Scope of NR-37
The regulation covers national and foreign platforms and certain authorised maintenance and safety units in Brazilian jurisdictional waters. It defines included installations and vessels outside its specific scope. An offshore activity must not be classified solely because it takes place at sea. The type of unit, its operation and applicable provisions must be identified.
Installation and process risks
NR-37 links the PGR to installation and process risk analysis. It also addresses responsibilities, participation in prevention and health care. On a platform, a technical failure may affect several operations and onboard living conditions simultaneously. Management must connect engineering, operations and maintenance information with preventive decisions.
Changes and activity stages
The text covers commissioning, modifications, repairs, decommissioning and dismantling. Each phase can change energy sources, available barriers and work organisation. Applying a procedure prepared for normal production to a shutdown involving multiple contractors is insufficient. The review must establish which systems remain operational and which temporary conditions require additional controls.
Working and living conditions
The regulation addresses access, accommodation, food, climate control, equipment and operations, alongside protection against fire, gases and other situations. Rest conditions and health care are part of the work environment. A training record does not replace suitable resources or demonstrate that a person can carry out the planned response with the resources actually available on board.
Change-management example
During a hypothetical repair, a protective barrier is temporarily taken out of service. Before continuing, those responsible must analyse which scenarios are affected, which operations remain compatible and which interim measures are needed. They must also define how the change is communicated and when the barrier is restored. The example authorises no bypass: it illustrates why the change requires a specific technical assessment.
Emergencies and verification
Plans and exercises must relate to the installation’s scenarios and resources. Recording observed deficiencies and verifying their closure is useful. Management of change in OSH provides the general framework, while NR-37 contributes Brazilian sector requirements. Certificates from other fields do not, by themselves, establish every labour obligation. The review must use the official text and consider interaction with applicable maritime and technical provisions.
