INTRODUCTION India stands at a pivotal moment in its journey to protect the health, safety, and dignity of its workers. The Occupational Safety, Health and Working Conditions Code, 2020 (OSH Code) offers a historic opportunity to turn fragmented regulation into a coherent framework for safer, healthier workplaces—if India can match ambitious legislation with equally ambitious implementation.1,2 WHY OCCUPATIONAL HEALTH AND SAFETY IS A DEVELOPMENT IMPERATIVE Occupational injuries and diseases are not merely workplace issues; they are a development challenge that erodes productivity, household income, and national growth. Global estimates suggest that about 4% of global gross domestic product is lost annually due to occupational injuries and diseases, reflecting both direct medical costs and indirect losses from disability and premature death. For India, epidemiological estimates indicate tens of thousands of occupational fatalities and tens of millions of injuries each year, alongside a substantial burden of work-related diseases such as silicosis and byssinosis.3 Recent analyses underline that non-fatal occupational injuries in India remain a major contributor to disability-adjusted life years, with injury risks concentrated among informal workers in highrisk, lowprotection jobs. Yet official data capture only a fraction of the true burden: in 2021, a little over 2,800 non-fatal injuries were recorded in registered factories, far below what would be expected from population-level estimates. This under-reporting masks the real scale of harm and weakens public and political urgency for reform.4 Ensuring strong occupational health and safety (OHS) is therefore not a luxury addon to economic growth. It is a precondition for inclusive development, demographic dividend, and global competitiveness. THE PROMISE OF THE OCCUPATIONAL HEALTH AND SAFETY CODE: CONSOLIDATION WITH A HUMAN FACE The OSH Code 2020 consolidates and replaces 13 central labor laws—including the Factories Act, Mines Act, and various establishment-specific statutes—into a single, overarching framework for occupational safety, health and working conditions. This consolidation responds to longstanding criticism that India’s labor regime was excessively fragmented, inconsistent, and difficult to navigate for both employers and regulators.5 The infographic Figure 1, highlights three core purposes of the Code: consolidating multiple laws, ensuring uniform safety, health, and welfare standards, and providing better welfare facilities for all workers.2Figure 1: Occupational Safety, Health and Working Conditions Code, 2020These goals are reflected in provisions that: Introduce a unified, electronic registration system for establishments, simplifying compliance and enabling better oversight. Standardize core safety, health, and welfare measures across sectors, including requirements for safe work environments, adequate ventilation, sanitation, drinking water, first aid, and canteen facilities in larger establishments. Mandate periodic health examinations for workers in notified categories, annual health checkups in certain cases, and special protections for workers exposed to hazardous processes or working in highrisk sectors such as mines and docks. The Code also formalizes maximum working hours—generally capping weekly hours at 48, with safeguards around overtime—and provides for rest intervals and leave, thereby reinforcing the idea that decent work must safeguard both physical and mental wellbeing. In principle, these reforms can generate a triple win: safer workplaces for workers, greater regulatory clarity for employers, and more efficient enforcement for the state. EXTENDING THE SAFETY NET: INCLUSIONS, EXCLUSIONS AND THE UNORGANIZED MAJORITY One of the most promising aspects highlighted in the infographic is the Code’s broader applicability. It covers all establishments with 10 or more workers, and explicitly references contract, migrant, and unorganized workers, alongside gig and platform workers, signaling an intent to move beyond the narrow confines of the traditional factory. For India’s evolving labor market—marked by platform-mediated work, layered subcontracting and mass migration—this recognition is long overdue.6 The Code also provides a framework for interstate migrant workers, aiming to formalize registration, portability of benefits and better oversight of contractor practices. In a country where migrant workers bore the brunt of the COVID19 lockdown and frequently face exploitative and unsafe conditions, this is ethically, and economically significant. However, serious gaps remain. Estimates suggest that close to 90% of India’s workforce is in informal employment, much of it in microenterprises, agriculture, homebased work, and other settings that fall outside the 10worker threshold or escape formal registration altogether. This means that, despite its progressive language, the Code may leave most workers with limited practical protection unless complementary strategies are adopted.4 Critics also argue that raising thresholds for factories and certain establishments effectively dilutes oversight for small units, where safety practices are often weakest and workers most