NR-1: documents for psychosocial risks in the PGR

Since May 26, 2026, the new wording of chapter 1.5 of NR-1 has been in force and expressly includes work-related psychosocial risk factors in Occupational Risk Management. For the company, this does not create an obligation to produce an isolated “psychosocial report”. What needs to exist is a coherent process of identification, assessment, prevention, monitoring and review, supported by documents and observable practice.

The questionnaire administered to workers, the mental health talk or the well-being action may be part of the process, but they do not alone prove risk management. Inspection can compare inventory, Preliminary Ergonomic Assessment, action plan, methodological criteria, participation records and evidence of implementation with real working conditions.

On August 6, 2026, the initial 90-day period in which the Labor Inspectorate tends to prioritize guidance, instruction and notification regarding new provisions was still ongoing. This period does not suspend the rule or waive compliance.

What the company needs to be able to demonstrate

NR-1 determines that the PGR contains, at a minimum, the risk inventory and the action plan. The integrating documents must be prepared under the responsibility of the organization, dated, signed and kept available to interested workers, unions representing professional categories and the Labor Inspectorate.

There is also a technical document necessary to detail the criteria used in severity and probability gradations, the levels and classification of risks and the decision-making rules. The official MTE questions and answers treat the inventory, the action plan and this record of criteria as mandatory documents.

There is, however, no single national form, a mandatory spreadsheet or an exclusive official methodology for psychosocial factors. The organization can select tools compatible with its reality, as long as it demonstrates technical foundations, methodological coherence and the ability to transform results into evaluation and prevention measures.

The audit question, therefore, should not just be “do we have the document?”. It needs to move forward to: does the document correspond to the actual work, guided decisions and has evidence of execution?

Management of working conditions is not a clinical diagnosis

The psychosocial risk factors addressed in the GRO are characteristics, requirements or problems related to the design, organization and management of work. The assessment must observe which conditions of the activity can act as stressors and produce injuries or injuries. It is not intended to measure individual symptoms, biological signs or establish mental health diagnoses.

Periodic medical evaluation also does not replace hazard identification and NR-1 risk assessment. The management process must examine causes and factors existing in the environment and work organization, while individual clinical assessment remains in its own professional flow.

In the inventory, the company must record, for example, the source or circumstance of the danger, the activities affected, the groups of exposed workers, the possible consequences, the existing measures and the risk classification. As governance guidance, nominal diagnoses, medical records, identifiable clinical reports, and individual medical results should not be used as the core of the RMP.

This separation avoids two mistakes: transforming an organizational prevention obligation into tracking workers' private lives and trying to solve work organization problems only through individual interventions.

Requirement–evidence–responsible–frequency matrix

The matrix below is an operational summary, not an official MTE model. It separates the documentary core provided for in the standard from the complementary evidence that helps to prove the continuity and coherence of the process. The frequency must be adjusted to the nature and classification of risks when NR-1 does not establish a specific interval.

Management requirement	Evidence to keep	Suggested operational manager	Frequency or trigger
Definition of scope and responsibilities	Registration of the establishment, unit, sector or activity covered; designated responsible persons; approvals and resources	Senior management and SST/SESMT	During implementation and when there is a change in structure or responsibility
Evaluation and decision criteria	Document with severity and probability scales, risk levels, classification and criteria for deciding measures	Technical manager or OSH team	Before the assessment and whenever the methodology or criteria are changed
Hazard identification and ergonomic assessment	AEP documented or integrated into the PGR; method used; actual activities observed; sources, circumstances and exposed groups	SST/SESMT, with the participation of workers and areas	For existing activities, new activities and relevant changes
Worker participation	Consultations, listening sessions, workshops, minutes, CIPA records, communications, feedback and training	SST, HR and CIPA or worker representation	During identification, assessment, implementation, monitoring and review
Risk inventory	Processes, environments, activities, hazards, sources, possible injuries, exposed groups, existing measures, exposure, ergonomic results and classification	SST/SESMT, with validation from those responsible for the processes	Continuous update and review triggers
Action plan	Prevention measures, priorities, responsible parties, deadlines, method of monitoring and measuring results	Process managers, with OSH coordination	According to the schedule and when a risk requires new measures
Implementation of measures	Orders, process changes, load or organization adjustments, training, communications and completion records	Responsible for the area or process	With each implementation and adjustment made
Monitoring effectiveness	Verification of actions, inspections, indicators, listening, assessment of residual risks and corrections	SST and those responsible for the processes	At planned intervals and after implementing measures
Communication to workers	Evidence of communication of consolidated risks and planned measures	SST, HR and leadership	After consolidation or relevant update of inventory and plan
Review and history	Inventory versions, change records, justifications, approvals and review results	SST and document management	As a rule, every two years or when a trigger foreseen in NR-1 occurs

