OSHA Recommendations to Reduce Risk of Workplace Violence

A combination of administrative controls and precautionary measures can greatly reduce the chance of violence at work.

According to the U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA), workplace violence is recognized as an occupational hazard in some industries. It may surprise some employers to learn that workplace violence has been among the top four causes of death at work for more than 15 years.

There are several factors that may increase the risk of violence at worksites, including working with the public or volatile, unstable people; working alone or in isolated areas; handling money and valuables; providing services and care; working where alcohol is served; and time of day and location of work, i.e. working late at night or in areas with high crime rates.

According to OSHA, four classifications describe the relationship between the perpetrator and the target of workplace violence.

1. Criminal. Violent acts by people who enter the workplace to commit a robbery or other crime, or current or former employees who enter the workplace with the intent to commit a crime.
2. Customer/Client/Patient. Violence directed at employees by customers, clients, patients, students, inmates or any others to whom the employer provides a service.
3. Co-worker. Violence against co-workers, supervisors or managers by a current or former employee, supervisor or manager.
4. Personal. Violence in the workplace by someone who does not work there, but who is known to or has a personal relationship with an employee.

Be Aware of Your Risk
OSHA has identified industries at particularly high risk of workplace violence, which include healthcare and social service settings (psychiatric facilities, hospital emergency departments, mental health clinics, drug treatment clinics, residential and long-term care facilities, etc.) and late-night retail settings (convenience stores, liquor stores, gas stations, etc.). It offers these general safety recommendations for all workplaces:

• Conduct a workplace violence hazard analysis (including analyzing vehicles used to transport clients).
• Assess any plans for new construction or physical changes to the facility or workplace to eliminate or reduce security hazards.
• Provide employees with training on workplace violence.
• Implement engineering controls, such as:
  • Install and regularly maintain alarm systems and other security devices where risk is apparent or may be anticipated. Arrange for a reliable response system when an alarm is triggered.
  • Provide metal detectors—installed or hand-held, where appropriate—to detect guns, knives or other weapons. 
  • Use a closed-circuit recording on a 24-hour basis in high-risk areas. 
  • Place curved mirrors at hallway intersections or concealed areas. 
  • Lock all unused doors to limit access, in accordance with local fire codes. 
  • Install bright, effective lighting both indoors and outdoors. » Replace burnt-out lights and broken windows and locks. 
  • Keep automobiles well maintained if they are used in the field, and locked at all times.
• Implement administrative controls to reduce exposure to hazards, such as: 
  • Establish liaisons with local police and state prosecutors. Report all incidents of violence, and give police physical layouts of facilities to expedite investigations.
  • Require employees to report all assaults or threats to a supervisor. Keep log books and reports of such incidents to help determine necessary actions to prevent recurrences.
  • Advise employees of company procedures for requesting police assistance or filing charges when assaulted and help them do so, if necessary.
• Provide management support during emergencies and respond promptly to all complaints.
  • Set up a trained response team to respond to emergencies.
  • Use properly trained security officers to deal with aggressive behavior.
  • Follow written security procedures.
• Develop a written, comprehensive workplace violence prevention program, which includes:
  • A policy statement and assignment of oversight and prevention responsibilities.
  • A workplace violence hazard assessment and security analysis, including a list of the risk factors identified and how the employer will address them.
  • Development of workplace violence controls, including implementation of engineering and administrative controls and methods to prevent workplace violence incidents.
  • A recordkeeping system designed to report any violent incidents.
  • Development of a workplace violence training program that includes a written outline or lesson plan.
  • Annual review of the program, which should be updated as necessary. Such review and updates shall set forth any mitigating steps taken in response to any workplace violence incidents.
  • Development of procedures and responsibilities to be taken in the event of a violent incident in the workplace.
  • Development of a response team responsible for immediate care of victims, re-establishment of work areas and processes, and debriefing sessions with victims and coworkers.

Employee assistance programs, human resource professionals and local mental health and emergency service personnel should be contacted for input in developing these strategies.

Reducing Risk in Retail
Additional recommendations for the retail industry include:

• Limit window signs to low or high locations, and keep shelving low so workers can see incoming customers and police can observe what is occurring from the outside of the store.
• Ensure that the customer service and cash register areas are visible from outside the establishment.
• Use door detectors so workers are alerted when someone enters the store.
• Have height markers on exit doors to help witnesses provide more accurate descriptions of assailants.
• Install fences and other structures to direct the flow of customer traffic into and around the store.
• Control access to the store with door entry (buzzer) systems.
• Install physical barriers between customers and workers, such as bullet-resistant enclosures with pass-through windows.
• Use drop safes to limit the availability of cash to cashiers and post signs stating that fact.
• Use a panic button and responsive staff or another system that can be used to call for backup assistance.
• Use an x-ray or other security screening to detect and prevent weapons from being brought into the facility.

