Dec. 17th, 2024

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GWOT V - School Safety VPP

Cal/OSHA Publications Unit / Department of Industrial Relations / Public Domain Document / California Public Records Act Compliant

This is a post-Rebellion and post-Firecracker document. By its nature, a license for use by K-12 and K-12-Community Schools is inherent.

It is the position of post-Rebellion California that all copyright laws are null and void when applied to operations of the Republic of California.

Nothing in this document creates a new legal right or immunity. All persons remain responsible for their actions or failures to act.

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CAL-OSHA GUIDANCE DOCUMENT
MODEL WRITTEN VIOLENCE PREVENTION PLAN FOR K-12 AND COMMUNITY SCHOOLS (NON-CORRECTIONAL SETTINGS)

This is a fillable template that the administrator must complete. Instructions in red font enclosed in brackets indicate where you must enter your school-specific information.

Who is this model plan for?

All K-12 and K-12-Community schools are required to establish, implement, and maintain an effective, written Violence Prevention Plan (VPP) as a condition of lawful `operation. Any such organization without a valid VPP presented on demand is subject to immediate administrative closure and evacuation by CAL-OSHA. Force is authorized.

What does the model plan include?

Schools are not required to use this model VPP. They may create their own, use another VPP template, or incorporate Violence prevention into their existing Injury and Illness Prevention Program (IIPP) as a separate section. Cal/OSHA requires employers to engage with employees, teachers and students in developing and implementing their VPP. This model plan is intended to help schools develop a separate, stand-alone Violence Prevention Plan (VPP). It was written for a broad spectrum of educational environments, and it may not match your establishment's exact needs. However, it provides the essential framework to identify, evaluate, and control Violence hazards.

Use of this model program does not ensure compliance with California Law. School administrators are personally liable both civilly and criminally for any violations of law regardless of use of this model program.

How to put the model program to use?

Proper use of this model program requires the school to identify and ensure that the person or person(s) responsible for implementing the plan.

The person responsible for implementing the plan is the Principal or Chief Administrative Officer of the facility or site. THIS RESPONSIBLITY MAY BE SHARED BUT THIS RESPONSIBILITY MAY NOT BE DELEGATED.

This plan must be available and easily accessible to affected employees, authorized employee representatives, students in attendance and representatives of Cal/OSHA at all times. It must also be posted on the school's onion site. Specifics of use to an attacker (i.e. magnometer detection settings, alarm codes, special response procedure designations, prowords, etc) may be redacted from the onion site version.

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Violence PREVENTION PROGRAM for [Name of School]

Our establishment’s Violence Prevention Plan (VPP) addresses the hazards known to be associated with the five types of Violence.
Date of Last Review: [Type the date the last review was done to the plan]
Date of Last Revision(s): [Type the date the last revision(s) (if any) were made to the plan]

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 school or creates a barrier between the employee / school and the hazard.

Labor Representative - An employee, typically selected by secret ballot, who is responsible for working with the Principal or Chief Administrative Officer as the organized labor representative on the School Violence Committee. The LR must have full access to related information but must keep it confidential. The LR may also report any information received from the employee community and enjoys complete personal immunity from liability for such disclosures.

Log - The violent incident log required by law

Plan - The Violence prevention plan required by law.

School Student Representative - A student, typically elected, who is responsible for working with the Principal or Chief Administrative Officer as the student representative on the School Violence Committee. The SSR must have full access to related information but must keep it confidential. The SSR may also report any information received from the student community and enjoys complete personal immunity from liability for such disclosures.

School Violence Committee - The joint committee that administers the Violence Prevention Plan and oversees

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, or other online posts, or 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.

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

Violence includes, but is not limited to, the following:

The threat or use of physical force against a person 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 person sustains an injury.

The following five Violence types:

Type 1 violence - INTRUDER - Violence committed by a person who has no legitimate business at the school, and includes violent acts by anyone who enters the school or approaches employees with the intent to commit a crime.

