OSHA to Propose Standard on Workplace Violence Prevention in Heal

Healthcare workers signed up to help peoplenot to develop Olympic-level dodge skills in the ER hallway.
Yet workplace violence has become one of the most stubborn, expensive, and emotionally draining safety problems in
health care and social assistance. That’s why OSHA has been movingsometimes quickly, sometimes like it’s pushing
a gurney through wet concretetoward a dedicated federal standard focused on workplace violence prevention.

This article breaks down what OSHA’s potential standard could mean, why it matters, what the timeline looks like,
and what smart employers can do nowbefore a Notice of Proposed Rulemaking (NPRM) shows up and everyone suddenly
“discovers” risk assessments exist.

What “OSHA to Propose a Standard” Actually Means (And What It Doesn’t)

When people hear “OSHA standard,” they imagine a neat rulebook with clear requirements, deadlines, and citations
ready to fly if you mess up. That’s the endgamebut it’s not the starting point.

Right now, OSHA has voluntary guidance for workplace violence prevention in health care and social
services, and it has also used the General Duty Clause when it believes an employer failed to
protect workers from recognized violence hazards. Voluntary guidance is helpfulbut it doesn’t create the same
uniform, enforceable baseline as a formal standard.

A dedicated standard (if issued) would likely require covered employers to build and maintain a documented,
systematic workplace violence prevention programsomething closer to how many organizations treat infection control
or hazardous chemicals: not optional, not “when we get around to it,” and definitely not “just tell staff to be
careful.”

Why OSHA Is Targeting Health Care and Social Assistance

The uncomfortable truth: health care and social assistance settings experience a disproportionate share of serious
workplace violence incidentsassaults and violent acts that are severe enough to cause days away from work, job
restriction, or transfer. National injury data consistently show these sectors carrying an outsized burden compared
with private industry overall.

The risk isn’t limited to big-city trauma centers. It shows up in:

• Emergency departments and urgent care (high emotion + long waits + intoxication + behavioral crises)
• Psychiatric and substance use treatment facilities (higher prevalence of patient aggression)
• Nursing and residential care (cognitive impairment, dementia-related behaviors, understaffing pressures)
• Home health and social work (uncontrolled environments, unpredictable third parties, isolation)
• EMS and mobile crisis teams (volatile scenes, limited engineering controls)

Beyond the human cost, violence drives turnover, burnout, workers’ comp costs, lost productivity, andironically
poorer patient care. A workplace can’t deliver calm, safe healing when staff are bracing for the next incident.

The OSHA Timeline So Far: From “Guidelines” to “We Might Make This a Rule”

OSHA didn’t wake up one morning and decide to regulate workplace violence because it sounded fun. The path has been
long and heavily documented:

1) OSHA’s voluntary guidelines (1996, updated 2004 and 2016)

OSHA has issued guidance for health care and social service employers for decades, with updates reflecting evolving
best practices (risk assessment, incident reporting, training, engineering controls, and program evaluation).

2) The 2016 Request for Information (RFI)

OSHA published an RFI to gather information on the scope of workplace violence, effective interventions, and
feasibilityclassic early rulemaking groundwork.

3) Petitions granted (January 2017)

OSHA granted petitions asking the agency to begin rulemaking for a workplace violence prevention standard in health
care and social assistance. In other words: “Yes, we agree this is serious enough to pursue.”

4) SBREFA / Small Business Advocacy Review (SBAR) panel (March 2023) and report (May 1, 2023)

Under SBREFA, OSHA convened a panel to hear from small entity representatives and evaluate potential impacts. OSHA’s
SBAR process covered a broad slice of health care and social assistance operations and put more structure around a
possible regulatory framework.

5) The agenda reality check: “To Be Determined”

OSHA’s rule entry has appeared on the Unified Agenda and RegInfo as a proposed rule-stage item, but later agenda
materials listed the NPRM timing as “To Be Determined,” signaling shifting priorities and/or timing uncertainty.
Translation: the train is still on the tracks, but it may be stopping at a few extra stations.

Who Would Likely Be Covered (Spoiler: It’s Not Just Hospitals)

OSHA’s SBREFA materials and related descriptions indicate the scope is aimed at the health care and social
assistance sectors broadly, potentially including settings such as:

• Hospitals (including emergency departments)
• Residential behavioral health facilities
• Ambulatory mental health and substance use treatment
• Freestanding emergency centers
• Residential care facilities
• Home health care
• Emergency medical services
• Social assistance services (with certain exclusions depending on final scope)
• Correctional health settings

Final coverage would depend on how OSHA defines “health care and social assistance” activities and how it handles
mixed-use employers, contracted staff, and settings that “look like” health care even when they aren’t classic
facilities.

