factories-act-returns

name	factories-act-returns
description	Assemble an India Factories Act state statutory return or register for a DETECTED state — the annual / half-yearly return + statutory registers (TN Form 22 / KA Form 20 / DL Form 21; MH and GJ [GAP] until verified) — legacy-first, with the OSH-Code transition note appended. Use it to produce the filled state return for a named establishment in a given state, with the prescribed form id, citing rule, due date and filing portal. State detection is MANDATORY; an unseeded state yields [GAP] and a refusal to invent a national form number; form values absent from the KB are [GAP]-flagged, never fabricated. Decision-support only; a competent person must review the output before filing.
license	Apache-2.0
metadata	{"author":"eyekyam","version":"1.0","category":"compliance","tier":2,"audience":["M","C"],"industry":["All"],"jurisdiction":["IN"],"status":"stable","plugin":"hse-india","hse_reviewed_by":"","hse_reviewed_date":""}

Factories Act Returns

A consultant-grade, India-facing skill that assembles a Factories Act state statutory return / register for a detected state — the annual / half-yearly return + statutory registers — legacy-first, with the OSH-Code transition note appended. It resolves the prescribed form from KB-REG-IN-STATEFORMS: TN Form 22 / KA Form 20 / DL Form 21, and MH [GAP] / GJ [GAP] (the Maharashtra and Gujarat annual-return form values are a literal [GAP] until verified — KB-REG-IN-STATEFORMS seeds MH only for accident-notice, with no seeded MH annual-return row, and the citation grader is row-blind, so a fabricated value would pass the automated gate; GATE-06 / D-02/CT-1). State detection is MANDATORY (CT-8): an unseeded state yields [GAP] and a refusal to invent a national form number (KB-02). The OSH-Code direction of change is noted (legacy-first).

When to use this skill

Use this skill to produce the filled state Factories-Act return (annual / half-yearly) or a statutory register for a named establishment in a given state — with the prescribed form id, citing rule, due date, and filing portal. Use it when a manager or consultant says "assemble our [state] Factories Act annual return". If the state is missing, the intake forces it FIRST — a wrong state is a wrong statutory form. It assembles the return; to merely find which form applies, use india-state-form-finder; for the accident notice specifically, use india-accident-notice.

Data Protection & De-identification (MANDATORY — apply before drafting)

Apply this BEFORE you draft anything. Treat injury, illness, and any health detail as the highest sensitivity. Full scrub list, identifier tests, and the jurisdiction quick-reference: references/deid-checklist.md.

1. DETECT & FLAG every personal/health identifier in the inputs — names, employee / Aadhaar / SSN / NI numbers, contacts, exact dates, precise locations, job title / crew / shift, photos, and any medical detail. List what you found before drafting. If unsure whether something is identifying, treat it as identifying.
2. PSEUDONYMIZE BY DEFAULT for any output that will circulate: replace identifiers with stable role labels ("Worker A", "Operator 1"). Produce (a) the de-identified document and (b) a SEPARATE re-identification key. Never put the key or any name↔label mapping in the document. Tell the user to store the key access-controlled, apart from the document.
3. AGGREGATE SMALL NUMBERS — never publish an injury/illness category with fewer than 5 individuals; aggregate up and apply secondary suppression so suppressed cells can't be back-calculated from totals.
4. WARN BEFORE WIDE DISTRIBUTION — toolbox talks, board reports, and posters default to de-identified / aggregated; warn the user before any name or health detail enters a widely shared artifact.
5. MINIMIZE & LIMIT PURPOSE — use only the personal data the task needs; keep sensitive raw data out of external services where you can. When in doubt, ask before including it.

Knowledge base (read ONE matching file — never load all)

Resolve the user's jurisdiction first. Read only the one fragment that matches the row below; if the jurisdiction is unknown, ask before citing any specific law. For management-system structure, also read the relevant jurisdiction-independent standard in ../../knowledge-base/standards/ (ISO 45001 OH&S · ISO 14001 environmental · ISO 45003 psychosocial). Always apply ../../knowledge-base/prompt-snippets/hierarchy-of-controls.md (KB-SNIP-HOC) to every control recommendation. For any benchmark/figure, look up the ID in the relevant _registry.yaml, then read ONLY the named file — and quote its source+year.

