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:

* will provide adequate authority and budgetary resources to responsible parties so that identified goals and assigned responsibilities can be met;

* includes and encourages employee participation in the design and implementation of its workplace violence prevention program;

* refuses to tolerate violence at the workplace, and has developed and implemented a program to reduce incidents of violence;

* applies workplace violence policies consistently and fairly to all employees, including supervisors and managers.

* requires prompt and accurate reporting of violent incidents, whether or not physical injury has occurred;

* will not discriminate against victims of workplace violence.

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: 

* recommending/implementing employee training programs on workplace violence; 

* implementing plans for responding to acts of violence; 

* communicating internally with employees. 

Threat Assessment Team membership should include representatives of the following: 

* senior management;

* operations;

* employees or their representatives;

* security;

* finance;

* legal;

* human resources.

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: 

* Appropriate required records

* Incident reports

* Records of, or information compiled for recording of, assault incidents or near assault incidents 

* Medical records

* Insurance records

* Workers Compensation records

* Police reports

* Accident investigations

* Training records

* Grievances

* Other relevant records or information (i.e. minutes of meetings, etc.)

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: 

* general building, work station and area design, security measures; 

* security equipment; 

* work practice controls and procedures;

* workplace violence prevention Policy Statement. 

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:

* Review the design of all new or renovated facilities to ensure safe and secure conditions for employees. Ensure
that facilities are designed to ensure the privacy of patients, clients and customers, yet permit employees to
communicate with other staff in emergency situations.  (Such communication could be via clear partitions, video
cameras, speakers or alarms, etc. as appropriate to the workplace situation.)

* Design work areas and arrange furniture to prevent entrapment of the employees and/or minimize potential for
assault incidents.

* Control access to employee work areas. (Use of locked doors, buzzers, card access, etc.) 

* Provide appropriate lighting systems for all indoor building areas as well as grounds around the facility and
in parking areas. Lighting should meet the requirements of nationally recognized standards such as ANSI A-85,
ANSI/IES RP-7 1983, ANSI/IES RP-1 1993; as well as local building codes. 

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:

* Utilize Electronic Alarm Systems activated visually or audibly. Systems should identify the location of the
room or location of the employee by means of an alarm sound and/or a lighted indicator or equally effective
measure. Adequate personnel must be available to render prompt assistance if such systems are utilized.

* Utilize Closed Circuit Television which permit security guards to monitor high risk areas, both inside and
outside the building. 

* Utilize Metal Detection Systems to identify persons with weapons. 

* Utilize cellular telephones, beepers, CB radios or hand-held alarms or noise devices in field situations. 

* Examine and maintain security equipment on a regular basis to ensure it effectiveness.

Work practice controls and procedures:

* Provide identification cards for all employees, and establish sign-in and sign-out books, and escort policy
for non-employees. When identification badges are provided, employees should be required to wear them. 

* Base staffing consideration on safety and security assessment. (Fixed site and field locations.) 

* Develop internal communication systems to respond to emergencies. 

* Develop policy on how to deal in emergency or hostage situations.

* Develop and implement security procedures for: 

* employees who work late or off hours;

* accounting for field staff;

* when to involve in-house security or local law enforcement in an assault incident;

* banning weapons in facilities unless authorized; and

* how the employer will respond to assault incidents.

* Develop written procedures for employees to follow when entering any locations where they feel threatened or
unsafe.

* Provide information and give assistance to employees who are victims of domestic violence and develop procedures to ensure confidentiality and safety for affected employees.

* Train employees on awareness, avoidance, and action to take to prevent mugging, robbery, rapes and other
assaults.

* Modify existing work practices that are identified by the hazard assessment where employees face increased risk of violence.

EMPLOYEE TRAINING AND EDUCATION

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

* techniques for recognizing the potential for violence; 

* procedures, policies and work environment arrangements developed to control the risk to workers; 

* proper use of security hardware;

* the appropriate response to incidents of violence, including emergency and hostage situations; 

* how to obtain medical assistance and follow-up; and

* procedures for reporting, investigating and documenting incidents of violence;

* travel safety;

* cash handling procedures.

Effective training:

* should be given on company time,

* uses easily understood terminology, 

* is given in languages spoken by the employees, 

* provides sufficient time for questions and answers,

* is conducted by trainers knowledgeable or qualified in their field of expertise,

* is conducted before taking a new job assignment, annually or when laws or procedures change.

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:

* report it to the local police department;

* secure work areas where disturbances occurred;

* ensure the physical safety of employees and others remaining in the area as soon as possible; 

* ensure that no work area is left short-staffed while others assist the victim or help in securing the area; 

* quickly assess the work area, if it was disturbed or damaged during an incident, to determine if it is safe; 

* provide critical incident debriefing to victims, witnesses and other affected employees; these conversations must be strictly confidential.

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:

* collect facts on who, what, when, where and how the incident occurred; 

* record information; 

* identify contributing causes;

* recommend corrective action;

* encourage appropriate follow-up; 

* consider changes in controls, procedures, policy.

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.

RECORD KEEPING

An effective record keeping 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: 

* Regulations require entry on the Injury and Illness log of any injury which requires more than first aid, causes loss of consciousness, requires modified duty, or results in lost time from work. Assaults should be entered on the log. Doctors' reports of work injury and supervisors' reports shall be kept of each recorded assault. Fatalities or catastrophes(8) must be reported.
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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.

* Incidents of assaults - should describe who was assaulted, the type of activity, (i.e. unprovoked sudden attack), and all other circumstances of the incident. The records should include a description of the location/environment, potential or actual costs, lost time, nature of injuries sustained, etc.

* Incidents of abuse, verbal attacks or aggressive behavior - Any acts of aggression should be recorded; they may be threatening to the worker, but may not result in injury, (i.e. pushing or shouting). These records may be assault incident reports that are evaluated routinely by the Threat Assessment Team.

* Minutes of safety meetings and inspection reports - that contain findings, corrective actions recommended relative to workplace violence, along with company's response and completion dates for action items. 

* Training records - which should include dates the training was conducted, type of training given, employees trained, etc.

* Inspection records - which should include dates of inspection, areas inspected, all findings and recommendations, any control measures implemented, etc.

* Employee questionnaires - that assess their views of high risk work areas and activities.

* Insurance records

* Workers' Compensation Records

* Medical records