OHC Requirements Under the Factories Act: What Indian Factories Must Actually Provide

About this corporate wellness service

"Do we need an OHC?" is one of the most common compliance questions an Indian plant HR or EHS manager has to answer, and it is unusually hard to answer from the internet, because most of what is written about it quietly mixes up two different things: what the Factories Act, 1948 says, and what your state's Factories Rules say.

This guide separates them. It covers the obligations that sit in the central Act and apply to every factory in India, the ones that sit in state rules and therefore differ depending on where your plant is, and the practical questions - staffing, records, examinations - that determine whether an inspection goes well. It is written to be checked against the bare Act, not instead of it.

Program highlights

• What the central Factories Act, 1948 requires of every factory
• Why 'ambulance room' and 'Occupational Health Centre' are not the same term
• Medical examinations and health records for hazardous processes
• What varies by state - and how to find your own state's rule

The two obligations that are in the Act itself

Section 45 of the Factories Act, 1948 is the provision most people are reaching for. It requires every factory to provide and maintain first-aid boxes or cupboards at the rate of not less than one for every 150 workers ordinarily employed, each stocked with the prescribed contents, and each placed in the charge of a separate responsible person who holds a first-aid certificate recognised by the State Government and who is readily available during working hours.

The same section adds the threshold everyone quotes: in every factory where more than 500 workers are ordinarily employed, the occupier must provide and maintain an ambulance room of the prescribed size, containing the prescribed equipment, in the charge of the prescribed medical and nursing staff, available at all times during working hours. Note the phrasing carefully - 'ordinarily employed', which is about your normal complement rather than a headcount on any single day, and 'prescribed', which is the Act handing the specifics to the state.

Those two are the floor. They apply to a factory regardless of what it makes. Everything more detailed than that - the size of the room, the equipment list, the qualification of the doctor, how often that doctor must attend - is prescribed elsewhere.

Why 'ambulance room' and 'OHC' are different words

The central Act says 'ambulance room'. The term 'Occupational Health Centre' comes from the state Factories Rules, where it is used for the facility required of factories carrying on hazardous processes - a facility with a wider brief than first aid, covering pre-employment and periodical medical examinations, exposure monitoring and health records.

In everyday use the two names have collapsed into one, and that is where confusion starts. A 600-worker packaging plant with no hazardous process has an ambulance-room obligation under Section 45. A smaller plant running a process listed in the Act's First Schedule can have an OHC obligation with a Factory Medical Officer attached to it, at a headcount well below 500. The two questions - how many workers, and what process - have to be asked separately, because they trigger different rules.

Hazardous processes: examinations, records and access

Section 41C sets out the occupier's specific responsibilities where a hazardous process is carried on. Three of them shape what an OHC actually does day to day.

First, medical examination. Every worker must be examined before being assigned to a job involving handling of or work with a hazardous substance, at intervals not exceeding twelve months while they continue in that job, and after they cease to work in it. That last one is the obligation most often missed, and it is the one that matters most to the worker.

Second, health records. The occupier must maintain accurate and up-to-date medical records of workers exposed to chemical, toxic or otherwise harmful substances handled, stored or transported in the factory. Third, those records must be accessible to the workers themselves, subject to the conditions prescribed. A health register that the workforce cannot see does not satisfy the section.

What the examinations should consist of follows from the exposure rather than from a generic package: audiometry where there is noise, spirometry and chest imaging where there is dust or fume, vision testing for visual tasks, and biological monitoring where a specific agent has an established indicator. A blanket annual health check bought as a benefit is not the same thing as an occupational examination, and an inspector will read them differently.

What your state's rules decide, and why you have to read them

Section 112 of the Act gives State Governments the power to make rules, and OHC specifics are made there. That is not a technicality - it is the single biggest reason generic advice about OHCs is unreliable. The room's minimum floor area, its equipment schedule, whether the Factory Medical Officer must be full-time or part-time and at what headcount, how many nurses and dressers, the format of the health register and how long it must be kept: all of that is a state question, and the answers genuinely differ between, say, Maharashtra, Gujarat, Tamil Nadu, Karnataka and Haryana.

So the correct starting point is never 'what does the internet say a factory needs' but 'what do the Factories Rules of my state say, for my headcount and my process'. If your company runs plants in more than one state, expect the answer to be different at each of them, and expect the strictest one to be the sensible internal standard.

Two related provisions are worth checking at the same time. Section 40B requires a Safety Officer where 1,000 or more workers are ordinarily employed, and in factories carrying on notified hazardous processes - a different role from the medical one, frequently conflated with it. Section 41F sets permissible limits of exposure for the chemical and toxic substances in the Act's Second Schedule, which is what your monitoring programme has to measure against.

Staffing an OHC in practice

A Factory Medical Officer is not simply any doctor. State rules generally require a registered medical practitioner with a recognised qualification in industrial or occupational health - the Associate Fellow of Industrial Health (AFIH) certification being the usual route in India - and the requirement tightens for hazardous-process factories. Recruiting for it is harder than most plants expect, and it is the item most likely to be outstanding when an inspection arrives.

Around that sit the roles that make the centre work on an ordinary day: a qualified nurse, a dresser or first-aid attendant per shift, and enough certified first-aiders spread across the floor to satisfy Section 45's one-per-box requirement on every shift, not just the day shift. Shift coverage is where paper compliance and real compliance separate, because a centre staffed only from nine to five in a plant running three shifts is neither.

The other practical dependency is ambulance access. Section 45's ambulance room is a room; it is not a vehicle. Whether you need a vehicle on site, on call, or under a tie-up with a nearby hospital is a function of your hazard profile and how far you are from definitive care - and it is a decision worth documenting alongside the on-site emergency plan required under Section 41B.

What an inspection actually looks at

In practice, inspections turn less on whether a room exists and more on whether the paperwork behind it is alive. The recurring findings are the same across plants: first-aid boxes stocked but with expired contents; a first-aid certificate holder named for a box on a shift they no longer work; periodical examinations run eighteen months apart rather than twelve; health records complete for current employees and missing for leavers; and an emergency plan that has never been rehearsed.

None of those require capital expenditure to fix. They require an owner, a calendar and a register that somebody actually maintains - which is the argument for treating the OHC as an ongoing service rather than a one-time build.

A note on the OSH Code, 2020

The Occupational Safety, Health and Working Conditions Code, 2020 consolidates the Factories Act and several other labour statutes, and carries forward obligations of the same shape - welfare facilities, medical examinations, and safety officers - into a single instrument, with the detail again left to rules.

Commencement has been staggered, and both central and state rules have moved at different speeds. Before you plan a compliance programme around either instrument, confirm what is actually in force for your state on the date you are planning for. Until the Code is notified in force for you, the Factories Act and your state's Factories Rules are what applies - and the practical obligations above do not change either way.

Closing the gap

Most plants we are called into are not non-compliant on purpose. They have a room, they have a doctor visiting, and they have a register - and what they do not have is certainty that the combination matches their own state's rule at their own headcount, or the staffing depth to cover every shift.

Wellfinity 360 sets up Occupational Health Centres from scratch, staffs and runs them, supplies the software that keeps the health records and examination schedules current, and trains in-house teams to take over. If you want the specific answer for your plant rather than the general one in this guide, tell us the state, the headcount and the process, and we will map it against the rules that apply to you.

Frequently asked questions