Section 22(2) of the OSH Code 2020 requires safety officers in a factory ordinarily employing 500 or more workers, in a factory carrying on a hazardous process with 250 or more, and on a building or construction site with 250 or more. In a mine the trigger is 100. The number, qualifications and duties come from the appropriate Government's rules, which for most Tamil Nadu factories means the State's.
Which sites need one
Four kinds of establishment, each at its own headcount. The employer must "also appoint" safety officers there, on top of any safety committee:
| Establishment | Workers ordinarily employed | OSH Code |
|---|---|---|
| Factory | 500 or more | s.22(2)(a) |
| Factory carrying on a hazardous process | 250 or more | s.22(2)(b) |
| Building or other construction work | 250 or more | s.22(2)(c) |
| Mine | 100 or more | s.22(2)(d) |
A hazardous process, under section 2(1)(za), is a process in an industry listed in the First Schedule to the Code where, without special care, the materials, products, wastes or chemicals would materially impair the health of the people working with them or pollute the environment. A plant that is not sure whether its process qualifies should check the First Schedule before it checks its headcount, because the answer halves the threshold.
A safety officer is not the same as a safety committee. The committee is a joint body of management and worker representatives under section 22(1), required in Tamil Nadu's draft rules at 250 workers, or at 50 where a hazardous process or substance is involved (r.18). The officer is an individual specialist appointed by the employer, and in a factory with an officer, the committee's work runs alongside the officer's.
How many, and under whose rules
Section 22(2) leaves the number, qualifications and duties to the appropriate Government. For most factories in Tamil Nadu that is the State. Its draft OSH rules of 11 April 2022 supersede the Tamil Nadu Safety Officers (Duties, Qualifications and Conditions of Service) Rules 2005 and set the scale in rule 23 [VERIFY: whether Tamil Nadu has since notified final rules, and whether the scale survived]. The OSH (Central) Rules 2026 set their own scales for dock work, construction (r.18) and mines (r.20), where the Centre is the appropriate Government.
| Workers ordinarily employed in the factory | Safety officers (Tamil Nadu draft, r.23(1)) |
|---|---|
| Up to 2,000 | One |
| 2,001 to 5,000 | Two |
| 5,001 to 8,000 | Three |
| 8,001 to 10,000 | Four |
| Above 10,000 | Five |
Where there is more than one, the Tamil Nadu draft has one designated Chief Safety Officer, in overall charge of the safety function (r.23(2)). The Central scale for construction is steeper: one officer up to 500 workers, two up to 1,000, three up to 2,000, four up to 5,000, and one more for every further 2,000 or part of 2,000 (r.18(1)(b)).
Do contract workers count?
The Code does not say in so many words, and the question is the same one that arises for the welfare officer and other headcount thresholds. Section 22(2) counts "workers ... ordinarily employed", which section 2(1)(zv) defines as the average number of persons employed per day over the preceding calendar year. The Code's definition of worker covers anyone employed in the establishment for hire or reward, and it treats contract labour as employed in the establishment's work. It does not repeat "including contract labour" in section 22(2), as it does for the canteen. A plant at 380 direct workers and 150 contract workers on average is at 530 on one reading and 380 on the other.
Who qualifies, and how they are appointed
In a Tamil Nadu factory, an engineer or scientist with supervisory experience and a qualification in industrial safety. The draft rules set it out:
- Qualification (r.20(1)). An engineering or technology degree with two years' supervisory experience; or a physics or chemistry degree, or an engineering diploma, with five years'. In each case also a diploma in industrial safety from a DGFASLI institute, or a degree or diploma in industrial safety of at least one year, and adequate knowledge of Tamil. Where most workers speak another language, the officer must learn it within a year of appointment.
- Recruitment (r.21). Advertised on a prominent online job portal or in two widely read newspapers, one Tamil and one English, with selection by a committee the employer appoints, and the appointment notified to the Chief Inspector-cum-Facilitator.
- Vacancies (r.22). A vacancy is notified to the Chief Inspector-cum-Facilitator at once and filled within three months.
- Status (r.23(3)–(6)). Senior executive status equivalent to a head of department, reporting to the chief executive; pay and conditions matching officers of the same status; and an appeal to the Chief Inspector-cum-Facilitator within thirty days of a dismissal or discharge.
- Support and focus (r.25–26). Technical and secretarial staff and the equipment and information the role needs, and no other work inconsistent with the safety duties.
What the officer does, including for contract crews
Advises and assists the establishment on preventing injuries and keeping the workplace safe, across everyone working on the floor. Rule 24 of the Tamil Nadu draft lists twelve duties. These touch contract crews most directly:
- Plant safety inspections that observe the physical conditions and "the work practices and procedures followed by workers", and advise on removing unsafe conditions and unsafe acts.
- Investigating all accidents and near-miss incidents, and assisting with accident, dangerous occurrence and disease reporting and records.
- Advising purchasing and stores on the quality and availability of personal protective equipment.
- Training and awareness programmes for preventing injuries, designed alone or with the training department.
- Job safety studies of selected jobs, and advice on the safety of all job studies.
A contractor's crew does the same jobs on the same floor, so its near misses, its practices and its PPE fall within those duties as much as the site's own staff's. The officer can only investigate what reaches them, which is why the contractor's supervisors need a route to the safety officer that does not wait for the next committee meeting.
How Velura Services helps
On sites with a safety officer, our supervisors report every accident and near miss involving our crew to the officer during the same shift, and our crew attends the site's safety training and inspections alongside its own workers. We give the site our crew's monthly attendance, so its ordinarily-employed count can show contract workers separately.
Sources
- Occupational Safety, Health and Working Conditions Code, 2020 (Act 37 of 2020), Gazette text hosted by DGFASLI. Sections cited: s.2(1)(m) (contract labour), s.2(1)(za) (hazardous process), s.2(1)(zv) (ordinarily employed), s.2(1)(zzl) (worker), s.22(1) (safety committee), s.22(2) (safety officers at 500, 250, 250 and 100), s.24(1)(v) (canteen, including contract labourers), First Schedule (industries involving hazardous processes). Opened and read.
- Occupational Safety, Health and Working Conditions (Tamil Nadu) Rules, 2022 (draft), G.O. Ms. No. 38, 11 April 2022, Tamil Nadu Government Gazette Extraordinary No. 216. Preamble (supersession of the 2005 Safety Officers Rules), r.18 (safety committee), r.20 (qualifications), r.21 (recruitment), r.22 (vacancies), r.23 (number, status, appeal), r.24 (duties), r.25 (facilities), r.26 (no inconsistent duties). Opened and read.
- Occupational Safety, Health and Working Conditions (Central) Rules, 2026, G.S.R. 345(E) dated 8 May 2026, mirrored copy of the Gazette. Rule 18 (safety officers for dock work and construction: scale and qualifications), r.19 (duties), r.20 (mines). Opened and read [VERIFY: against the e-Gazette original].