OSHWC Code Compliance Checklist Under New Labour Code 2025

Working Hours Regulations

✓ Daily Working Hours Limits
The OSHWC Code strictly limits working hours:

• Maximum 48 hours per week (can extend to 60 hours with overtime)
• Maximum 9 hours per day (10 hours with overtime)
• Maximum 10 consecutive days without weekly off
  
  

Verification Points:

• Attendance registers show actual working hours
• Overtime tracked separately and documented
• No employee consistently exceeds limits
• Payroll reflects overtime hours accurately
  
  

Common Violation: A Worli-based consulting firm required employees to work 55 hours weekly without overtime compensation. During inspection, authorities imposed ₹85,000 penalty and ordered retrospective overtime payment—₹3.2 lakhs in arrears.

✓ Weekly Off Requirements

• Minimum 1 day off per week (typically Sunday, but can be alternative day)
• Cannot be refused or adjusted without genuine emergency
• If adjusted, compensatory off must be provided within the week
• Documentation required showing weekly off taken

Documentation Checklist:

• ☐ Weekly off schedule displayed
• ☐ Roster showing off-days for each employee
• ☐ Records of adjusted weekly offs with compensation
• ☐ Employee acknowledgment of weekly off policy
  
  

Leave Entitlements

✓ Earned Leave

• Minimum 1 day per month (up to 30 days annually)
• Accrued on pro-rata basis for part-month employment
• Can be accumulated (carried forward to next year with limits)
• Must be approved and recorded

✓ Sick Leave

• Minimum 5 days per year (many states provide more)
• Required for illness (medical certificate may be needed after 3 days)
• Cannot be forfeited if not taken

✓ Casual Leave

• Minimum 8 days per year (varies by establishment size)
• Can be taken as required with reasonable notice
• Documented in leave registers

✓ Special Leave Provisions

• Maternity leave: 26 weeks (before and after delivery)
• Paternity leave: 15 days
• Bereavement leave: 3-5 days (varies by relation)
• Marriage leave: 3 days
• Blood donation leave: 1 day

OSHWC Compliance in This Area:

• ☐ Leave policy document exists and is communicated
• ☐ Leave registers maintained (digital or physical)
• ☐ Leave balances calculated correctly
• ☐ No forced leave or unpaid leave deductions
• ☐ Maternity leave properly facilitated (especially in manufacturing units in Thane and Bhiwandi)

Workplace Safety Standards

✓ Physical Infrastructure Safety
For all establishments across Mumbai (BKC offices to Andheri MIDC factories):

Facilities Checklist:

• ☐ Adequate lighting (minimum lux levels as per work type)
• ☐ Proper ventilation (no stagnant air, hazardous fumes removed)
• ☐ Temperature control (not excessively hot/cold)
• ☐ Drinking water (potable, accessible, adequate quantity)
• ☐ Restrooms (separate for men/women, minimum 1 per 50 persons)
• ☐ Crèche (mandatory if 50+ women employed)
• ☐ Canteen (mandatory if 250+ employees)
• ☐ Seating arrangements (where appropriate for work)
• ☐ Flooring (non-slippery, free from hazards)

Real Scenario: A Mulund pharmaceutical company lacked adequate ventilation in production areas. During inspection, authorities identified hazardous air quality levels, imposed ₹1,50,000 penalty, and ordered facility closure until remediation.

✓ Safety Equipment and Training

• ☐ Personal Protective Equipment (PPE) provided free to all workers
• ☐ PPE appropriate for hazard type (gloves, helmets, masks, eye protection)
• ☐ PPE condition checked regularly and replaced when worn
• ☐ Safety training provided before equipment use
• ☐ Training certificates maintained

✓ Hazardous Work Restrictions
The OSHWC Code restricts certain work categories:

Young Persons (15-18 years):

• ☐ Not employed in hazardous processes
• ☐ Medical fitness certificate obtained before employment
• ☐ Special training provided
• ☐ Working hours limited to 6 hours per day

Women:

• ☐ Night shift work restricted (requires special approval)
• ☐ Hazardous work restricted (pregnancy-related dangers)
• ☐ Safety provisions in place for shift work

Persons with Disabilities:

• ☐ Work assigned considering disability type
• ☐ Reasonable accommodations provided
• ☐ Safety modifications implemented

Health and Sanitation Requirements

✓ First Aid Facilities

• ☐ First aid box with prescribed contents
• ☐ First aid trained person available (1 trained person per 50 employees)
• ☐ First aid box prominently displayed
• ☐ Contents checked monthly and replenished

✓ Medical Facilities

• ☐ Health examination records maintained (especially hazardous industries)
• ☐ Occupational health doctor available (for large establishments)
• ☐ Health insurance provided (PF/ESI coverage)
• ☐ Ergonomic assessments for desk jobs (increasingly required in Powai IT offices)

✓ Sanitation Standards

• ☐ Floors swept and cleaned daily
• ☐ Drainage systems functioning properly
• ☐ Waste disposal managed safely
• ☐ No accumulation of hazardous materials
• ☐ Pest control measures in place

✓ Accommodation Standards (if provided)

• ☐ Adequate space (minimum 5.5 sq meters per person)
• ☐ Adequate lighting and ventilation
• ☐ Sanitation facilities
• ☐ Drinking water supply
• ☐ Clean bedding and maintenance

Establishment-Specific OSHWC Compliance

Manufacturing Units (Andheri MIDC, Bhiwandi, Thane):
Additional requirements:

• ☐ Machinery safety guards installed
• ☐ Dangerous machinery inspection certificates
• ☐ Accident register maintained
• ☐ Safety committee constituted (if 250+ employees)
• ☐ Hazard assessment completed
• ☐ Emergency response procedures established

Construction Sites (CBD Belapur, Turbhe, Navi Mumbai):
Additional requirements:

• ☐ Site safety plan documented
• ☐ Scaffolding inspection certificates
• ☐ Fall protection systems installed
• ☐ Site safety officer appointed
• ☐ Daily safety briefings conducted
• ☐ Medical aid station available
• ☐ Accident reporting system

IT & Corporate Offices (BKC, Powai, Ghatkopar):
Additional requirements:

• ☐ Ergonomic desk setup standards
• ☐ Eye care facilities (for screen workers)
• ☐ Repetitive strain injury prevention
• ☐ Mental health support programs
• ☐ Work-from-home safety guidelines
• ☐ Fire safety compliance (evacuation drills)

Retail & Hospitality (Worli, Lower Parel, Dadar):
Additional requirements:

• ☐ Customer-related safety protocols
• ☐ Heavy lifting assistance (for retail stockroom)
• ☐ Burn prevention (hospitality kitchens)
• ☐ Slip and fall prevention measures
• ☐ Staff break area safety