OHC Requirements under the Factories Act and OSH Code: A Practical Guide

Most EHS managers know their plant needs medical facilities, but the exact trigger points — headcount, hazardous processes and state rules — are often unclear. This guide sets out the practical questions to answer before an inspection.

What the Factories Act, 1948 requires

Section 45 requires first aid appliances in every factory and, above a prescribed headcount, an ambulance room in the charge of qualified medical and nursing staff. The detail — the headcount threshold, room size, equipment and staff qualifications — is set by each state's factory rules. Section 41C adds duties for factories carrying out hazardous processes, including medical examinations of workers and maintenance of health records.

The OSH Code, 2020

The Occupational Safety, Health and Working Conditions Code, 2020 consolidates the Factories Act and several other laws. Its health provisions take practical effect as the central and state governments notify rules, so plants should track the rules in their own state rather than assume a single national standard.

A practical OHC checklist

• Confirm your headcount per shift and whether any process is listed as hazardous in your state
• Check the ambulance room and staffing requirement in your state factory rules
• Map equipment, medicines and first aid boxes against the rules
• Set up OPD, injury and medical examination registers
• Arrange ambulance cover and hospital referral tie-ups
• Plan biomedical waste handling under the BMW Rules, 2016

Outsourcing versus running it yourself

Many plants find it easier to outsource OHC setup and management, so recruitment, relief cover, medicine stock and registers sit with one accountable partner. Others keep their own doctor and outsource only nurses, ambulance or pharmacy management.

This article is general guidance, not legal advice. Requirements vary by state, process and headcount, so confirm the rules that apply to each site with your factory inspectorate or a qualified adviser.

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