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Principal mployer under clr&a act

(Querist) 08 June 2013 This query is : Open 
In a big integrated factory employing 20000 workers and producing 2.5 MT steel and having many departments manufacturing intermediary products, the second in heirarchy has been named as Occupier and another officer reporting to him as manager as per the factories act.
As per the CLR&A act the principal employer will be the occupier or the manager of the factory and in an establishment the person having ultimate control or supervision in the said establishment.
Now for proper compliance of CLR&A act the head of departments heading different departments(establishments) which manufacture intermediary products have been named as principal employer,since the number two person who is occupier can have no supervision and control over the working of the said departments.
Since the number two cannot have supervision and control over the contractor and his employeees the head of each establisment have been named as the principal employer.
Is their any flaw in it?


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