Employers' Annual Workplace Violence Prevention Responsibilities Are Around the Corner

Now, employers must continuously respond to workplace violence concerns, hazards and incidents, conduct periodic inspections, and update their plan and provide additional training as necessary.

Plus, every year, employers must review their workplace violence prevention plan’s effectiveness and provide annual training on the law’s requirements and their plan. Since July 1 will be here soon — the first anniversary of workplace violence prevention plan requirements — employers should begin preparing for these annual requirements, including revising their plans, if necessary.

Workplace Violence Prevention Plan Review

California law requires employers to maintain a detailed workplace violence prevention plan, which may be maintained as a standalone document or integrated into their Injury and Illness Prevention Program (IIPP). Employers must review the effectiveness of their plan periodically — at least annually. But employers must also review their plan when they discover a plan deficiency and after a workplace violence incident.

As a reminder, a workplace violence prevention plan must cover a lot of topics, including:

• Names or job titles of the people responsible for implementing the plan. If multiple people implement the plan, the plan must describe their roles.
• Procedures for obtaining employees' and authorized representatives' input when developing and implementing the plan.
• Methods to coordinate the plan with other employers and their employees, as needed.
• Procedures to accept and respond to reports of workplace violence, and to prohibit retaliation for making a report.
• Procedures that ensure that supervisory and nonsupervisory employees comply with the plan, such as rewarding compliance or disciplining violations.
• Procedures for communicating with employees regarding workplace violence matters, including reporting concerns and incidents as well as how the employer conducts investigations.
• Procedures to respond to actual or potential workplace violence emergencies.
• Obtaining help from staff assigned to respond to workplace violence emergencies (if any), security personnel (if any) and law enforcement.
• Procedures to develop and provide training required under this law.
• Procedures to identify and evaluate workplace violence hazards, including but not limited to, scheduled periodic inspections. Inspections must also be conducted when the plan is first established, after each workplace violence incident, and whenever the employer is made aware of a new or previously unrecognized workplace violence hazard.
• Procedures to timely correct workplace violence hazards discovered during inspections.
• Procedures for post-incident response and investigation.
• Procedures to review the plan's effectiveness and revise it as needed.
• Any other requirements the Cal/OSHA implements.

When reviewing their plans, employers should review all the procedures related to the topics above to determine whether they have been effective. For example, for communication procedures, employers should determine whether:

• Their communications were received and understood by employees;
• Employees were able to effectively report workplace violence concerns and potential hazards; and
• They effectively communicated how it handled any investigations of potential concerns or hazards, etc.

Employers should also review any procedures that didn’t get used in real-life circumstances to determine if they would still be effective when needed. For example, assuming an employer didn’t have a workplace violence incident all year, they should still review their required post-incident response and investigation procedures to determine if they would still be effective for a workplace violence incident.

Additionally, the workplace violence prevention law specifies that reviewing a plan’s effectiveness includes obtaining the active involvement of employees and authorized representatives. So, employers should involve their employees in the process using effective methods, including  for example, obtaining information from employees and their supervisors on how the plan’s procedures have worked over the past year — either in writing, through a form or electronic method, or oral feedback.

During this process, employers should try to be specific. If, for example, an employer is reviewing their plan’s communication processes, they should try to get information specifically about the employees’ experience with those procedures and identify instances in which employees didn’t receive or understand communications or couldn’t report workplace violence concerns or hazards effectively.

Employers should also consider conducting a hazard inspection, as they did when they first established their plan. This may help to identify new or additional workplace violence hazards resulting from workplace changes since the last inspection, which may include, for example, personnel changes, changes in business hours and shift times, or worksite construction or renovations that impact existing workplace safety procedures.

Annual Workplace Violence Prevention Training

Employers must train their employees at least annually on California’s workplace violence prevention law and their specific workplace violence prevention plan. Employers should conduct their annual training after reviewing their plan as described above and making any necessary adjustments for ineffective procedures and/or discovery of new or additional hazards.

Training materials must be appropriate in content and vocabulary, accounting for your workforce's educational level, literacy and language. The training must include materials on:

• The employer's plan; how to obtain a copy of it at no cost; and how to participate in developing and implementing it.
• The plan's definitions and requirements.
• How to report workplace violence incidents or concerns to the employer or law enforcement without fear of reprisal.
• Workplace violence hazards specific to the employees' jobs; corrective measures the employer has implemented; how to seek assistance to prevent or respond to violence; and strategies to avoid physical harm.
• The violent incident log and how to obtain copies of the log; records related to the identification, evaluation and correction of workplace hazards; and training records.
• An opportunity for interactive questions and answers with a person knowledgeable about the employer's plan.

Generally, the law allows employers that discover a new or previously unrecognized hazard to make changes to their plan and provide additional training that is limited to the new hazard and plan changes. However, employers must provide training annually on all the requirements listed above. So even if an employer reviews their plan and only makes a small revision and trains as to that revision, they must still provide comprehensive training on their entire plan to satisfy annual training requirements.

Remember, employers must maintain employee training records for one year.

Employer Resources

For more information on California’s workplace violence prevention requirements and best practices, check out CalChamber’s HR Library, which covers:

• How the law defines workplace violence;
• Plan requirements;
• How employers may go about identifying and mitigating workplace violence hazards;
• Training;
• The benefits of distributing a workplace violence prevention policy; and
• Other important information.

Additionally, Cal/OSHA maintains a workplace violence prevention resources page  with frequently asked questions about the law, fact sheets and other educational materials. Cal/OSHA is also developing a workplace violence prevention regulation, though it will be some time before a final regulation takes effect. Cal/OSHA has until December 31, 2025, to propose a rule, and the Occupational Safety and Health Standards Board has until the end of 2026 to adopt the rule.

Employers can register now for CalChamber’s upcoming webinar — Revisiting Your Workplace Violence Prevention Program for 2025  — on May 15, 2025, where our employment law experts break down real-life scenarios and strategies to help you ensure compliance with the law, strengthen your plan, mitigate risks and properly respond to workplace violence incidents.

Lastly, to help employers with these requirements, CalChamber offers a Workplace Violence Prevention Toolkit, which contains numerous resources designed to assist employers in maintaining their plan and facilitating training, inspections, reporting, and recordkeeping.