On March 16, 2026, the Ministry of Labor and Employment released the interpretation manual for Chapter 1.5 of Regulatory Standard No. 01 (is the fundamental guideline for Occupational Safety and Health in Brazil), providing more detailed guidance on the practical application of Occupational Risk Management (a set of coordinated actions required by Brazilian law to identify, assess, and control risks in the workplace) and the Risk Management Program (a set of mandatory documents required by Brazilian law that companies must adopt to identify, prevent, and control occupational risks), among other relevant points.
It is worth noting that the effective date of the new guidelines, initially set for May 2025, has been postponed by one year due to the operational difficulties faced by companies. The expanded scope, particularly with the inclusion of psychosocial risks, has presented significant challenges in terms of cost, structure, and the maturity of internal management systems.
In this context, we highlight six key areas that companies should keep on their radar:
1. Consolidating Occupational Risk Management as a Continuous Management Cycle: Risk management is no longer a static document but now requires a dynamic approach based on the PDCA cycle, with traceability, constant updates, and concrete evidence of monitoring and improvement.
2. A risk management program that is technically sound and grounded in operational reality: The risk inventory and action plan must reflect the company’s actual circumstances, with a clear identification of hazards, definition of measures, responsible parties, and deadlines. Standardized or generic templates are increasingly being called into question, both during inspections and in litigation.
3. Integration of health and safety programs: The manual emphasizes that the Risk Management Program cannot be treated in isolation; rather, it must be aligned with the Occupational Health Medical Surveillance Program, ergonomic assessments, and other tools. A lack of consistency among these documents may indicate weaknesses in the management system.
4. Effective integration of psychosocial risks: The standard requires the adoption of structured methodologies for identifying and managing these risks, including a combination of tools such as observation, internal surveys, and listening sessions. Superficial approaches tend to prove insufficient in light of the new level of requirements.
5. Data protection in psychosocial risk mapping: The collection of information related to mental health, perceptions of the work environment, and psychosocial factors often involves sensitive data. This requires specific precautions regarding the purpose, necessity, transparency, and security of the information. Internal surveys, interviews, and assessments should include anonymization whenever possible, access controls, and clear governance regarding data use, thereby avoiding the creation of new liabilities in the area of privacy.
6. Responsibilities and governance: There is an increased emphasis on both coordinated action among companies that share workspaces and the active participation of workers in the risk management process. This requires more robust governance structures, effective communication, and consistent documentation.
The entry into force of the updates to Chapter 1.5 of Regulatory Standard No. 1, scheduled for May 2026, marks a turning point. More than simply meeting a regulatory requirement, the challenge now lies in establishing management systems capable of withstanding practical scrutiny, whether during inspections or in court proceedings.
This trend had already been gaining momentum. Issues such as burnout, occupational illnesses, and allegations of emotional and sexual harassment have been increasingly addressed in labor courts, requiring companies to adopt more sophisticated preventive measures. In this context, it is not only the implementation of the measures set forth in Regulatory Standard No. 1 that gains relevance, but also the ability to consistently demonstrate the practices adopted and their effectiveness.
