A. Review Issues and Questions

1.	Publication date.	Not known.
2.	Status: final, draft, other.	Final.
3.	Pending revisions.	Not known.
4.	Publishing Organization type.	Government.
5.	Type of OHSMS.	National regulation.
6.	Is it used by regulatory agencies to achieve agency mandate?	Yes.
7.	Is it meant to be an auditable standard?	Yes.
8.	Is it used as an auditable standard?	Yes. Contains a mix of shall and should statements.
9.	Is it a management system?	No. See checklist in section D. Missing key system variables.
10.	Are there technical appendices?	No.
11.	Is there a companion audit guidance document?	Not known.
12.	Are there stated limitations of use?	No.

B. Review Comments

As stated in the document:

"This Brazilian regulation (NR-9) establishes the obligatoriness of elaboration and implementation of an Environmental Risks Prevention Program (PPRA) by employers and institutions who have workers under their responsibilities, and which are to preserve workers health and integrity, considering the anticipation, recognition, evaluation and consequent environmental risks that exist or which could occurs in the work place, considering the environmental and natural resources protection."

Management system variables not included in NR-9 follow.

- management commitment and resources

- policy

- performance measures

- manual and procedures

- training system

- emergency response

- preventive and corrective actions

- procurement and contractor selection

- communication system

- document and record management system

- auditing and self-inspection

- incident investigation and root cause analysis

- medical program and surveillance

- continual improvement

- integration

- management review

Based on the criteria used, this regulation is a program, not a system. It is a regulation that contains aspects of a system, but there are major parts missing.

C. Outline

(Note: Numbering sequence presented here is as found in the copy analyzed.)

D. Analysis Checklist

	Management System Variable		Notes
1.0	Management Commitment and Resources
1.1	Reg. Compliance and OHSMS Conformance
1.2	Accountability, Responsibility, and Authority
2.0	Employee Participation	x
3.0	Occupational Health & Safety Policy
4.0	Goals and Objectives	x
5.0	Performance Measures
6.0	System Planning and Development	x
6.1	Baseline Eval. and Hazard/Risk Assessment	x
7.0	OHSMS Manual and Procedures
8.0	Training System
8.1	Technical Expertise and Personnel Qualifications	x
9.0	Hazard Control System	x
9.1	Process Design
9.2	Emergency Response
9.3	Hazardous Agent Management
10.0	Preventive and Corrective Action
11.0	Procurement and Contractor Selection
12.0	Communication System
12.1	Document and Record Management System
13.0	Evaluation System	x
13.1	Auditing and Self-Inspection
13.2	Incident Investigation and Root Cause Analysis
13.3	Medical Program and Surveillance
14.0	Continual Improvement
15.0	Integration
16.0	Management Review

IOHA Report to ILO on an International OHSMS - Appendix C [Title page]     [Table of Contents]     Chapters: I II III     Appendices: A B C D E F G

Updated by AS. Approved by EC. Last update: 30.11.2004.