California Bill Links Security Guard Training to Workplace Violence Prevention

00:00

24:53

Quick Hits

• California SB 1203 would increase required initial security guard training from thirty-two hours to forty-two hours and require sixty hours of annual training.
• The bill would require eight hours of initial and annual training to focus on practicing de-escalation skills through in-person, interactive training.
• Employers would be required to pay for required training and compensate security guards for time spent completing the training.
• The proposed requirements may also intersect with employers’ obligations to identify, evaluate, and correct workplace violence hazards and maintain an effective workplace violence prevention plan.
• SB 1203 would increase certain administrative penalties to as much as $10,000 per violation and require the IWC to develop a wage order specific to the security services industry.

Senate Bill (SB) 1203, the “Stand for Security: Security Industry Standards and Public Safety Act,” would increase initial and annual training requirements for private security guards, require in-person de-escalation training, increase potential penalties for violations, and require the Industrial Welfare Commission (IWC) to develop an industry-specific wage order.

The bill, authored by Senator Lola Smallwood-Cuevas, remains pending in the California Legislature and has been amended several times during the legislative process.

Expanded Training and De-Escalation Requirements

Security guards in California are currently required to complete thirty-two hours of security officer skills training within six months of their initial registration, including sixteen hours within the first thirty days.

Beginning July 1, 2028, SB 1203 would increase that requirement to forty-two hours, with eighteen hours required within the first thirty days. The bill would also require the training to be conducted through traditional in-person classroom instruction rather than online instruction.

A significant focus of the legislation is de-escalation. Eight hours of the initial training would be dedicated to practicing de-escalation skills using in-person role-playing and interactive training methods. The training would be required to use evidence-based and trauma-informed techniques.

SB 1203 would also double the annual training requirement for security guards from eight to sixteen hours. At least eight of those hours would similarly be dedicated to practicing de-escalation skills.

The increased training requirements could create additional costs and logistical considerations for security employers. The bill would expressly require employers to ensure the required training occurs and to compensate employees for their time spent completing the training. Employers would also generally be responsible for the cost of the required training.

The Workplace Violence Prevention Connection

The proposed legislation also intersects with California employers’ existing workplace violence prevention obligations.

Labor Code section 6401.9 requires most California employers to establish, implement, and maintain an effective workplace violence prevention plan (WVPP). Among other requirements, employers must have procedures to identify, evaluate, and correct workplace violence hazards and procedures for responding to actual or potential workplace violence emergencies. Those emergency procedures must address how employees can obtain assistance from staff assigned to respond to workplace violence emergencies, security personnel, if any, and law enforcement.

For some employers, depending on the workplace violence hazards present, security personnel may play an important role in the overall workplace violence prevention strategy. For employers that rely on security officers as a control measure or as part of their response to workplace violence incidents, SB 1203’s emphasis on de-escalation and scenario-based training may warrant consideration as part of the employer’s broader WVPP.

Labor Code section 6401.9 also requires employers to coordinate implementation of their WVPP with other employers, when applicable. Accordingly, employers that contract with third-party security providers may want to consider how their security contractor’s policies, training, incident response procedures, and responsibilities fit within the employer’s own WVPP.

If SB 1203 is enacted, employers may want to consider the role assigned to security personnel in their WVPPs and confirm that their written plans, employee training, emergency response procedures, and security protocols are appropriately coordinated.

Increased Penalties and Potential Wage Requirements

SB 1203 would also increase potential penalties for violations of California’s private security laws. Among other changes, the bill would increase the maximum administrative fine for certain violations from $2,500 to $10,000 per violation.

In addition to its training provisions, SB 1203 could eventually result in new wage requirements for the security industry. The bill would require the IWC to convene by July 1, 2027, to examine wages, hours, and working conditions in the “property services industry,” which includes covered security employees, and issue an industry-specific wage order by June 30, 2028.

Notably, SB 1203 itself does not establish a specific minimum wage for security guards. Instead, it would require the IWC to develop a wage order addressing wages and working conditions in the industry.

Next Steps

SB 1203 remains pending and could be further amended as it moves through the legislative process. If enacted, many of its significant training requirements would become operative on July 1, 2028.

Employers that employ security personnel or utilize private security services may want to monitor the legislation and consider how the proposed requirements could affect both their security operations and their workplace violence prevention programs.

Ogletree Deakins’ California offices, Workplace Safety and Health Practice Group, and Workplace Violence Prevention Practice Group will continue to monitor developments and will post updates on the California, Workplace Safety and Health, and Workplace Violence Prevention blogs as additional information becomes available.

Follow and Subscribe
LinkedIn | Instagram | Webinars | Podcasts