What a Workplace Violence Prevention Standard Would Probably Require

Until an NPRM is published, nobody can honestly say, “Here are the final requirements.” But OSHA has already laid
out the logic and many program elements repeatedly through guidance and SBREFA framework materials. A reasonable,
evidence-aligned standard would likely revolve around these core components:

1) A written Workplace Violence Prevention Plan (WVPP)

Expect a documented plan that spells out responsibilities, reporting pathways, response protocols, and how controls
are selected and evaluated. Think “living program,” not “binder therapy.”

2) Worksite analysis and hazard assessment

Employers would likely have to identify where violence risk is highest and why. Examples include:

• ED triage and waiting rooms (crowding, long waits, communication breakdowns)
• Behavioral health units (patient acuity, ligature-safe design constraints, staffing)
• Registration desks (public-facing conflict points)
• Home visits (unknown environmental hazards, pets, family conflict, weapons)
• Night shift entrances and parking areas (isolation, poor visibility)

3) Incident reporting, investigation, and follow-through

Reporting systems tend to fail when staff believe, “Nothing will happen anyway,” or “I’ll get blamed for it.”
A strong program includes easy reporting, non-retaliation protections, and consistent incident review that results
in changesnot just sympathy emails.

4) Controls using a hierarchy (yes, security is part of safety)

Violence prevention is not only about training people to “be better at getting hit.” Effective controls may include:

Engineering / physical design controls

• Controlled access points and visitor management
• Panic buttons, duress alarms, reliable radio coverage
• Visibility improvements (lighting, mirrors, line-of-sight redesign)
• Safe rooms or protected work areas where appropriate
• Physical barriers at registration or payment points (used thoughtfully)

Administrative and work practice controls

• Staffing and scheduling decisions that reduce high-risk situations
• Behavioral threat assessment processes and clear escalation pathways
• Patient flagging protocols that balance safety and privacy
• Rules for high-risk transports, restraints, and visitor restrictions
• Home visit “buddy systems,” check-in/check-out procedures, and route controls

Post-incident support

• Medical evaluation and trauma-informed support
• Return-to-work plans that don’t punish reporting
• Root-cause learning (not just “security will be more visible”)

5) Training that matches real risks (and real job roles)

Training tends to work when it’s specific to the environment and practiced under realistic conditions. Many
programs include de-escalation techniques, recognition of warning signs, safe exit strategies, teamwork drills,
and response protocols for acute threats.

Depending on the setting, employers may also integrate emergency preparedness guidance for extreme events (such as
active shooter scenarios) into their broader violence prevention readiness.

6) Program evaluation and continuous improvement

A strong prevention program measures leading and lagging indicators. Not just “How many assaults?” but also:

• How quickly are incidents reported?
• How many corrective actions are completed on time?
• Do staff believe leadership takes violence seriously?
• Are repeat locations, shifts, or patient categories driving incidents?

How OSHA Enforcement Works Today (Even Without a Dedicated Standard)

If you’re waiting for a federal standard before taking action, OSHA may still have opinions about that strategy.
OSHA has published enforcement guidance for inspections and citations related to workplace violence exposure.

Practically, OSHA cases often focus on whether workplace violence was a recognized hazard in a
specific setting and whether feasible steps existed to reduce it. Health care environments with repeated incidents,
predictable risk factors, and limited controls can face heightened scrutinyespecially after serious injury.

State Rules Are Already Doing a “Preview Episode” of What a Federal Standard Could Feel Like

Several states have moved ahead with workplace violence prevention requirementsespecially for health carecreating
a patchwork where multi-state systems have to manage different compliance obligations.

For example, California has a specific workplace violence prevention standard for health care settings (with written
plans, training, incident logs, and other requirements). Washington State has advanced rulemaking for workplace
violence prevention in health care. New York has workplace violence prevention requirements for certain public
employers and has also seen additional activity affecting health care employers.

If you operate nationally, these state approaches are useful “early warning” indicators: OSHA is not inventing a
brand-new conceptit’s likely to federalize program elements that already exist in stronger state frameworks and
well-run systems.

What Employers Can Do Now (Without Guessing the Final Rule)

You don’t need a crystal balljust a clipboard and a willingness to look honestly at where things go sideways.
Here’s a practical, no-drama action plan that holds up under both current expectations and future rulemaking.

Step 1: Treat workplace violence like a safety system, not a behavior issue

Violence is influenced by systems: staffing, layout, workflow, communication, and response readiness. Yes, human
behavior mattersbut systems determine how often staff get stuck in unsafe situations.

Step 2: Build or refresh a written WVPP (even a “Version 1.0”)

Document roles, reporting, response, investigation, corrective actions, training, and evaluation. Keep it alive:
assign owners and deadlines, and review it at least annually (or after major incidents).

Step 3: Map your high-risk scenarios and fix the “predictable pain points”

Common examples:

• ER waiting room: Improve communication cadence, signage, and escalation channels; reduce crowding triggers when possible.
• Behavioral health: Strengthen team response protocols, ensure alarms work everywhere, review restraint-related risk points.
• Home health: Formalize safety screening, establish check-ins, and define when staff can end a visit without fear of retaliation.
• Front desks: Consider physical design improvements, staffing support, and clear security response expectations.

