On September 8, 2011 the Occupational Safety and Health Administration issued its first written enforcement directive specifically addressing the problem of workplace violence. The directive established general policy guidelines and procedures for field offices to apply when conducting inspections in response to incidents of workplace violence. It identified the most susceptible industries to this kind of hazard, highlighted the steps that should be taken when reviewing incidents and when to initiate an inspection. This gives some documented connection to the general duty clause which is the enforceable regulation section of the OSH Act.

The directive established four categories of workplace violence based upon the aggressor’s relationship to the organization: 1. Criminal intent (violent acts by people who enter the workplace to commit a violent crime) 2. Customer/client/patient who directs acts of violence against employees  3. Co-worker (violence against an employee by a current or former employee, and  4. Personal (violence by a non employee against an employee with whom they have a personal relationship). This is significant in that most people’s perception of what workplace violence could include may not encompass all of these types of incidents. A company, or organization, has to account for the reasonable foreseeability of any of these happening in their workplace because OSHA may regard them as a “recognized hazard.”

The directive also established three different industries which OSHA considers to be at high risk for workplace violence incidents: 1. Health care facilities 2. Social services settings, and 3.Late night retail settings. Then, OSHA further identified numerous risk factors which need to be considered when evaluating the potential for workplace violence:

• Working with unstable or volatile persons in certain healthcare, social service or criminal justice settings
• Working alone or in small numbers
• Working late at night or during early morning hours
• Working in high crime areas
• Guarding valuable property or possessions
• Working in community-based settings, such as community mental health clinics, drug abuse treatment clinics, pharmacies, community –care facilities and long-term care facilities
• Exchanging money in certain financial institutions
• Delivering passengers, goods or services
• Having a mobile workplace such as a taxicab

The other guideline which OSHA established in this directive is the consideration for feasible means available to the employer to abate the hazard. These include the following suggested abatement methods in general:

• Conduct a workplace violence hazard analysis
• Assess any plans for new construction or physical changes to the facility or workplace to eliminate or reduce security hazards
• Provide employees with training on workplace violence
• Implement “Engineering Controls”
• Implement “Administrative Controls”
• Provide management support during emergencies and respond promptly to all complaints
• Develop a written, comprehensive workplace violence prevention program

There are many specific examples given for some of these suggestions as well as additional abatement suggestions for the specific industries listed above as high risk industries.

Though the directive is primarily intended as a tool for the Compliance Safety and Health Officers (CSHO’s), Area Directors, District Supervisors and other OSHA officials, it also serves to put organizations on notice. Especially those which the directive identifies as high risk, or are subject to high risk factors. They have put some definition into the workplace violence problem from the perspective of enforcing the existing general duty clause which all employers should be aware of. Now the responsibility is clearly on the employer to; do their research; identify potential for problems; explore feasible solutions or prevention measures; and get out of denial.

Employers have always had the potential civil liability hanging over their heads regarding workplace violence incidents. They have always had the social responsibility to reasonably protect their employees. Now they have a Federal compliance standard to address that has some teeth. Enlisting the help of a professional service provider with specialists in this area is going to be critical. IMAC can be your solution. Call me directly at 440.878.5114 if you would like to discuss this issue and your need to prepare your organization and educate your workforce. See www.imac-training.com for the full series of courses on workplace violence prevention.

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The recent release of IMAC’s Workplace Violence Training Series at www.imac-training.com is a timely response to what has again become the number one concern of today’s corporate security directors. The tragedies of 9/11 distracted attention from this problem and placed focus on how terrorism would affect the American company/organization. Though concerns regarding terrorism should not be ignored, there is a far greater probability in most American workplaces that there will be a workplace violence incident that will directly, or indirectly, impact the business and the employees.

Workplace violence is an often misunderstood phenomenon. There are many different types of crime and violence that get lumped into the workplace violence data. From robberies, to domestic disputes unfolding in the workplace, to vivid images of fired employees returning on shooting rampages, they are all contained in the sea of statistics on this problem. When this topic is discussed, most people only think of the disgruntled former employee returning to commit an act of vengeance. That is in fact, a small percentage of the problem. Workplace violence includes any conduct or behavior that creates a dangerous or threatening situation for the employees. Therefore, all of the reasonably foreseeable sources of potential violence, both internal and external, must be addressed in a prevention and response strategy.

A workplace violence prevention and response program must contain training, prevention and response strategies to address all of the following components:

• A Proactive Violence/Aggression Free Culture
• Effective Pre-Employment Screening
• A Workplace Violence Policy
• Employee Awareness Programs
• Training Programs for Supervisory Personnel
• A Trained Threat Response Team
• Development of a Threat Response Process
• Physical Security Reviews
• Knowledge and Utilization of Critical Assistance Resources
• Attention to (and Preparation for) Significant Events

Your company has a duty to your employees to provide a safe working environment that is free from violence and aggression, or the threat of them. The Occupational Safety and Health Administration (OSHA) standards for workplace safety demand it; your legal defense and financial health may depend on it; and your employees certainly deserve it.

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Law enforcement officers interested in making a career change into the corporate executive protection (EP) world need to be prepared to modify the way they operate on the job. This work requires a totally different mindset. Police and investigators are typically programmed to react to incidents and ‘handle the situation’. In most cases, prevention of those incidents is not a reasonable expectation. Law enforcement officers are simply relied upon to take charge afterwards. Executive protection demands a more proactive approach. The protective agent must keep the protectee out of harms way, and avoid conditions or environments that could lead to dangerous incidents. Not just react to them if they happen.

Law enforcement officers, when thrust into the role without preparation, will rely on instincts that are counter to the close protection mission. These same instincts which have been necessary for their own survival, and have been ingrained through years of experience, may not serve them well in executive protection. For example, in an assault attempt, their professional inclination would most likely be to respond to the aggressor and not the protectee. This makes them very vulnerable to a diversion and delayed attack scenario. Also, their instinct is to protect themselves – not be a shield for someone else. Their reaction cannot be to seek cover, but to be the cover! The EP agent’s first reaction should be to respond to the protectee, cover him or her with their bodies and evacuate from the area. This will not come naturally and requires specific training.

This is not a criticism. As a former police officer making such a transition years ago, I too felt that my savvy as a street cop afforded me the skills to do close personal protection work. Subsequent training from former US Secret Service agents taught me that, though some of the skills were useful, my approach had to change. It also taught me the value of solid intelligence and detailed security advance work to assure that I would keep the protectee out of positions of vulnerability and unnecessary exposure.

It is absolutely true that law enforcement operations require intelligence and careful planning, experience that will be valuable. Executive protection planning however focuses on minimizing risk, thinking logistically through each day, and always playing a ‘what if’ mental game with yourself. How will I respond? Am I positioned properly? Have I done everything possible to minimize the risk in the environment which the protectee must occupy? Can I affect the protectee’s decision to be there in the first place? The list goes on.

The so called hard skills developed in law enforcement such as interactive assertiveness, self defense maneuvers, weapons proficiency, control under stress, and many others are valuable. However, hard skills and physical prowess will not be more important than the ability to plan, think ahead, have contingencies, make necessary recommendations, avoid dangerous patterns and modify on the move.

Check out IMAC’s ‘Executive Protection – A Practitioner’s Overview’ course at www.imac-training.com.

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