First Schedule explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.
The First Schedule to the Occupational Safety, Health and Working Conditions Code, 2020 (the OSH Code) is the "List of Industries involving hazardous processes". It has 40 numbered items, from ferrous metallurgical industries to the use of mercury, arsenic and isocyanates. The Schedule's heading cross-refers to section 2(za), the definition of "hazardous process". If your plant may be on the list, our labour law compliance team can help check what follows.
The First Schedule lists 40 industries involving hazardous processes, including metallurgy, foundries, coal, power, pulp and paper, fertilisers, cement, petroleum, pharmaceuticals, chemicals, pesticides, asbestos, benzene, explosives, stone crushing, ship breaking, e-waste, semiconductors, styrene and nano-particles. Being in the list brings the hazardous-process duties of the Code, such as disclosure and occupier responsibility in sections 84 and 85, into play. Section 131 lets the Central Government add, alter or omit items by notification.
The First Schedule at a glance
| Item | Industry (as printed) |
|---|---|
| 1 | Ferrous metallurgical industries: integrated iron and steel, ferro-alloys, special steels |
| 2 | Non-ferrous metallurgical industries: primary metallurgical industries, namely zinc, lead, copper, manganese and aluminium |
| 3 | Foundries (ferrous and non-ferrous): castings and forgings, including cleaning or smoothening or roughening by sand and shot blasting |
| 4 | Coal (including coke) industries: coal, lignite, coke and like substances; fuel gases (coal gas, producer gas, water gas) |
| 5 | Power generating industries |
| 6 | Pulp and paper (including paper products) industries |
| 7 | Fertiliser industries: nitrogenous, phosphatic, mixed |
| 8 | Cement industries: Portland cement (including slag cement, puzzolona cement and their products) |
| 9 | Petroleum industries: oil refining; lubricating oils and greases |
| 10 | Petro-chemical industries |
| 11 | Drugs and pharmaceutical industries: narcotics, drugs and pharmaceuticals |
| 12 | Fermentation industries (distilleries and breweries) |
| 13 | Rubber (synthetic) industries |
| 14 | Paints and pigment industries |
| 15 | Leather tanning industries |
| 16 | Electro-plating industries |
| 17 | Chemical industries, sub-items (a) to (l), listed below |
| 18 | Insecticides, fungicides, herbicides and other pesticides industries |
| 19 | Synthetic resin and plastics |
| 20 | Man-made fibre (cellulosic and non-cellulosic) industry |
| 21 | Manufacture and repair of electrical accumulators |
| 22 | Glass and ceramics |
| 23 | Grinding or glazing of metals |
| 24 | Manufacture, handling and processing of asbestos and its products |
| 25 | Extraction of oils and fats from vegetable and animal sources |
| 26 | Manufacture, handling and use of benzene and substances containing benzene |
| 27 | Manufacturing processes and operations involving carbon disulphide |
| 28 | Dyes and dyestuff including their intermediates |
| 29 | Highly flammable liquids and gases |
| 30 | Printing and dyeing on fabrics in textiles, and plywood and laminate manufacturing process |
| 31 | Process involving usage of radium or radioactive substances |
| 32 | Stone crushing industry |
| 33 | Extraction of oil and raw material from scrap tyres |
| 34 | Cigarette manufacturing industry |
| 35 | Ship breaking industry |
| 36 | Hazardous waste and e-waste processing plants |
| 37 | Semiconductor manufacturing industry |
| 38 | Styrene manufacturing, handling and processing industry |
| 39 | Nano-particles utilising industry |
| 40 | Manufacturing, processing, preparation and utilisation of mercury or compounds of mercury, lead tetra-ethyl, manganese, arsenic, chrome, aliphatic series, beryllium, phosgene and isocyanates |
Item 17, chemical industries, has twelve sub-items: (a) coke oven by-products and coal tar distillation products; (b) industrial gases (nitrogen, oxygen, acetylene, argon, carbon dioxide, hydrogen, sulphur dioxide, nitrous oxide, halogenated hydrocarbon, ozone, or any like gases); (c) industrial carbon; (d) alkalies and acids; (e) chromates and dichromates; (f) lead and its compounds; (g) electrochemicals (metallic sodium, potassium and magnesium, chlorates, perchlorates and peroxides); (h) electrothermal products (artificial abrasive, calcium carbide); (i) nitrogenous compounds (cyanides, cyanamides and other nitrogenous compounds); (j) phosphorus and its compounds; (k) halogens and halogenated compounds (chlorine, fluorine, bromine and iodine); (l) explosives (including industrial explosives and detonators and fuses).
