Q I run a small non-profit. Last year, we implemented our workplace violence prevention plan and did comprehensive training for employees. Are there any periodic requirements we need to satisfy?

AYes. California’s workplace violence prevention standards (general industry) went into effect in July 2024. Other than a few limited exceptions, the new workplace violence prevention requirements apply to all employers in California. The new standards required covered employers to complete three essential tasks: (1) establish the written workplace violence prevention plan; (2) train employees on workplace violence; and (3) maintain a log of all workplace violence incidents.

Covered employers are also required to review their plans, update them if needed and train employees on an annual basis. Employers who implemented their plans and training employees in July of 2024 must complete these annual requirements soon.

Employers should keep in mind that the workplace violence prevention plan and the related training must be specific to the employer and the workplace. Although a model template is available through Cal/OSHA, there is not a one-size-fits-all plan, and employers must substantively build on the template with information and procedures specific to their workplace. A worksite inspection and a review of the current plan are likely necessary to determine what, if any, updates are needed.

The annual workplace violence training must be provided to all employees, including managers and supervisors. At a minimum, the training should cover:

• Familiarizing employees with the plan (such as how to obtain a copy, how to participate in its development/implementation)

• The definitions of key terms and the requirements of the new law

• How to report workplace violence incidents without fear of retaliation

• Understanding the job-specific violence hazards and the preventative and corrective measures in place. For example, a review of emergency exit locations and a discussion of the systems in place at the worksite to notify employees of emergencies.

• The purpose of the violent incident log

• Opportunities for interactive discussions with someone knowledgeable about the written plan. This includes employee questions and feedback.

Training sessions do not need to be overly formal, and employers do not need to hire a vendor to conduct the training. The training can be conducted by anyone with knowledge of the employer’s written plan, such as the plan administrator or a member of Human Resources. The key is that the training be interactive and provide opportunities for meaningful questions, answers and feedback relating to the written plan and the employer’s procedures.

Employers must also provide further training when a new or previously unrecognized workplace violence hazard has been identified and when changes are made to the written plan. Unlike the initial and annual training, this additional training can be limited to the new hazard or change to the plan. Records related to employee training must be kept for at least five years and provided to employees for free upon request.

These annual plan reviews and training require substantial planning and effort. Accordingly, employers who implemented their plans last year should start on these new requirements now, if they haven’t already. Employers with questions regarding workplace violence training or other requirements are encouraged to contact their labor counsel.

Marco Lucido is a lawyer with Fenton & Keller in Monterey. This column is intended to answer questions of general interest and should not be construed as legal advice. Email queries to mlucido@fentonkeller.com