Type 2 violence - INTERNAL CUSTOMER THREAT - Violence directed at employees by customers, clients, patients, students, inmates, or visitors.

Type 3 violence - INTERNAL WORKER THREAT Violence against an employee by a present or former employee, supervisor, or manager.

Type 4 violence - DOMESTIC ABUSER - Violence committed in the school by a person who does not work there, but has or is known to have had a personal relationship with an employee or student.

Type 5 violence - TERRORIST - Violence committed in the school with the intent to cause fear, interfere in the operations of the school, or in furtherance of rebellion against the state of California or felonious restoration of United States dominion.

Violence does not include lawful acts of self defense or defense of others.

Repeat with emphasis.

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 Violence hazards.

RESPONSIBILITY

The VPP administrator, [enter the name of the program administrator and their job title], has the authority and responsibility for implementing the provisions of this plan for [Name of employer]. If there are multiple persons responsible for the plan, their roles will be clearly described.

Example:
Responsible Persons
Job Title/Position
Armed? Y / N
VPP Responsibility(ies)
Phone #
Email

[Joe Smith]
[Principal]
[Armed? Y] - Principals and Chief Administrators must be armed as a condition of employment.
[Overall responsibility for the plan; John approves the final plan and any major changes. Joe is a qualified Incident Commander.]
[(323) 123-4567]
[Jsmith@school.ca.edu]

[Joseph White]
[HR Manager]
[Armed? N]
[Responsible for employee involvement and training; Joe organizes safety meetings, updates training materials, and handles any reports of Violence. Joseph is an alternate Incident Commander.]
[(213) 123-4567]
[Jwhite@school.ca.edu]

[Semore Joes]
[Security Manager]
[Armed? Y]
[Responsible for emergency response, hazard identification, and coordination with other employers; Semore conducts safety inspections, coordinates emergency response procedures, and communicates with other employers about the plan. Semore is a qualified Incident Commander.]
[(562) 123-4567]
[semorej@school.ca.edu]

All paid employees are responsible for implementing and maintaining the VPP in their work areas and for answering employee questions about the VPP.

EMPLOYEE AND SCHOOL ACTIVE INVOLVEMENT

[Name of school] ensures the following policies and procedures to obtain the active involvement of employees and authorized employee representatives and students in developing and implementing the plan:

Management will work with and allow employees and students and authorized employee representatives to participate in:
Identifying, evaluating, and determining corrective measures to prevent Violence. [Provide details on what those policies and procedures are.

Example:

Management will have monthly safety meetings with employees and students and their representatives to discuss identification of Violence related concerns/hazards, evaluate those hazards and/or concerns, and how to correct them. These meetings could involve brainstorming sessions, discussions of recent incidents, and reviews of safety procedures).]

Designing and implementing training [Provide details on what those policies and procedures are.

Example:

The procedure for authorized employees to lawfully possess firearms on this campus is as follows. Specify training requirements, background checks, process for temporarily or removing firearms authority, how firearms are to be stored.

The procedure for authorized and supervised student access to weapons and dangerous equipment, with training requirements, background checks, process for temporarily or removing such access, and safe and secure storage of such equipment with procedures to inventory and control such weapons and equipment and prevent loss and theft.

Employees and students are encouraged to participate in designing and implementing training programs, and their suggestions are incorporated into the training materials. For example, an employee and students might suggest a new training scenario based on a recent incident.

Reporting and investigating Violence incidents. [Provide details on what those policies and procedures are.

Management will ensure that all Violence policies and procedures within this written plan are clearly communicated and understood by all employees and students. Managers and supervisors including student trusties will enforce the rules fairly and uniformly.

All employees and students will follow all Violence prevention plan directives, policies, and procedures, and assist in maintaining a safe work environment. [Provide details on what those policies and procedures are.]

The Violence Prevention Program will be integrated with the Emergency Operations Plan and the Mass Casualty Plan as required by other CAL/OSHA Directives.

