Mexico NOM-019-STPS-2011 Explained (Employer Guide)

Why “NOM-019” Causes Confusion

In Mexico, the same NOM number can exist under different government authorities. Each authority issues its own standards, and the topic, obligations, and enforcement rules can be completely different.

• NOM-019-STPS-2011: This standard is issued by the labor authority and focuses on workplace safety. It regulates the creation, operation, and responsibilities of Safety and Hygiene Commissions inside Mexican workplaces. It applies to employers with employees in Mexico and is enforced during labor inspections.
  
  

• NOM-019-SCFI-1998: This standard is issued by a technical and commercial authority. It applies to manufacturers, importers, or sellers of specific equipment and products. It does not regulate employment, HR policies, or workplace safety management.
  
  

• Same number, different purpose: One NOM governs employer obligations toward employees, while the other governs technical or product-related requirements. They do not overlap.
  
  

For foreign employers hiring in Mexico, this confusion creates real risk. The only way to ensure compliance is to identify and apply the full NOM code, including the issuing authority and year, before building policies or documentation.

What Is NOM-019-STPS-2011?

NOM-019-STPS-2011 is a mandatory Mexican labor safety standard issued by the Secretaría del Trabajo y Previsión Social (STPS). It obligates employers in Mexico to formally establish and operate a Safety and Hygiene Commission inside the workplace.

This is a legal requirement, not an internal HR choice, and it applies to both Mexican and foreign employers with staff in Mexico.

• Mandatory legal standard under labor law: NOM-019-STPS-2011 has the same binding force as other STPS safety NOMs and must be complied with at all times, not only during inspections.
  
  

• Applies broadly across workplaces: The obligation is not limited to factories or hazardous environments. Office-based, service, and remote-managed workplaces with physical locations are also covered.
  
  

• Requires a formal Safety and Hygiene Commission: Employers must appoint representatives, define responsibilities, hold meetings, document findings, and track corrective actions in writing.
  
  

• Directly reviewed during inspections: STPS inspectors typically request commission records, meeting minutes, risk identification logs, and evidence that corrective measures were implemented.
  
  

In practice, NOM-019-STPS-2011 functions as a core control mechanism within Mexico’s safety framework. Employers that implement it correctly demonstrate proactive compliance, while those that overlook it often face inspection findings, corrective orders, or penalties.

Purpose of NOM-019-STPS-2011

NOM-019-STPS-2011 exists to ensure that workplace safety in Mexico is managed through a structured and accountable internal process, not handled informally or only after incidents occur. It defines how employers must organize safety responsibilities to protect employee health and comply with labor law.

• Why Safety and Hygiene Commissions exist
  Mexican labor law requires employers to maintain an internal body dedicated to occupational safety and health. The commission serves as the formal mechanism for monitoring conditions and supporting prevention.
  
  

• Accident prevention and risk identification
  The commission is designed to identify workplace hazards, review incidents, and recommend corrective actions before injuries or regulatory findings occur.
  
  

• Employer accountability for workplace safety
  Employers remain fully responsible for safety outcomes and must ensure the commission operates, documents its activities, and follows up on identified risks.
  
  

In practice, NOM-019-STPS-2011 makes workplace safety a continuous management obligation. Employers must be able to show active oversight, documented prevention efforts, and clear accountability during inspections.

Who Must Comply With NOM-019-STPS-2011

NOM-019-STPS-2011 applies broadly to employers in Mexico and is not limited to specific industries or high-risk activities. The obligation is based on the existence of an employment relationship, not on the type of work performed or the size of the operation.

• All workplaces in Mexico
  Any workplace with employees in Mexico must comply with NOM-019, whether the location is a factory, office, warehouse, retail space, or service site.
  
  

• All company sizes and industries
  The standard applies equally to small teams, growing startups, and large enterprises. There are no exemptions based on headcount, revenue, or sector.
  
  

• Foreign companies with employees in Mexico
  Foreign employers hiring staff in Mexico are fully subject to NOM-019. Using an EOR or local employer structure does not remove this obligation, it only changes who manages compliance.
  
  

• Administrative and low-risk operations
  Even workplaces considered low-risk, such as administrative or professional services environments, must establish a Safety and Hygiene Commission and maintain proper documentation.
  
  

In practice, many employers assume NOM-019 only applies to industrial or hazardous settings. This misunderstanding often leads to compliance gaps that surface during STPS inspections, where applicability is evaluated based on employment presence, not perceived risk level.

