Tab I Chapter 1
RETAIL BUSINESSES
By Jon F. Elliott J.D.
ABSTRACT:
Workplace violence prevention efforts are particularly
complex at locations that serve non-employees who come
to the siteand the most open are retail establishments
that invite the general public onto the premises and into the
workplace in order to sell them goods and services, and
taxi and livery drivers who do the same within their
vehicles. In these settings, employers need to supplement
efforts to manage and contain employees with additional
measures directed at non-employee customers, potential
customers, and visitors.
The U.S. Occupational Safety and Health Administration
(OSHA) has developed detailed guidelines for workplace
violence prevention at late-night retail establishments.
Four North American jurisdictionsFlorida, New Mexico,
Saskatchewan, and Washingtonrequire safety measures
at late-night retail establishments. Effective June 1, 2004,
New Mexico has become the first jurisdiction to require all
“convenience store” employers to provide worker training
in violence prevention, as well as requiring exterior
lighting to deter crime.
OSHA also has established less-detailed guidelines for taxi
and livery drivers (the riskiest retail service occupations),
and some cities have incorporated driver safety
requirements into local ordinances.
This chapter summarizes these provisions, and
supplements provide copies of relevant documents. Many
of the measures suggested for these highest-risk
establishments are useful at other retail establishments as
well.
WVP 9/04 STP
I-1 1
Tab I Chapter 1
Retail workers consistently suffer much greater harm from workplace violence than most
workers. They have been a focus for attention to workplace violence issues at least since
the publication of workplace “risk factors” by the U.S. National Institute for
Occupational Safety and Health (NIOSH) in 1996.1 Many retail establishments exhibit
some or all of the following risk factors:
 contact with the public,
 exchange of money,
 delivery of passengers, goods, or services,
 mobile workplace such as a taxicab,
 working alone or in small numbers,
 working late at night or during early morning hours,
 working in high-crime areas, and
 guarding valuable property or possessions.
Workplace injury and death statistics bear out these concerns. Worker safety agencies in the
United States and Canada (as well as employer and employee groups) have therefore focused
considerable attention on workplace violence prevention efforts covering this sector. As of this
writing, New Mexico has adopted measures applicable to all “convenience stores” (see Section A.2
below).2 Retail trade associations also promote measures to protect their members’ employees.
For example, the Retail Council of Canada and its provincial affiliates have produced a variety of
guidance for store owners, managers, and employees.3
Elsewhere, various jurisdictions have focused particular attention on two sub-groups within retail
services that are especially vulnerable to violence from customers:
 late-night retail establishments; and
 taxi and livery drivers (see Section C below).
1
2
3
NIOSH, “Violence in the Workplace: Risk Factors and Prevention Strategies,” Current Intelligence Bulletin No. 57 (1996). This
NIOSH report is discussed in Tab K Chapter 1 of this Guide. Worker safety agencies and others throughout North America continue
to refer to and even rely on this early NIOSH work.
Other agencies with related authority may also be active. For example, the Virginia State Police operate a “Convenience Store
Watch” program under which troopers visit rural convenience stores and provide advice on crime prevention. This program is
identified on the agency’s Internet site at www.vsp.state.va.us/crime_prevention.htm.
See, e.g., Retail Council of Canada, Health & Safety Guide for New Retail Workers (contains sections on “Preventing Violence” and
“Shoplifting and Robbery;” and “Robbery Prevention and Survival Techniques.” These documents are available on the Council’s
Internet site at www.retailcouncil.org.
I-1 2
WVP 9/04 STP
Retail Businesses
A. General: Workplace Violence Prevention at Retail Establishments
Although the specialized materials presented in this chapter highlight ways to protect retail
employees from customers and walk-in outsiders, retail establishments should also consider the
employee-management efforts described throughout this Guide (see Section A.1, below). It is
important for managers in this sector to prepare policies and programs that address workplace
violence possibilities, and to ready preventative and response procedures. The first generally
applicable set of workplace violence regulations for “convenience stores” took effect June 1, 2004,
in New Mexico (see Section A.2).
1. General Approaches
As one step to preventing violence at retail establishments, readers should review the general
methodologies set forth in this Guide. The chapters in this Guide that describe the development,
establishment, and administration of Workplace Violence Prevention Programs will help identify
and evaluate elements appropriate to retail establishments.1 If any of your employees work alone or
in isolation from co-workers (at a fixed establishment, or as a traveling sales representative), you
should also review Tab F Chapter 5.2
Second, review the specialized measures described in the remainder of this chapter. Although
not all will apply to fixed-location, day and early-evening retail establishments, many will.
2. New Mexico Regulatory Requirements
Effective June 1, 2004, worker protection regulations administered by the New Mexico
Environmental Improvement Board apply unique violence prevention requirements to all
“convenience stores.”3 The regulation defines this term as follows:4
‘Convenience store’ means any business that is primarily engaged in the retail sale of
