PCI WORKPLACE VIOLENCE PREVENTION PROGRAM POLICY

PCI’s Workplace Violence Prevention Plan (WVPP) addresses the hazards known to be associated with the four types of workplace violence as defined by Labor Code (LC) section 6401.9.

Date of Last Review: February 2024 Date of Last Revision(s): June 2024

DEFINITIONS

Emergency - Unanticipated circumstances that can be life threatening or pose a risk of significant injuries to employees or other persons.

Engineering controls - An aspect of the built space or a device that removes a hazard from the workplace or creates a barrier between the employee and the hazard.

Log - The violence incident log required by LC section 6401.9. Violence Incident Log

Plan - The workplace violence prevention plan required by LC section 6401.9.

Serious injury or illness - Any injury or illness occurring in a place of employment or in connection with any employment that requires inpatient hospitalization for other than medical observation or diagnostic testing, or in which an employee suffers an amputation, the loss of an eye, or any serious degree of permanent disfigurement, but does not include any injury or illness or death caused by an accident on a public street or highway, unless the accident occurred in a construction zone.

Threat of violence - Any verbal or written statement, including, but not limited to:

• Texts
• Electronic messages
• Social media messages
• Other online posts
• Any behavioral or physical conduct, that conveys an intent, or that is reasonably perceived to convey an intent, to cause physical harm or to place someone in fear of physical harm, and that serves no legitimate purpose.

Workplace violence - Any act of violence or threat of violence that occurs in a place of employment.

Workplace violence includes, but is not limited to, the following:

• The threat or use of physical force against an employee that results in, or has a high likelihood of resulting in, injury, psychological trauma, or stress, regardless of whether the employee sustains an injury.
• An incident involving a threat or use of a firearm or other dangerous weapon, including the use of common objects as weapons, regardless of whether the employee sustains an injury.
• The following four workplace violence types:

• Type 1 violence - Workplace violence committed by a person who has no legitimate business at the worksite and includes violent acts by anyone who enters the workplace or approaches employees with the intent to commit a crime.
• Type 2 violence - Workplace violence directed at employees by customers, clients, patients, students, inmates, or visitors.
• Type 3 violence - Workplace violence against an employee by a present or former employee, supervisor, or manager. 
• Type 4 violence - Workplace violence committed in the workplace by a person who does not work there but has or is known to have had a personal relationship with an employee.

Workplace violence does not include lawful acts of self-defense or defense of others.
Work practice controls - Procedures and rules which are used to effectively reduce workplace violence hazards.

All managers and supervisors are responsible for implementing and maintaining the WVPP in their work areas and for answering employee questions about the WVPP.

EMPLOYEE ACTIVE INVOLVEMENT

PCI ensures the following policies and procedures to obtain the active involvement of employees and authorized employee representatives in developing and implementing the plan:

•Management will work with and allow employees and authorized employee representatives to participate in:

• Identifying, evaluating, and determining corrective measures to preventworkplace violence.
  
• Management will have periodic safety meetings with employees and their representatives to discuss identification of workplace violence related concerns/hazards, evaluate those hazards and/or concerns, and how to correct them. Safety meetings will be conducted when a workplace violence incident occurs to conduct in-depth root cause.
  
• Designing and implementing training

PCI workplace violence trainers will train all district and general managers on the policy and methods to mitigate potential incidents.

• Reporting and investigating workplace violence incidents.
  
  • All incidents of workplace violence will be reported immediately to law enforcement, and the general manager will manage the immediate needs while coordinating with site security and PCI Risk Department. Violence Incident Report
• Management will ensure that all workplace violence policies and procedures within this written plan are clearly communicated and understood by all employees.
  • Managers and supervisors will enforce the rules fairly and uniformly.
• All employees will follow all PCI workplace violence prevention plan directives, policies, and procedures, and assist in maintaining a safe work environment.
• The plan shall always be in effect and in all work areas and be specific to the hazards and corrective measures for each work area and operation.

EMPLOYEE COMPLIANCE

Our system to ensure that employees comply with the rules and work practices that are designed to make the workplace more secure, and do not engage in threats or physical actions which create a security hazard for others in the workplace, include at a minimum:

• Training employees, supervisors, and managers in the provisions of PCI Workplace Violence Prevention Plan (WVPP)
• Effective procedures to ensure that supervisory and nonsupervisory employees comply with the WVPP.

