India’s Heat Action Plans Are Missing Caste, Income Vulnerabilities
Groups left vulnerable by income levels, caste, gender, or living conditions are more impacted by heat hazards and it is important that heat action plans pencil this into their strategies
Heat action plans drafted by states and cities in India do not take enough cognisance of the vulnerabilities of marginalised social groups who labour and live in conditions that exacerbate heat stress, say climate experts and labour activists. In doing so, they often erase local contexts and communities and fail to integrate labour rights or urban planning into heat action. The lack of data, poor accountability and disconnect between government departments, and the lack of legal muscle make these plans even more ineffective, we find.
“Dalit and Adivasi communities cannot afford to stop working during a heatwave, and we are the ones dying in this heat. But what does a heat action plan offer to a Dalit woman working at a construction site with her child strapped to her back in 45-degree heat?” asks Anju Singh, the founder of Global Campaign for Dalit Women. “These plans are not made for Dalit or Adivasi communities. They never reached us or benefitted our communities in a meaningful way.”
Anju has worked with Dalit communities, especially women, in more than 500 villages across the country over the last decade, and found shared stories of marginalisation that deepened with heat stress. Caste-based discrimination, caregiving responsibilities, and the nature of their work in informal and low-paid occupations – such as domestic work or waste picking – has exposed lakhs of workers to intense heat at work and at home. Their ability to respond and cope with the heat, through rest breaks or water or green cover, is also compromised by power dynamics and the lack of government support.
Heat impacts everyone, but groups left vulnerable by income levels, caste, gender, or living conditions are getting more impacted by increasing temperatures. A recent working paper found that marginalised caste groups faced up to 150% higher heat exposure during work compared to dominant caste groups but this is not reflected in India’s heat action plans or its climate adaptation and mitigation plans.
A Centre for Policy research from 2023 found most heat action plans “are not built for local context and have an oversimplified view of the hazard”. A recent Sustainable Futures Collective (SFC) report concluded that most such plans fail to identify those most vulnerable to heat and build their resilience due to poor data collection and heat mapping, lack of legal accountability, funding, and coordination among policymakers.
More than a decade ago, the nature of heat governance in South Asia saw a shift. Heat hazards had become catastrophic: extreme heat had claimed the lives of almost 1,300 people in Ahmedabad in May 2010, and almost 2,000 people earlier in 1998 during Orissa’s ‘killer heatwave’. But caution, coordinated action, and community outreach could help mitigate the devastating impact of extreme heat, a pilot action plan in 2011 indicated. Light clothing, ORS, heat wards, roofing programmes – the much-studied Ahmedabad Heat Action Plan articulated the steps of heat prevention that have become the language of India’s almost 23 heat action plans across states today.
But India’s guiding documents have failed at identifying who is vulnerable to the heat, and why, experts and activists tell BehanBox. “Heat action plans rarely account for how heat exposure intersects with housing insecurity, lack of water access, informal work conditions, caste-based spatial segregation, and economic precarity—all of which disproportionately affect marginalised communities,” says Selomi Garnaik, a climate and energy campaigner with Greenpeace India. The core problem, she adds, is that heat action plans tend to treat vulnerability as “uniform and technical, rather than as socially constructed”.
Experts complain that the lived experiences and perspectives of communities are rarely included in heat action plans which are often drafted by external consultants using historical temperature-related data, a ‘top down’ approach. They know little of local hotspots, cultural nuances in responding to heat, or a community’s coping mechanisms.
Mapping the Vulnerable
The original Ahmedabad heat plan had pointers on heat-related morbidities and mortalities, and conducting ‘vulnerability assessments’ of particular occupational groups to heat stress. However, most states and cities (with some exceptions like this) do not carry out localised vulnerability assessments.
India’s National Disaster Management Authority (NDMA) adopted the UN Sendai Framework for Disaster Risk Reduction and released its plan in 2016, which initially included only the elderly and disabled as vulnerable groups to natural disasters. This was later revised in 2019 to include Scheduled Castes and Scheduled Tribes.
Heat action plans have a narrow view of vulnerability, focussing on the intensity of temperature and those with health comorbidities. For instance, pregnant and lactating women, elderly people, children, people with disabilities, and cardiovascular diseases. Some have begun to mention income and occupation, for example identifying “outdoor workers” as a vulnerable category.
