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 3: DESIGNING PREVENTION PROCEDURES

Introduction

After completing the initial workplace assessment for risk factors, and developing a written policy, the next step is to develop a comprehensive written Violence Prevention Plan. One major component of any workplace violence prevention plan is, of course, prevention. This module will focus on important subjects which should be included in the plan:

Identifying warning signs of violence, and
Control measures to reduce the probability or prevent violence

An employer may choose to create a separate workplace violence prevention plan or incorporate this information into other company documents: for example, the company's accident prevention plan or an employee handbook.

Warning Signs of Violence

One important element in the written violence prevention plan, and usually the first question many people ask is, How can we identify potentially violent individuals? It is understandable that people want to know this -- and that "profiles" and "early warning signs" of potentially violent employees are in much of the literature on the subject of workplace violence. It would save time and solve problems if managers could figure out ahead of time what behaviors and personality traits are predictive of future violent actions.

However, no one can predict human behavior and it's important to state in the plan that there is no specific profile of a potentially dangerous individual. It is seldom (if ever) advisable to rely on what are inappropriately referred to as "profiles" or "early warning signs" to predict violent behavior.

"Profiles" often suggest that people with certain characteristics, such as "loners" and "men in their forties," are potentially violent. This kind of categorization will not help you to predict violence, and it can lead to unfair and destructive stereotyping of employees.

The same can be said of reliance on "early warning signs" that include descriptions of problem situations such as "in therapy," "has had a death in the family," "suffers from mental illness," or "facing downsizing."

Indicators of potentially violent behavior

However, "indicators" of increased risk of violent behavior are available. These indicators have been identified by the Federal Bureau of Investigation's National Center for the Analysis of Violent Crime, Profiling and Behavioral Assessment Unit in its analysis of past incidents of workplace violence. These are some of the indicators:

Direct or veiled threats of harm;
Intimidating, belligerent, harassing, bullying, or other inappropriate and aggressive behavior;
Numerous conflicts with supervisors and other employees;
Bringing a weapon to the workplace, brandishing a weapon in the workplace, making inappropriate references to guns, or fascination with weapons;
Statements showing fascination with incidents of workplace violence, statements indicating approval of the use of violence to resolve a problem, or statements indicating identification with perpetrators of workplace homicides;
Statements indicating desperation (over family, financial, and other personal problems) to the point of contemplating suicide;
Drug/ alcohol abuse; and
Extreme changes in behaviors.

Describing inappropriate behaviors

The written violence prevention plan should list sample inappropriate behaviors and emphasize that they need to be dealt with immediately. These behaviors should not be tolerated in the workplace. Appropriate procedures should be stated in the written plan so that managers and fellow employees know what to do in case they observe or are the object of:

Unwelcome name-calling, obscene language, and other abusive behavior.
Intimidation through direct or veiled verbal threats.
Throwing objects in the workplace regardless of the size or type of object being thrown or whether a person is the target of the thrown object.
Physically touching another employee in an intimidating, malicious, or sexually harassing manner which includes such acts as hitting, slapping, poking, kicking, pinching, grabbing, pushing, etc.
Physically intimidating others including such acts as obscene gestures, getting “in your face,” and fist-shaking .

Be proactive: confront the problem early-on

Each of the behaviors noted above is a clear sign that something is wrong. None should be ignored. By identifying the problem and dealing with it appropriately, managers may be able to prevent violence from happening. The written plan appoint an appropriate staff member (or an incident response team) to assist supervisors and other employees in dealing with such situations. Some behaviors require immediate police or security involvement, others constitute actionable misconduct and require disciplinary action, and others indicate an immediate need for an Employee Assistance Program referral.

Everyone experiences stress, loss, or illness at some point in life. All but a very few people weather these storms without resorting to violence. The written plan should address training for managers on how to deal with the kinds of difficulties mentioned above. However, this training should focus on supporting the employee in the workplace, and not in the context of, or on the potential for, workplace violence.

Proactive control measures

The written violence prevention plan should describe proactive methods and means to limit or reduce the potential for workplace violence. The plan should direct regular risk assessments of facilities, and address areas where simple improvements can be made that would greatly increase the safety of employees and visitors. Once existing or potential hazards are identified through the hazard assessment, then hazard prevention and control measures can be identified and implemented. These measures may include (in order of general preference):

Engineering controls.

