Workplace violence plan for NEMT drivers and dispatchers: hazards, check-ins, and reporting

This template is a written workplace violence prevention plan for a NEMT company, built around the people most exposed: the driver who is by themselves with a rider in crisis, and the dispatcher fielding calls from angry members. Its structure comes from the five parts of OSHA 3148, the agency’s 2016 violence guidelines for health care and social service work, plus the items California’s law requires. How a driver calms a tense ride and when a trip can be stopped are in the guide to difficult or unsafe riders, and the weapons rules brokers write into contracts are in guns in NEMT vans. This page is the plan that ties them together.

Who needs a written plan

Federal law does not require one from most NEMT companies, while California’s law reaches most companies there.

• Federal OSHA. There is no workplace violence standard. Under the OSH Act’s general duty clause (29 U.S.C. 654(a)(1)), every employer must keep the workplace free of recognized hazards likely to cause death or serious physical harm. OSHA’s inspection directive for violence (CPL 02-01-058, effective January 10, 2017) says an employer may be cited under it for failing to reduce or eliminate a recognized violence hazard, and it names taxi driving among the settings with a high incidence. OSHA’s own page lists taxi and ride share drivers, health care workers, and people who work alone among those at higher risk, and recommends a zero-tolerance policy that covers workers, clients, visitors, and contractors.
• A federal rule for health care and social assistance. OSHA opened this rulemaking with a request for information in December 2016 and completed its small business review on May 1, 2023. On the 2026 regulatory agenda it sits under long-term actions, and the proposed rule date reads “to be determined.”
• California. Labor Code 6401.9, in force since July 1, 2024, requires most employers to establish, implement, and maintain a written plan, keep a violent incident log, and give initial training followed by yearly refreshers. Workplaces covered by the health care violence standard (8 CCR 3342) follow that rule instead.
• Brokers. Contracts add their own rules on weapons, incident reports, and response times. Fold them into sections 5 and 7 so drivers learn one set of steps.

States that run their own OSHA programs can set stricter rules, and the OSHA for NEMT companies guide explains how state plans work.

How to fill in this plan

1. Start with your own incidents. OSHA 3148 builds the hazard review on records first: workers’ compensation and insurance claims, the OSHA 300 log if you keep one, incident and near-miss logs, and police reports. Pull every incident report from the last two years before you write section 4.
2. Ask the drivers. OSHA’s guidelines put worker participation next to management commitment as the first element, and California requires a written procedure for involving employees. A safety meeting where drivers name the addresses and times they dread is the fastest hazard review you will get.
3. Name people, not departments. Every bracket that says [name] needs a person with a phone number.
4. Keep it to what you will actually do. A check-in rule nobody follows protects no one, and it shows the hazard was known.

The template

[Company name] workplace violence prevention plan

Effective date: [date] | Plan administrator: [name, phone] | Next review: [date]

1. Policy statement

Violence, threats, and harassment are not tolerated at [Company name], whoever they come from and whoever they target: riders, family members, facility staff, coworkers, or strangers. This applies in our vehicles, at pickup and drop-off locations, at the office, and on the phone. No one will face retaliation for reporting a threat, an assault, or a near miss in good faith.

Signed: [owner name, title] | Date: [date]

2. Who does what

• Plan administrator: [name] keeps this plan, runs the hazard reviews, and investigates incidents.
• Dispatch lead: [name] runs driver check-ins and answers emergency calls from drivers on every shift.
• Employee involvement: drivers and dispatchers review hazards and this plan at [the quarterly safety meeting], and anyone can suggest a change to [name] at any time.
• Other employers: [name] tells the brokers and facilities we serve about hazards at their sites and agrees with them on who handles what.

3. What counts as workplace violence

Any act of violence or threat of violence at work, including the threat or use of force that injures an employee or is likely to cause injury, trauma, or stress, and any threat or use of a weapon or an object used as one. Examples for our work:

• A stranger tries to rob a driver at a pickup.
• A rider or family member threatens, grabs, spits at, or hits a driver or attendant.
• A current or former employee threatens a coworker.
• An employee’s partner or ex-partner shows up at the office or a pickup.

4. Finding hazards

Reviews happen when this plan starts, every [6 months], after every incident, and whenever someone reports a new hazard. Each review looks at:

• Incident reports, complaints, and injury records since the last review.
• Riders or addresses with a history of threats or violence.
• Pickups late at night or early in the morning, in high-crime areas, or at locations with no safe place to wait.
• Trips where a driver handles cash.
• What drivers and dispatchers report at the safety meeting.

