In 2014, the legislature passed a law that requires the Occupational Safety and Health Standards Board (OSHSB) to establish standards that require health facilities to adopt workplace violence prevention plans. OSHSB recently issued proposed regulations to implement this law.

The California Medical Association (CMA) views violence as a public health issue and supports policies that prohibit and punish anyone who by force or threat of force, intentionally injures, intimidates or interferes with any person who is or has been providing health services. We recognize the potential risks faced by physicians and their employees in office settings and the need for physicians to assess the risks and develop plans for preventing workplace violence.

CMA recently submitted comments on the proposed regulations, voicing the association's concerns about the "one size fits all" proposal given the wide variation in the types of office-based physician practices, which can vary by number and type of employees, physical plant, geographic location, specialty and financial resources. While providing guidance to these physician employers regarding the need to develop workplace violence prevention plans and the elements that could be included would be a valuable resource, establishing a regulatory mandate to develop a plan, employee training and recordkeeping processes with highly prescriptive requirements places a substantial burden on physician practices that could impact the provision of patient care. The proposed regulations establish a “one size fits all” framework that would apply substantially the same requirements for a solo rural physician practice and the largest acute care hospitals in the state, regardless of actual needs and resources.

CMA recommended several changes to the proposed regulations, including:

• Revising the overly broad definition of workplace violence so that actions that are more appropriately categorized as conflicts between coworkers do not need to be reported as workplace violence incidents.


• Developing simplified requirements that provide a less formal mechanism to allow physician small business employers to develop workplace violence prevention plans and policies.


• Consider moving prescriptive specifications regarding risk factors and possible security measures out of the proposed regulations and into an external guidelines document that can be adopted as appropriate to the health care setting, as well as more easily updated as needed.


• Setting the deadline for full implementation of the regulations to no earlier than one year after the effective date of the regulations.

Contact: Yvonne Choong, (916) 551-2884 or ychoong@cmadocs.org.