Rules 81 and 82 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.
Rule 81 says who may be a medical officer under the Occupational Safety, Health and Working Conditions Code, 2020 (the OSH Code): a registered medical practitioner with a recognised qualification who is also trained in an occupational health course. Rule 82 lists what the medical officer does, from issuing age and fitness certificates to conducting occupational health surveys.
Rule 81: the medical officer must be a medical practitioner with a recognised medical qualification under the National Medical Commission Act, 2019, enrolled on a State medical register, and trained in an Occupational Health course, including the ILO classification of chest radiographs, recognised by the Central Government. Rule 82: on a reference under section 42(2)(c), the officer gives prior notice of date, time and place, examines the worker and delivers an age and fitness certificate to the manager and the worker, keeping a copy. The officer can also be directed to examine, supervise and survey.
The Code provision behind the rules
Section 42 of the OSH Code lets the appropriate Government appoint medical practitioners "having prescribed qualification" as medical officers for factories, mines, plantations, motor transport undertakings and any other establishment as may be prescribed. A medical officer must disclose to the appropriate Government, before entering office, any interest in the concerned establishment (proviso to section 42(1)). Section 42(2) lists three duties: (a) examination and certification of workers in a mine, factory or other establishment engaged in dangerous occupations or processes as prescribed; (b) medical supervision where illness is reasonably believed to be due to a process or working conditions; and (c) examination and certification of adolescents for fitness for work likely to injure their health. See our section 42 explainer.
The Central Rules apply where the Central Government is the appropriate Government. Where the State Government is the appropriate Government, the State's own OSH rules prescribe the qualification and duties. If you are unsure which applies to your unit, a labour law compliance review will settle it.
Rule 81: who can be a medical officer
| Sub-rule | Requirement |
|---|---|
| 81(1) | A medical practitioner with any recognised medical qualification as defined in the National Medical Commission Act, 2019 (30 of 2019), enrolled on a State medical register as defined in that Act |
| 81(2) | Trained in an Occupational Health course, including International Labour Organisation classification of chest radiograph, duly recognised by the Central Government |
Two points follow.
- The qualification test is statutory, not just a degree. The practitioner must be enrolled on a State medical register. A degree without enrolment does not meet rule 81(1).
- The training is a separate requirement. The text asks for an Occupational Health course "duly recognised by the Central Government" that includes ILO chest radiograph classification. The rule does not name any course or institution, and it does not give a duration. The text is silent on these; do not assume one.
Rule 81 deals with qualification only. The disclosure of interest in the establishment comes from the proviso to section 42(1), which the rule does not repeat. Employers who propose a doctor to the Government should be ready to disclose any financial or employment link.
Rule 82: duties of the medical officer
Age and fitness certificate (rule 82(1) and (2))
When a reference is made under section 42(2)(c), the medical officer must:
- give prior notice regarding the date, time and place of the medical examination;
- examine the worker sent for the examination;
- prepare the age and fitness certificate; and
- deliver it to the manager of the establishment and to the worker concerned, after retaining a copy.
Under rule 82(2), the medical officer may seek the opinion of specialists, such as a radiologist, dentist or orthopaedic surgeon, "as the case may be", for determining age.
The rule does not fix a deadline for issuing the certificate and does not prescribe a form number or a fee in these sub-rules. The text is silent on those points.
Examinations and reports directed by the Central Government (rule 82(3))
The medical officer shall carry out such examination and furnish such report as the Central Government may direct:
| Clause | Subject |
|---|---|
| (a) | Examination and certification of workers in an establishment in hazardous processes specified in the First Schedule to the Code |
| (b) | Medical supervision of an establishment or class where cases of chronic occupational illness have occurred due to a hazardous process or hazardous condition of work |
| (c) | Establishments or classes where operations involve any risk of injury to the health of any person or class of persons employed |
| (d) | Occupational health survey of an establishment or class where cases of illness have occurred or there is prevalence of diseases specified in the Third Schedule to the Code |
| (e) | Assessing age and issuing fitness of an adolescent for employment in an establishment or class |
The word "direct" matters. Clauses (a) to (e) operate when the Central Government directs; the rule does not itself order every factory to arrange these examinations. Watch for directions and notifications that apply to your sector.
What employers and managers should do
- Know the officer's status. Check that the doctor sent to you holds the qualification and registration that rule 81 requires.
- Be ready to receive the certificate. The certificate goes to the manager of the establishment and the worker; keep your copy on file.
- Plan for adolescent workers. Rule 82(3)(e) links age and fitness to employment of adolescents. Do not place an adolescent on risky work without the certificate.
- Prepare for surveys. If illness or a disease from the Third Schedule has occurred, expect an occupational health survey on the Central Government's direction.
- Cooperate with the notice. Because the officer must give prior notice of date, time and place, arrange the worker's release and the venue.
Practical examples
Example 1. A chemical factory wants to place a 17-year-old on a process that may injure health. The reference under section 42(2)(c) goes to the medical officer, who gives notice, examines the youth, and hands the age and fitness certificate to the factory manager and to the worker.
Example 2. A doctor with an MBBS enrolled on a State register but with no occupational health training is proposed as medical officer. Rule 81(2) is not met; the training must be recognised by the Central Government.
Example 3. Several workers at a unit develop a disease listed in the Third Schedule. The Central Government directs an occupational health survey under rule 82(3)(d); the medical officer carries it out and furnishes the report.
Need help with medical officer and fitness compliance?
Medical, certification and survey duties sit alongside registers, notices and inspection readiness. Our team can map which of these apply to your establishment and who the appropriate Government is. Start with our labour law compliance service.
Key takeaways
- Rule 81 requires a medical practitioner with a recognised NMC Act qualification, enrolled on a State medical register, plus recognised Occupational Health training.
- The training must include ILO classification of chest radiograph.
- On a section 42(2)(c) reference, the medical officer gives prior notice, examines, and delivers an age and fitness certificate to the manager and the worker.
- Specialist opinions on age (radiologist, dentist, orthopaedic surgeon) are allowed under rule 82(2).
- Rule 82(3) examinations and surveys happen when the Central Government directs.
- Where the State is the appropriate Government, State rules apply.
Read next
- Section 42 of the OSH Code: medical officers
- Rules 83 and 84: employment of women and dangerous operations
- Rules 79 and 80: District Magistrate and experts for third party audit
- Mines Act: safety provisions and DGMS framework
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.