On January 8, 2025, Ohio Governor Mike DeWine signed House Bill 452 — the Healthcare Workplace Safety Act — into law. The bill passed with bipartisan support, sponsored jointly by Representative Andrea White (R-Kettering) and Representative Rachel Baker (D-Cincinnati). It took effect April 9, 2025. Full implementation was required by July 9, 2025.
Both deadlines have passed. Every Ohio hospital that does not have a compliant security plan, trained personnel in emergency and psychiatric departments, and a functioning incident reporting system in place is currently out of compliance — and the Ohio Department of Health knows it, because compliance must be attested through the state’s own platform.
This article covers what HB 452 requires, what the attestation process involves, and what non-compliant hospitals should do now. For a structured reference of every HB 452 requirement alongside the Kestralis assessment approach, see our Ohio compliance guide.
Why This Law Passed
Workplace violence in Ohio hospitals had been escalating for years before HB 452 passed. The legislation was catalyzed in part by the death of Tristin Kate Smith, a Dayton nurse who died by suicide on August 7, 2023, following a serious workplace violence incident. Her father, Ron Smith, attended the bill signing. The Ohio Nurses Association had been advocating for this legislation for years before the bill crossed the finish line.
The problem it addresses is real and well-documented. According to the World Health Organization, between 8% and 38% of healthcare workers suffer physical violence at some point in their careers. Bureau of Labor Statistics data shows that healthcare workers experience workplace violence at rates nearly double those of any other industry. Emergency departments and psychiatric units are the highest-risk environments in any hospital.
HB 452 is not a compliance exercise. It is a direct response to a documented crisis that has been building for decades and that the healthcare industry had not adequately addressed through voluntary measures.
Who HB 452 Covers
HB 452 applies to hospitals and hospital systems in Ohio. It does not apply to outpatient clinics, long-term care facilities, home health agencies, or other healthcare settings — though those settings remain subject to federal OSHA’s General Duty Clause and should be monitoring Ohio’s legislative trajectory closely as the framework established by HB 452 is likely to expand.
Both independent hospitals and hospitals that are part of larger health systems are covered. The law permits a single workplace violence prevention committee to serve multiple facilities within a health system, but the resulting security plan must be distinctly identifiable for each facility — meaning it must address the specific conditions and hazards of each location, not serve as a system-wide generic document.
The Six Requirements
1. Security Risk Assessment
The foundation of all other program elements. The assessment must evaluate the specific violence risks and hazards present at the hospital, with particular attention to high-risk areas. Emergency departments and psychiatric departments are specifically identified in the law as priority areas requiring targeted assessment. The security plan that follows must be based on the assessment findings — not on a template that was written without reference to the hospital’s specific environment.
2. Written Security Plan Developed by an Interdisciplinary Team
This is HB 452’s most operationally significant requirement, and the one most likely to create compliance gaps at facilities that treated the mandate as a documentation exercise.
The security plan must be developed by a team that includes healthcare employees who provide direct patient care and at least one current or former patient of the hospital. Both elements are required. A plan developed by administrators and security directors without direct care worker and patient input is not compliant with HB 452, regardless of how comprehensive the document appears.
This requirement reflects the research consensus on effective workplace violence prevention: bedside nurses, emergency department technicians, and psychiatric unit staff have the most accurate understanding of where the risks are and what interventions are practical. The law is designed to get that knowledge into the plan.
The process of developing the plan must be documented — who participated, in what capacity, and what their contributions were. That documentation is what demonstrates compliance with this specific requirement.
3. De-escalation Training at Peace Officer Standards
HB 452 grants hospital security personnel access to online security training previously available only to Ohio peace officers. It then requires security personnel to receive de-escalation training at a level equivalent to those standards. This is a meaningful elevation of the training requirement — and a meaningful compliance burden for hospitals whose security teams were trained to a lower standard before the law took effect.
All hospital staff must receive annual training on de-escalation techniques, recognition of potential violence, and appropriate response protocols. The peace officer-level standard applies specifically to security personnel; clinical staff training, while required to be annual, is scoped to their roles and responsibilities.
4. Continuous Trained Coverage in High-Risk Areas
At least one hospital employee trained in de-escalation practices must be present at all times in the hospital’s emergency department and psychiatric department. This is a staffing requirement, not just a training requirement. It imposes a scheduling obligation that must be maintained 24 hours a day, every day — and that must be documented to demonstrate ongoing compliance.
For many hospitals, this requirement will reveal gaps in coverage during overnight shifts, weekends, and high-volume periods. Compliance requires not just training the right people but scheduling them in a way that guarantees coverage without interruption.
5. Workplace Violence Incident Reporting System
Hospitals must establish a functioning incident reporting system that enables tracking and analysis of workplace violence incidents over time. The system must include clear criteria for when incidents must be reported to law enforcement and must enable the hospital to analyze patterns and implement corrective measures based on the data.
Anti-retaliation protections are explicit: hospitals may not discriminate against or retaliate against employees who report workplace violence incidents or participate in investigations. The prohibition on discouraging law enforcement contact is also explicit — hospitals cannot discourage employees from contacting police following a violent incident.
