Annual Workplace Violence Prevention Plan Review and Training
The first call we get on an annual workplace violence prevention plan rarely sounds like a renewal.
The first call we get on an annual workplace violence prevention plan rarely sounds like a renewal. It sounds like a question. A safety lead opens an email from corporate, a binder from 2024, or a calendar reminder that no one set, and asks the same thing: do we have to do this again?
The answer is yes. SB 553 was not a one-time July 2024 task. The plan has to be reviewed every year. The training has to be repeated every year. And the two have to happen in a specific order. Skip either one and the file you built last year stops being defensible the next time Cal/OSHA walks in.
This page covers what the annual obligation actually looks like in California, the sequencing rule that trips up most facilities, and what changes between Year 1 and Year 2. For the full picture of the plan itself, see our Workplace Violence Prevention Plan services in California page.
What California Requires Every Year
SB 553 (California Labor Code §6401.9) builds a recurring cycle into the plan. Three things have to happen on a schedule, not on demand:
- Plan review at least annually. The written plan is reviewed for accuracy and effectiveness on a yearly cadence, regardless of whether anything has changed.
- Plan review after any incident. Any workplace violence incident triggers a review of the procedures that were supposed to prevent or respond to it.
- Plan review whenever a deficiency is identified. If an employee report, a near-miss, or an inspection surfaces a gap, the plan is reviewed and the deficiency is corrected.
Refresher training is the fourth piece. Every employee who is covered by the plan receives refresher training at least annually, for as long as the plan is in effect, plus additional training whenever the plan changes or a new hazard is introduced. Initial training only counts once, on the day it is delivered. Everything after that is a refresher.
The Annual Obligations Timeline
A working view of what has to happen between this year and next:
| When | What Happens | Why |
|---|---|---|
| Each year (at minimum) | Review the written plan against current operations, hazards, and responsible-person assignments | §6401.9 annual review requirement |
| Each year (after plan review) | Deliver site-specific refresher training to all covered employees | §6401.9 annual training requirement |
| After any incident | Review the plan and document any changes resulting from the incident | §6401.9 incident-triggered review |
| Whenever a deficiency is identified | Review the plan, correct the deficiency, and document the correction | §6401.9 deficiency-triggered review |
| When the plan materially changes | Train employees on the changes before relying on them | §6401.9 change-triggered training |
| Ongoing | Maintain the violent incident log (5-year retention) and training records (1-year retention minimum) | §6401.9 recordkeeping |
If a year has gone by since your last documented review or refresher training, the plan you have on the shelf is no longer the plan Cal/OSHA expects to see.
Review the Plan First, Then Train
The single most common mistake we see is calendar logistics. Someone schedules refresher training because the year is ending, the trainer arrives, and the plan they are training to is last year’s version. Nothing has been reviewed. Nothing has been updated. The training records will show the right date and the wrong content.
The sequence has to run the other way:
Review the plan first.
Check the responsible-person assignments. Confirm the hazard assessment still matches operations. Walk the facility against what the plan says about access, lighting, alarms, and post-incident response.
Update what changed.
New shifts, new entry points, a different floor layout, a personnel change in any of the responsible-person assignments: each of those is a plan update, not a footnote.
Train on the current plan.
Refresher training references the version of the plan that exists today, including any updates from the review.
When a facility has had any kind of workplace violence incident in the past year, even one that did not result in injury, that incident has to be reflected in the review before the refresher goes out. Training employees on a plan that does not acknowledge what already happened is the kind of finding inspectors flag quickly.
What the Annual Review Actually Looks At
A real review is not a signature on a cover page. When we walk a facility for an annual WVPP review, we are comparing the written plan against three things:
- What the facility looks like now. Operations change. Loading docks get re-routed. Public-facing counters get added or removed. The hazard assessment in last year’s plan has to match what is actually on the floor.
- What has happened since the last review. Any reports filed in the violent incident log, any near-misses raised in employee meetings, any corrective actions taken. Each of those is evidence that the plan either worked or did not.
- Who is responsible for each designated plan function. Personnel turnover quietly breaks plans more often than any other factor. If the person named as the responsible party for incident response left in March and was never replaced in the document, the plan has a deficiency on its face.
The review produces a short written update: what was checked, what was changed, and the date it was completed. That document is what gets filed alongside the plan and shown to an inspector who asks when the annual review was last done.
Where the Annual Review Falls Off
Three patterns account for most of the lapses we see:
It was on someone’s calendar, and that person left.
The plan sat untouched for a year. Nobody else knew it was their responsibility.
Training got handled by a third party, and the plan review was assumed to be part of it.
It almost never is. A generic refresher video does not constitute a plan review and does not satisfy the site-specific training rule under §6401.9. The training requirements page covers why generic content alone is not compliant.
The plan was built once, in 2024, and never opened again.
Inspectors expect to see a dated review entry, a current responsible-persons list, and training records from the last twelve months. The absence of any of those is the citable item.
The facilities that stay current are the ones that put the annual review on a recurring schedule with a named owner, not a reminder. That is the function ongoing compliance management is built to handle, and the reason most clients who keep their WVPP current handle it inside a broader program rather than as a one-off each year. We cover that in our ongoing WVPP compliance page.
How CDMS Handles the Annual Review and Refresher
For facilities that want the obligation handled rather than tracked internally, our annual service includes both pieces in the right order. Our consultant comes to the facility and walks operations against the existing plan. The visit covers the violent incident log and any reports filed in the last year, the responsible-person assignments, and any plan updates those findings require. The refresher training is then scheduled against the current plan, in English or Spanish, in person, by webinar, or through online LMS, sized to your shifts.
The deliverable at the end of the year is the same one Cal/OSHA expects to see: a dated review record, an updated plan, current training records, and the violent incident log maintained through the cycle. Nothing on the shelf that was true once and is no longer.
Trusted throughout California
BSY started working with CDMS last year after our in-house EHS person departed the company. CDMS reviewed our existing operational permits as well as any additional Federal, State and Local regulations that could apply and helped us to create a comprehensive compliance calendar to track regulatory deadlines and submittal due dates. The CDMS team does an excellent job of tracking everything and can be relied upon to complete the forms accurately and assist with submittals, allowing me to focus on our business.
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