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Occupational Safety and Health (OSH): The case of Cambodia

What Responsible Investors Need to Know

Cambodia is undergoing a significant transition in its Occupational Safety and Health (OSH) ecosystem, notably through its shift toward OSH Management Systems (OSH‑MS), implementation of the Third OSH Master Plan (2023–2027), and enhanced labour inspection and penalty mechanisms. Despite this progress, Cambodia continues to face persistent gaps in enforcement capacity, enterprise‑level compliance, documentation quality, and workforce safety culture.

● Overview of OSH in Cambodia
● Legal and Institutional Framework for OSH          
β–Ά Key Institutions
● Legal Requirement for OSH 
● Types of Projects Requiring OSH Compliance    
● Who Can Conduct OSH Compliance     
    β–ΆGovernment Authorities    
    β–ΆEmployers  External Support
    β–Ά External Support
● OSH Process Flow in Cambodia
Step ➊: Business Registration
Step βž‹: Workplace Hazard Identification
Step ➌: Implementation of OSH Measures 
Step ➍: Routine Monitoring & Record Keeping
Step ➎: Labour Inspection by MLVT
Step ➏: Corrective Actions (if required)
Step ➐: Ongoing Compliance & Reporting
● Penalties for Non Compliance with OSH Requirements   
    β–ΆAdministrative Penalties, 
    β–ΆCivil Liability
    β–Ά Criminal Liability, 
    β–ΆReputational and Commercial Impact

● Critical Gap Assessment of MLVT’s Regulatory Scope and Institutional Capacity            
    β–ΆCritical Gaps Identified
    β–Ά Recommendations
    β–Ά Closing the Gaps: Strategic Outcome
    β–Ά Suggested Next Steps for MLVT Impact
 

1. Overview of OSH in Cambodia

Occupational Safety and Health (OSH) in Cambodia is a core component of labour protection and sustainable development, aimed at preventing workplace accidents, occupational diseases, and work‑related health hazards. OSH policy in Cambodia has evolved significantly since the promulgation of the Labour Law in 1997, with increasing alignment to International Labour Organization (ILO) standards and ASEAN frameworks.

Cambodia’s OSH framework covers both the formal and informal sectors, including manufacturing, construction, agriculture, mining, and services. The government recognizes OSH as critical to:

  • Protecting workers’ lives and health

  • Improving productivity and job sustainability

  • Enhancing investor confidence and ESG performance

The Third National OSH Master Plan (2023–2027) currently guides national OSH priorities, emphasizing prevention, inspection, training, and institutional coordination.

​2. Legal and Institutional Framework for OSH in Cambodia

β–Ά Key Institutions: OSH governance in Cambodia involves multiple state institutions, led by:

  • Ministry of Labour and Vocational Training (MLVT) – Principal authority for OSH policy, regulation, inspection, and enforcement

  • Department of Occupational Safety and Health (DOSH) – Technical arm under MLVT responsible for inspections, guidance, and statistics

  • National Committee on Occupational Safety and Health (NCOSH) – Tripartite body (government, employers, workers) coordinating OSH policy

  • Ministry of Health – Occupational disease prevention and health surveillance

  • Ministry of Environment / Line Ministries – Sector‑specific safety matters

​International Alignment

Cambodia is a member of the ILO and aligns its OSH framework with:

  • ILO Convention No. 187 (OSH Promotional Framework)

  • ASEAN OSH Strategic Action Plans

​3. Legal Requirements for OSH in Cambodia

Core Legal Instruments

OSH obligations arise mainly from:

  • Labour Law (1997, as amended) – Chapter VIII: Health and Safety of Workers

  • Civil Code (2007) – Employer duty of care

  • Prakas (ministerial regulations) on workplace safety, hygiene, PPE, and inspections

​Employer Obligations

Employers are legally required to:

  • Ensure safe and hygienic workplaces

  • Identify and control workplace hazards

  • Provide personal protective equipment (PPE) free of charge

  • Maintain machinery, tools, and equipment in safe condition

  • Provide OSH training and safety instructions

  • Report occupational accidents and diseases

  • Arrange workplace infirmaries or first‑aid facilities where required

​Workers have the right to refuse unsafe work and to receive OSH information and training.