What Are Safety and Hygiene Commissions?

Safety and Hygiene Commissions are formal internal bodies that employers in Mexico must establish to manage occupational safety and health within the workplace. They are not advisory groups or informal committees. Their existence, structure, and activity are required by law under NOM-019-STPS-2011.

These commissions act as the employer’s internal mechanism for identifying risks, monitoring safety conditions, and supporting accident prevention. Instead of relying only on external inspections, the commission provides continuous oversight of workplace safety.

• Definition of the commission
  A Safety and Hygiene Commission is a designated group of employer and employee representatives responsible for overseeing occupational safety and health conditions in the workplace.
  
  

• Role within the workplace
  The commission identifies hazards, reviews incidents, conducts periodic evaluations, and recommends corrective actions to reduce risks and prevent accidents.
  
  

• Legal importance during STPS inspections
  During inspections, STPS inspectors verify that the commission exists, is properly documented, and is actively performing its duties, not just created on paper.
  
  

In practice, Safety and Hygiene Commissions serve as proof that safety is being managed proactively. Employers that cannot demonstrate an active commission often face inspection findings, corrective orders, or penalties.

How Safety and Hygiene Commissions Must Be Formed

Under NOM-019-STPS-2011, Safety and Hygiene Commissions must be formed using a clear, formal structure defined by labor regulations. The way the commission is created matters just as much as its existence. An incorrectly formed commission can be treated as noncompliant during an inspection.

The standard requires balance, transparency, and documented appointments to ensure the commission represents both the employer and employees fairly.

• Bipartite structure
  The commission must be made up of representatives from both the employer and the employees. This shared structure ensures that safety decisions are not controlled by only one side.
  
  

• Equal representation requirements
  The number of employer representatives and employee representatives must be equal. An unbalanced commission does not meet NOM-019 requirements.
  
  

• Appointment and designation rules
  Employer representatives are designated by the company, while employee representatives are selected by the workforce. All appointments must be documented in writing.
  
  

• Commission leadership roles
  Coordinator and Secretary positions have a two-year term and must alternate between employer and worker representatives, as required by NOM-019
  
  

In practice, STPS inspectors review how the commission was formed, not just whether it exists. Clear documentation of representation, appointments, and leadership roles is essential to demonstrate valid compliance.

Responsibilities of Safety and Hygiene Commissions

Safety and Hygiene Commissions are responsible for the ongoing management of workplace safety, not just occasional reviews. NOM-019-STPS-2011 requires these commissions to actively monitor conditions, document findings, and follow up on risks in a structured and continuous way.

Their responsibilities focus on prevention, investigation, and corrective action, ensuring that safety issues are identified and addressed before they result in injuries or sanctions.

• Workplace inspections
  The commission must carry out periodic inspections of the workplace to review facilities, equipment, processes, and working conditions that could pose safety or health risks.
  
  

• Identification of unsafe conditions and practices
  During inspections and daily operations, the commission must detect hazardous conditions, unsafe behaviors, and procedural gaps that could lead to accidents or illnesses.
  
  

• Investigation of workplace accidents
  When incidents occur, the commission is required to investigate causes, document findings, and analyze whether preventive measures were missing or ineffective.
  
  

• Recommendation of corrective and preventive actions
  Based on inspections and investigations, the commission must propose specific corrective measures and track their implementation to reduce future risks.
  
  

In practice, STPS inspectors expect to see evidence that these responsibilities are performed regularly. Commissions that exist only on paper, without inspections, reports, or follow-up actions, are commonly cited during labor inspections.

Inspection Frequency and Operational Requirements

NOM-019-STPS-2011 does not allow Safety and Hygiene Commissions to operate casually or only when problems arise. The standard requires regular activity, documented participation, and clear follow-up, all of which are reviewed during STPS inspections. ‘

How often the commission meets and how it documents its work are key compliance indicators.

• Minimum inspection frequency
  The commission must conduct workplace inspections at least once every three months. These inspections must be planned, performed, and documented, even if no incidents have occurred.
  
  

• Extraordinary inspections after incidents
  Additional inspections are required after workplace accidents, dangerous events, or when significant changes to processes, equipment, or facilities occur.
  
  

• Participation and attendance expectations
  Commission members are expected to attend inspections and meetings. Attendance records must show active participation from both employer and employee representatives.
  
