Short answer. Yes. Article 159 of the Labor Code requires the physician an employer engages, in addition to their other duties, to "develop and implement a comprehensive occupational health program for the benefit of the employees." Treating employees who fall ill is only part of the role; building and running that program is a separate, ongoing duty.
What the law says
The physician engaged by an employer shall, in addition to his duties under this Chapter, develop and implement a comprehensive occupational health program for the benefit of the employees of his employer.
Labor Code, Article 159 — Company Physician’s Health Program. Read the full provision →
The duty Article 159 adds
Article 159 states that the physician engaged by an employer shall, in addition to his duties under this Chapter, develop and implement a comprehensive occupational health program for the benefit of the employees of his employer. The phrase "in addition to" is the key detail: this is layered on top of whatever other duties the chapter already assigns to a company physician, such as attending to employees who need medical attention. Building a program is a distinct, affirmative obligation.
What "comprehensive" and "occupational" signal
The article does not describe the program as a reactive service limited to treating whoever walks in sick — it calls for something comprehensive and specifically occupational, meaning oriented around the health risks and conditions particular to that workplace, not general medicine detached from the job itself. That framing points toward prevention and monitoring tied to the actual work environment, not only response after someone is already unwell.
What the article does not do is prescribe the contents. It fixes no schedule of medical examinations, no list of hazards to be monitored and no reporting format, leaving the design to the physician and the employer. The test it supplies is a qualitative one: whether what exists is genuinely comprehensive and genuinely occupational, or a clinic that happens to be open.
Who the program is meant to serve
The article specifies the program is for the benefit of the employees of his employer — the obligation runs to the workforce as a whole, not merely to whichever individual employee happens to seek treatment on a given day. A company physician who only sees employees one at a time as complaints arise, with nothing resembling an ongoing program for the workforce generally, is not fulfilling the fuller duty this article describes.
The duty attaches to the physician engaged by an employer, whether that engagement is full-time, part-time or on retainer, so an employer cannot escape it by keeping the arrangement casual. Article 160 completes the picture by requiring that same physician to have training in industrial medicine and occupational safety and health — which is what makes designing a workplace health program a realistic expectation rather than a paper duty.
If this duty is not being met at your workplace
If your workplace has a company physician but no visible occupational health program, note what health services actually exist, how long the arrangement has run, and any workplace conditions the program should reasonably be addressing. That record is what would let you or a lawyer evaluate whether the employer's arrangement satisfies this obligation or falls short of what Article 159 describes.
Not every doctor on staff counts
This duty attaches to a physician engaged for the role this chapter describes, and a separate provision ties that role to specific competence: the physicians, dentists, and nurses employers engage under this chapter are required to have training in industrial medicine and occupational safety and health, with the Secretary of Labor and Employment setting the qualifications for that kind of health personnel. A general practitioner brought in casually, without that occupational-health footing, is not automatically the physician this obligation is describing, even if they see employees regularly.