convenience goods, or both convenience goods and gasoline, and employs one or more
employees during the normal operating hours of the establishment. This term does not include:
gasoline service stations, grocery stores, or supermarkets. This term includes all businesses with
separate structures on their premises that are engaged in the retail sale of convenience goods or
both convenience goods and gasoline separate from their primary business.
1
2
3
4
Readers should also note that a wide variety of retail establishments in Minnesota are required to prepare and implement workplace
accident and injury reduction programs, under the provisions of that state’s A Workplace Accident and Injury Reduction (AWAIR)
Act. Minn. Stat. § 182.653. See Tab K Chapter 1, Section A.3.c of this Guide for a summary of these requirements, and of Minnesota
OSHA (MNOSHA) guidance stating that workplace circumstances may require individual employers to include violence prevention
measures within their plans.
Employers with traveling representatives may also wish to consider measures such as those recommended for home care health
personnel, which are presented in I-2 Supplement 6 of this Guide.
11 New Mexico Administrative Code (NMAC) §§ 5.6.1 – 5.6.27. In New Mexico, occupational safety and health requirements are
administered by the New Mexico Environment Department’s Occupational Health and Safety Bureau (known as “New Mexico
OSHA”), which can be reached via the Internet at www.nmenv.state.nm.us/OHSB_Website/ohsb_home.htm.
11 NMAC § 5.6.7.D.
WVP 9/04 STP
I-1 3
Tab I Chapter 1
Effective August 29, 2004, these regulations require all convenience stores to implement the
following security measures:1
 Exterior Lighting“...during all evening and nighttime operating hours that ensures clear
visibility of the parking areas, walkways, building entrances and exits, and gasoline pump areas.”
 Employee Crime Prevention and Safety Trainingupon hiring and at least every three months
thereafter, in a language that is understood by the employee.
The employer shall conduct training, or designate a knowledgeable representative to conduct
training, in accordance with the written training curriculum that includes but is not limited
to:
(a) an overview of the potential risk of assault;
(b) operational procedures, such as cash handling rules, that are designed to reduce risk;
(c) proper use of security measures and engineering controls that have been adopted in the
workplace;
(d) behavioral strategies to defuse tense situations and reduce the likelihood of violence,
such as techniques of conflict resolution and aggression management;
(e) specific instructions on how to respond to a robbery and how to respond to attempted
shoplifting; and
(f) emergency action procedures to be followed in the event of a robbery or violent incident.
Store-specific training shall be conducted by the employee’s immediate supervisor.
Current employees shall receive training within ninety days of the effective date of this
regulation.
All employers shall prepare [and maintain] training documentation for each employee and
have employees sign a statement indicating the date, time, and place they received their
safety training.
 Limits on Store Window Signageto maintain unobstructed views of the service counter and
cash register from outside the building.
 Security Surveillance Systememployer shall provide and maintain a continuous, fully
operational security surveillance system that records “a continuous unobstructed view of the
service counter area, all entryways and exits, parking areas, walkways, building entrances and
exits, and gasoline pump areas during all operating hours.”
 Security Alarm Systememployer shall provide and maintain a “fully operational security
alarm system with a working personal panic alarm for each employee” that signals to law
enforcement. This must be in a fixed location and be available as a portable device an employee
can carry.
 Depository or Time Lock Safe
 Cash Managementno more than $50 in the cash register at any time.
1
11 NMAC § 5.6.8
I-1 4
WVP 9/04 STP
Retail Businesses
 Required signsannouncing the presence of the following features:
there is a safe in the store;
employees do not have access to the safe;
there is an active security alarm system;
there is an active surveillance system; and
there is no more than $50 in the cash register.
 Pay phonesif any are present outside the store they must be located on the outside perimeter of
the property, well lit and in clear view of the service counter.
 Unobstructed view of the sales area throughout the store from the service counter.
In addition, any convenience store that operates between 5 p.m. and 5 a.m. must meet additional
“late night security measures” described in Section B.2.a, below. The full text of the New Mexico
regulations appears in I-1 Supplement 5.
WVP 9/04 STP
I-1 5
Tab I Chapter 1
B. Additional Measures for Late-Night Retail Establishments
Because late-night retail establishments are among the most dangerous for employees, they have
received special attention from occupational safety and health agencies. The following discussion
presents non-mandatory recommendations from OSHA (Section B.1), worker safety mandates from
New Mexico, Saskatchewan, and Washington (Section B.2), as well as a provision of Florida’s
criminal code (Section B.3).
The scope and applicability of these recommendations and regulations vary. For example, each
regulatory program excludes different subsets of retail establishments, and “late night” is not
defined consistently.
1. OSHA Recommendations
In 1998, OSHA issued Recommendations for Workplace Violence Prevention Programs in LateNight Retail Establishments (Late-Night Retail Recommendations).1 These Recommendations
appear as I-1 Supplement 1.2 The Late-Night Retail Recommendations suggest that these
programs should demonstrate at least the following five elements:
1
2
3

