Understanding the OSHWC Code under India’s Labour code: What Manufacturing HR Must Know

The Occupational Safety, Health and Working Conditions (OSHWC) Code, 2020 fundamentally reshapes how safety, health, and working conditions are governed in India’s manufacturing sector under the labour code reforms. For HR leaders, understanding its scope is essential—not just for compliance, but for building safer, more resilient workplaces.

What does OSHWC Code consolidates and replaces

The OSHWC Code brings together and replaces multiple legacy laws that earlier governed factories and hazardous workplaces, including the Factories Act, 1948 and other sector-specific safety legislations. This consolidation is a key pillar of the Labour code shift toward uniform, pan-India compliance.

By consolidating these into a single code, the government has created a uniform framework for occupational safety and health, reducing fragmentation while strengthening employer accountability.

Applicability thresholds for manufacturing units
The Code applies to manufacturing establishments based on workforce size and nature of operations. Factories employing the prescribed number of workers fall squarely under its provisions, with stricter requirements for units involved in hazardous processes. Importantly, applicability is no longer limited by contract type—coverage extends to permanent, fixed-term, and contract workers within manufacturing premises.

Pre vs post labour code reforms: What changed for manufacturing establishments

With Labour code implementation from 21 Nov 2025, compliance moves from state-led variance to standardized obligations.

Here is a short comparison of pre vs post labour code reform:

Core OSHWC compliance requirements for manufacturing HR

The Occupational Safety, Health and Working Conditions (OSHWC) Code significantly raises the bar for how manufacturing organizations manage safety, health, and working conditions. For HR leaders in manufacturing, compliance is no longer limited to factory audits or safety manuals—it requires structured systems, continuous monitoring, and documented execution.

Below are the three most critical compliance pillars manufacturing HR teams must operationalize under the OSHWC Code.

Workplace safety & hazard management

Manufacturing environments carry inherent risks, and the OSHWC Code places clear responsibility on employers to proactively identify, mitigate, and manage these hazards.

Key requirements include:

• Mandatory safety committees
  Establishments with 500 or more workers must constitute formal safety committees with equal representation of workers and management. These committees are responsible for monitoring safety practices, reviewing incidents, and recommending corrective actions.
• Hazard identification and control
  Employers must ensure the safe handling, storage, transport, and use of hazardous substances, including chemicals, gases, and flammable materials. This includes documented risk assessments and standard operating procedures (SOPs).
• Protective equipment and safety training
  Providing appropriate personal protective equipment (PPE) is compulsory, along with regular safety training for workers exposed to operational or chemical risks. Training must be role-specific and periodically refreshed.
• National safety standards for hazardous industries
  Manufacturing units involved in hazardous processes must comply with centrally prescribed safety standards issued under the OSHWC framework, replacing fragmented state-level norms with uniform benchmarks.

For HR, this means safety is no longer just an EHS function—it requires workforce communication, training tracking, committee coordination, and audit-ready documentation.

Preventive healthcare obligations

The OSHWC Code formally embeds preventive healthcare into employer responsibilities, making health monitoring a statutory requirement for manufacturing establishments.

Key obligations include:

• Free annual health check-ups for workers above 40
  Employers must provide employer-funded annual medical examinations for all employees aged 40 and above, irrespective of role or employment type.
• Mandatory health check-ups for hazardous roles (all ages)
  Workers engaged in hazardous processes must undergo periodic medical examinations, regardless of age, to detect occupational illnesses early.
• Medical facilities and first aid
  Manufacturing units must maintain adequate medical facilities, trained first-aid personnel, and emergency response systems proportional to workforce size and risk exposure.

HR teams must ensure these check-ups are not just offered, but actually conducted, tracked, and followed up—since “providing” healthcare under the OSHWC Code implies execution, not intent.

Working hours, overtime & rest

The OSHWC Code standardizes working time norms across states and industries, directly impacting shift planning and workforce scheduling in manufacturing.

