DEVELOPING A WORKPLACE VIOLENCE PREVENTION PROGRAM

Every employer should establish, implement and maintain a written WPV Prevention Program. It should be made available to all employees, including managers and supervisors; and all employees should receive specific training concerning its content and implementation. The program should reflect the level and nature of threat faced by the employee(s)/employer. The potential for and/or source(s) of violence in a specific workplace requires a review and assessment of the vulnerability to the four (4) categories of violence previously outlined; Violence by Strangers, Client/Customers, Coworkers and Personal Relationships.

When violence may be committed by strangers, workers can be victimized both in and outside the "traditional" workplace, but while acting within the course and scope of their employment. Use of specific training, staffing and protective equipment coupled with effective physical security methods, and policies must be reviewed and assessed.

Two basic types of violence by client/customer(s) against workers are of concern. The first involves individuals that may have a history of violent behavior, such as prison inmates, mental health service recipients. Situations where this may occur are usually well recognized, and prevention focuses on appropriate staffing, and specialized training, augmented with other control measures. The second arises when client or customers may be "situationally" violent and are provoked when they become frustrated by delays or by the denial of benefits or social services. In these cases, problem anticipation, appropriate training and other control measures deemed effective are the focus for prevention.

Coworker violence can occur on several levels; between supervisors and subordinates or between nonsupervisory and supervisory workers at the same level or different levels. A well written violence prevention policy which treats all employees fairly, training in conflict and dispute resolution and active involvement of trained Employee Assistance Program (EAP) personnel, is appropriate in these circumstances.

Finally, the potential for violence resulting from personal relationships must be considered. Estranged domestic partners may seek out their victims while they are at work. Employees who may be victims of domestic violence need to be aware and feel secure in alerting their employers to the potential for a workplace attack. Strict policies should be implemented that 1) address the confidentiality of personal employee information (i.e. home address, work schedules), 2) deny or restrict workplace access to employee relatives or outside visitors, and 3) allow flexibility in the use of leave, work schedules or transfers in situations where employee(s) may be at risk of violence.

To be successful, workplace violence prevention efforts must have commitment from top management and must involve supervisors, employees and employee representatives. Commitment and involvement are essential in any safety and health program. Management provides the organizational resources along with the motivating forces necessary to deal effectively with safety and security hazards. Employees should be involved, both individually and collectively, through participation in worksite assessment, assisting in the development of clear effective procedures and by identifying existing and potential hazards. Employee knowledge and experience should be incorporated into any written plan to correct and prevent safety and security hazards.

Elements of a WPV Prevention Program include:

WRITTEN WORKPLACE VIOLENCE PREVENTION POLICY STATEMENT

An important element of an effective program for prevention of workplace violence is a clearly written company policy statement which demonstrates top management's concern and commitment to their employees' safety and health.

The written policy should state that the employer:

The policy should be easily accessible to all employees and copies should be made available to employees upon request.

THREAT ASSESSMENT TEAM

The initial step in developing a workplace violence prevention program is to designate a Threat Assessment Team.

The Threat Assessment Team should be designated to assess the vulnerability to workplace violence and reach agreement on preventive actions to be taken. The team should also be responsible for:

Threat Assessment Team membership should include representatives of the following:

Responsibility for auditing the overall WPV prevention program should rest with the Threat Assessment Team.

HAZARD ASSESSMENT

The elements of a hazard assessment include records review, workplace security analysis and workplace surveys.

Records Review:

The Threat Assessment Team can begin its work by reviewing previous incidents of violence. A review and analysis of existing records is necessary to develop a baseline, by identifying patterns that may indicate the causes and severity of assault incidents, identifying changes necessary and developing an appropriate plan to correct these hazards.

The Threat Assessment Team should analyze the following, when available, to complete a record review:

The Threat Assessment Team should identify and analyze any apparent trends in assault incidents relating to particular departments, units, job titles, unit activities, time of day, etc. The Threat Assessment Team should communicate with similar local businesses, trade associations, community and civic groups concerning their experiences with workplace violence.

Workplace Security Analysis:

In addition to a records review, the Threat Assessment Team should inspect the workplace as well as evaluate the work tasks of employees to determine the presence of hazards, conditions, operations and situations which might place workers at risk of occupational assault incidents. The Threat Assessment Team should conduct follow-up inspections of the workplace and observe hazardous work tasks on a periodic basis.

