Early in my clinical training, I learned to read a room before I read a chart. You learn which patients are frightened, which families are about to come apart, and which moments are one wrong word away from becoming physical. What I didn’t learn, what almost none of us were taught, was that being hurt at work would come to feel like part of the job.

That normalization is the real danger, and the data now make it impossible to look away. Health care and social assistance workers make up roughly 10 percent of the U.S. workforce but absorb close to half of all nonfatal workplace-violence injuries serious enough to require time away from work, at a rate more than three times the all-industry average, according to Bureau of Labor Statistics and National Institute for Occupational Safety and Health (NIOSH) figures. Federal agencies are blunt that the dominant threat isn’t an armed intruder; it’s “Type II” violence from patients and visitors, in the ordinary course of care.

For years we were told a federal fix was coming. The Occupational Safety and Health Administration (OSHA) has been developing a health care-specific workplace-violence standard since 2016 and convened a small-business review panel in 2023. Then, on its 2025 regulatory agenda, the agency moved the rule to “long-term action,” with a proposed-rule date listed as “to be determined.” If you run a hospital or a unit, it would be easy to exhale.

I’d argue the opposite. The absence of one tidy federal rule doesn’t mean the absence of a duty. It means the duty is already scattered across instruments most hospitals are already accountable to:

• OSHA: The agency still enforces workplace violence as a recognized hazard under the General Duty Clause, Section 5(a)(1), supported by its longstanding Publication 3148 guidance. Hospitals have been cited for failing to address foreseeable patient and visitor violence.
• The Joint Commission: Its workplace-violence prevention standards have been in force since January 1, 2022, requiring a designated program leader, an annual worksite analysis with follow-up, incident tracking and trending, and training, now organized under its National Performance Goal on preventing workplace violence. Surveyors have written hundreds of findings against them.
• CMS: Conditions of Participation require care in a safe setting, an expectation increasingly read to include reasonable protection from foreseeable harm.
• States: They are moving in the federal vacuum. California set the template in 2017; Texas followed in 2024 with Health and Safety Code Chapter 331, requiring covered facilities to build a committee, a written plan, training, confidential reporting, post-incident response, and an annual evaluation reported to the board.

Different language, same architecture. A program built to the strictest applicable standard satisfies the rest.

Here’s the part that should move this from the safety committee to the boardroom: Workplace violence is a workforce problem. The nursing literature consistently links exposure to patient and visitor aggression with emotional exhaustion, burnout, and intent to leave. In a market where replacing a single bedside nurse runs well into the tens of thousands of dollars, a unit known for unaddressed violence doesn’t just generate incident reports. It generates resignations, agency premiums, and recruiting costs. Protecting staff and retaining staff are the same project.

So what does a defensible program actually look like? After years on both the clinical and administrative sides, the elements that hold up, to a surveyor and, after a bad night, to a plaintiff’s attorney, are consistent:

• Named accountability: A committee or program leader with clinical, security, and frontline voices, and minutes that prove it meets and acts.
• A facility-specific plan: Not a borrowed template, but one that names your real units, populations, and risks.
• An annual worksite analysis with follow-up to closure: Tracking each finding to an owner and a date.
• Training matched to real exposure: De-escalation and reporting at orientation, annually, and on change, reconciled against the full census, including agency and per-diem staff.
• Confidential, anti-retaliation reporting: With tracking and trending that visibly reaches leadership.
• A documented post-incident response and an annual evaluation reported to the governing body: The step facilities forget, and the one that proves the program is alive.

None of this requires a federal rule to start. It requires deciding that the safety of the people who deliver care is a measurable priority, and then building a survey-defensible workplace violence prevention program you can show, not just describe.

We taught ourselves to read the room. It’s time we documented what we do about what we see.

Amanpreet Mann is a physician.