​4. Types of Projects Requiring OSH Compliance

In practice, all workplaces in Cambodia must comply with OSH requirements. However, heightened OSH scrutiny applies to high‑risk sectors, including:

  • Construction and infrastructure projects

  • Manufacturing and garment factories

  • Mining and quarrying

  • Energy and petroleum facilities

  • Agriculture and agro‑industry

  • Logistics, warehouses, and industrial zones

Large projects, foreign‑invested enterprises, and export‑oriented industries are subject to more frequent inspections and stricter compliance expectations. 

​5. Who Can Conduct OSH Compliance in Cambodia?

Government Authorities

  • Labour Inspectors under MLVT/DOSH conduct official OSH inspections, audits, and enforcement actions

Employers

  • Employers are primarily responsible for internal OSH compliance, including appointing safety officers and establishing workplace OSH committees where applicable

External Support

  • Licensed OSH consultants and training providers

  • International programs such as Better Factories Cambodia (BFC) for garment and footwear sectors

​6. OSH Process Flow in Cambodia

Typical OSH compliance follows this process:

​Business Registration

↓

Workplace Hazard Identification

↓

Implementation of OSH Measures (PPE, safety systems, training)

↓

Routine Monitoring & Record Keeping

↓

Labour Inspection by MLVT

↓

Corrective Actions (if required)

↓

Ongoing Compliance & Reporting

​

For serious incidents, investigations may involve MLVT, Ministry of Health, and other relevant authorities. 

​7. Penalties for Non‑Compliance with OSH Requirements

Administrative Penalties

  • Warnings and compliance orders

  • Fines for OSH violations

  • Suspension of activities or parts of operations

Civil Liability

  • Employers may be liable for damages under the Civil Code for workplace accidents or diseases caused by negligence

Criminal Liability

  • Serious negligence causing injury or death may result in criminal sanctions under Cambodian law

Reputational and Commercial Impact

  • Blacklisting from buyers

  • Loss of export contracts

  • ESG and financing risks

Critical Gap Assessment

8. Gap Assessment of MLVT’s Regulatory Scope and Institutional Capacity

​▢ Critical Gaps Identified

Gap 1: Fragmented and Incomplete Regulatory Scope

Status

  • OSH obligations currently embedded mainly in the Labour Law (Chapter VIII) and secondary regulations.

  • No standalone OSH Law that:

    • Clearly defines OSHMS obligations

    • Establishes professional OSH roles

    • Regulates private OSH services

    • Covers informal and non‑traditional workplaces

Implications

  • Employers face unclear compliance pathways

  • Inspectors rely on general provisions rather than technical standards

  • Limited legal basis for regulating private OSH actors

  • Weak coverage of SMEs, construction sub‑contractors, and informal economy

βœ… Root Cause
Regulatory framework evolved incrementally and is compliance‑oriented, not systems‑oriented.

​Gap 2: Institutional Capacity Constraints in DOSH and Inspection System

Status

  • Number of labour/OSH inspectors significantly below national demand

  • Inspectors expected to perform:

    • Compliance checks

    • Technical OSH assessments

    • Advisory roles

    • Enforcement actions

Implications

  • Inspections are primarily reactive and checklist‑based

  • Limited time for preventive guidance or OSHMS evaluation

  • High‑risk sectors compete for limited inspection resources

  • Inconsistent enforcement across provinces

βœ… Root Cause
Mandate expansion without corresponding institutional resourcing or task differentiation.

​Gap 3: Absence of a Regulated OSH Professional Ecosystem

Status

  • No national framework for:

    • OSH professionals

    • OSH consultants

    • Trainers

    • Auditors

  • Private OSH services operate informally and unevenly

Implications

  • Variable service quality

  • Risk of misinformation or superficial compliance

  • MLVT inspectors become de‑facto technical advisors

  • Enterprises lack reliable support, especially SMEs

βœ… Root Cause
Regulatory silence on professional standards and service accreditation.

Gap 4: Limited Reach to SMEs and Informal Economy

Status

  • OSH framework designed largely for formal, factory‑based workplaces

  • SMEs and informal enterprises often:

    • Lack OSH knowledge

    • Cannot afford consultants

    • Perceive compliance as punitive rather than supportive

Implications

  • Majority of workforce remains under‑protected

  • High accident rates persist in construction, agriculture, and services

  • OSH enforcement perceived as selective

βœ… Root Cause
One‑size‑fits‑all regulatory approach unsuitable for enterprise diversity.

