Heat stress: Labour laws and missing safeguards

Extreme heat is a serious work hazard that calls for a climate-informed policy and enforceable protections.

Extreme heat at work is no longer a future concern; it’s shaping the reality of labour today. However, the Karnataka government’s ‘Draft Occupational Safety, Health and Working Conditions Rules, 2026’ falls short of embedding heat-stress science and workers’ lived realities into enforceable standards. The draft rules include nods to heat science, noting humidity through hygrometers, cold drinking water, and heat hazards from machinery. Yet, it remains detached from the scale of the climate crisis, ignoring how extreme heat endangers workers’ health and productivity across sectors.

Historically, India’s labour health and safety protections have been anchored in the physical workspace, most clearly in the Factories Act. The Act treats factories as a static, indoor world, regulating the built environment – ventilation, temperature, humidity, drinking water, sanitation, crowding – through design and engineering controls. This static perspective remains central within both the central government’s Occupational Safety, Health and Working Conditions Code, 2020, and now, the Karnataka draft.

We highlight three problems. First, the Karnataka draft continues to exclude the majority of workplaces. While safety committees with worker representation effectively drive science-informed, worker-led interventions, the draft restricts them to establishments with over 100 workers (500 for most factories). This abandons the majority of the working population, including in construction, platform-based work, street-vending, and small and medium factories. Coverage must be widened by lowering thresholds, with safety committees established through collective associations, such as town vending committees, for micro-enterprises. While Karnataka’s steps to expand the welfare architecture for gig and domestic workers are commendable, health and safety provisions in the draft rules remain limited.

The second issue is the rules’ preoccupation with the built environment, while physiological evidence identifies behaviour as the more powerful thermoregulatory response. Thermal behaviours include rest, slowing work, seeking cooling, and hydrating to offset sweating-induced fluid loss. Relegating behaviour to self-regulation diminishes impact. For example, relying on workers to hydrate when thirsty is ineffective, as thirst is a late sign of dehydration. Workers need to hydrate proactively, which requires awareness but also empowerment.

Emerging evidence suggests that allowing workers to self-pace sustains productivity, as workers can distribute their workload more effectively and avoid heat exhaustion. But current industrial systems actively discourage this. Piece-rate wages compel workers to continue in hot conditions, as resting imposes an economic penalty. Thermal protective behaviours must not be penalised.

While workers can raise complaints, they lack a framework for protective action. Behavioural mandates must be written in, including obligations for employer-led training on heat safety, safe-work procedures, and non-retaliation clauses protecting the right to slow down or refuse risky work during heat spikes.

Third, protective behaviours require accessible infrastructure including public infrastructure. The draft rules cover some essential workplace infrastructure like drinking water, sanitary toilets, ventilation, and exhaust systems for heat-radiating machines. However, the cumulative nature of heat stress beyond the workplace must be recognised. One study found that 70% of manual workers arrived at work already dehydrated. Heat action must address increasing heatwave days, urban heat island effects, and night-time temperatures.

Advisory to corrective action

Municipal drinking water points, toilets, shade, cooling centres, green and blue public spaces must be recognised as labour infrastructure, with financing assigned to employers, local bodies, and the State. The new codes and state rules must accomplish the following.

First, explicitly recognise heat stress, including humid heat, as a core health and safety issue across sectors, not just hazardous factories, and embed obligations for employers to anticipate and manage it. This requires defining maximum permissible Wet Bulb Globe Temperature (WBGT) thresholds and requiring establishments to monitor them using hygrometers. Threshold breaches must trigger legally binding responses like heat audits, work rescheduling, or immediate work stoppages.

Second, rules must enable behavioural intervention backed by economic security. We need protocols for maximum work durations, mandatory rest breaks, and the right to self-pace or refuse dangerously hot work without penalty. Participative workers’ committees can identify extreme heat zones and activities, and must be empowered with training and early warning systems. Third, enforcement must move away from self-declaration. The State must restore a credible, adequately staffed inspection system. Currently, most heat-exposed workers lack internal safety professionals to monitor conditions or a State apparatus to detect and penalise unsafe heat levels.

The well-established impact of workers’ heat stress on productivity, as well as the risk of chronic diseases afflicting heart, lungs and kidneys, makes addressing it a win-win-win for workers, employers, and the State. Alongside a general heat-protection framework, we need to synthesise climate science, occupational health, and social science to develop sector-specific guidelines and interventions. Such frameworks must answer: Where are hotspots in a city like Raichur at different times of day and year? Which occupations face compounded risks from heat, air pollution, and flooding? How do gender, caste, and informality shape exposure? This evidence-driven mapping should collectively involve unions, municipal bodies, and researchers.

Countries are shifting from ad-hoc, advisory models to embedding heat into labour law. France’s Labour Code now requires employers to take preventive measures during heatwaves, including adapting work processes, and supplying cool drinking water. Japan has gone further: revised regulations trigger mandatory action when WBGT crosses defined thresholds, requiring employers to monitor conditions, implement hydration protocols, and structured rest cycles, or face fines.

Karnataka has a chance to show what labour law can look like in a warming world: a climate-informed framework recognising that the right to work safely increasingly means the right not to be cooked, slowly, at work.

(Apekshita is the founder of HeatWatch, an initiative focused on the impact of extreme heat on India’s marginalised populations; Pratik is a British Academy Postdoctoral Fellow at the University of Sussex)

Disclaimer: The views expressed above are the author's own. They do not necessarily reflect the views of DH.