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Under Indonesia's Government Regulation No. 50 of 2012 (PP 50/2012), a company must implement SMK3, the national occupational safety and health management system, if it employs at least 100 people or has a high hazard potential. Implementation is assessed through an audit of 12 elements; at each level the auditor checks 64, 122 or 166 criteria. Part of that audit concerns occupational health: health requirements for job placement, first aid, work environment measurement, medical examinations and occupational health services. Almost all of these are checked from the entry level, yet the evidence usually sits with three different owners on site: HR, HSE and the clinic.
This article is for managers and HSE teams preparing an SMK3 audit at a mine, smelter, plantation or construction project in Indonesia.
Who has to implement SMK3?
Article 5 of PP 50/2012 requires every company to implement SMK3, and paragraph (2) says the obligation applies to companies that employ at least 100 workers or have a high level of hazard potential. The elucidation defines high hazard potential as hazards that could cause accidents harming human life, disrupting production or polluting the work environment. A workforce below 100 therefore does not exempt a company on its own.
At the time of writing (late September 2026), the Ministry of Manpower's JDIH portal still lists PP 50/2012 as in force.
Mineral and coal mining also has its own system, SMKP Minerba. Its guideline is in Attachment IV of Minister of Energy and Mineral Resources Decree No. 1827 K/30/MEM/2018 and covers holders of IUP and IUPK mining licences, mining service companies, and production operation IUPs dedicated to processing and/or refining. This article covers SMK3 under PP 50/2012 only. How the two systems are checked at your site is best confirmed with the mine inspector.
How are SMK3 and its assessment structured?
Attachment I splits implementation into five stages: setting the OHS policy, OHS planning, carrying out the plan, monitoring and evaluating performance, and reviewing and improving the system. Assessment is governed by Article 16(3) and Attachment II, which set out 12 audit elements.
Table 1 of Attachment II groups the criteria into three cumulative levels:
| Level | Criteria | Scope |
|---|---|---|
| Initial (awal) | 64 | Column 3 of Table 1 |
| Transition (transisi) | 122 | Initial criteria plus column 4 |
| Advanced (lanjutan) | 166 | All criteria, including column 5 |
The result is a compliance percentage: 0 to 59 percent is rated insufficient, 60 to 84 percent good, and 85 to 100 percent satisfactory. Findings are also classed as critical, major or minor. Failing to meet a statutory requirement counts as a major finding, and a company with a critical or major finding is judged not to have implemented SMK3 successfully. Minister of Manpower Regulation No. 26 of 2014 sets correction deadlines of 1x24 hours for critical findings and one month for major findings (Articles 26 and 27).
Which occupational health criteria do auditors check?
Many health criteria in Attachment II end with "in accordance with laws and regulations". If the underlying rule is not met, the finding can be classed as major. The table below lists the criteria that concern workers' health and their level in Table 1.ld practice, not the regulation.
| Criterion | What is assessed | Level |
|---|---|---|
| 6.3.1 | Health requirements for each task are used in selection and placement | Initial |
| 6.8.1 | First aid equipment is evaluated and the first aid system meets the rules | Initial |
| 6.8.2 | First aid officers are trained and appointed | Initial |
| 7.2.1 to 7.2.3 | The work environment (physical, chemical, biological, ergonomic, psychological) is measured regularly by competent parties and the results are used | Initial |
| 7.4.1 | Health of workers in high-hazard workplaces is monitored | Initial |
| 7.4.2 | Situations requiring medical examination are identified and a system supports them | Transition |
| 7.4.3 | Examinations are carried out by an appointed examining doctor | Initial |
| 7.4.4 | The company provides occupational health services | Initial |
| 7.4.5 | Health monitoring records are kept as required | Initial |
| 10.1.4 | Records of accident compensation and health rehabilitation are maintained | Advanced |
The second table shows the evidence usually prepared for each criterion and who holds it on site. It reflects our field practice, not the text of the regulation.