Step 4: Upgrade reporting culture (the quiet foundation of everything)

If incidents aren’t reported, they aren’t managed. Make reporting easy, normalize near-miss reporting, and close the
loop by sharing what changed because someone spoke up.

Step 5: Train like you mean itthen practice

One-and-done training doesn’t survive contact with reality. Use refreshers, drills, scenario-based practice, and
role-specific modules (ED vs. home health vs. inpatient psych are different planets).

Common Myths That Make Violence Prevention Harder

• Myth: “Violence is just part of the job.”
  Reality: Predictable hazards are exactly what safety programs exist to control.
• Myth: “Training is enough.”
  Reality: Training without staffing, design, and response support is like giving someone an umbrella in a hurricane.
• Myth: “Reporting makes us look bad.”
  Reality: Under-reporting makes you blindand regulators aren’t impressed by blindness.
• Myth: “Security owns this.”
  Reality: Violence prevention is interdisciplinary: leadership, nursing, HR, facilities, behavioral health, and security must share accountability.

What to Watch For Next

The big milestone is an OSHA NPRM that lays out scope, definitions, requirements, timelines, and the economic and
feasibility analysis. Once proposed, employers and stakeholders can submit comments, data, and suggestions. Whether
the rule advances quickly or slowly, the direction is clear: the expectation for structured violence prevention in
health care is rising.

If you’re in health care or social assistance, the smartest move is to strengthen your program nowbecause even
before a final federal standard exists, patients, staff, accreditation expectations, insurers, and state rules are
already pushing in the same direction.

Real-World Experiences (Composite): What Workplace Violence Looks Like on a Tuesday

Let’s talk about what this looks like in real lifenot as a sensational headline, but as the everyday “pressure
weather” of care delivery. The following experiences are composite scenarios drawn from common
patterns described by health care safety leaders, frontline staff, and industry guidance. They’re not about any one
person; they’re about the system moments where risk spikes and prevention either works…or fails loudly.

Experience 1: The ER waiting room that turns into a powder keg

It starts with something boring: a long wait and unclear expectations. A family member paces, checks the clock,
gets a different answer from each staff member, and starts recording on a phone “just in case.” A patient is in
pain, hungry, and scared. Another patient is intoxicated and loud. The atmosphere gets hotter by the minute.

In the worst version of this story, the first real “intervention” is when someone throws a chair.
In the better version, the system intervenes earlier: a predictable communication cadence (“here’s what happens
next”), clear signage, a trained greeter who can de-escalate, and a rapid path to call support before things erupt.
The lesson: prevention often happens before the violent actwhen you reduce triggers and improve the
environment.

Experience 2: Behavioral health and the myth of “we can talk our way out of anything”

A staff member notices a patient escalatingpacing, clenched jaw, aggressive tone. The staff member tries to
de-escalate (good!). But the unit is short-staffed, the alarm has a dead zone near one hallway (not good), and the
response team isn’t sure who leads the intervention (very not good). When the patient swings, it becomes chaos.

The prevention win here isn’t “teach better talking.” It’s the full package: reliable alarms, line-of-sight,
defined team roles, adequate staffing during peak risk times, and post-incident learning that results in real
changes. The lesson: a program that depends on perfect human performance will fail on the day humans are, you know,
human.

Experience 3: Home healthwhere the “facility” is someone else’s living room

A home health aide walks into a situation that looked fine on paper. But a relative is agitated, there’s substance
use in the background, and a dog is barking like it’s auditioning for a horror movie. The aide feels unsafe but
worries that leaving will be seen as “noncompliance with patient needs.” That hesitation is a risk multiplier.

A strong program makes it easy to do the right thing: pre-visit screening, clear stop-work authority, check-in
requirements, and rapid supervisor support. The lesson: for lone workers, administrative controls and culture are
the real “engineering controls.”

Experience 4: The aftermath matters more than the incident (and nobody says that enough)

After an assault, the way leadership responds can either reinforce reporting and improvementor teach staff to keep
quiet next time. If the response is “Are you sure you didn’t provoke them?” or “That patient didn’t mean it,” you
get under-reporting and resignations. If the response is immediate care, supportive follow-up, incident review,
and visible corrective action, you get trustand fewer repeats.

The lesson: a workplace violence prevention program is also a workforce retention strategy. People will tolerate a
hard job. They won’t tolerate feeling disposable.

Conclusion

OSHA’s movement toward a workplace violence prevention standard for health care and social assistance reflects a
simple reality: violence is a predictable occupational hazard in many care settings, and predictable hazards demand
systematic controls. Whether the NPRM arrives sooner or later, the organizations that act nowby building real
programs, improving reporting, investing in controls, and practicing responsewill be safer, more resilient, and
better prepared for whatever the final rule requires.