John, The issue arises not only due to the migratory nature of the labour workforce, but also because this group of workers are the least protected in India, i.e. the "unorganised" labour sector. This is complex and the party that can make the biggest difference is the "client". No simple solutions, but the following can be tried via the client:- 1) Insisting on a core workforce that will not change for the project/contract who will be provided the safety shoes by the client and perhaps providing a means of storage etc on site so that the shoes are not "sold off" . This does happen in reality! 2) Trying out safety overshoes that is the property of the client and can be re-used after disinfection--not ideal, but a practical solution 3) If not involved in construction activities, risk assess activities and decide to have safety shoes for the high risk ones irrespective of the "employees" having to wear safety shoes once they are in the factory--again, not ideal, but a practical solution The social/cultural/economic background and what part of the country the migrant workforce originates from plus what part of the country the factories are located is also an important factor to take into account. India is a very diverse country, with huge social and economic disparities. I do not have current experience, but worked in India at a major Fertilisers, Petrochemicals & Polymers manufacturing facility from 1982 to 1991 that employed 3000 at the main site at Vadodara in the state of Gujarat so I am aware of the issues regarding the "unorganised sector". ref:- http://www.gsfclimited.com/ The main difference from what you have indicated is that the company I worked for took safety very seriously and had the resources to provide the PPE to the contract labour workforce, but even then required getting this message and practical aspects to the contractor, who in turn use labour supply only sub-contractors took some doing and constantly being assertive/facilitating rather than confrontational

John, this has to be approved and budgetted for by the plant management, once they are convinced of the argument. When I worked for a US-owned company in India the local management were convinced by financial arguments: this is the safety regime we expect, achieve it and the bonuses are good; low audit scores hit you in your personal pockets. We will invest heavily to assist and educate you. In 5 years the 3 sites with which I was involved progressed from bare feet, dirty water, unskilled disposable workforce and many major accidents to become as good (H&S performance) as several of that company's European operations. I count that as one of my significant successes as a H&S professional.