Workplace Surveys:

A questionnaire or survey should be distributed to employees to identify the potential for violent incidents and to identify or confirm the need for improved security measures. A sample questionnaire and inspection checklist is available in Part IV of this document; or the team may develop their own questionnaires, with employee input into design, format and dissemination. All employees should be encouraged to complete the questionnaire.

Employee questionnaires should be reviewed, updated and distributed as needed, or at least once within a twenty-four (24) month period of time. Results should be analyzed and used to revise and improve the overall content and implementation of the WPV Prevention Program.

HAZARD CONTROL AND PREVENTION

The Threat Assessment Team should identify and institute a combination of control methods designed to eliminate or minimize the risks of assault incidents. These include, but are not limited to:

The employer may implement these control measures alone or in combination to address hazards identified in the hazard assessment.

General building, workstation and area designs:

Security should not conflict with Life Safety Code requirements. although it may be tempting to keep doors locked to prevent intrusion, egress from inside the building must not be impeded.

Security Equipment:

Work practice controls and procedures:

EMPLOYEE TRAINING AND EDUCATION

All employees, regardless of their level of risk, should be taught:

Effective training:

Workers with job tasks or locations that place them at higher risk for violent incidents should be provided specialized training in addition to those topics outlined above. Training should be designed to deal with the nature of this risk.

Managers and supervisors should undergo the training outlined thus far plus additional training to enable them to recognize a potentially hazardous situation or to make any necessary changes in the physical plant, patient care treatment program, staffing policy and procedures.

Managers and supervisors should also be trained to ensure that employees are not placed in assignments that compromise safety and in methods and procedures which will reduce the security hazards. They should be trained to behave compassionately towards co-workers when an incident does occur. They need to ensure that employees follow safe work practices and receive appropriate training to enable them to do this. They should reinforce the employer's WPV Prevention Program, promote safety and security, and ensure employees receive additional training as the need arises.

Security personnel need to be trained whenever possible for the specific job, facility layout, security hardware on premises and particular high risk jobs.

INCIDENT REPORTING, INVESTIGATION, FOLLOW-UP, and EVALUATION

Incident Reporting - A procedure for reporting violent incidents should be developed, if one is not already in place. This procedure should apply to all types of violent incidents, whether or not physical injury has occurred (i.e. verbal abuse, threats of violence, menacing, etc.). This procedure should be in writing and should be easily understood by all employees. It should take into account issues of confidentiality. Employees may be reluctant to come forward otherwise. Employees should not fear reprisal for bringing their concerns to management's attention.

Each incident should be reported to and evaluated by the Threat Assessment Team. The reports of incidents and their evaluation provide vital information and data necessary on workplace violence and serve as a basis to identify program improvements.

Once an incident occurs, the employer should:

Incident Investigation - After an incident occurs, a detailed investigation is imperative. All incidents, including near misses, should be investigated as soon as possible. A delay of any kind may cause important evidence to be removed, destroyed intentionally or unintentionally. The investigation should be focused on fact-finding to prevent recurrence and not fault-finding. Employers should have effective medical management programs available and maintain comprehensive records.

When conducting the investigation, the Threat Assessment Team should:

Follow-up - Procedures should be established for responding quickly and appropriately to the medical and psychological needs of employees following exposure to an assault incident. Use of existing Employee Assistant Programs (EAPs) or the establishment of such a program and its use should be encouraged. All employees affected by workplace violence should be provided with appropriate medical and psychological treatment and follow-up. Provisions for medical confidentiality and protection from discrimination(7) must be included to prevent the victims of workplace violence from suffering further loss.

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FOOTNOTE(7) See applicable laws governing confidentiality.

Evaluation - After doing the initial workplace security analysis, the Threat Assessment Team should conduct periodic physical evaluations of the worksite. These physical evaluations should focus on the identification and assessment of workplace security hazards and address changes in employee work practices. These evaluations may require an assessment of the potential for more than one type of workplace violence.

RECORDKEEPING

An effective recordkeeping system helps in selecting the appropriate level of controls to prevent recurrence and in determining required training. Records should be kept up to date. The following records should be kept:

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FOOTNOTE(8) An employee death resulting from an employment accident or illness caused by or related to a workplace hazard or the hospitalization (not examination and release) of three (3) or more employees resulting from an employment accident or illness caused by a workplace hazard must be orally reported by the employer within eight (8) hours.