What Changes with the New NR-01? GRO, PGR and Psychosocial Risk

The universe of Occupational Health and Safety (OHS) in Brazil has undergone a significant transformation in recent years. The new NR-01 is not just an update; it represents a paradigm shift, moving from management based on static documents to a process of continuous improvement.

The most profound changes were the introduction of the GRO (Occupational Risk Management) and the PGR (Risk Management Program). And now, a recent 2024 update has made this standard even more comprehensive by formally including psychosocial risk factors in management.

This article explains in detail what the New NR-01 is and what this new requirement regarding mental health means for your company.

What is NR-01 and why is it the "Mother Standard" of OHS?

Regulatory Standard No. 01 is considered the "mother standard" of OHS legislation. It establishes the general provisions and scope of application of all other Regulatory Standards. In its most recent version, its primary role is to define the guidelines for Occupational Risk Management (GRO), creating a framework that unifies the management of all risks present in the work environment.

The recent update: inclusion of Psychosocial Factors

Even though the PGR already contemplated ergonomic risks (which, in theory, included psychosocial ones), MTE Ordinance No. 1,419/2024 made this obligation explicit and unquestionable.

The ordinance amended chapter 1.5 of NR-01, determining that Occupational Risk Management (GRO) must explicitly include the identification and assessment of psychosocial risk factors related to work. This means that they must, obligatorily, be included in the PGR's Risk Inventory.

What are Psychosocial Risk Factors in NR-01?

For the purposes of application in the GRO, the Ministry of Labor and Employment (MTE) defines psychosocial risks as "hazards arising from issues in the design, organization, and management of work, which can generate effects on the worker's health at a psychological, physical, and social level...".

To guide companies, the MTE itself provided a guide with an illustrative list of factors that must be considered. Some of them include:

Harassment of any nature at work
Poor management of organizational changes
Low clarity of role/function
Low rewards and recognition
Lack of support/assistance at work
Low control over work/Lack of autonomy
Excessive demands (overload) or low demand (underload)
Poor relationships in the workplace

The impact of Mental Health in numbers

This change did not happen by chance. Market data on occupational health is alarming:

The International Labour Organization (ILO) and the World Health Organization (WHO) published data in 2022 showing that 12 billion working days are lost annually due to depression and anxiety, costing the global economy nearly $1 trillion.

In Brazil, occupational accident data from 2022 shows that "Other anxiety disorders" (ICD F41) are already the 3rd leading cause of illness. Summing all mental disorders, they rank 2nd in occupational illnesses (8.35%).

How to manage these risks in practice?

To manage psychosocial risk factors, it is necessary to use the provisions of NR-01 in combination with NR-17 (Ergonomics). The management of ergonomics, including psychosocial risks, must be carried out using two methods:

Preliminary Ergonomic Assessment (AEP): This is the initial approach, aligned with the GRO, to identify hazards and assess risks. The AEP is mandatory for all companies, including those that may be exempt from drafting the PGR (such as ME and EPP with risk level 1 and 2).
Ergonomic Analysis of Work (AET): This is a more in-depth analysis, used in more complex situations or when the AEP is not sufficient.

4 Preliminary steps to start the assessment

The MTE recommends that organizations follow key preliminary steps to begin this process:

Specialized help: Assess whether the organization possesses internal technical knowledge or if it will need to seek help from external professionals.
Involvement of key stakeholders in the company: The process must include senior management, managers, SESMT (if applicable), CIPA, and, fundamentally, the workers.
\3. Definition of responsibilities: Clearly define who will be responsible for conducting each stage of the process.
Communication to workers: Be transparent about the objectives of the assessment (e.g., application of questionnaires) to promote adherence and trust in the process.

It is crucial not to confuse the process of hazard identification of the GRO/PGR with the mental health assessment carried out in the context of the clinical examination for fitness for work (PCMSO/NR-07).

The goal of the GRO is not to assess the mental health of each individual worker, but rather to verify the conditions under which work activities are performed, identifying health-harming factors to implement prevention measures.

The deadline for adaptation: What to do until May 2026?

The new wording of NR-01, including psychosocial risks, is scheduled to take effect as of May 26, 2025. During this period, there will be no application of specific fines for the new requirements.

However, this window is not for inertia, but rather for diagnosis, planning, and preparation. Studies (such as Deloitte, 2022) already indicate that every dollar invested in mental health returns, on average, $4 in productivity.

With the inclusion of psychosocial risks, the documentation of GRO/PGR and AEP becomes even more complex and vital. Managing this volume of data, action plans, and evidence in a traceable manner is a challenge.