WORKPLACE VIOLENCE PREVENTION PLAN

Craftsman Lath and Plaster, Inc. (“The Company”) has established this Workplace Violence Prevention Plan (WVPP) to address the hazards known to be associated with the four types of workplace violence as defined by Labor Code (LC) section 6401.9 and to provide for a safe environment for our employees and others associated with our worksites.

Date of Last Review: July 1, 2024 Date of Last Revision(s): July 1, 2024

POLICY

Craftsman Lath and Plaster, Inc. is committed to providing a safe work environment in which employees are free from acts of aggression, intimidation, bullying or violence. The Company will not tolerate conduct of this kind, and will take every step deemed necessary by senior management to prevent its occurrence, including disciplinary action up to and including termination, referral to law enforcement, or both. Any employee reporting an incident or credible threat of workplace violence will be taken seriously and will not be subject to retaliation.

STANDARD OF CONDUCT

All employees are expected to adhere to a professional standard of conduct at all times during the course of business. The Company reserves the right to take disciplinary action against any employee, up to and including termination, and/or referral to law enforcement where warranted, for even a first offense involving the following confirmed behavior during the course of business:

·           Bullying or physical intimidation

·           Verbal or physical threats of violence to others or self

·           Rough-housing or violent horseplay

·           Excessive or repeated arguing with customers, vendors, co-workers or management

·           Destruction of property, whether company, public or private third party

·           Possession of a firearm, knife, explosive, or other weapon on company premises, including in one’s vehicle

·           Fighting, assault and/or battery

DEFINITIONS

Emergency - Unanticipated circumstances that can be life threatening or pose a risk of significant injuries to employees or other persons.

Engineering controls - An aspect of the built space or a device that removes a hazard from the workplace or creates a barrier between the employee and the hazard.

Log - The violent incident log required by LC section 6401.9.

Plan - The workplace violence prevention plan required by LC section 6401.9.

Serious injury or illness - Any injury or illness occurring in a place of employment or in connection with any employment that requires inpatient hospitalization for other than medical observation or diagnostic testing, or in which an employee suffers an amputation, the loss of an eye, or any serious degree of permanent disfigurement, but does not include any injury or illness or death caused by an accident on a public street or highway, unless the accident occurred in a construction zone.

Threat of violence - Any verbal or written statement, including, but not limited to, texts, electronic messages, social media messages, or other online posts, or any behavioral or physical conduct, that conveys an intent, or that is reasonably perceived to convey an intent, to cause physical harm or to place someone in fear of physical harm, and that serves no legitimate purpose.

Workplace violence - Any act of violence or threat of violence that occurs in a place of employment. Workplace violence includes, but is not limited to, the following:

•               The threat or use of physical force against an employee that results in, or has a high likelihood of resulting in, injury, psychological trauma, or stress, regardless of whether the employee sustains an injury.

•               An incident involving a threat or use of a firearm or other dangerous weapon, including the use of common objects as weapons, regardless of whether the employee sustains an injury.

•               The following four workplace violence types:

Type 1 violence - Workplace violence committed by a person who has no legitimate business at the worksite, and includes violent acts by anyone who enters the workplace or approaches employees with the intent to commit a crime.

Type 2 violence - Workplace violence directed at employees by customers, clients, patients, students, inmates, or visitors.

Type 3 violence - Workplace violence against an employee by a present or former employee, supervisor, or manager.

Type 4 violence - Workplace violence committed in the workplace by a person who does not work there, but has or is known to have had a personal relationship with an employee.

Workplace violence does not include lawful acts of self-defense or defense of others.

Work practice controls - Procedures and rules which are used to effectively reduce workplace violence hazards.

RESPONSIBILITY

The WVPP Administrator, Kevin Tunstill, President, has the authority and responsibility for implementing the provisions of this program for the Company, and he can be contacted via telephone at 909-208-6225 and via email at Kevin@CraftsmanLP.com.

EMPLOYEE ACTIVE INVOLVEMENT

The Company ensures the following policies and procedures to obtain the active involvement of employees and authorized employee representatives in developing and implementing the plan. Management will work with and allow employees and authorized employee representatives to participate in:

·         Identifying, evaluating, and determining corrective measures to prevent workplace violence.

·         Designing and implementing training.

·         Reporting and investigating workplace violence incidents.

Employees are encouraged to participate in the above aspects of the development, implementation, and maintenance of the plan by participating in brainstorming sessions/discussions, suggesting a new training scenario based on a recent incident, and submitting a violence incident report following an incident.

