Executive TL;DR
NR-35 (Work at Height) requires planning, a control hierarchy against falls of persons, and proven competence for anyone working above 2 m from the lower level, per criteria of the standard in force. In 2025–2026, MTE Ordinance No. 1.680 of October 2, 2025 stands out, approving Annex III — Individual-Use Ladders of NR-35, with technical rules for portable, fixed, and ship-style ladders, plus an effective date and transition schedule published in the Official Gazette (DOU). Beyond ladders, the hard core of NR-35 remains: compatible anchors, certified lifelines and connectors, lanyard with energy absorber when fall analysis so requires, free fall zone, APR, and pre-use inspection of equipment. This text is technical-legal; always cite the official wording on gov.br in internal audits.
Table of contents
- Systemic reading: NR-35 is not a "rappelling course"
- Ordinance 1.680/2025 and the Ladder Annex III
- Transition, legacy ladders, and critical reading of the annex
- PPC, connectors, and the manufacturer's role
- APR, work permit, and teamwork
- Rescue and emergency: what auditors require
- Implications for industry, maintenance, and energy
- Evidence chain: proof, incidents, and eSocial
- FAQ
- References
Systemic reading: NR-35 is not a "rappelling course"
Work at height combines fall physics, PPC fatigue, roof communication, and, often, production pressure on deadlines. A mature SESMT treats NR-35 as a system: from the service request to closure with reinstallation of protections and records. A common mistake in industrial plants is treating training as a substitute for engineering: an "authorized" worker does not fix improvised anchorage or an anchor with inadequate reserve capacity.
The hierarchy follows the logic of eliminating the fall (scaffold with guardrail, elevated platform), controlling in place (lifelines, certified guardrails), and only then restricting fall energy with individual PPC, including a lanyard with energy absorber when trajectory calculation (including "penetration" and lower obstacle) so determines. Document who sized it, which design standard was used, and when the system was reinspected.
Ordinance 1.680/2025 and the Ladder Annex III
MTE Ordinance No. 1.680 of October 2, 2025 approved Annex III of NR-35, dedicated to individual-use ladders, with tables of angles, dimensions, and use restrictions by ladder type. The ordinance provides for effectiveness in 90 days from DOU publication (consult the official edition for the exact start date and any transitional provisions for equipment already installed). It also contains items with differentiated effective dates (for example, markings on portable ladders may operate with an extended deadline — check sub-items in full).
In adaptation projects, engineering must separate: new ladders (already sized per the annex) and legacy assets, often subject to a transition rule when the standard expressly does not require retrofit of existing installations under certain conditions. Do not copy a competitor's spreadsheet: extract the official ordinance PDF and trace a compliance matrix by plant.
Effective date is usually counted 90 days from publication in the Official Gazette of the Union (do not confuse the ordinance date with the publication date). Summaries in specialized press pointed to DOU publication on October 3, 2025 and effectiveness starting January 1, 2026 — useful as an operational shortcut, but legal defense and SESMT should attach the DOU page or official extract with the wording that sets the timeline. When there is a correction or errata, update the single norm dossier on the intranet.
Transition, legacy ladders, and critical reading of the annex
The Ordinance 1.680/2025 package is not reduced to a "ladder data sheet." The Annex III structure itself mixes geometric requirements (steps, landings, angles of leaning and self-supporting portable ladders), use rules (when a ladder replaces a platform), and correlated updates in the NR-35 body appearing in the same ordinance — for example, reinforcement on lanyard with energy absorber in sections where fall analysis requires absorption and FFZ (free fall zone) control, with terms the standard began defining more rigorously in the glossary.
For installed assets, a transition device often does not retroactively apply to certain vertical fixed ladders already mounted or under installation at the effective date (exact sub-items vary per published wording). Other sections — such as markings and contrast on portable ladders — may have a differentiated deadline (legal analyses mention effectiveness within one year for specific items). The central point: SESMT does not "guess" the calendar. Build a legal matrix with columns sub-item, requires retroactive adaptation?, deadline, evidence on the ground (date-stamped photo, ladder purchase note with batch, installation ART, inspection report from an accredited company when applicable).
In substations, towers, and mezzanines where the vertical fixed ladder is the only access, a misinterpreted transition becomes a termination letter for an external building maintenance contract: no inspection record or no record that the manufacturer still supports load and fastening after civil changes. Keep the detail drawing of beam fastening and a photo of anchoring bolts with declared torque when engineering requires it.
PPC, connectors, and the manufacturer's role
A general-purpose connector is not interchangeable with a connector for an absorber or positioning; mixing brands and latch generations has a history of unintended opening under load or marginal contact. Enterprise policy usually includes an approved PPC list, procurement control of parallel purchases ("site buying"), and color-coded inspection by manufacture date.
NR-6 remains a mandatory partner: helmet with chin strap (when applicable to fall risk), footwear suited to the deck, gloves compatible with cable and climate. Keep the manual in Portuguese, certificate, and inspection record.
Free fall zone, absorber length, and impact geometry
In anchorage design, lanyard with absorber behavior changes fall trajectory and minimum distance below the user (FFZ — free fall zone). Engineering must consider absorber extension during arrest, rope sag, and lateral swing possibility. Enforcement often flags anchorage on a plane below the worker's level without geometric compensation or incompatible length of fall arrest device for the fall factor height predicted in the manufacturer's manual.
On roofs with metal eaves, live edge, and equipment fixed to light structure, the "PPC only" solution without collective barrier requires demonstrating that there is no free fall point beyond the absorber design. Record a simple drawing or 3D model capture from civil works when that is part of the safety package.
