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Ofício questiona deliberação do CREA/PR sobre quem pode elaborar o PGR

Por Paula Barcellos/Jornalista da Revista Proteção

Sindicatos de Técnicos de Segurança do Trabalho de várias partes do Brasil, além da Anatest (Associação Nacional dos Técnicos de Segurança do Trabalho), protocolaram na SIT (Secretaria de Inspeção do Trabalho), do MTE (Ministério do Trabalho e Emprego), um ofício conjunto que solicita um posicionamento diante da Deliberação 04/2023 do CREA/PR (Conselho Regional de Engenharia e Agronomia do Paraná) de que somente o engenheiro de Segurança do Trabalho pode se responsabilizar pelo PGR (Programa de Gerenciamento de Riscos), independente do tipo de estabelecimento/empreendimento.
O presidente do Sintesp (Sindicato dos Técnicos de Segurança do Trabalho do Estado de São Paulo), Valdizar Albuquerque da Silva, cita que a garantia de realização do PGR pelos técnicos de Segurança do Trabalho está na NR 4. Ele explica que o item 4.3.2 estabelece que o SESMT deve ser composto por médico do trabalho, engenheiro de segurança do trabalho, técnico de segurança do trabalho, enfermeiro do trabalho e auxiliar/técnico em enfermagem do trabalho, obedecido o Anexo II. Já o item 4.3.1 determina as competências do SESMT. “Como se pode ver o SESMT não é somente o engenheiro”, reclama.
Para Albuquerque, a deliberação do CREA/PR atenta ainda contra o artigo 5° da Constituição Federal que cita o livre exercício profissional quando atendidas as qualificações que a lei estabelecer. “No caso do TST estamos falando da Lei 7410/85, sobre a especialização de Engenheiros e Arquitetos em Engenharia de Segurança do Trabalho e a profissão Técnico de Segurança do Trabalho, e da Portaria 671/2021, que regulamenta disposições relativas à legislação trabalhista, à inspeção do trabalho, às políticas públicas e às relações de trabalho, no Artigo 130, itens III, IV, V, XII”, destaca.
O ofício ressalta ainda que conforme a Lei 7410, os técnicos de Segurança do Trabalho devem regularizar o seu registro perante o Ministério do Trabalho e Emprego, inclusive com credencial emitida pelo órgão, não tendo, portanto, nenhuma relação com o sistema Confea/CREA.

EFEITOS
O presidente do Sintesp alerta que a deliberação impacta em mais de 350 ramos de atividade econômica por todo o Brasil. “Nossa atuação abrange todas as categorias econômicas, assegurando práticas de segurança normatizadas pelo Ministério do Trabalho e Emprego. Além disso, a deliberação gera impactos diretos na empregabilidade de nossos colegas TST”, avalia.
O documento alerta que não é de hoje que ocorre um pobre diálogo sobre quem pode ou não realizar programas de SST, haja vista o antigo PPRA (Programa de Prevenção de Riscos Ambientais). “Pedimos que seja realizado posicionamento, até porque a presente entidade do Estado do Paraná com sua deliberação passa a mensagem para a sociedade que é de direito fiscalizar, legislar, referente à SST no Brasil e nosso entendimento contraria o exposto, sendo assim precisamos de resposta para dirimir todas as dúvidas que foram criadas”, solicita o documento.