EMPLOYEE COMPLIANCE

Management will ensure that all workplace security policies and procedures are clearly communicated and understood by all affected workers. Managers and supervisors will enforce the rules fairly and uniformly. All affected employees will follow all workplace security directives, policies, and procedures, and assist in maintaining a safe work environment. The Company will properly train employees in the provisions of the WVPP. The employee will recognize employees who have demonstrated safe work practices that promote the WVPP. The Company will discipline all employees who commit acts of violence or who fail to comply with the WVPP.

COMMUNICATION WITH EMPLOYEES

The Company recognizes that open, two-way communication between our management team, staff, and other employers, about workplace violence issues is essential to a safe and productive workplace. The following communication system is designed to facilitate a continuous flow of workplace violence prevention information between management and staff in a form that is readily understandable by all employees, and consists of one or more of the following:

·       New employee orientation includes workplace violence prevention policies and procedures.

·       Workplace violence prevention training programs.

·       Regularly scheduled meetings that address security issues and potential workplace violence hazards.

·       Effective communication between employees and supervisors about workplace violence prevention and violence concerns.

·       Posted or distributed workplace violence prevention information.

·       How employees can report a violent incident, threat, or other workplace violence concern to employer or law enforcement without fear of reprisal or adverse action. [For example, employees can anonymously report a violent incident, threat, of other violence concerns.]

·       Provided contact information for who to call for emergency response

·       Employees will not be prevented from accessing their mobile or other communication devices to seek emergency assistance, assess the safety of a situation, or communicate with a person to verify their safety.

·         Employees’ concerns will be investigated in a timely manner and they will be informed of the results of the investigation and any corrective actions to be taken.

·       Workers will not be threatened with adverse action or retaliated against in any way if they refuse to report to or leave a workplace or worksite because they have a reasonable belief that the workplace or worksite is unsafe.

COORDINATION WITH OTHER EMPLOYERS

The Company will implement the following effective procedures to coordinate implementation of its plan with other employers to ensure that those employers and employees understand their respective roles, as provided in the plan.

·       All employees will be trained on workplace violence prevention.

·       Workplace violence incidents involving any employee are reported, investigated, and recorded.

·       At a multiemployer worksite, the Company will ensure that if its employees experience a workplace violence incident the information will be recorded in a violent incident log and shall also provide a copy of that log to controlling employer [the general contractor or owner].

WORKPLACE VIOLENCE REPORTING PROCEDURE

The Company will implement the following effective procedures to ensure that:

·         All threats or acts of workplace violence are reported to an employee’s supervisor, manager, safety and health manager, security, human resources representative, or even leadership, who will inform the WVPP administrator. Employees may also report incidents directly to the WVPP Administrator, Kevin Tunstill (President), who can be contacted via telephone at 909-208-6225 and via email at Kevin@CraftsmanLP.com

·       If a serious act of violence is being committed, it would be appropriate to call emergency services (911) immediately, and then contact a company representative.

·       A strict non-retaliation policy is in place, and any instances of retaliation are dealt with swiftly and decisively. An employee who retaliates against a coworker for reporting an incident shall be subject to discipline or termination.

All reports of workplace violence incidents will ultimately be sent to our Human Resources Department to manage. HR will record the incident and determine appropriate next steps, such as contacting the authorities, interviewing those involved in the incident, contacting outside resources for assistance, determining corrective actions and disciplinary measures, etc. HR may also involve seek the assistance of the safety team in determining and implementing corrective actions. HR will also keep senior leadership apprised of the situation as needed.

Confidentiality will be maintained as much as possible.

Reports of workplace violence incidents will be taken seriously by the Company and fully investigated. Retaliation against anyone reporting a workplace violence incident is strictly prohibited. We do not condone or tolerate retaliation.

RESPONDING TO WORKPLACE VIOLENCE EMERGENCIES

The Company has in place the following specific measures to handle actual or potential workplace violence emergencies:

·       In the event of a workplace violence emergency, employees will be alerted via alarm system, intercom, or in person of the presence, location, and nature of the workplace emergency.

·         If necessary, employees will be directed to follow the Company’s evacuation and sheltering plans. Employees who need help in an emergency can contact the WVPP Administrator or their immediate supervisor. Employees can also call 911 or the local police department. Emergency numbers will be posted at each jobsite.

IDENTIFYING AND EVALUATING WORKPLACE VIOLENCE HAZARDS

The Company has in place the following policies and procedures to ensure that workplace violence hazards are identified and evaluated:

·       Inspections shall be conducted when the plan is first established, after each workplace violence incident, and whenever the employer is made aware of a new or previously unrecognized hazard.

