New OSHA Directive on Workplace Violence Investigations
Over the past several months, I have sent out several communiqués regarding OSHA's aggressive approach to incidents of workplace violence in healthcare facilities. This critical issue has now taken another turn, as OSHA has issued instructions to their field staff in how to investigate complaints of or incidents of workplace violence in healtchare and social service settings.
Attached is a .pdf of OSHA’s first directive, CPL 02-01-052, to OSHA field staff on Effective Procedures for Investigating or Inspecting Incidents of Workplace Violence. The directive provides uniform processes and procedures for OSHA field staff to use when “responding to incidents and complaints of workplace violence and conducting inspections in industries considered vulnerable to workplace violence, such as healthcare and social service settings, and late-night retail establishments.” The directive became effective on September 8th, 2011.
OSHA “strongly encouraged” individual states to adopt this directive to be used in conjunction with “their general duty clause, state-specific workplace violence standard, or other applicable authority under state law.” This is because “the directive is meant to provide guidance on both how an OSHA workplace violence case is developed and which steps Area Officers should take to assist employers in addressing the issue of workplace violence.”
The attached directive identifies factors that contribute to workplace violence, outlines what criteria will be used when considering whether to initiate an inspection, what to expect during a workplace violence-related OSHA inspection, etc. In addition to the directive, there is a newly launched OSHA web page on Workplace Violence which includes guidance on risk factors, prevention programs, training and other resources, etc.
Hopefully your hospital and/or long term care facility is moving aggressively to develop or refine your program, to include:
a) a written workplace violence prevention program,
b) appropriate risk specific training for affected staff (as opposed to canned, off-the-shelf programs),
c) documented drills and exercises designed to test your program
d) hotwashes and critique sessions to identify opportunities for improvements in your program
e) documented adjustments to the program, and repeated exercises
Attached is the article: OSHA WK PL VIOLENCE Directive cpl_02_01_052_20019_Sept 8 2011.pdf
If we can be of any assistance in helping you develop, audit, or test your program, please give me a call!