Why labour codes offer little climate protection for women in manufacturing

Rama Devi (name changed), a 33-year-old garment worker in Gurugram’s Udyog Vihar, has a packed schedule six days a week. She wakes up at 6 a.m., gets her three children ready for school, packs lunch for her family and manages to reach the factory at 9 a.m. Her work station is on the fourth floor, the top-most in the building, where at least 400 workers sit glued to their sewing machines for 8-12 hours a day, barring a 30-minute lunch break. For every eight machines, a garment presser works on finalised garments.

A tailor for 12 years, Rama Devi finds summers particularly difficult due to the heat, made worse by tin roofing, known for higher indoor temperatures compared to cement- or slab-roofed structures. However, she has no means of knowing the actual temperature on the factory floor without a recording device.

“We get headaches and rashes around the neck. Women regularly faint. Even our phones get hot,” says 31-year-old Sameeta (name changed), another garment worker in Gurugram. Facing intense pressure to complete 60 pieces an hour, workers like Rama Devi and Sameeta tolerate the discomfort and continue stitching.

Workers’ welfare is covered under Occupational Safety, Health and Working Conditions or OSH code, 2020, one of the four labour codes rolled out on November 21, 2025. Experts say these codes have a blindspot for changing climate, as we explained in the first part of this series.

Workers can experience heat stress through a combination of environmental and metabolic factors. These factors increase heat storage in the body, leading to heat-related illnesses such as heat rash, oedema (swelling of hands, feet and ankles), muscle cramps, spasms of the feet and hands, syncope, exhaustion, and heat stroke, according to a government factsheet.

The factsheet was part of a public health advisory for 2026, which called on employers to provide cool drinking water, shaded work areas, hourly rest breaks, assign additional workers or slow down the pace of work, install temperature and forecast displays at the workplace, and train and inform workers on symptoms and protections.

Workers in garment units, glass factories and small workshops often labour for long hours in poorly ventilated, heat-trapping spaces where temperatures can be as severe as those outdoors, a 2026 report by the International Institute for Environment and Development (IIED), a nonprofit, noted.

Even at lower temperatures, humid heat can start to show adverse health impacts. Research shows that the combined effect of temperature higher than 32°C and humidity beyond 60% is hazardous for the human body, as ISignal explained in May 2025.

Garment manufacturing units frequently exceed the standards for wet-bulb globe temperature—28°C for moderate work and 25°C for heavy work—a 2026 report by HeatWatch noted.

Many workers living in overcrowded homes with tin or tarpaulin roofs do not get respite at home either, affecting their recovery before the next working day.

In this second of a four-part series, we examine how climate change impacts working conditions and wages of women workers in two sectors: garment industry, where women make up more than 50% of those employed in the apparel and textile sector, and automotive and auto component manufacturing industry, where women constitute 8.7% of the workforce.

We have reached out to the Ministry of Labour and Employment as well as state labour departments in Haryana, Uttar Pradesh, Delhi, and Karnataka for comment. We will update this report when we receive a response.

The new thresholds

“While the old [labour] laws had relatively better provisions for workers, they were not properly implemented. So, many workers, especially women, might not know what they have lost under the new Codes,” explains Akash Bhattacharya, a historian, lawyer and trade unionist based in Delhi.

The OSH code increases the threshold for “factories” from 10 workers with power to 20, and 20 workers without power to 40, as we explained in the first part of this series. The government has clarified that health, safety and welfare workers’ rights protection is applicable to establishments having 10 or more employees.

However, the Code states that the Union government “may” prescribe standards for providing on issues such as ventilation, temperature and humidity, potable drinking water, and prevention of overcrowding, and tasks employers of “factories” with maintaining health, safety and working conditions.