The CPR analysis showed that 25 of the 37 heat action plans recognise occupation as a factor in heat exposure, and 15 also identified people living in slum settlements and below the poverty line as vulnerable groups. However, few focus on home-based labour such as domestic workers or gig-based occupations like delivery agents. Moreover, most such plans (with the exception of three including Rajkot, Surat, Bhubaneshwar) focussed on workers’ exposure to heat, and not their capacity to respond to it. But not being able to adapt to heat stress – through cooling, water, shade, rest, or health services – is a critical factor.
Domestic workers, for instance, are on their feet cooking in closed spaces or cleaning, for almost 5-6 hours a day without a break. “Kabhi kabhi shareer se aisa paseena nikalta hain, jaise ki nal laga hua hain (the sweat drips off me like a tap),” says Anita Kapoor, an activist with Shehari Workers’ Union, a coalition of informal workers in Delhi. Women will faint at work but shy away from asking for water or a glass of nimbu paani, she adds.
Almost 90% of India’s workers are part of the informal economy, with many belonging to Dalit community, Adivasi, and denotified tribes, according to a 2020 report by the National Campaign on Dalit Human Rights. Working in construction, street vending, and sanitation they deal with heat conditions outdoors or or in unventilated spaces.
“Even during normal times, sanitation workers and manual scavengers are working in the heat without any kind of protection and they don’t have water to drink. But during the heat, it’s so much more hazardous. It’s both the heat as well as the poisonous gasses that they are being exposed to,” says Beena Pallical, general secretary of National Campaign for Dalit Human Rights.
Terms like ‘slum dwellers’ or ‘informal workers’ in these plans are treated as neutral categories but in reality these identities are shaped by systemic caste hierarchies, generational exclusion, and entrenched social injustice, Anju points out.
Across New Delhi’s busy Lajpat Nagar and Palika Bazaar markets, in narrow lanes and congested alleys where street vendors sell clothes, fabrics, vegetables, and more, the politics of heat has surged over the last few years. Avinash Chanchal, a campaigner with Greenpeace India and who works with the National Hawker Federation, has captured alarming temperature readings in these concrete and paved areas – land surface temperatures (LST) that touched 60 degrees Celsius when the rest of the city was dealing with 45-47 degrees Celsius. (For comparison, a major fire broke out in the Bhalswa landfill in 2022 when the LST reached 62 degrees Celsius in 2022.)
There’s little green cover around these markets that allows them to take shade; access to public parks now requires a fee of Rs 20; laws prohibit the usage of umbrellas or other shelters in many zones.
“Earlier, we worked for twelve hours. Now, as it gets hotter, we can only pull for eight, then five, then three,” a rickshaw puller told the Workers’ Collective.
Sonia* has sold beedi at her redhi patri (pushcart) in New Delhi’s Sangam Vihar for almost 25 years now, but is under pressure from the Municipal Corporation of Delhi to remove her pushcart. Similar eviction drives are disrupting the livelihoods of many street vendors in Delhi, as MCD officials confiscate shade structures like tarpaulins as ‘encroachments’. Street vendors still pay Rs 100 a day in bribes, Rs 400 for transport, and Rs 6,000 per month in fees, but earn as little as Rs 300 per day due to heatwaves, compared to Rs 1200 on normal days, according a new report by Greenpeace India and Workers’ Collective for Climate Justice South Asia.
While incomes decline, expenditure on heat related purchases such as water or medicines to deal with urinary infections have gone up, says activists.
Many informal workers are exposed to heat hazards because they live in homes constructed of heat-trapping materials with tin or tarpaulin roofs, in neighbourhoods without trees or shade, and in overcrowded areas with poor access to clean water or sanitation, and without the resources to buy fans.
No Data, Legal Backing
Human vulnerability to heat is currently mapped on data on absolute temperatures, but the data on heat itself is not easily available. The SFC analysis found that regional climate information – what dangerous heat looks like or how the urban heat island effect contributes to heat stress – is not available to the local official tasked with implementing heat measures. Moreover, unlike other countries, India’s heat action plans didn’t take into account the impact of ‘humid heat’ (wet-bulb temperature), until 2023.
Similarly, without standardised methods to calculate and report on heat-related illness, India was found to lack “granular and high quality national data” on temperature-related health and healthcare impact, per an analysis published in Significance Magazine, an OUP journal.
