Workplace Violence Prevention Plans Are Now Required in More States: What HR Teams Need to Know

If you manage HR operations for an organization with employees in more than one state, workplace violence prevention just became a more complicated compliance obligation.

For years, workplace violence prevention was primarily a concern for healthcare employers and public-sector agencies that had industry-specific requirements. That changed in 2024 when California enacted SB 553, requiring nearly every employer in the state to establish a written Workplace Violence Prevention Plan. Now, New York has followed with its own requirements under the Retail Worker Safety Act, and other states are actively considering broader mandates.

For HR teams, this is not just a compliance checkbox. Building, maintaining, and updating a workplace violence prevention program involves documentation, training logistics, incident tracking, recordkeeping, and cross-functional coordination. These are operational processes, and they need to be designed to work at scale.

April is Workplace Violence Awareness Month, which makes this a good time to assess where your organization stands — and where the regulatory landscape is heading.

The Scale of the Problem

Workplace violence is not a rare event. According to OSHA, of the 5,283 fatal workplace injuries that occurred in the United States in 2023, 740 were due to violent acts. Homicides accounted for 458 of those deaths. Beyond fatalities, OSHA notes that workplace violence — including threats, verbal abuse, harassment, intimidation, and physical assaults — affects employees, clients, customers, and visitors across virtually every industry.

The Bureau of Labor Statistics reports that nonfatal workplace violence injuries requiring days away from work occur at a rate of roughly 3.1 cases per 10,000 full-time equivalent workers in private industry. Healthcare and social assistance account for the largest share of these incidents, but retail, education, and public service are also high-risk sectors.

These numbers are what prompted California to act first — and what is driving other states to follow.

California SB 553: The Template

California's Labor Code Section 6401.9, added by SB 553, took effect on July 1, 2024. It requires nearly all California employers to establish, implement, and maintain a written Workplace Violence Prevention Plan (WVPP). The law applies regardless of industry or size, with limited exceptions for certain healthcare facilities already covered by existing Cal/OSHA standards, some law enforcement agencies, and employees who telework from locations not controlled by the employer.

What the Plan Must Include

Under Section 6401.9, the WVPP must contain:

1. The names or job titles of persons responsible for implementing the plan
2. Procedures for obtaining the active involvement of employees and their representatives in developing, implementing, and reviewing the plan
3. Methods the employer will use to coordinate implementation with other employers, where applicable
4. Procedures for accepting and responding to reports of workplace violence, including a prohibition against retaliation
5. Procedures for communicating with employees regarding workplace violence matters
6. Procedures for responding to actual and potential workplace violence emergencies
7. Procedures for post-incident response and investigation
8. Procedures for reviewing the effectiveness of the plan and revising it as needed

Training and Recordkeeping

SB 553 also requires employers to provide training on the WVPP when the plan is first established and whenever it is updated. Employees must also be trained when a new or previously unrecognized workplace violence hazard is identified. Training must cover the plan itself, how to report incidents, and how to respond to emergencies.

Recordkeeping requirements include maintaining a violent incident log that records every workplace violence incident, regardless of whether it resulted in injury. The log must be retained for five years. Training records must be kept for at least one year. The plan itself must be available to employees and their representatives at all times.

Enforcement Is Active

Cal/OSHA is actively enforcing SB 553. Employers that lack a compliant plan are subject to citations and penalties. Serious violations can carry fines up to $25,000 per incident, and willful violations can result in penalties significantly higher.

Cal/OSHA is also developing a permanent general industry workplace violence prevention standard, which the Occupational Safety and Health Standards Board must adopt by December 31, 2026. This regulatory standard may introduce additional requirements or clarifications beyond what SB 553 already mandates.

New York Follows: The Retail Worker Safety Act

New York is the next major state to impose workplace violence prevention requirements on a broad class of private employers. The Retail Worker Safety Act, which took effect on June 2, 2025, applies to retail employers with 10 or more retail employees in the state.