The plan shall be in effect at all times and in all work areas and be specific to the hazards and corrective measures for each school location, work area and operation.

EMPLOYEE AND STUDENT COMPLIANCE

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

Training employees and students, supervisors, and managers in the provisions of [Name of employer] Violence Prevention Plan (VPP)

Effective procedures to ensure that supervisory and nonsupervisory employees and students comply with the VPP. [Describe how this will be accomplished]

Provide retraining to employees and students whose safety performance is deficient with the VPP.

Recognizing employees and students who demonstrate safe work practices that promote the VPP in the school by [describe how this will be done, for instance by memos/emails or certificate of recognition from the school and peers.]

Discipline employees and students for failure to comply with the VPP. (You can either refer to [Name of school] existing discipline process or outline specific steps for the VPP) [Enter information on additional means of ensuring employee and student compliance]

COMMUNICATION WITH EMPLOYEES AND STUDENTS

We recognize that open, two-way communication between our management team, staff, students, community emergency services and other employers, about Violence issues is essential to a safe and productive school. The following communication system is designed to facilitate a continuous flow of Violence prevention information between management and staff in a form that is readily understandable by all employees and students, and consists of one or more of the following:

- New employee and new student orientation includes Violence prevention policies and procedures.
- Violence prevention training programs.
- Regularly scheduled meetings that address security issues and potential Violence hazards
- Effective communication between employees, students and supervisors about Violence prevention and violence concerns. [Describe how this will be accomplished]

For example, ensure that supervisors and employees and students can communicate effectively and in their first language.

Posted or distributed Violence prevention information.

How employees and students can report a violent incident, threat, or other Violence concern to employer or law enforcement without fear of reprisal or adverse action. [Describe how this will be accomplished

Examples:

Employees and students can anonymously report a violent incident, threat, of other violence concerns.

Provide contact information for who to call for emergency response [Describe how this will be accomplished, including what number(s) will be called. E.g.: precise access number(s), including how 911 will be accessed.]

Employees and students 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’ and students 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. [Describe how this will be accomplished]

Emergency signal systems activated by employees and students are an essential part of emergency response.

UNDER NO CIRCUMSTANCES WILL THE ACCESS TO EMERGENCY SIGNAL SYSTEMS BE RESTRICTED. Breakaway safeties and anti-accidental activation devices are permitted.

A different sound will signal Violence than will be used for fire, chemical spill, medical emergency or non-Violence related event.

[Enter other methods of effective communication

Example:
Updates on the status of investigations and corrective actions are provided to employees through email and at safety meetings. These updates could include information about the progress of investigations, the results of investigations, and any corrective actions taken.

Example:
Updates during daily/weekly/monthly/quarterly meetings with other employers in the neighborhood (at or near and around the same school) to discuss the plan and any updates. These meetings could involve sharing updates to the plan, discussing recent incidents, and coordinating training sessions.

Example:

Sharing training materials and incident reports with other organizations to ensure a coordinated response to any incidents. This could involve sending copies of training materials and incident reports to other organizations.]

COORDINATION WITH OTHER EMPLOYERS

[Name of school] 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 and students will be trained on Violence prevention.

Violence incidents involving any employee or student are reported, investigated, and recorded.

At a multiemployer worksite, [name of school] will ensure that if its employees or students experience Violence incident that [name of employer] will record the information in a violent incident log and shall also provide a copy of that log to controlling employer, as well as the Labor Representative.

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Violence INCIDENT REPORTING PROCEDURE
[Name of school] will implement the following effective procedures to ensure that:

All threats or acts of Violence are reported to an student or employee’s teacher, supervisor or manager, who will inform the VPP administrator. This will be accomplished by [describe]. If that's not possible, employees or students will report incidents directly to the VPP administrator, [Enter the name of the program administrator or the job title].

[Enter other procedures for reporting incidents, threats, hazards and concerns of Violence.