Key provisions include:

• Working hour limits
  Normal working hours are capped at 8–12 hours per day, with a maximum of 48 hours per week, subject to government notifications and sector-specific rules.
• Overtime regulations
  Overtime must be consent-based and compensated at twice the ordinary wage rate, reinforcing worker protection and wage fairness.
• Mandatory rest and leave
  Employers must provide rest intervals, weekly offs, and statutory leave, ensuring adequate recovery time—especially critical in physically demanding manufacturing roles.

For HR, this requires accurate attendance tracking, overtime approvals, wage calculations, and clear communication to supervisors and workers to avoid inadvertent violations.

Manufacturing workforce categories covered under the OSHWC code

The Occupational Safety, Health and Working Conditions (OSHWC) Code adopts an inclusive approach to worker protection in manufacturing. It moves away from role-based or contractual distinctions and instead focuses on equal safety, health, and dignity at work—regardless of employment type or gender. For manufacturing HR teams, this means aligning policies and practices across all workforce categories, not just permanent shop-floor staff.

Fixed-term employees in manufacturing

Fixed-term employment is now formally recognised and regulated under the new labour framework, and the OSHWC Code ensures that safety and health protections apply on par with permanent workers.

Key provisions include:

• Equal wages and benefits
  Fixed-term employees are entitled to the same wages, working hours, leave, medical facilities, and social security benefits as permanent employees performing similar work.
• Gratuity after one year
  Unlike earlier rules, fixed-term employees become eligible for gratuity after completing one year of service, strengthening financial security for shorter-tenure workers.
• Full OSH protections
  All workplace safety measures—protective equipment, safety training, health check-ups, and accident reporting—must apply equally to fixed-term and permanent workers.

For HR, this requires eliminating parallel benefit structures and ensuring fixed-term workers are fully included in safety committees, medical programs, and compliance reporting.

Contract labour in manufacturing units

The OSHWC Code reinforces the accountability of manufacturing employers when engaging contract labour, particularly in high-risk and hazardous environments.

Key requirements include:

• Principal employer responsibility
  Even when labour is hired through contractors, the principal employer remains responsible for ensuring health, safety, and statutory welfare measures.
• Mandatory annual health check-ups
  Contract workers must be included in annual health check-up programs, especially those exposed to operational or chemical risks.
• Uniform safety standards
  The same safety norms—PPE, training, medical facilities, and emergency response—must apply to both direct and contract workers, eliminating dual standards on the shop floor.

HR teams must coordinate closely with contractors, monitor compliance, and maintain records to demonstrate that contract workers are not excluded from OSH protections.

Women workers in manufacturing

The OSHWC Code strengthens protections for women in manufacturing while expanding their participation across roles and shifts.

Key provisions include:

• Night shift work with consent
  Women are permitted to work night shifts with their consent, subject to compliance with prescribed safety and welfare conditions.
• Mandatory safety infrastructure
  Employers must provide CCTV surveillance, secure transport, adequate lighting, and trained security personnel to ensure a safe working environment.
• Equal pay and non-discriminatory roles
  The Code reinforces gender-neutral job roles and equal remuneration, preventing exclusion from specific functions purely on the basis of gender.

For manufacturing HR, this means updating shift policies, safety infrastructure, and grievance mechanisms to support women’s participation while meeting statutory safety standards.

Sector-specific OSHWC requirements relevant to manufacturing

The OSHWC Code recognises that manufacturing is not a single, uniform activity. Risk levels, operating conditions, and workforce exposure vary significantly across sectors. To address this, the Code introduces sector-specific obligations that manufacturing HR teams must factor into compliance planning—especially where operations intersect with hazardous processes, plantations, ports, or MSME classifications.

Hazardous industries within manufacturing

Manufacturing units engaged in hazardous processes—such as chemicals, pharmaceuticals, metals, mining-linked production, or heavy engineering—are subject to the most stringent OSHWC standards.

Key requirements include:

• Mandatory safety committees
  Establishments with 500 or more workers must constitute safety committees with worker representation to monitor hazards and preventive measures.
• National safety standards
  Compliance with centrally prescribed safety norms covering equipment, processes, exposure limits, emergency response, and accident reporting.
• Enhanced training and PPE
  Compulsory safety training, periodic drills, and employer-provided protective equipment for all exposed workers.

