Active shooter events are unpredictable and filled with confusion. They evolve very quickly. With active shooter incidents increasing at alarming rates, it is time for employers to prepare. Although it is impossible to prevent one of these events, prevention and preparedness policies and procedures will protect the workplace and minimize the loss of life. In addition, employees need to react rationally despite the chaos. Continuous employee awareness training along with active shooter training is key to an overall successful plan. Lexology, Fisher Phillips, focuses on the main points of interest all hotel establishments should develop into their programs.
An armed gunman just entered the lobby of your hotel. He announces he is taking your front desk employees and nearby guests as hostages. An image on a security camera reveals that the gunman is a former bellman who was fired last week. What is the first thing you and your management team do?
- Does someone call the police?
- Do you run? Fight? Hide?
- Is there a security guard? What does he or she do?
- What do your employees do?
- Do you know the precise, step-by-step actions that you would take?
- Do you have a system in place to minimize the likelihood of a catastrophe?
Workplace shootings continue to occur at an alarming rate, yet many employers have not addressed these concerns in their safety training programs.
Hospitality Businesses Could Be Easy Targets
Hotels, restaurants, and other workplaces in the hospitality industry present unique security challenges because they are – and by their nature must be – easily accessible by the public. A shooter likely will not have to knock down a locked door, struggle with a security guard, or otherwise breach a security threshold to obtain access to your employees and guests. Now is the time to address these issues.
No perfect response is currently available, but you should begin taking steps to avoid violent situations and minimize the risk to your property. Rather than take a reactive approach to workplace violence, you should consider acting proactively in an effort to avoid these incidents. We recommend implementing a pre-mortem analysis of “what could go wrong” instead of waiting for a “what-went-wrong” review after the fact.
Consider adopting some of the following measures to protect your business from disgruntled former or current employees, irate or unstable guests, and others.
1. Educate And Train Your Employees
Experts tell us that there are two types of training: preparing for what could happen, and responding once something bad has already happened. Most employers have done neither. There is much talk about workplace violence, but have you assessed your operation to determine where risks are present?
Do you have employees making deliveries or going to guests’ rooms unaccompanied? Have you had entrances and exits professionally assessed for security issues? Do your management and HR teams know when they should be concerned about potentially dangerous employee behavior and how to address it? Are your employees trained on how to deal with violence directed at or involving your guests or patrons? Given the rise of workplace violence in recent years, now is the time to address these issues.
At a minimum, any training program should require each employee to view the Department of Homeland Security’s “Run, Hide, Fight” video about surviving an active shooter situation. In addition, you should evaluate your individual workplace for exposure and devise specific solutions as you would for any potential safety hazard.
We recommend you develop specific training based on your work setting, location, security layout, as well as general situational awareness. Analyze situations involving employee travel, working alone, or interacting with guests in a remote or unsupervised location. Employees who enter guest rooms should be specifically trained on how to handle threatening situations, including disruptive or unstable guests, and how they should respond. Consider professional instruction by an active shooter expert who can provide on-site, simulation-based training.
2. Review And Adjust Policies On Bullying And Unprofessional Behavior
Unfortunately, many active shooters are either current or former employees who have developed a grudge against a supervisor or coworker. Review and adjust your policies about unprofessional behavior, bullying, threats, and workplace violence. Educate your employees to recognize unacceptable behavior, and train your supervisors to address it before it advances to actual violence. Adopt a zero-tolerance policy for violent behavior.
Have a process in place to monitor behavior of terminated employees from the time they are told the news until they leave the worksite. Did they make threats? Do they have a history of bullying or unprofessional behavior? How will you respond if they do?
3. Pay Attention If An Employee Is Served With Legal Process
If a sheriff arrives at the workplace to serve legal process on an employee, watch for red flags. A disgruntled employee may want to harm coworkers after receiving legal process, even if the legal trouble has no relationship to the workplace. If the employee becomes irate, consider trying to talk individually and calm the employee. Alert your security team if the employee makes threats. Hopefully a manager can avoid escalation, but you may have to ask security to escort the employee to an isolated area where he or she can meet with management.
You may want to consider offering the employee counseling or access to an Employee Assistance Program. Offer administrative leave if a cooling-off period is appropriate. If the employee is especially antagonistic or you have heard reports of possible violent behavior, you may have to involve outside security or law enforcement from the outset.
If the employee storms off after accepting service and you do not have an opportunity to meet before they depart, ensure that any on-site security is aware of the situation. If you receive any threats, call the police immediately. Don’t wait for the irate employee to return.
If necessary, you should consider retaining a private armed security service. Unfortunately, your local law enforcement department is often limited in how it can respond to threats and bad behavior. The prudent course may be to retain private security for a period of time until things have cooled down.
4. Request Information From Employees Who Seek Protective Orders
You should thoughtfully consider whether you should encourage employees to tell you when they are involved in a dispute where violence may be a risk. This is especially true when the employee has requested a restraining order.
If an employee has requested a protective order, ask for a copy of the order and a photograph of the recipient of the legal process. Provide the photo to any on-site security, reception employees, and management. If the individual arrives at your workplace for any reason, have a designated company representative approach the individual in a calm manner, isolate the individual in a designated area, and request that security respond to the situation.
Don’t offer to provide security to employees when off duty. This may establish a legal duty to protect the employee where none otherwise exists. Instead, you should encourage the employee to call the police if they feel threatened while off duty.
In any of these situations, you should obtain guidance from law enforcement and security professionals who can tailor their advice to your specific workplace. In order to have such advice available, you should establish relationships with professional security advisors now.
5. Recognize Your Responsibility
Before you ask or require employees to alert you to requests for restraining orders or concerns about domestic violence, remember that once you ask for this information, you may be taking on a duty to respond to this knowledge. A Missouri court recently found an employer liable because it was on notice of threats from an employee’s ex-boyfriend and offered to form ad hoc groups of employees to walk her to her car instead of using professional security.
An incompetent or incomplete response to workplace violence concerns or to an active shooter may be used as evidence that you failed to meet your duty.
6. Revise Your OSHA-Required Emergency Action Plan (EAP)
If you have more than 10 employees, you must develop a written Emergency Action Plan (EAP) when another OSHA Standard triggers the requirement. In addition, if fire extinguishers are available in your workplace, and if anyone will be evacuating during a fire or other emergency, you must have an EAP in place.
At a minimum, the EAP must include the following elements: the means of reporting fires and other emergencies; evacuation procedures and emergency escape route assignments; procedures for employees who must remain to perform critical operations before they evacuate; accounting for all employees after an emergency evacuation has been completed; rescue and medical duties for designated employees; and names or job titles of persons who can be contacted.
Now is the time to ensure your EAP is broad enough to cover management of an active shooter situation or respond to an irate worker served with legal process. Do employees know what to do if such an emergency were to arise? Who calls the police? Where do the employees go? Do you have an on-site security presence? How do they respond? Have you rehearsed your response to such a situation?
While you cannot accurately predict who and what may present a risk of workplace violence, perhaps you can anticipate and prevent most incidents. Taking the steps above is a great start to achieving that goal.