Como a falta de conhecimento das leis trabalhistas e previdenciárias prejudica o lucro das empresas

Como a falta de conhecimento das leis trabalhistas e previdenciárias prejudica o lucro das empresas

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Em época de crise, cada centavo é fundamental para equilibrar as contas das empresas. No entanto, todo o esforço de vendas realizado pelas corporações, aliado à redução de custos, poderiam ser maximizados se a alta administração tivesse conhecimento de várias oportunidades de diminuir suas perdas, especialmente na área de segurança e saúde do trabalhador.

A primeira delas é pagar adicional de insalubridade ou periculosidade por mero hábito ou como forma de conceder aumento salarial. Tais adicionais somente devem ser remunerados mediante laudo técnico e nunca por ato administrativo. O art. 194 da CLT prescreve que cessado o risco, cessa o pagamento do adicional, porém adicional concedido sem avaliação técnico-legal o incorpora ao salário em dois anos.

Além do que, o pagamento do adicional de insalubridade ou periculosidade não se encerra em si, havendo uma cascata de efeitos e responsabilidades pelo seu reconhecimento, a exemplo da aposentadoria especial e o pagamento do SAT – Seguro de Acidente do Trabalho – suplementar (6, 9 ou 12% de acréscimo sobre a folha de pagamento).
Por outro lado, deixar de pagar um adicional de insalubridade ou periculosidade que é devido, pode custar caro à empresa, especialmente se a questão se transformar num processo trabalhista, no qual a empresa arcará com honorários periciais e custos do processo. Por isso, é necessária a gestão das condições insalubres e perigosas para não se criar passivos que podem se transformar num elefante branco.

Outro problema trabalhista é a elaboração do PPRA – Programa de Prevenção de Riscos Ambientais – e do PCMSO – Programa de Controle Médico em Saúde Ocupacional – os quais podem servir como confissão de culpa da empresa, caso elaborados sem observância à defesa empresarial. Tais documentos invariavelmente circulam entre vários atores sociais, ávidos em tirar proveito de quaisquer colocações que podem vulnerabilizar a empresa.
Na área previdenciária, a questão ainda é mais delicada. O FAP – Fator Acidentário de Prevenção – é um flexibilizador do RAT – Risco de Acidente do Trabalho (antigo SAT – Seguro de Acidente do Trabalho). O FAP pode ser uma penalização ou recompensa em razão do desempenho da empresa em segurança e saúde no trabalho, vez que varia de 0,5 a 2,0, fazendo com que o RAT seja reduzido em 50% ou aumentado em 100%. Muitas empresas sequer acessam o site da Previdência Social, seja para conferir o seu FAP, seja para utilizá-lo como bônus, perdendo uma oportunidade de reduzir seu RAT.

O NTEP – Nexo Técnico Epidemiológico Previdenciário – é o estabelecimento automático de nexo de causa em doenças ocupacionais. A empresa deve conhecer muito bem seu mecanismo, bem como diariamente consultar o site da Previdência Social para evitar surpresas desagradáveis, a exemplo de acidente ou doença sem relação com o trabalho, que acabam, por erro, gerando benefício acidentário (B91), quando deveria ser benefício previdenciário (B31), cujos reflexos para a empresa são: o pagamento do FGTS durante o afastamento, estabilidade do segurado no retorno do afastamento e possível ação de indenização, motivada pelos documentos declaratórios da Previdência Social. O NTEP deve ser contestado nas situações de estabelecimento do nexo causal presuntivo, com comprovação de que a doença não possui relação com o trabalho.

Outro ponto vulnerável das empresas é quanto às ações regressivas movidas pela Previdência Social, contra as empresas que supostamente forem responsáveis por acidentes ou doenças que geraram desembolso da autarquia. O ponto chave na defesa de tais ações é a comprovação de que não houve negligência quanto às normas padrão de segurança e higiene do trabalho, nos termos do art. 120 da Lei de Benefícios da Previdência Social (Lei 8.213/91).
As empresas pecam por descumprirem itens da legislação que são meras formalidades, mas que acabam por responsabilizar a empresa na ocorrência de um acidente ou doença.

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Ainda na seara da Previdência Social, uma questão que tem redundado em prejuízos para as empresas é a aposentadoria especial. Benefício criado em 1960, a aposentadoria especial afasta o segurado exposto ao agente nocivo precocemente (25, 20 ou 15 anos) do trabalho. No entanto, a empresa participa do custeio desta aposentadoria com 6, 9 ou 12% sobre a folha de pagamento (SAT suplementar).

O documento que avalia a condição de exposição do segurado é o LTCAT – Laudo Técnico das Condições Ambientais de Trabalho – que frequentemente é confundido com o PPRA – Programa de Prevenção de Riscos Ambientais, que é um documento trabalhista e cuja legislação é distinta da aplicável à elaboração do LTCAT. Como resultado, o LTCAT é elaborado de forma incorreta, deixando de considerar agentes que poderiam no futuro gerar aposentadoria especial ou, considerando agentes que não concedem a aposentadoria especial, criando expectativas nos empregados e trazendo sérios dissabores à empresa, tais como multas e arbitramento do SAT suplementar para todos os segurados da empresa.

Como consequência de um LTCAT mal elaborado, o PPP – Perfil Profissiográfico Previdenciário – não poderia ser diferente, vez que preenchido com informações do LTCAT. Dentre as armadilhas contidas no PPP podemos citar: a prova do nexo causal com relação a doenças ocupacionais, as ações de equiparação salarial em virtude da equivocada descrição de atividades, os conflitos de preenchimento do código da GFIP com a documentação existente na empresa e, finalmente o uso na Justiça Trabalhista como ratificador do pedido de insalubridade.

Para finalizar, é preciso esclarecer que as empresas devem primar por elaborar documentos que sirvam como prova favorável aos seus interesses e, não o contrário, uma vez que um documento mal elaborado pode redundar em uma série de efeitos danosos e onerosos para as companhias.

Por: Antonio Carlos Vendrame

Fonte: Portal Dedução
Data: 16 de agosto de 2017
Acesso: 18 de agosto de 2017

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