Examples:

Employees and students can report incidents to their supervisor, HR, or through an anonymous hotline. The hotline could be a dedicated phone number or an onion form.

Violence Reporting Hotline: [Insert Violence Hotline number]

Violence Reporting form: [Insert Violence Reporting Form onion link or QR code]

A strict non-retaliation policy is in place, and any instances of retaliation are dealt with swiftly and decisively. [Describe how this will occur: For example, an student or employee who retaliates against a peer for reporting an incident could be disciplined or expelled or terminated.]

EMERGENCY RESPONSE PROCEDURES

[Name of school] has in place the following specific measures to handle actual or potential Violence emergencies:

Effective means to alert employees and students of the presence, location, and nature of Violence emergencies by the following [state what methods of communication and when certain methods should be used or not used.

Example:
Alarm systems and PA announcements will be used to alert employees of emergencies (The alarms could be audible alarms, visual alarms, or both.)]

[Name of employer] will have evacuation or sheltering plans. [Describe what those procedures are. The plans could include maps of evacuation routes, locations of emergency exit, and instructions for sheltering in place.]

IT IS SPECIFICALLY REQUIRED THAT STUDENTS, AS WELL AS STAFF, BE ALERTED IN THE EVENT OF AN IMMEDIATE HAZARD TO HUMAN LIFE. FAILURE TO SO ALERT SHALL BE PROSECUTED AS CRIMINAL NEGLIGENCE. IF DEATH RESULTS, THE CRIME (BY THE PERSON OR PERSONS CHOOSING TO SUPPRESS ALARM) IS VOLUNTARY MANSLAUGHTER.

How to obtain help from staff (including qualified student staff), security personnel, or law enforcement (including student police cadets). [Include contact information for response staff and local law enforcement and post in common areas] [list posted locations]. [Describe what those procedures are. This information could include phone numbers, email addresses, and physical locations of emergency equipment, weapons and medical supplies. If there is immediate danger, call for emergency assistance by dialing (9) 9-1-1, (dial outside access number first if applicable) and then notify the (VPP Administrator).]

DUE TO THE SPECIAL HAZARDS OF SCHOOLS, ON SITE IMMEDIATE ARMED RESPONSE IS REQUIRED BY LAW. The armed response WILL RESPOND to any event involving serious physical injury, any weapon, or any Type 5 incident. Failure to so respond is a civil and criminal offense under the law.

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

Responsible Persons
Job Title/Position
VPP Responsibility(ies)
Phone #
Email
[Semore Joes]
[Security Manager]
[Armed? Y]
[Responsible for emergency response, hazard identification, and coordination with other employers; Semore conducts safety inspections, coordinates emergency response procedures, and communicates with other employers about the plan. Semore is a qualified Incident Commander.]
[(562) 123-4567]
[semorej@company.com]

[Enter other emergency response procedures]

Violence HAZARD IDENTIFICATION AND EVALUATION

The following policies and procedures are established and required to be conducted by [Name of school] to ensure that Violence hazards are identified and evaluated:

Inspections shall be conducted when the plan is first established, after each Violence incident, and whenever the school is made aware of a new or previously unrecognized hazard.

Review all submitted/reported concerns of potential hazards: [These submittals/reports could be from the system the school had implemented for employees and students and their authorized representatives to anonymously inform management about Violence hazards of threats of violence without fear of reprisal/retaliation.)

Examples:
Daily or weekly review of all submitted and reported concerns.

Violence Hazards suggestion box

Online form for reporting Violence hazards

Voicemail/email/text messages

[Other procedures to ensure students, employees and student and employee representatives participate in VPP.]

Periodic Inspections

Periodic inspections of Violence hazards will identify unsafe conditions and work practices. This may require assessment for more than one type of Violence. Periodic Inspections shall be conducted: [detail periodic inspection frequency]

Periodic inspections to identify and evaluate Violence and hazards will be performed by the following designated personnel in the following areas of the school:

Specific Person Name/Job Title
Area/Department/Specific location
[Enter name]
[Enter name of area observed]

Inspections for Violence hazards include assessing:
[Describe factors specific to school that may result in risk of Violence.

