Brazil: Companies have until May to adapt to changes in H&S Normative Rule No. 1

In more detail

The recent updates to Normative Rule No. 1 (“NR-1”), established by Ordinance MTE No. 1,419, of August 27th, 2024, will come into effect on May 26, 2025, and it is crucial that companies are prepared to adapt to the new requirements.

In more detail

One of the most important changes was the determination to include psychosocial risks in the Risk Management Program (“PGR”), without specific definitions and criteria being established. This is a challenging aspect that will require cautious and multidisciplinary work from companies.

Other changes to NR-1 that need attention are related to:

(i) active participation of workers in the risk management process;

(ii) preliminary survey of hazards and risks that must be carried out to identify situations in which it is possible to avoid or eliminate hazards and identify situations of evident occupational risk in which the organization must immediately adopt reduction or control measures;

(iii) requirement that the action plan include a person responsible for the schedule and that the number of workers potentially affected be considered in order to prioritize actions;

(iv) emergency response with simulated exercises;

(v) analysis of dangerous events that could have serious consequences.

The changes are quite significant and will require companies to be careful when adapting their documents.

Psychosocial risks, for example, need to be analyzed carefully, taking into account internal numbers of sick leaves and accidents, working conditions, and external risks. However, their inclusion in the PGR cannot be done indiscriminately, as the identified risk must be properly managed. A joint analysis by health and safety, human resources, and legal teams will be essential in this regard.