Recent OSHA Directive Provides Guidance on Workplace Violence

In a recent directive entitled Enforcement Procedures for Investigating or Inspecting Workplace Violence Incidents (CPL 02-01-052, September 8, 2011), OSHA outlines general recommendations for all industries and workplaces concerning violence prevention.

Here are seven steps you can take to minimize the risk of violence in your workplace:

1. Conduct a workplace violence hazard analysis.

2. Assess plans for reducing any security hazards.

3. Provide employees with training on workplace violence.

4. Implement engineering controls, such as:

• Install and regularly maintain alarm systems and other security devices, such as panic buttons, hand-held alarms or noise devices, cellular phones and private channel radios, where risk is apparent or may be anticipated. Arrange for a reliable response system when an alarm is triggered.
• Provide metal detectors—installed or hand-held, where appropriate—to detect guns, knives or other weapons, according to the recommendations of security consultants.
• Use a closed-circuit recording on a 24-hour basis for high-risk areas.
• Place curved mirrors at hallway intersections or concealed areas.

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• Lock all unused doors to limit access, in accordance with local fire codes.
• Install bright, effective lighting, both indoors and outdoors.
• Replace burned-out lights and broken windows and locks.
• Keep company vehicles well maintained if they are used in the field.
• Lock company vehicles at all times.

5. Implement administrative controls to reduce risks. For example:

• Establish liaisons with local police and state prosecutors. Report all incidents of violence. Give police physical layouts of facilities to expedite investigations.
• Require employees to report all assaults or threats to a supervisor or manager (in addition, address concerns where the perpetrator is the manager). Keep log books and reports of such incidents to help determine any necessary actions to prevent recurrences.
• Devise a system that allows you to respond promptly to all complaints about threats or violent behavior.
• Advise employees of company procedures for requesting police assistance or filing charges when assaulted and help them do so, if necessary.

6. Provide management support during emergencies.

• Set up a trained response team to respond to emergencies.
• Use properly trained security officers to deal with aggressive behavior. Follow written security procedures.

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7. Develop comprehensive violence prevention program that includes:

• 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 you 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 report any violent incidents. Reports must be written 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.
• 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, reestablishment of work areas and processes, and providing debriefing sessions with victims and coworkers. Employee assistance programs, human resource professionals, and local mental health and emergency service personnel should be contacted for input in developing these strategies.

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