For many employers, July 1 marks the annual deadline for California workplace violence prevention training compliance. Ahead of this fast-approaching deadline, impacted employers should review their Workplace Violence Prevention Plans (WVPPs) and begin scheduling required employee training.
Under California Labor Code section 6401.9 (SB 553), employers must establish, implement, and maintain an effective written Workplace Violence Prevention Plan (WVPP) that includes employee training, hazard identification, incident response procedures, and plan reviews. In agriculture, workplace violence prevention requires a unique perspective because crews often work in remote locations, during early morning or late-night hours, and sometimes alone or in isolated areas. Cal/OSHA identifies these workplace violence risk factors as especially relevant to agricultural operations.
Cal/OSHA also reminds employers that effective plans must include procedures for communicating with employees, responding to incidents and emergencies, correcting workplace violence hazards, and prohibiting retaliation when employees report concerns. Employers are also required to maintain training records, violent incident logs, and investigation records for specified periods.
The annual training deadline is the perfect time to ensure your operations are compliance-ready. Consider these five key next steps:
- Review. Review and update your written WVPP to ensure it reflects current operations, supervisors, and worksite conditions, keeping in mind that each worksite must have its own WVPP.
- Train. Begin scheduling annual employee training for both supervisory and non-supervisory employees, including field and seasonal workers.
- Reassess. Conduct a reassessment of workplace violence risk factors at all worksites, including ranches, packing facilities, transportation areas, and remote work locations.
- Reporting. Confirm procedures are in place for reporting incidents, responding to emergencies, and documenting investigations.
- Record. Verify that all required records, including training documentation and violent incident logs, are maintained according to Cal/OSHA requirements. Keep in mind that California’s SB 513 expanded the scope of personnel records employers must maintain to include training records. This means workplace training records must include: 1) the employee’s name and the training provider’s name; 2) the core competencies covered during the training; and 3) any resulting certification, if applicable.