The inventory must remain up to date, and the history of its updates must be kept for at least 20 years, unless a different period is defined in a specific standard. PGR documents must also be dated and signed.

For other complementary records, the analyzed sections of NR-1 do not establish a single general retention period. The documentary policy must be defined with SST and legal, considering the type of evidence, other applicable standards and the need to demonstrate the evolution of the process.

How to structure the inventory without medicalizing workers

The inventory should not include only generic expressions such as “stress”, “anxiety” or “mental health”. These words may describe possible effects, but they do not identify the source of the danger or indicate what the organization needs to change.

Useful recording begins with the concrete working condition. Overload and harassment situations appear among the examples presented by the MTE, but the official lists are guidelines, not exhaustive. The company needs to evaluate the reality of its activities, and not just mark items in a catalogue.

A more technically consistent record should connect:

the activity and work actually carried out;
the source or circumstance related to the organization of work;
the exposed group, without depending on the nominal identification of people;
possible injuries or injuries;
existing prevention measures;
the criteria used to assess probability, severity and level of risk;
the necessary additional measure, when applicable.

NR-1 requires that the evaluation of ergonomic factors, including psychosocial factors related to work, consider the demands of the activity and the effectiveness of the prevention measures implemented.

Participation needs to leave evidence, not just signatures

The organization must create mechanisms for worker participation, consult them on their perception of risks and communicate the risks consolidated in the inventory and the measures provided for in the action plan. Participation also includes monitoring prevention measures.

The MTE informs that this participation can be demonstrated by records of consultations and listening, meetings, involvement in monitoring actions, communications, training and CIPA demonstrations, if any. There is no standardized document; The main point is to prove effective and continuous participation, and not to accumulate isolated minutes.

Quizzes are optional. When used, they need to be appropriate to the context, technically substantiated and integrated into the AEP or inventory. The completed form alone does not prove management. The MTE guide also recommends preserving anonymity when a survey is applied to groups or sectors.

For small groups, where anonymity may be compromised, the company can prioritize activity observation, work analysis and structured dialogue, rather than relying exclusively on quantitative research.

The action plan must prove execution and results

The action plan needs to translate the inventory into decisions. For each prevention measure, the organization must define a schedule, those responsible, ways of monitoring and measuring results. The implementation and adjustments made must also be recorded.

Evidence is not limited to a line marked “completed”. Depending on the measure, documents may be necessary that demonstrate process changes, redefinition of priorities, review of goals, adjustment of teams, updating of procedures, leadership guidance or other changes in work conditions and organization.

General well-being actions can be complementary, but do not replace measures related to the sources of identified risk. An initiative disconnected from inventory does not, by itself, demonstrate that the company has eliminated, reduced, or controlled the hazard.

Monitoring must verify the execution, continuity and effectiveness of the action. When data shows insufficient performance, the measure needs to be corrected. After implementation, the assessment must be reviewed to verify the residual risk, updating the inventory.

