California · SB 553 · Labor Code 6401.9

SB 553 two years on: what churches and nonprofits should have on file now

About a 5-minute read

Since 1 July 2024, most California employers, including churches, ministries and nonprofits with paid staff, have needed a written workplace violence prevention plan. The requirement comes from Senate Bill 553 and sits in California Labor Code section 6401.9. Many employers put a plan in place before that first deadline. More than two years later, the question has changed from "do we have a plan?" to "is the plan still current, and can we show it?"

This article sets out what the law asks an employer to keep on file today, the yearly tasks that are easy to miss, and what is expected to change in 2027.

Four things to have on file

1.
A written plan for each worksite.
The plan must be specific to the location. It names the people responsible, describes the hazards and controls for each work area, and sets out how employees report concerns and what happens in an emergency. The plan can be a separate document or a stand-alone section of the employer's Injury and Illness Prevention Program.
2.
A violent incident log.
Every workplace violence incident is recorded, without personal details that could identify the people involved. The log can be empty, but it should exist and be ready to use.
3.
A training record.
Employees are trained when the plan is first put in place and once a year after that, with extra training when a new hazard is found or the plan changes.
4.
A record of the annual review.
The plan is reviewed at least once a year, when a weakness becomes apparent, and after any workplace violence incident. Employees take part in the review.

The yearly tasks that are easy to miss

A plan written in mid-2024 and not touched since has missed at least one annual review and at least one round of annual training. These are the items most often left behind:

Names and roles. Staff turnover is the most common reason a plan goes out of date. Check that the people named as responsible still hold those roles.
Reporting channels. Test the phone number or email address in the plan and confirm someone receives the message.
Training content. Training should match the current plan and the current hazards, not the version from 2024.
Hazard findings. Repeat the site inspection and note changes in hours, staffing, cash handling or public access since the last review.
Records. Hazard records, incident logs and investigation records are kept for at least five years. Training records are kept for at least one year. Employees can ask for copies, and the employer has 15 calendar days to provide them.

What this looks like in a church or nonprofit

Open doors. Services, events and drop-in programs mean the public has access. That matters for the small-employer exemption: a location with fewer than 10 employees on site is exempt only if the public does not have access.
Clients and visitors in distress. Counselling, food programs, shelters and outreach bring staff into contact with people in crisis. These contacts belong in the hazard assessment, with the steps staff take when a situation escalates.
Shared buildings. Preschools, tenant congregations and community groups often share space. The plan should say how the organisations coordinate on reporting and emergencies.
Staff and volunteers. The law covers employees. Many organisations also tell volunteers what to do in an incident, because volunteers are often present when something happens.
Small teams, named roles. In a small organisation one person may hold several roles. The plan should still name who is responsible, and be updated when that person changes.

Who is exempt

The law does not apply to some workplaces, including health care settings covered by Cal/OSHA's separate health care standard, employees teleworking from a location they choose, and places where fewer than 10 employees work at any one time, the public has no access, and the employer maintains an Injury and Illness Prevention Program. Each worksite is judged on its own. Cal/OSHA can still require a plan where it finds workplace violence hazards.

What is expected to change in 2027

The law requires California's Occupational Safety and Health Standards Board to adopt a general industry workplace violence standard by 31 December 2026. Cal/OSHA has published draft text, and the draft has been revised more than once during 2026. The published drafts add detail in areas such as the examples of hazards employers should look for, when hazard inspections must take place, and how long records are kept. The final text has not been adopted, so the details may still change.

Separately, new workplace violence legislation passed in 2026 takes effect in 2027, including changes to workplace violence restraining orders.

None of this pauses the current requirement. The plan, log, training and annual review apply now. The annual review is the natural point to fold in any changes once the new standard is final.

A practical next step

Pull out the current plan and check it against the four items above. If the review, the training or the names are out of date, those are the first things to fix.

Cal/OSHA publishes a free model plan and guidance at dir.ca.gov/dosh/workplace-violence.html.

This article is general information about California's requirement, not legal advice. It may be republished in full or in part, with or without edits, in newsletters and member communications.

Courtesy of ClarAudit, which makes a site-specific California workplace violence prevention plan generator: claraudit.com/california-workplace-violence-prevention-plan