Laborers feel the Heat of the Enforcement Gap in Mumbai’s Heatwave Response

This article was originally published in 101 Reporter under Creative Common license. Read the original article.

By Vibha Singh

Mumbai, Maharashtra: At 2.30 pm, under a half-built flyover in Mumbai, Ramesh Yadav (32) is still mixing cement. The concrete slab above traps the heat. His shirt is soaked through. There is no shade, only a pillar. “Hum kaam nahin rok sakte (We cannot stop the work),” he told 101Reporters. The heat becomes unbearable as early as 8am but for workers like Yadav, a few hours off the job mean a day’s earnings gone. 

In March and April 2025, temperatures in Mumbai and Thane touched 40°C, prompting the India Meteorological Department (IMD) to issue a yellow alert for heatwave conditions. According to the IMD, a heatwave is declared in coastal cities such as Mumbai and Thane when temperatures reach 37°C or higher and remain at least 4.5°C above normal for at least two consecutive days. 

Experts say dense urban regions are particularly vulnerable because concrete-heavy development, shrinking green cover and the urban heat island effect intensify heat exposure. A Proceedings of the National Academy of Sciences (PNAS) study across Asia, Africa and the Middle East found that urbanization worsens human-perceived heat stress in fast-growing cities.

Even during heatwave alerts, informal workers in Mumbai and Thane rarely stop working. Both cities have heat advisories and Standard Operating Procedures (SOPs) for outdoor workers, issued by the Maharashtra State Disaster Management Authority (SDMA) in coordination with District Disaster Management Authorities (DDMAs). On the ground, however, workers, contractors and even officials say there is little clarity on who is responsible for enforcing them — or whether anyone can legally stop work during extreme heat.

Shweta Damle, director of the Habitat and Livelihood Welfare Association (HALWA), explained why. “As of now, the SOPs appear largely advisory rather than explicitly legally enforceable. The language used in government communications repeatedly refers to them as guidelines, advisories or directions.” Neither the Brihanmumbai Municipal Corporation (BMC), Thane Municipal Corporation (TMC) nor labor department routinely exercises powers to halt a private commercial project’s outdoor manual labour due to ambient heat alone, and the plans carry no statutory penalties for non-compliance.

The pressure to keep working

For workers in the gig economy, the pressure is algorithmic. Delivery riders receive “stay safe” notifications on the same screen that counts down delivery timers. On a delivery route along Ghodbunder Road in Thane, rider Imran Khan describes the reality of his working conditions. “If I cannot complete orders, my incentives drop. No one tells us to stop because of the heat.”

“To earn a decent amount or qualify for incentives, workers often have to work between 12 pm and 4 pm,” said Nitesh Kumar Das, organizing secretary of the Gig Workers Association. “If they log off early, it directly affects their earnings and ratings. The responsibility of managing that risk is left almost entirely to the worker.”

Raginii Jaain, environmentalist and founder of Geetanjali Envirotech, a Mumbai-based waste management company, points to the everyday adaptations workers are forced to make. Waste pickers -- many of them women -- often stop work during peak heat hours when conditions become unbearable. “But where will she sit?” Jaain asked.

Invisible heat inside homes

For women in the informal sector — including domestic workers, gig workers and construction workers — heatwaves bring both health risks and financial strain. Many women live in tin-roofed settlements that trap heat long after sunset. “I work in five houses in Chembur and walk 10 to 15 minutes between each one,” said Yashoda More, a domestic worker living in Trombay. “After 10 a.m., walking on the road becomes painful. Twice this week I had fever and palpitations after walking for just five minutes. The doctor said it was because of the heat. My house also becomes extremely hot because there are no windows. When I cook, it feels like sitting inside a furnace.”

A 2024 analysis by the World Resources Institute (WRI) found that informal settlements and homes with metal roofs faced higher heat exposure. “Heat inside low-income homes is not only due to high outdoor temperatures,” says Damle. “Cooking spaces, poor ventilation, heat-retaining floors and walls make homes especially difficult for women during heatwaves.”

See also: Roads Blocked and a Call for Capital Punishment: Protests Erupt in Maharashtra After a Four-Year-Old Victim is Raped and Killed by 65-Year-Old Farm Labourer in Pune

Rising health risks

Extreme heat contributes to rising cases of cardiovascular illness, high blood pressure, dizziness and fatigue. Outdoor laborers, the elderly and people living in poorly ventilated homes are among the most vulnerable. Mumbai has reported a rise in heat-related illnesses this summer, prompting emergency preparedness measures in hospitals across the state.

