Understanding GCC Labour Laws. Part one: Heat stress.
Background on Heat Stress
When a person performs hard physical work, the body produces high amounts of heat. To maintain a stable body temperature, this excess heat must be released to the environment. The body primarily achieves this by producing sweat and by directing more blood to cooler areas . Heat stress occurs when the body generates more heat than it can release. If the body cannot rid itself of this excess heat, the core temperature rises and the heart rate increases. As heat continues to build up, the person may begin to lose concentration, have difficulty focusing on tasks, become irritable or feel sick, and often lose the desire to drink water. The next stage is most often fainting and even death if the person is not rapidly cooled down. It becomes dangerous in high-temperature environments, particularly for outdoor and manual labourers.
Measuring occupational heat stress
The Wet-Bulb Globe Temperature (WBGT) index is widely used internationally to measure occupational heat stress, as it accounts for temperature, humidity, wind speed, and solar radiation. In the Gulf Cooperation Council (GCC), most countries mitigate heat stress through midday work bans during the summer months. These are defined by fixed hours and vary slightly by country. However, Qatar is currently the only GCC country that has formally mandated the use of WBGT measurements in national legislation to assess heat risk and adjust working conditions accordingly. The regulation requires WBGT instruments to be placed close to the workers without interfering with their tasks, ensuring accurate readings of heat exposure.
The challenge of workplace heat exposure is not limited to ambient temperature; it also includes access to water, rest, and shade, particularly in sectors like construction and agriculture, where workers often face intense workloads and limited control over pacing. While midday bans offer some protection, only Qatar has introduced a risk-based legal framework tied to WBGT, whereas the other GCC countries continue to rely on fixed summer work-hour restrictions.
Heat Stress Regulations per Country
Saudi Arabia
Ministerial Decree No. 3337 (14 May 2014)
1. Definition of Heat Stress
The Ministry of Human Resources and Social Development (MHRSD) defines heat stress as:
“A person develops a heat stress as a result of exposure to hot and humid weather, leading to the loss of many fluids from the body through profuse sweats such as occurs with Hajj and Umrah performers, as well as during running in very hot weather.”
2. Working Hours Ban During Summer
To reduce worker exposure to extreme heat, MHRSD enforces Ministerial Decree No. 3337, which:
Prohibits outdoor work from 12:00 to 15:00,
During the period from 15 June to 15 September each year.
3. Employer Responsibilities
As part of this mandate, the Ministry issued a procedural guide outlining required and recommended measures to protect workers from heat stress. Employers must:
Schedule rest breaks;
Provide designated shaded areas;
Ensure consistent access to hydration, with an emphasis on drinking fluids every 15 to 20 minutes;
Encourage the use of light-coloured clothing to minimize heat absorption.
Employers are also obligated to:
Install temperature and humidity monitoring devices;
Adapt work schedules to reduce prolonged heat exposure;
Provide regular health assessments to identify vulnerable workers;
Ensure workers have access to appropriate rest zones.
4. Team-Based Safety Practices
The guidance stresses collective safety. Workers are encouraged to:
Operate in teams;
Report symptoms promptly to colleagues;
Avoid working alone in high-heat conditions.
5. Exemptions
The decision excludes certain categories of workers, including:
Workers in oil and gas companies, due to the special nature of their work;
Maintenance workers in emergency situations.
6. Reporting and Penalties
Violations can be reported through the 19911 hotline or the MHRSD mobile app.
Penalties include fines ranging from SAR 3,000 to 10,000 (USD 800-2700) and
Possible business closures in cases of repeated violations.
Qatar
Ministerial Decision No. 17 of 2021
1. Summer Working Hours Rule
As of 26 May 2021, Qatar introduced a new regulation to protect workers from heat stress.
Outdoor work is banned from 10:00 a.m. to 3:30 p.m.
This applies every year from 1 June to 15 September.
The rule applies to all outdoor work under the sun or in open workplaces.
This replaced the previous rule (Decision No. 16 of 2007), which had shorter banned hours and a smaller time window during the year.
2. Scientific Approach – WBGT Threshold
In addition to the fixed working hours ban, a new system was introduced using the Wet-Bulb Globe Temperature (WBGT).
If the WBGT exceeds 32.1°C, outdoor work must stop immediately, even if it is outside the 10:00–15:30 ban.
WBGT measures heat stress by factoring in temperature, humidity, sun exposure, and wind speed.
*This approach is used year-round, not just during summer.
3. Employer Responsibilities
Employers must take specific steps to protect workers:
Monitor heat levels and stop work if WBGT goes over the limit.
Adjust work schedules to reduce exposure to high heat.
Provide drinking water, shaded rest areas, and other protective measures.
Conduct risk assessments with workers and make records available for inspection.
Offer annual medical check-ups, especially for workers with health conditions like diabetes or high blood pressure.
4. Enforcement and Inspections
The Ministry of Labour carries out inspections, especially during banned hours.
Inspectors check both working hours and WBGT levels.
Non-compliance can lead to worksite closures.
Workers can report violations anonymously through a hotline or a mobile app.
5. Scientific Basis for the Law
The regulation was based on a 2019 study by FAME Lab (University of Thessaly), commissioned by ILO, MOL, and the Supreme Committee for Delivery & Legacy.