These thresholds exclude smaller establishments. For example, in 2021-22, garment factories employed 1.2 million workers across India, but factory workers account for less than 10% of the total employment in the garment industry, researchers from the Indian Institute of Technology, Delhi noted in a 2024 paper. “The rest of the garment workers were attached to micro, small, and household-based enterprises (with less than 10 workers in each),” they wrote. The industry is also an important source of employment for women, accounting for 37.8% of the female manufacturing workforce in the country in 2021-22.

“These thresholds significantly swing the balance in favour of the employer. The Codes have come in a policy climate in which the ease of doing business is trumping basic rights of people,” Bhattacharya explains.

Dhanraj B., senior manager, advocacy at Safe in India (SII), a nonprofit, explains that women perform substantially the same risky production tasks as men in the auto component manufacturing units, with heavy manual lifting being the main exception. They typically work with high-risk machinery such as power presses, tools that are designed to shape, shear, punch, bend, and form metal.

Power press machines, which can cause crush injuries and lead to amputations, account for the largest share (74%) of serious crush injuries in Haryana (2019 - 2025) and Maharashtra (2022 - 2025), according to Crushed 2026, SII’s annual report on the Indian automotive manufacturing sector.

Working conditions

Smita (name changed), a 40-year-old garment worker in Gurugram, says that women fainting in the factory due to indoor heat and exhaustion is a common sight. “We sit under a ceiling fan but it barely gives any relief. Our eyes burn. We get headaches. We also feel a burning sensation when we urinate,” she says.

Despite the discomfort, workers have no choice but to go on. “Our targets are stiff. We are expected to complete stitching 60 pieces in an hour without breaks, regardless of how hot it gets. And if we fail to meet our targets or spend more than five minutes in the washroom, the supervisors humiliate us,” Smita adds.

“It is extremely stressful. They speak rudely to women, and we do not often retaliate,” Sameeta says.

The HeatWatch report found that 87% of 115 garment factory workers in Tamil Nadu and Delhi reported experiencing acute heat-related issues, such as headaches, dizziness, and muscle cramps, within the last year.

In the automotive sector, workers’ access to cooling depends on the size of the factories. Arti Devi, aged 40, is an operator at a factory in Faridabad that employs about 25 people, of whom 15 are women.

“We have 15 machines and two coolers. Those seated away from the cooler feel hot during summers,” she says. “And when I do not feel well, I take a leave and lose wages for that day,” she says. Arti Devi has been a contract worker for about four years now. She lost a part of her fingers in August while operating a power press. In 2025, she suffered another such injury.

“Power press machines generate heat at the work position. In addition, corrugated metal roof, poor cross-ventilation, sheet-steel stacks radiating stored heat, also contribute to the heat,” explains Dhanraj.

Nibha Kumari, a 33-year-old operator working with a different automobile component factory in Faridabad, lost her left palm eight months ago. Her workplace employs 200 people, of whom 70-80 are women, she says. “We have a tin roof and we have a cooler for each of the 30 machines. Sometimes, I get headaches during intense heat in the summer while working. To cope, I splash cold water on my face,” she adds.

Both women say their factories have no windows for ventilation. However, they get access to cool water. They also get a 30-minute lunch break, with two five-minute tea breaks during the day.

While Arti Devi is not given a daily target, she says her supervisor constantly monitors workers to ensure they do not waste time. Kumari is given a target ranging from 50-600 pieces, depending on the kind of work and material. “There is some pressure to meet our targets. Sometimes, our machines do not work. So we cannot do anything in those circumstances,” she says.

Low wages, limited growth

In the garment sector, women dominate smaller enterprises in the lower tiers of the garment supply chain and often trail men in terms of equal pay for work of equal value, according to the International Labour Organization (ILO), as we explained in the first part of this series.

“In the automotive sector, women workers experience virtually no career progression, in contrast to albeit rare instances of men being promoted from operators to supervisory roles,” the 2026 Crushed report notes, adding that these factors “collectively deepen their vulnerability to injury and exploitation”.

Low wages also make it challenging for women to cope against climate impacts. All seven garment workers that ISignal spoke with walked to work to save costs.