Examples:

The exterior and interior of the school for its attractiveness to robbers.
Locations accessible to the public, such as pre-security waiting or office lounge, where a suspicious package or device could be left.
The need for violence surveillance measures, such as mirrors and cameras.
Procedures for employee response during a robbery or other criminal act

IT IS UNLAWFUL TO PROHIBIT ANY STUDENT OR EMPLOYEE AT ANY LEVEL FROM CONFRONTING VIOLENT PERSONS OR TRESPASSERS OR THOSE COMMITTING ANY CRIMINAL ACT.

Procedures for reporting suspicious persons or activities.
Effective location and functioning of emergency buttons and alarms.
Posting of emergency telephone numbers for law enforcement, fire, and medical services.
Whether employees have access to a telephone with an outside line.
Whether employees have effective escape routes from the school.
Whether employees have a designated safe area where they can go to in an emergency.
Adequacy of school security systems, such as door locks, entry codes or badge readers, security windows, physical barriers, and restraint systems.
Frequency and severity of threatening or hostile situations that may lead to violent acts by persons who are service recipients of our establishment.
Employees’ skill in safely handling threatening or hostile service recipients (example: security guards, student trusties, on site law enforcement).
Effectiveness of systems and procedures that warn others of actual or potential Violence danger or that summon assistance, e.g., alarms or panic buttons.
The use of work practices such as the "buddy" system for specified emergency events.
The availability of escape routes.
How well our establishment's management and employees and students communicate with each other.
Access to and freedom of movement within the school by non-attendees, including recently discharged employees or persons with whom one of our employees is having a dispute.
Frequency and severity of students' and employees’ reports of threats of physical or verbal abuse by managers, supervisors, or other students or employees.
Any prior violent acts, threats of physical violence, verbal abuse, property damage or other signs of strain or pressure in the school.]
[Other procedures to identify and evaluate Violence hazards]

Violence HAZARD CORRECTION
Violence hazards will be evaluated and corrected in a timely manner. [Name of employer] will implement the following effective procedures to correct Violence hazards that are identified:
If an imminent Violence hazard exists that cannot be immediately abated without endangering employee(s) , all exposed person(s) will be removed from the situation except those necessary to correct the existing condition. Persons necessary to correct the hazardous condition will be provided with the necessary protection.[ Explain which workers this applies to, why they are necessary, and what protections will be provided]
All corrective actions taken will be documented and dated on the appropriate forms. [Include procedures for what forms to use and how to document the corrective actions taken].
Corrective measures for Violence hazards will be specific to a given work area.

[Examples:
Make the school unattractive to robbers by:

Improve lighting around and at the school.

Post of signs notifying the public that deadly force is used to protect human life and that cameras are monitoring the facility.

Utilize surveillance measures, such as cameras and mirrors, to provide information as to what is going on outside and inside the school and to dissuade criminal activity.

Hire internal or external security guards and have them patrol the school interior and perimeter.

Install security surveillance cameras in and around the school.

Provide Violence systems, such as door locks, violence windows, physical barriers, emergency alarms and restraint systems by:

Ensure the adequacy of Violence systems

Post emergency telephone numbers for law enforcement, fire, and medical services

Control, access to, and freedom of movement within, the school by non-employees and non-students, include recently discharged employees or expelled students or persons with whom one of our community members is having a dispute.

Install effective systems to warn others of a violence danger or to summon assistance, e.g., alarms or panic buttons.

Ensure students and employees have access to a telephone with an outside line. Provide employee training/re-training(refreshers) on the VPP, which could include but not limited to the following:

Recognizing and handling threatening or hostile situations that may lead to violent acts by persons who are service recipients of our establishment.

