Is a Workplace Violence Prevention Plan Required? SB 553 Coverage
If you run a California business with employees on site, the answer is probably yes.
If you run a California business with employees on site, the answer is probably yes. SB 553 cast a wider net than most employers realize. The law took effect July 1, 2024, and it covers most California workplaces, with a handful of specific exceptions.
The question of who is covered comes up constantly. Two scenarios drive it. An employer who has heard about SB 553 and is unsure whether the rules apply to a 12-person warehouse or a small office. A multi-location operator who knows one site is covered but is not sure about the back-office space with a few people and no customer traffic. Both have clear answers once you walk through the trigger.
This piece is the coverage check. For the full overview of the law and how to comply, see our workplace violence prevention plan California guide.
Who Does SB 553 Apply To?
California Labor Code §6401.9, created by SB 553, reaches nearly every California employer. The trigger has two parts. You need a written Workplace Violence Prevention Plan (WVPP) if:
- You have 10 or more employees on site at the same time, or
- Your workplace is accessible to the public, regardless of employee count.
The “10 employees at a time” wording matters. It is about how many employees are present at the workplace, not the size of your total payroll. A facility with 30 employees split across three shifts of 10 hits the trigger on each shift. A small operation with three employees plus a public lobby hits the trigger because of the public access.
When we walk a facility for the first time, the public-access question is one of the first things we work through with the operations lead. Many employers assume “public-facing” means retail. It does not. We see it most often in distribution warehouses with will-call pickup, labs that take in customer samples, small manufacturers with a front office where vendors and visitors come and go, and property management offices with walk-in tenants. If a person who is not your employee can walk in during business hours, the workplace is public-facing for SB 553 purposes.
Who Is Not Covered by SB 553: The Four Exception Categories
The statute carves out four narrow exceptions. Each one is specific. If you do not fit cleanly into one of them, you are covered.
Employers covered by the Workplace Violence Prevention in Health Care standard
California already has a separate Cal/OSHA standard, the Workplace Violence Prevention in Health Care standard (Title 8 §3342), that requires hospitals, clinics, and other covered health care employers to maintain a written workplace violence prevention plan. Health care facilities, service categories, and operations that are covered by, or comply with, that standard are not required to comply with SB 553 on top of it. The exemption tracks who is actually covered by §3342, so a health care-adjacent workplace that falls outside §3342 is not automatically exempt.
Employees teleworking from a location of their own choosing
If an employee works from home, a coffee shop, or any location they choose that is not under the employer’s control, that worksite is not covered by SB 553. The law applies to workplaces the employer controls. Remote workers who report to a covered facility are still factored into that facility’s plan; the exception only removes their home setup from scope.
Workplaces with fewer than 10 employees at a time and not open to the public
This is the small-employer exception, and it has three conditions, not two. To qualify, the workplace must have fewer than 10 employees on site at any given time, and not be accessible to the public, and be in compliance with the Cal/OSHA Injury and Illness Prevention Program (IIPP) standard (Title 8 §3203). Miss any one of the three and the plan is required. The IIPP condition catches a lot of small employers off guard: a sub-10-person, non-public workplace still needs a compliant IIPP to claim this exemption.
The Department of Corrections and Rehabilitation and law enforcement agencies
CDCR facilities and law enforcement agencies operate under their own workplace violence frameworks and sit outside SB 553.
SB 553 Coverage at a Glance
| Your Situation | Covered by SB 553? |
|---|---|
| 10+ employees on site, any industry | Yes |
| Fewer than 10 employees, public can walk in | Yes |
| Fewer than 10 employees, no public access, compliant IIPP in place | No |
| Fewer than 10 employees, no public access, but no compliant IIPP | Yes |
| Covered by the Cal/OSHA health care WVP standard (Title 8 §3342) | No |
| Remote employees working from a location of their choice | No (employer-controlled worksites only) |
| Multi-site operation, mix of sites above and below thresholds | Each site evaluated on its own |
| CDCR facility or law enforcement agency | No |
Common Edge Cases
The trigger sounds simple, but the way it lands at real facilities raises a few recurring questions.
- Multi-site operators. Each location is evaluated on its own facts. A company with one 50-employee plant and three two-person sales offices may need a plan for the plant and, depending on whether the sales offices are publicly accessible, plans for those as well. If the small sites are public-facing, they need to be in scope. If they are locked offices with no walk-in traffic, they may be exempt. For multi-site clients we usually build site-specific sections for each location rather than one document that tries to cover everything in the abstract. The detail in those per-site sections is what makes the plan defensible during a Cal/OSHA inspection.
- Part-time and seasonal workers. Cal/OSHA does not draw a line between full-time and part-time when counting employees. Anyone on your payroll who is on site counts toward the 10-person threshold while they are there.
- Contractors and temp workers. Independent contractors do not count toward your employee threshold, but SB 553 requires employers to coordinate with outside employers (staffing agencies, contractors) when their workers share the workplace. If you have temps on site through a staffing agency, you are still building the plan around that workforce.
- Recently grew past 10 employees. The obligation attaches as soon as you cross the threshold. The law does not provide a stated grace period for newly covered employers.
If You’re Covered, What Comes Next
The short version: every covered employer needs a written, site-specific WVPP, initial training for all employees, an annual plan review, annual refresher training, a violent incident log, and records kept for the required retention period. The plan must be tailored to the facility’s actual hazards, not pulled off a generic template and signed. If your operation has both a back warehouse and a customer-facing showroom, the hazard assessment for each is different, and the plan needs to reflect that. For public-facing operations specifically, see our piece on SB 553 for retail and public-facing California facilities.
If you are still untangling the basics of the law itself, our SB 553 explainer walks through what the bill did, who enforces it, and the timeline.
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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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