Model Policy on Workplace Violence Prevention Program

1. WORKPLACE VIOLENCE & HARASSMENT PREVENTION PROGRAM

• 01 Statement of Policy—Prevention of Violence in the Workplace

The management of <Qn> recognizes the potential for violent acts or threats directed against staff by persons other than employees. Every effort has been made to identify the sources of such action, and procedures have been developed to eliminate or minimize the risks to staff.

The management of <Qn> will ensure that all staff members are aware of the hazards and are trained in the appropriate actions to take for protection from acts or threats of violence.

Workers must follow the procedures implemented for their protection, and immediately report all incidents of violence.

Owner or Manager: ________________________________________________________

Date: ____________________________________________________________________

• Purpose of Program

<Qn> has adopted this Workplace Violence Prevention Program to ensure that all workers are protected and furnished a non-violent and professional working environment. The purposes of this Program include, but aren’t limited to helping you:

• Recognize what workplace violence is;
• Recognize that acts of violence are considered a serious offence for which necessary action will be imposed;
• Understand and follow the safe work procedures that <Qn> has implemented to protect you from violence and harassment;
• Respond appropriately if you encounter incidents or threats of violence or harassment at work;
• Report any incidents or threats of violence or harassment or injuries you sustain as a result of violence or harassment at work; and
• Other:
• Scope of Program

The rules in this Program that ban individuals associated with <Qn> from subjecting another person to violence apply not just to the physical premises of <Qn> and its facilities, vehicles and other properties but to off-site locations, including, but not limited to, off-site meetings or conferences, client locations, social situations related to work or workers’ homes if there are real or implied consequences related to the workplace—at all times of the day, not just working hours.

• Definitions

“Violence” means the attempted or actual exercise by a person, other than a worker, of any physical force so as to cause injury to a worker, and includes any threatening statement or behaviour which gives a worker reasonable cause to believe that he or she is at risk of injury. Examples:

• Threatening behaviour – shaking fists in front of or pushing a worker;
• Verbal or written threats – any expression of intent to inflict physical force that could cause physical injury, or involving body language or behaviours that leave little doubt in the mind of the recipient that the perpetrator intends to cause physical injury;
• Physical attacks – hitting, shoving, pushing, kicking, biting, pinching or inciting an animal to attack; and
• Threats against family – a threat against a worker’s family that’s the result of the worker’s employment is considered a threat against the worker for purposes of this Program.

1. RESPONSIBILITIES OF DIFFERENT PERSONNEL

Ensuring a violence-free workplace is everybody’s responsibility, including <Qn> management, supervisors and workers as well as people who don’t work for <Qn>. Responsibilities of different groups include:

• Upper Management:
• Serve as role models;
• Be familiar with and communicate this Program;
• Implement the measures necessary to achieve the goals set out in this Program;
• Monitor the effectiveness of this Program;
• Environment, Health & Safety Coordinator:
• Serve as role models, be familiar with and communicate this Program;
• Ensure the proper implementation of the hazard assessment required in this Program;
• Identify the training needed to implement this Program;
• Monitor the effectiveness of this Program;
• Supervisors:
• Serve as role models;
• Provide input as requested to help assess risks;
• Help identify the training needs of workers under this Program;
• Communicate this Program to all workers and ensure it’s properly implemented;
• Conduct investigations and identify corrective actions;
• Keep detailed records of training and incidents;
• Workers:
• Serve as role models; and
• Provide input into hazard assessment as requested; and
• Co-operate with <Qn> officials carrying out their duties under this Program, e.g., the Joint Health and Safety Committee or accident investigator; and
• Follow all safe work practices and procedures; and
• Report any hazards or incidents of violence to their supervisor or other company officials in accordance with the terms of this Program; and
• Participate in education programs;
• Other: <Qn>
• Joint Health & Safety Committee (JHSC)/Health & Safety Representative (HSR): Participate in the development, implementation and ongoing management of this Program, receive the results of hazard assessments, participate appropriately in work refusals or incident investigations, if called upon to do so.
• Contractors and Subcontractors: Be familiar with, communicate to employees and co-operate with in the implementation of this Program
• Building/Site Security:
• Visitors: Follow all safe work practices and procedures set out in this Program while on the worksite
• Others: <Qn>

