‘Warehouses are becoming heat chambers’: Amazon India Workers' Union flags OSH Code's silence on indoor heat hazards

THE AMAZON INDIA WORKERS UNION (‘AIWU’), a trade union representing the warehouse workers employed at Amazon India, has filed a formal representation before the Ministry of Labour and Employment raising serious objections to the Occupational Safety, Health and Working Conditions Code, 2020 (‘OSHWC Code’) and the draft Rules framed thereunder in 2025. 

The representation, signed by AIWU President Dharmendra Kumar and addressed to Shri Ravi Shankar Nirala, Under Secretary to the Government of India in the Ministry of Labour and Employment, argues that it is “imperative that the Code and the Rules have specific provisions relating to the requirement of minimum/maximum standards of heat, along with protective and preventive measures to safeguard against heat exposure.” It warns that the new Code and Rules not only fail to introduce any new safeguards against occupational heat stress, but have in fact dismantled protections that had existed for decades under the Factories Act, 1948.

A crisis hiding in plain sight

AIWU situates the objections within India's deteriorating heat crisis. Last year, record-breaking heat waves pushed temperatures above 50 degrees celsius in parts of the country. In 2024, more than 44,000 cases of heat stroke were officially recorded, a figure that AIWU notes is likely a significant undercount, as most cases in rural and informal settings go unreported.

Prolonged exposure to temperatures above 30 degrees Celsius, the trade union notes, is medically associated with heat exhaustion, heat stroke, increased workplace accidents, and long-term cardiovascular, respiratory, and reproductive harm. The 16th Finance Commission itself recommended adding heatwaves to India's national disaster list yet neither the new Code nor the Rules translate this recognition into enforceable workplace protections.

Warehouse workers as a uniquely vulnerable group

AIWU's objections pay particular attention to the conditions faced by warehouse workers. The trade union flags a 2024 media report documenting that Amazon warehouse workers in India were reportedly made to pledge not to take water or bathroom breaks during a heatwave. The nature of warehouse work which includes carrying heavy materials, pushing heavily loaded carts and moving at rapid speeds is classified as a “high metabolic rate activity” that significantly elevates internal body temperature. 

The trade union points out that warehouses, by virtue of their sheer physical size, are extremely difficult to keep cool. Moreover, existing cooling and ventilation systems are often incapable of sufficiently reducing workers’ body temperatures when outside heat is combined with the metabolic heat generated by physical exertion.

What the law stripped away

AIWU gives a detailed account of what the new Code has dismantled. Under the Factories Act, 1948, Chapter III contained specific statutory protections addressing ventilation, temperature, thermal insulation and separation of high-heat industrial processes. Section 13 of the Factories Act required every factory to maintain “effective and suitable provision” for adequate ventilation and a “reasonable temperature,” and empowered state governments to prescribe specific wet-bulb and dry-bulb temperature limits and mandate the installation of monitoring instruments. The Model Factories Rules adopted by many states had set a maximum wet-bulb temperature of 30 degrees at 1.5 metres above the floor.