POSH Act for Hospitals and Healthcare Organisations in Kerala

The POSH Act, 2013 applies fully to every hospital, clinic, nursing home, diagnostic centre, and healthcare organisation in Kerala with 10 or more employees. Healthcare is not a special category — and healthcare workplaces carry unique POSH risks that make compliance especially important.

Why Healthcare Needs Special Attention

Healthcare workplaces are uniquely complex environments for POSH compliance:

The workplace extends beyond the ward. Section 2(o) of the POSH Act defines "workplace" to include any place visited by an employee in connection with work. For healthcare workers this means corridors, duty rooms, ambulances, operation theatres, wards, patient homes for home care workers, and vehicles. A nurse harassed during a patient home visit is in a "workplace" under the Act.

Power hierarchies are steep. The doctor-nurse, senior-junior, and doctor-patient attendant dynamics in healthcare create conditions where harassment may go unreported out of fear of professional consequences.

Shift work and night duties. Female healthcare workers on night shifts are in a particular category requiring employer protection under the POSH Act and also under the Kerala Shops and Commercial Establishments Act, 1960.

Contract and agency staff. Hospitals employ large numbers of contract staff, outsourced housekeeping and security workers, and agency nurses. All are covered under the POSH Act's broad definition of "employee" under Section 2(f).

What Kerala Hospitals Must Do

Form an IC for every unit or location A multi-campus hospital — with a main hospital, satellite clinics, and diagnostic centres — must form a separate IC for each administrative unit under Section 4 of the POSH Act. One central IC does not cover all locations.

IC composition must be correct

• Presiding Officer: Senior woman employee (a senior nurse, woman doctor, or senior woman administrator)

• At least 2 employee members

• 1 external member from an NGO committed to the cause of women

• At least 50% women members

Conduct annual employee awareness training Every employee — doctors, nurses, administrative staff, housekeeping, security, and support staff — must receive awareness training under Section 19(c). FIO Foundation provides Malayalam-medium sessions for non-clinical staff who may not be comfortable in English-only training.

File Annual Report The IC Annual Report must be filed with the District Officer of the relevant district by 31 January each year. For NABH-accredited hospitals, POSH compliance documentation is also reviewed during accreditation assessments.

NABH Accreditation and POSH

National Accreditation Board for Hospitals and Healthcare Providers (NABH) standards include workforce safety and grievance mechanisms as part of the accreditation criteria. Hospitals undergoing NABH accreditation or renewal are increasingly required to demonstrate a functioning, documented POSH compliance framework — including IC constitution, training records, and Annual Report history.

FIO Foundation assists Kerala hospitals preparing for NABH accreditation with POSH compliance documentation and gap remediation.

FIO Foundation's Healthcare Track Record

FIO Foundation has conducted POSH training for:

• KIMS Al Shifa Hospital, Perinthalmanna — 100+ healthcare professionals

• National Urban Health Mission (NUHM), Malappuram — IC members from 14 Urban Public Health Centres, inaugurated by the District Medical Officer

• ESIC Feroke Hospital, Kozhikode — Central Government healthcare facility

📞 +91 99617 71711 | fiofoundation.org | WhatsApp: "Hospital POSH"