Must an employer in Iraq appoint a safety professional or an occupational physician?

For medical staff, yes, depending on headcount: above 50 workers the employer must engage a nurse and contract a physician who treats workers in a clinic at the workplace, and above 500 workers it must appoint a resident physician (Labour Law No. 37 of 2015, Article 121). The law does not require a safety engineer or OSH officer by name, but most clients require one by contract, and the current ministerial OSH instructions should be checked.

Short answer

• All workplaces: first aid equipment and first aid at known locations (Articles 114, 118 and 121).
• More than 50 workers: a nurse for first aid, plus a contracted physician working in a clinic at the workplace, providing treatment and medicines free of charge during work.
• More than 100 workers: the physician attends at least two hours a day.
• More than 500 workers: a resident physician and a dispensary with full means of care; employers in one area may share a common dispensary.
• Safety professional: not required by name in Labour Law No. 37 of 2015; we could not verify whether the OSH instructions require one. Oil, gas, power and construction contracts almost always do.

What Article 121 requires

Article 121 of the Labour Law No. 37 of 2015 (قانون العمل رقم 37 لسنة 2015) is the only headcount-based OSH staffing rule in the Labour Law. The thresholds are "more than" figures: an enterprise with exactly 50 workers needs first aid only, while one with 51 needs the nurse and contracted physician.

The resident physician of a large enterprise also reports on cases needing sick leave, specialist consultation or surgery, in line with the sick leave rules of the law. Employers of several enterprises in one region or municipality may set up a shared dispensary (Article 121(4)). The worker must not bear any cost for medical care, prescribed medicines, periodic and laboratory tests or X-rays (Article 120(3)), and must attend the periodic examinations set by the enterprise physician or the competent medical authority (Article 119).

The law does not set qualifications for the physician, such as a specialisation in occupational medicine. Confirm any qualification or registration requirement with the Ministry of Health and the National Centre for Occupational Health and Safety.

What about a safety engineer or OSH officer?

Labour Law No. 37 of 2015 places the OSH duties on the employer itself: a safe working environment, training, written hazard information, PPE, inspections of lifting and pressure equipment, emergency planning (Articles 114 to 118). It does not say who inside the company must carry them out, and it sets no minimum time per worker. Türkiye's Law No. 6331, by contrast, requires employers to provide OSH services through an OSH expert and a workplace physician (Article 6), with minimum service times set by regulation.

In practice, someone competent must run these duties. On large projects in Iraq, the client's contract usually names the HSE roles (HSE manager, site safety officers, often a ratio to the workforce), and these become binding through the contract. Ask the National Centre for OSH whether the current OSH instructions add a requirement for your sector, especially before applying for the enterprise's OSH licence.

Worked example

Example: A food factory near Baghdad has 230 workers on two shifts. It needs first aid points, a nurse and a contracted physician with a clinic at the factory, attending at least two hours a day because the workforce exceeds 100. It does not yet need a resident physician (that starts above 500). The factory nominates a trained OSH coordinator to manage training, PPE, inspections and reporting, even though the law does not name the role, because the inspection committee will judge compliance with all Chapter 13 duties.

Common mistakes

• Counting 50 workers as the trigger: the duty applies when the number exceeds 50.
• Charging workers for medicines or tests: all medical costs are on the employer.
• Assuming that no safety officer is needed because the law does not name one: the duties remain and contracts usually require named HSE staff.

Related on excodex

• Occupational safety and health in Iraq: law, authorities and employer duties
• Are pre-employment and periodic medical examinations required in Iraq?
• What is the main OSH law in Iraq and who enforces it?
• Occupational health services: workplace doctor and nurse

Standards and further reading

• Labour Law No. 37 of 2015 (قانون العمل رقم 37 لسنة 2015), Articles 114, 119 to 121; unofficial English translation: alnoor.edu.iq. The Arabic text in Al-Waqai al-Iraqiya is authoritative.

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.