Engineer controls reduce or eliminate the hazard by redesigning, installing, substituting materials, equipment, machinery, workstations, etc. (things we use)in the workplace. Examples include:

Installing surveillance cameras, silent alarms, metal detectors, or bullet-proof glass.
Improved lighting in and around the place of work, including parking lots.
Having reception areas that can be locked to prevent outsiders from going into the offices when no receptionist is on duty.

Management controls.

Management controls attempt to reduce or eliminate exposure to hazards by developing safe/secure processes and procedures (things we do/don't do) in the workplace. Examples include:

Establishing sign-in procedures for visitors.
Pre-employment screening procedures to reduce the number of personnel prone to exhibiting violent behaviors
Developing employee assistance programs.
Arranging escorts for employees who are concerned about walking to and from the parking lot.

See more examples of engineering and management controls.

Personal protective equipment.

Equipment we wear to protect us from harm. Examples include: bullet-proof vests for police and security personnel.

Posting applicable laws, such as those prohibiting assaults and stalking, in visible locations may also serve as a prevention measure.

Prevention measures for each violence type

Consider using one or more of the following prevention measures that help design the workplace and develop procedures to reduce risk factors for violence.

Type I (Criminal Violence)Prevention Measures

Training (include de-escalation techniques appropriate to your industry)
Post signs stating cash register only contains minimal cash
Leave a clear, unobstructed view of cash register from street
Have a drop safe, limited access safe or comparable device
Address adequate outside lighting
Examine and address employee isolation factors
Provide security personnel
Communication method to alert police/security
Increase police patrol in the area
Post laws against assault, stalking or other violent acts

Potential Type II (Recipient of Service) Prevention Measures

Training (including de-escalation techniques appropriate to your industry)
Control access to worksite (e.g., posted restricted access, locked doors)
Examine and address employee isolation factors
Quick communication method to alert security
Eliminate easy access to potential weapons
Client referral/assistance programs
Set up worksite so employees are not trapped from exiting
Provide security personnel
Post laws against assault, stalking or other violent acts
Employee reporting systems

Potential Type III (Employment Relationship) Prevention Measures

Training (including de-escalation techniques appropriate to your industry)
Enforced "no tolerance" policy for workplace violence
Management strategy for layoffs
Management policy for disciplinary actions
Access to employee assistance program or other counseling services
Enforced policy prohibiting weapons
Provide security personnel
Post laws against assault, stalking or other violent acts
Restraining orders
Control access to worksite
Access to consultation with employer, employee assistance program or other counseling program
Reporting procedures
Relocating within worksite where possible
Necessary staff notification
Provide security personnel
Post laws against assault, stalking or other violent acts
Policy regarding restraining orders

Your assessment should include a regular review and maintenance of appropriate physical security measures, such as electronic access control systems, and video cameras, in a manner consistent with applicable state and federal laws. Don't overreact, not everybody needs metal detectors. Assess your risk factors for an accurate determination. If no money, drugs, or other high risk situations are present, detectors and cameras may be excessive.

More about Management Control Strategies

Companies need to have programs in place to assist troubled employees and address managerial problems before threats or violence occur.

Pre-Employment Screening. Use a job application form that includes an appropriate waiver and release (permitting the employer to verify the information reported on the application). Prior to hiring any applicant, check references and inquire about any prior incidents of violence. In addition, conduct thorough background checks and use drug screening to the extent practicable.

In developing an employee screening process, remember the Americans with Disabilities Act of l990 (ADA) and related state statutes prohibit employers from discriminating against qualified individuals with physical or mental disabilities. While federal law and judicial decisions provide that an employer may disqualify an employee who is a danger to self or others, the employer may be obliged to investigate a claim of disability to determine whether dismissal is necessary for the protection of the employee or others in the workplace.
Institute an Employee Assistance Program. Consider providing a confidential EAP to address substance abuse, emotional, marital, and financial problems, or provide employees with a list of relevant community resources. Employees, supervisors, and managers should be actively encouraged to use these services. If an employee is going to be facing termination, for whatever reason, transition services such as EAP counseling should be considered.
Incident reporting. Encourage victims of threats and violence outside the workplace to notify their employers about the incident when warranted so their employers can take appropriate measures to help protect them and their co-workers from possible future incidents of violence at the worksite. Upon notification, employers should provide receptionists and other front-line personnel, having a need to know, a description or picture of the alleged offender and inform them what actions they should take in the event that the individual seeks entry or contact.
Using Alternative Dispute Resolution (ADR). Some companies use ombudsman programs, facilitation, mediation, and other methods of alternative dispute resolution (ADR) as preventive strategies in their workplace violence programs. ADR approaches often involve a neutral third party who can assist disputing parties resolve disagreements. ADR is most helpful in workplace violence programs at the point when a problem first surfaces, i. e., before an employee's conduct rises to a level that warrants a disciplinary action. Review additional information on ADR.
Conduct effective exit interviews. Conduct exit interviews when employees retire, quit, or are transferred or terminated, to identify potential violence-related security or management problems.

