Visitor management for factories in India: contractors, gate passes and gate entry

Factories and plants at a glance

What the OSH Code 2020 and contract labour rules ask at the factory gate

The Occupational Safety, Health and Working Conditions Code, 2020 came into force on 21 November 2025, consolidating thirteen labour laws including the Factories Act, 1948 and the Contract Labour (Regulation and Abolition) Act, 1970 (Lakshmikumaran & Sridharan). A “factory” has 20 or more workers where manufacturing uses power, or 40 or more without power (section 2(1)(w)). Three provisions shape the gate.

• Everyone on the premises. Section 6(1)(h) requires the employer in a factory to “ensure and be responsible for the safety and health of employees, workers and other persons who are on the work premises of the employer, with or without his knowledge”. Contractors, drivers and visitors are all “other persons”.
• Training. Section 6(2)(c) requires “such information, instruction, training and supervision as are necessary” for the health and safety of all employees at work. The text names employees; in our reading, section 6(1)(h) is the stronger basis for inducting visitors and contractors.
• Records. Registers may be kept “electronically or otherwise” (section 33).

The principal employer. For a factory, the principal employer is the owner or occupier, or a named manager (section 2(1)(zz)). Part I of the Code’s contract labour chapter (licensing, welfare and wages) applies where 50 or more contract workers are employed, up from 20 (section 45; Lakshmikumaran & Sridharan). It makes the principal employer liable for welfare facilities (section 53) and for wages a contractor fails to pay (section 55), and section 54 deals with contract labour from a “non-licenced contractor”. The threshold does not limit section 6, which covers every contract worker, and the Code counts the contractor as an employer too (section 2(1)(u)). BTG Advaya advises checking each contractor’s registration and licence before engaging them.

State rules. Factories fall under state rules; the Central Rules of 8 May 2026 cover establishments where the Centre is the appropriate government (Lakshmikumaran & Sridharan). Trilegal reads the Ministry’s transition statement as keeping rules under the old Acts in force, where they do not conflict with the Code, until a state notifies its own. Rajasthan, Bihar and Andhra Pradesh had notified final rules by August 2026 (Lakshmikumaran & Sridharan); Maharashtra published draft factory rules in May 2026. Check your state’s status.

Factory gate entry process: four scenarios

7:40 am, shift change at the main gate. Sixty contract workers from three contractors arrive for the 8 am shift as the night shift leaves. Santosh Pawar, the guard, cannot check sixty faces against a logbook. Regular contract workers use the attendance reader, against lists each contractor keeps current. The eight new boiler shutdown workers should have been registered by their supervisor the day before, inducted on their phones and ID-verified where policy calls for it. Anyone without an induction record waits, and night shift exits must be captured or the headcount is wrong all day.

10:20 am, a transporter’s new driver at the material gate. A solvent tanker arrives with an unfamiliar driver. The guard checks the vehicle number against the transporter’s advance intimation, the invoice and e-way bill, and the licence endorsement: rule 9 of the Central Motor Vehicles Rules, 1989 requires a driver carrying dangerous or hazardous goods to hold a certificate of passing the training course the rule prescribes, and in April 2025 the Supreme Court treated a missing endorsement as more than a technical breach. The driver gets the site rules (speed, no smoking, PPE at the bay) and waits in the drivers’ area.

11:00 am, a customer audit team. Four auditors from an export customer. Their company has signed an NDA, but each person should accept your confidentiality and photography rules, get PPE and a pass limited to the agenda’s areas, and stay escorted. Expect them to ask for contractor induction records and your last drill report.

2:10 am, a vendor engineer for a breakdown. A compressor trips and Imran Shaikh, the shift in-charge, calls the vendor, whose engineer arrives at 3:30 am. The usual approver is asleep, so a named backup approves, the engineer does a short induction at the gate, and no work starts until a permit-to-work is issued. He stays in the headcount until he leaves at 5:45 am.

Safety induction, permit-to-work and the evacuation headcount

Induction before arrival. An induction delivered to a queue of sixty is a formality. Send it before the visit, in a language the worker reads, with a short check at the end, and keep the record. At the gate the guard confirms it, issues PPE and briefs on that day’s hazards. ISO 45001:2018, still current (SGS expects its revision in 2027), brings contractors into its procurement controls (clause 8.1.4), so certification auditors look for this record.

Permit-to-work. The induction lets someone onto the site; a permit lets them do hot work, confined space entry, work at height or electrical isolation. The issuer checks the induction record before signing, and the permit names the people on the job.

Headcount. Contractors are the people most likely to be missed: in a tank, on a roof, at the effluent plant. Factories that must prepare an on-site emergency plan under the Manufacture, Storage and Import of Hazardous Chemical Rules, 1989 (rule 13) must also run a mock drill of it every six months, according to DGFASLI. In a real emergency, report anyone unaccounted for to the fire service at once, search only where safe, and let nobody back in until the fire officer in charge clears it. See our evacuation roll call guide.

