Health and Safety Policy (Pakistan)

A Health and Safety Policy in Pakistan establishes the framework of rules governing the area it covers and the steps taken when those rules are broken.

The Factories Act 1934, enforced by the provincial Inspector of Factories appointed under Section 8 of the Act, imposes thorough duties on occupiers (owners and managers) of factories to maintain safe working conditions. Chapter III of the Factories Act 1934 (Sections 13 to 40) covers cleanliness, overcrowding, ventilation, lighting, drinking water, latrines, spittoons, and dusty or noxious processes. Chapter IV (Sections 41 to 49) covers safety provisions including fencing of machinery (Section 21), precautions in case of fire (Section 38), and first aid appliances (Section 45). Chapter V (Sections 50 to 60) addresses welfare provisions including washing facilities, restrooms, canteens, and crèches for establishments employing more than 50 workers.

Pakistan's provinces have enacted their own Occupational Health and Safety legislation adding to the federal Factories Act 1934 framework: the Punjab Occupational Safety and Health Act 2019 (Punjab OHS Act) applies to all establishments with ten or more workers in Punjab — not just factories — and requires employers to prepare and display a written health and safety policy under Section 12 of the Punjab OHS Act 2019. The Sindh Occupational Safety and Health Act 2017 imposes similar requirements on establishments in Sindh. Khyber Pakhtunkhwa and Balochistan have parallel provincial OHS frameworks.

The Punjab OHS Act 2019 and the Sindh OHS Act 2017 represent a significant expansion of Pakistani occupational health and safety law beyond the factory sector: they cover offices, shops, hotels, hospitals, construction sites, and agricultural establishments — extending protection to the vast informal and services workforce not previously covered by the Factories Act 1934. Both provincial Acts create the obligation to conduct formal risk assessments, maintain accident registers, report serious accidents to the provincial OHS Authority, and establish Joint Occupational Health and Safety Committees in establishments with 50 or more workers.

Employers who fail to comply with the Factories Act 1934 and provincial OHS legislation face prosecution under the respective penalty provisions — the Factories Act 1934 Section 96 provides for imprisonment up to three months or a fine up to PKR 500 (outdated; provincial Finance Acts have revised penalty levels upward), while the Punjab OHS Act 2019 provides for fines up to PKR 500,000 for serious violations. Beyond regulatory penalties, employers face civil liability under the Fatal Accidents Act 1855 and the Law of Torts for injuries or deaths caused by unsafe working conditions.

The legal framework governing the Health and Safety Policy (Pakistan) in Pakistan draws on several key statutes and regulatory bodies. Under the Companies Act 2017, the Securities and Exchange Commission of Pakistan (SECP) maintains the register of Pakistani companies. Section 16 of the Companies Act 2017 governs company incorporation. The Contract Act 1872 governs general contractual obligations. The Federal Board of Revenue (FBR) administers corporate tax under the Income Tax Ordinance 2001. The High Courts (Lahore, Sindh, Peshawar, Balochistan, Islamabad) have original and appellate jurisdiction. Parties executing a Health and Safety Policy (Pakistan) in Pakistan should confirm the document reflects current law, including any amendments enacted since the original drafting date. The Factories Act 1934 sets the foundational requirements.

A Health and Safety Policy in Pakistan is required across a wide range of workplace situations and is mandatory for certain categories of employers under provincial OHS legislation.

A Health and Safety Policy is needed when a factory employing ten or more workers is required by the Inspector of Factories to demonstrate compliance with the Factories Act 1934 during a periodic inspection. The Inspector of Factories, appointed under Section 8 of the Factories Act 1934 by the provincial Labour Department, has authority to demand production of safety plans and records under Section 9 of the Act.

A Health and Safety Policy is required when an employer in Punjab with ten or more workers must comply with the Punjab Occupational Safety and Health Act 2019, which mandates a written safety policy under Section 12. The Punjab OHS Authority conducts enforcement inspections and can issue improvement notices, prohibition notices, and penalties for non-compliance.

A Health and Safety Policy is needed when a construction contractor or developer applies for a building permit or a no-objection certificate from a local government authority — many local development authorities in Lahore, Karachi, Islamabad, Peshawar, and Quetta now require submission of a site safety policy as part of the permit application under the applicable Building Regulations.

A Health and Safety Policy is required when a company seeks ISO 45001:2018 certification (the international standard for Occupational Health and Safety Management Systems) — a written OHS policy signed by senior management is the foundational requirement of the ISO 45001 standard, increasingly demanded by multinational clients and export market customers.

A Health and Safety Policy is needed when an employer participates in a public procurement tender under the Public Procurement Rules 2004 administered by the Public Procurement Regulatory Authority (PPRA), where the procuring agency requires bidders to demonstrate OHS compliance as part of the technical qualification criteria.