For HR, this means tighter documentation, regular audits, and continuous coordination with safety officers and line managers.

Plantation-linked manufacturing units

Manufacturing units linked to plantations—such as tea, coffee, rubber, or agro-processing facilities—carry additional responsibilities due to chemical exposure and environmental risks.

Key requirements include:

• Chemical safety protocols
  Safe handling, storage, and disposal of fertilizers, pesticides, and processing chemicals.
• Mandatory PPE
  Protective gear for workers exposed to chemicals, dust, or biological agents.
• Health surveillance
  Monitoring and medical support for workers exposed to long-term occupational health risks.

HR teams must ensure plantation-linked manufacturing workers are included in health check-ups, safety training, and exposure monitoring programs.

Dock-linked or export-oriented manufacturing

Manufacturing units operating in or around docks, ports, or export processing zones face specific OSHWC obligations due to extended shifts and physically demanding work.

Key requirements include:

• Adequate health facilities
  On-site or accessible medical and first-aid facilities to address injuries and fatigue-related risks.
• Overtime regulation
  Overtime must be consent-based and compensated at double wages, with clear records maintained.
• Working hours compliance
  Strict adherence to limits on daily and weekly working hours, especially during peak export cycles.

HR teams must balance production pressures with statutory limits on working time and rest, ensuring no dilution of worker protections.

MSME Manufacturing units

The OSHWC Code introduces simplified compliance mechanisms for MSME manufacturing establishments while retaining core worker protections.

Key provisions include:

• Simplified registrations and returns
  Reduced administrative burden through single registration, licensing, and return filings.
• Retained safety and health obligations
  Simplification does not dilute requirements around workplace safety, health check-ups, PPE, or working hours.
• Proportionate enforcement
  Supportive compliance approach through the Inspector-cum-Facilitator model.

For MSME HR teams, the focus should be on leveraging simplified processes while ensuring that safety, health, and welfare standards remain fully implemented on the shop floor.

HR Compliance checklist for manufacturing units under the OSHWC code

For manufacturing HR teams, OSHWC compliance is no longer a one-time audit exercise—it’s an ongoing operational discipline. The checklist below helps ensure readiness across safety, health, workforce parity, and documentation, while reducing administrative strain through digital enablement.

• Safety committees constituted and documented
  Ensure mandatory safety committees (where applicable) are formally constituted, roles defined, and meeting records maintained. Digital documentation platforms help store and retrieve records easily during facilitation visits.
• Annual health check-ups scheduled and tracked
  Free annual health check-ups for workers above 40—and mandatory screenings for hazardous roles—must be planned, completed, and recorded. Centralised dashboards make participation tracking and follow-ups easier at scale.
• PPE, safety training, and SOPs in place
  Confirm availability of protective equipment, regular safety training, and updated SOPs for hazardous processes. Digital learning and communication tools help ensure consistent coverage across shifts and locations.
• Working hours and overtime systems compliant
  Monitor daily and weekly hour limits, consent-based overtime, and double-wage payments through transparent, auditable systems that integrate attendance and payroll data.
• Women safety measures implemented
  Night-shift consent, CCTV coverage, transport arrangements, and security protocols must be clearly documented and communicated. Mobile-first communication ensures awareness and accessibility for all women workers.
• Contract and fixed-term worker parity ensured
  Verify equal wages, health coverage, social security eligibility, and OSH protections for contract and fixed-term workers. Unified benefit and engagement platforms help maintain parity without manual complexity.
• Digital records ready for inspection or facilitation visits
  Maintain up-to-date digital records for health check-ups, safety training, benefits access, and worker communication—enabling quick, transparent responses during Inspector-cum-Facilitator interactions.