1. HAZARD ASSESSMENT

• Identification of Risk Factors

<Qn> will designate a competent person or persons to, in consultation with the JHSC or HSR for the workplace, assess each workplace where and identify the factors that put workers at risk of violence from members of the public and other persons who aren’t workers of <Qn>. The competent person[s] will consider the following risk factors:

1. Nature of Interactions between Workers and the Public:

• Money transactions
• Selling or dispensing alcohol or drugs
• Delivering healthcare or social services
• Providing security or regulatory enforcement services
• Civil disobedience or labour disputes

1. Characteristics of Workers:

• Training, experience and skills
• Age
• Gender
• Appearance
• Size and stature
• Health
• Personality and attitude

1. Nature of Work Environment:

• Work location
• Number of workers
• Workplace layout, including decor, furniture placement, existence of barriers and fences between workers and the public
• Internal lighting
• External lighting
• Security arrangements
• Hours of operation
• Equipment and tools used or available for use
• Methods of communication available
• Existence of exit signs and exit procedures
• Availability of backup

1. History of Incidents in Your Workplace and Similar Operations in Past Year:

• Number or frequency of incidents
• Type and severity of incidents
• Time and location of incidents
• Job classification
• Attributes of workers
• Attributes of clients
• Nature of interaction between worker and client

1. Other: <Qn>

• Gathering Data for Hazard Assessment

The competent person[s] will gather data necessary to conduct a workplace violence hazard assessment, including incident reports of all previous incidents of violence in the workplace, reports of corrective actions, if any, taken in response to such incidents and surveys and other input from workers, supervisors and other personnel indicating their perceptions of the security of the workplace and the potential for violence.

• Completion of Hazard Assessment

Having identified the risk factors and gathered the appropriate data, the competent person[s], in consultation with the JHSC or HSR, will complete a written report documenting the risks of violence posed to workers—both generally within the workplace and with regard to specific jobs and operations. The Assessment Report will also recommend measures to reduce, control or eliminate the risks identified.

A Model Assessment Report is attached to this Program as Exhibit A.

• Written Assessment Report

The competent person[s] who does the assessment will deliver to <Qn> a written, signed and dated report describing the results of the Assessment (referred to as the Assessment Report). <Qn> shall make a copy of the Assessment Report available to the JHSC or HSR for the workplace or, if no JHSC or HSR exists, to the workers who perform the work. <Qn> shall retain a written copy of the Assessment Report available to workers and others who might want to access it.

• Review of Assessment

Shall review the Assessment to ensure it remains accurate <Q9> at least once a year. The Assessment will also be reviewed:

• Any time new work processes in the site covered in the Assessment are introduced; and
• Any time significant changes to the work processes or operations in the site covered in the Assessment are made; and
• Any time significant new technology is introduced affecting work in the site; and
• Any time construction is undertaken or alterations are made to the site; and
• Other: <Qn>

1. SAFE WORK PROCEDURES

• Travelling to and from Work

<Qn> has developed the following procedures to help you minimize the risk of being subjected to violence while traveling to and from work:

1. Pre-Arrival Planning: Before you leave for work:

• Visualize where you’ll park when you arrive
• Make sure you have enough gas to get to and from work
• Make sure you have everything you need for work on the front seat beside you if you’re travelling alone
• Form a backup plan in cas your arrival at work doesn’t go as planned.