CREA/PR
Verginio Luiz Stangherlin, engenheiro de Segurança do Trabalho, conselheiro titular no CREA/PR e representante nacional da Modalidade de Engenharia de Segurança do Trabalho no Confea, diz que a deliberação se deu no intuito de orientar, por exemplo, as ações de fiscalização nas indústrias e hospitais. “Nestes locais são identificadas elaborações do PGR por profissionais que, eventualmente, não possuem a formação acadêmica necessária e suficiente para a elaboração de tão importante programa, fato este oportunizado pelo generalismo trazido pelas Normas Regulamentadoras 1 e 9, que não têm a função de especificar qual o profissional que poderia elaborar este programa, uma vez que já encontra-se definido pela Portaria 671 e Resolução 359/91 (sobre o exercício profissional, o registro e as atividades do engenheiro de Segurança do Trabalho), com base na Lei 7410”.
Segundo Stangherlin, a deliberação amparou-se em uma série de normativas legais, tendo sido também objeto de análise jurídica anteriormente à sua publicação. Dentre elas, consideram-se: a Lei Federal 5.524/1968 (dispõe sobre o exercício da profissão de Técnico Industrial de nível médio), o Decreto 90.922/1985 (dispõe sobre o exercício da profissão de técnico industrial e técnico agrícola de nível médio ou de 2º grau), a Resolução 1.073/2016 do Confea (regulamenta a atribuição de títulos, atividades, competências e campos de atuação aos profissionais registrados no Sistema Confea/Crea), e, por fim, a própria Portaria 671, em sua seção II, Artigo 130, itens IV, V, VII e outros que definem ao profissional de ensino médio a execução de programas e não sua elaboração conforme prevista para profissional habilitado em Engenharia de Segurança do Trabalho pela Resolução 359.
O conselheiro concorda que o registro dos técnicos de Segurança do Trabalho no Sistema Confea/CREA, conforme definições legais, é facultativo. “Porém, ao fazê-lo, o profissional devidamente registrado, estará submetido, tal qual os demais profissionais registrados, às regras e ao poder de polícia administrativa das profissões, condições inerentes à existência e ao funcionamento deste sistema profissional”, alerta.
Ele sugere que nas situações que venha a ser indagado, o Ministério do Trabalho emita “uma nota técnica para equacionar as polêmicas que eventualmente se apresentam relacionadas ao tema ora abordado”.

CONFLITUOSA
Para Rodrigo Vieira Vaz, auditor fiscal do trabalho que coordena o treinamento da Auditoria de Fiscalização do Ministério do Trabalho e Previdência nas questões da nova NR 1, essa posição do CREA/PR é infundada e a resposta para isso está na própria NR 1. “Essa posição do CREA/PR nesse parecer é totalmente conflituosa com a Norma Regulamentadora 1 – Disposições Gerais e Gerenciamento de Risco Ocupacional. O item 1.5.7 estabelece a documentação do GRO, e determina em seu subitem que: ‘1.5.7.2 Os documentos integrantes do PGR devem ser elaborados sob a responsabilidade da organização, respeitado o disposto nas demais Normas Regulamentadoras, datados e assinados.’ Portanto, não há na NR 1 qualquer obrigatoriedade da documentação do item 1.5 GRO da NR 1 ser elaborada por um profissional especializado ou específico. A escolha é da organização”, finaliza.
Todas as decisões do CREA-PR são públicas e podem ser consultadas no site do conselho. Já o posicionamento dos sindicatos dos técnicos de segurança pode ser consultado no ofício conjunto que encontra-se aqui.

Fonte: protecao.com.br

FABIO LIMA DOS SANTOS

TECNÓLOGO EM GESTÃO DE RECURSOS HUMANOS
REGISTRO Nº CRA-PA Nº 60.1433

PÓS-GRADUADO EM SAÚDE E SEGURANÇA DO TRABALHO
TÉCNICO DE SEGURANÇA DO TRABALHO
REGISTRO Nº CREA-PA Nº 15.1487756-2

DIRETOR PROPRIENTARIO DF PROTEÇÃO ASSESSORIA E CONSULTORIO EM SEGURANÇA DO TRABALHO
DIRETOR COMERCIAL DF CLÍNICA
E-MAIL: FABIO15PL@BOL.COM.BR
ATUAÇÃO EM CONSULTORIA EM SEGURANÇA DO TRABALHO, MEDICINA DO TRABALHO, AVALIAÇÃO AMBIENTAIS, TREINAMENTOS DE SSO, ELABORAÇÃO DE DOCUMENTOS DE SSO.

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