·       All submitted/reported concerns of potential hazards shall be reviewed by the WVPP Administrator.

Periodic inspections and reviews to identify and evaluate workplace security and violence hazards will be performed by the WVPP Administrator. The following areas/departments shall be inspected: worksites, offices, parking lot, yard, warehouse.

The Company has accessed and incorporated, and will continue to access and incorporate, the following in its inspections for workplace violence hazards:

·       The exterior and interior of the workplace for its attractiveness to robbers.

·       The need for violence surveillance measures, such as mirrors and cameras.

·       Procedures for employee response during a robbery or other criminal act, including our policy prohibiting employees, who are not security guards, from confronting violent persons or persons committing a criminal act.

·       Procedures for reporting suspicious persons or activities.

·       Effective location and functioning of emergency buttons and alarms.

·       Posting of emergency telephone numbers for law enforcement, fire, and medical services.

·       Whether employees have access to a telephone with an outside line.

·       Whether employees have effective escape routes from the workplace.

·       Whether employees have a designated safe area where they can go to in an emergency.

·       Adequacy of workplace security systems, such as door locks, entry codes or badge readers, security windows, physical barriers, and restraint systems.

·       Frequency and severity of threatening or hostile situations that may lead to violent acts by persons who are service recipients of our establishment.

·         Employees’ skills in safely handling threatening or hostile service recipients (example: security guards).

·       Effectiveness of systems and procedures that warn others of actual or potential workplace violence danger or that summon assistance, e.g., alarms or panic buttons.

·       The use of work practices such as the "buddy" system for specified emergency events.

·       The availability of employee escape routes.

·       How well our establishment's management and employees communicate with each other.

·         Control over non-employees’ access to the workplace, including recently discharged employees or persons with whom one of our employees is having a dispute.

·         Frequency and severity of employees’ reports of threats of physical or verbal abuse by managers, supervisors, or other employees.

·        Any prior violent acts, threats of physical violence, verbal abuse, property damage or other signs of strain or pressure in the workplace.

CORRECTION OF WORKPLACE VIOLENCE HAZARDS

Workplace violence hazards will be evaluated and corrected in a timely manner. The following procedures are implemented to correct hazards that are identified:

·       If an imminent workplace violence hazard exists that cannot be immediately abated without endangering employee(s), all exposed Workers or employees will be removed from the situation except those necessary to correct the existing condition. Employees necessary to correct the hazardous condition will be provided with the necessary protection.

·       All corrective actions taken and dates they are completed will be documented on the appropriate form.

·       Corrective measures, such as the following, will be specific to a given work area:

o   Ensure adequate lighting at the workplace, parking lots, etc.

o   Utilize surveillance measures, such as cameras, where necessary.

o   Hire security guards and have them patrol the workplace interior and perimeter, where necessary.

o   Provide door locks, violence windows, physical barriers, and emergency alarms.

o   Post emergency telephone numbers for law enforcement, fire, and medical services.

o   Control non-employees’ access to and freedom of movement within the workplace.

o   Provide employee training/re-training(refreshers) on the WVPP.

o   Ensure adequate employee escape routes.

o   Provide procedures for a "buddy" system for specified emergency events.

POST-INCIDENT RESPONSE AND INVESTIGATION

Once the immediate threat of the incident has been addressed, an investigation will be conducted. The WVPP Administrator or another designated employee will:

·       Visit the scene of an incident as soon as safe and practicable.

·       Interview involved parties, such as employees, witnesses, law enforcement, and/or security personnel.

·       Review security footage of existing security cameras if applicable.

·       Complete the Violent Incident Log (see attached).

·       Examine the workplace for security risk factors associated with the incident, including any previous reports of inappropriate behavior by the perpetrator.

·       Determine the cause of the incident.

·       Take corrective action to prevent similar incidents from occurring.

·       Record the findings and ensuring corrective actions are taken.

·       Obtain any reports completed by law enforcement.

·         Ensure that no personal identifying information is recorded or documented in the written investigation report. This includes information which would reveal identification of any person involved in a violent incident, such as the person’s name, address, electronic mail address, telephone number, social security number, or other information that, alone or in combination with other publicly available information, reveals the person’s identity

We will also provide post-incident assistance to employees as needed through our Employee Assistance Program or Workers’ Compensation Program in effect at the time.

