A precision machining plant in Tamil Nadu, which we supply with contract workers, planned an electroplating line to finish its own parts. The project was run as a capital purchase. Nobody had asked whether it changed the plant's legal category until our ramp planning raised the question six weeks before start-up. Electroplating is on the OSH Code's list of hazardous processes. This is a representative composite; no single client is described.
The situation
Electroplating is entry 16 of the First Schedule to the OSH Code 2020, and Tamil Nadu's draft OSH rules of 11 April 2022 also declare "electrolytic plating" a dangerous operation (r.81(2)) [VERIFY: whether Tamil Nadu has since notified final rules]. The plant's existing machining work had been assessed as outside the First Schedule [VERIFY: composite]. With 310 workers on its own payroll, it was past 250 whichever way contract labour was counted.
What the new line triggered
More than the project team had planned for. The site's HR and its safety adviser mapped the duties:
| Duty | Source | Where the plant stood |
|---|---|---|
| Tell the Chief Inspector-cum-Facilitator at least thirty days before the process starts | OSH Code s.84(5) | Not done; six weeks left before the planned start [VERIFY: composite] |
| Approved on-site emergency plan and disaster control measures | s.84(4) | General fire plan only |
| Safety officer, now required from 250 workers instead of 500 | s.22(2)(b) | None appointed |
| Factory medical practitioner full-time above 250 workers, with an occupational health centre, nurse and dresser | TN draft r.92(1)(iii) | A retainer doctor for first aid only |
| Pre-employment fitness certificate for everyone on the line, then six-monthly examinations and a health register | s.85(c); TN draft r.91 | Not in the line's staffing plan |
| Hazard information to every worker, a cautionary notice at the gate, and information to the public nearby | s.84(1); TN draft r.83, r.86, r.89 | Not prepared |
| An ambulance, or an arrangement with a nearby hospital below 250 workers | TN draft r.93 | No ambulance |
What was done
- Start moved back. The line's start was put back three weeks, so the thirty-day notice under section 84(5) could go in with the process details complete [VERIFY: composite].
- People appointed. A safety officer and a full-time factory medical practitioner, with the occupational health centre set up in two converted rooms beside the existing first-aid room, and an ambulance van arranged for the site [VERIFY: composite].
- The crew certified before the first shift. We screened the 25 workers for the line, and the practitioner examined each one and issued Form XXIII certificates before anyone worked on it. Two who were not certified fit were placed elsewhere on the site [VERIFY: composite].
- Information in the workers' languages. The hazard sheet, the role of each worker in the emergency plan, and the cautionary notice at the gate went out in Tamil and Hindi, to direct and contract workers alike.
- Free to the worker. The examinations and the line's protective equipment were provided at no cost to any worker, as section 6(1)(g) requires.
What changed
| Measure | Before | After |
|---|---|---|
| Capital projects | Approved on cost and output | Every new process checked against the First Schedule and the dangerous-operations list before approval [VERIFY: composite] |
| Contractor briefing | Headcount and start date | Headcount, start date, and whether the work is in a hazardous process or a dangerous operation |
| Health register | None | Form XXIV, with each worker's six-monthly date, kept by the occupational health centre |
| Leavers | Exit by gate pass | Health record made available to every worker leaving the line, contract workers included (TN draft r.90) |
The lesson carries to any plant adding a process. The First Schedule turns on what a plant does, not what it is called, and a single new line can bring a whole factory under the hazardous-process rules. The thresholds then apply to the whole factory's headcount, not the line's. How a particular process is classified is a question for the site's own safety adviser and counsel. This composite describes a method, not an outcome.
How Velura Services helps
Before we staff any new line, we ask whether the work is a hazardous process or a declared dangerous operation, and plan the fitness examinations, training and protective equipment it needs. Our crew on such a line is examined and certified before the first shift, receives the hazard information in their own language, and pays nothing for any of it.
Sources
- Figures are a representative composite drawn from our own deployments; no single client is described. Founder to confirm or replace before publish.
- Occupational Safety, Health and Working Conditions Code, 2020 (Act 37 of 2020), Gazette text hosted by DGFASLI. Sections cited: s.2(1)(za) and First Schedule entry 16 (electro-plating), s.6(1)(g) (no charge for safety and health), s.22(2)(b) (safety officers at 250 in a hazardous-process factory), s.83 (site appraisal), s.84 (disclosure, emergency plan, thirty days' notice), s.85 (health records and medical examination). 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. Rules cited: r.81(2) (electrolytic plating a dangerous operation), r.83 (information to workers), r.86 (information to the public), r.89 (cautionary notice), r.90 (health records), r.91 (examinations; Forms XXIII and XXIV), r.92 (occupational health centres), r.93 (ambulance). Opened and read.