CONSTRUCTION SAFETY IN JAPAN AND MALAYSIA: A COMPARATIVE STUDY OF REGULATORY SYSTEMS AND ON-SITE IMPLEMENTATION

Abstract

The construction industry remains one of the most hazardous sectors worldwide, with high rates of occupational accidents and fatalities in both developed and developing countries. Although construction safety in Japan and Malaysia has been examined separately, limited comparative research has systematically examined how differences in regulatory implementation, safety management systems, and on-site practices relate to safety outcomes. This study compares construction occupational safety governance and management practices in Japan and Malaysia, focusing on accident trends, fatality types, regulatory frameworks, contractor responsibilities, safety management systems, and worker training. A comparative documentary analysis was conducted using occupational safety statistics, legislation, regulatory guidelines, government reports, and peer-reviewed literature. Given differences in accident definitions, reporting systems, classification practices, and data completeness, the analysis emphasises relative trends and proportions rather than direct comparison of absolute accident numbers. The findings indicate that both countries have broadly similar regulatory principles and major categories of fatal construction accidents, with falls from height emerging as a prominent category. However, differences are more evident at the implementation level. From a macro perspective, both countries have established formal legal and institutional frameworks for construction occupational safety. At the micro level, Japan demonstrates a more systematic and proactive approach through detailed operational guidelines, structured safety training, continuous improvement mechanisms, and stronger integration of safety responsibilities into contractor management. In contrast, Malaysia remains comparatively compliance-oriented, with greater challenges in consistent implementation, structured training, and workforce competency, particularly among foreign workers. The findings suggest that Japan’s sustained improvement in construction safety performance is associated with the integration of regulatory requirements with practical code of conduct that guide on-site safety behaviour and decision-making. The study highlights the importance of strengthening implementation mechanisms, safety education, and industry-led initiatives to improve construction safety outcomes in Malaysia and other rapidly developing countries.