| Criterion | Evidence usually prepared | Owner on site |
|---|---|---|
| 6.3.1 | Health requirements per position, pre-employment examination results | HR and company doctor |
| 6.8.1 | First aid box inventory and inspection records, box location map | HSE and clinic |
| 6.8.2 | Appointment letters, training certificates, first aid licences and logbooks | HSE and HR |
| 7.2.1 to 7.2.3 | Measurement reports, proof of the assessor's competence, follow-up records | HSE |
| 7.4.1 | Periodic and special medical check-up programme, list of workers by hazard | Clinic and HSE |
| 7.4.2 | Examination matrix by hazard and position, check-up schedule that follows the roster | Clinic and HR |
| 7.4.3 | Appointment letter for the examining doctor | Management and clinic |
| 7.4.4 | Clinic operating documents or service contract, occupational health service reports | Management and clinic |
| 7.4.5 | Medical check-up records, summaries by hazard group | Clinic |
| 10.1.4 | Work accident claim records, rehabilitation and return-to-work records | HR and clinic |
Ten of the criteria in the first table are among the 64 initial-level criteria, so even a company facing its first audit will be asked about medical check-ups, the examining doctor, occupational health services and first aid. Periodic examination programmes are covered in our article on periodic medical check-ups for mine workers.
Which regulations sit behind those health criteria?
Attachment II does not name the regulations. The ones most often relied on are:
- Law No. 1 of 1970, Article 8. Paragraph (1) requires management to have the physical health, mental condition and physical ability of workers examined when they are hired or transferred. Paragraph (2), the basis of criterion 7.4.3, requires periodic examination of all workers by a doctor appointed by the employer and approved by the Director.
- PER.03/MEN/1982 on occupational health services, the basis of criterion 7.4.4. Article 4 lets a company run the service itself, contract a doctor or another health service, or share a service with other companies. Article 7(1) requires management to report on the service to the Director.
- PER.15/MEN/VIII/2008 on first aid, the reference for criteria 6.8.1 and 6.8.2. Article 2 requires employers to provide first aid officers and facilities, and Article 3 requires each officer to hold a licence and an activity logbook. Staffing numbers are covered in our article on workplace first aid officers, and box contents in first aid box contents under Indonesian rules.
The OHS committee (P2K3) is now governed by Minister of Manpower Regulation No. 13 of 2025. Article 9(2) gives the committee health duties: monitoring workplace nutrition and catering, developing occupational health services, and developing OHS laboratory work and evaluating workers' medical examination results. The committee's six-monthly report to the Head of the Provincial Manpower Office also includes occupational health service activities (Article 11 and Attachment). The site clinic doctor should therefore sit in on P2K3 meetings.
Emergency procedures: from first aider to hospital referral
Attachment I, section C, point 7 requires a procedure for accident and industrial emergencies that covers enough first aid personnel and facilities until the casualty receives medical help, plus a process for follow-up care. The procedure must be tested regularly by competent personnel. At a remote site, that means this chain:
- First aid officers in the work area, on every shift and at work units far from each other.
- A site clinic that stabilises the casualty, with medicines and consumables stocked against the actual delivery time to site.
- A referral route and transport to hospital, including alternatives when the road, sea or weather does not allow it.
- Recorded follow-up care and return to work, which also feeds criterion 10.1.4.
Test the chain in drills that include the clinic, on night shifts and across roster groups, because on a roster such as 10 weeks on and 2 weeks off the people on duty keep changing. Record the time from the incident to arrival at the clinic and at hospital as evidence of testing.
Who audits, and how often?
Article 16(1) says the assessment is carried out by an independent audit body appointed by the Minister at the company's request. Paragraph (2) requires companies with high hazard potential to be assessed, and its elucidation names mining and oil and gas as examples. Article 3(2) of Regulation 26/2014 sets out three routes to an external audit: a voluntary request, companies with high hazard potential such as mining and oil and gas, and companies designated as high hazard by the Director General or the head of the provincial manpower office.
PP 50/2012 does not require the external audit to be repeated every set number of years. What Regulation 26/2014 Article 30(7) does say is that the award, a silver or gold certificate or flag, is valid for at most three years. Internal audits must be periodic, with their frequency based on previous audit results and evidence of hazards at the workplace (Attachment I, section D).
PP 50/2012 also has no chapter on sanctions. Its six chapters cover general provisions, SMK3, assessment, supervision by labour inspectors, transitional provisions and closing provisions. For a company required to undergo an external audit that scores insufficient, Regulation 26/2014 Article 30(2) allows the Director General to take legal action.
Checklist for occupational health evidence
- Assign one owner and one file location to each criterion in the table above.
- Align the medical check-up schedule with the roster so that workers on leave are not missed.
- Make sure the examining doctor's appointment letter names the doctor currently on duty.
- Match the list of first aid officers per shift against their licences and logbooks.
- Keep medical records at the clinic, and prepare summaries for the auditor that do not reveal individual diagnoses.
Our OHS training prepares first aid officers and site teams through medical emergency drills scheduled around the roster, and our occupational health team helps put the medical examination evidence in order before the audit.