A Health and Safety Policy is required when a business applies for Workers Welfare Fund (WWF) registration under the Workers Welfare Fund Ordinance 1971, as WWF-registered employers are subject to periodic inspections that may examine safety arrangements for the workforce.

A Health and Safety Policy is needed when an employer is subject to audit by a buyer under a supply chain compliance programme — for example, textile exporters supplying to European or American retailers under the EU's General Scheme of Preferences Plus (GSP+) arrangement, which requires compliance with ILO Conventions on occupational safety ratified by Pakistan.

A thorough Health and Safety Policy in Pakistan under the Factories Act 1934, the Punjab Occupational Safety and Health Act 2019, and the Sindh Occupational Safety and Health Act 2017 must contain the following essential elements to satisfy regulatory requirements and protect both employer and employees.

Policy Statement: A clear, unambiguous statement of the employer's commitment to confirming the health, safety, and welfare of all persons affected by the business — employees, contractors, visitors, and the surrounding community. The statement must be signed by the Chief Executive Officer or Managing Director and dated. The Punjab OHS Act 2019 Section 12 and the Sindh OHS Act 2017 require this statement to be conspicuously displayed at the workplace in both English and Urdu.

Scope of Application: The establishments, locations, activities, and categories of workers to which the policy applies — including permanent employees, contract workers, apprentices registered under the Apprenticeship Ordinance 1962, and women workers covered by the Protection Against Harassment of Women at the Workplace Act 2010 and special provisions of the Factories Act 1934 (Sections 45A to 48).

Legal Compliance Framework: A reference to the applicable legislative framework including the Factories Act 1934, the Punjab OHS Act 2019 or Sindh OHS Act 2017 (as applicable), the Mines Act 1923 (for mining operations), the Boiler and Pressure Vessel Ordinance 2002, the EOBI Act 1976, and any relevant ILO Conventions ratified by Pakistan. The policy must commit the employer to complying with all applicable statutory requirements and to exceeding them where reasonably practicable.

Organisational Responsibilities: A clear allocation of health and safety responsibilities across the management hierarchy — the roles and duties of the occupier/owner under Section 7 of the Factories Act 1934, the factory manager, departmental supervisors, safety officers appointed under Section 45C of the Factories Act 1934 (mandatory in factories with 500 or more workers), members of the Joint OHS Committee, and individual workers. Under Section 15 of the Punjab OHS Act 2019, every worker has a duty to take reasonable care of their own health and safety and that of others.

Hazard Identification and Risk Assessment: Procedures for identifying workplace hazards — physical hazards (machinery, noise, heat, fire), chemical hazards (toxic substances governed by the Pakistan Environment Protection Act 1997), biological hazards (for healthcare and food processing workers), and ergonomic hazards. The risk assessment process must document findings in a Risk Register, assign risk ratings (high/medium/low), and identify control measures following the hierarchy of controls: elimination, substitution, engineering controls, administrative controls, and personal protective equipment (PPE).

Safe Work Procedures: Written Standard Operating Procedures (SOPs) for hazardous operations identified in the risk assessment — including lockout/tagout procedures for electrical and mechanical isolation under Section 21 of the Factories Act 1934, confined space entry procedures, hot work permit systems, and chemical handling procedures under the relevant rules of the National Environmental Quality Standards (NEQS) administered by the Pakistan Environmental Protection Agency (Pak-EPA).

Accident Reporting and Investigation: Procedures for reporting workplace accidents, dangerous occurrences, and occupational diseases — including the obligation to notify the Inspector of Factories within 24 hours of a fatal or serious accident under Section 88 of the Factories Act 1934, and to maintain an Accident Register under Section 90. The policy must include a root cause analysis process for all accidents and near-misses to prevent recurrence.

Emergency Preparedness: Documented emergency response procedures covering fire (mandatory fire drills under Section 38 of the Factories Act 1934), medical emergencies, chemical spills, and natural disasters — including evacuation plans, assembly points, emergency contact numbers (Rescue 1122, Edhi Foundation ambulance, police), and first aid arrangements. Section 45 of the Factories Act 1934 requires a first-aid box for every 150 workers.

Training and Competence: Commitment to providing OHS induction training to all new workers before they commence work, task-specific safety training for hazardous operations, and refresher training at defined intervals. Training records must be maintained under the Punjab OHS Act 2019 Section 13.

Monitoring and Review: Procedures for internal OHS audits, inspection schedules, performance measurement using leading indicators (near-miss reports, safety observations) and lagging indicators (accident frequency rates, lost-time injury rates), and the frequency of management review of the policy — at minimum annually or following a significant accident.

Forms-legal.com provides this Health and Safety Policy (Pakistan) template to help employers across all sectors document their OHS commitment. Employers with complex or high-hazard operations — chemical plants, construction sites, mining operations, large factories — should engage a certified OHS professional or consultant to conduct a detailed risk assessment and develop site-specific safe work procedures to supplement this policy.