The Recorder, “Beyond Traditional Workplace Safety: California’s Expanding Workplace Violence Prevention Rules,” by Melissa Meister, Esq., 7-15-2026

Kaufman Dolowich’s Los Angeles Partner Melissa Meister discusses in a recent Recorder article how California’s evolving workplace violence prevention regulations signal a broader shift toward continuous compliance and ongoing program administration for employers.

Beyond Traditional Workplace Safety: California’s Expanding Workplace Violence Prevention Rules

For employers, the practical lesson extends beyond workplace violence itself. Compliance is increasingly measured not by the existence of written policies alone, but by an organization’s ability to demonstrate thoughtful implementation, continuous evaluation and documentation, and meaningful program administration.

By Melissa A. Meister

July 15, 2026

When California’s workplace violence prevention law took effect in 2024, employers understandably focused on immediate compliance. For covered employers, that generally meant developing written workplace violence prevention plans, implementing reporting procedures, conducting employee training, and establishing recordkeeping systems to comply with Senate Bill 553, 2023 Cal. Stat. ch. 289 (codified principally at Cal. Lab. Code Section 6401.9).

Two years later, California appears to be moving well beyond that initial compliance exercise.

In April 2026, the California Division of Occupational Safety and Health (Cal/OSHA) released revised draft regulations implementing California Labor Code Section 6401.9. Although the regulations have not yet been finalized, they offer important insight into how regulators expect employers to administer workplace violence prevention programs over the long term.

Viewed individually, many of the revisions appear technical. Taken together, however, they reflect Cal/OSHA’s evolving approach to workplace violence prevention, treating it not as a standalone safety program, but as a continuous management system requiring regular evaluation, documentation, employee engagement, and operational oversight.

From One-Time to Continuous Compliance

The shift reflected in the proposed regulations emphasize ongoing administration, including identifying hazards, investigating incidents, evaluating corrective measures, maintaining documentation, reviewing programs periodically, and updating workplace violence prevention practices as workplace conditions evolve.

In other words, compliance is becoming continuous rather than episodic.

This approach is hardly unique to workplace violence prevention. California has increasingly adopted employment regulations that emphasize ongoing compliance through documentation, periodic review, recordkeeping, and active program administration rather than one-time policy adoption. For example, California’s Injury and Illness Prevention Program requirements, pay transparency laws, personnel records obligations, and workplace safety regulations all emphasize documentation, periodic review, ongoing administration, and demonstrable compliance rather than one-time implementation.

Viewed in that broader context, the workplace violence regulations fit within an emerging pattern of California employment regulation.

More Detail, Higher Expectations

The April 2026 draft regulations do not fundamentally alter the statutory framework established by SB 553. Instead, they provide substantially greater detail regarding how employers are expected to satisfy their existing obligations in practice and collectively demonstrate how Cal/OSHA expects workplace violence prevention programs to operate.

Several revisions illustrate this evolution.

The draft regulations provide additional clarification regarding the scope of remote work coverage. For example, they clarify that employees teleworking from a location of their own choosing not under the employer’s control are generally excluded from the regulation’s scope.

The draft regulations also expand the scope to expressly include employer-provided transportation. Although the proposal does not establish transportation-specific compliance requirements, it reflects Cal/OSHA’s recognition that workplace violence prevention obligations may apply in employer-controlled environments beyond a traditional fixed worksite.

Post-incident investigations receive particularly detailed treatment. Rather than simply documenting that an incident occurred, employers are expected to identify contributing factors, evaluate corrective actions, and use those findings to improve future prevention efforts.

These revisions reinforce an important point: investigations are not simply records of past events. They are intended to function as tools for continuous improvement.

Documentation as Evidence of Compliance

One of the most notable themes running throughout the revised draft regulations is documentation.

California employment law has increasingly emphasized documentation as both a compliance tool and an important means of demonstrating compliance. Wage-and-hour laws, pay transparency requirements, personnel records, and workplace safety regulations all require employers to create and maintain records that demonstrate compliance.

The workplace violence regulations continue that trend.

Incident logs, training records, hazard assessments, corrective actions, and periodic reviews should be viewed as more than administrative paperwork. Such documentation may become critical evidence during a Cal/OSHA inspection or in subsequent litigation concerning an employer’s response to workplace violence.

