On September 8, the Occupational Safety and Health Administration (OSHA) issued a Directive with general enforcement policies and procedures for field offices when conducting inspections relating to workplace violence.  The Directive focuses not only on the steps to be taken in response to an incident of workplace violence but the factors OSHA will consider when deciding to initiate inspections in industries that OSHA has identified as susceptible to violence in the workplace.  The identified industries are susceptible to workplace violence because of the actions of others, such as patients, customers, or ordinary criminals.

 Pursuant to the Directive, inspections will generally be conducted in response to complaints and referrals or as part of a fatality and/or catastrophic event involving violence.  Inspections will also be conducted if the employer belongs to an industry identified as high risk for employee violence or where a hazard is identified.  OSHA has identified high risk industries to include healthcare and social service settings (psychiatric hospitals, emergency rooms, health clinics, pharmacies, long term care facilities, and residential facilities) and late-night retail settings (gas stations, convenience stores, and liquor stores).  The following risk factors may also trigger an inspection:  working with unstable or volatile people in a healthcare, social service or criminal justice setting, working alone or in small numbers, working late at night or during early morning hours, working in high crime areas, guarding valuable property, exchanging money in certain financial institutions, delivering passengers, goods, or services, and having a mobile workplace such as a taxicab.

Employers with a history of workplace violence or who are in high risk industries should develop comprehensive workplace violence programs with the assistance of qualified counsel.  Any workplace violence policy should establish a zero tolerance for violence and identify personnel for monitoring and responding to incidents of violence and caring for victims.  The violence prevention program should include engineering controls, such as alarm systems, panic buttons, closed circuit surveillance, security locks, and lighting.  At risk employers should adopt administrative controls, such as modifying work practices and policies to reduce risks, requiring employees to report all incidents of workplace violence, and establishing a liaison with local law enforcement.  For additional guidance, OSHA offers a website dedicated to workplace violence, http://www.osha.gov/SLTC/workplaceviolence/index.html.  The website contains industry specific advice for late-night retail establishments and the healthcare and social services industries.