SB 553 Annual Review: What California Employers Are Required to Do Every Year

SB 553 required every California employer to have a Workplace Violence Prevention Plan in place by July 1, 2024. Many employers treated that deadline as a finish line. It was not. It was the start of an ongoing compliance cycle that repeats every year and accelerates after every incident.

If you have not reviewed and updated your WVPP since it was first written, you are already out of compliance.

Annual Review Is Mandatory, Not Discretionary

Labor Code Section 6401.9 requires employers to review their WVPP at least annually. The statute also requires review after any workplace violence incident. This is not guidance or a best practice. It is a legal obligation with enforcement consequences.

The review must evaluate whether the plan still accurately reflects conditions at your worksite: physical layout changes, staffing changes, new hazards, and the effectiveness of corrective actions taken during the prior year.

A plan that was accurate in July 2024 and has not been touched since is not compliant in 2026. If the most recent review date is more than 12 months old, that alone can support a citation.

What the Annual Review Must Cover

The review requires substantive evaluation of every component of the plan. At minimum, you must assess and document:

• Personnel assignments. Are the individuals named in the plan still in their roles? If someone has left or changed positions, the plan must be updated with current names and titles.
• Hazard identification. Have new workplace violence hazards emerged? This includes changes in client population, neighborhood conditions, late-night operations, or staffing levels.
• Corrective actions. Were corrective measures implemented after the last review or after any incidents? Did they work? Document what was done and whether it was effective.
• Incident log entries. Review all entries in the violent incident log from the prior year. Identify patterns, recurring issues, or gaps in the response.
• Reporting mechanism. Is the employee reporting system still functional and accessible? Anonymous reporting must remain available.
• Training records. Confirm that all employees received annual refresher training. Identify any employees who were missed.

Incident-Triggered Reviews

The annual review is the minimum frequency. SB 553 also requires a plan review after any workplace violence incident. This is a separate obligation. You cannot wait until the next annual cycle to address a serious event.

An incident-triggered review must evaluate whether the plan's response procedures worked as intended, whether the hazard assessment needs updating, and whether additional corrective measures are necessary. Document the results in writing.

How to Document the Review

Cal/OSHA does not prescribe a specific format for the annual review, but documentation is essential. If you cannot produce written evidence that a review occurred, it will be treated as though it did not occur.

Effective documentation includes:

1. Date of the review. The specific date, not a vague reference to "annual review."
2. Who participated. Names and titles of the individuals who conducted the review. Inspectors may ask whether employees participated in the review process.
3. What was evaluated. A section-by-section assessment noting what was reviewed and what, if anything, was changed.
4. Changes made. If sections were updated, note what changed and why. If no changes were needed, state that explicitly.
5. Next steps. Any corrective actions identified during the review, with assigned responsibility and target dates.

Keep the review documentation filed with the WVPP itself. When an inspector asks for your plan, they will expect to see review records alongside it.

Retraining Requirements

Annual review triggers annual retraining. Under Labor Code Section 6401.9, all employees must receive training on the WVPP at least once per year. If the plan is updated as a result of the annual review, training must cover the updated content.

Training must be interactive. A recorded video with no opportunity for questions does not satisfy the statute. Employees must have the opportunity to ask questions and receive answers from a person knowledgeable about the plan. For more detail on what qualifies as compliant training, see our guide on SB 553 employee training requirements.

Document training with sign-in sheets, dates, topics covered, and the name of the trainer.

Record Retention: Five Years

Most WVPP-related records must be retained for five years: the plan itself, all prior versions, annual review documentation, and the violent incident log. Training attendance records have a shorter statutory minimum of one year (LC 6401.9), though many employers retain them for the full five-year period alongside other compliance documents for simplicity. Cal/OSHA can request records going back the full five-year period during an inspection. If you cannot produce your 2024 plan and your 2025 review documentation, you have a records retention problem that compounds any underlying compliance gaps.

The Bottom Line

SB 553 compliance is a cycle, not a project. Every 12 months, you must review the plan, update it as needed, retrain your workforce, and document everything. After any incident, that cycle accelerates. The employers who treat this as an annual administrative task, and document it accordingly, are the ones who survive an inspection without a citation. As we covered in our one-year retrospective, the grace period is over.

If your plan has not been reviewed since it was first created, start here.