1. Arrival at Your Parking Spot

• Park in well-lit areas
• Avoid alleys, wooded areas and tunnels
• Use caution in underground lots — stay in open, lit areas near exits
• As you enter the parking lot, keep the vehicle locked and the windows rolled up
• As you enter the designated parking area and before you leave your vehicle, scan the area for suspicious persons
• Have a backup plan ready
• Prepare yourself to get out of the vehicle with everything you need before unlocking the door
• Make sure you have the key to the building, a whistle or other personal alarm, and personal belongings
• Avoid having to reach back into the vehicle for items after you have exited
• Ensure the vehicle is locked and the windows are up while it’s unattended

1. Walking to Your Place of Business

• Proceed directly and quickly to your store or office
• Walk with your head erect, look alert and scan your route
• Use the main entrance as much as possible — avoid rear or secluded entrances

1. Returning to Your Vehicle

• Prepare yourself to leave the store or office with everything you need, e.g., keys to lock doors, the key to open your vehicle and a whistle or other personal alarm
• Use the main entrance as much as possible — avoid rear or secluded exits
• Scan the area for suspicious or menacing individuals
• Have a backup plan if there’s danger
• Proceed directly and quickly to your vehicle
• Walk with your head erect, look alert and scan your route
• If possible, avoid walking to your vehicle alone. Go with other workers, security guards, or another escort. Provide the escort with a ride back to the main entrance.
• If you must walk to your vehicle alone, have a co-worker watch you from a window, if possible, and wave to him or her on the way to your vehicle.
• If no one is available, pretend you’re being watched and wave to an imaginary co-worker on the way to your vehicle
• Once you’re in your vehicle, ensure all doors are locked and windows are up

1. Travelling to Work via Public Transit

• Avoid isolated and poorly lit bus stops
• Plan your arrival time at the bus stop to get you there just before your bus arrives
• If you’re alone or it’s late at night, sit near the driver
• If someone bothers you, tell the driver immediately
• Try to sit where you can see your upcoming bus stop as you arrive
• If you see suspicious or menacing individuals at your stop, get off at the next stop
• When stepping off the bus, check to see if you’re being followed
• If you are being followed, walk directly and quickly — without running or looking back — to a service station or store. Call 911.
• If possible, plan to have someone meet you at your home bus stop

1. If You’re Confronted

• If attacked, scream — as loud and long as possible — and run to the nearest well lit area
• If someone grabs your purse, deposit bag, or other personal property, do not resist and do not chase the robber
• Call the police immediately after any incident and record the appearance and mannerisms of the offender. <Q10a>
• Working Alone

<Qn> has developed the following procedures to help you in case you have to work alone.

• Have someone contact you periodically to ensure you’re okay
• The checking procedure must require you to take some predetermined action to confirm you’re all right and don’t need help
• Contact may be in person, telephone, or any other effective means, including reciprocal agreements with other <Qn> locations, adjacent merchants or security firms
• Reciprocal agreements may include:
• Telephone contact at predetermined intervals
• Visual contact or a signal to workers in adjacent premises, or to security patrols
• Use personal alarms or monitored video surveillance systems, provided that you verify that:
• They’re properly maintained
• The response to signs of distress is made immediately by qualified personnel
• <Qn> has made arrangements with adjacent employers to have employees watch each other’s premises
• <Qn> has prominently displayed notices indicating:
• That the premises are monitored
• What emergency numbers to call for assistance
• If possible, do not open back doors and leave them open and unattended
• If possible, do not empty the garbage at night, especially if the dumpster is in a secluded spot or back alley

Assault Prevention Tips for When You’re Working Alone

• If attacked, scream — as loud and long as possible — and run to a neighbouring store or the nearest well-lit area and continue calling for help
• If someone grabs your purse, deposit bag, or other personal property, do not resist and do not chase the thief
• Call the police immediately after any incident and record the appearance and mannerisms of the offender.

<Q10b>

• Working in Retail Establishments Late at Night (11 PM to 6 AM)

<Q10c>

• Dealing with Irate Customers

<Qn> has developed the following procedures to help you in case you have to deal with an irate customer.

• Focus on the emotions first. Remain calm, and try to calm the other person.
• Avoid escalating the situation. Find ways to help the irate customer save face.
• Listen carefully and try to put yourself in the customer’s shoes, so you can better understand how to solve the problem.
• If you can’t calm the person, ask for help.

<Q10d>

• Dealing with Robberies

<Qn> has developed the following procedures to help you prevent and, if necessary, deal with a robbery.