What the listing is for
The heading of the Schedule reads "". That is the definition of "hazardous process" (see our definitions article on hazardous process). The Schedule gives the list of industries involving hazardous processes that the definition refers to. The Code does not restate, in the Schedule, what a hazardous process is; read the definition for that.
Several consequences in the Code attach to hazardous processes. The occupier of a factory carrying on a hazardous process has disclosure and responsibility duties in sections 84 and 85 (see sections 84 and 85). Emergency standards for hazardous processes are under section 87 (see sections 86 to 88). Sections 102 and 103 set the penalty for breaching the hazardous-process duty where an accident follows (see sections 102 and 103). For the old-law comparison, the Factories Act, 1948 also had a schedule of industries with hazardous processes (see our note on hazardous processes under the Factories Act).
Items that are new or unusual to see
Reading the list as enacted, some items stand out for modern industries:
- Item 33: extraction of oil and raw material from scrap tyres.
- Item 34: cigarette manufacturing.
- Item 35: ship breaking.
- Item 36: hazardous waste and e-waste processing plants.
- Item 37: semiconductor manufacturing.
- Item 38: styrene manufacturing, handling and processing.
- Item 39: nano-particles utilising industry.
- Item 40: mercury, lead tetra-ethyl, manganese, arsenic, chrome, aliphatic series, beryllium, phosgene and isocyanates.
This article does not say which of these items were or were not in any earlier schedule. Compare the enacted Schedule with the list that applied to you under the old Act if the comparison matters for your transition.
Changing the list
Section 131 lets the Central Government, by notification, "amend any Schedule by way of addition, alteration or omission", with the Schedule deemed amended on the notification (see sections 130 to 133). The list above is the list as enacted. Later amendments, if any, are not in the text used here, so check the current Gazette before relying on it.
How to use the list
- Match your activity to an item. Read the item as printed. For example, item 23 is "grinding or glazing of metals", not any fabrication.
- Check sub-items. Item 17 has twelve sub-items, each with named products.
- Check the definition. Being in a listed industry is the start; the definition in section 2(1)(za) also matters.
- Identify the appropriate Government. The forms and time limits sit in the Central Rules, 2026 where the Central Government is the appropriate Government, and in State rules otherwise.
- Plan the duties. Disclosure, occupier responsibility, medical examination and emergency standards follow.
Example. A unit that makes printed fabrics and another that makes plywood and laminates both fall in item 30 as printed. A unit that only stitches garments does not appear in any item as printed. A unit that processes e-waste falls in item 36.
Need help with hazardous-process compliance?
If you think your plant is in a listed industry and want a map of the disclosure, standards and inspection duties that follow, our labour law compliance team can work through the list, the definition and the rule set that applies to you.
Key takeaways
- The First Schedule lists 40 industries involving hazardous processes; item 17 has twelve sub-items.
- The Schedule cross-refers to section 2(za), the definition of hazardous process.
- Listed industries face hazardous-process duties in the Code, including disclosure and occupier responsibility.
- The Central Government can amend the list by notification under section 131.
- Check both the Schedule and the definition, then the applicable Central or State rules.
Read next
- Section 2 definitions: hazardous process, hazardous substance and serious bodily injury
- Sections 84-85: disclosure of information and responsibility of occupier for hazardous process
- Second Schedule: matters for occupational safety and health standards
- Hazardous processes under the Factories Act: sections 41A to 41H
Disclaimer: Based on the Occupational Safety, Health and Working Conditions Code, 2020 (as enacted) and, where noted, the Occupational Safety, Health and Working Conditions (Central) Rules, 2026 (G.S.R. 345(E), 8 May 2026), as on 30 September 2026. The Code is in force from 21 November 2025; some provisions may be notified later, and State Governments make their own rules for establishments where the State is the appropriate Government. Verify the current position before acting.
