At 250 workers ordinarily employed under Tamil Nadu's 2022 draft OSH rules, or at fifty where the site runs a hazardous process or handles hazardous substances. The OSH (Central) Rules 2026 set 500. The committee has equal management and worker members, meets every quarter, and the employer has fifteen days to act on its recommendations. The rules never say whether contract workers count; the Code's definition of worker suggests they do.
The thresholds
They depend on which rules govern the site. Section 22(1) of the OSH Code 2020 leaves it to the appropriate government to require a Safety Committee "in the prescribed manner", with at least as many worker representatives as employer representatives. For a Tamil Nadu factory the State is that government, and its 2022 draft rules set a lower bar than the Centre's.
| Rules | Safety Committee required where | Tenure |
|---|---|---|
| Tamil Nadu draft OSH Rules 2022, r.18 | 250 or more workers ordinarily employed; or 50 or more where a hazardous process or a dangerous operation is carried on; or 50 or more where a hazardous substance is handled | Two years |
| OSH (Central) Rules 2026, r.14 | 500 or more workers employed; the Centre may set other thresholds for classes of establishment | Three years |
The fifty-worker limbs are the ones sites miss. A plant of 120 that runs a process listed as hazardous under the Code, or handles a listed hazardous substance, needs a committee under the draft even though it is nowhere near 250 [VERIFY: whether Tamil Nadu's final OSH rules keep these thresholds]. Safety officers are a separate duty with separate numbers: section 22(2) requires them in factories of 500 or more workers, hazardous-process factories and building work of 250 or more, and mines of 100 or more.
Do contract workers count?
Probably, though neither set of rules says so. Both speak of "workers", and the OSH Code defines a worker as "any person employed in any establishment" to do manual, skilled, technical, operational, clerical or supervisory work "for hire or reward" (s.2(1)(zzl)). The definition excludes managers and supervisors drawing more than ₹18,000 a month, but says nothing about who pays the worker. A contract crew on the floor is employed in the establishment, and section 6(1)(h) makes a factory's employer responsible for the safety of everyone on the premises.
Where a provision is silent, the safer count is the wider one: everyone on site, direct and contract, less the managerial and higher-paid supervisory staff the definition leaves out. A site with 180 direct employees and 90 contract workers is past 250 on that count. Whether a particular site must constitute a committee on those numbers is a question for its counsel.
Who sits on it
Equal numbers from management and the workforce. Under the Tamil Nadu draft (r.19), the management side is a senior official as chairman, a safety officer where there is one, and a representative each from production, maintenance, human resources and purchase; the workers' side matches it in number, "as elected by the workers", with adequate representation of women. The Central rules (r.15) add a qualified medical practitioner where available, make the safety officer secretary, cap the committee at twenty, and have a negotiating union or council nominate the worker members, or the workers choose among themselves where there is none, with women represented at least in proportion to their share of the workforce.
Neither set of rules says whether contract workers vote or stand. On a floor where a third of the workforce is contract labour and the riskiest jobs, the loading, the cleaning, the maintenance shutdowns, are done by contract crews, a committee elected only by direct employees will miss the hazards it most needs to hear about. Including contract workers in the election is consistent with the definition of worker; how to do it on a given site is worth settling with counsel and the contractor.
What it does, and the fifteen-day clock
It reviews hazards and accidents, and the employer must act on what it recommends. The Tamil Nadu draft gives the committee the right to be informed of potential hazards and of accident data, and lists its duties: dealing with all matters of health, safety and environment, creating awareness, discussing safety audits, risk assessments and emergency plans, identifying causes of accidents, and reviewing whether its own recommendations have been carried out. Both sets of rules require the employer to take action on the committee's recommendations within fifteen days of receiving them.
The committee is also a route for individual workers. Section 14 of the OSH Code lets an employee raise inadequate safety provision with the employer directly or through a member of the Safety Committee. Where the employee reasonably fears imminent serious injury, death or danger to health, the worker can raise it the same way and must simultaneously tell the Inspector-cum-Facilitator; the employer then acts immediately and reports, or, if not satisfied the danger exists, refers the matter to the inspector, whose decision is final (s.14(2)–(4)).
What a site should do
- Count the whole floor. Direct and contract workers ordinarily employed, against 250, and against fifty if any process or substance on site is hazardous.
- Give contract crews a voice on the committee. A seat in the election at least, and an invitation to the contractor's site supervisor for the items that concern the crew's work.
- Keep minutes and a recommendation log. The Tamil Nadu draft has the minutes produced to the Inspector-cum-Facilitator on demand, and the log is what shows the fifteen-day clock was met.
- Feed it the accident data. Including the contract crew's near-misses and injuries, which are the ones most often left out of the site's own figures.
How Velura Services helps
We nominate representatives from our crew to your safety committee where your structure provides for them, and our supervisors attend its meetings. Issues the committee raises about our crew, such as training, PPE or rosters, are closed out by our team and reported back to you.
Sources
- Occupational Safety, Health and Working Conditions Code, 2020 (Act 37 of 2020), Gazette text hosted by DGFASLI — s.2(1)(zzl) (worker; the ₹18,000 supervisory limit), s.6(1)(h) (responsibility for all persons on the premises), s.14 (right to represent through a member of the Safety Committee; imminent danger), s.22(1) (Safety Committee), s.22(2) (safety officers). Opened and read.
- Occupational Safety, Health and Working Conditions (Tamil Nadu) Rules, 2022 (draft), G.O. Ms. No. 38, 11 April 2022 — r.18 (thresholds of 250, and of 50 for hazardous processes, dangerous operations and hazardous substances; two-year tenure; quarterly meetings; fifteen days to act on recommendations), r.19 (composition; workers' representatives elected; minutes; right to information; functions). Opened and read. Draft only.
- Occupational Safety, Health and Working Conditions (Central) Rules, 2026, G.S.R. 345(E) dated 8 May 2026 — r.14 (500 workers; three-year tenure; quarterly meetings; fifteen days), r.15 (composition; cap of twenty; nomination by negotiating union or council; women's representation). Opened and read from a mirrored copy of the Gazette [VERIFY: against the e-Gazette original].