1. Preventing a Robbery

• Make the store or facility attractive to customers and unattractive to robbers
• Keep the premises clean, tidy and well-lit
• Keep active and alert
• Get away from the sales counter when there are no customers
• Ensure the sales counter is clearly visible from outside the store. A cash register location that’s hard to see clearly from the street helps a robbery to happen unnoticed.
• Keep alert at all times
• Identify your escape routes
• Know the location of phones or assistance outside the premises
• Be aware of areas with poor lighting
• Avoid looking directly at suspicious loiterers. Prolonged eye-to-eye contact, especially if there’s a group involved, may be seen as a challenge and escalate the situation.
• Fill out a description sheet. If the loiterers don’t leave, call the police and ask for a patrol check.
• Greet everyone who enters the store
• Be friendly and briefly look directly into their eyes
• Ask the customer ahead of someone suspicious, “Are you together?” The customer will usually turn around to look at the person. This may deter a robber.
• Keep the cash register fund to a minimum—remove all $50 and $100 bills from the cash register as soon as you receive them.
• Post signs advising “Minimum cash kept on premises”
• Ask customers for exact change or the smallest bills possible
• Take extra precautions after dark and during slow periods
• Check each night to see that outside lights are on and working
• Operate only one register late at night through early morning
• Open the empty unused register drawer and tip it up for display
• Run an “empty register” — just $5 bills and change

1. If a Robbery Occurs

• Remain cool and calm
• Handle the entire procedure as if you’re making a sale to a customer. Most robberies last under 2 minutes. The longer a robbery takes, the more nervous the robber becomes, so keep it short and smooth
• Listen carefully to what the robbers say, and obey them.
• Don’t be a hero. Don’t fight. Don’t use weapons. Don’t jeopardize your own safety or that of other workers.
• Give the robbers all the cash and merchandise they want.
• Don’t delay or argue
• Tell the robbers of any possible surprises
• Tell the robbers if you must reach for something or move in any way. Ask them for their directions.
• Tell the robbers if another employee is in the back room so they won’t be startled
• Activate the alarm system only after the robbers have left, not while they’re still in the store
• Continue to remain cool and calm
• Be careful not to stare or fix your gaze too long on the robbers, but observe what they look like, what they are wearing, their size, and the type and colourof weapons.
• Listen carefully to what they say
• Note the robbers’ exact heights against the height strip as they exit
• Immediately after the robbers have left, record their appearance, mannerisms, and any distinguishing characteristics on a description sheet
• Don’t chase robbers
• Call the police
• Keep police numbers near the phone — 911 or your local emergency number
• Tell the police:
• The direction robbers took when they left
• The time of the robbery
• The appearance of the robbers, and any weapon or vehicle used
• Stay on the phone until the police tell you they have all the information they need
• Protect the crime scene
• Ask any witnesses to wait for the police
• Get names and addresses
• Don’t touch the evidence

<Q10e>

• Making Deposits

<Qn> has developed the following procedures to help you avoid the risk of violence when making deposits.

• Avoid making night deposits
• Vary the times of deposits
• Do not make deposits alone
• When making deposits with a co-worker or trusted friend, have him or her face the other way to keep an eye on everything while you make the deposit.

<Q10f>

• Other Workplace Violence Prevention Work Procedures

<Q10g>

• Review of Work Procedures

<Qn> shall review the above work procedures at least once a year. Review will also take place when the conditions on which the hazard assessment leading to the creation of the procedure change such as:

• Any time new work processes are introduced; and
• Any time significant changes to the work processes or operations covered in the Assessment are made; and
• Any time significant changes in or affecting the location where the procedure is carried out take place;
• Any time an injury or incident of violence takes place; and
• Other: <Q11>

1. PROCEDURES FOR REPORTING VIOLENCE

• Reporting Threats or Incidents of Violence

Whenever a person observes what appears to be an incident or act of violence, he or she must report it as soon as possible to a supervisor or other <Qn> official. Where possible, reports of violence should be in made in writing by completing the <Qn> Violent Incident Report form, a copy of which is attached to this Program as Exhibit B. <Qn> will investigate the reported threat or act of violence and ensure that any necessary corrective action is taken without delay in accordance with the terms of Part 6 of this Program.

