Developing Your Comprehensive Workplace Violence Prevention Policy / Plan

Developing your organizational comprehensive workplace violence prevention policy and emergency action plan (EAP) does not have to be a complicated or complex process or document. However, assumptions aside,  you must begin with the notion that every workplace is a workplace environment and as such can become an at risk setting. Prior planning and preparation are key.  Assumptions aside, employers must understand the unique aspects of their workplace environments; type of workplace setting and its relevant risks. There must be a process that involves a risk or security assessment to help identify your work-site specific vulnerabilities, hazards, conditions and situations and potential risks to employees at whatever work-site they maybe performing their official duties at.

The policy and subsequent plan should not only address the employee on employee threat but it must be inclusive of the policy and subsequent plan should not only address the employee on employee threat but inclusive of the OSHA 4 Categories of Workplace Violence listed below in order to properly lay out the risk and helpm the workforce understand the risks in taking appropriate risk mitigation measures. We know that workplace violence ranges from threats and verbal abuse to physical assaults, sexual harassment, suicide and homicide. Comprehensive efforts entail education of the workforce on mitigation measures and situational awareness that informs against current employee, former employee threat, opportunistic criminals during an armed robbery, patients, clients, vendors and even personal relationship violence and its workplace spillover.  OSHA defines the 4 categories as:

– Type I: Criminal Intent

Criminal intent workplace violence occurs when the perpetrator has no legitimate relationship to the business usually while committing a crime and use of a deadly weapon to further their cause. These types of crimes occur in workplace settings where the employee handles cash, drugs or jewelry and other commodities. Taxi drivers, those who work at night, or who primarily work alone and other workplace settings where the employee engages the public are at greater risk from these perpetrators.  Supervisors are encouraged to conduct visual observations of all workplaces but particularly remote workplace settings on occasion to help employees identify and minimize their risks. Employees who travel from work-site to work-site to meet with clients or customers become vulnerable when they are not cognizant of their surroundings or let their guards down.

– Type II: Customer/Client.

Customer/client workplace violence occurs when the perpetrator is a customer or client of the employee and attacks that employee or others.  The most common targets of customer/client workplace violence are school teachers, healthcare workers, social workers and public transportation operators.

– Type III: Employee-on-Employee.

Employee-on-employee workplace violence occurs when the employee attacks his or her co-worker(s). It is important to note that contrary to the media representation of such crimes that this category makes up a small percentage of all workplace violence.  We associate this behavior with a disgruntled employee who is exacts their violence at the workplace and its employee(s).  Usually conflict arises from an unresolved dispute or disagreement that escalates. Because these incidents involve supervisors and managers they are at greater risk of being victims of this category of workplace violence. As stated above, no workplace is immune from this category of workplace violence. It requires an ongoing effort involving multiple intervention strategies and proactive leadership and supervision.

– Type IV: Personal Relationship.

Personal relationship workplace violence occurs when the employee has a personal relationship with the perpetrator of violence.  This category is typified by domestic violence and/or what is commonly referred to as intimate partner violence.  Perpetrators of this type of violence are not typically employees or former employees. This is an area where workplaces might desire to pursue innovative approaches to mitigating risks. Workplaces might consider providing whatever assistance can be offered in creating a comfortable and supportive workplace setting.  I was once told by a victim whose husband assaulted her in the employee parking lot, “that had she felt comfortable and trusting of her supervisors perhaps better protective measures could have been introduced to secure the parking lot.” Employees who are victims of domestic violence or intimate partner violence should be encouraged to take appropriate measures and to inform their supervisors when the court issues any type of restraining order. Workplaces should not dismiss the potential risk associated by not taking proactive measures with this type of violence.  All too often unaware employees make assumptions that allow access to disgruntled persons that ultimately compromise workplace access controls. Protecting against the workplace violence spillover from this type of workplace violence is imperative and must be discussed and included in workplace violence prevention training.

While the OSHA Act (Occupational Safety and Health Act) has introduced stricter enforcement instructions to their enforcement personnel, workplaces must not wait around to be sanctioned. They can show initiative in implementing proactive workplace violence prevention and violence response risk mitigation procedures and plans.  Recently OSHA has sent a definite signal to workplaces that it is going after those blatant workplaces that fail to take corrective action in rectifying known hazards or risks that contribute to violence or place employees at risk of violence.

Companies that do not always have the dedicated resources should not consider themselves excused or immune from taking risk mitigation measures.  Regardless of the real or perceived limitations, comprehensive workplace violence prevention strategies can be enhanced by integrating, collaborating and coordinating resources in  maximizing the effort. This methodology allows for an organizational response by non-security personnel. The objective of a comprehensive workplace violence prevention initiative is to create an “early warning system” based on a unified process that aligns organizational resources in combating the threat of violence.  The idea is to develop holistic workplace violence prevention strategies, processes and methods that bridge the gap between confusion, myths, complex theories and practical applications for employees and supervisors in all organizations to feel comfortable relying on each other.  The goal is to be in a position to share information at the right levels tied to credible reporting and monitoring of employee reports, complaints and observations.  

Developing a comprehensive workplace violence prevention policy/plan starts with a senior management commitment and investment in workforce safety and security usually in the form of the policy and its support.  It requires undertaking a work-site specific analysis and establishing an accountable and credible reporting system. Employers should not wait to be surprised by a serious incident, they should analyze records and maintain good reporting records. To avoid assumptions and make correlations employers are encouraged to review past incident reports and even review employee complaints relative to the unintentional consequences of policy, supervision and decisions as contributing factors. Do not assume a particular departments, supervisor or manager and activities cannot be responsible for creating conflict or increasing tensions.  In short, the organizational culture is not immune from scrutiny if it can help in identify contributing factors in preventing workplace violence.

Considering your organizational capabilities and/or imitations, workplaces can be proactive in preventing workplace violence by enhancing physical security, visitor management and access controls. Risk mitigation measure can involve “engineering controls” to enhance physical security and access controls by attempting to remove workplace violence hazards or creating barriers between the worker and the hazard or threat. Examples of “engineering controls can include installation and maintenance of partitions, controlled entry and waiting areas, alarm systems, security devices, panic buttons, hand-held alarms and noise devices.  Alert, Notification and Communications systems play a significant role during a serious threat of workplace violence such as in the case of an armed intruder.  “Administrative controls” can also play a vital part in workplace violence prevention through the establishment of parameters, identifying responsibilities and establishing accountable behavior.  Deployment of uniform security personnel can be considered in certain situations.

In closing, a comprehensive workplace violence prevention policy and violence response initiative will never be realized without investing in proper and relevant initial and ongoing training for all employees, supervisors and managers. For maximum value, the topics and content should be audience specific.  Helping to make your workplace safer from the threat of a homicidal act of workplace violence requires that we dispel myths and prepare for the “when” and not the “if”.  We can improve our chances by creating a workplace where the employee is treated with regard from “hiring to firing”.  

Remember, that following a time of crisis your most trusted employees will always be the most credible witnesses.  Don’t put them in an uncomfortable position of making the choice.  A comprehensive workplace violence prevention policy/plan relies on organizational empowerment as part of an ongoing process of  responsibility, accountability, proper supervision and effective leadership.