American industry has made great strides in addressing the problem of workplace violence (WPV). Beginning with pioneering work by the FBI and the United States Secret Service in the late 1980s and 1990s and continuing to this day, industry standards and best practices have been developed and refined. Protocols and procedures have been codified in OSHA regulations and other state laws and regulations. The American National Standards Institute (ANSI) in conjunction with ASIS have published an updated national standard for WPV prevention. The health care industry has also promulgated updated and stringent accreditation guidelines articulating specific WPV prevention steps health care organizations must take to obtain and maintain accreditation. WPV prevention plans and active shooter/active assailant response plans have become standard within American businesses.
But are we doing enough?
Are we executing and living the plans we are developing, or do we have a dusty three-ring binder sitting on a shelf that comes out once every other year for a cursory review?
Do You Have a Program or a Potemkin Village?
What is a Potemkin village?
During my final assignment with the FBI prior to retirement, I served as the Legal Attaché assigned to the U.S. Embassy in Moscow, Russia. In this role, I served as a liaison to Russian law enforcement and security services. While not a big fan of the current regime in Russia, during my assignment there, I developed a deep and abiding respect for the Russian people, their culture, and their history.
A Potemkin village is defined as any literal or figurative construct that seems impressive but in fact, lacks substance. The term comes from stories of a fake portable village consisting only of elaborate facades built by Grigory Potemkin, former lover of Russian Empress Catherine II. According to lore, Potemkin erected phony portable settlements along the Empress’s route of travel to impress her during a journey to Crimea in 1787. The structures would be disassembled after she passed and re-assembled farther along her route to be viewed again as if they were yet another village.
The Lasting Impact – Oxford, Michigan School Shooting November 30, 2021
Recently two members of the Oxford school board resigned in frustration over what they perceived to be a lack of transparency and follow-up after the 2021 school shooting. One of the outgoing school board members stated, “We had all the policies, we had the guidelines, but did we follow them? Did we execute? We found the Secret Service DHS protocols after the shooting but were these used in our district?”
Another of the resigned board members made the comparison to fire protection requirements in schools. He noted that all schools are required to adhere to National Fire Protection Association (NFPA) standards. School principals must develop and follow a plan for fire drills, fire safety education, and actual physical prevention measures such as smoke alarms and fire extinguishers. This board member pointed out that there has not been a fire-related death of a student in an American school since 1958 and credits this to strict adherence to the NFPA standards. This board member then asked the question, “Why can’t we have similar results regarding violence prevention and school shootings when we have clear evidence-based protocols to follow for threat assessment and management?”
While we agree with this comparison at some level, we must point out the significant difference between fire protection and threat assessment. This is the key difference in dealing with things rather than people. Fire protection standards are clearly articulated, and an organization either implements them, or they do not. Human behavior is dynamic and less black and white. This does not mean there is no merit to the comparison. Vigilance and adherence to protocol will help reduce the risk of violence.
Our firm recently worked with one organization with a comprehensive and well-written WPV prevention and threat assessment policy. This policy specified a detailed protocol for a Threat Management Team (TMT) that fully complies with the current ANSI National Standard. The problem was that nobody other than the authors of the plan were trained on the plan’s details or even knew of its existence. The policy identified specific individuals within the organization as being members of the TMT. When we contacted these individuals, they not only weren’t aware that the organization had a TMT but were completely unaware that they were supposed to be members of it.
The same organization clearly articulated a policy for reporting WPV concerns by directing employees to contact a security hotline. This organization also utilized an off-the-shelf risk management reporting platform available to all employees to report a wide range of risks. The reporting platform utilized a drop-down menu of all potential risks allowing the user to select a category for the problem they are reporting. Since this was a health care organization so many of the potential risks involved patient care and other medical issues along with traditional workplace risks such as defective equipment or concerns regarding facilities. During our review of this risk management reporting system, we found that “threats” was listed as one risk category. Upon further review, we identified 148 reported threats within an 18 month period through this platform. The problem was that nobody within the organization responsible for threat management was reviewing entries to this reporting platform, expecting such complaints to come through the security hotline. Employees who used the platform to report threats reported frustration that their complaint was never acted upon.
