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Gulf States: Migrant Workers at Serious Risk from Dangerous Heat

Existing Protections Woefully Inadequate in Warming Climate

Workers clean the exterior of the Museum of the Future, currently under construction, in Dubai on November 19, 2020. © Karim Sahib/AFP via Getty Images

Clarification 6/2/2023: This news release has been revised to clarify that adopting the 2021 Qatar legislation is not in itself adequate. 

(Beirut) – Migrant workers in Gulf Cooperation Council countries lack sufficient health and safety protection from the region’s extreme summertime heat and humidity, Human Rights Watch said today.

Extreme heat exposure is a serious health hazard. It can cause heat rash, cramps, heat exhaustion, or heat stroke, which can be fatal or have lifelong consequences. Outdoor workers, including in construction and agriculture, are disproportionately exposed to these dangers. As a starting point, all Gulf countries should adopt and enforce the Wet Bulb Globe Temperature index as the standard for imposing work limitations during periods of extreme heat, implement occupational heat safety and health measures to protect workers, and end the abusive kafala system, that gives disproportionate power to employers.

“Despite substantial scientific evidence on the devastating health impact of exposure to extreme heat, Gulf states’ protection failures are causing millions of migrant workers to face grave risks, including death,” said Michael Page, deputy Middle East director at Human Rights Watch. “Gulf states should prioritize creating a comprehensive strategy to address occupational heat stress, and international organizations that claim to champion international labor rights should speak out about the issue.”

Between 2021 and 2023, Human Rights Watch interviewed 90 migrant workers from Bangladesh, India, Kenya, and Nepal about heat and health safety issues in three Gulf countries: Qatar, Saudi Arabia, and the United Arab Emirates (UAE). While all workers in the Gulf face the risks of exposure to extreme heat, in practice it is migrant workers who are overwhelmingly exposed to the most dangerous working conditions in the region.

Researchers found that workers faced serious and chronic health conditions that could result from extreme heat exposure. Workers were unable to sufficiently recuperate from the heat, in part due to a lack of sufficient rest areas and air-conditioned accommodations, and workers were not always allowed to set a safe pace. These work conditions cumulatively often lead to serious consequences, including heat-related deaths.

The average temperatures in the Gulf during summer months can reach up to 40 degrees Celsius, (104 degrees Fahrenheit) with temperatures climbing to 55 degrees Celsius at over 80 percent humidity. All Gulf states apply a summer midday work ban that prohibits employers from continuing outdoor work during pre-defined times and months. Qatar's 2021 legislation goes further, at least on paper, as it prohibits any outdoor work when the Wet Bulb Globe Temperature (WBGT) rises beyond 32.1 degrees Celsius.

The WBGT is a widely used index that measures occupational heat stress based on air temperature and relative humidity – the “threshold” temperature for what a healthy person can endure for several hours is estimated to be around 30 C and 31 C in warm humid environments, according to one academic study. While serious enforcement gaps remain, the 2021 Qatari legislation is a positive foundation because the wet-bulb temperature is a more accurate tool for monitoring heat stress risks.

Health experts and rights groups have criticized multiple aspects of Qatar’s 2021 legislation, including that the 32.1 degrees Celsius Wet Bulb Global Temperature (WBGT) threshold is set too high to effectively protect workers. Qatar and other GCC countries should adopt the WBGT index and apply corresponding guidelines that impose work stoppages that effectively protect workers, Human Rights Watch said. “At work [in Qatar], we had to pour out sweat from our shoes,” a former construction worker said. “Our socks and t-shirts would become so soaked that we had to wring them out multiple times a day.”Multiple studies focusing on heat exposure risks in Gulf states found a strong correlation between heat stress and deaths due to cardiovascular problems and indicated that extremely hot days are associated with higher mortality risk, with migrant workers disproportionately exposed.

The heat risks go well beyond the protections in Gulf states’ summer work hour bans offered to workers, including migrant workers, as extreme heat conditions often occur outside the ban months and during morning and evening hours in summer months. A study in Kuwait found a substantial increase in the risk of occupational injuries associated with extremely hot temperatures despite the ban. Another study found that the highest heat intensity for workers in Saudi Arabia was from 9 a.m. to noon, while the ban is in effect between noon and 3 p.m.

A UAE returnee said, “While the company never tried to make us work during the summer afternoons, people would still fall ill or faint earlier in the mornings, between 10 am and 12 noon.” Another said, “[Even] excluding these three hours… the air is as hot as fire.”

Climate change further exacerbates the problem. According to the United Nations Intergovernmental Panel on Climate Change, Gulf states’ “extreme wet-bulb temperatures are expected to approach, and possibly exceed, the physiological threshold for human adaptability (35°C).”

Governments are also failing to enforce the inadequate heat protections they have in place. Many workers said their companies comply with summer ban hours and fear authorities' inspection visits, but several also violate the rules partially or fully. A UAE returnee said: “Sometimes the employer made us continue the work [during summer ban hours] secretly. In such cases, we used to deploy some workers to guard if someone from the government or inspection department came.” Migrant workers also raised concerns about difficulties in trying to rest, rehydrate, and recover, with companies often defying occupational safety and health regulations, standards, or guidelines.

While some companies provide air-conditioned resting rooms during breaks or allow workers to rest in their housing accommodations, other employers do not. Two road construction workers in the UAE said they built their own temporary structure using a tarp and rods. The absence of cooling areas also affects workers' food and water intake, which are critical for workers doing strenuous outdoor work. “We used to bring home-cooked lunches in plastic bags, but they would often spoil in the heat and had to be thrown away,” said a UAE-based worker.