Some reports and interviews with activists suggest heatwave deaths are underreported. “Many people have died but we have no estimate of the number. Last year, when Delhi’s temperature reached 50 degrees, a security guard just fell down and there was no investigation,” Beena says.
Heatwave related-deaths data are collected separately by different agencies such as the Ministry of Earth Sciences, Ministry of Statistics and Programme Implementation, National Disaster Management Authority, National Crime Records Bureau, Ministry of Health and Family Welfare based on different metrics. [Guidelines to confirm heatstroke and heat-related deaths were put in place only last year.] The numbers are often incongruous, vague, or sometimes not released.
Disaggregated large scale data, says Selomi, can strengthen India’s case for climate adaptation financing and strengthen labour rights advocacy for heat-protective measures such as work-rest cycles. But heat plan actions do not generate nuanced data although research shows that gender norms, caste hierarchies, caregiving burden, and unequal access to resources affect women disproportionately.
“Jab bhi mausam mein badlav aata hain, garib workers par hi sabse zyada maar padhti hain, and usme mahila workers hi sabse zyada suffer karti hain (women suffer the impact of seasonal changes the most),” says Anita.
Equally incriminating is the fact that there is no centralised, large-scale government database tracking how heat affects labour productivity, income loss, or occupational health—especially in the informal sector.
“Heat is largely treated as a disaster management issue, rather than a workplace hazard that requires regulatory safeguards, enforcement, and accountability,” Selomi says. No national survey currently captures occupational health or diseases. The NSSO collects data on employment and socioeconomic status, but not on health; the National Family and Health Surveys on the other hand do not collect information about people’s work.
“Mainstream climate governance in India has focused on emissions, energy, and adaptation infrastructure, with little integration of labour and occupational health considerations,” says Selomi.
A Greenpeace report from 2024 on street vendors in Delhi found heat not only impacted their health but also their livelihood, compromising their ability to seek hospital treatments. Specific advisories for workers in specific jobs – brick kiln work or garment labour, for instance – could enhance the effectiveness of heat plans and acknowledge the burden of dealing with wage loss, illness and healthcare.
No Legal Muscle
Heat action plans are positioned as general advisories, with no legal framework. Last year, when temperatures crossed 50 degrees Celsius in some parts of India, the Ahmedabad heat advisory recommended access to washrooms or drinking water. But private companies were not mandated to adhere to this advice.
In Delhi this year the government has tasked 11 nodal officers with ensuring workers rest between 12 pm and 3 pm at construction sites. “But which company will let workers rest for three hours, and who will actually implement this?” asks Anita. She points to the fact that most sites do not even have ORS, water or toilet facilities as mentioned in HAPs.
There are currently only feeble legislations governing occupational health and safety. The now-replaced Factories Act, 1948, required factories to ensure “adequate ventilation by the circulation of fresh air” and maintain “such a temperature as will secure to workers therein reasonable conditions of comfort and prevent injury to health”. The 2020 amendments consolidated central laws on workers’ safety into the Occupational Safety, Health and Working Conditions Code, 2020. The code refers to heat in the context of dock workers only, and also exempts new factories from legal provisions in order to create more employment and economic activity, according to the PRS Legislative Research.
With no specific fund allocation for heat wave related services, and many heat plans face funding constraints. The CPR analysis found only 11 of the 37 HAPs discussed funding sources and eight of them required departments to find the resources themselves. Heatwaves are currently not a notifiable disaster in India, which forestalls the allocation of a dedicated fund.
“We need funding for heat action, similar to the centralised funding under the 15th Finance Commission for the National Clean Air Action Program,” Avinash says. A 2024 Climate Policy Initiative report also recommended that India’s 16th Finance Commission (whose recommendations will take effect from April 2026) include vulnerability-related parameters, such as occupation and gender, as variables when setting the criteria for allocating funds to state governments.
The SFC analysis noted there is a persistent belief that heat is not a pressing problem. Political and public attention is focussed on short term concerns but not long term intentional actions such as death surveillance, free water ATMs, cash transfers to allow workers to purchase protective equipment – especially needed for tasks taken on by marginalised communities.