For example, 45-year-old Sameera (name changed), a resident of Kapashera in Delhi, starts her day early to ensure she saves money and reaches the factory on time. “It takes about 20-25 minutes by walk. If I am even two minutes late, I could be sent home, which means I’d lose a day’s wage. This is especially hard when it rains and the roads get waterlogged. Regardless of how bad the condition is, we have to report to the factory on time,” says Sameeta, who earns around Rs 16,000 a month.

Kavita (name changed), a 35-year-old garment factory worker in Kapashera in Delhi, reaches her factory on foot, which takes about 40 minutes. “I have become used to the heat. Shared autos cost me Rs 40 a day. I can use that money to buy vegetables instead,” the mother of six explains. Being the sole breadwinner, every penny counts, Kavita says, adding that cost of living is high and she earns around Rs 16,000 a month.

Haryana increased its minimum wages for all the employment in April 2026 ranging from Rs 585 per day for unskilled workers to Rs 747 per day for highly skilled workers.

“After our wages have increased, our targets have also gone up,” Kavita said. “Before the revision, my target was to stitch 40 pieces an hour and now it is 60. They are increasing targets so we buckle under pressure and leave the job,” Rama Devi says, adding that she still manages to complete 40-45 pieces in an hour.

“The garment industry is labour-intensive and women dominate the sector. This probably explains why the minimum wages are among the lowest for the garment workers in Karnataka. Unskilled workers in this industry get Rs 13,200 a month in Bengaluru,” explains Prathibha R., a labour rights activist and the president of the Garment and Textile Workers Union (GATWU) in Bengaluru.

The situation in the automobile sector is not too different. Arti Devi earns a monthly wage of Rs 13,500. Her partner, who is also an operator, earns Rs 14,000. They spend Rs 3,000 for rent and look after her five children. She does not have any savings at the end of the month.

Kumari was drawing Rs 14,000 a month (before losing her left palm) with five years of experience as an operator. Her colleague, Ram (name changed), who also has about six years of experience, earns Rs 17,000, an increase of Rs 3,000 since Haryana revised minimum wages.

Worker-reported data captured in SII's 2024 report show that women are paid less than men for the same risk. “Further, workers report to us that factory owners or management say they prefer women workers because women take fewer breaks and do not protest," explains Dhanraj.

Arti Devi, who is not educated, joined the industry because she learned that no experience was needed to operate a power press and the salary was decent.

All the workers say they work overtime. Rama Devi gets double wages for overtime work. “My income increases to Rs 20,000 and this is a big help,” she says.

Kumari and Arti Devi also work overtime but do not get double wages. “We also work on Sundays if they call us. Extra money helps us,” Kumari says.

Social protection schemes exist, yet many remain exposed

Climate change could harm workers in multiple ways. This could either result in loss of a day’s wage, an intravenous drip paid through out-of-pocket expenditure, a slower afternoon’s work, food that spoils before it can be eaten, a night without sleep, the IIED report explains. “Households quietly absorb such losses, often through borrowing, untracked by any institution,” it adds.

Managers of nine garment factories saw worker productivity drop by roughly 3% to 10% and absenteeism increase by 2% to 5% during peak summer months, according to a June 2026 report by New York University’s Stern Center for Business and Human Rights.

This leads to a decline in income, in addition to extra costs during treatment of heat-related illness, higher electricity bills to run fans or cooler, additional spending on hydrating drinks and food, as well as using shared autos for commuting to work, the report noted.

One tool that could help workers cope with climate impacts such as heat-related illnesses is Employees' State Insurance Corporation (ESI), a social security scheme available to workers in establishments employing 10 or more persons, drawing monthly wages up to Rs 21,000. It is financed by contributions from employers (3.25% of wages) and employees (0.75% of wages). ESI was earlier covered under Employees' State Insurance Act of 1948 and has now been subsumed under the Code on Social Security, 2020.

