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    Labor and Social Security Law

    Publication date - 23/03/2026

    NR-1: Manual outlines requirements and sets final deadline for May 26, 2026

    NR-1: Conheça as exigências da norma e o prazo para adequação

    Leonardo da Costa Carvalho
    Author: Leonardo da Costa Carvalho Sócio
    NR-1: Manual outlines requirements and sets final deadline for May 26, 2026

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    The Ministry of Labour and Employment has published the Interpretation and Application Manual for Chapter 1.5 of NR-1, a comprehensive guide that details the implementation of the Risk Management Program (PGR) and redefines the level of regulatory requirements for companies. Effective enforcement will begin on May 26, 2026.

    The educational phase is already underway, but the outlook is clear: organizations that have not yet initiated or properly structured their PGR enter an immediate risk zone. The new manual not only consolidates existing interpretations but also raises the standard of enforcement, particularly in relation to documentation, governance, and practical evidence of risk management.

    Published on March 16, the regulation positions itself as the most relevant document for Occupational Health and Safety since MTE Ordinance No. 1,419/2024. Among its key developments is the integrated approach to risk management, with an unprecedented emphasis on psychosocial risks, now addressed in a structured manner and with a clear expectation that companies will identify, assess, and mitigate them.

    See below the explanatory summary prepared by our team.

    1. Integrated and comprehensive PGR: general risk management

    • Risk Inventory
      Mandatory and detailed: analysis of layout, workflows, workstations, working hours, shifts, and workforce profile.
    • Regulatory Integration
      Mandatory integration with NR-17 (ergonomics), PCMSO, ergonomic assessments, and other OHS programs.
    • PDCA Cycle
      Use of AEP and AET, with an action plan including a timeline, defined responsibilities, and measurable performance indicators.
    • Active Participation
      Mandatory involvement of employees (CIPA, DDS, SIPAT, questionnaires), leadership, and SESMT in the risk identification process.
    • Proactive Measures
      Elimination and substitution of hazards, simulation exercises, and inclusion of outsourced workers within the scope of the PGR.

    2. Psychosocial Risks: Key Highlight of the Manual

    The Manual devotes item 17 to psychosocial risks, complemented by the Guide on Psychosocial Risk Factors (April 24, 2025). Identification must be carried out through direct observation, dialogue, validated surveys, and participatory workshops, ensuring anonymity and trust. There is no requirement to use a specific tool — the methodology is chosen by the company.

    Examples of psychosocial risk factors:

    • Moral and sexual harassment
    • Low autonomy
    • High cognitive demand
    • Lack of support
    • Work overload
    • Inadequate postures
    • Environmental discomfort
    • Interpersonal conflicts
    • Job insecurity

    3. What the Manual Requires in Practice: Concrete Obligations

    • Complete Risk Inventory: mapping of all physical, chemical, biological, ergonomic, and psychosocial risk agents, including analysis of each workstation, working hours, and worker profile.
    • Documented Action Plan: including a timeline, designated responsible parties, allocated resources, and performance indicators that allow assessment of the effectiveness of the measures adopted.
    • Integration with NR-17 and PCMSO: the PGR cannot be a standalone document; it must be formally aligned with the ergonomics program and the Occupational Health Medical Control Program.
    • Employee Participation: CIPA, DDS, SIPAT, and questionnaires are not optional. Employee involvement is a condition for the validity of the risk identification process.
    • Inclusion of Outsourced Workers: employees of service providers operating within the contracting company’s environment must be included in both the risk inventory and the PGR measures.
    • Continuous Review (PDCA): GRO is not static. Periodic review is mandatory following incidents, process changes, or changes in the workforce.
    • Psychosocial Risks in the Inventory: failure to identify psychosocial risks in the PGR may be interpreted as a serious compliance failure by labour inspectors.

    4. Regulatory Timeline: Milestones and Deadlines

    • 2024: Ordinance | MTE Ordinance No. 1,419/2024 — New wording of Chapter 1.5 of NR-1 published, establishing the regulatory framework for the PGR.
    • April 2025: Guide | Psychosocial Risks Guide — Guide on Psychosocial Risk Factors (April 24, 2025), providing specific guidance on the identification and management of psychosocial risks.
    • March 2026: Manual | Interpretation Manual (March 16, 2026) — 140 pages of technical guidance on the effective implementation of the PGR. Educational phase currently underway.
    • May 26, 2026: Enforcement | Start of effective inspection — Full effectiveness of MTE Ordinance No. 1,419/2024. Fines, embargoes, and work stoppages may be imposed based on the new regulatory framework.

    Rely on our Labour team to assess your company’s level of compliance, structure the PGR, and mitigate risks ahead of the start of enforcement.

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