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

Not for every employer. The Labour Law requires medical cover that grows with headcount: trained first-aiders and first-aid boxes from 5 workers, a nurse above 100 workers and a clinic with at least one physician and one nurse above 500 workers. It contains no general headcount rule for appointing a safety professional; in practice, HSE officers are required by client contracts and project specifications.

Short answer

• First aid (Article 104): 5 to 25 workers need a first-aid box in the care of a trained first-aider; above 25 workers, one box for each group of 5 to 25.
• Nurse: above 100 workers, a nurse in addition to the boxes (the English text of the law says full-time; a 2005 decision summary says part-time, so confirm with the Ministry of Labour).
• Physician: above 500 workers, a workplace clinic with at least one physician and one nurse; the 2005 decision adds a first-aid room.
• Safety professional: no general statutory duty by headcount was found in the Labour Law or the decisions we could read. The heat-stress decision requires trained OSH supervisors on site, and Decision No. 18 of 2005 expects a health and safety manager to supervise injury data where there is one.
• Contracts: large clients set ratios. The national energy company's contractor HSE regulations (QP-REG-S-001, Rev. 3 of 2009) require an HSE officer for any contractor with more than 20 people on a worksite.

What the law requires for medical cover

Article 104 of Labour Law No. 14 of 2004 is the only headcount-based staffing rule in the law. The contents of the first-aid box are set by the competent medical authority, the body designated by the national health authority (today the Ministry of Public Health). Decision No. 16 of 2005 on medical care for workers adds that a suitable number of workers must be trained in first aid, that the clinic must be ventilated, lit and equipped, and that health authority and labour administration clinics may inspect workplace clinics. The same decision lists the medical care the employer provides, including check-ups, laboratory tests, vaccinations advised by the health authority and a medical file for each worker.

Unlike Türkiye, where Law No. 6331 (Article 6) requires every employer to appoint or contract an OSH expert and a workplace physician, Qatar does not require every employer to contract an occupational physician. Below 500 workers, medical examinations required by Article 105 and Decision No. 19 of 2005 (for workers exposed to occupational disease risks) are usually bought from licensed clinics.

Safety officers in practice

Although the law does not set a ratio, most medium and large sites in Qatar employ HSE staff because:

1. Clients and main contractors write ratios into the contract. In the energy company regulations quoted above, more than 20 people on a worksite means an HSE officer who spends at least 5 hours a day on HSE supervision; in hazardous areas one more officer may be added for every 20 extra workers, and one for every 30 in non-hazardous areas. Officers need client approval.
2. Ministerial Decision No. 17 of 2021 requires paramedics and OSH supervisors trained to guide workers and give first aid during hot weather.
3. A competent person is needed to carry out the heat-stress risk assessment, WBGT monitoring, accident reporting and six-monthly statistics that the law requires.

How this compares

Common mistakes

• Waiting until 500 workers to add medical staff: the nurse is due above 100.
• Counting first-aid boxes per site instead of per group of up to 25 workers.
• Assuming a client's HSE officer ratio is national law; it applies through the contract and can differ between clients.

Related on excodex

• Occupational safety and health in Qatar: law, authorities and employer duties
• Are pre-employment and periodic medical examinations required for workers in Qatar?
• Occupational health services: workplace doctor and nurse
• OSH law comparison: appointments and reporting deadlines

Standards and further reading

• Law No. 14 of 2004 promulgating the Labour Law, Article 104, Al Meezan legal portal: almeezan.qa (search for Law No. 14 of 2004); English text used: Al Meezan export.pdf)
• Decision No. 16 of 2005 on medical care for workers in establishments (summary): gulfmigration.grc.net
• Ministerial Decision No. 17 of 2021 on heat stress: gulfmigration.grc.net
• HSE Regulations for Contractors QP-REG-S-001, Rev. 3, 2009: qatarenergy.qa

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.