Regardless of the way workplace violence might manifest itself, employers are expected to provide a safe working environment, which means they must understand, prepare for and mitigate workplace violence exposures.
Because of the broad spectrum of workplace violence and the inability to completely transfer or eliminate this exposure, an enterprise risk approach should be used for risk identification, quantification, control and administration. This article – the first in a three-part series dedicated to workplace violence – will focus on regulatory and accepted standards as they pertain to creating a safer work environment.
The Occupational Safety and Health Administration (OSHA) is tasked with assuring safe and healthy working conditions for employees and has taken an active role in pushing employers to think about and implement prevention strategies. This is achieved, in part, through the enforcement of particular regulations and standards. In the area of workplace violence, OSHA has few regulations currently in place. Citations related to workplace violence are most frequently issued based on recordkeeping errors or omissions discovered on OSHA 300 injury logs at inspection time. These are also frequently issued under the general duty clause (OSHA’s catch-all regulation applicable to employers in industries with well-known risks that fail to take basic precautionary measures to protect their employees).
In 2011, OSHA issued a directive for its compliance officers with specific enforcement procedures for investigating or inspecting workplace violence incidents. This directive has mainly affected industries that have been identified as high risk, including healthcare and social services, in-home care and late-night retail establishments. Although not written to be geared toward employer use, this directive serves as a measuring tool when employers ask themselves, “Are we doing enough to keep our employees safe?”
Other workplace violence risk factors identified by OSHA include employees in mobile workplaces such as taxi drivers or other for-hire drivers, exchanging money with the public, working with violent or unpredictable individuals or working alone or in an isolated area. The time of day and area crime rates are both important considerations when employers evaluate the risk to their employees and begin to develop prevention and training programs. OSHA’s website provides more guidance and recommendations for high-risk industries.*
Additional insight regarding prevention expectations can be found in past OSHA-issued general duty clause citations. This data can guide employers during the assessment stage when developing a workplace violence prevention program or during the review process of an existing program. While most employers can benefit from using these tools, it is particularly crucial for those in high- risk industries. Below are some of the assessment elements worth reviewing:
- Administrative Controls – Examples include a jobsite hazard assessment, a review of existing operating procedures and controls, the implementation of new policies or procedures, and a new incident review process if the need for a modified program is identified.
- Engineering Controls – Examples include installing panic buttons, creating physical barriers and reconfiguring workspaces so employees can escape a violent event.
- Personal Protective Equipment – Examples include personal alarms worn by employees or some other means of requesting assistance or providing notification when a problem arises.
Setting the Standard
In addition to the government’s role in requiring a safe work environment, a great deal of research has been done in the past 25 years to understand the growing phenomenon of workplace violence and much is being done to increase awareness among employees and their employers. This is reflected in the establishment of standards, guidelines and best practices for organizations to prevent, intervene and mitigate the risk of violence to an organization’s most valued resource – its employees. The American National Standards Institute (ANSI) has collaborated with two organizations to lead the charge in this effort – ASIS International (ASIS) and the Society for Human Resource Management (SHRM).
ASIS is the preeminent organization for security professionals, with more than 37,000 members worldwide. It is dedicated to increasing the effectiveness and productivity of security professionals by developing programs and materials that address security issues. SHRM is the world’s largest association dedicated to human resource (HR) management. With more than 250,000 members worldwide, SHRM serves to advance the interests of HR professionals.
One of the results of this collaboration is the American National Standard on Workplace Violence Prevention and Intervention that was released in 2011. This standard provides an overview of policies, processes and protocols that organizations can adopt to help identify threatening behavior in the workplace before it manifests itself in violence. It also enables organizations to better respond to violent incidents. Much can be learned by understanding and implementing key elements addressed in the standard, some of which are discussed in the following paragraphs.
Get People Involved
An effective workplace violence prevention and intervention program must include a cross-functional and collaborative approach from several key stakeholders. Each of these individuals brings a unique perspective to the process because each views the threat of violence and its consequences through a different lens. The list of people who should be involved may include the following, depending on organizational size and complexity:
- Executive management
- HR personnel
- Security staff
- Legal counsel
- Safety personnel
- Employee Assistance Program (EAP) team members
- Public relations / corporate communications staff
Key Elements of a Formal Program
The culture of an organization and the tone set by leadership goes a long way toward promoting and implementing a strong and sustainable workplace violence prevention and intervention program. Even before a program is formally started, efforts should be made toward identifying potential threats, as well as the organization’s vulnerability to those threats and the subsequent risk to employees and the organization as a whole. Once these issues have been identified, construction can begin on a formal program.
Build on that Foundation
Once an organization has determined its potential risks and vulnerabilities, it has the proper framework to begin developing policies and protocols. The standard recommends the following list as a starting point in building an effective and sustainable workplace violence prevention and intervention program:
- Establish a workplace violence prevention policy
- Create an interdisciplinary threat management team
- Develop an incident management process
- Create emergency and high-risk protocols
- Provide training
- Maintain centralized recordkeeping
- Review effective strategies for high-risk workplaces
- Implement additional prevention and intervention strategies and protocols as needed
More to Come
While we have outlined the basic elements to initiate a workplace violence prevention and intervention strategy, it is important to remember that one size does not fit all. Additional information and planning is needed to create an effective program. In the second part of this series, we delve deeper into this topic by discussing how to assess threats and distinguish the difference between making a threat and posing a threat, while also covering the process of threat management within an organization.
James Dale of Seven Citadels Consulting also contributed to this article.
* See OSHA publication 3148-04R 2015: “Guidelines for Preventing Workplace Violence for Healthcare and Social Service Workers,” and OSHA publication 3153-12R 2009: “Recommendations for Workplace Violence Prevention Programs in Late-Night Retail Establishments.”
1 “Safety and Health Topics: Workplace Violence.” United States Department of Labor Website. Accessed on January 8, 2016.
2 “Enforcement Procedures for Investigating or Inspecting Workplace Violence Incidents.” OSHA Directive Number: CPL 02-01-052. September 8, 2011. United States Department of Labor website. Accessed on January 8, 2016.
This article originally appeared in the Winter 2016 issue of the SilverLink magazine under the title “Workplace Violence – Regulatory and Accepted Standards. A Three-Part Review – Part One” To receive a complimentary subscription to the SilverLink magazine, sign up here.