safety resources may be reduced.

If coordination is poor, site clashes become more likely.

If the design stage is rushed, hazards may remain hidden until construction begins.

That is why CDM moves safety responsibility upward into the decision-making level.

One thing I personally found very important in the FAQ is this:

The client’s duties start during the pre-construction stage — even before physical construction begins.

This is a huge shift from traditional thinking.

Previously, many clients became actively involved only during tendering or site progress monitoring. Under CDM, the client now has responsibilities much earlier during:

• Feasibility studies

• Conceptual design

• Project planning

• Budget allocation

• Appointment of designers

• Appointment of contractors

• Pre-construction coordination

Honestly, I think this approach is much more realistic.

Because many construction risks are actually created during these early planning stages.

For example:

• Poor site access planning

• Tight project deadlines

• Insufficient welfare allocation

• Unsafe design concepts

• Limited maintenance access

• Poor sequencing arrangements

Once construction starts, fixing these problems becomes much harder and more expensive.

The DOSH guideline and CDM framework are basically trying to push the industry toward “Prevention Through Design” and proactive project management rather than reactive safety enforcement later on site.

And personally, I think that is exactly where the industry needs to move.

Why Are Clients Given So Much Responsibility Under CDM 2024?

Honestly, when people first read CDM 2024, many are shocked by how much responsibility is placed on the client.

Some people even ask:

“Why is CDM putting safety responsibility on developers and project owners? Isn’t safety the contractor’s job?”

But after reading the FAQ carefully, the logic behind it actually makes complete sense.

According to DOSH, clients have major influence over the planning, organization, and execution of construction projects.

And honestly, that is true in almost every project.

The client controls:

• Project budget

• Timeline

• Procurement strategy

• Consultant appointments

• Contractor selection

• Overall project expectations

In simple terms, the client shapes the entire project environment long before construction starts.

That means if the client prioritizes safety properly, the whole project team is more likely to take safety seriously as well.

The FAQ specifically mentions that clients should demonstrate good OSH leadership by ensuring sufficient allocation of:

• Time

• Funding

• Resources

• Safety arrangements

Personally, I think this is one of the strongest messages in CDM.

Because if we are being realistic, many site safety problems actually begin with poor project decisions at management level.

For example:

• Unrealistic deadlines may cause rushing.

• Insufficient budgets may reduce safety resources.

• Poor procurement planning may lead to unqualified contractors.

• Weak coordination may create overlapping hazardous work activities.

When these things happen, the site team ends up struggling to manage risks that could have been prevented much earlier.

And honestly, this happens very often in real projects.

I’ve personally seen projects where:

• Workers were pushed to work overtime continuously.

• Temporary access systems were poorly planned.

• Welfare facilities were insufficient.

• Design changes came too late.

• Contractors rushed activities just to recover project delays.

By the time the SHO identifies the issue on site, the root cause may already exist at planning stage.

That is why CDM pushes responsibility upward to the client level.

Another important thing highlighted in the FAQ is that clients usually possess detailed project information before anyone else.

This includes:

• Site conditions

• Existing hazards

• Project constraints

• Operational requirements

• Future maintenance needs

• Utility information

• Design intentions

The regulation expects clients to share this information properly with designers and contractors so risks can be identified and controlled early.

Personally, I think this improves project coordination significantly.

Because one major cause of construction accidents is poor information flow between stakeholders.

Sometimes contractors only discover hidden site risks after work has already started.

Sometimes designers create maintenance hazards because they lack operational information.

Sometimes subcontractors work without understanding surrounding project risks.

CDM tries to reduce these gaps through better coordination and communication from the beginning.

And honestly, this is probably the biggest cultural change under CDM 2024:

Safety is no longer treated as a site-level issue only.

It becomes part of project leadership, planning, budgeting, procurement, design, and decision-making from the very beginning of the project lifecycle.

What Are the Main Duties of Clients Under CDM 2024?

After understanding why clients now carry major responsibilities under CDM, the next obvious question is:

“What exactly must the client do?”

Honestly, this is where many developers, project owners, and even consultants may underestimate the regulation.

The DOSH FAQ explains that the client’s duties are detailed under Regulations 4 to 8 of CDM 2024.

And when you actually read the list carefully, you realize the client’s role is much more active than before.

One of the first duties mentioned is that the client must ensure sufficient:

• Time

• Funding

• Resources

are allocated for project safety and health management.