management commitment and employee involvementincluding preparation of a formal
written program;

worksite analysis—to identify hazards.3 This section discusses the applicability of the
NIOSH factors discussed above, and pays particular additional attention to the risks of
robberies;

hazard prevention and controlsincluding the following:
prevention strategiesintended to deter violent perpetrators through some combination of
the following:
increase the effort,
increase the risks, and
reduce the rewards;
engineering controls and “Workplace Adaptation”to promote physical security of the
workplace. OSHA lists the following as possible enhancements:
improve visibility,
maintain adequate lighting,
use fences,
use drop safes,
OSHA, Recommendations for Workplace Violence Prevention Programs in Late-Night Retail Establishments, OSHA Publication
3153 (1998). The Late-Night Retail Recommendations present an approach to workplace violence that uses the analytical and
program frameworks from OSHA’s generic Safety and Health Program Guidelines (S&H Guidelines), which are discussed in Tab K
Chapter 1, Section A.2, and reproduced in K-1 Supplement 2.
The Supplement omits appendices presenting OSHA offices and additional resources, current as of 1998. Readers will find the latest
OSHA office information in K-1 Supplement 1, and references throughout this Guide; the entire OSHA Recommendations are
available on OSHA’s Internet site at www.osha.gov.
See Tab A Chapter 3 of this Guide for a general discussion. Worksite analysis could be tied to self-audits described in Tab K Chapter
1, Section A.2.a. OSHA, Final Policy Concerning the Occupational Safety and Health Administration’s Treatment of Voluntary
Employer Safety and Health Self-Audits. 65 Federal Register 46498 (July 28, 2000).
I-1 6
WVP 9/04 STP
Retail Businesses
install video surveillance equipment and closed circuit television,
put height markers on exit doors (to help witnesses describe perpetrators),
use door detectors,
control accesswith door buzzers,
use silent and personal alarms, and
install physical barriers;
administrative and work practice controlsto ensure that employees work as safely as
possible, including structuring their interactions with clients. OSHA lists the following
as possible enhancements:
integrate violence prevention activities into daily routines,
keep minimal cash on hand and accessible,
adopt appropriate emergency procedures,
establish communications systems,
limit or restrict areas of customer access, and adopt procedures for the proper use of
physical barriers,
increase staffing,
lock rear/side doors when not in use, and establish safe procedures for using these
doors (e.g., to take our garbage),
keep doors locked before and after business hours, and
adopt safety policies and procedures for offsite work (e.g., deliveries);
post-incident response and evaluationto determine how an incident occurred and
whether further workplace changes can prevent future incidents;

safety and health trainingincluding trainings targeted to all employees, and additional or
different training for supervisors and managers, and/or for security personnel;1

program evaluationincluding recordkeeping to provide data for ongoing evaluation, as
well as compliance with OSHA’s general Injury and Illness (I&I) Recordkeeping Standard.2
The Late-Night Retail Recommendations also present the following useful appendices, with
model documents for employers to consider and adapt to their specific circumstances:
1
2

