CRA Members:

The CRA team is working on a letter to Cal/OSHA regarding the Agency's workplace violence advisory committee process and the Workplace Violence Prevention Plan, which was in SB 553 (Cortese - 2023), which we negotiated on with the Governor's office.

Please provide feedback to ryan@calretailers.com by July 7, 2025.

As a reminder, SB 553 put into statute a workplace violence regulation (Labor Code 6401.9) – but also required Cal/OSHA to undergo a rulemaking process to consider revisions to that standard, and to bring a draft to the Standards Board by Dec 31, 2025, and for the Standards Board to vote on this proposed set of changes by Dec 31, 2026. We are presently in that rulemaking process, as Cal/OSHA’s staff at the Division craft the text that they’ll submit to the Board later this year. Our time to weigh in is now, because once text is submitted to the Board, it will be very unlikely to change before their vote.

The content of this ongoing advisory process (and the draft circulated by Cal/OSHA which we’re now commenting on) is available HERE. The link to the most recent draft release (May 13^th, 2025) is available on that page as well.

A few pieces we want to emphasize:

• Please look at the langauge in (c)(10)(B) that states: The employer shall not retaliate against an employee involved in a lawful act of self-defense or defense of others. CRA belives this raises liability concerns for our members, so please provide feedback.

• We are focusing primarily on the fresh changes released in the May 13^th, 2025 draft – these are visible in Cal/OSHA’s text as bold and double underlined. Some of the preceding elements (contained in the July 2024 draft text) are commented on again in this letter, and some are not, based on our perception of what was achievable. If you see a big issue that is in this draft that we have not commented on, feel free to highlight and we'll work with the Chamber to consider adding and/or add into CRA's separate letter, which we are also working on. Again, to see Cal/OSHA’s proposed version which we’re commenting on, use the above link.

• Please note: We cannot go backward on items included in the legislation that are already in statute (see Labor Code 6401.9). This means that we cannot walk back certain fundamental pieces of this proposal because, even if we could convince division staff, they are statutorily not allowed to lighten precautions contained in the legislation.

The final letter is due to Cal/OSHA on July 14, 2025, so we need all comments from you by July 7.

As always, feel free to email or call if you have any questions. Thank you.