vulnerable. Any editorial assessment of India’s OHS trajectory must therefore ask whether legal rationalization is inadvertently deepening a twotier system: modern, compliant workplaces for the organized minority and hazardous, unregulated environments for the rest.7 IMPLEMENTATION: FROM PAPER TO PRACTICE The OSH Code formally came into effect in November 2025, but its impact will depend heavily on how states draft and enforce their rules. Early signs point to a patchwork rollout. Only a handful of states have notified detailed rules, while many others remain in various stages of drafting or consultation. This uneven adoption risks undermining the Code’s core promise of national uniformity.5,8 Multiple implementation challenges are already evident: Administrative capacity: State labor departments often operate with limited staffing, weak technical expertise in occupational hygiene, and under-developed digital infrastructure, which constrain proactive inspections and data-driven enforcement. Inspectorcumfacilitator model: The Code seeks to move away from the old “inspector raj” mindset towards a more facilitative, riskbased inspection regime, supported by electronic filings and randomized inspections. While conceptually sound, this model demands robust training, transparent algorithms, and safeguards against regulatory capture—conditions that are not yet uniformly present. Data and surveillance gaps: As current injury and disease data show, India lacks a comprehensive, integrated OHS surveillance system. Underreporting is rampant, especially in informal and subcontracted settings. Without reliable data, risk prioritization, policy evaluation and resource allocation remain guesswork. If “strengthening OHS” is the objective, then passing codes is only the first step. India now needs an implementation mission that treats OHS as seriously as other flagship national initiatives. ALIGNING INCENTIVES: WHY EMPLOYERS SHOULD EMBRACE, NOT RESIST, THE CODE The infographic depicts that the OSH Code offers benefits to employers as well as workers: clearer compliance rules, reduced paperwork through consolidated registration and returns, and potentially fewer fines for minor violations when corrective action is taken. At a deeper level, robust OHS is a strategic investment in business continuity and reputation. Evidence from global and Indian literature shows that effective safety and health programs reduce absenteeism, equipment downtime, and compensation claims, while improving morale, retention, and productivity. For export oriented sectors, adherence to modern OHS standards is increasingly a prerequisite for integration into international supply chains and ESGconscious capital flows. Conversely, serious accidents can trigger production stoppages, legal liabilities, reputational damage, and investor flight. The Code also introduces stronger penalties for serious contraventions, including imprisonment and substantial fines, with courts empowered to direct a portion of fines as compensation to victims or their families. For responsible employers, these sanctions level the playing field by discouraging “race to the bottom” costcutting through unsafe practices. India’s corporate sector would therefore do well to go beyond minimal statutory compliance. Boardlevel oversight of OHS, integration of safety indicators into ESG reporting, and adoption of international standards such as ISO 45001 can turn legal compliance into competitive advantage. WORKERS’ VOICE, TRAINING AND A CULTURE OF PREVENTION The OSH Code embeds worker participation in safety governance by providing for safety committees and safety officers in larger establishments and highrisk sectors. This is a welcome recognition that safety is not a topdown checklist but a continuous dialogue about risks, nearmisses and process improvement. Yet formal committees will only be effective if workers are trained, empowered, and protected from retaliation when they raise concerns. The Code allows workers to report imminent danger to employers and, if unsatisfied, to the inspectorcumfacilitator, and mandates that they not willfully endanger themselves or others or misuse safety equipment. In practice, active worker participation requires: Basic OHS training as part of induction, refreshed periodically and adapted to literacy levels. Clear, anonymous channels for reporting hazards and nearmisses, integrated into management systems. Union engagement or worker representatives in sectors with weak collective bargaining, particularly for contract and gig workers. International experience shows that a “culture of prevention”—where every worker sees safety as part of their job and every supervisor is accountable for hazard control—yields far better outcomes than rulebooks alone. India’s OHS reforms should therefore be accompanied by national campaigns, sector specific toolkits and training collaborations with professional bodies and academic institutions.3 REACHING THE UNREACHED: UNORGANIZED, MIGRANT, AND PLATFORM WORKERS The strongest critique of India’s OHS landscape remains its limited reach into the unorganized sector. Literature consistently reports that occupational health services are virtually nonexistent for most