By: Georgina Herrera Guerrero
Internal implementation of NOM-035 begins with a clear, communicated policy that sets objectives, scope, and specific commitments regarding psychosocial risk factors, the organizational environment, and workplace violence. It falls to the workplace to organize its preventive services in accordance with NOM 030 and the RFSST, to maintain its Diagnosis and its Program, and to coordinate with the Safety and Health Committee provided for in NOM 019. Consequently, it is sufficient to document how functions and lines of coordination are assigned to execute and monitor NOM 035, without the need to create a specific “NOM 035 officer.” Rules on confidentiality and data protection are a condition of legitimacy for complaint mechanisms and for clinical referrals.
Next, the workplace determines its size and maps areas, positions, shifts, and schedules. On that basis, it selects the tool to identify and analyze psychosocial risk factors and, where applicable, the method to evaluate the organizational environment. The guides provided by the standard may be used, or equivalent instruments that meet its technical criteria. It is essential to document the methodology, the population covered, sampling assumptions, and limitations. The evaluation is not aimed at diagnosing individuals; it is aimed at describing conditions and processes that are susceptible to improvement.
The technical report becomes an action plan when it is integrated into the Occupational Safety and Health Diagnosis and the Occupational Safety and Health Program. At that stage, findings are prioritized by criticality and reach, and measures proportionate to the identified risks are formulated. Typical actions include leveling workloads and targets; managing schedules and night rotation with recovery periods; clarifying roles and communication processes; training supervisors in leadership and conflict management; strengthening social support within teams; and recognizing performance. Where reports of violence exist, the corresponding protocol ensures timely investigation, protection, and proportional sanctions.
Communication accompanies the entire process. The organization informs the workforce about the policy, complaint mechanisms, and, where appropriate, general results and measures adopted. This information is delivered in accessible formats and supported by materials and attendance records. In parallel, the workplace establishes a clear pathway to identify and refer persons exposed to severe traumatic events, avoiding revictimization and guaranteeing confidentiality. At all times, records are created and safeguarded with version control and access for consultation.
The cycle closes with verification and improvement. Management periodically reviews the effectiveness of measures, internal audits proportionate to risk are carried out, and instruments are updated no less often than every two years or when relevant changes occur. Consistency among what is documented, what employees report, and what is observed on site is the practical criterion that commonly guides the authority’s assessment.
Prevention of sanctions is not exhausted by formal compliance. A system that demonstrates visible measures, maintains orderly evidence, responds to requests on time, and processes official notices reduces exposure. Likewise, training of frontline supervisors drives correct execution in teams and shifts.
Where the authority makes findings, the adoption of corrective actions with defined dates and responsible parties closes gaps and reduces the likelihood of recurrence. When NOM 035 is integrated into the diagnosis and the safety and health program, and the chain of traceability from finding to result is maintained, verification becomes an exercise in confirmation rather than a risk factor.
NOM 035, as a technical instrument that operationalizes legal mandates on occupational safety and health, requires identifying conditions, intervening with proportionate measures, informing clearly, referring with care, and verifying methodically. An organization that orders its evidence, preserves its records, and demonstrates consistency between documents and practice complies with the standard and prevents sanctions, while improving the quality of its day to day management.
