Workplace Violence (2019) – Guidelines
These guidelines are intended to assist divisions in meeting Occupational Health and Safety Act and Workplace Violence Policy obligations. The Workplace Violence Policy and Guidelines for Implementing the Workplace Violence Policy define workplace violence, set out the roles and responsibilities of employees and management in preventing workplace violence, as well as for reporting, investigating and following up on incidents of workplace violence.
The procedures that are developed by a division based on these guidelines will form part of the division’s overall health and safety program. It is recommended that these procedures be developed and implemented in cooperation and consultation with the assigned People, Equity & Human Rights (PEHR) health and safety (H&S) consultants, joint health and safety committees (JHSCs) or health and safety representatives, and where appropriate, Corporate Security.
The potential for workplace violence and the nature of the workplace violence risk experienced within divisions is expected to vary based on the nature of the workplace and work performed. To ensure clarity, it is recommended that divisions describe their interpretation of the definition by using examples of inappropriate behaviours and acts among employees and among the clients and public with whom they come into contact.
The nature and extent of the program will be based on the risk factors/hazards and potential hazards identified by the risk assessment and should include the following elements:
1. Workplace Violence Risk Assessment
Conduct an initial evaluation to determine whether a risk of violence exists due to the nature of the workplace, the type of work or the conditions of work. A Workplace Violence Risk Assessment Form is provided as Appendix A. Divisions may add questions to this Form, if needed, to ensure all aspects of workplace violence within their workplaces and work operations are addressed. Management is encouraged to involve PEHR Health & Safety consultants and JHSCs in the evaluation.
The risk assessment includes a review of:
- past incidents
- past employee complaints
- past JHSC or OH&S representative reviews and recommendations
- employee concerns identified through interviews or surveys
- current work situations with potential for violence
- physical premises
The steps include:
- Reviewing past incident, injury and other reports (e.g., Security, Ministry of Labour orders) regarding incidents of violence and identifying the potential for violence, the circumstances contributing to the cause of the incident(s) and any recommendations made.
- Reviewing past employee complaints or concerns regarding workplace violence and actions that were taken or that should be taken to address these concerns.
- Reviewing past JHSC or OH&S representative discussion and recommendations regarding workplace violence.
- Considering interviewing staff to ascertain their experiences of workplace violence, to ascertain whether workplace violence controls are in place, are adequate or are in need of enhancement. A Sample Workplace Violence Employee Survey is provided as a tool that may be used for this purpose (Appendix B).
- Reviewing work situations that may place employees at risk of workplace violence and identifying risk factors.
- Reviewing physical premises (the workplace) to identify risk factors that may result in workplace violence.
At the end of the Workplace Violence Risk Assessment, work locations/work operations will have identified workplace violence risk factors that will require controls. These controls may already be in place or may need to be introduced and implemented.
These risk assessments are to be reviewed at least annually, as well as when there are changes to the nature of the workplace, the type of work or the conditions of work. Further risk assessments are also to be completed when an increase in the number and/or severity of workplace violence incidents is noted, in order to ensure that appropriate measures are in place to minimize or eliminate risks identified during investigation of these incidents. The risk assessment document should be revised to reflect changes identified as needed through the review process. The results of workplace violence risk assessment reviews and the measures in place to minimize or eliminate risks should be communicated to all employees to whom the assessment and protective measures apply.
2. Completion of Workplace Violence Risk Factors and Controls Checklist
A Workplace Violence Risk Factors and Controls Checklist (Appendix C) has been developed to assist divisions in identifying appropriate controls for identified risk factors. It should be noted that the list of identified controls by risk factor may not represent all measures available. Nor does one risk factor necessitate implementation of all measures listed. The application of identified and other controls should be evaluated within the context of the work environment and risk factors identified. Divisions are required to identify and implement controls appropriate to their workplaces and work operations.
While a Workplace Violence Risk Factors and Controls Checklist may be completed for clusters of similar positions or similar work locations, risk factors unique to individual work locations or operations must also be considered.
Where workplace violence risk factors (including potential risk factors) are identified, evaluation and implementation of appropriate corrective actions are required to ensure reasonable and practical measures are taken to reduce or eliminate the hazard or risk. Wherever possible, consideration should be given to re-organization of the work to eliminate the risk factor. If removal of the risk is not feasible with work organization changes, an effort to minimize the remaining risks through physical security improvements. It should be noted that divisional policies, safe work procedures, worker training, incident reporting and investigation, record keeping and regular program evaluation will be required regardless of risk factors identified or controls that are introduced.