Sample Workplace Violence Factors and Controls Checklistto help address workplace
violence issues and systems in the workplace; and

Incident Report and Suspect Description Form.
See Tab C Chapter 2 of this Guide for a discussion of workplace violence training.
29 C.F.R. part 1904. The I&I Standard requires employers to record work-related I&I events (including those caused by workplace
violence) in a log available for review and inspection, and to report within eight hours any event that results in any fatalities or three or
more hospitalizations.
WVP 9/04 STP
I-1 7
Tab I Chapter 1
2. Worker protection mandates
Although there are no national requirements in either the U.S. or Canada for special measures at
late-night retail establishments, New Mexico, Saskatchewan, and Washington do enforce such
requirements.
a. New Mexico regulatory requirements
Section A.2 above described requirements applicable to all convenience stores in New
Mexico effective June 1, 2004. In addition to those requirements, New Mexico requires that
at least one of the following additional security measures be implemented in all convenience
stores operating between 5 p.m. and 5 a.m.:
 two-employee shiftthis shift must include at least two employees, or one employee
plus onsite security personnel;
 controlled access areabehind bullet-proof glass or other similar material;
 pass-through windowfor transactions, with bullet-proof glass or other similar
material; or
 alternative operationsthe store may be closed for business, but employees allowed
access for restocking or other duties, if signs are posted on all entryways saying the store
is closed.
The full text of the New Mexico regulations appears in I-1 Supplement 5.
b. Saskatchewan regulatory requirements
Saskatchewan’s Occupational Health and Safety (OHS) Act requires employers to take action
to protect their employees against workplace violence. The basic statutory requirement is the
following:
14(1). An employer at a prescribed place of employment where violent situations
have occurred or may reasonably be expected to occur shall develop and
implement a policy statement to deal with potentially violent situations….1
This policy must be developed in consultation with the occupational health committee,
occupational health and safety representative, or the workers.
Regulations issued by the Saskatchewan Department of Labour, Occupational Health and
Safety Program, “prescribe” several specific types of workplaces, including “retail sales
establishments open between 11:00 p.m. and 6:00 a.m.”2
1
2
Sask, OHS Act § 14(1); Sask. O-1.1 Reg. 1, § 37 (effective December 4, 1996). (Note that, because Canadian provinces generally
retain copyright to their governmental publications [including laws, regulations, and agency guidance documents], provincial
documents are not included in this Guide.) These requirements are also discussed in Tab K, Chapter 1.B.2.c of this Guide. The OHS
Act, and regulations and guidance documents issued by the Saskatchewan Department of Labour, Occupational Health and Safety
Program, are available for review on the Department’s Internet site, at www.labour.gov.sk.ca.
Sask. O-1.1 Reg. 1, § 37(2)(i), effective January 1, 1997. Other prescribed activities cover the same ones noted throughout this Guide
as being at particularly high risk for workplace violence.
I-1 8
WVP 9/04 STP
Retail Businesses
These regulations also require that the employer’s policy statement be in writing, and include
the following:1
 employer’s commitment to minimize or eliminate the risk of workplace violence;
 identification of worksites where violent situations have occurred or “may reasonably be
expected to occur”;
 identification of staff positions “that have been, or may reasonably be expected to be,
exposed to violent situations”;
 procedures the employer will follow to inform workers of the nature and extent of the
risk of violence, including any non-prohibited disclosures about individuals with a
history of violent behavior likely to be encountered;
 actions the employer will take to eliminate or minimize the risk, including personal
protective equipment, administrative arrangements, or engineering controls;
 incident reporting procedures for workers, and follow-up investigation and
documentation to be undertaken by the employer;
 recommendation that employees exposed to workplace violence consult with a health
professional for treatment or referral;
 employer’s commitment to provide training, which is to include at least the following:
how to recognize workplace violence,
procedures, administrative arrangements, and engineering controls to minimize or
eliminate workplace violence risks,
appropriate responses to violence, including seeking assistance, and
procedures for reporting, investigating and documenting workplace violence incidents.
If a worker is exposed to workplace violence and seeks treatment or counseling, the employer
