SB 553, One Year Later: What Cal/OSHA Is Now Expecting

California's workplace violence prevention law, SB 553, became enforceable on July 1, 2024. For the first six months, enforcement was relatively measured. Cal/OSHA gave employers time to develop their Workplace Violence Prevention Plans, train their workforce, and establish incident reporting systems.

That grace period is over.

Year Two Means Year One Obligations Are Being Audited

January 2026 marks the start of the second full year under SB 553. That triggers a critical set of obligations that many employers have overlooked: the annual review cycle.

Under Labor Code Section 6401.9, every employer with California employees must review and update their WVPP at least annually. This is not optional. It is not a suggestion. It is a statutory requirement with real enforcement consequences.

The annual review must assess whether the plan still reflects:

• Current worksite conditions and physical layout
• Current personnel assignments for plan administration
• Updated hazard identification based on incidents or changes in operations
• Effectiveness of existing corrective measures
• Any new types of workplace violence risks

If your plan has not been reviewed and updated since it was first written in mid-2024, you are already behind.

What Cal/OSHA Inspectors Are Actually Looking For

Cal/OSHA has been clear about what constitutes a compliant WVPP. Inspectors are not simply checking whether a document exists. They are evaluating whether the plan is implemented, site-specific, and documented.

Here is what that means in practice:

• Named personnel. Your plan must identify specific people responsible for implementation, by name and title, not just "management."
• Site-specific hazards. A plan that lists generic hazards without reference to your actual worksite layout, hours of operation, customer-facing roles, or neighborhood conditions will not pass inspection.
• Training records. You must be able to produce documentation showing that every employee received initial training and that annual refresher training has been conducted or scheduled.
• Incident log. The violent incident log must contain all eight fields required by the statute. A blank log is acceptable only if no incidents have occurred, but you must still have the log and the reporting mechanism in place.
• Reporting mechanism. Employees must have a way to report workplace violence concerns, including anonymously if they choose. Many employers still have not established this.

The Copy-Paste Problem

One of the most common deficiencies Cal/OSHA has identified is employers using copy-paste plans downloaded from the internet or lifted directly from the Cal/OSHA model template without customization. Cal/OSHA has stated directly that such plans generally fail inspection.

The model plan published by Cal/OSHA is 19 pages long and explicitly designed to be adapted. It contains placeholder language (brackets, blanks, and instructions) that must be replaced with your specific information. If an inspector opens your plan and sees bracketed placeholder text, that is a citation.

The Permanent Standard Is Coming

SB 553 was always intended as a placeholder. The legislation itself requires Cal/OSHA to adopt a permanent workplace violence prevention standard by December 31, 2026. A draft of that permanent standard was submitted to the Standards Board in late 2025 and is currently under review.

The permanent standard is expected to be more prescriptive than SB 553, particularly around engineering controls, work practice controls, and post-incident response procedures. Employers who have invested in a thorough, well-documented WVPP under the current law will be better positioned to adapt when the permanent standard takes effect.

What You Should Do Now

If you have not taken action since mid-2024, here is the minimum you need to do immediately:

1. Conduct your annual WVPP review. Document the review in writing, including any changes made and the date of the review.
2. Complete annual retraining. All employees must receive refresher training on your WVPP. Document attendance.
3. Update your incident log. Confirm your log contains all eight required fields and that your reporting mechanism is functional and accessible.
4. Verify plan specificity. Read your plan with fresh eyes. Does it name your actual worksite address? Does it identify your specific hazards? Does it name the people responsible for implementation?
5. Prepare for the permanent standard. Monitor Cal/OSHA's Standards Board proceedings. The permanent standard will likely require additional measures beyond what SB 553 mandates.

The Cost of Non-Compliance

Cal/OSHA penalties for workplace violence prevention violations reach up to $25,000 per serious violation. Willful or repeat violations can reach significantly higher. Beyond the financial penalty, a citation creates a public record and can complicate insurance renewals, client relationships, and litigation defense.

The cost of compliance is a fraction of the cost of a single citation. The time to act is now, not when an inspector arrives.