APR, work permit, and teamwork
APR must reflect the real scenario: temporary lifeline, crane obstruction, heat on the roof, night work, electrical isolation adjacent to NR-10 lines. The work permit integrates lockouts with maintenance. During plant shutdowns, "rush to return to operation" is a risk factor — treat it as a variable in the pre-task meeting.
Rescue and emergency: what auditors require
A rescue plan is not generic paperwork: it needs tested mechanical means, maximum tolerable suspension time, and trained personnel outside the immediate team (to avoid duplicating exposure to the same event). Train scenarios of worker entrapment on the line and communication with ground support.
In extreme heat or roofs with metal trusses, include thermal stress and dehydration in rescue risk assessment — the rescuer may require a second rope or a rotation policy. Document dated simulations and nonconformities opened when rescue equipment was out of inspection.
Integration with the PGR and ISO 45001 management review
Companies certified to ISO 45001 usually tie height incidents to systemic corrective action, not just the "inattentive employee." Use the PGR to record structural cause: missing barrier, APR approved without signature of the area's legal responsible person, or PPC purchase outside the approved list. This aligns NR-35 with the Plan-Do-Check-Act cycle and prevents certification audits from finding gaps that enforcement would already see.
Implications for industry, maintenance, and energy
In continuous industry, the maintenance shift is the most exposed segment; use indicators of open APR, average closure time, and height near misses. In energy, interface with NR-10 is critical: lockout order, commissioning, and re-energization only after recommissioning protections.
Table: typical traps in large-scale maintenance
| Scene | Mistake | Mature control |
|---|---|---|
| Boiler shutdown | removing grating without a reinstallation plan | work order with closure step and photo |
| Fan rotation change | rope positioned without redesign | reanalysis of anchorage and fall factor |
| Warehouse painting | scaffold without bracing | scaffold design per NR-18 / good practice |
Training and "role matrix"
Serious companies separate authorized height worker, immediate height supervisor, and internal rescue/fire brigade member. Program content must appear in digital work card / internal record per union policy and agreements. Avoid a "single two-day training" mixing all profiles without practical assessment: simulation on a low structure with conduct evaluation corrects behavior before the real edge.
ACSMT supports anchor mapping, review of maintainer procedures, and integration with the PGR. Contact us at /contato.
Evidence chain: proof, incidents, and eSocial
Internal NR-35 audit fails when files are "loose folders" on SharePoint. A minimum defensible package includes: APR with version, date, and signatures of executors and whoever approves the work; lockout order or proof of de-energization when there is an electrical interface; anchorage system certificate or pull test report when company policy or the manufacturer requires periodicity; daily PPC inspection checklist with photographable serial number; training with content by role, hours, and instructor name; and rescue simulation record.
When there is a fall even with partial control — worker hangs on the line without hitting the ground with intense impact — discussions of "typical accident" arise. Technical classification and duty to notify follow legal definition and the eSocial manual; involve Occupational Medicine early. Event S-2210 for work accident is sensitive: inconsistency between what the digital work card and report describe and what fire department video shows creates technical and reputational liability.
Practical recommendation: do not narrate alone after the fact: preserve GPS and time in anchor photos, chain of custody of own bodycam video, and structured interview of the worker the same day, without leading questions. In groups with global insurance, aligning report language with the broker reduces friction in claims.
Finally, leadership indicators should separate height near miss (protection absent for minutes) from chronic condition (improvised lifeline for weeks). The second tends toward negligent homicide in serious legal analysis; the first is still a serious failure, but with a faster correction path if there was safe stop and documented reversal.
FAQ
What is the height limit under NR-35?
Per the legal definition of work at height in NR-35 itself (consult consolidated text): activities performed above 2 m from the lower level, with fall risk. Always check current wording on gov.br.
Does a lanyard replace training?
No. PPC is the last line of the hierarchy; training without source risk control is insufficient.
Who can inspect PPC?
Define the role in procedure: normally the worker before each use + documented periodic technical inspection.
Does Ordinance 1.680/2025 affect only ladders?
It specifically addresses Annex III on ladders; other NR-35 changes may exist in separate ordinances. Consult the official consolidated package.
How to prove compliance during enforcement?
Trail: APR, signatures, anchor certificates, PPC inspection, training attendance list with content compatible with the role.
Can I use a foreign NR in Brazil?
International standards may inform good practice in design, but legal obligation is Brazilian.
References
- Brazil. Ministry of Labor and Employment. MTE Ordinance No. 1.680 of October 2, 2025 — approves Annex III (Individual-Use Ladders) and amends sections of NR-35. Official PDF (download) on the MTE portal, OHS / Ordinances / 2025 section: https://www.gov.br/trabalho-e-emprego/ — check DOU publication, 90-day deadline for effectiveness, and transitional provisions in full.
- Brazil. NR-35 — Work at Height (consolidated on
gov.br, with amendment history). - Brazil. NR-6 — Personal Protective Equipment.
- Brazil. NR-10 — interaction with work orders and de-energization in industrial maintenance near height.
- ABNT. NBR family for ropes, chains, and accessories cited by PPC manufacturers for work at height and rescue (always validate current edition against the purchased equipment manual).
- ISO 16368 — Mobile elevating work platforms (MEWP); engineering reference when access means is equipment covered by the standard.
- EU-OSHA. Comparative resources on falls and work at height in the European Union. https://osha.europa.eu
- Official Gazette of the Union — confirmation of publication date of Ordinance 1.680/2025 for exact 90-day count and any correction.
Editorial note: wording on effective dates, deferred items, and exceptions for already installed equipment was checked against legal and specialized summaries and must be cross-checked with the ordinance PDF and DOU before use in administrative defense.