• PCI trainers conduct train the trainer workshops. All managers are required to attend.
  • The WPVP training sessions are conducted for bus and shuttle drivers, parking attendants and office settings.
• Training sessions are taped for ongoing training with new:
  • Sites
  • Managers
  • Employees
• Mandatory training modules are assigned through PayCom for all new hires with completion recorded with HR.
  • Managers will have access to employee training completion to ensure that all frontline employees are trained.
• Provide retraining to employees whose safety performance is deficient with the WVPP.
  • Recognizing employees who demonstrate safe work practices that promote the WVPP in the workplace by:
  • PCI recognition processes include facility inspection audits, safe work habit observations, and site and regional safety incentive plans.
• Discipline employees for failure to comply with the WVPP.
  • PCI has a zero-tolerance policy on violating WVPP and procedures.

 

COMMUNICATION WITH EMPLOYEES

The following communication system is designed to facilitate a continuous flow of workplace violence prevention information between management and staff in a form that is readily understandable by all employees, and consists of one or more of the following:

• New employee orientation includes workplace violence prevention policies and procedures.
• Workplace violence prevention training programs.
• Regularly scheduled meetings that address security issues and potential workplace violence hazards
• Effective communication between employees and supervisors about workplace violence prevention and violence concerns.
• PCI has an open-door policy related to reports of risk hazards including workplace violence concerns or suggestions for additional preventive methods.
• Supervisors and employees can communicate effectively and in the employees’ first language.
• Posted or distributed workplace violence prevention information.
• Employees can report a violent incident, threat, or other workplace violence concern to employer or law enforcement without fear of reprisal or adverse action.
• Employees can anonymously report a violent incident, threat, or other violence concerns.
• Employees have contact information for who to call for emergency response specific to their site.
• Employees will not be prevented from accessing their mobile or other communication devices to seek emergency assistance, assess the safety of a situation, or communicate with a person to verify their safety. Employees’ concerns will be investigated in a timely manner, and they will be informed of the results of the investigation and any corrective actions to be taken.
• PCI training is robust, and employees have various means to voice questions and concerns. Including post incident workforce notification, post-incident root cause analysis with the risk and safety team.

• The individual post-incident report system includes a meeting with the Risk Department. 

            POST ACCIDENT CHECK LIST and WVPP Report LOG 

 

COORDINATION WITH OTHER EMPLOYERS

PCI will implement the following effective procedures to coordinate implementation of its plan with other employers to ensure that those employers and employees understand their respective roles, as provided in the plan.

• All employees will be trained in workplace violence prevention.
• Workplace violence incidents involving any employee are reported, investigated, and recorded. Violence Incident Log
• At a multiemployer worksite, PCI will ensure that if its employees experience a workplace violence incident that PCI will record the information in a violent incident log and shall also provide a copy of that log to controlling employer.

WORKPLACE VIOLENCE INCIDENT REPORTING PROCEDURE

PCI will implement the following effective procedures to ensure that:

• All threats or acts of workplace violence are reported to an employee’s supervisor or manager, who will inform the WVPP administrator. This will be accomplished by immediate phone or text. If that's not possible, employees will report incidents directly to the Risk Department.
• Procedure for reporting incidents, threats, hazards, and concerns of workplace violence.

Employees will report incidents to their supervisor, risk or to HR through Paycom.

• Workplace Violence Reporting form: Workplace Violence Incident Report

A strict non-retaliation policy is in place, and any instances of retaliation are dealt with swiftly and decisively.

• An employee who retaliates against a coworker for reporting an incident will be disciplined and potentially separated from the company.

EMERGENCY RESPONSE PROCEDURES
PCI has in place the following specific measures to manage actual or potential workplace violence emergencies:

• Effective means to alert employees of the presence, location, and nature of workplace violence emergencies by the following the site policy and procedure which may include:
• PCI has evacuation or sheltering plans in place where applicable.

• Unless otherwise specified the emergency egress plan for the site will be used when practicable to do so.

• Sites that are outside only will be directed by law enforcement or site security on sheltering, as necessary.

 

How to obtain help from staff, security personnel, or law enforcement shall include contact information for response staff and local law enforcement and post in common areas. Sites shall ensure all employees know where the list is posted. Site specific information is listed below.

