California hospitals will soon face a significant new workplace violence prevention obligation. Cal/OSHA has proposed amendments to its Violence Prevention in Health Care standard (8 CCR § 3342) that would require most general acute care hospitals, acute psychiatric hospitals, and special hospitals to develop and implement a written weapons detection screening policy. The policy would require hospitals to screen a person’s body and personal items for weapons at all unrestricted entrances.
Unrestricted Entrance Defined
An unrestricted entrance would mean “an entrance that is open to any individual without locks or access-control systems,” including, for example, a hospital’s main public entrance, the entrance to the hospital’s emergency department, and the hospital’s labor and delivery entrance if it is separately accessible to the public.
Under this definition, most hospitals would have numerous entrances that would each require weapons-detection screening equipment and personnel to operate it. As a result, employers should be prepared for the significant costs associated with installing screening devices and staffing each screened entrance.
Screening Procedures
All individuals entering through an unrestricted entrance would need to be screened for weapons or other objects capable of inflicting death or serious bodily injury.
Protocols would need to be developed for alternative search and screening procedures for patients, family members, or visitors who refuse to undergo weapons-detection-device screening.
Recognizing operational realities, the proposal allows hospitals to exempt current hospital employees and hospital health care providers from screening requirements if they enter the facility wearing a photo identification badge that includes their name and title.
The exemption appears to leave out contract workers who would not be considered hospital health care providers, such as cafeteria workers, security personnel, maintenance workers, and janitorial staff. If these workers are required to stand in security lines on a regular basis, employers would most likely be required to pay them for that time or face potentially significant wage-and-hour liability.
The phrase “other objects capable of inflicting death or serious bodily injury” raises concerns because of its breadth and ambiguity. Countless ordinary items could arguably fall within this definition, depending on how they are used. For example, even an ordinary pen could be used to inflict serious bodily injury. This lack of clarity may make it difficult for hospitals to determine which items should be permitted and which should be prohibited.
This vagueness could also cause Cal/OSHA enforcement to vary depending on how an inspector interprets the phrase. As a result, employers may be uncertain about which objects should be allowed and which should be prohibited. The screening process in general and especially coupled with an extensive policy governing prohibited objects, could cause significant delays in entering a hospital and potentially delay care.
Response Procedures
Hospitals would also need to develop protocols addressing how they will respond when a dangerous weapon is detected. If an individual triggers a weapons-detection device, the individual must be permitted to leave the facility with the object and return without it, and may not be denied entry solely because they previously possessed the detected object.
The proposed amendments do not appear to take into consideration emergency situations, for example, where an injured individual is carrying a weapon but is physically unable to leave the facility and return without it due to an injury or illnesses, or were doing so would delay the provision of immediate life-saving care.
Weapon Screening Devices
Screening devices may include, for example, walk-through metal detectors, handheld metal detector wands, x-ray screening systems, artificial-intelligence-assisted weapons-detection systems, magnetic anomaly detection systems, and other technologies that can detect metallic and nonmetallic weapons or other objects.
However, handheld metal detector wands cannot be the sole screening equipment used except in limited circumstances.
Additional Staffing Obligations
The proposed amendments would also create substantial staffing obligations.
Hospitals would be required to assign trained personnel, other than healthcare providers, to operate the screening equipment and implement the policy whenever unrestricted entrances are open to the public. Most facilities will have numerous unrestricted entrances that would need to be staffed up to 24 hours per day.
For many facilities, this would mean additional hiring, expanded security contracts, or reassignment of existing personnel. Trained personnel would also need to be available to cover workers assigned to weapons-screening duties so that those employees can take California-mandated meal and rest breaks. Otherwise, the employer could be required to pay up to two hours of premium pay per day.
Furthermore, not only are gaps in coverage prohibited by the proposed amendments, but gaps in coverage could also delay care if an individual is unable to enter a facility because no trained screening personnel are available at the entrance.
Extensive Training Requirements
The proposal contains a remarkably detailed and extensive training program.
Personnel responsible for implementing the weapons-screening policy would be required to receive at least eight hours of training before conducting any weapon screening duties, including searching personal belongings and confiscating weapons.
The proposed required training consists of 17 topics and numerous subtopics.
The topics range from weapons-detection principles and recognition of improvised weapons to the proper to implicit bias and disability awareness. Practical exercises involving hands-on operation of screening equipment, scenario-based exercises, and role-playing would also be required.
Additional training would be required annually and whenever new equipment is introduced, new work practices are implemented, or previously unidentified screening hazards arise.
Employers should be aware that the proposed training requirements are substantial and will require a significant investment of time and resources to ensure compliance.
Notice Requirement
The proposed regulation would also require hospitals to post highly visible notices near screened entrances informing the public that the hospital conducts weapons screening and that no individual will be denied medical care.
What’s Next
Cal/OSHA invites public comment on these proposed revisions by October 12, 2026. Comments can be submitted to Cal/OSHA’s Research and Standards Unit by email at rs@dir.ca.gov.
For more information on Cal/OSHA’s proposed revisions or on the current healthcare workplace violence prevention regulation, please contact Rachel Conn or Andrea Chavez.