Personally, I think this is one of the most important requirements in the entire regulation.

Because honestly, no matter how good the contractor or SHO is, safety performance will struggle if:

• The project duration is unrealistic

• The manpower is insufficient

• Welfare facilities are poor

• Safety budgets are inadequate

• Work sequencing is rushed

Many site-level safety problems actually begin because projects are under pressure from the start.

CDM now makes the client directly responsible for ensuring these issues are considered early.

The FAQ also explains that clients must ensure construction work can be carried out safely “so far as is practicable” without risks to safety and health.

That sounds simple, but it has very big implications.

It means clients cannot simply prioritize cost and timeline while ignoring practical safety considerations.

For example:

• Is there enough site access?

• Is there proper welfare provision?

• Is the sequencing realistic?

• Are maintenance risks considered?

• Are temporary works properly coordinated?

These are all decisions that may start from the client level.

Another major duty is ensuring welfare facilities are provided according to legal requirements.

Honestly, welfare is often overlooked in construction projects.

But poor welfare conditions directly affect:

• Worker fatigue

• Hygiene

• Morale

• Heat stress management

• Mental wellbeing

• General site discipline

Basic things like proper toilets, rest areas, drinking water, washing facilities, and eating spaces actually contribute significantly to safer working environments.

The regulation also requires clients to provide pre-construction information to designers and contractors.

This is extremely important.

Because if contractors or designers do not receive accurate project information early, hidden risks may only appear after construction begins.

For example:

• Underground services

• Existing structures

• Soil conditions

• Restricted access

• Hazardous materials

• Operational constraints

Poor information sharing has caused many accidents in real projects.

Another duty many people overlook is that clients must ensure the Principal Designer (PD) and Principal Contractor (PC) carry out their responsibilities properly.

This means the client cannot simply appoint duty holders and assume the responsibility disappears completely.

There must still be oversight and coordination.

The FAQ also mentions that clients must ensure:

• Construction Phase Plans are prepared

• Safety and Health Files (SHF) are developed and maintained

Personally, I think this is one of the biggest changes under CDM.

Previously, many clients viewed safety documentation mainly as contractor paperwork.

But under CDM, safety planning becomes part of overall project governance.

And honestly, that is probably the direction Malaysia’s construction industry needs to move toward if we want long-term improvement in construction safety performance.

Does CDM 2024 Apply to Oil and Gas Projects?

This is actually a very common question, especially among contractors involved in plant construction, shutdown works, piping installation, and industrial maintenance projects.

For many years, people in the oil and gas industry sometimes treated their projects separately from “normal construction projects” because they already followed strict client requirements, PETRONAS systems, or internal HSE standards.

But according to the DOSH FAQ, CDM 2024 still applies to many oil and gas activities.

The FAQ clearly states that any work other than mineral exploration and extraction activities can be categorized as construction work under the regulation.

In simple terms, this means many downstream oil and gas construction activities still fall under CDM obligations.

Personally, I think many people misunderstand this part.

When DOSH excludes “exploration and extraction,” it mainly refers to activities directly related to extracting mineral resources from the ground. But once the work involves construction-related activities, CDM responsibilities may apply.

For example:

• Plant construction

• Structural erection

• Piping installation

• Mechanical installation

• Electrical works

• Maintenance shutdown projects

• Tank construction

• Demolition works

• Brownfield modification projects

• Fabrication-related installation activities

These types of activities may still fall within CDM requirements because they involve construction risks and project coordination.

And honestly, the risks in oil and gas projects are often even more complex than ordinary building projects.

You are not only dealing with:

• Work at height

• Lifting operations

• Excavation

• Confined space entry

• Electrical hazards

But also:

• Flammable atmospheres

• Toxic gas exposure

• Process safety risks

• Simultaneous operations (SIMOPS)

• Pressurized systems

• High-energy equipment

That is probably why DOSH wants stronger coordination and planning responsibilities under CDM.

Personally, I think the CDM concept actually fits very well with oil and gas projects because these projects already rely heavily on:

• Permit-to-work systems

• Risk assessments

• Engineering reviews

• Work coordination

• Hazard identification

• Multi-contractor management

CDM simply formalizes these responsibilities further under Malaysian OSH legislation.

