www.calodging.com May + June 2024 13 REGULATION and evaluate workplace violence hazards at certain intervals (i.e., when the plan is first implemented, periodically thereafter, following an incident of workplace violence, and whenever a new hazard becomes known); (ix) procedures to timely correct workplace violence hazards identified; and (x) procedures for post-incident response and investigation. Workplace Violence Incident Log Employers will now need to maintain a separate Cal/OSHA log for incidents of workplace violence, but the law does not create any new employer reporting requirements. The log must consist of all incidents of workplace violence, even if the incident does not result in injury. The log must be maintained for a minimum of five years and made available to Cal/OSHA upon request. Notably, employers must exclude personal identifying information that would identify any person involved in the incident. There are also special rules for multiemployer worksites. Workplace Violence Training Employers must provide all employees with effective interactive workplace violence training: (i) when the Plan is first established; (ii) on an annual basis thereafter; and (iii) when a new or previously unrecognized workplace violence hazard is identified and/ or the Plan is revised. The law details the required topics for the training. Recordkeeping Requirements There is a five (5) year recordkeeping rule for: (i) records pertaining to your workplace violence hazard identification, evaluation, and correction methods; (ii) records of any workplace violence incident investigations; and (iii) incident logs. Training records must be kept for a minimum of one year. Next Steps Now is the time to begin preparing your Workplace Violence Prevention Plan as the July 1, 2024, deadline is just around the corner. As the Plan must be specific to the hazards of each workplace, employers should spend time analyzing their workplace and formulating effective response protocols for a workplace violence incident. For example, employers should evaluate evacuation routes, shelter in-place locations, and methods for immediately alerting employees of a violent incident in the workplace. Employers also should evaluate and discuss how to best achieve employee participation in the creation and maintenance of the Plan because active employee participation is mandatory. Employers in multi-employer worksites should consult with the other employers to coordinate implementation of the Plan and to ensure recordkeeping compliance. Finally, like most other employee protective legislation, the new law contains anti-retaliation provisions to protect employees who lodge complaints or concerns about the employer’s Plan or planning process. Employers should ensure that management at all levels of the organization and HR team are aware of and embrace these new important requirements.
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