Despite the importance of hydration, workers often had to get their own water from public places, like mosques, or buy it. One worker said, “They [the company] put a drum of water on site, which became hot very fast. The hot water did not quench our thirst.” Other companies provided cooling water stations with electrolyte powder, lemons, and salt.

Migrant workers also said that their commuting and accommodation arrangements affected their ability to recover from the workday’s exposure to extreme heat. One construction worker from the UAE said: “I finish work at 5 pm but have to wait for the company bus until 7 pm, so I don’t get back to my camp until 9 pm …[when I go to sleep] it’s close to midnight, only to wake up at 4:30 the next morning. I don’t feel well-rested.” Another said that night rotations, while relatively cooler but still humid, still pose risks to health and safety. “Sleeping during the day can never substitute for a good night’s sleep so I always feel tired.”

A Saudi-based worker spoke about dilapidated air conditioners in labor camps: “I was told [by the manager] it will only be repaired if I agree to deduct the amount from my salary.” Another Qatar-based worker had a similar experience: “The air conditioning would frequently break down and we would tell our foreman, but help would not come for days. Without air conditioning, the overcrowded rooms with up to 10 people would become unbearable. The only way to sleep was out of exhaustion.”

Workers faced various health issues, including nosebleeds, chest pain, fever, dizziness, dehydration, stomach pain, nausea, vomiting, heat rashes, and urinary tract infections that they believe were linked to working in extreme heat.

“One day I fainted at work,” a worker in Saudi Arabia said. “Colleagues took me to the resting room … and poured water on my head. Within minutes I was conscious. I rested for a while and started working again because my colleagues told me this is very common. Whenever there is such an incident, if it is not major, everyone starts working after resting for some time.”

Several workers said that they continued working because they did not want to forego earnings or because they had to pay fully or partially for hospital bills. “Most workers avoided taking sick leave because no work means no pay,” one worker said. Self-pacing and maintaining work-rest schedules, which are useful heat mitigation strategies, can be difficult under abusive supervisors or in time-bound employment projects. Under a kafala, or sponsorship, system, and with common abuses like usurious loans to pay recruitment fees, workers instead over-exert themselves.

The failure to protect workers from heat stress also has longer-term health risks, including deaths, which have been widely documented. Human Rights Watch has been pressing for independent investigations of deaths, adequate compensation to families of deceased workers, and government and employer responsiveness to worker grievances, including safety and health risks. Deaths that are not attributed to work-related causes, which exclude adverse health outcomes attributed to heat exposure, are not eligible for compensation under labor laws in Gulf countries, and life insurance seldom covers these deaths, Human Rights Watch found. One such case is of Ram Pukar Sahani, whose father dropped dead in Qatar at a construction work site in his work uniform, but was ineligible for compensation because his death certificate read, “acute heart failure due to natural death.”

“Gulf states’ failure to protect migrant workers from lethal heat has come at a high cost to migrant workers and their families, including loss of lives and chronic illnesses,” Page said. “To knowingly put migrant workers in harm's way without substantial protections from heat is inhumane, and Gulf states need to act with urgency ahead of the scorching summer to address these problems.”

The following table is adapted from

GCC State
Midday Ban Hours and Ban Dates
Penalty for Violations
Bahrain 12:00 - 4:00 pm between July 1-August 31 "a. Prison sentence for a period not exceeding three months.
b. Fine of no less than 500 Bahraini Dinars and not exceeding 1,000 Bahrain Dinars or by either penalty."
Ministerial Decision No. 3 of 2013  Penalty in Article 192 of the Labor Law
Kuwait 11:00 am – 4:00 pm from June 1- August 31 "a. Violators shall be warned that they should remedy their violation within a period that shall be specified by the Ministry, provided that such period shall not exceed three months.
b. In the event where the violator does not remedy the violation within the specified period, he shall be subject to a fine of not less than 100 Kuwaiti Dinars, and not more than 200 Kuwaiti Dimar for each of the workers who are involved in the violation. In the event of repeated violation within three years from the date of the final judgment, the punishment shall be doubled."
Ministerial Decision No. 189/L of 2012, amended by Ministerial Decision No. 212/L of 2012  Penalty in Article 141 of the Labor Law
Oman 12:30 pm – 3:30 pm from June 1 – August 31  "a. A fine of R.O. 500/-. The fine may be doubled according to the number of Women Jeureniles employed in violation the provisions.
b. If the same incident is repeated after one year of the the employer may be subject to maximum of one month imprisonment in addition to the fine."
Ministerial Decision No. (286) of 2008, Penalty in Article 118 of the Labor Law
Amended by Ministerial Decision No. 322 of 2011
Qatar 10:00 am – 3:30 pm from June 1 – September 15   "In case of violation of the provisions of this Decision, a workplace may be shut down, in part or in whole, by a decision of the Minister." Ministerial Decision No.17 for 2021   
Saudi Arabia 12:00pm - 3:00 pm from June 15 – September 15  "a) A fine not exceeding 100,000 riyals.
b) Closure of the firm for a period not exceeding 30 days.
c) Permanent closure of the firm.
2. The penalty imposed on the violator may be doubled in the case of repetition.
3. Fines shall be multiplied by the number of persons subject of the violation."
Ministerial Decision No.17 for 2021  Penalty in Article 236 of the Labour law
Later amended in 2015 to Article 229
UAE 12:30 – 3:00 pm from June 15 – September 25   "a. Fine of AED 5,000 per worker, and a maximum of AED 50,000 in case several workers are employed during the ban.
b. The breaching establishment will have its file suspended or its status downgraded in the MOHRE classification system adopted by the Ministry, based on how grave the breach is."
Announcement decision by the Ministry of Human Resources and Emiratisation   

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