What Does the Heat Emergency Mean for Workers?

The government needs to urgently review their current approach to protect workers from occupational heat exposure

A lot has been written about the rising temperatures and unprecedented heatwaves ever since the beginning of April, but what do the rising temperatures mean for workers who do hard physical labour?

A new report by the International Labour Organisation (ILO) has warned that out of a global workforce of 3.4 billion, over 2.4 billion workers are likely to be exposed to excessive heat at some point.

In India, 90 percent of the labour force is engaged in the informal sector, performing outdoor jobs that involve physically demanding tasks in agriculture, construction, brick kilns and other similar fields, workers face significant risk due to heat stress.

The impact of heat on workers creates a “cocktail of hazards”, which results in serious health conditions such as chronic kidney disease, organ damage heat exhaustion, heat cramps, heat strokes, miscarriages or stillbirths, loss of unconscious, fungal infections, respiratory ailments, and ultimately death.

The technical term given to such work conditions is called “occupational heat exposure” (OTE) which includes factors such as outside temperature, and metabolic heat from exertion.

What Steps Has the Government Taken So Far?

The Indian government declared heatwaves as a natural disaster under the National Disaster Management Act of 2005 as late as 2015. In April 2016, the NDMA drew up national guidelines ‘Preparation of Action Plan-Prevention and Management of Heat Wave’, which were twice revised in 2017 and then in 2019.

A few days ago, the Union Health Ministry held a review meeting with States on Heatwave Preparedness. States and Union Territories were urged to take proactive measures to prevent incidents caused by extreme heat by developing their own Heat Action Plans.

For example, some of the measures proposed by the Delhi Disaster Management Authority 2024-25 (issued by the Delhi Disaster Management Authority) are early warning by the India Meteorological Department (IMD), construction of shelters, ensuring drinking water at major points, ensuring shade to traffic place personnel.

Measures taken for workers include recognising “working individuals” as vulnerable groups during heatwaves; organising training for employees, outside labourers and workers; changing the shift of outdoor workers from peak hours; and preparing emergency kits for construction workers.

Subsequently, the Labour Department of Delhi on 30th May issued a circular asking establishments to ensure clean drinking water, coolers and fans in the workplace and also sensitise workers to take precautions such as covering their heads, among other measures. The circular also says that no worker should be allowed to work in direct exposure to sunlight and advises a change in the shift of work to avoid peak hours between 12 noon and 4 pm.

While the exact number of Heat Action Plans in the country is unknown, the National Disaster Management Agency and the India Meteorological Department are currently working with 23 states to develop HAPs.

Despite these efforts, the Indian government needs to urgently review their current approach to protect workers from occupational heat exposure. Although the Heat Action Plans are a welcome step to protect vulnerable sections, the effectiveness of these measures is not being monitored at present. The HAPs released by state and local governments are advisory and are not binding on employers.

There needs to be legislation to ensure that employers are legally mandated to provide breaks of an appropriate duration, in cooled shaded areas, where there is an occupation risk of heat stress. Mandatory break times should take into account, the environmental heat risks – using the Wet Bulb Globe Temperature (WBGT) as an index – along with the exertional nature of the work being performed.

What Needs to be Done?

Firstly, the India Meteorological Department’s definition of heatwave needs to be updated. The IMD declares heatwave only based on maximum temperature. A heatwave is proclaimed when the highest temperature at a station surpasses 45 degrees Celsius; if it exceeds 47 degrees Celsius, it is referred to as a severe heatwave. Heatwaves in coastal and hilly locations are declared using similar criteria.

The human body, however, reacts to a combination of heat and humidity, measured as the “wet-bulb temperature”. The wet-bulb temperature can be high even when the temperature is relatively low. For example, if the temperature is 35 degrees Celsius and the relative humidity is 80 percent, the wet-bulb temperatures will be 32 degree Celsius, which is considered dangerous for manual labour. Similarly, if the temperature is 40 degrees Celsius and the relative humidity is 75 percent, the wet-bulb temperature is about 36 degrees Celsius.

Few humans can tolerate a wet-bulb temperature exceeding 35 degrees Celsius because their bodies can no longer cool themselves. Many regions of India now experience wet-bulb temperatures exceeding 32 degrees Celsius during certain parts of the year. However, we are not declaring such days to be heatwaves, endangering the lives of people engaged in manual labour.

The United States Occupational Safety and Health Administration (OSHA) recommends that employers should consider any Wet Bulb Globe Temperature (WBGT) reading of over 25 Celsius as a trigger for acclimatised workers to stop and take a break from strenuous work.

Secondly, the Government must not restrict measures to shifting summer working hours. Most Heat Action Plans recommend that employers shift outdoor work schedules away from peak afternoon hours (12-4 PM). Rather than rudimentary summer working bans, India must adopt international best practices on heat stress and require the implementation of work-rest ratios (or “activity medication”) based on the prevailing WBGT.

The US National Institute for Occupational Safety and Health Administration (NIOSH) has issued some of the most detailed available guidance in a 192-page report. In addition to NIOSH, International Standards Organisation (ISO) Standard 7243 recommends the use of WBGT and specifies recommended rest/work cycles at different physical work intensities.

Studies have shown that nighttime temperatures are warming faster than daytime ones, which means that if workers are in daytime heat at work but nighttime temperatures are sufficiently hot, their bodies cannot cool themselves.

Thirdly, while most HAPs recognise broader categories of vulnerable groups, the list of solutions they propose does not necessarily focus on these groups. The HAPs need a more nuanced understanding to recognise specific occupations and livelihood groups and how heat impacts these groups differently.

For example, workers working in brick kilns are particularly vulnerable because they are not only exposed to high outside temperatures but also radiant heat from furnaces. These conditions are exacerbated by poor living conditions and a lack of access to welfare benefits. A suitable solution can only be found by recognising specific livelihood groups and the unique challenges that heatwaves pose to them.

(Moksha Tarini is a lawyer based in New Delhi. This is an opinion piece and the views expressed above are the author’s own. The Quint neither endorses nor is responsible for them.)