Implementing An Effective
Workplace Violence Program

Occupational Safety & Health Administration (OSHA) is committed to using all of its inspection and enforcement authority to compel employers to anticipate and avoid incidents of workplace violence. OSHA’s past and present inspections, citations and large fines demonstrate that it is not hesitant to use that authority. The prudent employer acts in advance. That employer protects its employees by evaluating its workplace, inside and out, for risks of workplace violence and implements and maintains a workplace violence program to eliminate or reduce those risks to the extent feasible. By taking this action, the prepared employer protects itself from large fines and oppressive abatement orders from OSHA.

OSHA has an internal directive (also called an instruction) that it follows when conducting inspections and issuing citations and penalties concerning workplace violence. The directive provides OSHA’s view of the process employers should follow to develop a workplace violence program and methods for an employer to protect its employees. Note that OSHA defines workplace violence to include threats of violence that do not result in physical contact or an assault.

OSHA’s workplace violence directive, which cross-references industry-specific guidelines on workplace violence, is available online. If you prefer, you may obtain OSHA’s workplace violence directive and related material from us by calling 513.621.2120 or emailing me at jwfischer@strausstroy.com.

Overview Of Workplace Violence Program Elements:

1. Evaluate the particular facilities, jobs, functions and activities, individually and in combinations, for their potential for triggering workplace violence.

2. Write a comprehensive workplace violence program to address the risks identified in the employer’s assessment. The policy may provide different and additional steps for protection depending on such variables as the physical location of the facility, the work area within the facility, the work shift or time of day, type of job, number of other employees on duty and available and the availability of outside resources. While a good program should be complete and detailed, it must also be practical and straight forward so that it can be easily understood and followed in practice.

3. Address, to the extent feasible, any physical or structural items in or related to the work area that can be modified to make the workplace safer for employees from potential sources of workplace violence. Address and, where necessary, modify administrative work and care practices and procedures to improve the safety of any work activities or functions the employer has identified as potential sources or triggers of workplace violence.

4. Train supervisors and employees about the violence prevention program, as well as the specific work practices to follow and to avoid.

5. Determine, in advance, how employees, supervisors and managers should respond to incidents of workplace violence. Establish and train a multi-disciplinary crisis team, with prearranged areas of responsibility, to investigate, respond to and follow-up on any incidents of workplace violence.

6. Periodically reassess the circumstances and conditions inside and outside the workplace for potential risks. Update or change the violence prevention program when appropriate. Periodically review and update the training component of the program. When called for, conduct refresher or updated training.

For most industries and employers, a satisfactory workplace violence prevention program cannot, and should not, be a standard “off-the-shelf” form or product. For a program to be effective in addressing workplace safety, and meeting the often shifting expectations of OSHA, the program must be tailored to the particulars of the specific workplace.

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