PURCHASE COLLEGE

Workplace Violence[1] Prevention Policy

 

SECTION I – Workplace Violence Prevention Policy

Purchase College, including any of its off-site locations (hereafter Purchase College property), is committed to providing a safe workplace/learning environment. Purchase College will respond promptly to threats, acts of violence, and acts of aggression against its employees, including those of domestic violence (see related Purchase College “Domestic Violence and The Workplace Policy”). This policy sets forth standards for employee conduct and guidelines for reasonable precautions. The accompanying procedures outline responses to threats or violence, should they occur in the workplace. (Note: This policy shall not act to abridge, modify or in any way limit the administration of the Federal laws and/or of the State of New York.)

Prohibited Conduct:

A. Purchase College has a Zero Tolerance Standard with respect to acts or threats of violence in the workplace. The workplace is further defined as the Purchase College property, which also includes its grounds, perimeters, and sidewalks or while in transit to its off-site locations, parking facilities or local mass transit or otherwise while in work status.

B. No person may engage in violent conduct or make threats of violence, implied or direct, including acts of domestic violence, on Purchase College property or in connection with college business or employment. This includes but is not limited to:

• The use of force with the intent to cause harm, e.g. physical attacks, any unwanted contact or touching including but not limited to spitting, pushing, hitting, fighting, or throwing objects;
• Behavior that diminishes the dignity of others through gender, sexual, sexual orientation, racial, religious or ethnic harassment;
• Acts or threats which are intended to intimidate, harass, threaten, bully, coerce, or cause fear of harm whether directly or indirectly; and,
• Acts or threats made directly or indirectly by oral or written words, gestures or symbols that communicate a direct or indirect threat of physical harm including the use of a third-party, making internal or external phone calls, sending mail, packages, faxes or emails, tampering with a computer, other equipment or motor vehicle, repeated, malicious verbal mistreatment, attempting to intimidate, or intentionally inflicting emotional distress.
• Engaging in behavior that subjects another to extreme emotional distress;
• Carrying, possessing, or using any firearm, explosive or other dangerous weapon on College property or in College buildings or facilities without legal authority; and,
• Taking retaliatory action against anyone acting in good faith who has made a complaint of workplace violence, a potential workplace violence incident, who has reported witnessing workplace violence, or who has been involved in reporting, investigating, or responding to workplace violence is in violation of this policy. 

C. In accordance with SUNY policy, no person, except authorized University Police Officers, other local, state and federal Police Officers with jurisdiction (example: Rye Brook, Harrison, and NYS Police) and Peace Officers in the line of duty, may carry, possess or use any weapon on Purchase College property or in its buildings or facilities.

Workplace Violence Advisory Committee:

A. The President, or her designee, shall cause to establish a Workplace Violence Advisory Committee, which shall be chaired by the University Chief of Police or approved designee. This committee will:

• Perform a risk evaluation[2] of the workplace to determine the presence of factors or situations that might place employees at risk of workplace violence;
• Assess the campus’ readiness to address violence and domestic violence in the workplace;
• Facilitate appropriate responses to reported incidents of workplace violence;
• Assess the potential problem of workplace violence;
• Evaluate incidents to prevent future occurrences;
• Utilize prevention, intervention, and interviewing techniques in responding to workplace violence;
• Develop workplace violence prevention tools (such as pamphlets, guidelines and handbooks) to assist in recognizing and preventing workplace violence on campus;
• Arrange regularly scheduled workplace violence prevention training sessions for employees; and,
• Establish subcommittees as needed.

B. This Advisory Committee shall include representative(s) from University Police, Employee Assistance Program, Human Resources, Campus Personal Safety Committees and local labor representatives. As needed, subcommittees shall be established. It is recommended that such subcommittees be chaired or co/chaired by an Advisory Committee member and, as appropriate, should include University Police, Administration, Academic Affairs, and local Labor representatives. Regional Counsel’s Office will serve as counsel to the Committee/subcommittees, as needed.                               

Workplace Violence Prevention Program:

Purchase College shall develop and implement a written workplace violence prevention program[3] for its workplaces that includes the following:

• A definition of workplace violence including the meaning of zero tolerance;
• Commitment to zero tolerance of workplace violence;
• Techniques on how to recognize and avoid workplace violence situations;
• Identification of the high risk occupations, functions and work locations;
• Importance of reporting all workplace violence incidents and procedure to do so;
• Investigations of incidents by the employer; and,
• Employee assistance

Information And Training For Employees:

Purchase College shall make the written workplace violence prevention program available, upon request, to its employees and/or their authorized representatives.