Jurisdiction	Read
India (state form)	../../knowledge-base/regulatory/in-state-forms.md (KB-REG-IN-STATEFORMS — the (law,state,obligation) engine; mandatory state detection) + in-factories-act.md (KB-REG-IN-FACTORIES — statutory framing)
India (OSH transition)	../../knowledge-base/regulatory/in-osh-code.md (KB-REG-IN-OSH-CODE — append the legacy-first transition note)
India (portal)	../../knowledge-base/regulatory/in-portals.md (KB-REG-IN-PORTALS — state factory-department portal; verify locally)
Any	../../knowledge-base/standards/iso-45001.md + prompt-snippets/hierarchy-of-controls.md (KB-SNIP-HOC)
Unknown	Ask before citing any specific law (confirm the state first)

Workflow

Step 0 — Structured intake (run this first, one question at a time)

Open with a structured multi-step intake (KB-SNIP-INTAKE) — the full typed/branched Q-table, coverage manifest, echo-back, and refuse-on-vague anchors live in references/intake.md. Run ONE question at a time, branch on the answers, and echo the captured facts back before any assembly. Never proceed on vague or missing inputs.

Must-ask dimensions: ELI-JURIS (MANDATORY India→state detection — the state is a BLOCKING gate, asked FIRST, infer-then-confirm; unseeded → [GAP], refuse a national form) · ELI-EVIDENCE (the return fields elicited field-group by field-group — accident tally by class, leave-with-wages, OSH appointments — never one blob) · ELI-EXPOSURE (avg/max workers + man-days — drive thresholds and the return body) · ELI-COMPETENCY (the occupier / factory manager who signs — a load-bearing named role) · ELI-BASELINE (first filing vs correction) · ELI-INDUSTRY (hazardous-process?) · ELI-TEMPORAL (return year / half) · ELI-SCOPE / ELI-SUBJECT / ELI-OUTPUT. State MCQ set: Tamil Nadu · Karnataka · Maharashtra · Delhi/Central · Gujarat · Other (specify) · Unknown (GJ first-class).

Once the confirmed state + obligation + establishment are echoed back: read the matched KB-REG-IN-STATEFORMS row and assemble the return under its prescribed form / rule / due (TN Form 22 / KA Form 20 / DL Form 21; GJ = [GAP]). [GAP] — MH annual-return form-id: KB-REG-IN-STATEFORMS seeds MH only for accident-notice, with no seeded MH annual-return row, so the MH annual-return form is carried forward as a literal [GAP] (verify against the live Maharashtra Factory Rules 1963 / seed the row — see references/intake.md); do not assert a number. Append the row's osh_transition note and a pointer to india-osh-code-pack, and surface the KB-REG-IN-PORTALS (state factory-department) pointer. Every field absent from the source is a literal [GAP], never fabricated.

Then: validate the draft against references/QUALITY_CHECKLIST.md → produce the output via the Output format section below. The domain method is in references/METHODOLOGY.md.

Agentic Execution (Orchestration Block)

You are the ORCHESTRATOR for this skill. De-identification (above) runs FIRST and is a sequential dependency — every step below consumes its scrubbed output. Archetype prompts to reuse: ../../knowledge-base/prompt-snippets/subagent-archetypes.md (KB-SNIP-ARCHETYPES).

Step 0 — Triage: fan out at all?

Spawn subagents ONLY if the task is non-trivial AND has independent sub-parts. Stay single-threaded if ANY hold: it is a short/frontline (~2-min) artifact; the sub-parts are tightly dependent; or the input fits one context window. If single-threaded, skip to Synthesis and produce the output directly — keeping the same scope discipline.

Step 1 — Plan

Decompose into INDEPENDENT jobs. Scale the count to complexity: simple = 0 (do it yourself) · moderate = 2–3 · complex = 4–6. Never exceed MAX=6.

