Dinesh Divekar
Business Mentor, Consultant And Trainer
Process Industry Consultant / Soft Skill
Gopinath Varahamurthi
Mindhour Partner, Ass.professor/adm. Officer,
Asso.prof.(commerce & Management) Pg
Kadam Rupali
Assistant Manager - Hr And Admin

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Dear Seniors,
I am working in medical equipment mfg company,Yesterday Factory inspector visited our factory.
It is directed us that :-
1. Fans location is not safe,change fans with AC.
2.Handrails to staircase.
3.Medical examination of workers
4.Emergency exit should be obstacle free.
Show cause notice issued us as why legal action shall not be taken against us.
What will be the format to explain in show cause .
How we can proceed further
Thanking You,

From India, Mumbai
Dear Rupali,

Of the four, except Sl No 1, other three are valid observations. I recommend you working on them. You can clear emergency exit in 2-3 days, conduct the medical examination of workers, specially for contagious diseases within a fortnight and install handrails to the staircase in maximum one month.

I recommend you writing them back tell them that the you need one month's time to clear point Sl No 2 to 4. Once the changes are made, send a follow up letter with photographs stating that work on each point has been completed.

As far as replacing fans with AC is concerned, it is a costly solution. Find out whether you can change the position of fans or install additional fans so that workers do not sweat. In coming month, you should be able to clear this point also.

When government officials visit, it is important that they raise some objection of other. Do not expect zero observations. Therefore, no need to get perturbed as such on these observations. At the same time do not take lightly their observations.

By the way, do you have safety officer in your company. Why things came to such a pass where Factory Inspector had to issue notice on emergency exit? Emergency exit should be obstacle free this is a very basic safety requirement. Possibly observation on this point reflects that your company needs to improve safety awareness amongst the employees. I request you to take this as wake up call.


Dinesh Divekar

From India, Bangalore
Dear Sir,
Thanks for your response.
I am working in small scale organisation.employee strength 60.
Concept as HR introduced after my joining 6 months back.
I have experience of big manufacturing org.which helped me to operate here individually.
1.Obstacle of emergency exit removed immediately.
2. For medical examination,I have started process.
3.Handrails - Contacted person.
But, In case of AC, inspector just gave us 15 days ( we asked him more time,but he refused).
Fans are not guarded and located at low height, any person can be injured.He asked to remove fans(50 in Quantity) immediately.
Can we use Any other mode of ventilation other than AC? Inspector said , for medical equipment manufacturing AC is first requirement.Is it true?

From India, Mumbai
Dear Kadam Rupali,

It seems the clarification by Shri Dinesh Divaekar is the fit to adhered,

You please send reply in the following format,

1) For observation (1) now the Fans are fitted rightly to the place duly consulting the safety authorities, and you should have a safety authority for the factory premises as such the observation is met and duly rectivied.

2) Handrails are being replaced by stair case and this can be done without harm as hand rails are not suitable either in near future. Thus the observation pointed is rectified by stair case and necessary steps initiated and you can bargain time for one month in replacing the same.

3) Medical examination of employees be done which will not take more than two days and a report attached in reply to the show cause. Medical examination is done to our employees on (give date).

4) Now the emergency exit is obstacle free, as no obstacles found near by the exit. (Please remove the obstacles kept nearby)

All the observations(in the same note as you have mentioned) are not that much punishable that can be easily rectified..

best of luck...

From India, Arcot
Dear Rupali, Please advice the process you have started for health check up of workers. Please advice me... Regards,
From United States, New York
Dear Binuss, Factory inspector gave us contact details of certified medical practitioner. I have contacted him.I will inform you further progress.
From India, Mumbai
dear kadam rupali,
Have a tieup with LION CLUB members (will certainly available) they will arrange you the medical checkup as well as try to conduct blood donation camp as a social welfare measure...

From India, Arcot
What is the difficulty Rupali. Don't you have any nursing home/hospital or even a Doctor in your place. Have a tie up with them and complete requirement by paying some fees to them and close the matter. Afterall this a requirement and various options are all available. Instead of replying with "non-compliance report" to the SCN you should try to send a "fully complied with" reply to the authorities and try to close the matter. Don't try to make it as a complicated issue by dragging it too much. See that violations are rectified to the extent possible. Otherwise you have to incur hefty "B" for closing the matter.

From India, Bangalore
Hi Rupali Kadam,
You are ready with solution for three of the four points.
Regarding FANS, discuss with your top technical person and see if a safety guard can be fitted.
You can even try to get an external help.
Once you are successful the idea can be replicated for other fans.
Then you can request the factory inspector for a reasonble time to complete the rest of the jobs
Another alternative, slightly costly, would be locate the fans outside and take the air through ducts inside.
Air conditioning could be last the resort.
If Air conditioning is a MUST, please check with similar type companies, if it is so.
You can also see if it is specified for your type of industry in the factory act.

From India
Dear Seniors,
I received show cause notice from Factory Inspector in regarding to contravention of Section 21.
i.e. Fencing of Machinery.
Kindly help me out and send me the reply letter format.
mailid - [email protected]

From India, Mumbai
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