Developing a Violence Prevention Program

Oregon OSHA Online Course 120

This material is for training purposes only. Its purpose is to inform Oregon employers of best practices in occupational safety and health and general Oregon OSHA compliance requirements. This material is not a substitute for any provision of the Oregon Safety Employment Act or any standards issued by Oregon OSHA. For more information on this online course and other OR-OSHA online training, visit the Online Course Catalog.

MODULE 2: WRITING A WVPP POLICY STATEMENT

Advantages of Written Policies

Once a workplace violence program is ready to be implemented, companies must decide whether to issue a written policy statement.

Company programs can also be implemented without a written policy statement. In these companies, employees are often given information about the program (especially whom to call) in training sessions, on posters, in newsletter articles, or by other similar methods. Note: Companies have an inherent right to take action against employees who engage in disruptive or threatening behavior whether or not they have issued a written policy statement. What are some of the advantages of formal policies?

• It informs employees that the violence policy covers intimidation, harassment, and other inappropriate behavior that threatens or frightens them;

• It encourages employees to report incidents;

• It informs employees whom to call; and

• It demonstrates senior management's commitment to dealing with reported incidents.

Policy Statement Contents

A workplace violence policy statement should convey that:

• All employees are responsible for maintaining a safe and healthful work environment;

• The policy covers not only acts of physical violence, but harassment, intimidation, and other disruptive behavior;

• The policy covers incidents involving all interactions between:

  • supervisor and employee

  • employee to employee

  • employee to supervisor

  • employee to non-employee

  • non-employee to employee;

• The company will respond appropriately to all reported incidents;

• The company will act to stop inappropriate behavior; and

• Supervisors and all of the departments involved in responding to incidents will be supported by company management in their efforts to deal with violent and potentially violent situations.

Recommended Approaches

Consider the following recommendations in developing your written policy statement:

Keep it brief. A written policy statement should be brief and simple. Implementation details can be provided in training and in more detailed backup documents. For example, roles and responsibilities of the various departments involved in responding to potentially dangerous situations can be outlined in memoranda of understanding or in operating manuals/instructions rather than in the written policy statement that is issued to all company employees. This approach gives company staff the flexibility they will need to deal creatively with these fluid, unpredictable situations.

Consider the disadvantages of using definitions. There are disadvantages to using definitions of terms such as violence, threats, and harassment in your written policy statement. Definitions can discourage employees from reporting incidents that they do not believe fall within the definition. The reporting system should not deter employees from reporting situations that frighten them. An employee knows a threat or intimidation or other disruptive behavior when he or she experiences it -- definitions are not necessary. If you want to clarify the scope of your organization's concept of one or more of the terms in the policy, you could use examples. For example, you may want to give examples of verbal and non-verbal intimidating behavior.

Another consideration is that definitions are often restrictive and may create legal problems in the future when you are taking disciplinary actions against the perpetrators of workplace violence. Use of definitions can make it more difficult to defend a case on appeal.

Be cautious with "Zero Tolerance." Consider that there could be negative consequences from using the term zero tolerance. It could create legal problems in the future when you are taking disciplinary actions against the perpetrators of workplace violence. Use of the term could make it more difficult to defend a case on appeal because a third party could conclude, however mistakenly and inappropriately, that the company has not considered a penalty appropriate for the particular offense.

There are other possible consequences. The term, "zero tolerance" might appear to eliminate any flexibility an company has in dealing with difficult situations even if this is not intended. Another undesirable side effect is that the appearance of inflexibility can discourage employees from reporting incidents because they do not want to get their coworker fired -- they just want the behavior stopped. This appearance of inflexibility also may discourage early intervention in potentially violent situations.

The sample policy below contains language that is similar to "zero tolerance," but takes care of the previously mentioned concerns. It says the company will not tolerate violent or disruptive behavior and then clarifies what that means by saying "that is, all reports of incidents will be taken seriously and dealt with appropriately."

Consult with Legal Counsel. Be sure to consult the company legal department or attorney for the legal implications of your draft policy.

You can't always prevent violence because violent incidents are sometimes unpredictable, but you can reduce the risk by planning ahead and being prepared to act swiftly to deal with threats, intimidation, and other disruptive behavior at an early stage.

So there you have it. Not everything you need to know, but it's a start. The only task left is the module quiz, so let's get to it.

Module Review Quiz

9. Companies have an inherent right to take action against employees who engage in disruptive or threatening behavior whether or not they have issued a written policy statement:

a. True
b. False

10. Which of the following is not listed in the text as an advantage of formal policies?

a. informs everyone on policy
b. tells everyone who to call
c. encourages incident reporting
d. demonstrates employee commitment

11. A workplace violence policy statement should convey that the policy covers only acts of physical violence:

a. True
b. False

12. Definitions of violence are often restrictive and may create legal problems.

a. True
b. False

13. According to the text, to clarify the scope of your organization's terms in the WVPP policy, you could:

a. define terms
b. use examples
c. limit definitions
c. use legal language

14. All of the following are considered negative consequences from using the "term zero tolerance," except:

a. could create legal problems
b. perceived as an unreasonable goal
c. limits flexibility
c. discourages intervention

Congratulations! You've finished Module 2. In Module Three we'll discuss designing prevention procedures. See you there!