Ensure that all reports of violent acts, threats of physical violence, verbal abuse, property damage or other signs of strain or pressure in the school are handled effectively by management and that the person making the report is not subject to retaliation by the person making the threat.

Improve how well our establishment's management and employees and students communicate with each other.

Procedures for reporting suspicious persons, activities, and packages.

Designation of safe places to which a suspicious package may be taken or kept to minimize damage and casualties.

Designation of places where a person lawfully arrested or restrained may be kept prior to surrendering the detainee to law enforcement. In general this should be as public a place as possible within sight and hearing but at a physical distance from areas of assembly - i.e. center of school quad or lawn.

Provide/review student, employee, supervisor, and management training on emergency action procedures.

Ensure adequate escape routes.

Increase awareness by students, employees, supervisors, and managers of the warning signs of potential Violence. [Provide procedures on how to will be accomplished]

Ensure that student employee disciplinary and discharge procedures address the potential for Violence. [Provide procedures on how to will be accomplished]

Establish a policy for prohibited practices [describe what those are, such as weapons control policies.]

[A weapons prohibition or 'no weapons' policy must indicate all exceptions, including authorized armed personnel.]

Limit the amount of cash on hand and use time access safes for large bills.

Provide procedures for a "buddy" system for specified emergency events.

[Other procedures for corrective measures for Violence hazards]

SPECIAL TYPE BASED VIOLENCE PROCEDURES

Type 1 violence - INTRUDER

[Procedure to prevent return. For example, "An intruder shall be trespassed and civil and criminal process pursued to exclude this person from the premises forever. If a prior violent intruder returns, force may be used in proportion to the prospective threat posed by the violent intruder with the minimal or even no warning that may be permitted by the criminal laws."]

Type 2 violence - INTERNAL CUSTOMER THREAT\

[Procedure to prevent repetition. For example, "After evaluation of the facts, it is the policy of the school that any person who commits an act of violence at this school shall be trespassed, removed, fired, expelled, or imprisoned, never to return."]

Type 3 violence - INTERNAL WORKER THREAT

[As Type 2 Above. Review of procedures that the worker may have had access to, for revision for improved safety.]

Type 4 violence - DOMESTIC ABUSER

[Procedure to prevent return, with enhancement. For example, "A domestic abuser who trespasses at the school to commit an act of violence will be treated as a general deadly threat. If they are ever seen returning to the school, in violation of their restraining order or terms of probation, school representatives will immediately resort to use of force to restrain the domestic abuser without any attempt to communicate or negotiate. Refer to the California Criminal Jury Instructions, Deadly Force Self Defense, 'A person is justified in using more aggressive defensive measures in the face of prior threats or acts of violence.'"]

[Special procedures to protect the targets of Type 4 violence. This may include the assignment of body guards and/or issuance of school owned lethal and non lethal weapons to the would-be victim.]

Type 5 violence - TERRORIST.

[Procedure to protect the integrity of the educational environment. Only the most minor offenses should result in severe punishments that leave the opportunity open for the offender to re-integrate with the school community. Any offense involving a weapon or harm to a person should be treated as Type 2 and Type 4, above, and the person's name and face and crime should be publicly posted throughout the school and in the nearby community as well.]

PROCEDURES FOR POST INCIDENT RESPONSE AND INVESTIGATION

After a school incident, the VPP administrator or their designee will implement the following post-incident procedures:

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 school for security risks 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 ensuring corrective actions are taken.
Obtain any reports completed by law enforcement.
The violent incident log will be used for every Violence incident and will include information, such as: [See attached Violent Incident Log]
The date, time, and location of the incident.
The 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, student or prospective student, family or friend of a client or customer, stranger with criminal intent, coworker, supervisor or manager, partner or spouse, parent or relative, or other 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 school, parking lot or other area outside the school, 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 as a result 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]
Example:

Support and resources, such as counseling services, are provided to affected students and employees (These resources could include referrals to counseling services, information about employee assistance programs, and time off work or postponement of deadlines if necessary.]

