3 Key Insights for Instituting a Workplace Violence Prevention Program in Compliance with SB 553
Workplace Violence | Threat Management Assessment
With over 2 million reported incidents of workplace violence annually in the U.S., as documented by the Occupational Safety and Health Administration (OSHA), it’s an issue that’s impossible for organizations to ignore. Affecting all industries and growing in complexity with the increase in remote and hybrid work from COVID-19, it’s crucial to adopt proactive measures to swiftly identify and manage threats before they escalate.
California is the first state to take state-level action to address the rise in Workplace Violence by passing Senate Bill (“SB”) 553 on May 31, 2023. When this bill goes into effect on July 1st of 2024, every employer with 10 or more employees will be mandated to develop and maintain written prevention plans tailored to their specific workplaces.
What’s at stake if organizations fail to comply?
Organizations across California are scrambling to put together measures and document incidents to comply, as the cost of not complying is extremely high from a financial and reputational standpoint. Fines will likely range from $18,000 to $25,000 per incident and, in more severe cases, can result in legal action and revocation of permits or licenses needed to operate as a business.
Not to mention the overarching ‘duty of care’ that security teams and employers face — their legal obligation to provide a safe environment and protect employees from harm. “A work environment that doesn’t address workplace violence risk will conceal issues that will negatively impact employees’ morale, productivity and retention, consequently impacting business operations.” (Security Magazine)
What measures does SB 553 require?
Beneath the surface of SB 553’s directive for employers to develop and maintain written workplace violence prevention plans, what exactly does it entail? (source: California Legislative Information Bill Analysis) Here are four core areas to be aware of:
- Dedicated employee training program — Employers must coordinate the implementation of the Workplace Violence Prevention Plan (WVPP) and ensure that employers and employees understand their respective roles, including training and incidents logging. Additionally, retaliation is prohibited against an employee making a report.
- Designate an employee to oversee the program — Employers must assign an on-site staff member to oversee the training, ensuring it’s reviewed and updated regularly (at least annually). The names or job titles of the persons responsible for implementing the WVPP should also be included.
- System of record for managing incidents — Employers are required to maintain detailed records of workplace violence occurrences for a mandatory five-year period. These records, containing comprehensive incident descriptions, must be accessible to the division, as well as to employees and their representatives for examination and copying.
- Effective procedures for incident response — Employers must have protocols in place to respond to workplace violence emergencies, including aspects such as: efficient methods to notify employees, evacuation or sheltering strategies, procedures for alerting designated emergency response personnel, if available, and coordination with law enforcement agencies.
Selecting a vendor to manage Workplace Violence Prevention
The volume of incidents reported today demands a holistic approach that not only captures occurrences of workplace violence but provides leaders with the tools and resources needed to assess their severity and manage the case over time.
“Many organizations utilize a combination of Excel spreadsheets or saved Word documents, and even handwritten notes in some instances, that aren’t connected or consistent,” Michael Rozin, President and Co-Founder of Rozin Security Consulting, shares when initially assessing clients’ baseline for establishing a workplace violence prevention plan.
Without a system in place to connect the dots, the ability to identify patterns and progression toward the Pathway to Violence, behaviors are often overlooked or under-investigated. Here are a few areas to look for when assessing your process for workplace violence prevention standards and how Rozin can help:
1. Implement an Actionable Workplace Violence Training Program
Relying on a training program tailored to an organization’s environment, even down to the site level, provides a needed sense of control when something goes sideways. Figuring out a plan of action while an event is unfolding is a recipe for disaster.
Rozin Security has been partnering with clients for years on designing and implementing a training plan that works for an organizations’ unique needs and can be easily adopted by employees. The SIRA® (Suspicion Indicators Recognition and Assessment) system was developed by Rozin Security and helps clients detect workplace violence threats through methods such as field deployment techniques and security interviewing. Areas they are especially adept at managing are screening for concerning behavior, identifying resources to monitor active threats, and intervening when there is danger on the horizon.
2. Collect and Centralize Reporting for Workplace Violence Incidents
Having one centralized source for collecting information and generating reporting and analysis of active cases at a moment’s notice is a necessity for all organizations, but especially those in California with the upcoming legislation.
