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For many years, OSHA has stressed the need for enhanced workplace violence policies to protect health care and social service workers. The agency released guidelines for workplace violence prevention in the health care and social services industries in both 1996 and 2004, recognizing that caregivers are at an increased risk of unpredictable, violent behavior from the very people whom they provide care to. In spite of these efforts, violence in health care and social service workplaces continues to rise. In 2013, the Bureau of Labor Statistics reported more than 23,000 serious injuries due to assault at work. More than 70 percent of those assaults took place in health care or social service settings. Health care and social service workers are almost four times more likely than the average private sector worker to be injured as a result of an assault.
Re-emphasizing its commitment to reducing this risk, OSHA published its revised Guidelines for Preventing Workplace Violence for Healthcare and Social Service Workers on April 2, 2015. The revised guidelines are significantly more comprehensive than those released by the agency in the past, and they include a number of tools, such as a workplace violence prevention program checklist, to enable employers to more easily navigate and implement OSHA’s suggested strategies.
The new guidance calls for a five-part program consisting of:
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management commitment and worker participation—OSHA deems management responsible for controlling hazards by, among other things, urging all levels of management to become deeply involved in all aspects of the workplace violence prevention program, and worker participation should be required because workers can help identify and assess workplace hazards;
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worksite analysis and hazard identification—management and workers are called upon to work together to assess records, existing procedures, and operations for jobs, employee surveys, and workplace security analyses;
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hazard prevention and control—after the worksite analysis is complete, employers should take appropriate steps to prevent or control the identified hazards and periodically evaluate the effectiveness of the chosen controls and improve, expand, or update them, as needed;
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safety and health training—all workers (including contractors and temporary employees) should receive training on the workplace violence prevention program at least annually and, in particularly high-risk settings, as often as monthly or quarterly to effectively reach and inform all workers; and
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recordkeeping and program evaluation—OSHA logs of Work-Related Injuries and Illnesses (OSHA Form 300), worker injury reports, information regarding patients with a history of violence, and other documents reflecting trends or patterns at the workplace should be studied and the effectiveness of the workplace violence prevention program should be frequently evaluated and improved, as necessary.
Although there is no formal OSHA standard regarding workplace violence, the agency has invested significant resources into providing health care and social service employers with an all-encompassing set of guidelines to enable these employers to create high-quality workplace violence prevention programs. OSHA has already announced that it intends to increase enforcement efforts in the health care and social services industries in the coming year. If OSHA conducts an inspection and finds that an employer’s workplace violence prevention program is lacking, the agency could issue the employer a citation under the General Duty Clause for failing to provide workers with a safe and healthy work environment.
Accordingly, health care and social service employers are well advised to review OSHA’s new guidelines and to work closely with employees to develop a program appropriate for their worksites. Taking this step will provide critically important protection for employees, increase employee engagement in safety and health efforts, and reduce the possibility of receiving a citation for an inadequate workplace violence prevention program.