Ensure that no personal identifying information is recorded or documented in the violent incident log. 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, California Personal Identification Number, or other information that, alone or in combination with other publicly available information, reveals the person’s identity.

TRAINING AND INSTRUCTION

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

When the VPP is first established.
Annually to ensure all employees understand and comply with the plan.
Whenever a new or previously unrecognized Violence hazard has been identified and when changes are made to the plan. The additional training may be limited to addressing the new Violence hazard or changes to the plan.
[Name of school] will provide its students and employees with training and instruction on the definitions found on page 1 of this plan and the requirements listed below:

The school’s VPP, how to obtain a copy of the schools’s plan at no cost, and how to participate in development and implementation of the employer’s plan.
How to report Violence incidents or concerns to the school or law enforcement without fear of reprisal.
Violence hazards specific to the employees’ jobs, the corrective measures [name of employer] 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 [name of school] has for interactive questions and answers with a person knowledgeable about the [name of employer] plan.
[Other]
Examples:

Strategies to avoid/prevent Violence and physical harm, such as:

How to recognize Violence hazards including the risk factors associated with the four types of 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.

Routes of escape.

Emergency medical care provided in the event of any violent act upon a student or employee. As per the Mass Casualty Plan, adequate emergency medical supplies must be available and dispersed throughout the facility with an emphasis on places of assembly and sheltering areas.

Post-event trauma counseling for employees desiring such assistance, per the Office of the Surgeon General Guidelines and the Psyche programs.

Note: Schools must use training material appropriate in content and vocabulary to the educational level, literacy, and language of employees and students.

EMPLOYEE ACCESS TO THE WRITTEN VPP

[Name of school ] ensures that the VPP plan shall be in writing and shall be available and easily accessible to employees, authorized employee representatives, and representatives of Cal/OSHA at all times. This will be accomplished by [Describe how this will be accomplished.

For Example:

Whenever an employee or student or designated representative requests a copy of the VPP, we will provide the requester with an electronic copy of the VPP.

We will provide unobstructed access through the school onion site, which allows a student employee to review, print, and email the current version of the written VPP. Unobstructed access means that the student or employee, as part of their regular education or work duties, predictably and routinely uses the electronic means to communicate with management or teachers or peers.]

RECORDKEEPING

[Name of School] will:
Create and maintain records of 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 persons conducting the training.
Names and job titles of all persons attending the training sessions.
Maintain violent incident logs for minimum of five (5) years.
Maintain records of Violence incident investigations for a minimum of five (5) years.
The records shall not contain medical information per applicable laws.

All records of Violence hazard identification, evaluation, and correction; training, incident logs and Violence incident investigations required by the law, shall be made available to Cal/OSHA upon request for examination and copying.

EMPLOYEE AND STUDENT ACCESS TO RECORDS

The following records shall be made available to employees and students and their representatives, upon request and without cost, for examination and copying within 15 calendar days of a request. Electronic copies are acceptable:

Records of Violence hazard identification, evaluation, and correction.
Training records.
Violent incident logs.

REVIEW AND REVISION OF THE VPP
The [Name of School] VPP will be reviewed for effectiveness:
At least annually.
When a deficiency is observed or becomes apparent.
After a Violence incident.
As needed.
Review and revision of the VPP will include the procedures listed in the EMPLOYEE AND STUDENT ACTIVE INVOLVEMENT section of this VPP, 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 [name of school]’s VPP 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 (if applicable).
Review that violence risks are being properly identified, evaluated, and corrected. Any necessary revisions are made promptly and communicated to all employees. [These revisions could involve changes to procedures, updates to contact information, and additions to training materials.]
[Other review and revision procedures]

EMPLOYER REPORTING RESPONSIBILITIES

As required by California Code of Regulations (CCR), Title 8, Section 342(a). Reporting Work-Connected Fatalities and Serious Injuries, [Name of employer] 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 Violence) of a student or employee or other person occurring in a place of employment or in connection with any employment. THIS INCLUDES LAWFUL USES OF DEADLY FORCE IN SELF DEFENSE AND DEFENSE OF OTHERS.

