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Part I: Section 2
Development of Written Policy Statement

• Advantages of Written Policies
• Policy Statement Contents
• Recommended Approaches

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Advantages of Written Policies

Once a workplace violence program is ready to be implemented, agencies must decide whether to issue a written policy statement. Among the advantages of issuing a statement are:

• It informs employees that the violence policy covers intimidation, harassment, and other inappropriate behavior that threatens or frightens them;
• It encourages employees to report incidents;
• It informs employees whom to call; and
• It demonstrates senior management's commitment to dealing with reported incidents.

Agency programs can also be implemented without a written policy statement. In these agencies, employees are often given information about the program (especially whom to call) in training sessions, on posters, in newsletter articles, or by other similar methods. Note: Agencies have an inherent right to take action against employees who engage in disruptive or threatening behavior whether or not they have issued a written policy statement.

Policy Statement Contents

A workplace violence policy statement should convey that:

• All employees are responsible for maintaining a safe work environment;
• The policy covers not only acts of physical violence, but harassment, intimidation, and other disruptive behavior;
• The policy covers incidents involving coworkers and incidents involving individuals from outside the agency perpetrating violence against agency employees;
• The agency will respond appropriately to all reported incidents;
• The agency will act to stop inappropriate behavior; and
• Supervisors and all of the offices involved in responding to incidents will be supported by agency management in their efforts to deal with violent and potentially violent situations.

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Recommended Approaches

Consider the following recommendations in developing your written policy statement:

Keep it brief

A written policy statement should be brief and simple. Implementation details can be provided in training and in more detailed backup documents. For example, roles and responsibilities of the various offices involved in responding to potentially dangerous situations can be outlined in memoranda of understanding or in operating manuals/instructions rather than in the written policy statement that is issued to all agency employees. This approach gives agency staff the flexibility they will need to deal creatively with these fluid, unpredictable situations.

Consider the disadvantages of using definitions

There are disadvantages to using definitions of terms such as violence, threats, and harassment in your written policy statement. Definitions can discourage employees from reporting incidents that they do not believe fall within the definition. The reporting system should not deter employees from reporting situations that frighten them. An employee knows a threat or intimidation or other disruptive behavior when he or she experiences it -- definitions are not necessary. If you want to clarify the scope of your organization's concept of one or more of the terms in the policy, you could use examples. For example, you may want to give examples of verbal and non-verbal intimidating behavior.

Another consideration is that definitions are often restrictive and may create legal problems in the future when you are taking disciplinary actions against the perpetrators of workplace violence. Use of definitions can make it more difficult to defend a case on appeal.

Be cautious with "Zero Tolerance"

Consider that there could be negative consequences from using the term "zero tolerance." It could create legal problems in the future when you are taking disciplinary actions against the perpetrators of workplace violence. Use of the term could make it more difficult to defend a case on appeal because a third party could conclude, however mistakenly and inappropriately, that the agency has not considered a penalty appropriate for the particular offense.

There are other possible consequences. The term "zero tolerance" might appear to eliminate any flexibility an agency has in dealing with difficult situations even if this is not intended. Another undesirable side effect is that the appearance of inflexibility can discourage employees from reporting incidents because they do not want to get their coworker fired -- they just want the behavior stopped. This appearance of inflexibility also may discourage early intervention in potentially violent situations.

The sample policy on the next page contains language that is similar to "zero tolerance" but takes care of the previously mentioned concerns. It says the agency will not tolerate violent or disruptive behavior and then clarifies what that means by saying "that is, all reports of incidents will be taken seriously and dealt with appropriately."

Consult with Legal Counsel

Consult your Office of General Counsel for the legal implications of your draft policy. Agencies that wish to issue a written policy statement can use the following sample, changing the format and tone as appropriate, and adapting it for their own situations.

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Sample Written Policy Statement MEMORANDUM FOR EMPLOYEES OF THE DEPARTMENT OF _________ FROM:    DEPARTMENT OR AGENCY HEAD SUBJECT:    Workplace Violence It is the [insert Department or Agency name]'s policy to promote a safe environment for its employees. 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. While this kind of conduct is not pervasive at our agency, no agency is immune. Every agency will be affected by disruptive behavior at one time or another. Violence, threats, harassment, intimidation, and other disruptive behavior in our workplace will not be tolerated; that is, all reports of incidents will be taken seriously and will be dealt with appropriately. Such behavior can include oral or written statements, gestures, or expressions that communicate a direct or indirect threat of physical harm. Individuals who commit such acts may be removed from the premises and may be subject to disciplinary action, criminal penalties, or both. We need your cooperation to implement this policy effectively and maintain a safe working environment. Do not ignore violent, threatening, harassing, intimidating, or other disruptive behavior. If you observe or experience such behavior by anyone on agency premises, whether he or she is an agency employee or not, report it immediately to a supervisor or manager. Supervisors and managers who receive such reports should seek advice from the Employee Relations Office at xxx-xxxx regarding investigating the incident and initiating appropriate action. [PLEASE NOTE: Threats or assaults that require immediate attention by security or police should be reported first to security at xxx-xxxx or to police at 911.] I will support all efforts made by supervisors and agency specialists in dealing with violent, threatening, harassing, intimidating or other disruptive behavior in our workplace and will monitor whether this policy is being implemented effectively. If you have any questions about this policy statement, please contact ______________ at xxx-xxxx.