The Factories Act 1948 and your State Factory Rules set four things an Inspector of Factories will check: which workers were examined, at what interval, who signed the fitness certificate, and whether the health register can prove it. This page walks through each, and how a programme is built so the answer is always in hand.
Intervals, forms and retention periods differ by state and by process. Treat this as orientation and confirm the schedule for your plant with your State Factory Rules or an occupational health physician.
Statutory surveillance starts with the process, not the person. Map every role to its exposures first and the list of who needs examining writes itself.
Every worker employed in a hazardous process listed in the First Schedule of the Act must be medically examined before employment and at prescribed intervals afterwards, with records maintained for the Inspector of Factories.
State Factory Rules notify specific operations (lead, chromium, solvents, silica, asbestos, pesticides and others) as dangerous, each with its own schedule of examinations, tests and exclusion criteria.
A person under eighteen may not work in a factory without a certificate of fitness granted by a Certifying Surgeon, renewed as the Act prescribes.
Beyond the statutory minimum, ISO 45001, SEDEX and most group EHS standards expect surveillance for anyone with a mapped exposure — noise, dust, heat, ergonomic load, working at height — whether or not the process is scheduled.
A worker with two exposures is owed the shorter of the two intervals. That single rule is where most spreadsheets fail an audit.
| Interval | What it covers |
|---|---|
| Before joining | Pre-employment medical examination (PEME) for every worker entering a hazardous or dangerous process, and a baseline for anyone with a mapped exposure. |
| Every 6 months | The interval most State Factory Rules prescribe for hazardous processes — the Gujarat Factories Rules 1963 record these findings in the Form 32 health register. |
| Every 12 months | Routine periodic examination for exposed workers outside the scheduled processes, and the cycle most group EHS standards audit against. |
| Monthly to quarterly | Specific dangerous operations carry shorter intervals — lead exposure under the Maharashtra Factories Rules is the usual example. |
A generic executive panel does not satisfy surveillance for a noise-exposed or dust-exposed worker. The battery has to answer the exposure.
| Exposure | Typical surveillance tests |
|---|---|
| Noise above 85 dB(A) | Pure-tone audiometry, both ears; standard threshold shift tracked against the baseline |
| Dust, silica, cotton, grain | Spirometry (FVC, FEV1, ratio), chest X-ray read to ILO classification |
| Solvents, aromatic hydrocarbons | Liver and kidney function, complete blood count, urinalysis |
| Lead, chromium, heavy metals | Blood lead or urinary metal levels, haemoglobin, renal profile |
| Working at height, driving, crane | Vision including colour and depth, ECG, blood pressure, fitness for the task |
| Food handling | Stool examination, skin and nail inspection, vaccination status under food safety regulations |
An examination that cannot be traced from the register entry to a released result and a signed decision is, to an inspector, an examination that did not happen.
Prescribed by your State Factory Rules — Form 32 under the Gujarat Factories Rules 1963, Form 7 under the Maharashtra Factories Rules, with equivalent forms elsewhere. One line per worker per examination, signed by the examining physician, kept at the factory and produced on demand.
A signed decision — fit, fit with restrictions, temporarily unfit or unfit — carrying the physician's name and registration number and the restrictions the employer must apply. A restriction that never reaches the shop-floor supervisor is a finding waiting to happen.
Section 89 requires a medical practitioner who detects a disease in the Third Schedule to notify the Chief Inspector. Surveillance that cannot escalate a finding is surveillance in name only.
The employer receives the fitness decision and the work restrictions; clinical values stay between the physician and the worker. Consent captured before the examination, in the worker's language, is what makes the record defensible.
Job role maps to hazards, hazards to a protocol, the protocol to a due date. An AFIH-qualified physician signs every decision, and the register exports in the prescribed layout with each line traceable to a released result.
A qualified medical practitioner appointed by the State Government under Section 10 of the Factories Act 1948 to examine workers, grant certificates of fitness and enforce the occupational health provisions of the Act. State Factory Rules also allow suitably qualified factory medical officers — in practice, physicians holding the AFIH (Associate Fellow of Industrial Health) — to carry out the prescribed examinations.
For workers entering a hazardous process under Section 41-C, or a dangerous operation notified under State Factory Rules, yes — before employment and at the intervals prescribed afterwards. For other roles the employer's own EHS policy, group standards and customer audits usually require it even where the Act does not.
The physician records the decision and, where fitness can be regained, a retest date. The employer must not deploy the worker in the process they are unfit for, and the finding is entered in the health register. A worker found fit with restrictions can continue subject to the coded restrictions on the certificate.
State Factory Rules prescribe the retention period for the health register and fitness certificates, and it is long — decades for some exposures, because occupational disease surfaces years after exposure ends. Keep every examination traceable to the result and the signing physician for as long as the Rules require, and longer if the process is one with latency.
Share your workforce profile and receive a written proposal within 48 hours — protocol design, plant-wise scope, camp schedule and commercials, reviewed by an occupational physician.