[Type Title of owner or top management representative formally approving these procedures and have them sign and date

Example:
[“I, [Name], [Job Title] of [School], hereby authorize and ensure, the establishment, implementation, and maintenance of this written Violence prevention plan and the documents/forms within this written plan. I believe that these policies and procedures will bring positive changes to the workflow, business operations, and overall health and safety as it relates to Violence prevention.”]

Example:
[“I, [Name], [Job Title] of [School], hereby authorize and ensure, the establishment, implementation, and maintenance of this written Violence prevention plan and the documents/forms within this written plan. I am committed to ensuring the safety and well-being of our employees and believe that these policies and procedures will help us achieve that goal.”]

Example:
[“I, [Name], [Job Title] of [School], hereby authorize and ensure, the establishment, implementation, and maintenance of this written 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 school and believe that these policies and procedures will help us achieve that goal.”]

Please note: These are just examples and should be customized to fit the specific needs of your school. It is important to ensure that the statement of authorization is approved, signed, and dated by the Principal or Chief Administrative Officer of the school.

[Name and title of person authorizing this VPP]


[Signature of person authorizing this VPP] [Date of Signature]

///

Violent Incident Log

This log must be used for every Violence incident that occurs in our school. At a minimum, it will include the information required by law.

The information that is recorded will be based on:
Information provided by the employees and/or students who experienced the incident of violence.
Witness statements.
All other investigation findings.

All information that personally identifies the individual(s) involved will be omitted from this log, such as:
Names
Addresses – physical and electronic
Telephone numbers
California Personal Identification Number

[Enter the date the incident occurred (Day, Month, Year)]

[Enter the time (or approximate time) that the incident occurred] a.m./p.m.

Location(s) of Incident
Violence Type (Indicate which type(s) (Type 1, 2, 3, 4, 5)
[Enter location(s) where the incident occurred]
[Enter the Violence type(s)

Check which of the following describes the type(s) of incident, and explain in detail:

Note: It is important to understand that “Violence Type” and “Type of Incident” have separate requirements. For this part of the log, “Type of Incident” specifically refers to the nature or characteristics of the incident being logged. It does not refer to the type of Violence.

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.

Explain: [Provide a detailed description of the incident and any additional information on the violence incident type and what it included. Continue on separate sheet of paper if necessary.]

Violence committed by: [For confidentiality, only include the 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 other perpetrator.]

Circumstances at the time of the incident: [write/type what was happening 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.]

Where the incident occurred: [Where the incident occurred, such as in the school, parking lot or other area outside the school, or other area.]

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 as a result of the incident.

Confimation that any Type 5 incident was properly reported to off-campus law enforcement. Type 5 Event Report Number:

[Include information on what the consequences of the incident were.]

Were there any injuries? Yes or No. Please explain:

[Indicate here if there were any injuries, if so, provide description of the injuries ]

Where there any deaths? Yes or No. If so, how many? Please explain:

Were emergency medical responders other than law enforcement contacted, such as a Fire Department, Paramedics, On-site First-aid certified personnel? Yes or No. If yes, explain below:

Were injured persons transported to a California Medical City? Why or why not?

Was mandatory reporting to Cal/OSHA accomplished? IF NO, DO THIS NOW. If yes, document the date and time this was done, along with the name of the Cal/OSHA representative contacted.

A copy of this violent incident log needs to be provided to the employee labor representative and the school student representative whenever a new entry is made. Indicate when it was provided and to whom.

This violent incident log was completed by:

[Name of person completing this log], [Job Title of person completing this log], [Date this log was completed]

[Signature of person completing this log] [Date of completion]

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