Environmental, Health, and Safety (EHS) Framework for Chemical Cleaning Operations in Malaysian Semiconductor Manufacturing

The corrosive, toxic, flammable, or reactive properties in the cleaning chemicals used in semiconductor manufacturing can pose significant occupational safety, health, and environmental risks if not properly managed. 

Why EHS Matters in Cleaning Operations?

The semiconductor industry relies heavily on specialised cleaning agents to ensure the cleanliness and integrity of wafers, components, and manufacturing equipment. These cleaning agents are used throughout wafer fabrication, assembly, testing, and packaging processes to remove contaminants, residues, particles, flux residues, and oxides that could affect product quality and yield. Common semiconductor cleaning chemicals include isopropyl alcohol (IPA), acetone, hydrofluoric acid (HF), sulfuric acid, hydrogen peroxide, ammonium hydroxide, hydrochloric acid, and proprietary cleaning formulations.

Advanced cleaning solutions from ZESTRON are widely used within the semiconductor and electronics manufacturing industry for precision cleaning applications. Products such as VIGON®, HYDRON®, ATRON®, and ZESTRON® cleaning solutions are specifically designed to remove flux residues, solder pastes, adhesives, and process contaminants from electronic assemblies, semiconductor components, stencils, and maintenance equipment. While these products are formulated to improve cleaning efficiency and support environmentally responsible processes, proper handling and control measures are required in reference to the Safety Data Sheets (SDS) and workplace risk assessments.

The corrosive, toxic, flammable, or reactive properties in the cleaning chemicals used in semiconductor manufacturing can pose significant occupational safety, health, and environmental risks if not properly managed. In Malaysia, semiconductor manufacturers must comply with Environmental, Health and Safety (EHS) requirements enforced by the Department of Environment (DOE) and the Department of Occupational Safety and Health (DOSH) to ensure the protection of employees, facilities, and the environment.

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compliance & regulationsEnvironmental Compliance - Department of Environment Malaysia (DOE)

The Department of Environment Malaysia, also known as DOE or Jabatan Alam Sekitar, plays an important role in ensuring that industrial activities are carried out in an environmentally responsible manner. Industries are expected to comply with the Environmental Quality Act 1974 and all applicable environmental regulations to prevent pollution and protect public health and the environment.

Environmental legal compliance: Schedule Waste Management

In the Semiconductor manufacturing process, a wide range of chemical waste streams will be generated; therefore, strict compliance with the Environmental Quality Act 1974 and other applicable environmental regulations is mandatory. Effective schedule waste management practices are essential to ensure regulatory compliance, protect the environment, and safeguard public health.

Organisations are required to establish and maintain a comprehensive scheduled waste management program. Key requirements include the identification and classification of scheduled waste in accordance with regulatory guidelines, storage of waste in designated and approved areas, and proper labelling of waste containers to ensure traceability and safe handling. In addition, accurate waste inventory and tracking records must be maintained, while waste disposal activities should be conducted only through licensed Department of Environment (DOE) contractors. Disposal documentation, including consignment notes and related records, must also be retained for regulatory verification and auditing purposes.

Environmental legal compliance: Wastewater Management

Wastewater generated from semiconductor cleaning and manufacturing operations may contain various contaminants, including acids and alkalis, heavy metals, organic solvents, and fluorides. Appropriate wastewater treatment or disposal systems must be implemented to ensure that effluent discharge complies with applicable regulatory limits before being released into the environment.

 

Environmental legal compliance: Spill Prevention and Response

To minimize the risk of environmental contamination resulting from chemical spills, facilities should establish and maintain effective spill prevention and response measures. These measures include the installation of secondary containment systems for chemical storage and handling areas, development and implementation of chemical spill response procedures and emergency plans, provision of spill response equipment such as spill kits and neutralization materials, and the conduct of routine inspections and preventive maintenance programs to identify and mitigate potential spill risks.

These measures play a critical role in supporting environmental stewardship, operational sustainability, and compliance with regulatory obligations within the semiconductor industry.


Occupational Safety and Health Compliance

Department of Occupational Safety and Health (DOSH) expects industries in Malaysia to maintain a safe and healthy workplace by complying with applicable occupational safety and health legal requirements. This includes identifying and controlling workplace hazards, appointing competent persons where required, providing adequate training and supervision, managing chemical and machinery-related risks, reporting incidents, maintaining proper records, and cooperating with DOSH during inspections or enforcement activities.

The use of cleaning chemicals in semiconductor manufacturing is regulated under the Occupational Safety and Health Act 1994 (Act 514), as amended by the Occupational Safety and Health (Amendment) Act 2022, and the Occupational Safety and Health (Use and Standards of Exposure of Chemicals Hazardous to Health) Regulations 2000 (USECHH Regulations). These requirements oblige organizations to identify chemical hazards, assess occupational exposure risks, and implement appropriate control measures to protect employees from potential health effects arising from chemical exposure.