Gap 5: Weak OSH Data, Reporting, and Evidence Base

Status

  • Accident and occupational disease under‑reporting remains common

  • Paper‑based or fragmented data systems

  • Limited integration with NSSF, health, and insurance data

Implications

  • Policy decisions rely on incomplete evidence

  • Risk‑based inspection planning is constrained

  • Preventive interventions lack targeting

βœ… Root Cause
OSH data systems were not designed as strategic decision tools.

​▢ Recommendations: How MLVT Can Close the Gaps
Recommendation 1: Enact a Standalone OSH Law (Foundational Reform)

Purpose

  • Consolidate OSH governance into a coherent, modern legal instrument

Key Elements

  • Legal recognition of OSHMS

  • Clear duties for employers, workers, professionals

  • Coverage of informal and high‑risk non‑standard work

  • Legal basis for accrediting OSH service providers

Impact

  • Clarifies compliance

  • Strengthens enforcement legitimacy

  • Aligns Cambodia with ILO best practice

Recommendation 2: Redefine and Differentiate MLVT’s Operational Role

Shift From

  • Inspector = enforcer + technical advisor + trainer

Shift To

  • MLVT = regulator, inspector, certifier, oversight body

  • Private sector = technical service delivery (under MLVT control)

Actions

  • Separate inspection, technical guidance, and training functions

  • Move inspectors toward risk‑based supervision and enforcement

Impact

  • Better use of limited inspection capacity

  • Higher inspection quality

  • Reduced burnout and inconsistency

Recommendation 3: Establish National OSH Professional and Service Accreditation System

Framework

  • Licensing/accreditation for:

    • OSH consultants

    • Trainers

    • Auditors

  • Codes of ethics and scope of practice

  • MLVT monitoring and sanctions

Impact

  • Builds national OSH expertise

  • Improves compliance support for enterprises

  • Protects MLVT authority and credibility

Recommendation 4: Introduce Tiered OSH Compliance Models

Approach

  • Different OSH compliance pathways for:

    • Large enterprises (full OSHMS)

    • SMEs (simplified OSHMS)

    • Informal enterprises (basic safety standards)

Tools

  • Special Prakas or Guidelines

  • Sector toolkits

  • Group‑based compliance via associations

Impact

  • Expands OSH coverage without lowering standards

  • Improves acceptance and practicality

Recommendation 5: Modernize OSH Data Systems and Integration

Actions

  • Digital accident and disease reporting

  • Integration with NSSF and health systems

  • Use data to guide inspections and policy priorities

Impact

  • Evidence‑based policymaking

  • Targeted enforcement

  • Measurable OSH outcomes

β–Ά Closing the Gaps: Strategic Outcome

If implemented together, these reforms will:

  • Expand MLVT’s effective regulatory reach without expanding bureaucracy

  • Transform OSH from reactive compliance to preventive systems

  • Enable safe economic growth and investor confidence

  • Position Cambodia as an emerging ASEAN OSH governance leader

β–Ά Suggested Next Steps for MLVT

  1. Establish an inter‑departmental OSH Reform Taskforce

  2. Draft concept notes for:

    • Standalone OSH Law

    • OSH professional accreditation

    • SME OSH compliance framework

  3. Pilot reforms in one high‑risk sector

  4. Engage ILO and development partners for technical support

Conclusion

Cambodia stands at a pivotal moment in OSH development. With the upcoming OSH Law, OSH‑MS rollout, and strengthened penalty frameworks, MLVT has a historic opportunity to build a modern, reliable, and internationally aligned OSH system.

The recommendations in this policy paper provide a roadmap for achieving that vision—protecting Cambodian workers, improving enterprise performance, and positioning Cambodia as a regional leader in workplace safety.

Relevant Regulatory References

Legal Title:

αž€αŸ’αžšαž˜αžšαžŠαŸ’αž‹αž”αŸ’αž”αžœαŸαžŽαžΈ αž†αŸ’αž“αžΆαŸ†αŸ’αŸ αŸ αŸ§

Civil Code (2007)

Ministry/Institution:

Ministry of Justice

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Legal Title:

αž…αŸ’αž”αžΆαž”αŸ‹αžŸαŸ’αžαžΈαž–αžΈαž€αžΆαžšαž„αžΆαžš αž†αŸ’αž“αžΆαŸ†αŸ‘αŸ©αŸ©αŸ§

Cambodian Labor Law (1997)

Ministry/Institution:

Ministry of Labour and Vocational Training

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