Prioritizing Changes and Fostering Safety Culture in response to Delhis New Draft OSH Code Rules - CiteHR

Incident – In early December, the Delhi government notified the draft Delhi Occupational Safety, Health and Working Conditions Rules, 2025, signalling a major reset in how factories, construction sites and large establishments will be run. The draft rules propose a 10-member Occupational Safety and Health Advisory Board chaired by the labour commissioner, and mandatory safety committees for establishments with 250 or more workers. They also hard-code basics that many employers still ignore: no one can be employed without a formal appointment letter, serious accidents must be reported immediately to the labour department, and working time is capped at 48 hours per week with overtime limited to 144 hours per quarter. Stakeholders have 30–45 days from early December to send objections and suggestions before these rules move toward finalisation.
The Times of India

Emotional/Workplace Impact – For HR and compliance teams in Delhi, this draft feels like both a wake-up call and an opportunity. Safety officers and plant HR managers who have long struggled to get budgets approved for health checks, PPE and safety training now have a regulatory lever: annual free medical exams for workers over 45 and stricter oversight in hazardous processes will no longer be “nice to have,” they will be mandatory. Workers who have operated in informal, appointment-letter-free arrangements may finally see their identities and service recorded in a way that matters for future disputes. At the same time, small and mid-sized employers are anxious about the cost and administrative burden, especially around forming functional safety committees rather than token ones. The emotional undercurrent is mixed: hope among workers and progressive HR leaders that this will force long-ignored basics, and quiet worry in some corners that decades of patchwork practices are about to be exposed.
MillenniumPost

Compliance/Leadership Lens – For leadership, these draft rules move occupational safety from policy slides to board-level risk. They bake OSH principles into local law: documented appointment letters, clear working-time caps, mandatory incident reporting, safety committees, age-linked health checks, and structured roles for inspectors and advisory boards. Organisations operating across states will need to reconcile central labour codes with Delhi-specific rules, updating standing orders, contractor agreements, and site SOPs. Audit trails around overtime, medical check-ups and safety incidents will become essential to survive inspections or litigation. For HR heads, this is a chance to argue for integrated safety-management systems instead of fragmented spreadsheets. For founders and CXOs, the question is no longer “Can we get by with minimal compliance?” but “What is our exposure if something goes wrong under this new regime?”

What changes would you prioritise first if your Delhi unit had to comply with these draft rules tomorrow?
How can HR and safety teams use these rules to build genuine safety culture instead of just more paperwork?


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If your Delhi unit had to comply with these draft rules tomorrow, the first priority would be to ensure that all employees have formal appointment letters. This is a basic requirement that has been highlighted in the draft rules. It not only provides a legal basis for employment but also helps in recording the service of the employees which can be crucial in future disputes.

Next, establish a safety committee if your establishment has 250 or more workers. This committee should be functional and not just a token one. It should be empowered to make decisions regarding safety measures and should have regular meetings to discuss safety issues.

Thirdly, make sure that serious accidents are reported immediately to the labour department. This is not just a legal requirement but also an ethical one. It helps in identifying the causes of accidents and preventing similar incidents in the future.

Fourthly, ensure that working time is capped at 48 hours per week and overtime is limited to 144 hours per quarter. This is important for the health and well-being of the employees. It also helps in maintaining a good work-life balance.

Finally, prepare for annual free medical exams for workers over 45 and stricter oversight in hazardous processes. This might require budget allocation and planning, but it is crucial for the health and safety of the employees.

To build a genuine safety culture, HR and safety teams can use these rules as a framework. They should communicate the importance of these rules to all employees and ensure that they are implemented in spirit and not just in letter. Regular safety training sessions should be conducted and safety measures should be reviewed periodically. The safety committee should be involved in decision-making processes and their suggestions should be taken seriously. In case of any safety incidents, a thorough investigation should be conducted and corrective measures should be taken promptly. By doing so, a culture of safety can be fostered in the organization.

From India, Gurugram
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