Another thing worth mentioning is that many oil and gas projects involve multiple contractors working simultaneously in restricted spaces.

For example:

• Civil contractors

• Mechanical contractors

• Scaffolding teams

• NDT specialists

• Rope access personnel

• Electrical teams

• Instrumentation contractors

Without proper coordination, the risk of conflicting activities becomes extremely high.

That is why the Principal Contractor (PC) and duty holder concepts under CDM become very important for these types of projects.

I also personally feel that CDM pushes oil and gas projects to improve “Prevention Through Design” even further.

For example:

• Safer maintenance access

• Better equipment layout

• Improved emergency escape routes

• Reduced confined space exposure

• Safer lifting arrangements

• Better temporary works planning

These are all design-level decisions that can significantly reduce operational risks later.

And honestly, that is the core idea behind CDM:

• Do not wait until workers are exposed to hazards on site before thinking about safety.

• Start managing the risks much earlier during planning, coordination, and design stages.

What Is the Safety and Health File (SHF) Under CDM 2024?

Honestly, when many people first hear about the Safety and Health File, they assume it is just another safety document for compliance purposes.

But after reading the DOSH FAQ carefully, I realized the SHF is actually meant to serve a much bigger purpose than ordinary project documentation.

According to the FAQ, the Safety and Health File (SHF) must contain important project information that may be needed in future works to ensure the safety and health of people involved in later activities.

In simple terms, the SHF acts like a long-term safety reference for the structure even after the project is completed.

Personally, I think this is one of the smartest concepts introduced under CDM.

Because in real projects, many safety risks continue long after construction finishes.

For example:

• Maintenance workers may need rooftop access years later.

• Contractors may carry out future renovations.

• Plant equipment may need replacement.

• Structural modifications may be required.

• Demolition may eventually happen decades later.

If critical safety information is lost after handover, future workers may unknowingly expose themselves to serious hazards.

That is exactly what SHF is trying to prevent.

The FAQ explains that the file should contain project-related information likely to be required in future projects to ensure safety and health.

Personally, I think many companies still underestimate how useful this can become.

Imagine future maintenance contractors trying to work on a building without knowing:

• Hidden underground services

• Structural limitations

• Hazardous materials used

• Permanent lifeline details

• Confined space hazards

• As-built service layouts

• Safe access systems

• Load restrictions

Without proper information, workers may end up creating unnecessary risks simply because they do not fully understand the structure.

Another thing I noticed is that SHF encourages project teams to think beyond “construction completion.”

Traditionally, many projects focus heavily on handing over the building as quickly as possible. But CDM pushes teams to think about the building’s entire operational lifecycle.

And honestly, this makes a lot of sense.

A building may stand for 30, 40, or even 50 years.

During that period, hundreds of workers may eventually carry out:

• Maintenance work

• Upgrading works

• Mechanical replacements

• Façade cleaning

• Roof repairs

• Renovation works

The information stored inside the SHF can directly affect whether those future activities are carried out safely.

The FAQ also explains that SHF is different from the DOSH Log Book.

This is something many people still confuse.

The DOSH Log Book mainly records:

• Inspection findings

• Enforcement observations

• Audit records

• DOSH visit details

But the SHF focuses on long-term project safety information relevant to future works.

Another important point mentioned in the FAQ is that even existing projects are encouraged to prepare SHF after CDM enforcement.

Personally, I think this is a good move because many older buildings have very poor historical safety records and incomplete documentation.

In the long run, SHF could significantly improve:

• Maintenance planning

• Future renovation safety

• Asset management

• Contractor coordination

• Hazard communication

And honestly, that is probably the main idea DOSH is trying to achieve under CDM:

Construction safety should not stop at project completion.

The responsibility continues throughout the entire life of the structure.

Is BOWECs Still Applicable After CDM 2024?

Honestly, this is one of the biggest questions people in the construction industry are still asking.

Many contractors, SHO, supervisors, and even consultants are so used to BOWECs that they still refer to it automatically during discussions, toolbox meetings, or inspections.

For years, BOWECs was basically the “main construction safety regulation” in Malaysia.

But according to the DOSH FAQ, the answer is very clear:

No — BOWECs has been fully repealed starting from 1 June 2024.

This means the old Factories and Machinery (Building Operations and Works of Engineering Construction) (Safety) Regulations 1986 are no longer in force.

Personally, I think this is a major turning point for Malaysia’s construction industry.