Material gate pass and vehicles: returnable and non-returnable

GST rules sit behind the returnable pass. Goods sent for job work move under a challan (CGST Rules, rules 45 and 55); inputs must come back within one year and capital goods within three, or the dispatch is treated as a supply (section 143, which excludes moulds and dies, jigs and fixtures, and tools). An e-way bill is generally needed above ₹50,000 consignment value, and goods sent to a job worker in another state need one whatever their value (rule 138, as Circular 38/12/2018 explains).

Foreign technicians, customer audits and auditors

Foreign technicians. In December 2025 DPIIT announced the e-Production Investment Business (e-B-4) visa for work such as installation and commissioning, quality checks, maintenance and training. The Indian company generates the sponsorship letter on the National Single Window System, and the technician quotes it when applying online. Confirm before the visit that the visa covers the work, and apply the same escort and permit rules as for any vendor engineer.

Reporting to immigration. The Immigration and Foreigners Act, 2025 has applied since 1 September 2025. Its reporting duties fall on accommodation providers (section 8, a Form III return within 24 hours of arrival), educational institutions (section 9) and hospitals (section 10). In the provisions we checked, a factory has no standalone duty to report a foreign visitor who comes for the day. If the technician stays in your plant guest house, section 8 may apply to you as the keeper of that accommodation: confirm with counsel.

Contractor and visitor data under the DPDP Act

Gate records in a spreadsheet or visitor management system are digital personal data. Most duties under the DPDP Rules 2025 apply from 13 May 2027 (Rule 1(4)); some firms, including Cyril Amarchand Mangaldas, give 14 May 2027. A proposal to shorten the timeline was floated in January 2026 (Business Standard); as of 12 October 2026 no change had been notified (S.S. Rana & Co.).

• Contract workers are unsettled ground. PSA Legal (August 2026) reads the employment ground in section 7(i) as the contractor’s; whether the principal employer can use it for attendance, safety and CCTV “is not expressly settled by the Act”. It treats the plant as a data fiduciary in its own right for site access, CCTV and safety training records.
• Visitors, drivers and vendor engineers should get an itemised notice before you collect anything (section 5(1), Rule 3), in English or any Eighth Schedule language they choose (section 5(3)). We advise English, Hindi and the state’s main language at the gate, others on request, since many contract workers come from other states.
• ID verification where your policy calls for it: record “verified, by whom”, not the number or a copy.
• Your guard agency is usually your data processor, so you need a valid contract with it (section 8(2)). Check its licence on the MHA’s PSARA portal.
• Retention. Rule 8(3) sets a one-year minimum for personal data, traffic data and processing logs “for the purposes as specified in the Seventh Schedule”, which Cyril Amarchand Mangaldas and Lakshmikumaran & Sridharan read as binding every data fiduciary. Keep the visit record and its logs for a year, then erase them; records another law requires follow that law (section 8(7)). Keep photos and mobile numbers for days, as a written decision your DPO and counsel sign off.

Phones, cameras and theft: protecting the plant

A phone camera is the cheapest route to your tooling, layouts and process settings. India has no specific trade secrets statute; protection rests on contract, equity and general law (Anand and Anand, Chambers Trade Secrets 2026), and the Law Commission recommended a Protection of Trade Secrets Bill on 5 March 2024. Your NDA and site rules are most of your protection.

• Photography rules by area, accepted by each visitor at check-in.
• Phones in sensitive areas: lens stickers or deposit at the entrance, with a named exception process for auditors, and no phones in flammable areas unless your safety officer has approved the device.
• Escorts for non-employees not inducted for that area; drivers stay in their area and the bay.

Recommended set-up for a factory gate

1. Decide who is a visitor. Employees and regular contract workers use your attendance system; everyone else goes through visitor management.
2. Define visitor types, each with its own questions and pass validity: customer, auditor, vendor engineer, day contractor, driver, candidate, foreign national, official.
3. Set approvals with backups. Every host has a named backup, and the shift in-charge approves out of hours.
4. ID verification for the types your policy names, usually contractors and drivers, recording only who verified it.
5. Inductions and NDAs before arrival, phone and camera rules at check-in, yearly refresh and a gate briefing on the day’s hazards.
6. Link inductions to permits-to-work, so no permit names someone without a current induction.
7. Passes limited to areas and valid until the end of the shift or visit.
8. Separate registers for people, vehicles and material, with returnable passes reviewed weekly.
9. A live headcount that includes contractors and drivers, tested in every drill.
10. Retention: visit records and logs for one year, photos and mobile numbers for days.
11. Contracts: processing terms with the guard agency; a licence check, induction, worker list and data terms with every contractor.

Common mistakes at factory gates

• One register for everything. People, vehicles and material in one book that no guard fills in fully.
• Contractors outside the headcount. Employees are counted at the assembly point; the shutdown crew is not.
• Induction once, at joining. A worker inducted three years ago for one area is now welding in another.
• The 2 am phone call. A vendor engineer let in on a manager’s verbal approval, with no record, permit or exit time.
• Copies of every contract worker’s ID in a cabinet in the security cabin.
• VIP exceptions. Senior customers excused from PPE and photography rules.
• Guards photographing the register for a WhatsApp group at shift end.

Where Orb fits

Orb, our visitor management system, works at a plant gate with no new hardware: print the QR poster and start.

Questions buyers ask