  

• Follow-up on corrective actions
  Identified risks must be tracked until corrected. The commission must document corrective actions, responsible parties, and completion status.
  
  

In practice, inspectors look for continuity. Regular inspections, attendance records, and documented follow-up demonstrate that safety oversight is active and ongoing, not reactive or symbolic.

Mandatory Documentation Under NOM-019-STPS-2011

Documentation is a core requirement under NOM-019-STPS-2011. Safety and Hygiene Commissions must be able to prove their existence, activity, and follow-up actions through written records. Verbal practices or undocumented efforts are not considered compliant during STPS inspections.

• Commission formation records
  Employers must keep written evidence of the commission’s creation, including member appointments, equal representation, and designated leadership roles.
  
  

• Inspection reports
  Each workplace inspection must be documented, detailing identified risks, observations, and recommended actions, even when no issues are found.
  
  

• Meeting minutes
  The commission must record meeting discussions, decisions made, and agreements reached. These minutes demonstrate active operation and participation.
  
  

• Corrective action tracking
  Identified risks must be logged with assigned responsibilities, deadlines, and completion status to show follow-through on safety measures.
  
  

• Record retention expectations
  All documentation must be retained and readily available for review during labor inspections, covering both current and past commission activities.
  
  

In practice, missing or incomplete records are one of the most common findings during STPS inspections. Proper documentation shows that safety oversight is structured, continuous, and enforceable.

NOM-019-STPS-2011 and STPS Inspections

During an STPS inspection, NOM-019-STPS-2011 is treated as a foundational compliance item. Inspectors use it to assess whether workplace safety is being managed in an organized and preventive manner, not just whether safety rules exist on paper.

• What labor inspectors review
  Inspectors verify that a Safety and Hygiene Commission is formally established, correctly structured, and actively operating according to NOM-019 requirements.
  
  

• Common documentation requested
  STPS typically requests commission formation records, inspection reports, meeting minutes, attendance lists, and evidence of corrective action follow-up.
  
  

• Typical compliance failures identified by STPS
  Common issues include commissions that exist only on paper, missing inspection reports, outdated records, lack of follow-up on identified risks, or incorrect commission structure.
  
  

In practice, inspections focus on evidence of continuous activity. Employers that cannot demonstrate regular inspections, documented meetings, and completed corrective actions are frequently cited, even if no workplace accidents have occurred.

How NOM-019-STPS-2011 Relates to Other Safety NOMs

NOM-019-STPS-2011 does not operate in isolation. It acts as the organizational foundation that supports compliance with several other STPS safety standards.

While other NOMs regulate specific risks or scenarios, NOM-019 defines who inside the workplace is responsible for identifying, reviewing, and following up on those obligations.

• Relationship with NOM-030 (preventive safety services)
  NOM-030 requires employers to manage preventive safety and health services. The Safety and Hygiene Commission created under NOM-019 is the internal body that supports and monitors those preventive activities.
  
  

• Relationship with NOM-035 (psychosocial risks)
  NOM-035 focuses on identifying and managing psychosocial risks. The commission under NOM-019 plays a role in reviewing findings, documenting actions, and tracking preventive measures related to psychosocial conditions.
  
  

• Relationship with NOM-037 (telework safety)
  NOM-037 regulates safety and health conditions for telework. When applicable, the commission supports oversight, documentation, and internal follow-up for telework-related safety obligations.
  
  

• Why NOM-019 is foundational
  NOM-019 establishes the structure that allows other safety NOMs to function in practice. Without an active commission, employers often lack coordination, documentation, and accountability across multiple safety requirements.
  
  

In practice, STPS inspectors often evaluate NOM-019 first. If the commission is missing or inactive, compliance with other safety NOMs becomes difficult to demonstrate, even if policies exist.

Penalties and Risks for Non-Compliance

Failing to comply with NOM-019-STPS-2011 exposes employers to regulatory, legal, and operational risks. STPS treats this standard as a core safety requirement, and noncompliance often triggers penalties even when no accident has occurred.

• Administrative fines
  STPS can impose fines when a Safety and Hygiene Commission is missing, improperly formed, inactive, or undocumented. Penalties may increase if violations are repeated or ignored.
  
  

• Increased liability in workplace accidents
  If an accident occurs and the commission was not properly operating, employers face higher exposure. Lack of inspections, reports, or corrective actions weakens the employer’s defense.
  
