LifeWays Operating Procedures

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1 WORKPLACE VIOLENCE I. PURPOSE: LifeWays is committed to preventing workplace violence and to maintain a safe work environment through the development of a Workplace Violence Action Plan. II. SCOPE This procedure applies to all persons who come onto LifeWays property, to all use of LifeWays equipment, and to all times and places where an individual is on LifeWays business. III. IV. WORKPLACE VIOLENCE ACTION PLAN A. The first and foremost priority of this plan is to SAVE LIVES in the unanticipated event of an active shooter or other workplace violence. The plan is to be realistic, straight forward and effective in protecting lives, yet flexible for departments to add specific requirements based on building locale and specificity of the functions, i.e., consumer interaction. B. This plan is to be distributed and reviewed with all employees. Departments are encouraged to provide further training to all employees, specific to their locale within the facility so each employee knows at least two different escape routes/protective strategies in any situation. C. Given the increasing violence in society in general, LifeWays has adopted a policy of zero tolerance for any threatening, intimidating, harassing or coercive behavior, whether overt or implied, as well as any improper, harmful or offensive physical contact. It is also the belief of LifeWays Administration and Board of Directors that LifeWays is not at greater risk of an active shooter incident due to its customer population. Individuals who are treated for a mental illness do not present more danger to society than the individual without a mental illness. PROCEDURE A. The prohibition against threatening, intimidating, harassing or coercive behavior is intended to be absolute. Intent will not ordinarily be an excuse, and LifeWays will not accept claims that prohibited conduct was not meant to be taken seriously, constituted horseplay, or was only a joke. B. LifeWays encourages employees to bring their disputes or differences with other Page 1 of 9

2 employees to the attention of their supervisors or the Human Resources Director before the situation escalates into potential violence. LifeWays is eager to assist in the resolution of employee disputes, and will not ordinarily discipline employees for raising such concerns. C. Weapons on premises: 1. Employees are prohibited to have possession of weapons on LifeWays time or property. Any employee who violates this policy will be subject to immediate dismissal. 2. LifeWays discourages the possession of weapons on LifeWays property by customers. 3. The prohibition of weapons in this policy is not restricted to firearms, knives and explosives but rather applies to anything that a reasonable person would consider to be a weapon or a dangerous item with the potential to inflict harm. LifeWays does not intend to debate this definition, and employees with any doubt about the appropriateness of any item should either obtain permission from Human Resources or leave it at home. 4. The prohibition of weapons in this policy does not apply to tools necessary for the performance of any employee s job with LifeWays. 5. The prohibition of weapons in this policy applies whether or not the person is licensed to carry the weapon, concealed or otherwise. It likewise applies to any weapons that may be stored in any vehicles or containers that come onto LifeWays property. D. For the safety and security of our employees, residents, visitors and property, LifeWays may, at its discretion, inspect the contents of all desks, work areas or other LifeWays property. It also reserves the right to inspect all vehicles, packages, purses, bags, containers and other items brought onto LifeWays property or used/possessed while engaged in LifeWays business. E. If a customer comes into the building, with a weapon visible, in an emotionallycompromised or otherwise agitated state and it is staff s judgement that there is a great potential for harm with regard to the weapon the individual is carrying, staff will: 1. Follow usual protocols for verbal de-escalation of a client 2. Contact a management member of the Access or Medical Services to alert them that the individual is agitated and has a weapon on their person. This shall be done in a calm manner that does not alarm other employees. 3. Management staff, with assistance from another staff member, will attempt to Page 2 of 9

3 quietly and privately engage the customer and have a polite discussion about people feeling uncomfortable. In a non-prohibited way, the person will be gently asked to leave the weapon in their vehicle (or other designated place) while being seen for their appointment. 4. Treating staff reserve the right to not see a person if they feel they are in harm s way for any reason, not just weapons carry. The staff member must have the approval of his or her supervisor to invoke that right. F. If a customer brings a weapon in and is in an open carry situation and is not agitated, nor acting in a suspicious manner, etc., staff do not need to address or mention the weapon issue. HOWEVER, front desk staff should notify whomever will be seeing the customer so that they are aware. G. If another customer should approach the front desk and express concern over another customer, due to a weapon or any other situation, the front desk staff will politely remind the person (if the stated concern is related to a weapon) that it is an individual s constitutional right to open carry, and shall offer the customer a different area in which to be seated. Staff will focus on keeping the individual calm. H. Under certain circumstances, involving reasonable suspicion of improper conduct in violation of this procedure, the Drug Free Workplace Procedure, or other policies/procedures protecting safety or security, LifeWays may request employees to submit to a search of their persons. Refusal to consent to any search may result in disciplinary action up to and including discharge. All searches will be conducted with due regard for the privacy of the persons involved. V. REPORTING VIOLATIONS A. All violations of this policy that an employee experiences or witnesses should be reported immediately to the immediate supervisor or any other member of Administration. This includes violations from any source, whether other employees or residents, vendors, solicitors, or members of the public. Reporters are encouraged to be as specific and detailed as possible when reporting a threat of violence. B. Employees shall never place themselves in danger. Instead, all violations and any suspicious individuals or activities shall be reported as soon as possible and allow LifeWays to address the situation. C. LifeWays will promptly and thoroughly investigate all reported violations of this policy. The identity of the individual making a report will be protected as much as is practical. In order to maintain workplace safety and the integrity of its investigation, LifeWays Page 3 of 9

