Occupational safety International framework and country guides
Must an employer in the United Arab Emirates appoint a safety professional or an occupational physician?
Part of: Occupational safety and health in United Arab Emirates: law, authorities and employer duties
Short answer
Every industrial establishment, and construction establishments with 100 or more workers, must appoint a qualified OSH officer (Ministerial Resolution No. 44 of 2022). Federal law names no occupational physician but requires medical examinations, supervised first aid and care.
Yes, for an OSH officer in industry and construction: every industrial establishment, and every construction establishment employing 100 or more workers, must appoint a technically qualified occupational safety and health (OSH) officer. Federal law does not require an occupational physician by name, but the employer must arrange medical examinations, supervised first aid and free medical care.
Short answer
- OSH officer: mandatory for every industrial establishment and for construction establishments with 100 or more workers (Ministerial Resolution No. 44 of 2022, Article 2, as worded on the official u.ae portal). The Arabic sentence is less clear about whether the 100-worker threshold also covers industry, so a small industrial employer should confirm its position with MOHRE.
- Qualification: an engineer or a graduate of an OSH institute with a certified qualification (MOHRE Administrative Decision No. 19 of 2023, Article 10).
- Construction below 100 workers, and other sectors, have no federal appointment duty that we found, but all OSH duties still apply and someone must be named to run them (the OSH system must list OSH officials).
- No federal duty to appoint an occupational physician; examinations must be done by a medical professional and first aid supervised by a person specialised in medical care.
- Emirate rules, notably Abu Dhabi's OSHAD-SF, and client contracts can add requirements.
What the OSH officer must do
Ministerial Resolution No. 44 of 2022 describes the role as preventing hazards and supervising compliance with the rules. Administrative Decision No. 19 of 2023 lists the duties in more detail:
| Area | Duties |
|---|---|
| Planning | Risk assessment, annual OSH objectives, action and emergency plans, medical check-up schedules, safety checks before equipment is bought or rented, selection of training |
| Supervision | Monitoring compliance, internal inspections including contractors, preventive actions, equipment checks |
| Incidents | Reporting accidents immediately to the Ministry and the relevant authorities, incident reports, keeping an OSH reports file |
| Awareness | Educating workers, updating instructions, improvement plans after incidents, acting on worker suggestions |
Every employer must also maintain an OSH management system that includes a list of OSH officials with their roles and contact details, so even a firm below the threshold needs a named, competent person.
Medical staff and health services
The federal texts place the health duties on the employer rather than on an appointed doctor:
- a medical examination before work starts and periodic examinations at least every six months for workers exposed to occupational disease risks (Administrative Decision No. 19 of 2023, Article 6);
- free medical care and medication through approved means, such as insurance or a hospital contract;
- first-aid supervision delegated to a specialist in providing medical care, and stocked first-aid kits (Cabinet Resolution No. 1 of 2022, Article 22(1)(d));
- trained first aiders whose names are recorded;
- for establishments with 50 or more workers, a monitoring system with a medical examination log and exposure records kept for at least five years after service ends (Ministerial Resolution No. 657 of 2022).
In practice this is met by contracting a clinic or occupational health provider licensed by the health authority of the emirate. Fitness-for-work decisions belong to the examining doctor.
Example: A food factory in Ajman has 120 workers. It is an industrial establishment, so it appoints a qualified OSH officer (it would need one under either reading of the threshold). It has no in-house doctor; it contracts a licensed clinic for pre-employment and six-monthly examinations of workers exposed to noise and cleaning chemicals, trains first aiders on each shift and keeps the medical log required for 50+ workers.
Common mistakes
- Applying the 100-worker rule to all sectors. The appointment duty is written for industrial establishments and for construction from 100 workers; other firms still carry every OSH duty.
- Appointing an officer without the qualification. Administrative Decision No. 19 of 2023 requires an engineer or an OSH institute graduate with a certified qualification.
- Forgetting Abu Dhabi rules. OSHAD-SF and its sector regulators can set their own requirements for OSH practitioners and systems; check with the sector regulator.
Related on excodex
- Occupational safety and health in United Arab Emirates: law, authorities and employer duties
- Are pre-employment and periodic medical examinations required in the UAE?
- What OSH training must employers provide in the UAE?
- Comparison of OSH laws: appointments and reporting deadlines
Standards and further reading
- Ministerial Resolution No. 44 of 2022 on OSH and Labour Accommodation, Article 2 (Arabic): government.ae
- Official portal, Occupational Health and Safety Officer: u.ae
- Administrative Decision No. 19 of 2023, Articles 6 and 10: government.ae
- Cabinet Resolution No. 1 of 2022, Article 22: uaelegislation.gov.ae
- MOHRE, guidelines on work injuries (Ministerial Resolution No. 657 of 2022): mohre.gov.ae
This article is general occupational safety and health information prepared by the excodex editorial team. It does not replace the applicable legislation, standards, manufacturers' instructions or the assessment of a competent OSH professional or occupational physician.
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