Take a team approach

To facilitate developing an effective violence prevention plan that adequately addresses how to respond to potential and actual violent acts, a series of case studies are provided in this course. There you will find examples of the plans that were in place to handle a number of situations.

It will become apparent from reviewing these examples that plans for a coordinated response to reported incidents must be kept flexible. Responsibility for overall coordination and direction is usually assigned to one individual or one department. The coordinator must have the flexibility to use the plan as a guideline, not a mandatory set of procedures. More important, the coordinator must have the flexibility to tailor the recommended response to the particular situation. It is important to recognize that threatening situations often require creative responses. Given this, the importance of flexibility cannot be overemphasized.

The case studies highlight the need for backup plans in situations calling for an immediate response where the individual responsible for a certain aspect of the response effort has gone home for the day, is on vacation, or is out of the building at a meeting. Taking a team approach in responding to a potentially violent situation is an ideal way to provide backup coverage. A team approach ensures that all staff in Employee Relations, the Employee Assistance Program, Security, and other departments are thoroughly trained and prepared to work together with management to deal with potentially violent situations. It ensures coverage, regardless of which staffer in each of the departments is on duty when the incident occurs.

Take Advantage of Community Resources

Finally, there are many programs and resources in the community that can help you develop your workplace violence prevention plan. Some examples follow:

Invite local police into your firm to review the written violence prevention plan. They may also promote good relations and become more familiar with your facility. The police can explain what actions they typically take during incidents involving threats and violence. Such visits can help your firm work better with police when incidents do occur.
Use security experts to evaluate your written plan and educate employees on how to prevent violence in the workplace. Such experts can provide crime prevention information, conduct building security inspections, and teach employees how to avoid being a victim.
Consider using local associations and community organizations, such as the Chamber of Commerce, security organizations, and law enforcement groups, as a resource in order to stay abreast of crime trends and prevention techniques. Communicate to your employees those issues and trends which pose a significant threat.

Developing a written plan that clearly informs and directs is crucial to an effective violence prevention program. Now it's time to take the review quiz for this module, so let's get to it.

Module Review Quiz

15. It is ______________ advisable to rely on profiles or early warning signs to predict violent behavior.

a. always
b. usually
c. seldom
d. never

16. The FBI's Profiling and Behavioral Assessment Unit has identified all of the following as indicators of increased risk of violent behavior, except:

a. Direct or veiled threats of harm
b. Intimidating, belligerent, harassing, bullying
c. Subtle changes in behaviors
d. Statements indicating desperation

17. Installing surveillance cameras, silent alarms, metal detectors, or bullet-proof glass are examples of _______________.

a. Engineering controls
b. Management controls
c. Personal Protective Equipment
d. Interim measures

18. Management controls include all of the following except:

a. Improved lighting around parking lots
b. Establishing sign-in procedures for visitors
c. Developing employee assistance programs
d. Arranging escorts for employees

19. According to the text, it would be effective to consider using any one of the following prevention measures for Type I (Criminal Violence), except:

a. Training (include de-escalation techniques)
b. Obtain restraining orders
c. Leave a clear, unobstructed view of cash register from street
d. Post signs stating cash register only contains minimal cash
e. Examine and address employee isolation factors

20. According to the text, it would be effective to consider using any one of the following prevention measures for potential Type III (Employment Relationship) violence, except:

a. effective policy for disciplinary actions
b. provide security personnel
c. restraining orders
d. Post signs that cash register contains minimal cash

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