Unlike most private insurance that covers hospitalisation, ESIC is a unique scheme that covers various dimensions of work and health, explains Indranil Mukhopadhyay, professor at the School of Government and Public Policy, OP Jindal Global University. “In the context of climate change, we see heat-related stress in factory settings and urban areas. Those involved in manual work are facing increased occupational diseases, which might require prolonged treatment and not hospitalisation,” he says.

ESI performs two functions: First, income protection through cash transfers during sickness, maternity, temporary or permanent disability, occupational disease, or unemployment. Second, it finances healthcare, determines coverage and payment for treatment and direct delivery of healthcare through its own hospitals and dispensaries.

“When a worker falls sick, treatment costs are not the only expense. There are associated expenses such as decline in family income when an earning member is unwell, or becomes disabled or loses life. ESI covers this,” Mukhopadhyay explains.

Still, of the seven garment workers in Udyog Vihar ISignal spoke with, none had used the ESI card for primary health care. “We rely on private clinics for outpatient care,” says Sameeta. Rama Devi, for example, visits a private clinic near her residence in Kapashera and spends an average of Rs 1,500 for consultation and medications. This amounts to about 10% of her monthly wages.

“Availability of diagnostic services for secondary care (basic hospital services with specialist doctors) needs strengthening as patients are forced to get a diagnosis in the private sector. Primary care also needs strengthening, as do the supply and quality of medicines,” Mukhopadhyay adds.

But ESI’s dispensaries per 100,000 insured persons have halved from 9.80 to 4.47 over 15 years, SII found.

A 2023 report from Cividip, a nongovernmental organisation based in Bengaluru, found most garment workers prefer private healthcare options over ESI, despite having to spend 25-30% of their wages. This preference could be due to convenient access and better quality of care at private clinics.

“The ESI facility is far away,” says Kumari. Arti Devi agrees. She says she cannot afford to wait for hours at the ESI dispensary. She estimates that she spends Rs 2,000 for consultation and medications at private clinics, which is 15% of her monthly wage.

There are other factors that discourage workers.

“ESI dispensaries have not been set up in some of the newer industrial areas. The other issue is that when workers are registered with ESIC, they are not matched by a consultant hired by the contractor or employer to the dispensary closest to the worker,” explains Dhanraj. In many cases, he adds, SII has seen that workers were matched to the first dispensary that appears in the drop-down menu in the online form, which might not necessarily be the closest to the worker.

Further, registrations are often delayed. Three in five injured workers received their ESIC e-Pehchaan card only after their accident, as ISignal reported based on SII’s 2026 report.

Mukhopadhyay hopes that ESI will set up a strong system of periodic medical camps, screening programmes across factory settings. Employers fear that such camps could waste workers’ time and be counterproductive, he says. “If workers are diagnosed and treated early, they are more likely to be fitter and more productive, which might eventually save costs for employers. Global evidence suggests that social health is intrinsically linked to labour productivity,” he explains.

The Code on Social Security, 2020, does not mandate such screening. Instead, it says that ESIC “may” take preventive and curative measures for welfare of the insured persons and carry out such occupational and epidemiological surveys and studies to assess their health and working conditions.

Challenges in compensation

The Code on Social Security, 2020 recognises diseases due to extreme heat and cold as occupational diseases. This means employers are liable for compensation for diseases that result from workplace exposures and hazards. This is similar to the Employee’s Compensation Act, 1923, which has been subsumed under the Code on Social Security, 2020. But this is only applicable to specified workers.

“If a worker has a heat-related illness, they can get a sickness certificate from a doctor and submit it. Those workers will get sickness benefits, which means 70% of their wages will be given,” says Ashok Kumar Singh, Director General of Employees' State Insurance Corporation (ESIC).

However, this gets complicated if a heat-related disease results in permanent disability or even death. For example, heat stroke can cause permanent disability or death if the person does not receive emergency treatment.

