Workplace violence prevention plan must be implemented by California dental practices by July 1

CDA members can use Sample Workplace Violence Prevention Plan and Physical Hazard Risk Assessment
May 1, 2024
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QUICK SUMMARY: California dental practices are required to establish, implement and maintain a workplace violence prevention plan no later than July 1 under legislation signed into law last year. Employers must involve employees in the plan's development for preventing and responding to threats of violence and violent incidents and report such incidents in a log among other requirements. CDA’s new sample plan and other resources can help members comply.

May 3, 2024: The article as first published reported incorrectly that the law only applies to California employers with 10 or more employees. Correction: The law applies to all places of employment that are open to the public, regardless of the employer’s size. Only workplaces that are not open to the public and have fewer than 10 employees are exempt from the law.

May 1, 2024: California dental practices and other covered employers in the state that are open to the public are required to establish, implement and maintain a workplace violence prevention plan no later than July 1 under legislation, SB 553, signed into law in September 2023, as CDA first reported last October.

Employers will include the plan in the practice’s existing injury and illness prevention program. The plan must be reviewed at least annually but sooner if a violent incident occurs or if the employer observes a deficiency in the plan. CDA recommends reviewing the plan as part of the onboarding process for all new hires as well as when the facility is remodeled.

The plan must contain specific information and procedures for preventing and responding to violent incidents, such as how employees will participate in developing the plan, how the employer will train employees to follow the plan and how employees will respond during and after a violent incident.

California dentists may read elsewhere that the new law does not apply to health care. Some health care facilities are exempt because they are already complying with a California regulation adopted in 2018, but dental practices were not covered by that regulation. They are covered by this new law.

CDA’s sample Workplace Violence Prevention Plan includes all required elements

To help member-dentists comply with the law, CDA’s regulatory compliance experts have developed a sample Workplace Violence Prevention Plan that includes all the required elements in the plan, including procedures for how the practice will:

  • Develop and implement the workplace violence prevention plan using employee input and with the goal of identifying potentially violent situations in the practice, preferred and effective communication methods and more.
  • Ensure employees’ rights to report a threat or violent incident without fear of retaliation.
    Conduct a comprehensive physical hazard risk assessment in consideration of previous threats or acts of violence, awareness of escape routes, use of security cameras and more.
  • Identify workplace situations that may have the potential for violence, such as with a disgruntled patient, domestic violence related to a patient or employee or a patient’s or visitor’s inappropriate behavior.
  • Implement procedures to correct hazards and prevent violent situations, which may include posting signs to indicate the presence of security cameras, for example.
  • Document procedures for responding to a violent incident in the workplace, including theft or burglary during working hours, a visibly angry patient or guardian or an individual carrying and threatening with a firearm or other weapon.
  • Report every violent incident in a workplace violence incident log and maintain that log, which should include information from employees who experienced violence and from witnesses, as well as findings from investigations.
  • Communicate the plan to employees — whether through staff meetings and annual trainings or in writing.
  • Provide violence prevention and training safety to employees.

CDA’s comprehensive sample Workplace Violence Prevention Plan contains customizable sections. Individual practices must document situations with a potential for violence and the steps they have taken to prevent violence at the practice, for example.

The sample plan also includes links to workplace violence training videos and a fillable form employees can complete to certify that they completed the required Workplace Violence Prevention Plan training.

Physical hazard risk assessment: Examining interior and exterior areas of the practice

How are sightlines from one area of the practice or lobby area to other areas of the practice? Do any heavy objects exist in the waiting room or other public access areas that could be used or thrown as a weapon? Is lighting good in all areas, and is there a mirror at the staff entrance? These are some of the questions employers and their staff will consider when completing the required physical hazard risk assessment.

The assessment, part of the Workplace Violence Prevention Plan, should document the locations of previous workplace violence incidents and any hazards identified in areas inside and outside the workplace — along with the corrections made.

CDA’s sample Physical Hazard Risk Assessment for members is customizable and aids the dental practice in complying with the law. The assessment must be reviewed at least once a year.

Managing conflicts and emergencies, protecting dental team’s mental health

CDA is committed to the health and welfare of its member-dentists and their dental team members and patients. Beyond implementing the required workplace violence prevention plan, members will find additional workplace protection resources to help them manage conflicts and emergency events in the workplace. And the CDA Foundation’s Wellness Program offers confidential peer-to-peer assistance for dental professionals who are battling physical or mental ailments, including anxiety, depression and substance dependence.

All members and their staff are also invited to join CDA’s virtual membership meeting at 6 p.m. on Thursday, May 9. CDA President Carliza Marcos, DDS, CDA Foundation Wellness Program Chair Matt Korn, DDS, and CDA Senior Regulatory Compliance Analyst Teresa Pichay, CHPC, will address patient conflict, mental health and workplace violence prevention. Register for the event.

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