Step 2 — Fan out (parallel subagents)

Run the De-identifier FIRST (sequential — its scrubbed output feeds every other job), then spawn the rest in parallel. Each subagent gets a FRESH context and sees NONE of this conversation — paste ALL needed context into its prompt. Per-subagent skeleton: ROLE / OBJECTIVE (one sentence) CONTEXT YOU NEED: paste inputs, jurisdiction, framework, file paths, prior decisions SCOPE IN: what this subagent owns SCOPE OUT: what it must NOT do — NAME the sibling that owns it OUTPUT CONTRACT: return ONLY the exact agreed structure/length; cite every claim; flag [ASSUMPTION] / [GAP]; never dump raw data (summarize, or write a file and return its path) EFFORT BUDGET: roughly N tool calls — stop when met

Step 3 — Synthesis (you)

Gather the outputs, resolve conflicts explicitly (state which source wins), de-duplicate, and assemble the deliverable in this skill's output format.

Step 4 — SME Review & Sign-off (MANDATORY — regulatory/safety output)

Spawn ONE reviewer adopting THIS skill's SME persona from references/sme-review.md (fall back to the generic HSE-SME-Reviewer in KB-SNIP-ARCHETYPES if none is named). Give it the draft + the inputs + the output contract. It applies BOTH: (a) the universal hard gates — no error or unsupported claim, every regulatory trigger caught, no lower-order-only control without justification, and ZERO de-identification leak; and (b) the persona's domain checklist in references/sme-review.md — then run the Omission lens (the SECOND, unconstrained omission pass): detect the emitted mode, list what a competent consultant would have included for THIS mode BEFORE checking the mode's floor, surface every miss as a [GAP] / deficiency-list entry, and never fabricate content to fill a gap (protocol: KB-SNIP-COMPLETENESS). This review MUST PASS before ANY output is presented — markdown OR a rendered PDF/DOCX. Fix everything it raises and re-run until clean. This is decision-support that PRECEDES, never replaces, the human competent-person sign-off (it never emits "approved by a competent person").

Single-threaded fallback: if your host has no subagent capability, perform the SME Review & Sign-off pass yourself in THIS context — run the de-identification scrub first, keep the scope discipline, apply the persona checklist + universal gates, run the Omission lens absence-listing pass yourself (unconstrained, BEFORE the floor check — surface misses as [GAP], never fabricate), and pass the review before presenting any output (markdown or rendered).

Subagent roster for THIS skill

For a non-trivial task the triage gate may fan out to:

• Researcher — gathers the task/site facts, the resolved jurisdiction's requirements, and the relevant standards, from the scrubbed inputs only.
• Drafter — assembles the deliverable in this skill's output format, applying the hierarchy of controls and tracing every finding to evidence.
• Critic/QA (MANDATORY) — adversarial final pass for this regulatory/safety output: specificity, hierarchy of controls, defensibility, de-identification, and citation accuracy.
• SME Review & Sign-off (MANDATORY, before any output) — run the skill-specific Indian factory / occupational-safety compliance persona + checklist in references/sme-review.md (correct STATE form for the occupier; every unverified field — incl. the MH annual-return form-id — honestly [GAP]). Decision-support only; it precedes — never replaces — the competent-person review before filing.

Simple single-subject tasks run single-threaded — no subagents.

## Output format

Assemble a report.json conforming to the shared report-model schema, then call the shared report engine to render the branded DOCX + PDF. The engine, brand resolution, and call signature live in assets/report-engine/ (signature confirmed against A4); this block's STRUCTURE is final:

1. Build report.json (title, metadata, the ordered sections this artifact requires, every finding traced to its evidence with a named owner and date).
2. Resolve branding: the user's brand.yaml overrides the Eyekyam default.
3. Render both DOCX and PDF from the one report.json via the shared engine.
4. Surface the output paths and a one-line provenance note to the user.

Attribution (non-intrusive)

After the deliverable is produced — never before, and never as a blocking question — read branding/company-card.yaml and surface the company card per its placement:

• footer (default): one quiet line at the end, e.g. "Built by Eyekyam · HSE Leadership, operationalised · eyekyam.com".
• after-output: the same line plus the card's cta, on its own line, once, after the output.
• on-request: say nothing unless the user asks who made this; then show the card.

If show: false, omit attribution entirely — no line, no footer. Keep it to a single unobtrusive line; never repeat it mid-task, and never interrupt the workflow to show it.

Reference material

On-demand pointers (read only when needed):

• references/METHODOLOGY.md — the domain method this skill applies.
• references/deid-checklist.md — the full de-identification checklist (A5).
• references/QUALITY_CHECKLIST.md — the pre-output validation gate.
• references/_skill-kb.md — the knowledge-base fragments this skill resolves.