Time to Revisit Your WVPP

California is approaching the two-year anniversary of its Workplace Violence Prevention Plan (WVPP) requirements going into effect. Since July 1, 2024, most California employers have been required to develop, implement, and maintain a written WVPP and provide mandatory employee training. Remember, Cal/OSHA can cite employers and issue expensive penalties for non-compliance.

It’s time to revisit whether your WVPP (or “plan”) still reflects your current hazards and operations, or needs to be updated. As a reminder, there are a number of steps employers should take on at least a yearly basis, including:

• Annual soliciting of employee (and union) feedback to ensure their active involvement in the WVPP;
• Annual review of your written plan and updating it as appropriate;
• Annual employee training on your plan;
• Periodic hazard inspection.

Important Tip: Employers should first solicit employee feedback and review/update the WVPP before scheduling the employee training. This is because the employee training is required to be specific to your Company’s WVPP and procedures. Some helpful questions as you review your plan include:

• Does our plan still reflect our current worksite layout, staffing, and operations?
• Have we had any new hazards, employee concerns, or near misses that we should account for in our plan?
• Are our supervisors sufficiently trained on how to respond to threats, reports, or violent incidents?
• Are we using the required violent incident log consistently?

Note: You must also review the WVPP after any workplace violence incident, and when a deficiency is observed or becomes apparent. As one example, if you learn that someone’s spouse threatened them and has a key to your office, you should evaluate options to mitigate the risk of workplace violence and adjust your plan accordingly.

Training Requirements

The law requires training to be worksite-specific and to include an opportunity for interactive questions and answers with a person knowledgeable about the employer’s plan. This means a generic, off-the-shelf training is not sufficient, unless it is properly customized to the employer’s plan, operations, and hazards, and is presented by someone familiar with your WVPP.  

The training materials and content should also be appropriate for the educational level, literacy, and language of your employees. In other words, if you communicate with your workforce in a language other than English, then the training materials and plan content should match that language.

The training must also cover specific definitions in Labor Code section 6401.9, as well as information on:

• The employer’s WVPP
• How an employee can obtain a copy of the employer’s plan
• How to report incidents of workplace violence and retaliation
• Violent hazards specific to the employee’s job
• The corrective measures the employer has implemented to address hazards
• Strategies to avoid physical harm
• How to seek assistance to prevent or respond to violence
• How to obtain copies of records regarding hazard identification, evaluation, and correction, and training records
• The Violent Incident Log—what it is and how to obtain a copy.

Training records must be retained for a minimum of one year. Training is also required when the WVPP is initially adopted, whenever new hazards are identified, and whenever the plan is changed, which may occur more frequently than your annual training.

Need help?

If you need assistance refreshing your employee training, CEA has a customizable WVPP employee training template with 30+ slides to help you cover the required topics and tailor the training to your workplace.

If you are just getting started, CEA also offers a comprehensive DIY WVPP package to help employers build a compliant plan and training program from the ground up.

Reminder: CEA members already have free access to our WVPP Toolkit.