Because BOWECs had existed for decades and shaped how most construction safety systems were managed in the country.

Most site personnel became very familiar with requirements involving:

• Scaffolding

• Excavation

• Machinery safety

• Falsework

• Temporary structures

• Lifting operations

• Site housekeeping

• Work at height

So naturally, many people now wonder:

“If BOWECs is repealed, what replaces all those requirements?”

The FAQ explains that CDM 2024 replaces part of the old BOWECs provisions, while some other technical requirements will later be replaced by future regulations related to work at height.

And honestly, this is where some confusion currently exists in the industry.

Because CDM focuses more on:

• Planning

• Coordination

• Design risk management

• Duty holder responsibilities

• Project management

• Communication

• Safety integration throughout the project lifecycle

It is not designed to function exactly like the old BOWECs technical regulation framework.

That is why DOSH mentioned that future Work at Height regulations will eventually provide more detailed technical requirements for areas like:

• Scaffolding

• Formwork

• Falsework

• Temporary structures

Personally, I think the industry is currently going through a transition phase.

Many companies are still adapting because for years safety compliance focused heavily on physical site conditions alone. But CDM pushes companies to think much earlier during:

• Design stages

• Procurement stages

• Planning stages

• Coordination stages

• Pre-construction activities

That is a very different mindset compared to traditional compliance systems.

Another important thing I noticed is that some contractors mistakenly assume that because BOWECs has been repealed, technical safety requirements are now “less strict.”

Honestly, that is the wrong way to look at it.

If anything, CDM expands responsibilities even further.

Now DOSH can examine whether:

• Risks were identified early

• Safety coordination was effective

• Designers considered safety properly

• Clients allocated sufficient resources

• Project planning created foreseeable hazards

So safety responsibility no longer sits only with the site team. Personally, I think this is actually a more mature approach to construction safety.

Because in reality, many serious accidents are not caused solely by workers making mistakes on site.

Sometimes the root causes begin much earlier through:

• Unsafe design concepts

• Poor project coordination

• Unrealistic schedules

• Inadequate planning

• Weak contractor management

CDM tries to address these root causes before work even begins. And honestly, that is probably the biggest difference between the old BOWECs mindset and the new CDM approach:

• BOWECs focused heavily on controlling hazards during construction.

• CDM focuses on preventing those hazards from being created in the first place.

Can DOSH Take Action Against Clients and Designers Under CDM 2024?

Honestly, this is the part of CDM 2024 that many people are still not fully prepared for.

Under the old mindset, when construction accidents happened, people usually looked immediately at:

• The contractor

• The site supervisor

• The SHO

• The workers on site

But CDM changes this approach quite significantly.

According to the DOSH FAQ, enforcement action can now be taken against any duty holder under the regulation.

This includes:

• Clients

• Principal Designers (PD)

• Designers

• Principal Contractors (PC)

• Contractors (CC)

Personally, I think this is one of the most serious changes introduced under CDM.

Because now, safety accountability is spread across the entire project chain — not only at site level.

The FAQ also explains that DOSH may take various forms of legal or punitive action under OSHA 1994, including:

• Prosecution

• Compounds

• Notices

• Instruction letters

And honestly, this completely changes how companies need to think about construction safety.

Previously, some project stakeholders may have assumed:

“As long as the contractor handles site safety, our responsibility ends there.”

But under CDM, that assumption no longer works.

For example, a client may now face scrutiny if:

• Project timelines were unrealistic

• Safety resources were insufficient

• Coordination arrangements were poor

• Pre-construction information was incomplete

• Duty holders were not properly appointed

Similarly, designers may also face responsibility if foreseeable risks were ignored during design stages.

Personally, I think this is actually a very logical approach.

Because many construction hazards are created long before work starts on site.

For example:

• Designing roof areas without safe maintenance access

• Creating layouts that force difficult lifting operations

• Poor temporary works considerations

• Designing confined spaces with limited rescue access

• Unsafe sequencing assumptions

If these hazards are foreseeable during design stage but ignored, workers may later be exposed to unnecessary risks during construction or maintenance.

That is exactly why CDM strongly emphasizes “Prevention Through Design.”

Another thing I personally noticed is that CDM will likely force much better documentation and communication between project stakeholders.

