OHC setup requirements in India: a state-by-state checklist for employers

An occupational health centre (OHC) is the medical room, team and record system that looks after workers' health at a factory, plant or large site. In India the duty to provide one comes from central labour law and, in practice, from the factory rules each state writes under it. That is why two plants owned by the same company, with similar headcounts, can face different OHC requirements in Maharashtra and Gujarat.

This guide gives employers a practical way to work out what applies to them. It does not replace legal advice: the rules change, and the deciding details — your process, headcount and whether the process is classed as hazardous — are specific to each site. Wherever specifics vary, consult the applicable state rules. For help with setup and staffing, see our occupational health centre (OHC) setup services.

Why OHC requirements vary by state

Central law sets the framework for health, safety and welfare at factories, and the newer labour codes are reshaping it. States then issue their own factory rules that specify details such as when an OHC or ambulance room is needed, what it must contain, the qualifications of medical staff and the records to keep. States also notify which processes count as hazardous, and those processes usually carry stricter medical requirements.

Because of this layering, the safest approach is to start from your state's current factory rules and any notifications from the state factory inspectorate, then check whether the labour codes have changed anything that applies to you.

The questions that decide your obligations

• How many workers are employed at the site, counting contract workers and all shifts?
• Does the site run any process notified as hazardous in your state?
• Which state's factory rules apply, and have they been updated recently?
• Are there additional conditions in your factory licence, consent orders or customer audit standards?
• Does your industry have its own regulator with medical requirements (for example mines, ports or petroleum)?

Write the answers down for each site. They become the basis of your OHC scope and the first thing an inspector or auditor will ask about.

A state-by-state checking routine

Rather than relying on a summary table that may go out of date, use the same routine for every state you operate in:

1. Get the current rules

Download the latest factory rules from the state labour or factories department website, along with any amendments and circulars. Note the date you checked.

2. Find the medical provisions

Look for the sections on ambulance rooms, occupational health centres, first aid, medical examination of workers and hazardous processes. Note the headcount triggers, staffing, equipment and record requirements in your own words.

3. Map them to your site

Compare each requirement with your headcount and processes. Mark what you already meet, what is partly met and what is missing.

4. Confirm with the inspectorate or an advisor

Where wording is unclear, ask the inspectorate or a qualified advisor. Keep the written answer on file.

5. Review every year

Re-run the routine annually and whenever you add shifts, processes or a large contract workforce.

Groups with plants in several states — say Maharashtra, Gujarat and Tamil Nadu — benefit from keeping one comparison sheet so differences are visible at a glance.

What a typical OHC includes

Exact requirements differ, but most OHC setups cover the same building blocks:

• Space: a clean room with an examination area, privacy, handwashing and, often, a rest or observation bed
• Staff: a qualified medical officer (an MBBS doctor, with occupational health qualification such as AFIH where the rules or process require it) and trained nurses or attendants by shift — see our OHC doctor and nurse services
• Equipment and medicines: emergency kit, oxygen, stretcher, BP apparatus, glucometer and an essential medicines list suited to your hazards
• Ambulance arrangement: an own or contracted ambulance with a hospital tie-up — see ambulance services for factories and construction sites
• Records: medical examination records, injury and visit registers, and medicine and equipment logs
• Biomedical waste: segregation and disposal through an authorised facility — see biomedical waste management

Common gaps we see during OHC reviews

• Night shifts without a nurse or trained first-aider, even though the day shift is covered
• Contract workers left out of periodic medical examinations
• Paper registers that are incomplete or cannot be found during an inspection
• Expired medicines and unserviced equipment
• No written emergency plan linking the OHC, ambulance and nearest hospital

Most of these are inexpensive to fix once they are visible, which is why a structured gap review is worth doing before an inspection, not after.

Setting up or upgrading your OHC

Start with a site walk-through and the checklist above, then decide which parts to run in-house and which to outsource. Many companies keep the OHC room and records in-house but contract doctors, nurses, ambulance cover and waste disposal. A digital occupational health centre can keep registers and fitness certificates searchable across sites.

For related reading, see our OHC setup checklist and the guide to OHC requirements under the Factories Act and OSH Code.

Plan My Health sets up and staffs OHCs for factories and sites across India. Request a proposal and we will start with a gap review of your site.