3. Develop and implement appropriate violence prevention procedures
Where the need is identified through a risk assessment, divisions should develop and implement the procedures to:
- Establish a communication/warning system to alert employees of potentially violent or disruptive clients in the context of the work environment, potentially dangerous work locations, or job duties based on the findings from the risk assessment
- Describe the organizational and security controls introduced to prevent incidents of violence
- Establish well defined limits of employee responsibility in carrying out their duties
- Provide direction to employees on safe response methods to potentially violent individuals
- Describe how incidents are to be responded to, reported, documented, investigated, and addressed
- Describe the interpretation of the definition of violence including unacceptable behaviours within the context of the work environment of the division’s employees. To the extent possible, provide examples of workplace violence and examples of code of conduct violations.
- Define and document the appropriate remedial or disciplinary/legal action to be taken against a perpetrator of violence and a perpetrator of reprisal against an employee according to the nature of the incident
- Post the policy and divisional procedures at each work location where a violence hazard or the potential for violence has been identified. Ensure that the posted version of the policy is current (dated within a one-year period).
4. Develop and implement a process for responding to, investigating, and reporting incidents
Where a potential risk factor/hazard is identified through the risk assessment, a procedure for responding to emergencies and other incidents of violence is required.
All workplace violence incidents must be reported, investigated and acted upon, as appropriate.
Management Response, Investigation and Reporting:
- In the event of an emergency, contact Police and Paramedic Services (9-911 for internal phones or 911 for external phones), state the nature of the emergency and indicate that the Police (and if there are injuries), Paramedic Services are required.
- Follow the requirements of the City’s Critical Injury Investigation & Reporting policy if the workplace violence incident results in a critical injury.
- Follow the requirements of the City’s Investigation and Reporting of Work-Related Injuries and Incidents policy for workplace violence incidents (e.g. lost time, medical aid, first aid, near miss/incident only).
- Three documents have been developed to assist with the investigation and reporting process:
- A Workplace Violence and Threat Report – supervisor and employee portion (Appendix D)
- A Workplace Violence Incident Response Contact List (Appendix E)
- A Supervisor Checklist for Addressing Workplace Violence Incidents (Appendix I)
- A Workplace Violence and Threat Report ( supervisor and employee portion) is to be completed whenever there is a workplace violence incident (critical injury, lost time, medical aid, first aid, near miss/incident only). A Supervisor’s Report of Injury/Incident must also be completed when staff are injured and require medical aid and/or lost time. A copy of completed forms must be submitted to the appropriate People, Equity & Human Rights Consultant (WSI) for the service area.Note: When a Supervisor’s Report of Injury/Incident is being completed within Quatro Safety, the supervisor’s portion of the Workplace Violence and Threat Report is completed on-line. Under these circumstances, the employee is to be provided the employee portion of the Workplace Violence and Threat Report and to be given an opportunity to complete and submit it for attachment to the Workplace Violence and Threat Report that is tabled with the joint health and safety committee]. The employee section is available as a separate form (Workplace Violence and Threat Report – Employee Description of Incident) on the Health and Safety Intranet site].
- In accordance with the Criminal Code, physical violence or threats of physical violence must be reported to the Toronto Police Services. Depending on the circumstances, management or the assaulted/threatened employee will file this report. [Note: Toronto Police Services may prefer or expect that the report be made by the person directly involved]. In the event that management and the employee who reported an incident are in disagreement on whether the reported incident constitutes workplace violence, either party has the right to contact the police to report the incident should they believe it appropriate to do so.
- In accordance with the Corporate Security Policy, ensure all security related incidents are reported promptly to Corporate Security.
- Other actions that may be taken in investigating and responding to a workplace violence incident are:
- Consult People, Equity & Human Rights health and safety consultants and/or local JHSC/H&S representative regarding the investigation and identification of causation and corrective measures
- Consult the Employee Assistance Program to discuss an appropriate plan of response for critical incidents and ensure that support services are offered to victims and witnesses of violence
- Debrief staff of the incident, actions taken, and further steps that can be taken to prevent a recurrence
- Consult the Human Rights Office regarding issues of harassment, Employee and Labour Relations regarding disciplinary action, the Toronto Police Services and/or the City’s Legal Services regarding criminal charges
Divisions must establish an internal communication process to ensure workers are informed of the potential for violent behaviour among the clients they service. Additionally, consideration is to be given to notification of other divisions whose staff may be at risk if divisions encounter members of the public or clients with a history of violent behaviour.