Because once accountability is shared, every duty holder will need to show evidence that:

• Risks were considered

• Coordination was conducted

• Safety information was communicated

• Responsibilities were fulfilled properly

In other words, safety management becomes much more systematic and traceable.

Honestly, I think this will eventually improve overall project quality as well.

Because proper coordination usually improves:

• Planning

• Sequencing

• Communication

• Contractor management

• Risk control

• Decision-making

Another important point is that enforcement under CDM is not only about reacting after accidents happen.

DOSH may also take action if project stakeholders fail to comply with legal duties even before incidents occur.

That means poor planning, weak coordination, missing documentation, or failure to fulfill duty holder responsibilities may already become compliance issues.

And honestly, this is probably one of the clearest signals DOSH is sending to the industry:

Construction safety is no longer viewed as only a site operational issue.

It is now treated as a project management responsibility shared by everyone involved in creating construction risks.

Who Is Responsible for Conducting Risk Assessments Under CDM 2024?

Honestly, when people talk about risk assessments in construction, many immediately think only about HIRARC forms prepared by the SHO or safety department.

But after reading the DOSH FAQ carefully, it becomes very clear that risk assessment responsibilities under CDM and OSHA go far beyond just paperwork.

According to the FAQ, Section 18B of OSHA 1994 places responsibility on:

• Employers

• Self-employed persons

• Principals

to conduct risk assessments related to occupational safety and health risks that may affect people at the workplace.

Personally, I think this is a very important clarification because many companies still assume risk assessment is only the SHO’s responsibility.

But in reality, risk management should involve every level of the project team.

For example:

• Designers should assess design-related risks.

• Contractors should assess work execution risks.

• Clients should assess project planning risks.

• Engineers should assess technical and operational risks.

• Supervisors should assess daily activity risks.

That is actually the whole philosophy behind CDM.

Instead of waiting for hazards to appear physically on site, the regulation pushes stakeholders to identify and control risks much earlier.

The FAQ also mentions that risk assessments should refer to relevant regulations and industry codes of practice.

This is important because construction risks today are very wide-ranging.

It is no longer only about obvious physical hazards like falling objects or excavation collapse.

Modern projects may involve:

• Noise exposure

• Chemical hazards

• Ergonomic risks

• Mental stress

• Confined spaces

• Heat stress

• Vibration exposure

• Dust and airborne contaminants

• Electrical hazards

• Process safety risks

And honestly, some of these risks are still poorly managed in many projects.

For example, noise exposure is often normalized in construction sites even though long-term hearing damage can permanently affect workers.

Similarly, chemical exposure during waterproofing, painting, welding, cleaning, or confined space activities is sometimes underestimated until health effects start appearing later.

Personally, I think CDM is trying to push the industry toward a more mature safety culture where risk management becomes part of project decision-making — not just site documentation.

Another thing I noticed is that CDM strongly supports the concept of “Prevention Through Design.”

That means risk assessments should not only happen during site work.

They should also happen during:

• Design stages

• Planning stages

• Procurement stages

• Construction sequencing discussions

• Maintenance planning

For example:

• Can workers maintain rooftop equipment safely later?

• Can materials be lifted safely during installation?

• Is there enough access for rescue operations?

• Are confined spaces avoidable through design improvements?

• Can temporary works be simplified?

These are all forms of risk assessment, even if people do not always label them that way. And honestly, I think this is where the industry is slowly evolving. Previously, risk assessments were sometimes treated as compliance documents prepared after decisions had already been made. But CDM encourages project teams to use risk assessments proactively before hazards are created. That shift may sound simple, but it can completely change how construction safety is managed in real projects.

Is an OSH Coordinator (OSH-C) Required Under CDM 2024?

Honestly, this is another area where many companies are still confused.

Some people assume the OSH Coordinator (OSH-C) replaces the Safety and Health Officer (SHO). Others think every construction project automatically requires both positions.

But after reading the DOSH FAQ carefully, the requirement is actually more specific than many people realize.

According to the FAQ, Section 29A of OSHA 1994 requires employers with workplaces that are not already classified under SHO-required categories, and which employ five or more workers, to appoint one employee as an OSH Coordinator (OSH-C).

In simple terms, the OSH-C requirement is intended to strengthen safety coordination in workplaces where a full SHO may not legally be required.

Personally, I think this is actually a good move.

Because many smaller projects or workplaces still carry significant risks even though they may not meet SHO appointment thresholds.

