What Are The Workplace Violence Prevention Requirements: Businesses, State and Federal Agencies, and OSHA’s General Duty Clause

william demuth
1 day ago
5 min read

Workplace Violence Prevention Requirements: Business, State and Federal Employers, and OSHA’s General Duty Clause

The federal floor everyone stands on

There is no stand-alone OSHA standard for workplace violence for general industry. OSHA enforces duties through the General Duty Clause, Section 5(a)(1). If violence is a recognized hazard in your operations and there are feasible controls, you must implement them. OSHA cites employers that fail to do so, using its enforcement guidance and long-standing publications. OSHA

What Are The Workplace Violence Prevention Requirements: Businesses, State and Federal Agencies, and OSHA’s General Duty Clause

OSHA is also developing a sector standard for healthcare and social assistance. A Small Business Review (SBREFA) panel concluded on May 1, 2023, and the item remains active on the regulatory agenda. Until a final rule is issued, enforcement remains under the General Duty Clause. OSHA

What federal agencies must do (beyond the General Duty Clause)

Federal agencies must maintain complete occupational safety and health programs under Executive Order 12196 and 29 CFR Part 1960. These programs include inspections, training, recordkeeping, employee involvement, and abatement. Workplace violence hazards must be managed within that framework, which means agencies cannot treat them as optional. National Archives

State requirements that go further than the federal floor

Several jurisdictions already require written programs and specific controls. If you operate in these states, their rules apply in addition to OSHA.

California, most employers. Labor Code 6401.9 (SB 553) requires a written Workplace Violence Prevention Plan, training, a violent-incident log, response procedures, and annual program review. Cal/OSHA has posted guidance and is refining rule text to implement and clarify these statutory requirements. Department of Industrial Relations
New York, public employers. 12 NYCRR Part 800.6 requires public employers to assess risks, implement a written program with employee participation, and provide training and reporting. The New York DOL summarizes scope and enforcement through its PESH program. Department of Labor
Washington, healthcare settings. RCW 49.19 requires healthcare employers to develop and implement workplace violence prevention plans, conduct security and safety assessments, provide training, and periodically review the program. Updated provisions take full effect January 1, 2026. Washington State Legislature
New Jersey, covered healthcare facilities. The Violence Prevention in Health Care Facilities Act requires a violence prevention program with specified elements. Separate 2023 legislation, the Health Care Heroes Violence Prevention Act, adds criminal protections for healthcare workers. New Jersey Legislature

What compliance looks like in practice (your build sheet)

The following elements align with OSHA’s enforcement expectations, federal agency program requirements, and the strictest state models. If you implement these, you satisfy the federal baseline and position yourself well in states with tougher rules.

Written Workplace Violence Prevention Plan (WVPP)-Scope every site and shift, assign responsible roles, and describe hazard identification, reporting, response, investigation, recordkeeping, and annual review. California requires specific sections and employee access, so mirroring that structure covers you broadly. Department of Industrial Relations
Hazard identification and assessment-Evaluate environmental, operational, and job-task risks, for example public-facing work, late-night operations, cash handling, working alone, patient or client risk factors, staffing patterns, and physical layout. Reassess after incidents and at least annually. This satisfies OSHA’s recognized hazard and feasible abatement analysis under the General Duty Clause. OSHA
Feasible controls and corrective actions-Implement engineering and administrative controls that match your risks, for example controlled access, lighting, surveillance coverage, panic devices, staffing adjustments, sign-in protocols, client risk flags, and secure cash handling. Document fixes and track closure. OSHA expects evidence that hazards were actually abated, not just discussed. OSHA
Training and drills-Provide onboarding and at least annual refreshers. Cover warning signs, de-escalation, safe disengagement and escape, incident reporting, law-enforcement coordination, and post-incident resources. State rules may specify cadence and content for certain sectors, so default to the strictest applicable requirement. Department of Industrial Relations
Incident reporting, investigation, and a violent-incident log-Capture who, what, when, where, precipitating factors, response actions, injuries, and follow-up. California prescribes a log, and many programs require trend analysis to inform corrective actions. Department of Industrial Relations
Post-incident response and worker support-Provide medical evaluation, leave options as applicable, security measures, temporary work modifications, counseling resources if available, and documented corrective steps. OSHA weighs post-incident abatement heavily in enforcement. OSHA
Employee participation and committees-Involve frontline staff in assessments, plan development, and reviews. This is required for many public employers in New York and common in healthcare laws such as New Jersey’s, and it aligns with federal program elements for agencies. Department of Labor
Recordkeeping and access-Maintain assessments, corrective action trackers, training rosters, incident logs, and annual reviews. Provide employee access as state rules require, and be prepared to furnish materials during inspections or audits. Department of Industrial Relations
No retaliation-Prohibit retaliation for reporting threats, incidents, or hazards, or for participating in the prevention program. This is an OSHA expectation and is explicit in several state frameworks. OSHA

Quick reference: who needs what

Private businesses (most industries)-Follow OSHA’s General Duty Clause. Implement a WVPP with the elements above. If any of your sites are in California, the California WVPP requirements apply. If you run healthcare in Washington or New Jersey, follow those sector rules. New Jersey Legislature
Federal agencies-Build and maintain your WVPP inside the agency occupational safety and health program mandated by EO 12196 and 29 CFR Part 1960, with inspections, training, committees, and abatement documentation.
Public employers in New York-Comply with 12 NYCRR Part 800.6, which mandates a written program, risk evaluation, employee participation, training, and incident reporting. Department of Labor
Healthcare and social assistance (all employers in that sector)-Track OSHA’s rulemaking, since a federal standard is in development. In the meantime, follow the General Duty Clause and any state sector rules that apply, such as Washington’s RCW 49.19 or New Jersey’s healthcare statute. New Jersey Legislature

Minimum documentation set to have on day one

Written WVPP that names responsible roles and covers procedures
Completed facility and task-level hazard assessments, with a corrective action tracker
Training curriculum, delivery records, and attendance rosters
Violent-incident log and investigation templates
Annual program review, with metrics and updated controls

Before you finalize your program, verify requirements beyond the federal baseline. Check your state and local laws, plus any industry specific rules, since many jurisdictions and sectors impose additional mandates on plan content, training frequency, incident logging, committee participation, and record retention.

Pay special attention if you operate in states known for stricter rules, or if you work in higher risk sectors such as healthcare, social services, education, or public transportation. Confirm with your legal or compliance team, your insurer’s risk control guidance, and the appropriate state labor or safety agency to ensure your Workplace Violence Prevention Plan aligns with all applicable statutes, regulations, and guidance.

Final word

OSHA expects you to identify recognized violence hazards and apply feasible controls. States like California, New York, Washington, and New Jersey already require detailed written programs and logs.

If you implement the build sheet above and maintain solid documentation, you will meet the General Duty baseline and be prepared for the stricter state inspections. Washington State Legislature

If you want, I can convert this into a branded WVPP template set with a log, assessment forms, training outline, and an annual review checklist that match the strictest rules.

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