informal workers, despite high exposure to chemicals, dust, noise, ergonomic strain, and psychosocial stress. Construction workers, wastepickers, homebased garment workers, smallscale miners, agricultural laborers, and domestic workers continue to face unsafe conditions with minimal regulatory presence.4 The OSH Code’s references to unorganized, migrant and gig workers must therefore be operationalized through concrete measures: Integration of OHS into the broader social security and welfare architecture for informal workers, including those registered on national or state level worker portals. State and municipal level programs for highrisk informal sectors, combining training, provision of personal protective equipment, and incentives for safer technologies. Specific standards and responsibilities for platform companies with respect to the safety of delivery workers, drivers, and other gig workers, including during travel and interactions with clients. Partnerships with worker organizations, NGOs, and local governments to extend OHS awareness, reporting mechanisms, and basic services into informal clusters. The pandemic has already demonstrated the systemic risks of neglecting migrant and informal workers. A resilient, inclusive OHS system must consciously priorities these groups. A ROADMAP FOR STRENGTHENING OCCUPATIONAL HEALTH AND SAFETY IN INDIA To translate legislative intent into tangible improvements, India needs a multipronged strategy built around the principles reflected in the infographic Figure 1—safer workplaces, better welfare, and shared benefits for workers and employers. Five priorities stand out. Build a national OHS mission and surveillance system A dedicated national mission on occupational safety and health, with clear targets, financing and accountability structures, can coordinate efforts across ministries, states, and sectors. A modern, digital OHS surveillance system—integrating employer reports, hospital and insurance data, and targeted surveys—should be established to capture injuries, diseases and nearmisses across both formal and informal settings. Transparent, regularly published data will help drive policy, public awareness, and corporate responsibility Strengthen state capacity and inspectorates State labor departments require investment in staffing, training, laboratories, and technology. Riskbased inspection algorithms should be publicly documented and periodically audited to ensure fairness and effectiveness. Inspectors should be trained not only in legal provisions but also in occupational hygiene, ergonomics, and participatory risk assessment. Collaboration with academic institutions can help create a cadre of occupational health professionals Embed OHS into ESG, CSR and board governance: Regulators and stock exchanges can encourage or mandate disclosure of OHS indicators—such as injury rates, nearmiss reporting, and coverage of safety training—as part of ESG reporting frameworks. Corporate social responsibility funds can support capacity building for supplychain partners and informal sector projects. Boards should explicitly treat OHS as a strategic risk and require periodic independent audits Invest in education, research, and innovation: India needs to integrate its curriculum across medical, engineering and management to support occupational safety, occupational health physicians, and nurses. Research funding should priorities neglected issues such as informal sector exposures, gender and OHS, mental health at work, and technologyenabled safety solutions Empower workers and communities: Worker education campaigns, grievance redress platforms, and legal aid can help workers assert their rights under the OSH Code. Communitybased monitoring, involving panchayats and urban local bodies, can support enforcement in highrisk clusters. Public recognition for exemplary workplaces—through awards, certifications, and media coverage—can create positive competitive pressure.9 CONCLUSION: FROM CODE TO CULTURE The OSH Code 2020 represents a significant legal milestone, consolidating 13 central enactments, promising safer and healthier workplaces, and laying out a more streamlined, technologyenabled compliance regime. The attached infographic Figure 1 captures its core message succinctly: better safety standards, improved welfare amenities, and clearer responsibilities for both employers and workers. But codes do not prevent accidents; cultures do. Strengthening OHS in India will require moving beyond a mindset of minimum compliance towards a shared ethic of prevention, justice, and respect for human life. That means investing in data and institutions, extending protections to the unorganized and gig workforce, and embedding OHS in corporate strategy and public policy alike. If India can rise to this challenge, the dividends will be profound: fewer families pushed into poverty by preventable injury, a healthier and more productive workforce, and a global reputation as a country that values not just the growth of its economy, but the safety and dignity of those who build it. Financial support and sponsorship Nil. Conflicts of interest There are no conflicts of interest.
Rajgopal Thirumalai (Thu,) studied this question.