is to ensure that the worker is fully paid for such time.2 The employer is to make the policy
available for reference by workers, and review it at least every three years.3
1
2
3
Sask. O-1.1 Reg. 1, § 37(3). The Program also publishes several guidance documents, including A Guide to Developing a Violence
Policy Statement, and A Sample Policy on Workplace Violence, both of which appear on the Department’s Internet site.
Sask. O-1.1 Reg. 1, § 37(4).
Sask. O-1.1 Reg. 1, § 37(5)-(6).
WVP 9/04 STP
I-1 9
Tab I Chapter 1
c. Washington regulatory requirements
The Washington Industrial Safety and Health Act Services Division (known as WISHA)
requires employers at “late-night retail establishments” to adopt certain safety measures and
provide employees with training designed to address the risks of workplace violence in these
locations.1 I-1 Supplement 2 reproduces this regulation. This requires all retail businesses
that operate between 11 p.m. and 6 a.m. to take several inter-related steps.
First, the employer must include crime prevention training in the Accident Prevention
Program (APP)2 required of all Washington employers. Each APP must provide a “safety
orientation” to employees, a safety and health committee, and a safety and health training
program. This training is to ensure that employees understand “the purpose and function of
robbery and violence prevention,” and have skills necessary to protect themselves. The
training must include at least the following elements:
 explanation of the importance of keeping the store clean, neat, and uncluttered, in order
to make it as unattractive as possible to robbers;
 explanation of the purpose of maintaining an unobstructed view of the cash register from
outside the store (assuming the cash register is visible from the street);
 instruction on reasons for operating only minimum number of cash registers at night;
 instruction to keep cash register funds to a minimum;
 extra precautions after dark, i.e., keep alert, observe lighting and dark corners, spot
possible hiding places; and
 violence prevention procedures in case of robbery.
The employer must provide an initial training to new employees, and annual refresher
training on or near each employee’s anniversary date. Each employee must sign off on the
date, time, and place of training at the completion of the training. The employer must place
the training documentation in each employee’s personnel file. The employer must also make
videotape and crime prevention material available for employee’s review at their request.
WISHA’s regulation also requires employers to take several specific workplace violence
risk reduction measures, including at least the following:
 post a conspicuous sign stating that there is a safe on the premises, not accessible to
employees, and that the cash register contains only minimal cash needed to conduct
business;
 if possible, ensure that the cash register is visible from the street;
 provide a drop-safe, limited access safe, or comparable device onsite; and
 provide and operate outside lights covering premises parking and approach throughout
night hours the establishment is open.
1
2
Washington Administrative Code (WAC) chapter 296-832, §§ 296-832-100, 296-832-10005 – 296-832-10025. Information can be
found on WISHA’s Internet site at www.lni.wa.gov/Safety/Topics/AtoZ/WPV.
APPs are described in Tab K Chapter 1, Section B.2.
I-1 10
WVP 9/04 STP
Retail Businesses
3. Florida Convenience Business Security Act
In 1992, Florida adopted the Convenience Business Security Act, which establishes minimum
security standards for late-night retail establishments throughout the state.1 A copy of the statute
is provided as I-1 Supplement 4. Because of its policy focus on violent crime, this act is
assigned to the state’s Attorney General to implement as part of Florida’s criminal code, not to a
routine worker protection program.2
This requirement applies to “convenience businesses,” which are small businesses primarily
involved in the retail sale of groceries and/or gasoline, and open at any time between the hours
of 11 p.m. and 5 a.m. However, the following definition3 contains significant exclusions, which
narrow its applicability:
As used in this act, the term “convenience business” means any place of business
that is primarily engaged in the retail sale of groceries, or both groceries and
gasoline, and that is open for business at any time between the hours of 11 p.m. and
5 a.m. The term “convenience business” does not include:
(1) A business that is solely or primarily a restaurant.
(2) A business that always has at least five employees on the premises after 11 p.m.
and before 5 a.m.
(3) A business that has at least 10,000 square feet of retail floor space.
The term “convenience business” does not include any business in which the owner
or members of his or her family work between the hours of 11 p.m. and 5 a.m.
Every convenience business must provide the following security measures:4
1
2
3
4