The study observed 5,500 work hours in construction and agriculture.
It found that heat stress was common even outside the old banned hours.
The results helped shape the new policy and the WBGT threshold.
Oman
Ministerial Resolution No. 286/2008 (as amended by Resolution No. 322/2011)
1. Midday Work Ban
Article 16/3-3 of Ministerial Resolution No. 286/2008, as amended by Ministerial Resolution No. 322/2011, establishes a midday work ban in Oman.
The regulation prohibits outdoor work, particularly on construction sites,
Between 12:30 p.m. and 3:30 p.m.,
From 1 June to 31 August each year.
2. Public Health Guidance and ‘Safe Summer’ Campaign
The Ministry of Health has issued guidance on preventing heatstroke, emphasizing the risks of prolonged exposure to high temperatures and direct sunlight.
In May 2025, the Ministry launched the ‘Safe Summer’ guidelines to further protect workers from heat stress. These guidelines complement the ministerial decision with the following measures:
Smart work scheduling: Reassigning strenuous tasks to early morning or late afternoon; maintaining the outdoor work ban during peak heat hours (12:30 p.m.–3:30 p.m. in June–August).
Regular breaks: Mandating breaks every 45–60 minutes in shaded or air-conditioned areas.
Hydration support: Ensuring access to water and hydration materials.
Environment cooling: Encouraging the use of air conditioning, fans indoors, and portable fans or umbrellas outdoors.
Heat alert systems: Monitoring daily temperature and humidity to guide operations.
Targeted protection: Identifying high-risk workers (such as the elderly or those with chronic conditions) for prioritized intervention.
Training and materials: Delivering heat-stress education through posters, brochures, videos, and worker training sessions.
3. Occupational Safety and Health Requirements
The Ministry of Labour requires employers to integrate occupational safety and health (OSH) measures into workplace practices. This includes training workers on the risks associated with heat exposure and the protective actions they should take.
4. Penalties for Non-Compliance
Violations of the regulation may result in:
Fines ranging from OMR 100 to OMR 500, (USD 260-1300) and
Up to one month in jail.
UAE
Ministerial Decree No. 401 of 2015 (commonly referred to as the Midday Break Decree)
Midday Work Ban
Prohibits outdoor work between 12:30 and 15:00 from June 15 to September 15. Issued by the Ministry of Human Resources and Emiratisation (MoHRE), the regulation seeks to reduce workers' exposure to extreme heat and limit the incidence of heat-related illnesses.
Additional Information
Complementing this legal framework, the UAE government launched the “Safety in the Heat” program, implemented specifically within Abu Dhabi and supported by the Abu Dhabi Public Health Centre (ADPHC). It aims to educate both employers and workers on managing heat-related risks, targeting an outreach of 800,000 individuals.
For workers, the program emphasizes hydration, salt intake, rest breaks, and timely symptom reporting. For employers, it mandates shift scheduling, acclimatization support, workload reduction, and provision of shaded rest areas and water. It includes training on managing heat-related illnesses.
Under the Abu Dhabi OSH Framework (ADOSH-SF) Code of Practice 11.0, employers must conduct heat stress risk assessments, use WBGT or TWL indices, and provide medical services and first aid for heat-related conditions.
Exemptions
According to the Ministry of Human Resources and Emiratisation, exemptions apply in the following cases:
Laying asphalt or pouring concrete when technically unfeasible to postpone.
Emergency repairs to water, electricity, sewage, or other critical infrastructure.
Work that, if interrupted, would cause disruption to traffic or services and for which a permit has been issued by the competent authority.
Even when exempted, employers must provide shaded rest areas, cooling systems, adequate drinking water and rehydration materials, and first aid on site.
Penalties
Non-compliance may result in AED 5,000 fines per worker (up to AED 50,000 in total) ( USD 1361 USD and up to USD 13,600 in total), as well as suspension of work permits.
Bahrain
Order No. 3 of 2013 regulating working hours outdoors.
Midday Work Ban
Prohibits outdoor work between 12:00 and 16:00 from July 1 to August 31 annually. Employers must develop work schedules in compliance and display them visibly for workers and inspectors.
Exemptions
Workers in oil and gas installations
Workers performing emergency maintenance
These exemptions require employers to implement additional protective measures against heat exposure.
Employer Obligations
Display compliant work schedules in visible locations
Provide appropriate safety equipment
Ensure safe handling and storage of materials
Educate workers on risks of working in high-heat conditions.
Penalties
Violators face up to 3 months’ imprisonment, a fine of BHD 500–1,000 (USD 1326-2653) per offense, or both.
Kuwait
Kuwait is known for ranking among the hottest countries globally during summer, frequently reaching above 50 °C.
Ministerial Decision No. 535/2015 (‘Noon Work Ban’) issued by the Public Authority for Manpower (PAM).
Midday Work Ban
Prohibits outdoor work from 11:00 to 16:00, annually, from June 1 to August 31
Exemptions
Workers in the oil and gas sectors are exempt from this ban.
Enforcement
The PAM conducts unannounced inspections at outdoor work sites.
Penalties
Employers face fines of KWD 100–200 (USD 327-654) per worker for violations
In severe or repeated cases, operations may be suspended