AFTER A Long Beach Memorial Medical Center pharmacy technician shot and killed the pharmacy’s executive director and supervisor, then killed himself, Cal/OSHA cited the hospital for failing to address potential violence in the workplace in its Injury and Illness Prevention Program (IIPP).
The agency cited Long Beach Memorial for two alleged general violations of the IIPP and Emergency Action Plan standards. Cal/OSHA investigators found several deficiencies in the hospital’s IIPP (General Industry Safety Orders §3203), including failure to have procedures for identifying and evaluating potential threats.
While this kind of workplace violence is rare, it does happen on occasion. To ensure you can best protect your employees, comply with OSHA standards and also reduce the economic fallout of a violent incident, you need to make sure your IIPP addresses potential violence.
This program should include procedures for handling a potentially violent situation, in addition to prevention.
Some of the fallout from workplace violence can include physical injuries, destruction of property, substantial potential liability and an immense impact on the morale and continuing operation of the workplace. In addition, OSHA inspectors will show up on your doorstep.
Research has shown that following an incident of workplace violence, a measurable loss of productivity will occur. This will affect every department, and not be limited to those directly impacted. Productivity may decline in the wake of an incident, and workers’ compensation claims and litigation may also follow.
The key to avoiding a crisis is good leadership. This means maintaining open communication with employees, setting clear standards, enforcing consistent personnel practices and promptly addressing employee concerns while they are manageable and before they can become major problems.
Employees should be encouraged to recognize that a problem is present. If someone overhears a co-worker talking about suicide, violence or vandalism, or empathizing with individuals who commit acts of violence or destruction of property, repeatedly talking about weapons, or expressing unreasonable fears or resentments, red flags should go up.
Injury and Illness Prevention Plan
All California employers are required to adopt an IIPP that includes workplace violence prevention.
A documented company policy must include:
• Definitions that clearly indicate what behaviors constitute workplace violence, including threatening or abusive physical and verbal behavior. Specify exactly what prohibited actions are and spell out the consequences of those actions.
• A review and response system for all reported violent incidents, along with guidelines to assist those with the responsibility to review and respond. (Sometimes this is best accomplished via a team approach.)
• Establishment of a process for reporting workplace violence or threats of violence.
• Specific procedures for reviewing each reported incident, and mechanisms to support and protect all affected persons. Require that reports are comprehensive.
• Effective follow-up procedures. Remember that poor follow-up can lead to negative worker perception of management commitment. Victims and recipients of threats or harassment expect a firm response.
Programs that discourage reporting or blame the victim will not likely be successful. At a minimum, the policy should be reviewed annually. Good communication, confidentiality, teamwork and accountability are musts.
Communication must flow vertically (management to staff, and vice-versa) and horizontally (i.e., across organizational divisions or departments). Communication can take many forms, and organizations should think outside the box when communicating information about workplace violence policies. For example, information about company policy can be communicated via inserts with pay stubs or on stickers for telephones.
Training for both managers and workers is a key element in any workplace violence prevention program. The presence of management at training sessions can increase the visibility of the organization’s top-level commitment to prevention.
In general, training (initially and on a recurring basis) should be provided on the hazards found in the organization’s workplaces and in the organization’s prevention policies and procedures, with emphasis on reporting requirements and the companys’ review, response and evaluation procedures.
Training can be implemented from the top down, with managers and supervisors trained first. A train-the-trainer approach can be used in larger organizations, with supervisors responsible for training and evaluating training for their own staff. Specialized training on creating a positive work environment and developing effective teams could be useful, as well as training to improve awareness of cultural differences (diversity) and to enable the development of workers’ cultural competence.