a security camera system capable of recording and retrieving an image;

a drop safe or cash management device for restricted access to cash receipts;

a lighted parking lot illuminated at an intensity of at least 2 foot-candles per square foot at
18 inches above the surface;

a conspicuous notice at the entrance which states that the cash register contains $50 or less;

window signage that allows a clear and unobstructed view from outside the building and in
a normal line of sight of the cash register and sales transaction area. A convenience
business must not have window tinting that reduces exterior or interior view in a normal
line of sight;
Florida Statutes Annotated (FSA) §§ 812.1701 – 812.175.
Information can be found on the Florida Attorney General’s Internet site at www.myfloridalegal.com.
FSA § 812.171.
FSA § 812.173(1)-(3).
WVP 9/04 STP
I-1 11
Tab I Chapter 1

height markers at the entrance of the convenience business;

a cash management policy to limit the cash on hand at all times after 11 p.m.; and

a silent alarm to law enforcement or a private security agency (unless the business applies
for and receives an exemption from this requirement from the Attorney General).
In addition, if the business suffers any specified business-related violent crime, it thereafter must
either cease operations between 11 p.m. and 5 a.m., or provide at least one of the following
additional security measures1 during the 11 p.m. to 5 a.m. time period:

provide at least two employees at all times;

install for use by employees a secured safety enclosure of transparent polycarbonate or other
material that meets specified minimum standards;

provide a security guard on the premises at all times; or

lock the business premises throughout these hours, and only transact business through an
indirect pass-through trough, trapdoor, or window.
If the business does not suffer another violent business-related crime for at least 24 months after
instituting these additional measure(s), it may file a notice of exemption from continuation of
these measures, to the Attorney General.
In addition, employers at convenience businesses subject to this act must provide their
employees with training in “proper robbery deterrence and safety,” following a state-approved
curriculum.2
1
2
FSA § 812.173(4).
FSA § 812.174.
I-1 12
WVP 9/04 STP
Retail Businesses
C. Taxi and Livery Drivers
Drivers of taxis, limousines and other ‘livery’ vehicles face extremely high risks of workplace
violence, generally from their customers. OSHA has analyzed data from NIOSH and estimates that
taxi and livery drivers are 60 times more likely than typical workers to be murdered on the job (see
below). Nevertheless, because these activities are primarily subject to local regulation throughout
North America, there are no uniform national provisions in the U.S. or Canada. However, OSHA
has recommended protective measures (see Section C.1), worker safety measures intended to
protect “workers working alone or in isolation” may apply (see Section C.2), and some local
governments incorporate driver protection measures into local ordinances (see Section C.3).
1. OSHA recommendations
In May 2000, OSHA issued a two-page fact sheet entitled “Risk Factors and Protective
Measures for Taxi and Livery Drivers” that presents a short discussion of the risks faced by
these workers, and suggests some useful safety measures. The fact sheet notes that no specific
OSHA Standards govern these people’s employers, but that the General Duty Clause does
apply.1 This fact sheet is reproduced as I-1 Supplement 3.
OSHA notes that NIOSH data indicate that taxi and livery drivers are 60 times more likely than
typical workers to be murdered on the job. OSHA identifies the following primary risk factors
(drawn from the NIOSH list discussed above):

working with the public,

working with cash,

working alone,

working at night, and

working in high-crime areas.
To ameliorate the effects of these hazards, OSHA recommends consideration of the following
safety measures:2
1
2

automatic vehicle location or global positioning systems to track vehicles;

caller ID at dispatch centers to trace customer locations;

on-board first aid kits;

on-board surveillance cameras;

partitions or shields between drivers and passengers;