When to review the assessment

As a rule, the risk assessment must be reviewed every two years. NR-1 also provides for early review:

after implementing measures to assess residual risks;
when changes in technologies, environments, processes, procedures or work organization create or modify risks;
when measures are inadequate, insufficient or ineffective;
after work-related accidents or illnesses;
when there is a change in legal requirements;
after justified request from workers or CIPA, if applicable.

These triggers show why the PGR cannot be treated as a file produced once a year and saved until the next hire. It is a continuous process, and documents need to follow the organization's real decisions and changes.

RACI matrix for OSH, HR and legal

The RACI below is a governance proposal, not a mandatory legal distribution. Legal responsibility for the PGR remains with the organization, which must appoint people or teams with technical knowledge compatible with the nature and complexity of the risks. NR-1 and NR-17 do not generally establish an exclusive profession to conduct the entire process.

R executes; A is responsible for the decision and appeals; C is consulted; I must be informed.

Activity	A — responds	R — execute	C — consulted	I — informed
Approve scope, governance and resources	Senior management	OSH Coordination	HR, legal and managers	CIPA and workers
Define method and technical criteria	Organization representative	SST/SESMT or technically qualified team	HR, CIPA, managers and specialists required	Senior management
Perform AEP, observations and listening	OSH Coordination	SST and qualified facilitators	HR, CIPA and leadership	Participating workers
Consolidate and approve inventory	Organization representative	SST/SESMT	Managers, HR, occupational health and legal	CIPA and interested workers
Define the action plan	Manager responsible for the process	Action managers, with OSH coordination	HR, CIPA and legal	Affected workers
Implement the measures	Area manager	Responsible persons indicated in the plan	SST and RH	Senior management, CIPA and workers
Monitoring effectiveness and residual risks	Organization representative	SST and process managers	CIPA, HR and occupational health	Senior management and workers
Control versions and evidence	OSH Coordination	SST and document management	Legal	Responsible for processes

Legal should help review responsibilities, retention, contracts, confidentiality, and interfaces with other obligations. This does not make the legal department technically responsible for the assessment. Likewise, HR can facilitate communication and organizational change, but should not replace technical OSH analysis.

Operational sequence to locate gaps

Define the scope. Confirm which establishments, units, sectors, in-person, remote or hybrid activities will be evaluated and who is responsible for each stage.
Gather what already exists. Locate inventory, action plan, AEP, evaluation criteria, CIPA minutes, research, communication records, indicators and evidence of previous actions.
Check the quality of the identification. Confirm that the records describe work conditions, sources and circumstances, exposed groups and actual activities, without relying on individual diagnoses.
Test traceability. For each identified risk, look for the classification, the decision taken, the corresponding measure, the person responsible, the deadline and evidence of execution.
Check participation. Check whether workers and CIPA were involved in the relevant steps and whether they received feedback on risks and measures.
Evaluate effectiveness. Look for records that demonstrate follow-up, results, corrections, and assessment of residual risk.
Update and approve. Fix gaps, control versions, date and sign documents, and record upcoming review triggers.

Gaps that leave management invisible

The company must carefully review situations such as:

climate survey or archived questionnaire without technical analysis and integration into the PGR;
inventory that only records “stress” without indicating the generating work condition;
generic action plan, without connection to the classified risks;
actions completed without evidence of implementation or measurement of results;
isolated minutes used as the only proof of participation;
lack of documented criteria to classify risks;
individual diagnoses, symptoms or medical information mixed into the inventory;
replaced versions without change history;
well-being actions presented as substitutes for necessary changes in work organization.

Inspection tends to examine the coherence between assessment, measures adopted, effective implementation and monitoring. The formal existence of a folder does not compensate for a process that is incapable of explaining how the company recognized, assessed and controlled the risks encountered.

Without evidence, an action can exist and remain invisible to governance. Use the matrix with SST, HR, leadership and legal, assign those responsible and transform each gap into an action with a deadline, proof of execution and review criteria.