Policy Requirements

Covered retail employers must develop and distribute a written workplace violence prevention policy that includes:

• A list of risk factors and situations that place retail employees at risk of workplace violence
• Methods the employer will use to prevent incidents, including reporting systems and environmental controls
• Information about federal, state, and local laws concerning violence against retail workers, along with available remedies for victims
• A clear prohibition against retaliation for reporting workplace violence or participating in related proceedings

The policy must be provided to employees at hire and at regular training intervals.

Training Requirements

Training obligations vary by employer size:

• Employers with 50 or more retail employees must provide interactive workplace violence prevention training upon hire and annually
• Employers with 10 to 49 retail employees must provide interactive training upon hire and every two years

All training must be delivered in the employee's primary language. The New York Department of Labor has committed to making model policies and training materials available in the 12 most common non-English languages spoken in the state.

Silent Response Buttons

Beginning January 1, 2027, retail employers with 500 or more retail employees in New York must also provide a silent response button system that allows employees to alert an internal security officer, manager, or supervisor during an emergency. This replaced an earlier proposal that would have required direct 911 panic buttons.

Beyond Retail: Public Employer Expansions

New York also has longstanding requirements for public employers. Labor Law Section 27-b requires public employers with 20 or more employees to develop and implement workplace violence prevention programs. Recent legislative proposals — including bills that would expand the definition of workplace violence to include "abusive conduct and bullying" — suggest these requirements may grow more detailed in the near future.

Other States to Watch

California and New York are not alone in expanding workplace violence prevention obligations:

• Oregon currently requires workplace violence prevention programs for healthcare employers, with legislative discussions underway to extend these requirements to other high-risk industries
• Washington similarly focuses its existing requirements on healthcare settings, but is tracking California and New York's legislative models closely
• Illinois and Connecticut have introduced or considered legislation that would create broader workplace violence prevention obligations for private employers

At the federal level, OSHA does not have a specific workplace violence prevention standard. However, OSHA's General Duty Clause — Section 5(a)(1) of the OSH Act — requires employers to provide a workplace "free from recognized hazards that are causing or are likely to cause death or serious physical harm." OSHA has used this clause to cite employers that fail to address known workplace violence risks, and the agency recommends that all employers establish a zero-tolerance policy and develop a written prevention program.

What This Means for HR Operations

For HR teams, the expanding patchwork of state workplace violence prevention laws creates several operational challenges:

1. Multi-State Compliance

If your organization operates in more than one state, you may need to maintain state-specific plans, training programs, and recordkeeping procedures. California's requirements are the most comprehensive, but New York's approach differs in scope (retail-focused, for now) and specific obligations (language accessibility, silent response buttons). A single national policy may not satisfy every state's requirements.

2. Documentation and Recordkeeping

Both California and New York require written plans, training documentation, and incident records. California mandates a detailed violent incident log with a five-year retention period. These records must be accessible to employees and their representatives, which means HR needs a system — not just a folder — for managing them.

3. Training Logistics

Annual or biennial interactive training in multiple languages is a significant operational undertaking, especially for organizations with high turnover or distributed workforces. Training must be tracked, documented, and updated when the plan changes or new hazards are identified.

4. Cross-Functional Coordination

A workplace violence prevention plan touches HR, legal, security, facilities, and front-line management. Someone needs to own the process, and that person needs the authority to coordinate across functions. SB 553 specifically requires the plan to identify who is responsible for implementation.

What Employers Should Do Now

Whether or not your organization currently operates in a state with mandatory workplace violence prevention plan requirements, the direction of the regulatory trend is clear. Here is how to prepare:

1. Assess Your Current State

Start by determining which state requirements apply to your workforce. If you have employees in California, you should already have a compliant WVPP under SB 553. If you have retail employees in New York, you need a policy and training program that meets the Retail Worker Safety Act's requirements. Map every state where you have employees and identify applicable laws.

