Human Resources and other business leaders are keenly aware of their responsibility under the General Duty Clause of the Occupational Safety and Health Act to furnish to each of their employees a workplace that is free from recognized hazards that are causing or likely to cause death or serious physical harm. But the magnitude of the problem of workplace violence, coupled with the myriad options of how to address it, can make company leadership consensus difficult and can result in inaction.
I propose starting with a needs assessment and training.
When speaking on violence, I often say that it is rare to find a simple solution to a complex problem. The problem of violence, particularly as it affects the workplace, is an exceedingly complex, multifaceted one, and it will not be solved by trite partisan platitudes or knee-jerk responses.
A thoughtful approach to violence, which addresses its root causes and many aspects, is required.
Troubling behavior: our chance to act, or missed signals?
Although the school environment is in many ways distinct from the commercial setting due to special considerations surrounding the protection of children, I will focus on one element that is critical to prevention in both: the recognition and reporting of troubling behavior.
The American Society of Industrial Security (ASIS) and the Society for Human Resource Management (SHRM) Workplace Violence Prevention and Intervention American National Standard (“National Standard”) suggests that a workplace violence policy contain the following elements:
“a. Clearly define unacceptable behavior prohibited by the policy…
b. Regulate or prohibit weapons on-site and during work-related activities, to the extent permitted by applicable laws.
c. Require the prompt reporting of suspected violations of the policy and of any circumstances that raise a concern for safety from violence.
d. Provide multiple avenues for reporting – including human resources, security personnel, and members of the organization’s Threat Management Team.
e. Assure employees that reports made under the policy will be treated with the highest degree of discretion and will promptly be investigated by the employer.
f. Include a commitment to non-retaliation toward employees who make a good faith report under the policy.
g. Impose discipline for policy violations, as appropriate, up to and including termination.
h. …the policy should require or encourage employees to inform clearly-identified personnel of any protective or restraining order that they have obtained that lists the workplace as a protected area.”
The National Standard’s guidance to report unacceptable behavior implies an important fact: there are observable behaviors that can be used to prevent acts of violence.
The United States Secret Service’s 2019 Protecting America’s Schools Report, which studied the 41 incidents of targeted school violence between 2008 and 2017, stated that all of the “attackers exhibited concerning behaviors… [and] Most elicited concern from others, and most communicated the intent to attack.” Unfortunately, the report further states that “In many cases, someone observed a threatening communication or behavior but did not act…”
Similarly, the FBI’s seminal Study of Active Shooter Incidents between 2000 and 2013, recently updated to cover up to 2018, identifies a number of behavioral red flags, such as: Development of a real or perceived personal grievance; contextually inappropriate and recent: acquisitions of multiple weapons, escalation in target practice and weapons training, interest in explosives, or interest or fascination with previous shootings or mass attacks. The study goes on to say that “many active shooters experienced a significant real or perceived personal loss in the weeks and/or months leading up to the attack, such as a death, breakup, divorce or loss of a job.” Other causes for concern, according to the FBI, include erratic, unsafe, aggressive or hostile behaviors, based on claims of injustice; drug and alcohol abuse; changes in work performance, sudden and dramatic changes in home life or in personality, claims of marginalization or distancing from friends and colleagues; financial difficulties, pending civil or criminal litigation; and grievances and making statements of retribution. While the above warning signs apply specifically to active shooters, they can also be helpful to consider as indicators of other potential types of violence.
Training is a key element to establishing a culture of engagement.
Research points to the human element as a key component in preventing violent attacks. A major challenge to employee and citizen involvement in preventing attacks is our societal bias toward viewing one’s personal safety as the responsibility of one’s management or the police. Changing this cultural norm requires training in the importance of student/employee/citizen involvement in violence prevention and in what behaviors merit concern. Further, useful workplace violence prevention training must stress the importance of using the existing physical security measures and policies and not defeating them for convenience or to prevent embarrassment (such as propping doors open, or allowing unknown or unauthorized people entry).
The mention of a Threat Management Team (TMT) in the National Standard points to the understanding that a multi-disciplinary group of professionals can assess problem behavior and intervene appropriately. A threat Management Team is a specially selected and trained group, representing the human resources, security and legal functions, but may also, according to the National Standard, may include Occupational Safety and Health, Union, Employee Assistance, Crisis Management, Risk Management and Public/Corporate Relations personnel. The FBI’s Behavioral Threat Assessment Center points out in its Making Prevention a Reality: Identifying, Assessing, and Managing the Threat of Targeted Attacks that TMTs are useful tools because no single person or discipline “is positioned to see every single risk factor, warning behavior, or mitigator, nor is one single individual positioned to manage a threat.”
Training should empower, not traumatize.
And it is not just student concerns that drive this controversy. Teachers privately (and understandably) lament that they did not sign up to lead the preparation of the educational equivalent of a military hasty defensive position in the event of an active shooter. Many feel that Active Shooter training that is designed to be realistic goes too far. One teacher in Montana was compensated $100,000 after sustaining hearing damage during an Active Shooter drill: https://securityofbuffalo.com/2019/12/03/helena-pays-100000-active-shooter-drill-caused-ear-damage/
All violence prevention measures, including training, should be carefully tailored to the population they serve, should take affirmative steps to include those with special needs and should have safety as their first priority. Training should not sacrifice comprehension in the name of providing a realistic experience.
Many current and former law enforcement officers and military professionals are accustomed to the longstanding law enforcement/military training practices which expose students to repeated stress in simulated emergencies. While this methodology is successful at developing instinctive reactions to future harrowing situations, it requires repetition, often over long periods of time. This approach should be avoided, or used with extreme care by security consultants, because frequently, they deal with people who are unwilling or unable to learn under the stress of simulated attacks and often only have one relatively short opportunity to train. Further, this approach can lead to physical and emotional injury and can incur liability for the provider and the employer.
Businesses and other organizations seeking to prevent workplace violence should consider a needs assessment, according to the ASIS/SHRM National Standard,” designed to evaluate the presence of any specific risks” for violence. Further review of current prevention and intervention policies and practices is also recommended. This process of self-evaluation, coupled with customized training aimed at creating a culture of empowered employees who take ownership in their collective security, are two solid first steps toward creating a safer workplace.
Jonathan R. Lacey is principal of Security & Training Solutions, which provides security training and consulting services nationwide. He retired from the Federal Bureau of Investigation after over 21 years as a Special Agent. Mr. Lacey is also a former officer in the U.S. Army and a West Point graduate.