Administrative chaos has also weakened HAP’s ability to respond to its mandate. During heatwaves, the labour department, state disaster management authorities, the India Meteorological Department and other state authorities release heat action plans. The efforts to mitigate heat wave impact (such as constructing shelters or providing drinking water) are the responsibility of multiple ministries including Ministry of Urban/Rural Development, Ministry of Health and Family Welfare, Ministry of Labour & Employment, Ministry of Surface Transport, Department of Drinking Water and Sanitation. Existing schemes that already provide basic services in informal markets and settlements, like Jal Jeevan Mission or Mahatma Gandhi National Rural Employee Guarantee Scheme, are rarely mentioned in HAPs.
The Ministry of Labour and Employment said last year that it doesn’t maintain a centralised database on HAPs, and said the responsibility of occupational support for informal workers rests with states and UT governments.
The NDMA guidelines and HAPs reproduce a “trope in disaster governance of the paternalistic state” by identifying the state’s role as central to avoiding heat-related deaths, noted a 2024 analysis of HAPs in PLOS Climate. This “zero casualty” approach can divert attention from other priorities such as minimising heat impacts of the most vulnerable, the authors added.
A recent spate of forced evictions and urban displacements have magnified workers’ precarity by prolonging their commute, adding to fatigue and stress, and forcing them into houses and settlements that are worse equipped for heat. For instance, ever since Delhi’s dhalaos were closed down due to cleanliness concerns, waste pickers have been forced to work in the open or in cramped homes.
The Gender Context
Global data is zooming on rising health vulnerabilities related to heat– women are more likely to experience heat cramps, menstrual irregularities, miscarriage, and stillbirths. A 2023 study in Tamil Nadu found that occupational exposure to extreme heat more than doubled the risk of miscarriage in pregnant women.
Consider for instance India’s large domestic labour market, notes Anita. Many domestic workers work in poorly ventilated kitchens, and those employed as full-time workers are often made to sleep in balconies, living rooms, or attached cramped spaces without any fans or open windows. “They work and live like bonded labour,” she says.
From garment factories to home-based work, women often work in overcrowded spaces built using heat-trapping materials, and often lack the agency to demand breaks or better conditions. Those who work outdoors as street vendors or sanitation workers face direct sun exposure and do not have access to shade or toilets.
Sonia sits at her redhi from 12 pm to 8 pm, and limits her water intake during peak hours because there are no clean public washrooms in close proximity. “Toilets are very important for women…men can go anywhere, but women can’t,” she says. In a crisis, she goes home which is close to her pushcart. She has had multiple urinary tract infections over the years, treating which costs Rs 800 every time, which depletes her earnings considerably.
Anita reports that many women in her circle complain of dehydration, swelling, menstruation cramps, dizziness, rashes, kidney problems. There are reports that women are opting for hysterectomies to deal with the physical demands of working in an era of climate change. Many go to local “jhola chhaap (quack)” healers who offer them fluids to cure their immediate dehydration.
Without job security, missing even a single day of work translates into a loss of income, forcing many women to continue work in conditions of low pay and harassment.
There are barriers of discrimination that prevent many communities – landless labourers for instance – from accessing resources to help them cope with heat. “If there is a water resource, it is in the area where the dominant community lives, making it difficult for caste-marginalised communities to go there,” says Beena.
Underreported cases illustrate instances of Dalit women being harassed, molested, and abused for drawing water or touching a water vessel.
The pressure does not let up at home either since women do not get to rest or recover from heat stress brought on by travelling lost distances using public transport and walking without access to water or shade. “Dalit women carry a double burden at work and at home,” says Anju. “Even when they are sick or completely exhausted from heat exposure, they are still expected to manage household chores and caregiving responsibilities.”
The Workers’ Collective for Climate Justice report noted that in the absence of systemic support for heat related crises, workers have forged networks to survive: women waste pickers share tips and offer emotional support to each other, street vendors pool in resources to restock or collectively organise responses after evictions. In areas like Lal Quila and Lajpat Nagar market, many street vendors also act as first responders, offering customers water or ORS if they faint.
In Delhi, street vendors are collecting money to arrange water pots and dispensers in public spaces, their version of ‘free’ water ATMs. “CSR is not working for us, We need a VSR – vendor social responsibility – to take its place,” a vendor said in a meeting.
Selomi agrees that a community-driven approach could be effective. This includes participatory planning with health workers like Accredited Social Health Activists (ASHAs) and local women groups, localised heat mapping, and community audits of HAP.
With communities already taking action, it’s up to the government to step up, says Avinash. “But we are not acting like we are in a crisis,” he adds.
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