Rozin Technology’s TIPS® software (Threat Information Protection System) is a cutting edge proactive physical security platform that enables organizations to collect and centralize reporting, storage, analysis of incidents and threat information. As a result, organizations can recognize patterns in behavior and more accurately predict and act on evolving risks.
TIPS is also integrated with industry-leading structured professional judgement (SPJ) tools, such as WAVR-21, for users determine what poses an actual risk and what can be pushed aside based on real data.
3. Holistically Assess and Manage Cases with Potential of Targeted Violence
Workplace violence cases are rarely one and done events. The ability to proactively identify and manage potential workplace violence incidents empowers employees at all levels to focus on their work and not get sidetracked.
Rozin Security can partner with your organization to perform a threat assessment, ongoing analysis of social media accounts to observe actors’ activities, communications, disposition, and communication to develop a threat management plan. They can also implement layered security measures, including security technology, physical and operational measures.
This level of protection involves a company-wide effort and Rozin has experience providing security consulting services to ensure multiple departments are engaged in redesigning physical security measures, security operations, and the technology that supports them.
Frequently Asked Questions
This upcoming SB 553 is a lot to take in for organizations in California and beyond, as the state is often seen as a catalyst for future legislation. Below Rozin has addressed some of the more common questions on employer’s minds:
1. Rozin has clients in California. How are you advising them to prepare for this bill (SB 553) to take effect in a few months (July 1)?
This bill is significant since it requires any business with 10 or more employees to make workplace violence prevention measures part of their operations. It’s also mandated (not optional) and when executed July 1, and there’s not much left for interpretation of what’s required.
The good thing is Rozin has been offering workplace violence prevention training now for years, so this is not new territory for us. We have been evolving it and making it better and better. The combination of Rozin Security and Rozin Technology provides everything needed to make just about any employer compliant.
We’ve been talking to a number of clients about putting together a workplace violence prevention plan, including how to educate employees on what to report, how to report it, when to report it, and then talking with HR teams on how to manage these reports.
2. Share some common oversights you observe as companies organize their WPV training and documentation.
I’ve observed a huge gap between what this bill requires employers to do versus what the concept of workplace violence entails. What I see often is organizations slapping together an emergency response plan — showing a video and assuming they’re covered.
Many utilize a combination of Excel spreadsheets or saved Word documents that aren’t connected or consistent. It turns into a mess when it comes time to create a report. I’ve even seen handwritten notes from HR managers that are put in a folder or binder. Having a system in place that automatically connects these pieces of information and recognizes how they apply to the pathway to violence is critical.
3. What makes Rozin’s Platform (TIPS) different from other incident reporting platforms?
Many tools on the market have a lot of features and they’re designed for advanced users and can feel overwhelming to others. TIPS is designed to be very clean and simple to understand so there’s no barrier to taking action and reporting incidents.
TIPS is also integrated with industry-leading professional judgment (SPJ) tools — WAVR-21v.3, HCR-20 V3; SARA-V3; AVRT, and SDV — so users can figure out to what extent there’s an actual risk of violence. Research shows us that there’s always a Pathway to Violence, or a progression of behavior that leads to an incident. People who are not trained have trouble differentiating if something is serious or can be addressed later in the week.
TIPS will connect what’s in the system to determine the pattern of behavior and the degree of severity. From a reporting perspective, the tool can generate an audit trail of activity and analysis at the click of a button. Reports can be tailored to the customer and display a limited or complete view of information, depending on what’s important to the viewer. This is especially important as the SB 553 Bill requires organizations to keep easily accessible records of all activities related to workplace violence training, incident reports, and plan evaluations.
4. What’s next on the horizon in the realm of WPV? (Are other states following California’s lead?)
I think this is just the beginning of what we’ll see. Connecticut, Illinois, Maryland, New Jersey, Oregon, and Washington have similar bills in progress. Workplace Violence is unfortunately on the rise.
California is changing the landscape when it comes to legislation in these critical areas of need, and it is often viewed as a catalyst for other areas of the country.
For more information on how Rozin Security can address your Workplace Violence and SB 553 concerns, contact our team.