4 Things You Could Be Doing Right Now to Mitigate the Threat of Workplace Violence – Write a Rock-Solid Policy (Part 2 of 4)

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This is a part two of a four-piece article written by guest contributor, David Corbin. He is the former Director of Facilities, Engineering and Public Safety & Parking at Newton-Wellesley Hospital. Corbin managed all aspects of Public Safety, Facilities, Engineering and Construction operations for a 3.6 million square foot, 313-bed institution. He created and held the co-chair positions for the hospital’s first multidisciplinary Infant Security Committee and Workplace Violence Subcommittee. Corbin has an extensive background in the security industry and consults on a national level. He is a Certified Protection Professional (CPP) and a Certified Healthcare Protection Administrator (CHPA).  Corbin obtained both a Bachelor’s Degree and Master’s Degree in Criminal Justice from Roger Williams University and Northeastern University respectively. Visit David’s website here.

What’s the definition of workplace violence? How are reports of violence investigated?  Who is responsible for preventing violence? One of the keys to creating a solid foundation under your workplace violence program is to write a rock-solid policy to answer these questions and more.

What makes a workplace violence policy well-written?  First of all, the policy should be created in collaboration with the other key players who have a vested interest in preventing workplace violence, including, but not limited to: Human Resources, Risk Management, Employee Assistance Program, Domestic Violence Program, General Counsel, Executive Leadership, Safety, and Security.  This is essentially your Workplace Violence Committee that was discussed in the first part of this series. By involving the right people from the start in the drafting and review process, you can avoid headaches down the road caused by major revisions and/or clashes with other departments.

You should also be sure to cover all of your legal bases, particularly if your state has certain requirements for workplace violence programs. Overall, a great workplace violence policy has the following key elements:

• Workplace violence is defined from the start.
  • It should be clear in your policy what constitutes workplace violence.  Here’s an example definition: “Behavior that creates an environment that a reasonable person would find intimidating, threatening, violent or abusive; regardless of whether the behavior may affect a person’s psychological or physical well-being; occurring on-site, at an off-site location operated by the hospital, or occurring outside of these locations when related to the hospital.”  Did you notice that the definition covers all the bases regarding location?  This is an easily overlooked element of the policy.

• Examples of workplace violence are provided.
  • List some of the more common types of violence, but don’t forget the examples that others may not always consider, including lateral/horizontal violence, verbal abuse, stalking, and domestic violence.  This need not be an exhaustive list of every possible form of violence, but enough to give employees a good idea about the range of behaviors included.

• All categories of violence are covered.
  • Remember that we’re not just talking about employee-related violence, but also violence involving strangers, personal relations, patients, visitors, contractors, and others. Find the categories of violence and more info about each here.

• Instructions are given for responding to workplace violence, including reporting.
  • How can an employee, patient, visitor, or contractor report workplace violence?  I would suggest that reporting methods be divided into two types: immediate fear for safety and no immediate fear for safety.  Obviously, those with an immediate fear for their safety should be calling your STAT line or security emergency line. Employees without an immediate fear for safety can utilize their chain-of-command within their department or go directly to Human Resources or Security.  There should also be instructions on how to file an anonymous report through a confidential tip line or by other means.

• The investigation and corrective action process is described.
  • Who is responsible for what once an employee or someone else has reported workplace violence?  Hospital leadership should be mandated to report to Human Resources and/or Security any time a workplace violence complaint is received- no matter how insignificant it may seem.  Some investigations may start and end with Human Resources, but most should involve Security at some level.  If you have a Threat Management/Assessment Team, this group may also get involved.  These investigations may ultimately lead to corrective action that should also be defined.  Are you going to terminate for certain offenses but not others?  This should be clearly spelled out.

• Restraining orders are discussed.
  • Orders of protection are very personal by their very nature.  However, they are obtained in response to an ongoing threat against a employee, patient, or other person in your hospital. It’s important that employees understand that these types of orders should be reported to their manager and Security for the safety of the protected employee, their co-workers and others. The policy should be clear that there shall be no retaliation for an employee informing the hospital of a restraining order.

• Confidentiality and “no retaliation” statements are included.
  • The policy should state how confidentiality will be maintained in addition to stating that no retaliation will be taken against employees who files a report of workplace violence in good faith.

• Post-incident support is outlined.  
  • What steps will the hospital take after an incident has occurred to support the employees, patients, visitors, or others affected?  Don’t just think about the major incident like an active shooter, but also consider a bullying situation that has impacted several employees on a unit.  Post-incident support may include pulling in your Employee Assistance Program or other counseling resources to conduct a debriefing and ongoing employee welfare monitoring.

• Mitigation strategies that are being employed are described.
  • What is your hospital actually doing right now to mitigate the threat of workplace violence? Prevention is certainly key whenever we’re talking about workplace violence and there must be clear ownership for each mitigation strategy in place. Here are some examples of mitigation strategies that you may have in place (or may want to consider):

Education– This is a big one.  What type of training is provided to hospital staff regarding workplace violence?  Are you using a de-escalation program such as CPI or MOAB?  If so, who gets the training and why?  Is it mandatory and documented?  You may only give de-escalation training to emergency department, security, and behavioral health staff, but you should define your rationale for this model (i.e.- these employees are at a higher risk of violence).

Incident and Trend Monitoring– You should be on the lookout for trends and issues emerging regarding workplace violence at your institution and across the country.  The Environment of Care Committee (aka- the Safety Committee) and/or your Workplace Violence Committee are good groups to look at this information.

Security Staffing– Do you provide on-site security at each location?  If so, is the location staffed 24/7?

Committees and Special Groups– If you have a Workplace Violence Committee and/or a Threat Management/Assessment Team, their purpose, membership, and responsibilities can be defined within the policy.

Resources & Communication

While this is not meant to be an exhaustive list of everything that should be in your policy, I hope that it will help you in evaluating your own workplace violence policy or even creating one from scratch. For even more in-depth information on creating a workplace violence policy and more, check out the ASIS/SHRM Workplace Violence Prevention and Intervention Standard. This is a great resource that should be in every security practitioner’s reference library.

Last, but certainly not least, remember even the most well-written policy is fairly useless if it’s not communicated to staff at all levels in your institution. In particular, managers and supervisors should receive additional training on the policy and their responsibilities in the identification, reporting, investigation, and prevention of violence. We’ll cover more on training and education in part three of this series- stay tuned!

Firestorm is pleased to share this practitioner point-of-view. For more information on developing Workplace Violence Prevention policies, plans and programs, please Contact us Here.

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