on-board radios with “open mike switch”;
The General Duty Clause is discussed at length in Tab K Chapter 1, Sections A (U.S. laws) and B (Canadian laws).
Readers should note that as of this writing NIOSH is sponsoring research into the effectiveness of two of these measures, bulletresistant partitions and video surveillance cameras. This research is identified on NIOSH's Internet site at
www.cdc.gov/niosh/injury/traumaviol_taxi.html.
WVP 9/04 STP
I-1 13
Tab I Chapter 1

on-board silent alarms;

safety training for drivers, dispatchers and management;

use of debit/credit cards to conduct cashless fare systems; and

protocols with police.
2. Provisions for workers working alone or in isolation
As is noted above, taxi and livery drivers’ isolation greatly increases their risks of workplace
violence. All worker protection agencies make some recognition of these hazards, but five
Canadian provinces have adopted specific provisions for “working alone or in isolation.” These
are described in detail in Tab F Chapter 5 of this Guide. As described in that chapter, employers
in those jurisdictions must do the following:

assess the isolated worker’s conditions or circumstances; and

develop and document a plan incorporating methods to address these hazards.
3. Local regulations
Although local regulations of taxis and limousines generally focus on controlling numbers of
service providers, setting fare schedules, and protecting riders, some jurisdictions require
vehicles to incorporate safety features intended to protect drivers from criminal activity. For
example, Chicago and New York City both require most cabs to incorporate a partition (“safety
shield”) between the driver’s seat and the rear passenger compartment.1 Chicago allows
installation of a silent trouble alarm plus a safe as an alternative, and New York allows for an
alarm plus an additional safety measure (such as a video surveillance camera) approved by that
city’s Taxi and Limousine Commission.2
1
2
City of Chicago, Rules and Regulations for Public Passenger Vehicle License Holders, Rule No. 12.1; New York City Taxi and
Limousine Commission, For Hire Vehicle Rules, § 6-13.
The Commission reviews applications from taxi companies and vendors seeking approval for individual safety measures.
I-1 14
WVP 9/04 STP
Retail Businesses
IMPLEMENTATION CHECKLIST
(1) Conduct an initial hazard assessment.
Has the workplace been assessed for risks of workplace violence (see
Tab A Chapter 3)?
Does the workplace exhibit any risk factors for workplace violence:
 Employees work with customers known or suspected to have a
history of violence?
 Any employees with a history of assaults, or who have exhibited
belligerent, intimidating or threatening behavior to others?
 Workplace has experienced a violent crime?
 Workplace handles valuables (e.g., money, jewelry)?
 Employees who guard money or valuable property or possessions?
 Employees who work alone or in small groups, especially at night
and during early morning hours?
Have the physical attributes of the facility, including access control,
egress control, door locks, lighting, and alarm systems, been
evaluated?
Has staffing, including security staffing, been evaluated?
Does the workplace exhibit any other risk factors?
If so, what are they? __________________________________
Yes
No














(2) Establish a workplace safety and health program.
Has the employer established a general workplace safety and health
program?
If so, is it consistent with worker protection provisions (see Tab K
Chapter 1)?
 Is it consistent with applicable guidelines (e.g., OSHA’s Safety and
Health Program)?
 Does it comply with applicable state or provincial requirements
(e.g., WISHA APP)?
If so, which one? _______________________________
WVP 9/04 STP
I-1 15
Tab I Chapter 1
(3) Establish specific measures to address workplace violence.
Has the employer established a formal workplace violence prevention
program?
Yes
No




 Is an individual or group of individuals assigned responsibility for its
implementation?
 Are all employees made responsible for compliance with the
program?
Whether or not there is a full program, does the employer undertake
any of the following individual workplace violence prevention
activities:
 Workplace security assessment?
 one time (baseline)?
 periodic ongoing?
 Review of/revision to physical attributes of the establishment
including access control, egress control, door locks, lighting,
and alarm systems?
 Install safe/lockbox, and limits on accessible cash?
 Design and implementation of safe and violence-preventing
work practices?
 Review of staffing, including security staffing?
 Review of personnel policies?
 First aid and emergency procedures?
 Criteria for determining and reporting verbal threats?
 Employee education and training in workplace security and violence
prevention?
 Incident reporting and recordkeeping?
 Incident followup and subsequent corrective measures?
 Other: _______________________________________
I-1 16
WVP 9/04 STP