OSHA’s Compliance Directive (CPL) 02-01-058, Enforcement Procedures and Scheduling for Occupational Exposure to Workplace Violence, dated January 10, 2017, explains that a written, comprehensive workplace violence prevention program should include
- A policy statement regarding:
- Potential violence in the workplace, and
- Assignment of oversight and prevention responsibilities.
- A workplace violence hazard assessment and security analysis, including:
- A list of the risk factors identified in the assessment, and
- How the employer will address the specific hazards identified.
- Development of workplace violence controls, including implementation of:
- Engineering and administrative controls, and
- Methods used to prevent potential workplace violence incidents.
- A recordkeeping system designed to:
- Address each specific hazard identified in the workplace evaluation, and
- Report any violent incidents. (The reports must be in writing and maintained for review after each incident and at least annually to analyze incident trends.)
- Development of a workplace violence training program that includes a:
- Written outline, or
- Lesson plan.
- Development of a defined procedure and means for logging incidents.
- Annual review of the workplace violence prevention program, which should be updated as necessary. (Such review and updates shall set forth any mitigating steps taken in response to any workplace violence incidents.)
- Development of procedures and responsibilities to be taken in the event of a violent incident in the workplace.
- Development of a response team responsible for:
- Immediate care of victims,
- Re-establishment of work areas and processes, and
- Debriefing sessions with victims and coworkers.
OSHA suggests contacting the following entities for input in developing response strategies:
- Employee assistance programs,
- Human resource professionals,
- Local mental health service personnel, and
- Local emergency service personnel.
Employers must be familiar with crossover topics related to workplace violence as well to better understand implications that reach further into the organization. These crossover topics include human resources topics like discrimination, harassment, etc.