  

• Legal exposure during labor disputes
  In labor claims, missing NOM-019 compliance records can be used as evidence of negligence. This can affect outcomes in disputes related to injuries or unsafe working conditions.
  
  

• Operational risk for foreign employers
  Foreign companies often underestimate this NOM. Noncompliance can delay operations, complicate audits, and damage credibility during inspections or regulatory reviews.
  
  

In practice, NOM-019 noncompliance is rarely treated as a minor issue. It often becomes a multiplier that increases risk across inspections, disputes, and operational continuity in Mexico.

Why Foreign Companies Commonly Fail NOM-019 Compliance

Foreign companies often fail NOM-019-STPS-2011 compliance not because of intent, but because Mexican labor safety rules operate very differently from those in other countries. The obligation is structural and documentation-driven, which makes it easy to overlook when expanding into Mexico.

• Lack of local labor safety knowledge
  Many foreign employers are unfamiliar with Mexico’s occupational safety framework and assume safety committees are optional or industry-specific, which is not the case.
  
  

• No formal commission despite having employees
  Companies often hire staff quickly but never establish a Safety and Hygiene Commission, especially in office-based or administrative operations.
  
  

• Poor documentation practices
  Even when safety activities occur, they are frequently undocumented. Missing formation records, inspection reports, or meeting minutes result in noncompliance during inspections.
  
  

• Reliance on non-Mexico-specialized providers
  Global HR or payroll providers may not actively manage NOM-019 requirements, leaving employers exposed despite believing compliance is handled.
  
  

In practice, these failures surface during STPS inspections. Foreign employers are often surprised to learn that informal safety efforts or generic global policies do not satisfy Mexico’s strict structural and documentation requirements under NOM-019.

How Human Resources Mexico (HRM) Ensures NOM-019 Compliance

Human Resources Mexico (HRM) manages NOM-019-STPS-2011 compliance as an operational responsibility, not a checklist item.

By combining local expertise with integrated compliance management, HRM ensures Safety and Hygiene Commissions are properly formed, active, and inspection-ready at all times.

• Mexico-only employer model
  HRM operates exclusively in Mexico, with local teams that understand STPS enforcement practices, labor inspections, and real-world compliance expectations.
  
  

• Formation and maintenance of Safety and Hygiene Commissions
  HRM handles the correct formation of commissions, including equal representation, formal appointments, leadership roles, and ongoing operational support.
  
  

• Inspection-ready documentation management
  Commission records, inspection reports, meeting minutes, and corrective action tracking are maintained in an organized and audit-ready format for STPS inspections.
  
  

• Integrated HR, payroll, and labor compliance oversight
  NOM-019 compliance is managed alongside payroll, HR administration, and other labor obligations, reducing gaps caused by fragmented providers.
  
  

By managing NOM-019 as part of a unified compliance framework, Human Resources Mexico helps foreign employers avoid last-minute fixes, inspection findings, and operational disruption.

If you are hiring or planning to hire employees in Mexico, reach out to HRM to discuss your workforce structure and get a custom proposal tailored to your hiring needs in Mexico.

Frequently Asked Questions (FAQs)

Is NOM-019-STPS-2011 mandatory for all employers in Mexico?

Yes. NOM-019-STPS-2011 is mandatory for all employers with employees in Mexico. It applies regardless of company size, industry, or risk level. The obligation exists as soon as an employment relationship is established, and compliance is verified during STPS labor inspections.

Does NOM-019 apply to office-based or remote employees?

Yes. NOM-019 applies to office-based and administrative workplaces, not only industrial or high-risk environments. If employees work from a physical workplace in Mexico, a Safety and Hygiene Commission must be established. Telework obligations may also connect with this NOM.

Who can be appointed to the Safety and Hygiene Commission?

The commission must include both employer and employee representatives with equal representation. Employer representatives are appointed by the company, while employee representatives are selected by the workforce. Leadership roles such as coordinator and secretary must also be formally designated.

What documents must be shown during an STPS inspection?

Inspectors typically request commission formation records, inspection reports, meeting minutes, attendance lists, and evidence of corrective actions. All documents must show that the commission is active, properly structured, and performing its duties on an ongoing basis.

How does HRM help foreign companies comply with NOM-019?

Human Resources Mexico manages NOM-019 compliance as part of its Mexico-only employer model. HRM forms and maintains Safety and Hygiene Commissions, manages documentation, and ensures inspection-ready compliance for foreign companies hiring in Mexico.