Stop bullying

Predicting Failure for Your Workplace Violence Policy

Dec. 27, 2017
You can have the best, most comprehensive workplace violence policy that ever existed, but if you don't communicate and enforce it with employees at all levels, it's worthless.

Adopting a good workplace violence policy is a first step and earns you a point from me. The second step, once you have a good policy in place, is to communicate it to your managers and staff and to reinforce it every year or two because of employee turnover and to reinforce the messaging.

If you have a good policy and you communicate it well, you get two points from me and that is a good start, but it is still not enough. If you want to have a workplace that attracts and keeps talent, you have to enforce your policy.

Here is an example of a good policy that is a failure. Don’t let this happen in your organization.

Breakdown in Communication of a Good Policy

First, let us look at what seems to be an apparent failure in the communication of the U.S. Department of Health and Human Services’ (HHS) workplace violence policy, “Understanding and Responding to Workplace Violence” of 2008. When I first collected cabinet-level workplace violence policies in 2013, HHS’s policy was the best. (In 2017, I started looking for it to see whether it had been updated.) Note that the problem is not with the policy itself.

Unfortunately, in the course of reaching out to many offices, I found that few HHS employees knew about the department’s workplace violence policy. With one exception, the immediate staff and managers working under John Bardis, the assistant secretary for administration of HHS, did not know that HHS had a workplace violence policy.

The senior staff and managers who should have known about the policy did not, which means there likely was a lack of knowledge about it among rank-and-file employees.

Employees Need to Know Your Policy

Should employees know about your workplace violence policy? Definitely, and particularly if it is specified in your operating procedures. In the case of the HHS employees, there appears to be a failure to carry out the Standard Operating Procedure for Violence in the Workplace (OHR SOP 700 WRD/CSC 04, issued 8/19/2011).

The SOP for Violence in the Workplace, Section V. Responsibilities, paragraph B, essentially states that managers and supervisors are responsible for “ensuring all employees are fully informed of and understand HHS workplace violence policy and procedures.”

So, employees are supposed to know, but only one with whom I spoke knew what I was talking about. That manager did get back to me with the requested policy. I was delighted, so I asked where he found it (I wanted the new URL). He said he could not find it on the HHS web site, he happened to have a copy of it.

HHS states: “The Department is committed to working with its employees to maintain a work environment free from violence, threats of violence, harassment, intimidation and other disruptive behavior.” However, that commitment to maintain a good work environment is worthless if HHS employees don’t know about the workplace violence policy or HHS’s commitment to it.

A Further Check on My Findings

The National Institute for Occupational Safety and Health (NIOSH) is part of the Centers for Disease Control (CDC), which is a part of HHS. NIOSH has studied and published research about workplace violence, including bullying.

To see whether the message of the HHS workplace violence policy had gotten to the CDC, I called them to inquire about workplace violence policies at the CDC. The HR office turned me over to the office that handled Freedom of Information Act (FOIA) requests, and it required a formal application for that information. I requested all the workplace violence policies that applied to CDC.

The FOIA office got back to me with the CDC’s policy, but not the HHS policy! They apparently do not know about the HHS policy, which applies to ALL employees of HHS – including the CDC. This is sad, because the HHS policy of 2008 significantly is better than the CDC’s own policy.

“Understanding and Responding to Workplace Violence” (of 2008) was on the HHS public web site. When I looked, it was gone. I suggest putting it back on the public site. It will help the public and HHS’ own employees find it. Also, tell subordinate agencies about the policy.

Issues Not Limited to HHS

For an article I wrote for EHS Today on bullying and retaliation, I looked at workplace violence policies in a random selection of hospitals around the country. I looked at their web sites and I called their HR offices, public affairs offices and union offices to find more information.

I did find policies (on their web sites or through my phone calls) and they were very respectable policies. I did have difficulty finding people who knew about the hospitals’ policies. People with whom I spoke also didn’t know about the anti-bullying policy required of every accredited hospital by the Joint Commission – another good policy. I was surprised and disappointed to learn that the union officers and the HR personnel didn’t know about these policies.

You can have a good or even a great policy. But if you don’t get the word out, the policy is worthless. Don’t let this happen in your organization. It will contribute to a loss of talent.

About the author: Edward Stern served the U.S. Department of Labor for more than 40 years as a senior economist and policy/program analyst.

About the Author

Edward Stern | Researcher and Expert Witness

Edward Stern served the U.S. Department of Labor for 40+ years as a senior economist and policy/program analyst. He developed regulations, analyzed enforcement strategies and innovated methods of compliance assistance. For the last 27 years, in OSHA, he examined health and safety risks and regulatory feasibility. He also led teams of scientists, IH’s, engineers, doctors, nurses, systems analysts and attorneys from the Department of Labor and the public sector to develop interactive, diagnostic “Expert Advisors” to answer which, whether and how OSHA rules applied to situations. DOL adopted this approach for many other labor law issues. He presented a study on bullying at the Labor and Employment Relations Association annual conference in 2007. He wrote the workplace bullying and psychological aggression chapter of “Halt the Violence” (e-book, Amazon). He is a researcher and advisor on workplace bullying to management and labor, and an accepted, expert witness on bullying in arbitration cases. As a retired fed, he represents AFGE Local 12 on the USDOL Workplace Violence Committee. He can be reached at [email protected].

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