That reality should influence how employers approach compliance.

Documentation may also take on heightened importance outside the Cal/OSHA context. Plaintiffs’ attorneys increasingly scrutinize employer policies, investigations, training records, and internal communications during employment litigation. As workplace violence prevention programs mature, employers should recognize that records created to satisfy regulatory obligations may later become discoverable and relevant in civil discovery, retaliation claims, negligence actions, or other workplace disputes.

Well-maintained records may demonstrate thoughtful implementation of a workplace violence prevention program. Conversely, incomplete documentation—or documentation revealing inconsistent practices—may invite additional scrutiny from regulators and plaintiffs’ counsel alike.

Although the regulations focus on workplace safety, documents created for one regulatory purpose frequently become relevant in entirely different proceedings. Internal investigations, personnel disputes, retaliation claims, and civil discovery often draw upon the same records. Accordingly, workplace violence prevention should not remain solely within the responsibility of environmental health and safety personnel. Legal, human resources, security, operations, and compliance professionals should work collaboratively to ensure that documentation accurately reflects both regulatory compliance and sound employment practices.

Training Is Becoming an Ongoing Process

The revised regulations also reflect a more sophisticated approach to employee training.

Historically, employers often viewed mandatory training as a compliance obligation completed once employees attended a required session. The proposed regulations instead emphasize ongoing instruction tied to the employer’s workplace violence prevention plan and workplace-specific hazards. In addition to requiring initial and annual training, the draft regulations contemplate additional training when new workplace violence hazards are identified or when material changes are made to the employer’s prevention plan. They also clarify that training conducted remotely must provide employees with an opportunity to receive answers to interactive questions from a knowledgeable person within one business day.

That approach reflects a broader shift toward continuous education. As workplaces evolve, new technologies emerge, and organizational structures change, regulators increasingly expect training programs to evolve as well.

Employers that rely indefinitely on the same training materials developed in 2024 may find those programs increasingly difficult to defend if they no longer reflect current workplace risks or organizational practices.

What This Means for Counsel

The proposed regulations also have important implications for attorneys advising California employers.

Compliance discussions can no longer focus exclusively on whether a workplace violence prevention plan exists. Counsel increasingly may be asked to evaluate how effectively the program functions in practice.

Threat assessments may intersect with disability accommodation obligations under state and federal law. Incident investigations may overlap with harassment, discrimination, or retaliation complaints. Corrective actions may involve employee discipline or termination decisions. Communications surrounding workplace violence concerns may later become relevant in administrative investigations or civil litigation.

Accordingly, workplace violence prevention increasingly occupies the intersection of employment law, workplace safety, corporate governance, and enterprise risk management.

That integrated perspective may become increasingly important if Cal/OSHA continues expanding its expectations regarding ongoing program administration.

Looking Ahead

Although the Cal/OSHA revised regulations remain in draft form, they suggest that California regulators increasingly expect employers to demonstrate not merely that workplace violence programs are in place, but that they are being actively implemented, regularly evaluated, and adapted as workplace conditions evolve.

Because the regulations have not yet been finalized, employers should continue monitoring the rulemaking process before making significant changes to existing compliance programs. Nevertheless, the revisions provide valuable insight into Cal/OSHA’s likely enforcement priorities and regulatory direction.

For employers, the practical lesson extends beyond workplace violence itself. Compliance is increasingly measured not by the existence of written policies alone, but by an organization’s ability to demonstrate thoughtful implementation, continuous evaluation and documentation, and meaningful program administration.

California has often shaped broader employment law trends. If that pattern continues, the lessons employers learn from implementing SB 553 may extend well beyond workplace violence prevention and influence how organizations approach compliance across a broad range of employment obligations. Employers that view workplace violence prevention as an ongoing governance responsibility—rather than a completed compliance project—will likely be better positioned not only for future regulatory developments, but also for the increasingly integrated compliance expectations that are reshaping California employment law.

Melissa A. Meister is a partner in the Los Angeles office of Kaufman Dolowich. She focuses her practice on labor and employment law, professional liability, and commercial litigation. 

Reprinted with permission from the July 15, 2026 edition of “The Recorder” © 2026 ALM Global Properties, LLC. All rights reserved. Further duplication without permission is prohibited, contact 877-256-2472 or reprints@alm.com. “