The main objective of this study is to synthesize a composite of hydroxyapatite (HAp)-chitosan-polyvinyl alcohol (PVA) and to evaluate its uses as bone filler. An injectable bone substitute (IBS) material is a suspension of bone filler which applied by injection to fill the gaps caused by osteoporosis. A hydroxyapatite used as the composite's component was synthesized from Tutut shell. The composite was made by mixing hydroxyapatite, chitosan and PVA to homogeneous followed by irradiation with gamma rays at 20 kGy. The composite was characterized by FTIR analysis, XRD, SEM, viscosity test, and cytotoxicity assay. The FTIR analysis showed the bond formation between hydroxyapatite and chitosan, which later formed cross linkages by the addition of PVA. The viscosity of the composite was 36dPa. The cytotoxicity assay (MTT assay) showed that the suspension is not toxic because the cell viability value was obtained at more than 50%. As a conclusion, the composite of HAp from tutut shell-chitosan-PVA is suitable to be used as an injectable bone substitute.