At the time of employees’ initial appointment and annually thereafter, the Purchase College shall provide its employees with the following information and training on the risks of violence in their workplace(s):

• The requirements of NYS Labor Law § 27-b;
• The risk factors in their workplace(s);
• The location and availability of the written workplace violence prevention program; and,
• Training sessions that outline:

Retaliation:

Retaliatory action against anyone acting in good faith who has made a complaint of workplace violence, who has reported witnessing workplace violence, or who has been involved in reporting, investigating, or responding to workplace violence is a violation of this policy. Those found responsible for retaliatory action will be subject to discipline up to and including termination.

SECTION II - PROCESS:

Incidents of workplace violence, threats of workplace violence, or observations of workplace violence are not to be ignored by any member of the Purchase College community. Workplace violence must be reported immediately to the appropriate Purchase College official (see below). Additionally, all members of the Purchase College community are encouraged to report, in the same manner, behavior they reasonably believe poses a potential for workplace violence in order to maintain a safe working environment. An employee or supervisor who fails to adhere to the requirements of this policy may be subject to administrative action including possible discipline.

Reporting Procedures:

1. Any person experiencing or witnessing imminent danger or personal injury or violence involving weapons or actual violence shall immediately call University Police local 911 Emergency Services Call Center at 914-251-6911 or Extension 6911 (from campus land line phones). Complaints can also be filed anonymously by calling 914-251-5970 or Extension 5970 (from campus land line phones) or via the Purchase College Human Resources/Reporting Workplace Violence -Anonymously website. Just click on “Workplace Violence Report (Anonymous)” link.
2. Any person who is the subject of a suspected violation of the Workplace Violence Prevention Policy involving violence without weapons or personal injury, or is a witness to such suspected violation, should report the incident to their supervisor and University Police.
3. Employees are required to report any threat or act of violence that they have witnessed, received, or have been informed of, to University Police and if another employee is involved, also notify their supervisor and Human Resources.
4. Every threat must be reported immediately. Any individual believed to be a substantial threat to the health and safety of the campus community is to be reported to University Police immediately for investigation, recommendation and disposition.
5. Employees who commit a violent act or threaten to commit a violent act shall be subject to the full range of criminal/civil prosecution and/or disciplinary action, as appropriate.      
6. An individual who makes a substantial threat, exhibits threatening behavior or engages in violent acts on the Purchase College property shall be subject to removal from the campus as quickly as safety permits, and barred from campus (persona non gratis) pending the outcome of an investigation and administrative proceedings.

Employees:

1. Employees are responsible for promoting and maintaining and helping to maintain a safe work and educational environment and are required to take reasonable precautions to prevent violence and other unsafe conditions in the workplace and report indicators of increased risk of violent behavior including but not limited to the following examples:

Precautions:

• In response to verbal, telephonic or other electronic inquiries including emails, do not release information about coworkers’ schedules, home address or telephone numbers, or other personal information;
• In the event of suspicious conduct, request the credentials of any stranger who enters your office to do repair or other service work. If necessary, verify the work request with Facilities Department or University Police;
• Never leave money, credit card, travel documents or any thing else of value in an unlocked desk or cabinet; and,
• If something is stolen, report it to University Police immediately. 

Indicators/Predictors[4]:

• Direct or veiled threats of harm including gestures, pictures or drawings;
• Intimidating, belligerent, harassing, bullying, or other inappropriate and aggressive behavior;
• Numerous conflicts and/or aggressions with supervisors and/or other employees;
• Bringing a weapon to the workplace, brandishing a weapon in the workplace, making inappropriate references to guns including claims of carrying a harmful weapon, or fascination with weapons;
• Statements showing fascination with incidents of workplace violence, statements indicating approval of the use of violence to resolve a problem, or statements indicating identification with perpetrators of workplace homicides;
• Statements indicating desperation (over family, financial, and other personal problems) to the point of contemplating suicide;
• Drug/alcohol abuse; and,
• Extreme changes in behavior.

2. Employees are required to notify University Police immediately whenever a Protective Restraining Order is granted which mentions Purchase College property, or involves a Purchase College employee, or a person working at or attending Purchase College, and provide a copy of the order to University Police (a photo would be helpful). Appropriate efforts will be made to protect the privacy and sensitivity of the information provided. It is recommended that the employee also notify their supervisor.

3. Victims or potential victims of domestic violence who believe the violence may extend into the workplace, or employees who believe that domestic or other personal matters may result in them being subject to violence extending into the workplace, are strongly encouraged to notify their supervisor and University Police. Confidentiality will be maintained to the extent possible and/or reasonably prudent to do so.

4. Employees have an obligation to report incidents of violence and/or inappropriate conduct or behavior to their supervisor and University Police immediately.

5. Any employee or representative of employees who believes that a serious violation of a workplace violence protection program exists or that an imminent danger exists shall bring such matter to the attention of the supervisor and University Police immediately and follow-up with a written notice to them. If, following a written notice, the matter has not been resolved and the employee or representative still believes that a violation of a workplace violence prevention program remains, or that an imminent danger exists, the employee or representative should contact the Chief of University Police.