<Q12>

• No Recriminations for Reporting

<Qn> will take all reports of violence filed by employees very seriously, investigate and, where circumstances warrant, take measures to address any and all problems identified. <Qn> will also make all reasonable efforts to protect the confidentiality of individuals who file reports. <Qn> also makes the unconditional promise that no individual will be disciplined, demoted or treated unfavourably because they’ve issued a report of violence. 

<Q13>

• Assistance and Support Available to Those Who File Reports

<Qn> will provide assistance and support in filing complaints to any individual that wants it.  <Q14>

1. WORKPLACE VIOLENCE INCIDENT INVESTIGATION PROCEDURES

• Responsibility for Investigation of Reports of Violence

 <Q15>

• Incident Investigation Procedures

 <Q16>

• Preservation of Incident Scene

Workers, supervisors and others shall refrain from touching anything or taking any other actions that disturb the scene of an injury or incident before <Qn> or a government official conducts an investigation except when necessary to:

1. Attend to persons injured or killed;
2. Prevent further injuries or death;
3. Protect property endangered as a result of the accident.

<Q17>

• Recordkeeping

<Q18>

1. INCIDENT RESPONSE & FOLLOW-UP

• Debriefing of Victim

<Qn> will immediately de-brief individuals who have been victims of violence or harassment. Such de-briefing will involve:

1. Review of the critical facts of the incident as determined by the investigation;
2. Review of the victim’s needs;
3. Assessment for symptoms of Post-Traumatic Stress Disorder;
4. Social support; and
5. Other: <Q19>

• Support Available to Victims

<Qn> will ensure that a worker reporting an injury or adverse symptom as a result of an incident of violence is advised to consult a physician of the worker’s choice for treatment or referral.

<Q20>

• Discipline for Acts of Violence

<Qn> applies a zero tolerance policy toward violence. This means that acts of violence will not be tolerated from any person and will be responded to with appropriate disciplinary action, up to and including termination, based on a thorough investigation of the incident and the surrounding circumstances. Such disciplinary action may include immediate termination, even if the person committing the act has committed no prior offences or engaged in previous acts of violence.

1. WORKPLACE VIOLENCE SAFETY TRAINING & INSTRUCTION

• All Workers to Receive Workplace Violence Training

<Qn> will provide safety training, information and education about workplace violence and the terms of this Program to all workers.

• Orientation Training

Workplace violence training will be provided to each new worker at the time of hiring as part of the new worker’s orientation and on an ongoing basis thereafter.

Workplace violence, including risks from robbery, assault or confrontation, will also be one of the topics covered in the new and young worker orientation training provided as required by Sec. 3.23 of the BC OHS Regulation.

<Q21>

• What Training Covers

Workplace violence training will ensure that all workers understand, at a minimum:

1. How to recognize workplace violence;
2. The policies, procedures and workplace arrangements implemented by <Qn> to protect them from the risks of workplace violence;
3. The appropriate response to workplace violence, including how to get help;
4. The <Qn> procedures for reporting, investigating and documenting incidents of workplace violence;
5. The follow-up and support procedures available to them in case they’re involved in an incident of violence; and
6. Other <Q22>

• Ongoing Education & Awareness

<Qn> will provide ongoing communication and distribution of information to reinforce initial orientation training and maintain awareness of the terms of this Program.

<Q23>

• Training Records

<Qn> shall maintain training records showing who provided and received training, the nature of the training and when it was provided, including:

<Q24>

Steps will be taken to verify that workers have understood their training and are actually applying it while working.

1. WORKPLACE VIOLENCE PROGRAM REVIEW

• Responsibility for Program Review

<Q25>

• Program Evaluation Method

<Q26>

• Program Evaluation Data

<Q27>

• Program Evaluation Reports

<Q28>

EXHIBIT A

Risk Assessment Summary Report

A risk assessment has been conducted at: [place] ______________________________________ on: ­­­­­­­­­­­[date] ____________________ by [name of management and worker representative(s)]___________________________________________________________.

The following potential risks of violence were identified:

❒

EXHIBIT B

Violent Incident Report Form