Cal/OSHA Provides Model Workplace Violence Prevention Plan Ahead of July 1, 2024 Implementation Deadline
On September 30, 2023, Governor Newsom signed into law Senate Bill 553 (SB 553), which mandates that nearly all California employers must implement a workplace violence prevention plan (WVPP) by July 1, 2024. For an overview of SB 553’s requirements, see our October Client Alert (California Employers Must Develop Workplace Violence Prevention Plans). With that deadline fast approaching, the California Department of Industrial Relations, Division of Occupational Safety and Health (Cal/OSHA) has finally published a model WVPP and fact sheet that provide additional guidance on SB 553’s laundry list of requirements.
SB 553 requires certain information in the WVPP, such as procedures related to the development, implementation, and review of the WVPP, and how to prevent, respond, and document workplace violence incidents. However, SB 553 requires more than just a compliant WVPP. For instance, upon implementation and annually thereafter, employers must provide training on various topics, including the WVPP itself; how to prevent, respond, and report workplace violence incidents; and workplace violence hazards specific to employees’ jobs. Employers must also record each incident of workplace violence and its investigation, and maintain hazard identification, evaluation, and correction records.
While the State’s Model WVPP is a resource, employers need to understand that the WVPP must be implemented and maintained, not merely established. Therefore, it is important that employers tailor their WVPP to their actual workplace and accurately represent the procedures that are, or will be put, in place. Failure to comply with the extensive requirements of SB 553 could result in penalties as high as $153,744 for each willful violation. Contact your Vorys lawyer if you have questions about creating your workplace violence prevention plan.