Supervisors

1. Each dean, department chairperson, director, administrator, or other person with supervisory responsibility (hereinafter “supervisor”) is responsible within their area to implement this policy.

2. Supervisors are required to contact University Police immediately in the event of imminent or actual violence involving weapons or potential physical injuries.

3. Supervisors must report to University Police immediately any complaint of workplace violence made to them and any other incidents of workplace violence of that they become aware of or reasonably believes to exist.

4. Supervisors are also expected to inform their immediate supervisor promptly about any complaints, acts, or threats of violence even if the situation has been addressed and resolved. After having reported such complaint or incident to University Police and immediate supervisor, the supervisor should keep it confidential and disclose it only as necessary during the investigation process and/or subsequent proceedings.

5. Supervisors are also required to report any knowledge of such conduct to Human Resources immediately.

University Police:

1. University Police is responsible for:

1. Responding to;
2. Intervening;
3. Developing and providing education and prevention training in cooperation with the Environmental Health & Safety & Human Resources; and,
4. Documenting[5] all incidents of violence in the workplace.

2. University Police will immediately log all incidents of workplace violence and will notify Human Resources and the respective supervisor of an incident with their employee.

3. University Police will report all critical incidents of violence to the Administrative Chain of Command and, as appropriate (information on active criminal investigations will not be shared), the Chair of the Advisory Committee referenced herein.

4. University Police will maintain an internal tracking system of all threats and incidents of violence. Annual reports will be submitted to the President detailing the number and description of workplace violence incidents, the disposition of the incidents, and recommend policy, training issues, or security procedures that were or should be implemented to maintain a safe working environment.

5. University Police officers will be trained in workplace violence awareness and prevention, non-violent crises intervention, conflict management, and dispute resolution.

6. When informed, University Police will maintain a record of any Orders of Protection and will provide escort service to members of the college community within its geographical confines, when requested as long as sufficient personnel are available. Such services are to be extended at the discretion of the Chief of University Police or designee. Only the President, her designee or the Chief of Police can authorize escort service outside of the geographical confines of Purchase College.

Department of Human Resources:

1. The Department of Human Resources is responsible for:

1. Assisting the Chief of University Police and supervisors in responding to workplace violence through the enforcement of this policy;
2. Facilitating appropriate responses to reported incidents of workplace violence;
3. Notifying University Police of workplace violence incidents reported to HR;
4. Consulting with, as necessary, counseling services to secure professional intervention;
5. Providing new employees or an employee transferred to Purchase College with a copy of the Workplace Violence Prevention Policy at the time of orientation as well as training that includes workplace violence prevention. A record of the signed receipt will be placed in each new or transferring employee’s personnel file (electronic or otherwise);
6. Reported incidents of workplace violence including but not limited to providing critical contact information to Authorities.
7. Working with University Police to ensure that all employees are provided appropriate training pursuant to NYS Labor Law §27b; and,
8. Developing supportive training programs such as conflict resolution, dispute resolution and anger management.
9. Disseminating annually this policy to all employees and posting it on the Purchase College website, as appropriate. 

Appendix A – Members of the Workplace Advisory Committee

• Mercedes Andujar– UPD - NYSCOPBA
• James McGowan – UPD –NYSPBA
• Fred Vanzillotta - UPD - NYSPBA
• Paula Rankine-Belgrave – UUP
• Sherwin Reid – CSEA
• Louis Wirtz – Associate Director, Environmental, Health and Safety
• Barbara Washington – Enrollment Services
• Mary Cozier – Health Services
• Odile Delgado – Employee Assistant Program Coordinator
• Cathy VanBomel – Counseling Center
• Ricardo Espinales – Assoc. Director of HR
• Kristi Gullen– Labor Relations Specialist - HR

[1] For what constitutes Workplace Violence see the National Institute for Occupational Safety and Health’s (NIOSH) definition in the NYS Department of Labor Division of Safety and Health’s, Workplace Violence Prevention Requirements for NYS Public Employers website.

[2] For a description of a risk evaluation visit the NYS Department of Labor Division of Safety and Health’s, Workplace Violence Prevention Requirements for NYS Public Employers website.

[3] From the New York State Department of Labor Division of Safety and Health’s, Workplace Violence Prevention Requirements for New York State Public Employers website

[4] Identified by the FBI’s National Center for the Analysis of Violent Crime, Profiling and Behavioral Assessment Unit) in Dealing with Workplace Violence: A Guide for Agency Planners by the United States Office of Personnel Management, Workforce Relations, February 1998

[5] For recordkeeping requirements see NYS Labor Law § 27-a. Safety and health standards for public employees.