This organization had all the elements of a good WPV prevention program in place yet failed to execute and train staff resulting in a significant exposure to risk for this organization.
How do we train our staff on WPV prevention?
Violence prevention and active shooter training have become just one topic in an ever-expanding universe of mandatory training topics most workforces must cover. There is a cost to this training not only in the development and acquisition of curriculum but in the actual labor hours required to attend such training. A typical annual training load includes WPV prevention, workplace safety, diversity equity and inclusion, sexual harassment, and other industry-specific topics such as electrical safety, fire safety, bloodborne pathogen training, and a potential multitude of other topics. This is costly to an organization and can also lead to “training fatigue” among staff.
The training issue has already come up in the wake of the Walmart shooting in Chesapeake VA, in November 2022. As the first lawsuits are filed, questions have been raised about the effectiveness of the existing training. According to one recently filed lawsuit, the shooter “repeatedly asked coworkers if they had received their active shooter training. When coworkers responded that they had,” the lawsuit said, the shooter “just smiled and walked away without saying anything.” This comment was not reported to management at the time.
When surveyed regarding their WPV/active shooter training, multiple Walmart employees described the training as “mediocre and inadequate.” One employee stated, “The issues with the training are abundant, we watch the same video all the time. It has become a meme.”
Organizations should supplement mandated training with actual discussions led by a manager during employee meetings. It is not enough to watch a video about active shooter response. A trained manager should discuss active shooter response with their employees, walking them through how to respond, and locating exits while actually walking through the protocol articulated in the policy. This will reinforce management’s commitment to workplace safety while reinforcing the video-based curriculum.
Typically, most training of this type is delivered in e-learning format, most e-learning curriculum has a life span of between three to five years before requiring an update.
Can we make our training more impactful by considering this shelf life when developing the curriculum?
Should our workplace violence prevention training be developed with several presentations of the same content that can be delivered on alternating training cycles to keep the material fresh?
Build a culture of collaboration
Our firm has helped organizations from many business sectors develop and implement WPV prevention plans to include the selection and training of TMTs. Many organizations view WPV prevention as a linear process, that is the first line supervisor “handles” the problem until they can no longer do so then the matter is referred to the TMT. In many cases, this is too late. A TMT should be viewed as yet another resource in a supervisor’s management toolbox.
In our discussions with first line managers, many report reluctance to reach to their organization’s TMT for help fearing this will be perceived as their inability to handle a problem with their employees. Organizations must realize that a successful threat management program involves collaboration at all levels. To use a common cliché from the world of mental health therapy, asking for help is not a sign of weakness; it is a sign of strength. Organizations should foster a collaborative and consultative relationship between supervisors, Human Resources, and their TMT.
Another point of concern frequently noted in our review of WPV prevention programs is the tendency of organizations to conflate progressive disciplinary actions with threat management interventions. These are two distinctly different actions that are not mutually exclusive. Simply put progressive discipline focuses on what the employee did whereas a threat assessment focuses on what an employee might do. Management, in concert with Human Resources can and should appropriately initiate progressive disciplinary measures regarding workplace threats. Concurrently the organization’s TMT should conduct an assessment, develop a plan, and apply interventions designed to prevent the employee in question from continuing along the Pathway to Violence. These two complementary efforts, progressive discipline and threat management, must be implemented in close coordination.
Do we train our supervisors and managers to implement a workplace violence plan in their worksites?
How do we create a culture of collaboration between first-line supervisors and managers, Human Resources, Security, and our Threat Management Teams?
It is one thing to have written policy or plan to address workplace violence, but have we trained and empowered first line supervisors and managers to implement these plans?