In accordance with the decision of the Occupational Health and Safety Coordinating Committee (Appendix J), the applicable union(s) are to be notified of the following types of workplace violence events:
- A shooting at, or impacting, a City building
- A lockdown where police are involved and whereby external doors are locked
- A building evacuated for workplace violence reason
- Any incident involving an assault where police are contacted
- Use or threatened use of a weapon, including a firearm
- The nature of the incident means that media are involved or are likely to be involved
- The incident is sufficiently significant to be escalated to senior management
Management (either directly involved or delegated) are to notify the applicable union(s) via e-mail as soon as practicable and no longer than 3 business days after the incident. JHSC co-chairs are to be copied on the e-mail. A copy of the Workplace Violence and Threat Report (both sections – supervisor and employee) regarding the incident is to be provided.
The process should also include the response to employee reports of workplace incidents associated with domestic violence (i.e., the abusive partner harasses, threatens, stalks, etc. a City employee). The consequences of ignoring the presence of domestic violence in the workplace can be very grave for the abused employee and co-workers. Please refer to the City’s policy and guidelines entitled to “Addressing Domestic/ Intimate Partner Violence in the Workplace“.
5. Provide information and instruction to staff as appropriate to the extent of the hazards identified
Divisional management staff are to advise their employees of the results of workplace violence risks assessment and of the violence-related risks associated with their jobs. Employees at risk or potential risk and their supervisors must receive specific instruction in the identification of hazards and appropriate prevention and response procedures. Records of instruction must be maintained. The frequency of refresher instruction should be determined in consultation with the assigned H&S consultant.
It is also recommended that employees be informed that they can seek advice and assistance from their supervisor, JHSC/H&S representative, designated Human Resources health and safety consultant, Corporate Security, Employee Assistance Program, their union or staff association, and the Human Rights Office. Information provided by employees to the Human Rights Office and the Employee Assistance Program will remain confidential and will only be released with their informed, written consent. The exceptions to this are situations where individuals may pose a serious threat to themselves or others, or where required by law (e.g., the mandatory reporting of suspected child abuse).
All employees are to have access to information and instruction. Appendix F provides information with respect to workplace violence information and instruction resources. Appendix G is a safety talk regarding workplace violence that can be used by supervisory staff during staff meetings or tailgate talks to ensure that all employees, regardless of the risk factors that are associated with their jobs, are aware of:
- the City’s commitment to preventing workplace violence, its policy and program
- how to summon immediate assistance
- how to report incidents of workplace violence
- how the employer will investigate and deal with incidents, threats and complaints
This safety talk must be supplemented with information with respect to measures and procedures that are in place to protect employees from workplace violence and expectations of employees regarding procedures that are part of the division’s workplace violence program.
6. Program Review
After the implementation of the policy, annual review of the policy is required to identify trends and focus H&S efforts for improvement.
- The Occupational Health and Safety Coordinating Committee will review the City’s policy and guidelines annually. In doing so, the OHSCC may establish a working group/committee to evaluate the implementation and effectiveness of the policy and procedures.
- PEHR – Occupational Health and Safety will distribute each year an updated Workplace Violence Policy for posting in workplaces
- Management staff of divisions, with the assistance of their People, Equity Human Rights health & safety consultants and joint health and safety committees/health and safety representatives, will annually review the effectiveness of their policies, programs and procedures and make improvements as required. A compliance checklist that can be used by divisions in evaluating their policies, programs and procedures is attached as Appendix H.
Appendix A – Workplace Violence Risk Assessment Form
Appendix B – Workplace Violence Employee Survey
Appendix C – Workplace Violence Risk Factors and Controls Checklist
Appendix D – Workplace Violence and Threat Report
Appendix E – A Workplace Violence Incident Response Contact List
Appendix F – Training Information and Resources
Appendix G – Workplace Violence Safety Talk
Appendix H – Workplace Violence Legislation/Policy Compliance Checklist
Appendix I – Supervisor Checklist for Addressing Workplace Violence Incidents
Appendix J – Notification of Significant Workplace Violent Incidents
Appendices are available in msword and pdf
Occupational Health and Safety Co-ordinating Committee (OHSCC), April 23, 2002
September 16, 2014
December 6 2016
OHSCC Reviewed and re-aproved:
April 23, 2002
Reviewed and re-approval:
September 27, 2017
Ontario Occupational Health & Safety Act