Multi-Employer WVPP Coordination for Staffing Agencies and Shared Workplaces

How staffing agencies, multi-tenant buildings, and shared workplaces coordinate SB 553 compliance across multiple employers.

Quick Answer

When multiple employers share a workplace — staffing agencies, multi-tenant buildings, contractors on premises — SB 553 requires documented coordination of workplace violence prevention efforts. The host employer and staffing agency must both have WVPPs, share hazard information, coordinate emergency response, and ensure all workers at the site are trained regardless of which company employs them.

Host Employer vs. Staffing Agency Responsibilities

The host employer (where work is performed) is responsible for site-specific hazard identification, emergency response procedures for the physical location, communication of site-specific hazards to all workers, and maintaining the VIL for the location. The staffing agency is responsible for ensuring their workers receive WVPP training, maintaining employment-related records, communicating with the host employer about any hazards their workers identify, and including multi-employer coordination in their own WVPP.

Multi-Tenant Building Coordination

In multi-tenant buildings, each employer needs their own WVPP covering their space, but coordination is required for shared areas (lobbies, parking, restrooms, elevators). Building management should be involved in emergency response coordination. Each tenant employer should document in Section 3 of their WVPP how they coordinate with building management and neighboring tenants.

Documentation Requirements

Multi-employer coordination must be documented in writing. Include the names of coordinating employers, the specific coordination procedures, how hazard information is shared between employers, joint emergency response protocols, who is responsible for shared areas, and how training ensures all workers understand the full site plan. Cal/OSHA inspectors will check that coordination is substantive, not just a boilerplate statement.

Summary

When multiple employers share a workplace — staffing agencies, multi-tenant buildings, contractors on premises — SB 553 requires documented coordination of workplace violence prevention efforts. The host employer and staffing agency must both have WVPPs, share hazard information, coordinate emergency response, and ensure all workers at the site are trained regardless of which company employs them.

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Frequently Asked Questions

Which employer is cited if a staffing agency worker is involved in a workplace violence incident?

Both employers can be cited. The host employer can be cited for site-specific hazards and emergency response failures. The staffing agency can be cited for training failures and lack of coordination. Cal/OSHA evaluates each employer's responsibilities separately.

Do contractors need to be covered by my WVPP?

Independent contractors are not your employees, but if they work at your location, your WVPP should address how contractor presence is managed, how contractors are informed of workplace violence hazards and emergency procedures, and how incidents involving contractors are handled and documented.

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