NR-35 on the Factory Floor: Permits, APT, and Daily Evidence

Compliance with NR-35, which regulates work at height, is essential to ensure the safety of employees in factories and construction sites. Although many professionals are familiar with the standard, practical application in daily operations goes beyond merely fulfilling annual training requirements. It is crucial for companies to adopt an integrated approach that includes permits, Preliminary Risk Analysis (APT), and ongoing evidence of compliance. This text explores how to effectively implement these elements on the factory floor.

Permit for Work at Height

The first step to ensuring safety in height-related activities is the issuance of permits that formalize the authorization to carry out the work. The permit must be clear and always accessible to workers. Here are some points to consider:

• Documentation: The permit must be properly filled out and signed by a technical responsible person. This ensures that all safety aspects have been considered before the activity begins.
• Validity: It is crucial that the permit has a defined validity period and that workers are informed about it. The common practice of “renewing” permits without re-evaluation can lead to unnecessary risks.
• Weather Conditions: The permit should include an assessment of weather conditions. For example, on days with strong winds or rain, work at height should be suspended.

Preliminary Risk Analysis (APT)

The APT is a tool that helps identify risks associated with work at height. For the analysis to be effective, it must be conducted before each activity that involves risks. Here’s how to implement it:

1. Risk Identification: The team must identify all potential risks related to work at height, such as falls, inadequate equipment, and environmental conditions.
2. Control Measures: After identifying the risks, control measures must be defined. This includes the use of PPE (Personal Protective Equipment), such as safety harnesses, and the development of operational procedures.
3. Specific Training: Training must be specific to the risks identified in the APT, not just generic training. Each worker must be trained to handle the situation they will face.

Daily Evidence

Evidence is fundamental to ensure that standards and procedures are being followed. They serve as a record that can be consulted during audits and inspections. Here are some recommended practices:

• Daily Checklists: Develop checklists that workers must fill out daily before starting work at height. This may include checking PPE, equipment conditions, and evaluating the work environment.
• Incident Reports: Maintain a detailed record of any incidents or near-misses that occur during work at height. This helps identify failures in procedures and implement improvements.
• Regular Inspections: Conduct periodic inspections of work areas at height and the equipment used. These inspections should be documented, and non-conformities must be corrected immediately.

Common Errors in Implementing NR-35

It is common for some companies to face difficulties in implementing NR-35. Here are some frequent mistakes that should be avoided:

• Irregular Training: Many companies only conduct annual training without recycling or updates. This can lead to misinformation about new practices and risks.
• Ignoring the APT: Failing to conduct the APT for each activity is a serious mistake that can result in fatal accidents.
• Lack of Supervision: The absence of supervision during work at height can lead to carelessness and improper use of PPE.

When to Seek a Specialist

There are situations where internal experience may not be sufficient to ensure compliance with NR-35. It is advisable to seek the help of a specialist when:

• The company is starting activities that involve work at height and has no prior experience.
• There are significant changes in activities or team structure, requiring a new risk assessment.
• Accidents or near-misses occur, indicating the need for a complete review of safety procedures.

Implementing NR-35 on the factory floor requires continuous effort and a commitment to safety. Permits, APT, and daily evidence are fundamental pillars for the protection of workers. Focusing on practice and real application of the standards, rather than just formal compliance, is crucial for accident prevention and promoting a safe work environment. For companies looking to enhance their Occupational Safety and Health processes, specialized consulting can be an important differentiator. Legnova is an option to consider for guidance in this regard.