SB 553 does not treat your workplace violence prevention plan as a one-time document. The statute requires review at least annually, when a deficiency appears, and after any incident. Here is a checklist for doing the review the law actually describes.
Most California employers wrote their workplace violence prevention plan in a hurry. The law has been in effect since July 2024, and in a lot of companies the plan has not been opened since the week it was finished. That is a problem, because Labor Code 6401.9 does not treat the plan as a one-time document. It requires employers to review the plan's effectiveness and revise it as needed, at least once a year, and more often in two specific situations.
An annual review that consists of changing the date on the cover page is not a review. Here is a checklist for doing the review the statute actually describes.
The statute sets three occasions for review. The plan must be reviewed at least annually. It must also be reviewed when a deficiency is observed or becomes apparent, and after any workplace violence incident. The annual date is the one everyone tracks. The other two are the ones that get missed.
A deficiency can surface at any time: a door that was supposed to lock and does not, a reporting procedure employees turn out not to know about, a work area that changed layout without the plan catching up. If someone spots it in March, the review happens in March, not at the annual mark.
The post-incident review is separate from the incident investigation. The investigation asks what happened. The review asks what the incident shows about the plan: did reporting work, did the response match the plan, does anything need to change.
The statute requires the log to be reviewed during the periodic reviews of the plan, so the log is the natural starting point. Read it as a set, not as individual entries. Which violence types appear. Which locations and shifts. Whether threats are being recorded alongside physical incidents, because the statute counts threats whether or not anyone was injured.
Then look for what is missing. A year with zero entries in a customer-facing operation usually means underreporting, not a year without incidents. If employees are not reporting, that is a finding, and it belongs in the review. Our post on the violent incident log and recordkeeping covers what the log itself must contain.
The plan has to be specific to the hazards and corrective measures for each work area and operation. Buildings change. Tenants move, staffing shifts, hours extend, a lobby that used to be staffed is now open. A hazard walk during the review compares the plan against the workplace as it exists today, not the one described last year.
Walk each work area and ask whether the hazards the plan names are still the right ones and whether the corrective measures are in place and working. A corrective measure that exists on paper but failed in practice is a deficiency, and a deficiency triggers the review cycle on its own.
Employee involvement in the review is not a best practice; the statute requires procedures to obtain the active involvement of employees and authorized employee representatives in reviewing the plan. A review done entirely by one HR manager behind a closed door does not meet that requirement.
Make it concrete. Ask each crew or department where they feel exposed, whether they know how to report a threat, and whether anything they reported went nowhere. Write down who participated and what they said. That record is both your evidence of involvement and usually the most useful material in the whole review.
The review is the right moment to confirm training is current: new hires trained, annual training delivered, temporary and contract staff included. It is also where the review findings feed the next round of training, since training must address the risks employees can reasonably anticipate in their specific jobs. If the log and the hazard walk surfaced risks the training never mentions, the training needs to change, not just the plan document.
Every hazard the review confirms should end up attached to a corrective measure with an owner and a target date. The common failure is a review that lists findings and assigns nothing. Six months later the same findings reappear, and the employer has a written record showing it knew about a problem and did not act. Carry unfinished items forward explicitly from one review to the next until they are done.
Finally, document the review itself: the date, who took part, what was examined, what changed and what did not, and which version of the plan resulted. The plan must be in writing, available and easily accessible to employees at all times, so an updated plan also means replacing the old copies wherever employees actually look for it. If the updated version lives in a folder nobody can find, the update did not happen in any way that counts.
The annual review is the least expensive part of SB 553 compliance and the part most likely to be checked when something goes wrong. A review that is real, documented and acted on is most of what separates a working plan from a binder.
If you want a second set of eyes on your plan before the annual mark, we do this as part of our SB 553 compliance work. Book a consultation and we will walk through it with you.