5. Controls

• Check-ins. Dispatch always knows where each driver is. Drivers call or message dispatch at each pickup, and again at once if a rider wants to go somewhere other than the booked drop-off. If a driver does not check in within [15] minutes of an expected time, dispatch calls, then [steps, ending in a 911 call to the last known location].
• A phone in every vehicle. Every driver starts the shift with a fully charged phone [and a mounted charger in the van]. Saying [agreed code phrase] on any call tells dispatch to phone 911 for the driver.
• Vehicle set-up. Driver-controlled door and window locks, the dome light on during boarding and drop-off, and [a partition / a dash camera / none] where the van allows.
• Flagged riders. When a rider has threatened or assaulted staff, dispatch records a safety note on the rider’s profile, listing the triggers and what helps, tells every driver assigned to that rider, and sends [a second staff member / a different vehicle type] when [name] decides it is needed. The note holds only what drivers need for safety.
• Declining unsafe pickups. A driver may decline to begin a trip, or wait in a locked van at a distance, when a situation is clearly hazardous. Dispatch hears from the driver before the van pulls away, and dispatch tells the broker. A rider is never left on the roadside once a trip has begun.
• Cash. [Private-pay riders pay by card only / Drivers carry no more than $(amount) and turn in cash during the shift]. In a robbery, hand over the money and do not resist.
• Weapons. [Your weapons rule, matching your broker contracts and state law.]

6. During an incident

1. Get to safety first: [pull over in a lit public place / leave the residence / lock the doors].
2. Call 911 for any weapon, assault, or threat of immediate harm.
3. Call dispatch at [number] once you are out of danger.
4. Do not restrain the rider or attempt to disarm anyone.
5. Follow the de-escalation and ride-stop steps from driver training.

7. Reporting

• Every threat, assault, weapon sighting, and near miss is reported to [name] the same shift, by phone first and on the incident report by [end of shift].
• [Name] notifies each broker within the time its contract sets, and the facility where it happened when that helps protect the next crew.
• Reports can also go to [anonymous option]. Retaliation against anyone who reports is grounds for discipline.

8. After an incident

• The injured employee gets first aid and medical care at no cost, and a ride to care when needed.
• [Company name] offers free counseling through [employee assistance program or provider] to anyone who was hurt or saw it happen.
• [Name] explains how to request police help or file charges, and helps the employee do it.
• [Name] files the workers’ compensation paperwork and phones OSHA about a fatality within 8 hours, or about an inpatient hospitalization, amputation, or eye loss within 24 hours. Qualifying injuries go on the OSHA 300 log if we keep one.
• [Name] investigates within [3] working days to find the root cause, not just what happened, and updates section 5.

9. Training

Every employee is trained before the first shift, then yearly, plus extra sessions whenever the plan changes or a new hazard turns up. Training covers what the plan says and where the copy is kept, reporting steps, check-ins and the code phrase, recognizing escalation and calming a rider, what to do in a robbery, and where to get help afterward.

10. Violent incident log

Every incident goes on the log, even with no injury: date, time, and location; the type of violence; what happened; who committed it (a rider, a stranger, a coworker, or a person with a personal relationship to the employee), without names; the circumstances; whether a weapon, physical attack, or threat was involved; the consequences, including police involvement; what was done to protect employees; and who completed the entry, with their title and the date.

11. Review

[Name] goes over this plan once a year, after each incident, and any time a weakness shows up, then records the changes here.

12. Acknowledgment

I read the [Company name] workplace violence prevention plan (version [date]) and had the chance to ask questions.

What California adds

California’s law turns several of the items above from good practice into requirements, so a California company should check its plan against them:

• Plan content. The names or titles of the people responsible, how employees take part, how you coordinate with other employers, how you accept reports and prevent retaliation, emergency response, hazard reviews (at the start, on a schedule, after incidents, and whenever a new risk comes to light), timely fixes, post-incident response and investigation, and review of the plan.
• Plan form. A written document that applies around the clock and fits the hazards of each operation, open to workers, worker representatives, and the agency whenever they ask. It may stand alone or form its own section within the company’s Injury and Illness Prevention Program.
• The log. Section 10 lists the fields Cal/OSHA’s employer fact sheet gives. Personal identifying information about anyone involved stays out of it.
• Records. Hazard reviews, the log, and investigations are kept 5 years and training records 1 year, and a worker who asks for copies receives them at no charge within 15 calendar days of asking.
• Injuries. Notice of workers’ compensation eligibility within one working day of an incident, and serious injuries reported to Cal/OSHA under 8 CCR 342.

Cal/OSHA publishes a model plan for general industry. Its license allows nonprofit and educational use only, so read it as a checklist rather than copying it into a company document. A permanent Cal/OSHA standard is still being drafted: the September 2026 draft of new section 3343 goes to an in-person advisory meeting in Oakland on October 27, 2026.

Keeping track of drivers on the road

The check-in rule in section 5 is easier to keep when dispatch can see every van. In HealthRide, every vehicle appears live on one map with its ETAs, and a late trip is flagged, so a van stopped somewhere it should not be is easy to spot. A team chat announcement reaches every driver together and shows who has read it, which helps when a flagged address needs a warning before the next pickup. See the live map and team chat.