If 2025 taught safety leaders anything, it’s this: compliance pressure doesn’t arrive politely. It shows up as an inspection, an audit question you can’t answer fast, or an incident where the “paper process” collapses under real-world speed.

The Occupational Safety, Health and Working Conditions (OSH) Code, 2020 is now effective (notified for enforcement on 21 November 2025) and it consolidates 13 central labour laws into a single framework.
At the same time, the “how exactly” of implementation continues to evolve through rules and state-level notifications, which is where many organizations feel stuck.

So let’s remove the anxiety: you can get OSH Code ready without guessing. The trick is separating what’s stable (the operating system of compliance) from what varies (forms, thresholds in rules, state specifics).

This blog gives you a practical readiness method with a strong focus on:

• contractor compliance
• training & competence proof
• inspections that generate evidence
• records that don’t collapse into backfilling

“Without guesswork” starts with one clarity

The OSH Code sets the legal backbone and duties. Rules and state notifications fill in operational detail (specific formats, portals, state processes, and some thresholds).

Your readiness goal for 2026 is simple:

Build a system where safety activity automatically produces proof—so compliance doesn’t depend on memory, spreadsheets, or last-minute document chasing.

The four proofs auditors and inspectors look for (even when they don’t say it)

Across industries—manufacturing, construction, utilities—compliance questions tend to fall into four buckets:

1) Governance proof

Who is responsible, and is that structure active (not ceremonial)?

The OSH Code empowers the appropriate government to require a Safety Committee, and it defines when Safety Officers are mandatory—for example, factories with larger workforces, hazardous process factories at lower thresholds, building and construction, and mines.

What to prepare now

• Documented Safety Committee constitution (where applicable), meeting cadence, minutes, and action follow-up.
• A clear Safety Officer responsibility map: who owns PTW discipline, inspections, training compliance, and closure verification.
• A monthly management review rhythm where open risks and overdue actions are discussed and recorded.

This is governance that produces evidence, not governance that produces posters.

2) Competence proof (training that can be verified)

Training compliance fails most often in two places:

• contractors and short-term workforce
• refreshers and role-based competence

The OSH Code places clear duties on employers to provide information, instruction, training and supervision necessary for health and safety. It also includes duties like ensuring certain health examinations/tests as prescribed, and issuing appointment letters as required.

What to prepare now
Instead of thinking “training calendar,” think competence trail:

• Role → required training → completion record → renewal logic → evidence
• Contractor induction that is traceable to the person (not a generic register)
• Supervisor verification that the worker is cleared for the task type (high-risk work should not depend on “he’s experienced”)

A clean training system has one superpower: when asked “who is competent for this job today?”, you can answer in minutes, not days.

3) Control-of-work proof (permits, inspections, visitor control)

A big compliance risk in 2026 is not missing policy—it’s missing control at the “edge”:

• a contractor doing work with a lighter SOP
• visitors/vendors entering operational areas without traceability
• parallel jobs conflicting because permit discipline is weak

The OSH Code’s duty of the employer includes responsibility for the safety and health of employees, workers, and other persons on the premises—even with or without the employer’s knowledge (relevant when you think about visitors, vendors, and transient contractor presence).

What to prepare now

• Visitor/third-party entry workflow: purpose, area allowed, escort, PPE, acknowledgement, and time-stamped exit.
• Contractor onboarding workflow tied to work scope: documents, induction, role-based training, access permission.
• Inspection routines that verify critical controls (not just housekeeping).

This is where you convert “we have a process” into “we can prove the process was used.”

4) Closure proof (the end of open loops)

Most safety systems don’t fail at reporting. They fail at follow-through.

To be audit-ready, you need a closure engine:

• actions have owners
• due dates are real
• evidence is attached
• effectiveness is verified

This closure discipline becomes your best answer to every compliance conversation: “Yes—we found it, we assigned it, we fixed it, and here’s proof.”

Contractor compliance: the OSH Code reality on multi-employer sites

Contractor-heavy workplaces are where compliance breaks fastest, because responsibilities get blurred.

The OSH Code includes requirements around contractor licensing and principal employer responsibilities. For example: a contractor supplying contract labour generally requires a license, issued electronically, with defined validity, and employing contract labour through an unlicensed contractor is treated as a contravention under the framework.

What to prepare now (as a contractor compliance operating model)
Build a single contractor “compliance path” that runs end-to-end:

Prequalification
Contractor profile, scope, safety capability checks, document validity windows.

Induction & access
Training evidence, site rules acknowledgement, ID linkage, restricted zones, PPE issue tracking if relevant.

Work authorization
Permit linkage for high-risk tasks, supervisor approvals, tool/equipment checks, daily verification.

Field verification
Inspections and observations tagged to contractor + location + work type, with photo evidence.

Action & closure
CAPA tasks assigned to contractor or principal employer owners, escalations, closure proof, effectiveness check.

This model prevents the classic failure mode: “the contractor had their own method.”

Records and documentation: stop treating proof like a separate job

One of the most practical shifts in the OSH Code is that it explicitly enables maintaining registers and records electronically, and contemplates web-based inspection schemes and prescribed returns.

This matters because “paper compliance” fails under speed. Digital records don’t automatically make you compliant—but they make compliance repeatable.

What to prepare now
Create a “Compliance Proof Pack” that can be exported any time:

• permits raised/approved/closed (with attachments)
• inspection logs (with evidence)
• incidents and investigations (with action linkage)
• training completion + upcoming renewals
• contractor status + work scopes + inductions
• open actions by priority + overdue list + closure evidence

If you can generate this pack on demand, you’re not just audit-ready—you’re operationally controlled.

Where many teams waste time: waiting for perfect clarity

It’s smart to track rules and state notifications as they mature. But readiness doesn’t require waiting, because the big levers are already clear:

• accountability structure
• competence tracking
• control-of-work discipline
• evidence + closure

Even government and expert guidance around labour codes repeatedly flags that employers may need to navigate state rules and parallel local requirements while the ecosystem settles.

So your best move is to build the system now and adapt formats later—rather than doing nothing and hoping the final templates will save you.

How OQSHA supports OSH Code compliance (without turning this into a product pitch)

OSH Code readiness becomes easier when safety activity runs as one connected system:

• Inspections generate findings with evidence
• findings become actions (CAPA) with owners and due dates
• permits and high-risk work controls remain traceable
• training records stay linked to roles, sites, and contractors
• dashboards show what’s open, overdue, repeating, and high-risk

That’s the practical value: fewer blind spots, faster proof, tighter follow-through.

“If your safety evidence lives across paper, chats, and spreadsheets, OSH Code readiness will feel heavier than it needs to. OQSHA helps teams run permits, inspections, incidents, training, assets, and actions as one system—so proof is always available.”

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