The true toll, however, remains unclear, as heatstroke is rarely listed on death certificates. In many cases, deaths may instead be recorded as cardiac arrest, kidney failure or another immediate cause. Dr Deepak Baid, physician at Nulife Hospital and former president of the Association of Medical Consultants, Mumbai, says, “These are largely preventable — rest, hydration and avoiding peak heat can make a big difference.”

Prevention, however, requires control over working conditions, something many workers do not have.

Heat as a labor rights issue

In April 2025 and again in 2026, the government issued SOPs for outdoor informal workers, recommending that work be shifted to cooler hours and halted between 12 pm and 4 pm during orange and red alerts. The measures specifically targeted construction workers, sanitation staff, vendors and delivery riders exposed to outdoor heat.  Unlike the earlier guidance, the 2026 SOP moved beyond advising workers to avoid peak heat and set out a more comprehensive package of protective measures aimed at reducing heat -related illness among outdoor informal workers.

The Occupational Safety, Health and Working Conditions Code, 2020 — India’s main workplace safety law — does not explicitly recognize ambient heat as a workplace hazard. The Factories Act, 1948 also contains no specific provisions for thermal stress. 

Sonam Chandwani, senior labor lawyer and managing partner at KS Legal & Associates explained that while “these labor statutes were not drafted specifically with climate-linked heat exposure in mind, their language is broad enough to cover excessive heat as an occupational hazard.” But while the legal framework exists on paper, it is rarely invoked for climate-related heat stress.

Maharashtra’s heat SOPs, on the other hand, presently function more as administrative advisories and operational guidelines than enforceable statutory instruments carrying independent penal consequences. Enforcement becomes difficult because they are not backed by an explicit legislative framework prescribing penalties for non-compliance. Given that India’s labor statutes do not explicitly deal with heat exposure, it is easy for such measures to fall through the legislative gap.

According to Jaya Goyal, an independent researcher, former TISS professor and founder of Circadian Connect, framing heat as a labor rights concern as opposed to purely a public health or weather issue would help bridge this gap, and allow for heat-exposure related precautions and SOPs to be enforced more effectively.

See also: Labour Codes Explained: Centre Notifies Final Rules for Four Labour Codes; Omission of Minimum Support Wage Formula Wage Raise Concerns

Another pressing difficulty is the issue of administrative responsibility. In theory, multiple institutions should act together when heat alerts are issued. Labor departments oversee worker safety, while municipal bodies regulate public spaces. These systems, however, do not converge into a single chain of command. 

“The responsibility for heat management is currently shared between the central government and state government -- one makes policy and other implements the policy in terms of labor compliances and distributes compensation,” said Goyal, “Even when officials in municipal bodies recognize dangerous conditions, they often lack the explicit statutory authority or budget to stop work without a formal complaint. The gap between alerts and enforcement goes back to a deeper structural problem, which has not been addressed by the central government.”

TMC officials said that there is no publicly available notification which currently specifies penalties, prosecution, fines or mandatory shutdown mechanisms for non-compliance. There is no clearly defined enforcement authority publicly identified for stopping unsafe outdoor work, penalizing contractors or forcing mandatory heat breaks during red alerts.

According to Goyal, the state government and SDMAs should set scientific heat thresholds and issue binding restrictions during "red alerts". Labor departments should have the power to inspect worksites like construction zones in Mumbai to enforce hydration and shade. Municipal bodies should be empowered to issue stop-work orders for informal workers in public spaces, such as street vendors or delivery partners. 

“There is also no centralized data on heat deaths and no incentive for agencies to report it. Another challenge in cities like Mumbai is that many informal workers, such as those engaged in construction or street vending, are unregistered and mobile, making them nearly invisible to standard labour inspections,” she said.

Cooling the city

Municipal authorities insist that localized heat management measures are being implemented across high-risk zones. The Brihanmumbai Municipal Corporation (BMC) heat action plan, integrated within the Mumbai Climate Action Plan (MCAP), includes measures such as white roofs in slums, cooling shelters and shaded bus stops in high-risk wards. BMC officials said, “We have firstly identified high-risk wards covering areas like Govandi, Mankhurd, Deonar, Kurla, Bandra East and parts of Lower Parel.”

Jaain said, “The problem is that all these areas lack basic cooling infrastructure. The cooling responses need to be decentralized at the community level. Parks and playgrounds should be prepared for summers with public cooling spaces to be used by laborers who travel from far away to work.” 

Suggested reading: