Applicability Of ESIC For Company Having 280 Employees, However Only 5 Fall Under ESIC Bracket

Dear Seniors,
Please advice whether would ESIC be applicable if there are only 5 employees drawing salary less than 21,000 out of total of 280.
The structure is given as under:
280 - Permanent Employees (5 employees below 21,000)
100 - Contractual - Third Party payroll (almost 60 employees for whom ESIC is applicable.
Suggestions from industry expert is that our company does not get covered under ESIC until we reach atleast 20 employees drawing less than 21,000 as salary.
Please advise.
Regards,
Jasmine

for ESIC coverage eligibility, the exempted are also counted as manpower, irrespective of the salary above the esic limit,
they are not eligible to pay the esic contribution, but are in master roll of employer, so as soon as the master roll exceed TEN ( for factory with power) or TWENTY ( for others) esic acts get applied. ............ in some cases, where not a single employee is contributing under esic, but the establishment has to get covered.

1. Sir, please confirm in which State your establishment or factory is located ? Whether it is a factory or an establishment ? Further it is also essential to know whether the said establishment is located in implemented area as declared under section 1(3) of said Act ?
2. Further it will be more better if you contact ESIC Social Security Officer / appropriate Regional Office of the area and get the position verified with a view to ascertain the coverability of your unit under said Act.