In the aftermath of the Gilroy Garlic Festival shooting, and now two others in quick succession, we feel it's important for all employers to recognize that an active shooter can happen anywhere. Active shooter incidents have been on the rise in recent years, including, tragically, workplace shootings.

What can employers do to keep their employees safe?

How can you prepare for workplace violence incidents?

Note that the California Division of Occupational Safety and Health (DOSH), better known as Cal/OSHA, enforces workplace safety standards. California Labor Code states that all employers have a general duty to provide places of employment that are safe and healthful for all employees (section 6401).

So what can you do? First let's look at some suggestions for stopping violence at work before it happens, and then we'll look at your obligations as California Employers

Workplace Violence Prevention Tips

The DHS recommends preparing now for an active shooter. Consider posting FEMA's active shooter preparation flyer>.

Here are some steps you can take:

• Zero-Tolerance Policy. Maintain a workplace violence prevention policy, which stands on its own, or is incorporated into your Injury and Illness Prevention Program (IIPP) or employee handbook, or both. Your policy should clearly state that your organization has zero tolerance for threats or acts of violence, and also ensure that any incident, complaint, or report of violence is immediately addressed, investigated and properly managed.
• Include a policy in your employee handbook that clearly bans firearms or dangerous weapons of any kind from the workplace premises.
• Pay attention to warning signs. Often people who become violent communicate their intentions in advance.
• Train your supervisors. Take the time to train people on how to identify behaviors that have a high correlation to violent behavior and the people who display those behaviors. Also make sure all understand your Emergency Action Plan.
• Put physical security measures such as video surveillance, alarm systems or key card systems in place when necessary.
• In addition, make sure your building and parking areas are well-lit.
• Encourage your employees to report any and all suspicious behaviors or threats of violence. If you see something, say something.

Injury & Illness Prevention Program (IIPP) is Required in California

All employers in California must create and have available an effective, written Injury and Illness Prevention Program (IIPP), containing a general plan to keep the workforce free from work-related injuries and illnesses, including keeping employees safe from threats of violence in the workplace.

Under the regulation, a written IIPP must include the identity of those responsible for implementing the plan, a company safety policy statement and a plan for safety training, among other requirements.

Employers can choose to include a plan for active shooter scenarios in their IIPP. The United States Department of Homeland Security (DHS) provides a wealth of active shooter preparedness materials for Human Resource professionals. Resources range from guides, brochures, and pamphlets, to courses, videos, and workshops.

California Health Care Employers Special Note

Health care employers in California are regulated under the Violence Protection in Health Care standard. As of April 1, 2018 these employers must implement a Violence Prevention Plan and train employees on eight specific components including how to recognize the potential for violence, in addition to other provisions.

Emergency Action Plan

All employers must maintain an Emergency Action Plan (EAP) for handling emergencies, and employers with more than 10 employees must have the plan in writing.

An EAP designates the actions that must be taken to protect employees from various emergencies such as:

• natural disasters
• acts of terror
• other incidents of violence

An EAP must include the specific procedures for several categories, including emergency evacuation and how to account for all employees after emergency evacuation has been completed. Alarm system and training requirements are also included.

While you are exempt from the written plan requirement if you have 10 or fewer employees, you are not relieved from your obligation in having a plan for handling emergencies.

Preparation Creates Confidence

Some employers might think that discussing frightening things like an active shooter situation in their workplace might create more fear and anxiety, but being prepared tends to quiet the free-floating anxiety that mass shootings create.

The active shooter risk, sadly, is real, and taking some time now to create a plan and discuss it with your employees can help everyone when seconds count.

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