ISO 45001 and Legal Requirements for OHS: Evidence Beyond Training

Implementing an Occupational Health and Safety Management System (OHSMS) according to ISO 45001 requires an integrated approach that considers both international standards and local legislation. In Brazil, this integration necessarily involves Regulatory Norms (NRs) and the Risk Management Program (PGR), which are fundamental for legal compliance and minimizing occupational risks.

One of the central challenges for organizations is to go beyond training and demonstrate concrete evidence that OHS processes are being followed and are effective. This involves collecting and analyzing data, operational records, and documenting corrective, preventive, and improvement actions.

ISO 45001: Structure and Focus on Evidence

ISO 45001 is based on the PDCA cycle (Plan, Do, Check, Act), promoting continuous and proactive risk management. The standard requires organizations to establish, implement, and maintain processes to identify hazards, assess risks and opportunities, and determine and implement controls. A crucial aspect of this structure is the ability to produce and maintain evidence of compliance and performance.

This evidence is not limited to training records but also includes internal audits, safety inspections, incident and accident records, and actions taken to mitigate risks. Traceability and proof that activities are aligned with both the standard and national legal requirements are essential.

Regulatory Norms and the PGR

In the Brazilian context, Regulatory Norms, such as NR-01 and NR-12, are fundamental pillars. NR-01, which establishes general provisions, including the PGR, emphasizes the need for a documented system that identifies hazards and assesses risks. NR-12, which addresses safety in machinery and equipment work, highlights the importance of maintaining detailed records of inspections and maintenance performed.

The Risk Management Program (PGR), which must be an integral part of the management system, is a living document. It must be regularly updated to reflect changes in working conditions and identified risks. Associated operational records, such as audit reports and inspection records, are essential to demonstrate compliance and effectiveness of the PGR.

Evidence in OHS: What Should Be Documented

To meet ISO 45001 and Brazilian legal requirements, organizations must maintain a wide range of records. Here are some concrete examples of records that are critical:

• Inspection Reports: Documentation of safety inspections conducted, including date, responsible parties, and proposed corrective actions.
• Incident and Accident Records: Complete detailing of any incident or accident, including investigation, root cause analysis, and preventive measures adopted.
• Training and Qualifications: Detailed records of all training conducted, with attendance lists, program content, and effectiveness evaluations.
• Corrective and Preventive Actions: Documentation of actions implemented to correct or prevent non-conformities and the effectiveness of these actions.

These documents not only demonstrate compliance but also serve as a basis for the continuous improvement of the OHS management system.

Integration with the Federal Senate Resolution No. 1/2024

The recent Federal Senate Resolution No. 1 of 02/29/2024, which updates aspects of OHS legislation, reinforces the importance of an integrated and documented approach to occupational risk management. This resolution emphasizes that in addition to meeting normative requirements, organizations must demonstrate, through traceable documents, the effectiveness of their OHS practices.

This integration with updated legislation requires companies to review and adapt their documentation and monitoring processes, ensuring they are aligned with both ISO standards and national requirements.

Common Challenges and How to Overcome Them

Many organizations face challenges when trying to integrate ISO 45001 requirements with local norms. Among common mistakes is the lack of record updates and inadequate documentation of corrective actions. To overcome these challenges, it is advisable to:

1. Implement a Document Management System: Use digital tools to facilitate the updating and accessibility of records.
2. Conduct Regular Internal Audits: These audits help identify gaps and ensure that records reflect operational reality.
3. Train the Team: Ensure that all employees understand the importance of accurate documentation and are trained to maintain it.

When to Seek a Specialist

In cases where the organization lacks sufficient internal expertise to handle the complexity of integrating ISO 45001 with Brazilian norms, it may be necessary to seek a specialist. Experienced consultants can offer guidance on process adequacy, assist in audit preparation, and ensure that all legal and normative aspects are being met.

Relying on specialized consultancy can be a crucial differentiator to ensure not only compliance but also the effectiveness of the OHS management system, contributing to a safer and more efficient work environment.

For more information on how to integrate ISO 45001 with legal OHS requirements in Brazil, Legnova offers specialized consultancy to help your organization achieve excellence in occupational health and safety management.