“Once disability or death is attributed to employment, a person can get permanent disability benefit (to avail monthly pension) or dependents’ benefit (periodic support to eligible dependents in case of death due to employment injury or disease),” explains Dhanraj. But data from occupational diseases such as silicosis, where attribution is hard, show that this attribution is precisely where workers (and their families) are most likely to be blocked, he adds.

Vidhya Venugopal, country director for the Centre on Environmental Change and Non-Communicable Diseases at the National Institute for Health and Care Research, also fears that attributing heat- and cold-related diseases to occupational exposure might not be easy.

“Symptoms like fatigue, dizziness, and nausea are non-specific and they overlap with many other conditions,” she explains. Factors such as age, hydration status, nutrition, and pre-existing health conditions also interact with heat exposure, making it difficult to say that heat alone caused a particular illness, she adds.

Venugopal, who is a professor of occupational and environmental health at the Chennai-based Sri Ramachandra Institute of Higher Education and Research, points out another issue. “Many of the most serious effects of heat exposure are chronic and delayed, and they emerge gradually over years of exposure,” she says.

A recent study published in BMC Nephrology showed a link between occupational heat stress and chronic kidney disease (CKD). The kidneys, it explains, play a crucial role in regulating body temperature and fluid balance, making them particularly vulnerable to heat-related illnesses.

Venugopal’s 2020 study of 340 steel workers engaged in moderate to heavy labour found that of the heat-exposed workers who underwent renal ultrasound, a third showed kidney stones or structural renal anomalies significantly higher than unexposed workers. “These are workers who may feel broadly unwell but have no acute, easily attributable event,” she says, adding that this factor makes formal recognition and compensation extremely difficult.

The ILO estimates that 26.2 million people worldwide were living with CKD linked to workplace heat stress in 2020. “Yet the costs associated with treatment, reduced earning capacity and declining health often emerge years after the original exposure and are rarely attributed to heat,” the IIED report says.

For cold exposure, Venugopal explains, the challenges are compounded by the fact that it is understudied in India, and that it is relevant only to specific sectors and regions. Garment factory workers in Gurugram tell ISignal that they do not find the winters too troubling. “The machines produce heat and that helps us stay warm,” says Kavita.

Venugopal also flags practical barriers for factories. “Smaller enterprises often lack occupational health infrastructure, routine monitoring is rare, physician awareness of occupational contributions is low, and underreporting is widespread,” she says, calling for standardised diagnostic and exposure criteria. “Without this, even a well-intentioned policy provision struggles to function in practice,” she warns.

The OSH Code, 2020 rules mandate that every factory, mine and building or other construction employing more than 500 workers be equipped with a suitable ambulance room or dispensary with a full time qualified medical practitioner and adequate number of paramedical staff. Karnataka had amended the threshold to 200 workers in the state.

Garment workers in Udyog Vihar in Gurugram told ISignal that their factories have a medical room but are unsure of whether it is manned by a doctor. “People are taken in when they faint and given Oral Rehydration Solution (ORS). We have seen a woman in the medical room but we do not know if she is a nurse or a doctor,” says Kavita. Nibha Kumari says there is no medical room at her automotive component factory. “We have a first aid kit and some common medications,” she explains.

Meanwhile, as Haryana is yet to finalise rules under the new Codes, garment workers hope to see an improvement in working conditions and wages. “We get a 30-minute break for lunch. It would be nice to have a longer break,” explains Sameeta.

To ensure a decent standard of living, all seven women in the garment sector would like to see their salaries go up by at least Rs 3,000. For Nibha Kumari, she would like her workplace to have an ambulance, given that injuries are common. As she plans to return to work this month, she is determined not to use the power press machine again. “What will I do if I lose my other hand?”

This is the second of a four-part series examining India's labour codes and climate risks for women workers. You can read the first part here.

This report is republished with permission from ISignal, formerly IndiaSpend, a data-driven, public-interest journalism non-profit. It has been lightly edited for style and clarity.