Since 2016 when  US Occupational Health and Safety Administration (OSHA) is in the process of developing a standard for workplace violence prevention in the healthcare and social services sector. In 2021 Congress passed The Workplace Violence Prevention for Health Care and Social Service Workers Act (H.R. 1195) which requires OSHA to develop and publish standards to govern healthcare workplace violence prevention programs.

In 2022 and 2023 OSHA conducted a review of its proposed Standard language with stakeholder groups through a Small Business Advocacy Review Panel (SBREFA)process, which resulted in significant comment from healthcare organizations and industry groups on the proposed language. Based on this feedback OSHA had planned to publish a finalized version of the standard as a Notice of Proposed Rulemaking (NPRM) in the Federal Register in December of 2024 starting the formal process for making the standard law. This NPRM was delayed, and in January of 2025 OSHA updated their timeline for release to June 2025.

With this update we expect to see a Notice of Proposed Rulemaking published in June with the final rule going into effect and requiring compliance in late 2025. While the full content of the standard is not yet available, based on the draft circulated during the SBREFA process and OSHA earlier Guidelines healthcare organizations do have some visibility into what the new Standard may require. From our analysis of these documents we expect the final rule to include requirements that healthcare and social services organizations develop and maintain a workplace violence prevention program that minimally includes:

• Written policies and procedures;
•  A formal hazard assessment process;
• Deployment of specific physical security measures and systems in areas of identified as high risk, including:
  • enclosed nurses’ stations,
  • barriers between employees and patients/visitors in admissions and triage areas,
  • personal panic alarms for staff,
  • Video surveillance equipment,
  • Furnishings that are permanently secured to walls/floor or cannot be used as a weapon; 
• Training for all staff at risk of workplace violence;
• A record keeping system to document all incidents of workplace violence, with specific record retention requirements;
• An investigations process to investigate root cause of every reported incident of violence and a process to conduct a formal hazard assessment of any areas where an incident occurs;

It should also be noted that in its preliminary drafts OSHA defines workplace violence as “any violent act, including physical assault and threat of physical assault” and has identified a “High Risk Area” as “an area where a workplace violence incident has occurred in the previous three years”. We anticipate that unless changed in the final Standard this language will force healthcare organizations to classify nearly all public and patient care areas of their facilities as “High Risk Areas” triggering the need for enhanced controls.

What to expect next, OSHA’s current plan to release its Notice of Proposed Rulemaking in June of 2025. After publication of the NPRM there will be a 30-60 day public comment period followed by publication of the final rule. After the publication of the final rule is published in the Federal Register organizations will have between thirty and ninety days to achieve compliance, unless this is specifically extended by OSHA. With this timeline, we anticipate that the earliest organizations may need to achieve full compliance will be August or September of 2025, but suggest that all healthcare and social services organizations and agencies begin review of their workplace violence prevention programs to identify and start closing potential gaps.