Last January, I alerted you that national surveys reported that Workplace Violence (WPV) was the number one concern of senior management in 2024.
California is always ahead regarding workplace safety standards and promulgates new WPV regulations. Effective 1 July 2024, all California employers—without exception—shall have a WPV Response Plan.
So, write some Run/Hide/Fight response procedures and move on.
My Drill Sergeant in the U.S. Army taught me, "For every complex problem, there is a simple solution that’s always wrong.” So, here we are in California regulations.
The complex problems:
- This 35-page, 15,000-word regulation is a bear for any employer to claw through.
- You must comply if your organization has a California office of at least one employee.
- If your California office is one of your many facilities nationally, should all your offices outside California comply with the “strictest standard” protocol applied at court when you’re sued?
- “Orders” (court, restraining, protection) are referred to 366 times, demanding that employers and employees take responsibility for reports, investigations, meetings, alerts, etc. CalOSHA will issue more regulations regarding these orders over the next 30 months, so we’re just getting started.
- These WPV regulations demand reference to all the other California safety regulations (I2P2, EAP, FPP, etc.) issued over the last 30 years, all of which are to work together with the new WPV regs.
- Your WPV Response Plan shall ensure employees' “active involvement” every step of the way: plan development, identifying threats, training, investigations, meetings, reporting, keeping logs for five years, and more.
- WPV comes in many forms for which you must detail response procedures:
- Active Shooter
- Bomb Threat
- Workplace Bullying
- Suspicious Package
- Suspicious Person
- Civil Disobedience
- Stalking
- Assault
- Rape
- Explosion
- Hostage
- Lockdown
- Lockout
- Perimeter Security
- Protection Order
- Visitor Management
- Security After Hours
- Parking Lot/Garage
- Suicide
- Weapons at Work
- CalOSHA offers employers a template to aid in writing your WPV Response Plan. It is 19 pages and 6,000 words long.
Simple, right?
What to do?
If you don’t have a dedicated safety or security manager, immediately abandon turning to your HR, BC, CIO, CAO or COO. They will be lost in the first paragraph of those 35 pages. If you have a dedicated safety or security officer, do not assume s/he will have the skills or experience to attack these regulations. You will also need outside counsel to navigate this very special area of law in workplace emergency management.
If you need skilled outside help, please turn to ASIS International. ASIS is a standards-making organization in all forms of WPV. ASIS has certified thousands of experts in workplace security. There, you can partner with experts who know the standards and have the skills to create, train and exercise your WPV Response Plan in California and every state in the union.
You need a complex answer to this complex problem to comply with your duty of care to keep all personnel safe and secure in your workplace.
