Analyze potential workplace hazards.

A significant portion of the OSHA directive encourages field officers to investigate the employer’s recognition of the risk for workplace violence. Employers are encouraged to conduct assessments of the risk of workplace violence at their job sites. A simple walk-through of a workplace can reveal potential workplace hazards. For example, employers should look for items such as burnt out lights in an isolated parking lot or a broken door lock.

OSHA says that employers should be aware of potential workplace hazards because of specific past incidents, characteristics of the employer’s facility, or general industry-wide knowledge of the potential of workplace violence. Employers in the health care, social services, and late-night retail industries should pay particular attention to potential risks, as OSHA will likely deem these industries to be on notice of the potential for workplace violence in light of OSHA’s published guidance. Employers will also be deemed to know that a workplace is prone to violence if multiple incidents of violence have occurred in the past. The directive instructs field officers to look beyond OSHA-reported events. Field officers are encouraged to evaluate workers’ compensation records, insurance reports, police reports, security reports, first-aid logs, and accident logs in order to determine whether or not an employer had notice that violence was a hazard of the workplace. Additionally, employee complaints may cause OSHA to conclude that the employer knew of potential hazards at the workplace. Employers should note employees’ concerns about workplace violence and analyze whether or not a complaint presents a legitimate risk that the employer should seek to remedy.

Implement reasonable safety mechanisms.

Once an employer has completed an analysis of the potential hazards related to workplace violence, OSHA posits that the employer should take reasonable steps to implement safety mechanisms to minimize or eliminate those risks. Determine whether there are simple changes that can be made to minimize potential risks, such as adding lighting or replacing light bulbs in dimly lit areas. For workplaces in high crime areas, consider limiting access to facilities by adding locks to doors or installing security alarm systems. Employers should take care to document the potential hazards and the steps that were taken to minimize the risk of such hazards.

Employers should also consider whether or not a formal workplace violence prevention program is appropriate (Violence prevention programs are not mandated by federal law, but California, Illinois, Maine, New Jersey, New York, Oregon, Washington, and West Virginia all require various forms of such programs for all or certain kinds of employers.) Illinois law, for example, requires health care workplaces to adopt and implement a violence prevention plan which addresses potential hazards in the specific workplace. The OSHA directive outlines several items it analyzes in looking at workplace directives: a description of the potential violence, identification of those with prevention responsibilities, documented hazard assessment, a documented record-keeping system, a training program with written lesson plans and training materials, a mechanism for periodic review of the prevention program, and an identified response team. A formal violence prevention program may not be practical for all workplaces; however, employers should consider whether a simple version could be implemented in their organization.