 


safety & health compliance: Chemical Health Risk Assessment (CHRA) & Exposure Control

Chemical Health Risk Assessment (CHRA) should be conducted by a Department of Occupational Safety and Health (DOSH)-registered assessor to evaluate chemical-related risks within the workplace. 

The assessment typically includes identifying chemical hazards in manufacturing processes, evaluating employee exposure levels, reviewing existing control measures, determining requirements for exposure monitoring and medical surveillance, and recommending risk-reduction measures.

The CHRA serves as a fundamental component of an organization's chemical management program and provides the basis for regulatory compliance and the implementation of effective risk control strategies.

 

safety & health compliance: Chemical Inventory and Documentation

Organisations are required to establish and maintain comprehensive chemical management documentation. Key records include a Chemical Register, current Safety Data Sheets (SDS), chemical approval and procurement records, exposure monitoring reports, medical surveillance records where applicable, and employee training records related to chemical safety.

In addition, all hazardous chemicals must be classified, labeled, and communicated in accordance with the Globally Harmonized System (GHS) requirements as stipulated under the Classification, Labelling and Safety Data Sheet of Hazardous Chemicals (CLASS) Regulations.

safety & health compliance: Engineering Controls and Exposure Prevention

Engineering controls represent the primary means of minimising employee exposure to hazardous cleaning chemicals and should be prioritised over administrative controls and personal protective equipment. Common engineering controls implemented within semiconductor manufacturing facilities include wet benches equipped with integrated exhaust systems, Local Exhaust Ventilation (LEV), chemical fume hoods, automated chemical dispensing systems, enclosed chemical delivery systems, chemical leak detection systems, and interlocked process equipment.

To ensure continued effectiveness, these control measures should be subject to regular inspection, testing, maintenance, and performance verification in accordance with applicable regulatory and industry requirements.

safety & health compliance: Personal Protective Equipment (PPE)

Personal Protective Equipment (PPE) should be selected based on the findings of the CHRA and the specific hazards associated with the chemicals being handled. Typical PPE requirements may include chemical-resistant gloves, chemical splash goggles, face shields, chemical-resistant aprons or protective suits, safety footwear, and respiratory protective equipment where necessary.

Employees should receive adequate training on the proper selection, use, limitations, storage, maintenance, and replacement of PPE to ensure effective protection against chemical exposure.

safety & health compliance: Chemical Exposure Monitoring and Medical Surveillance

Certain semiconductor cleaning chemicals may present inhalation, dermal absorption, or systemic health hazards. Where recommended by the CHRA, organizations should implement Chemical Exposure Monitoring (CEM) and Medical Surveillance programs to assess and manage employee health risks.

safety & health compliance: Chemical Exposure Monitoring (CEM)

Exposure monitoring may be required for chemicals commonly used in semiconductor manufacturing, including:

  • Isopropyl Alcohol (IPA)
  • Acetone
  • Hydrofluoric Acid (HF)
  • Ammonia
  • Hydrochloric Acid (HCl)
  • Sulfuric Acid vapours

Monitoring results should be evaluated against applicable Occupational Exposure Limits (OELs) to verify the effectiveness of existing control measures and ensure compliance with regulatory requirements.

safety & health compliance: Medical Surveillance

Medical surveillance may be recommended for employees who are routinely exposed to specific hazardous chemicals, particularly substances that pose respiratory, dermal, neurological, or systemic health risks. Such programs are intended to facilitate the early detection of adverse health effects, assess employee fitness for work, and support the ongoing effectiveness of workplace health protection measures.

Collectively, these occupational safety and health requirements form an essential framework for managing chemical risks, protecting employee well-being, and maintaining regulatory compliance within semiconductor manufacturing environments.

Conclusion

In conclusion, effective EHS management is essential for semiconductor cleaning agent users to ensure legal compliance, protect workers and prevent environmental pollution. Cleaning agents used in semiconductor and electronics manufacturing can support high-quality production and process efficiency, but they must be managed responsibly through proper chemical classification, risk assessment, exposure control, waste management and emergency preparedness.

By complying with DOE and DOSH requirements, maintaining accurate documentation, implementing suitable engineering controls, and ensuring employees are trained in safe chemical handling practices, organizations can reduce operational risks and strengthen their commitment to workplace safety, environmental protection and sustainable manufacturing.

A proactive EHS approach not only supports regulatory compliance but also promotes safer operations, responsible chemical use and long-term business continuity within the semiconductor industry.

 

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