TRAINING AND INSTRUCTION

All affected workers, including managers and supervisors, will have training and instruction on general and job- specific safe workplace security practices. Training materials shall be appropriate in content and vocabulary to the educational level, literacy, and language of employees. Training and instruction will be provided as follows:

·         When the WVPP is first established and annually thereafter.

·         To all new workers.

·         To all workers given new job assignments for which training has not been provided.

·         Whenever new workplace security concerns are introduced to the workplace and represent a new hazard.

·         Whenever we are made aware of a new or previously unrecognized workplace security hazard.

·         To supervisors so that they can recognize the workplace security hazards to which workers under their immediate direction and control may be exposed.

·         To all affected workers whenever there are changes to the plan.

The Company will provide its employees with training and instruction on the definitions found on page 1 of this plan and the requirements listed below:

·           The employer’s WVPP, how to obtain a copy of the employer’s plan at no cost, and how to participate in development and implementation of the employer’s plan.

·         How to report workplace violence incidents or concerns to the employer or law enforcement without fear of reprisal.

·           Workplace violence hazards specific to the employees’ jobs, the corrective measures [name of employer] has implemented, how to seek assistance to prevent or respond to violence, and strategies to avoid physical harm.

·         The violent incident log and how to obtain copies of records pertaining to hazard identification, evaluation and correction, training records, and violent incident logs.

·         Opportunities for interactive questions and answers with a person knowledgeable about the WVPP.

·       Strategies to avoid/prevent workplace violence and physical harm, such as:

o   How to recognize workplace violence hazards including the risk factors associated with the four types of workplace violence.

o   Ways to defuse hostile or threatening situations.

o   How to recognize alerts, alarms, or other warnings about emergency conditions and how to use identified escape routes or locations for sheltering.

o   Employee routes of escape.

o   Emergency medical care provided in the event of any violent act upon an employee.

o   Post-event trauma counseling for employees desiring such assistance.

MEDIA POLICY

Certain workplace violence events may draw media attention. Please follow our company guidelines regarding dealing with the media. Never offer any information to the media and instead, politely and courteously refer them to the WVPP Administrator.

EMPLOYEE ACCESS TO THE WVPP

The Company will make our WVPP available and easily accessible to employees, authorized employee representatives, and representatives of the division (Cal/OSHA) at all times. Whenever an employee or designated representative requests a copy of the written WVPP, we will provide the requester with a printed copy of the WVPP, unless the employee or designated representative agrees to receive an electronic copy.

Where we have distinctly different and separate operations with distinctly separate and different WVPP’s, we may limit access to the WVPP applicable to the employee requesting it.

An employee must provide written authorization to make someone their “designated representative.” A recognized or certified collective bargaining agent will be treated automatically as a designated representative for the purpose of access to the company WVPP. The employee’s written authorization for their “designated representative” must include the following information:

·         The name and signature of the employee authorizing the designated representative.

·         The date of the request.

·         The name of the designated representative.

·         The date upon which the written authorization will expire (if less than 1 year).

VIOLENT INCIDENT LOG

The Violent Incident Log, attached hereto, is to record all violent workplace incidents.

RECORDKEEPING

Records will be kept per Senate Bill 533. All these required records will be made available to the Division (Cal/OSHA) upon request for examination and copying. All these required records will be made available to employees and their representatives, upon request and without cost, for examination and copying within 15 calendar days of a request.

REVIEW OF THE WVPP

We have established and implemented a system to review the effectiveness of our WVPP and make revisions as deemed necessary:

·         At least annually.

·         When a deficiency is observed or becomes apparent.

·         After a workplace violence incident.

·         As needed.

Review and revision of the WVPP will include the procedures listed in the EMPLOYEE ACTIVE INVOLVEMENT section of this WVPP, as well as the following procedures to obtain the active involvement of employees and authorized employee representatives in reviewing the plan’s effectiveness:

·         Review of the WVPP should include, but is not limited to:

o   Review of incident investigations and the violent incident log.

o   Assessment of the effectiveness of security systems, including alarms, emergency response, and security personnel availability (if applicable).

·       Review that violence risks are being properly identified, evaluated, and corrected. Any necessary revisions are made promptly and communicated to all employees. These revisions could involve changes to procedures, updates to contact information, and additions to training materials.

EMPLOYER REPORTING RESPONSIBILITIES

As required by California Code of Regulations (CCR), Title 8, Section 342(a). Reporting Work-Connected Fatalities and Serious Injuries, we will immediately report to Cal/OSHA any serious injury or illness (as defined by CCR, Title 8, Section 330(h)), or death (including any due to Workplace Violence) of an employee occurring in a place of employment or in connection with any employment.