In the event of an emergency, including a Workplace Violence Emergency, contact the following:

WORKPLACE VIOLENCE HAZARD IDENTIFICATION AND EVALUATION

The following policies and procedures are established and required to be conducted by PCI to ensure that workplace violence hazards are identified and evaluated:

• Inspections shall be conducted when the plan is first established, after each workplace violence incident, and whenever the employer is made aware of a new or previously unrecognized hazard.
• Review all submitted/reported concerns of potential hazards are managed immediately and reported using the WVPP incident report form.

PERIODIC INSPECTIONS
Periodic inspections of workplace violence hazards will identify unsafe conditions and work practices. This may require assessment for more than one type of workplace violence. Periodic Inspections shall be conducted using the Facility Inspection Form once a month or more often should an incident occur.

Periodic inspections to identify and evaluate workplace violence and hazards will be performed by designated PCI personnel.

Inspections for workplace violence hazards include review of the facility inspection report and any WVPP incident reports that have been reported. Facility Inspection Form

WORKPLACE VIOLENCE HAZARD CORRECTION

Workplace violence hazards will be evaluated and corrected in a timely manner. PCI will implement the following effective procedures to correct workplace violence hazards that are identified:

• If an imminent workplace violence hazard exists that cannot be immediately abated without endangering employee(s), all exposed employee(s) will be removed from the situation except those necessary to correct the existing condition. Employees asked to correct the hazardous condition will be provided with the necessary protection in coordination with local law enforcement when necessary.
• All PCI locations completed WVPP mitigation process corrective actions taken will be documented and dated on the WVPP incident report form, as necessary.
• Corrective measures for workplace violence hazards will be specific to a given site and work area.

 

PROCEDURES FOR POST INCIDENT RESPONSE AND INVESTIGATION
After a workplace incident, the WVPP administrator or their designee will implement the following post-incident procedures: Post Incident Checklist

• Visit the scene of an incident as soon as safe and practicable.
• Interview involved parties, such as employees, witnesses, law enforcement, and/or security personnel.
• Review security footage of existing security cameras if applicable.
• Examine the workplace for security risk factors associated with the incident, including any previous reports of inappropriate behavior by the perpetrator.
• Determine the cause of the incident.
• Take corrective action to prevent similar incidents from occurring.
• Record the findings and ensure corrective actions are taken.
• Obtain any reports completed by law enforcement.
• The PCI violent incident log will be used for every workplace violence incident and will include the following information:
  • The date, time, and location of the incident.
  • The workplace violence type or types involved in the incident.
  • A detailed description of the incident.
  • A classification of who committed the violence, including whether the perpetrator was a client or customer, family or friend of a client or customer, stranger with criminal intent, coworker, supervisor or manager, partner or spouse, parent or relative, or another perpetrator.
  • A classification of circumstances at the time of the incident, including, but not limited to, whether the employee was completing usual job duties, working in poorly lit areas, rushed, working during a low staffing level, isolated or alone, unable to get help or assistance, working in a community setting, or working in an unfamiliar or new location. 
  • A classification of where the incident occurred, such as in the workplace, parking lot or other area outside the workplace, or other area.
  • The type of incident, including, but not limited to, whether it involved any of the following:
    • Physical attack without a weapon, including, but not limited to, biting, choking, grabbing, hair pulling, kicking, punching, slapping, pushing, pulling, scratching, or spitting.
    • Attack with a weapon or object, including, but not limited to, a firearm, knife, or other object.
    • Threat of physical force or threat of the use of a weapon or other object.
    • Sexual assault or threat, including, but not limited to, rape, attempted rape, physical display, or unwanted verbal or physical sexual contact.
    • Animal attack.
    • Other.
• Consequences of the incident, including, but not limited to:
  • Whether security or law enforcement was contacted and their response.
  • Actions taken to protect employees from a continuing threat or from any other hazards identified because of the incident.
  • Information about the person completing the log, including their name, job title, and the date completed.
• Reviewing all previous incidents.
• Other post-incident procedures as deemed necessary.

PCI will ensure that no personal identifying information is recorded or documented in the written investigation report. This includes information which would reveal identification of any person involved in a violent incident, such as the person’s name, address, electronic mail address, telephone number, social security number, or other information that, alone or in combination with other publicly available information, reveals the person’s identity.