4 may suspend employees, either with or without pay, pending the conclusion of its investigation. D. Employees are expected to cooperate in all investigations of suspected violations of this policy. VI. VII. TRAINING STAFF FOR AN ACTIVE SHOOTER SITUATION A. To prepare staff for a workplace violence/active shooter situation training exercises that review and reinforce the Workplace Violence Action Plan will be conducted annually. The training exercise will prepare the staff to appropriately respond and help minimize loss of life. Training shall include local law enforcement, emergency responders, SWAT teams, K-9 teams, and bomb squads during exercises to support a realistic scenario. Staff will learn to: 1. Recognize the sound of gunshots 2. React quickly when gunshots are heard and/or when a shooting is witnessed 3. Report to authorities 4. Report to all staff when possible: LifeWays Emergency Paging Protocol Code W Weapon/Hostage 5. React when law enforcement arrives HOW TO RESPOND IN AN ACTIVE SHOOTER SITUATION Quickly determine the most reasonable way to protect your own life. Remember that clients are likely to follow the lead of employees and managers during an active shooter situation. A. There are three options that a person has: 1. Run/Evacuate a) If there is an escape path, attempt to evacuate the premises, even if others agree to or not. Be sure to: 1) Have an escape route and plan in mind 2) Evacuate regardless of whether others agree to follow 3) Help others escape if possible 4) Leave belongings behind 5) Prevent individuals from entering the area 6) Follow instructions of any police officers 7) Do not attempt to move wounded people Page 4 of 9

5 8) Keep your hands visible 9) Call 911 when you are in a safe location 10) If possible, call in a Code W 2. Hide (a) If it is not safe to evacuate, then find a place to hide where the active shooter is less likely to find you. (b) If the office should have a panic button, push it. (c) The hiding place should: 1) Be out of the active shooter s view 2) Provide protection if shots are fired in your direction (i.e., an office with a closed and locked door) (d) Do not trap yourself or restrict your options for movement (e) To prevent an active shooter from entering your hiding place: 1) Lock the door 2) Blockade the door with heavy furniture (f) If the active shooter is nearby: 1) Lock the door 2) Silence cell phone and/or pager 3) Turn off any source of noise (i.e., radios, televisions) 4) Turn off lights 5) Hide behind large items (i.e., cabinets, desks) 6) Remain very quiet (g) If evacuation and hiding out are not possible: 1) Remain calm 2) Dial 911, if possible, to alert police to the active shooter s location 3) If you cannot speak, leave the line open and allow the dispatcher to listen 3. Fight/Take action against the active shooter (a) As a last resort, and only when your life is in imminent danger, attempt to disrupt and/or incapacitate the active shooter by: 1) Attempt to incapacitate shooter 2) Act with physical aggression 3) Improvise weapons and throw items 4) Commit to your actions 5) Yell if you think this will distract the shooter 4. How to react when law enforcement arrives: Page 5 of 9

6 (a) Law enforcement s purpose is to stop the active shooter as soon as possible. Officers will proceed directly to the area in which the last shots were heard. It is important to have an idea of what to expect: 1) Officers will wear regular patrol uniforms or external bulletproof vests, Kevlar helmets, and other tactical equipment 2) Officers will be armed with rifles, shotguns, handguns 3) Officers will use pepper spray or tear gas to control the situation 4) Officers will shout commands, and may push individuals to the ground for their safety (b) For the officers to do their work as efficiently as possible, it is important staff and other customers respond appropriately: 1) Remain calm, and follow officers instructions 2) Put down any items in your hands (i.e., bags, jackets) 3) Immediately raise hands and spread fingers 4) Keep hands visible at all times 5) Avoid making quick movements toward officers such as holding on to them for safety 6) Avoid pointing, screaming and/or yelling 7) Do not stop to ask officers for help or direction when evacuating, just proceed in the direction from which officers are entering the premises 8) Information to provide to law enforcement or 911 operator: i. Location of the active shooter ii. Number of shooters, if more than one iii. Physical description of shooter/s iv. Number and type of weapons held by the shooter/s v. Number of potential victims at the location vi. Access to camera footage, if applicable (c) The first responders or officers that arrive to the scene will not stop to help any of the injured persons. They are there to take down the active shooters. There will be a rescue team comprised of officers and emergency medical personnel to follow the initial officers. This is the team that will treat and remove the injured persons. In order to treat and remove the injured bodies in a quick manner, they may ask any able-bodied individuals to assist in removing the wounded from the premises. (d) Any individual that has been evacuated or escaped from the premises will likely be held in an area by law enforcement until the situation is under control, and all witnesses have been identified and questioned. Do not leave until law enforcement authorities have instructed to do so. Page 6 of 9