For example:

• Small renovation projects

• Interior fit-out works

• Minor maintenance projects

• Domestic extension works

• Small factory upgrading works

These projects may still involve:

• Work at height

• Electrical hazards

• Confined spaces

• Manual handling

• Hot work

• Temporary structures

But traditionally, smaller workplaces sometimes lacked structured OSH coordination entirely.

The OSH-C requirement helps close that gap.

Another important thing mentioned in the FAQ is that if the appointed employee has already attended the Site Safety Supervisor (SSS) course, they do not need to attend separate OSH-C training again.

Honestly, that makes practical sense because many SSS personnel already possess site-level safety coordination knowledge.

Personally, I think DOSH is trying to create more widespread OSH leadership across workplaces instead of relying only on SHO appointments.

Because if we are being realistic, SHO alone cannot control every safety issue on every project.

Good safety culture depends heavily on:

• Daily supervision

• Worker engagement

• Communication

• Early hazard reporting

• Site coordination

• Management support

That is where roles like OSH-C can become very useful. Another thing I noticed is that CDM generally pushes the idea that safety responsibilities should exist at multiple levels throughout the organization.  Instead of depending entirely on one “safety person,” the regulation encourages:

• Clients to lead safety planning

• Designers to eliminate risks through design

• Principal Contractors to coordinate site activities

• Supervisors to manage daily risks

• Workers to participate actively in safety management

And honestly, I think this creates a much healthier safety system overall.

Because many accidents happen when safety becomes isolated within one department rather than integrated into project operations.

The OSH-C role may seem small compared to SHO or Principal Contractor responsibilities, but it reflects the bigger direction CDM is pushing toward:

Making occupational safety and health part of everyday project management, communication, and workplace culture — even in smaller construction environments.

Final Thoughts: CDM 2024 Is More Than Just Another Safety Regulation

After going through the DOSH FAQ and understanding the intent behind CDM 2024, honestly, I feel this regulation is trying to push Malaysia’s construction industry into a completely different direction.

For many years, construction safety was often treated as something reactive.

Accidents happen >> Then investigations start >> Then corrective actions follow.

But CDM changes that entire mindset.

The regulation is pushing the industry to think about safety much earlier — during planning, design, procurement, budgeting, coordination, and decision-making stages.

And personally, I think that is exactly where the industry needed to move.

Because if we are being honest, many serious construction risks are already created long before work even starts on site.

• Poor planning.

• Unsafe design.

• Aggressive timelines.

• Weak coordination.

• Insufficient budgets.

• Poor maintenance considerations.

These problems eventually flow downward to workers during execution. That is why one of the strongest concepts under CDM is shared responsibility. Instead of placing all pressure only on contractors or SHO, the regulation now involves:

• Clients

• Designers

• Principal Designers

• Principal Contractors

• Contractors

• Employers

• Project stakeholders

Everyone now carries some level of responsibility for occupational safety and health. Personally, I think this is one of the biggest cultural changes the Malaysian construction industry has seen in decades. Another thing I noticed while reading the FAQ is that CDM does not only focus on preventing accidents during construction. 

It also looks at the long-term safety of:

• Maintenance workers

• Future renovation works

• Building operations

• Demolition activities

• Facility upgrades

That is why concepts like:

• Prevention Through Design

• Safety and Health Files (SHF)

• Pre-construction information

• Early risk assessment

• Better coordination

become so important under the regulation. And honestly, if properly implemented, these ideas can improve much more than just safety performance. 

They can also improve:

• Project planning

• Communication

• Work sequencing

• Contractor coordination

• Quality management

• Long-term asset management

At the same time, I think many companies are still underestimating how significant CDM really is.

Some organizations still treat it as “just another compliance requirement.”

But once DOSH enforcement becomes more active under the new framework, project stakeholders will likely realize that safety accountability is now much broader than before.

Clients can no longer fully transfer safety responsibility downward.

Designers can no longer ignore foreseeable risks.

Contractors can no longer work without proper coordination.

Everyone is now part of the safety management system. And honestly, that may be the biggest lesson from CDM 2024:

• Construction safety is no longer only about controlling hazards on site.

• It is about preventing those hazards from being created in the first place.

Well I hope answering these questions about CDM had help your understanding on CDM. I will dive deeper on CDM on other post. Cheers.