TRAINING AND INSTRUCTION
All employees, including managers and supervisors, will have training and instruction on general and job-specific workplace violence practices. These sessions could involve presentations, discussions, and practical exercises. Training and instruction will be provided as follows:

• When the WVPP is first established.
• Annually to ensure all employees understand and comply with the plan.
• Whenever a new or previously unrecognized workplace violence hazard has been identified and when changes are made to the plan. The additional training may be limited to addressing the new workplace violence hazard or changes to the plan.

PCI will provide its employees with training and instruction on the definitions found on page one (1) of this plan and the requirements listed below:

• The employer’s WVPP, how to obtain a copy of the employer’s plan at no cost, and how to participate in development and implementation of the employer’s plan.
• How to report workplace violence incidents or concerns to the employer or law enforcement without fear of reprisal.
• Workplace violence hazards specific to the employees’ jobs, the corrective measures PCI has implemented, how to seek assistance to prevent or respond to violence, and strategies to avoid physical harm.
• The violent incident log and how to obtain copies of records pertaining to hazard identification, evaluation and correction, training records, and violent incident logs.
• Opportunities PCI has for interactive questions and answers with a person knowledgeable about the PCI plan.
• Strategies to avoid/prevent workplace violence and physical harm, such as:
  • How to recognize workplace violence hazards including the risk factors associated with the four types of workplace violence.
  • Ways to defuse hostile or threatening situations.
• How to recognize alerts, alarms, or other warnings about emergency conditions and how to use identified escape routes or locations for sheltering.
• Employee routes of escape.
• Emergency medical care provided in the event of any violent act upon an employee.
• Post-event trauma counseling for employees desiring such assistance.

EMPLOYEE ACCESS TO THE WRITTEN WVPP

PCI ensures that the WVPP plan shall be in writing and shall be available and easily accessible to employees, authorized employee representatives, and representatives of Cal/OSHA always.

• PCI provides unobstructed access through PCI PayCom server and the IAP portal, which allows an employee to review, print, and email the current version of the written WVPP.

RECORDKEEPING

PCI Will:

• Create and maintain records of workplace violence hazard identification, evaluation, and correction, for a minimum of five (5) years.
• Create and maintain training records for a minimum of one (1) year and include the following:
  • Training dates.
  • Contents or a summary of the training sessions.
  • Names and qualifications of people conducting the training.
  • Names and job titles of all people attending the training sessions.
• Maintain violent incident logs for minimum of five (5) years.
  • Maintain records of workplace violence incident investigations for a minimum of five (5) years. The records shall not contain medical information per subdivision (j) of section 56.05 of the Civil Code.
•  All records of workplace violence hazard identification, evaluation, and correction; training, incident logs and workplace violence incident investigations required by LC section 6401.9(f), shall be made available to Cal/OSHA upon request for examination and copying.

EMPLOYEE ACCESS TO RECORDS
The following records shall be made available to employees and their representatives, upon request and without cost, for examination and copying within fifteen calendar days of a request:

• Records of workplace violence hazard identification, evaluation, and correction.
• Training records.
• Violent incident logs.

REVIEW AND REVISION OF THE WVPP
The PCI WVPP will be reviewed for effectiveness:

• At least annually.
• When a deficiency is observed or becomes apparent.
• After a workplace violence incident.

Review and revision of the WVPP will include the procedures listed in the Employee Active Involvement section of this WVPP, as well as the following procedures to obtain the active involvement of employees and authorized employee representatives in reviewing the plan’s effectiveness:

• Review of PCI’s WVPP should include, but is not limited to:
  • Review of incident investigations and the violent incident log.
  • Assessment of the effectiveness of security systems, including alarms, emergency response, and security personnel availability when applicable.       
• Review that violence risks are being properly identified, evaluated, and corrected. Any necessary revisions are made promptly and communicated to all employees.

 

EMPLOYER REPORTING RESPONSIBILITIES
As required by California Code of Regulations (CCR), Title 8, Section 342(a). Reporting Work- Connected Fatalities and Serious Injuries, PCI will immediately report to Cal/OSHA any serious injury or illness (as defined by CCR, Title 8, Section 330(h)), or death (including any due to Workplace Violence) of an employee occurring in a place of employment or in connection with any employment.

 

I, David Mueller, President of PCI hereby authorize and ensure the establishment, implementation, and maintenance of this written workplace violence prevention plan and the documents/forms within this written plan. I am committed to promoting a culture of safety and violence prevention in our workplace and believe that these policies and procedures will help us achieve that goal.

David Mueller, President                                                                                            June 1, 2024