7 5. Managing the consequences of workplace violence (a) After the active shooter has been incapacitated and is no longer a threat, human resources and/or management should engage in post-event assessments and activities, including: 1) Count of all individuals to see if anyone is missing and/or potentially injured 2) Determine a method for notifying families of individuals affected by the active shooter, including notification of any casualties 3) Assessing the psychological state of the individuals at the scene, and referring them to health care specialists accordingly 4) Participate in the law enforcement investigation as needed 5) Facilities department to return the space back to normal 6. Monitoring and Reporting (a) For future emergencies, it is important to analyze the active shooter situation and create an after-action report. The analysis and reporting contained in the report is useful for: 1) Identifying successes and failures that occurred during the event. 2) Providing an analysis of the effectiveness of the current procedure 3) Describing and defining a plan for making improvements VIII. PREVENTION OF AN ACTIVE SHOOTER SITUATION A. Recognizing Potential Workplace Violence in employees: An active shooter in the workplace may be a current or former employee, or an acquaintance of a current or former employee. Intuitive managers and coworkers may notice characteristics of potentially violent behavior in an employee. The Human Resources Department should be notified if there is suspicion regarding an employee or coworker exhibiting potentially violent behavior. If an employee has taken out a PPO on any individual, they are required to notify the Human Resources Department. B. Other Prevention Strategies A. Foster a respectful workplace B. Be aware of indications of workplace violence and take remedial actions accordingly C. Conduct effective employee screening and background checks D. Create a system for reporting any signs of potentially violent behavior E. Do not allow non-lifeways badged, unknown individual to follow through a secured door unaccompanied F. Periodically inspect work areas for security hazards and unsafe conditions Page 7 of 9

8 G. Report any suspicious activity H. An established and routinely tested emergency notification system to alert various parties of emergency including: (a) Individuals within the building. (b) Local law enforcement. I. Panic buttons in the Physician Services Unit: When a panic button is activated it sends a loud alarm to a box in the front desk area. J. LifeWays maintains 7 panic buttons, which are provided to each doctor working in the Jackson Physicians Services Unit. (a) Testing of each panic button will be assigned to a position within the appropriate department and should be completed once a month. IX. SECURITY CAMERAS A. Eleven cameras are located throughout the Jackson facility. The Jackson facility camera program is a software application installed on all computers cameras are located in the back parking lot, 3 cameras are located in the lobby and 1 camera is located in the vestibule of the Jackson Facility. These camera record and are maintained for 33 days cameras are located in the front parking lot of the Jackson Facility 3. 8 cameras are located in each of the 8 evaluation rooms of the Jackson Access Center; 2 cameras are located in the 2 evaluation rooms of the Hillsdale Access Center; one per room. In accordance with federal law, these cameras do not record. Activity is observed randomly and/or when there is reasonable belief of behavior that may put staff at risk cameras are located throughout the Hillsdale facility. They record for approximately 30 days. The Hillsdale facility camera program is a web-based application available by a user name and password provided to applicable personnel. Their locations are as follows: a) 1 in the Access Center Lobby b) 1 in the East Hallway (Integro) c) 1 in the West Hallway (Hope Network Southeast) d) 1 in the Center Hallway e) 1 in the South Hallway (Doctors) B. Testing of security camera should be assigned to a position within the appropriate department and shall be completed once a month. Page 8 of 9

9 X. BOMB THREAT A. In the event any staff person/tenant is notified of a bomb threat by telephone, the person receiving the call shall complete a Bomb Threat Report form, Form #114, during the call, if possible. B. Immediately, upon termination of the call, the Team member or tenant shall notify the LifeWays Safety Officer/Designee who shall immediately inform the Chief Executive Officer. C. The Chief Executive Officer will evaluate the threat and circumstances and determine need for building evacuation. Building evacuation shall occur following procedures for building evacuation via an office by office sweep of the building. D. Use of electronic devices such as beepers, phones, radios, and building paging is strictly prohibited in the evacuation due to a bomb threat. E. The LifeWays Safety Officer/Designee shall notify and coordinate a building search in cooperation with police authorities. F. The bomb threat procedure shall be reviewed by each department at least annually. REFERENCES Audience: LifeWays Staff LifeWays Provider Network HISTORY *Replaces Weapons or Hostage Emergencies and Bomb Threats Effective 11/01/2016 Reviewed/Revised: Page 9 of 9