How Xoxoday helps manufacturing HR leaders move from OSHWC compliance to workforce resilience

The Occupational Safety, Health and Working Conditions (OSHWC) Code sets clear statutory obligations for manufacturing organizations around workplace safety, health monitoring, welfare facilities, and working conditions. However, meeting regulatory requirements alone is no longer sufficient.

Manufacturing HR leaders today must also ensure that large, shift-based, and deskless workforces can easily access safety communication, health programs, benefits, and recognition—consistently and at scale. The real challenge lies in translating OSHWC mandates into everyday behavior, awareness, and engagement on the shop floor.

Xoxoday’s blue-collar workforce engagement solutions are designed to support this shift. By using mobile-first access, digital benefits, and recognition-led engagement, Xoxoday helps manufacturing organizations operationalize OSHWC requirements while strengthening workforce resilience, productivity, and retention.

1. Mobile-first access aligned with blue-collar workforce realities

Most blue-collar employees do not have regular access to laptops, corporate email IDs, or internal HR systems. Xoxoday Empuls addresses this by offering a mobile-first engagement experience built specifically for frontline and shop-floor workers.

Through a simple mobile interface, blue-collar employees can:

• Access rewards, benefits, and recognition without visiting HR offices.
• Receive important updates on safety, policies, shifts, and announcements in real time.
• View recognitions, incentives, and milestones transparently.
• Stay connected to the organization across plants, shifts, and job roles.

This ensures that engagement, communication, and benefits are portable, inclusive, and always accessible, supporting labour law expectations around equity and worker inclusion.

2. Easy access to employee benefits directly on WhatsApp

For blue-collar workers, WhatsApp is often the most trusted and frequently used digital channel. Empuls leverages this behavior through its Super Saver Bot, enabling workers to access and redeem benefits directly on WhatsApp—without downloading complex apps or navigating portals.

With WhatsApp-based access, employees can:

• Redeem vouchers and everyday savings benefits directly from chat
• Log in easily using their mobile phone number, removing credential friction
• Access benefits on the go—before or after shifts, during breaks, or from home
• Reduce dependency on supervisors or HR teams for basic benefit queries

This approach simplifies benefit adoption and ensures that statutory and non-statutory benefits are actually utilized, not just offered.

3. Multilingual support for inclusive workforce participation

Manufacturing and industrial workforces are linguistically diverse, often spanning multiple states, regions, and migrant populations. Language barriers frequently prevent effective safety communication, benefit understanding, and participation.

Empuls supports 20+ regional and global languages, enabling organizations to:

• Deliver safety messages, announcements, and recognition in local languages\
• Ensure workers fully understand benefits, policies, and initiatives
• Increase adoption of engagement programs across migrant and contract labour
• Create a more inclusive and respectful employee experience

Multilingual engagement ensures that no segment of the workforce is excluded, aligning with labour law principles of dignity, accessibility, and fairness.

4. Giving blue-collar workers a voice through eNPS and pulse surveys

Traditional feedback mechanisms rarely reach the shop floor. Empuls changes this by enabling eNPS and pulse surveys through a mobile-first, deskless engagement app, ensuring that blue-collar workers can share feedback easily and anonymously.

With Empuls, HR teams can:

·       Run regular pulse surveys to track morale, safety perception, and wellbeing

·       Capture eNPS feedback from frontline workers, not just corporate staff

·       Identify early warning signals around fatigue, disengagement, or attrition risk

·       Act on real insights to improve policies, communication, and working conditions

This creates a two-way engagement model where blue-collar employees are heard, not just managed, strengthening trust and long-term workforce stability.

5. Enabling compliance through practical, everyday engagement

As labour regulations place greater emphasis on worker welfare, safety, and inclusion, HR leaders need tools that work at ground level, not just in policy documents.

By combining mobile-first access, WhatsApp-based benefits, multilingual communication, and continuous feedback, Xoxoday helps organizations move from theoretical compliance to real, lived engagement for blue-collar workers—without adding operational complexity.

For manufacturing HR teams navigating this shift, deskless workforce engagement platforms provide a scalable foundation to support compliance, wellbeing, and retention—while building a more resilient frontline workforce.