California WVPP Annual Review and Training Deadlines

As a reminder that California employers may face upcoming annual review and retraining obligations under the state’s workplace violence prevention requirements.

Labor Code section 6401.9 required covered employers to maintain an effective written Workplace Violence Prevention Plan (WVPP), review it at least annually as well as after certain triggering events, and provide annual workplace violence prevention training.

This law took effect on July 1, 2024, and employers that implemented a WVPP around that time are now approaching July 1, 2026, annual review and retraining cycle.

What Employers Need to Do

• Calendar annual WVPP review and retraining deadlines if the employer has not already done so, especially where the original implementation occurred in spring or early summer 2024.

• Conduct a substantive annual WVPP review, not a formality, including review of the violent incident log, prior incident investigations, employee-involvement procedures, and whether the plan is still effective in practice.

• Confirm the WVPP still functions as written, including whether the designated responsible person, reporting channels, emergency response procedures, investigation steps, communication practices, and employee participation mechanisms remain accurate and workable.

• Provide annual workplace violence training that covers job-specific workplace violence hazards, strategies to avoid physical harm, reporting procedures, and employees’ ability to ask interactive questions and receive answers from a knowledgeable person.

• Check recordkeeping readiness so the employer can produce required WVPP-related records if Cal/OSHA inspects, including logs, incident investigations, hazard-correction records, and training records.

Overview

• At a minimum, the annual review should have examined the violent incident log, employee-involvement procedures, and the effectiveness of the plan as a whole.

• Annual training also remained mandatory, including training on workplace-violence hazards specific to employees’ jobs, strategies to avoid physical harm, and reporting procedures.

• Cal/OSHA’s general-industry guidance page remained the better source for current compliance obligations, while the advisory-meetings page tracked the proposed future regulation.

• On April 23, 2026, Cal/OSHA posted a revised draft standard for proposed Title 8, section 3343 and invited comments by June 1, 2026, but that draft did not replace the live statutory requirements under section 6401.9.

Why This Matters

For employers, this reminder mattered because California’s workplace violence prevention requirements were never a one-time rollout. The statute required ongoing review, revision, and retraining, meaning employers that implemented a WVPP in 2024 needed to revisit both their written plan and their training calendar as annual deadlines approached.

This update is particularly important given the revised Cal/OSHA draft, which could create confusion for employers. While employers can review the draft to anticipate the direction of future rulemaking, current compliance should continue to be measured against Labor Code section 6401.9 and Cal/OSHA’s existing guidance, not a discussion draft.

Key Risks for Employers

• Treating the annual WVPP review as a check-the-box exercise instead of a substantive review of logs, incident history, employee involvement, and plan effectiveness.

• Missing annual workplace violence training deadlines or failing to cover job-specific hazards and required reporting topics.

• Failing to revise the WVPP after an incident or after a deficiency became apparent, which is a separate trigger for review beyond the annual cycle.

• Relying on draft regulatory language instead of current law when assessing present obligations under California’s workplace violence requirements.

Additional Information

Cal/OSHA’s current general-industry guidance explains the live requirements under Labor Code section 6401.9, including plan elements, hazard assessment, response procedures, training, and recordkeeping. It also notes that records of hazard identification, violent incident logs, and incident investigations must generally be retained for five years, while training records must be kept for at least one year.

The advisory meetings page separately tracks draft versions of the proposed permanent regulation, including the April 23, 2026, revised discussion draft and earlier advisory materials from 2024 and 2025.

Source References

• DIR – Workplace Violence Prevention in General Industry
• DIR – Cal/OSHA Workplace Violence Prevention for General Industry (Non-Health Care Settings)
• Cal/OSHA Workplace Violence Prevention Regulation Advances Post-Comment Period (VensureHR)

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