The industrial physician is a doctor with occupational health training who advises the employer on keeping employees healthy. The obligation applies per workplace, not per company. Any workplace where 50 or more workers are regularly employed, including part-timers, must appoint one within 14 days of reaching the threshold and report the appointment to the Labour Standards Inspection Office. Most appoint a part-time contracted physician. Workplaces with 1,000 or more workers, or 500 or more in specified hazardous work, need a full-time physician; those with more than 3,000 need two.
The role is defined by law. The physician inspects the workplace, normally monthly, sits on the health committee, reviews health check results and advises on any changes to work. Employees working more than 80 hours of overtime a month and showing fatigue are entitled to an interview with a doctor, usually this one, and the employer must act on the doctor's opinion. Workplaces with 50 or more workers must also run an annual stress check; a 2025 amendment extends that duty to smaller workplaces from 1 April 2028.
In practice, the industrial physician is central to mental health cases. Before an employee returns from a leave of absence, the employer usually asks for the physician's opinion, alongside the treating doctor's, on whether they can work and under what conditions.
What it means for a foreign employer
- Count heads per office. A Tokyo office that grows past 50 workers, including contract and part-time staff, needs a physician, a health committee and a stress check. This is easy to miss during rapid growth.
- Use them on long hours. The physician interview is your evidence that you took overwork seriously if a karoshi or mental health claim ever arises.
- Return-to-work decisions need them. Ending a leave of absence without the physician's view is a legal risk.
- Good physicians are scarce. Contracting through a specialist provider is the usual route, and English-speaking physicians are worth asking for if your managers do not speak Japanese.
Sources
- Industrial Safety and Health Act, Articles 13, 18, 66-8 and 66-10, and the Ordinance on Industrial Safety and Health, Articles 13 to 15 and 52-2.
- Act partially amending the Industrial Safety and Health Act, promulgated 14 May 2025, and the cabinet order setting 1 April 2028 as the date stress checks become mandatory for workplaces with fewer than 50 workers.