2. Build or Update Your Written Plan

If you already have a workplace violence prevention plan, compare it against the specific requirements of each state where you operate. If you do not have one, start with OSHA's recommended prevention program framework, which covers the core elements that most state laws require:

• Management commitment and employee involvement
• Worksite analysis and hazard identification
• Hazard prevention and control measures
• Training and education
• Recordkeeping and program evaluation

3. Establish an Incident Log and Reporting System

A violent incident log is required in California and is a best practice everywhere. The log should capture the date, time, and location of the incident; the type of violence (physical, verbal, threat); a description of what happened; and any actions taken. Design the log so it protects employee confidentiality while still providing enough detail to identify patterns and inform plan updates.

4. Design a Repeatable Training Program

Training cannot be a one-time event. Build a training program that can be delivered at hire, repeated on a regular schedule, and updated when the plan changes. Track completion, and make sure the training is available in the languages your workforce requires. For multi-state employers, maintain records that meet the most stringent retention requirement across all applicable jurisdictions.

5. Assign Ownership and Review Cadence

Designate a person or team responsible for maintaining the plan, tracking incidents, coordinating training, and reviewing the program's effectiveness. Schedule annual reviews at a minimum — and conduct additional reviews after any incident or when new state requirements take effect.

6. Prepare for What Comes Next

Cal/OSHA's permanent workplace violence prevention standard is expected to be adopted by the end of 2026. New York's public-sector requirements may expand to include psychological harm, and the silent response button mandate for large retailers takes effect on January 1, 2027. Monitor legislative developments in the states where you operate, and build your program with enough flexibility to adapt as requirements evolve.

For employers looking for a structured framework to track compliance obligations and close operational gaps before they become liabilities, BlueHive's white paper 2026 OSHA Changes: What Has Taken Effect, What is Coming, What Employers Should Do Now provides a practical overview of the current federal regulatory landscape and the deadlines employers need to be watching.

The Process Improvement Opportunity

Workplace violence prevention plans are a compliance requirement, but they are also a test of HR operational maturity. Organizations that treat these mandates as paperwork exercises — writing a plan, filing it, and hoping it never gets tested — will find themselves exposed when an incident occurs, an employee files a complaint, or a state agency conducts an inspection.

The organizations that handle this well will be the ones that build workplace violence prevention into their existing HR infrastructure: integrating incident tracking with their HRIS, automating training reminders and completion records, assigning clear ownership, and reviewing the plan with the same rigor they apply to any other operational process.

The regulatory direction is clear. More states are going to require written workplace violence prevention plans. The employers that start building scalable, well-documented programs now will spend less time scrambling when the next deadline arrives.

Sources

• OSHA — Workplace Violence Overview — Federal overview of workplace violence risks, statistics, and employer responsibilities
• OSHA — Workplace Violence Prevention Programs — OSHA's recommended framework for employer prevention programs
• California Labor Code Section 6401.9 (SB 553) — Official statute text for California's workplace violence prevention plan requirement
• California SB 553 — Bill Text — Full text of the enacted legislation
• JD Supra — "SB 553 Workplace Violence Prevention: 12 Answers to Employers' Questions" — Employer FAQ on SB 553 compliance and enforcement
• Western Growers — "Status of Cal/OSHA's Workplace Violence Regulations" — Regulatory timeline for Cal/OSHA's permanent standard
• New York Retail Worker Safety Act (S8358C) — Official bill text for New York's retail workplace violence prevention law
• Perkins Coie — "New York's Amended Retail Worker Safety Act To Take Effect on June 2, 2025" — Legal analysis of the amended Act and employer obligations
• Greenberg Traurig — "New York Retail Employers, Take Note: New Retail Worker Safety Protection Requirements" — Summary of requirements including silent response button mandate
• New York Labor Law Section 27-b — Public employer workplace violence prevention program requirements
• Bureau of Labor Statistics — Injuries, Illnesses, and Fatalities — Federal data on workplace injury and illness incidence rates
• OSH Act Section 5(a)(1) — General Duty Clause — Federal requirement for employers to provide a workplace free from recognized hazards
• BlueHive — 2026 OSHA Changes: What Has Taken Effect, What is Coming, What Employers Should Do Now — White paper covering 2026 federal OSHA regulatory developments