Minimize risk through administrative and work practice controls, such as:

• Integrate violence prevention activities into daily procedures, like checking lighting, locks and security cameras to help maintain a secure worksite.
• Develop and implement procedures for the correct use of physical barriers, such as enclosures and pass-through windows.
• Establish a policy of when doors should be locked. Require workers to keep doors locked before and after official business hours, and to lock doors not in use.
• Require that deliveries be made during normal daytime operations.
• Develop and implement emergency procedures for workers to use in case of a robbery or security breach, such as calling the police or triggering an alarm.
• Train all staff to recognize and defuse verbal abuse that can escalate to physically combative behavior.

Reducing Risk in Healthcare and Social Services
Additional recommendations for healthcare and social services facilities include:

• Enclose nurses’ stations and install deep service counters or bullet-resistant, shatter-proof glass in reception, triage and admitting areas or client service rooms.
• Provide employee “safe rooms” for use during emergencies.
• Establish “time-out” or seclusion areas with high ceilings and without grids for patients who “act out,” and establish separate rooms for criminal patients.
• Provide comfortable waiting rooms designed to minimize stress.
• Ensure that counseling or patient care rooms have two exits.
• Lock doors to staff counseling and treatment rooms to limit access.
• Arrange furniture to prevent entrapment of staff.
• Use minimal furniture in interview rooms or crisis treatment areas, and ensure that it is lightweight, without sharp corners or edges and affixed to the floor, if possible. Limit the number of pictures, vases, ashtrays or other items that could be used as weapons.
• Provide secure and lockable bathrooms for staff members separate from patient/client and visitor facilities.
• Install partitions in transport vehicles to protect drivers from aggressive patients or clients.

Minimize risk through administrative and work practice controls, such as:

• State clearly to patients, clients and employees that violence is not permitted or tolerated.
• Ensure that properly trained staff is available to restrain patients or clients, if necessary.
• Provide timely information to people waiting in line or in waiting rooms. Adopt measures to decrease waiting times.
• Ensure that adequate and qualified staff is available at all times. The greatest risk occurs during patient transfers, emergency responses, mealtimes and at night. Areas with the greatest risk include admission units and crisis or acute care units.
• Institute a sign-in procedure with passes for visitors, especially in a newborn nursery or pediatric department, and enforce visitor hours.
• Establish a list of “restricted visitors” for patients with a history of violence, and make copies available at security checkpoints, nurses’ stations and visitor sign-in areas.
• Review and revise visitor check systems when necessary. Limit information given to outsiders about hospitalized victims of violence.
• Supervise the movement of psychiatric clients and patients throughout the facility.
• Control access to facilities other than waiting rooms, particularly drug storage or pharmacy areas.
• Prohibit employees from working alone in emergency areas or walk-in clinics, particularly at night or when assistance is unavailable. 
• Establish policies and procedures for secured areas and emergency evacuations.
• Determine the behavioral history of new patients to learn about any past violent behaviors.
• Establish a system to identify patients with assaultive behavior problems. Keep in mind patient confidentiality and worker safety issues. Update as needed. Review any workplace violence incidents from the previous shift during change-in-shift meetings.
• Treat and interview aggressive or agitated clients in relatively open areas that still maintain privacy and confidentiality, such as rooms with removable partitions.
• Prepare contingency plans to treat clients who are “acting out” or making verbal or physical attacks or threats. Consider using certified employee assistance professionals or in-house social service or occupational health service staff to help diffuse client anger.
• Transfer assaultive clients to acute care units, criminal units or other more restrictive settings.
• Ensure that nurses, physicians and other clinicians are not alone when performing intimate physical examinations of patients.
• Discourage employees from wearing necklaces or chains to help prevent possible strangulation in confrontational situations. Urge workers to carry only required identification and money.
• Survey the facility periodically to remove tools or possessions left by visitors or maintenance staff that could be used inappropriately by patients.
• Provide staff with identification badges, preferably without last names, to readily verify employment.
• Discourage employees from carrying keys, pens or other items that could be used as weapons.
• Provide staff members with security escorts to parking areas in evening or late hours. Ensure that parking areas are highly visible, well-lit and safely accessible to the building.
• Use the “buddy system,” especially when personal safety may be threatened. Encourage home healthcare providers, social service workers and others to avoid threatening situations.
• Advise staff to exercise extra care in elevators, stairwells and unfamiliar residences. Leave the premises immediately if there is a hazardous situation; or request police escort, if needed.
• Develop policies and procedures covering home healthcare providers, such as how visits will be conducted, the presence of others in the home during visits, and the refusal to provide services in a clearly hazardous situation.
• Establish a daily work plan for staff to keep a designated contact person informed about their whereabouts throughout the workday. Have the contact person follow up if an employee does not report in as expected.

OSHA may fine employers in violation of the so-called “general duty clause” if they fail to reduce or eliminate serious recognized hazards. OSHA inspectors will gather evidence to determine whether an employer recognized, either individually or through its industry, the existence of a potential workplace violence hazard affecting its employees. iBi

Michael R. Lied is an attorney with Howard & Howard PLLC, located at One Technology Plaza, Suite 600 in Peoria. He can be reached at (309) 672-1483 or [email protected].