6. Annual Review and Governing Body Report
The security plan is not a one-time deliverable. HB 452 requires the hospital or hospital system to review and evaluate the plan on an annual basis, with results reported to the hospital’s governing body. That governing body visibility is one of the most important elements of the statute from a liability perspective — a board that has received the annual report, been informed of identified deficiencies, and taken no action has documented knowledge of the problem.
Additional Employee Protections
HB 452 includes two categories of employee protection beyond the program requirements that distinguish it from comparable state mandates.
Civil immunity for self-defense. HB 452 grants general civil immunity to individuals who sustain injuries while acting in self-defense or defense of another during an actual or imminent act of workplace violence. This provision addresses a documented deterrent to self-protective action — the fear among healthcare workers that intervening or defending themselves against a violent patient could expose them to civil liability.
Required workplace signage. HB 452 makes mandatory what was previously optional — hospitals must post prominent notices stating that threatening or aggressive behavior toward staff will not be tolerated and may result in removal from the premises or criminal prosecution. Staff working in high-risk areas may display only their first name on ID badges to protect their personal information.
The Attestation Requirement — What Non-Compliant Hospitals Need to Know
HB 452 includes a compliance element that has no equivalent in comparable state mandates: each covered hospital must submit an attestation of compliance to the Ohio Department of Health in the form and manner the agency specifies. Per Ohio Hospital Association guidance, attestation is submitted through the Juvare EMResource platform — the same system ODH uses for other regulatory reporting. Hospitals should confirm the current platform and submission path with ODH directly before filing.
This requirement has practical implications beyond typical compliance obligations. A hospital that has not submitted an attestation has self-identified as non-compliant in the state’s own systems. Unlike a law enforced only through reactive inspections or complaint-triggered investigations, the attestation requirement means the Ohio Department of Health has affirmative visibility into which hospitals have and have not certified compliance.
Hospitals that have not previously submitted regulatory reporting to ODH through Juvare EMResource will need to request platform access before they can attest. The current request process and instructions should be confirmed with ODH directly — a failed or incomplete attestation submission does not constitute compliance.
Enforcement and Liability Exposure
HB 452 does not include an explicit citation and penalty schedule of the kind found in California’s SB-553 (up to $162,851 per willful violation). There is no defined fine per violation. This does not mean non-compliance is without consequences.
The Ohio Department of Health has licensing authority over covered hospitals. Failure to comply with Chapter 3727 requirements — which now includes HB 452’s security plan obligations — is grounds for disciplinary action against a facility’s license. For a licensed Ohio hospital, a licensing action is not a financial penalty that can be managed as a cost of doing business. It is an existential threat to operations.
The Joint Commission workplace violence prevention standards adopted in 2022 apply independently to accredited hospitals. Most Ohio acute care hospitals are Joint Commission accredited. A facility that is both non-compliant with HB 452 and out of conformance with Joint Commission standards faces compounding regulatory exposure from two independent sources.
The legal exposure created by the annual governing body reporting requirement deserves specific attention. Once a hospital’s governing body has received the committee’s annual report, been informed of identified gaps, and taken no corrective action, it has created a documented record of knowledge. In a post-incident negligence case, that record is the foundation of a failure-to-act claim against both the institution and its leadership. The governing body reporting requirement is not administrative formality — it is evidence in waiting.
What Ohio Hospitals Should Do Now
For hospitals that are not yet compliant, the situation is urgent but not irreversible. The steps are clear:
- Assess current program status honestly. Does a written security plan exist? Was it developed with direct care staff and patient input? Has the risk assessment been documented? Is trained coverage present in the ED and psychiatric units at all times? Is the incident reporting system functioning? Has the plan been reviewed and the results reported to the governing body?
- Establish or confirm ODH platform access. If your hospital has not yet submitted an attestation, begin the platform access request process with ODH immediately. Attestation cannot happen without platform access, and platform access requires a separate request — confirm the current process with ODH directly.
- Remediate the most critical gaps first. The requirement for at least one de-escalation-trained employee on-site at all times in emergency and psychiatric departments is the most operationally demanding. If staffing gaps exist, they need to be addressed before attestation. The interdisciplinary team requirement is the most documentation-intensive — if the plan was built without proper team composition and documentation, the development process needs to be reconstructed.
- Engage legal counsel before submission.Attestation is a legal statement of compliance. Submitting an attestation for a program that does not actually meet HB 452’s requirements is worse than not submitting — it creates a documented misrepresentation. Review the program against the statute before submitting.
Ohio in the National Healthcare Compliance Picture
Ohio HB 452 is one of more than 20 state mandates currently requiring healthcare employers to maintain workplace violence prevention programs. Health systems with operations in multiple states are navigating a patchwork of inconsistent requirements that share a common architecture but differ significantly in specifics.
California’s SB-553 is the most demanding general industry mandate. Texas’s SB 240 covers the broadest range of healthcare facility types. Ohio’s HB 452 adds the strongest specific requirements around continuous ED coverage, interdisciplinary planning, and state attestation. Virginia’s healthcare mandate is expanding through 2026 legislation. A health system operating in Ohio, California, and Texas simultaneously is operating under three different active mandates with different requirements, different enforcement mechanisms, and different deadlines.
The efficient approach is a coordinated multi-state program — a common architectural foundation built to the most demanding standard in each state, with state-specific configurations layered on top. The work done for California does not need to be duplicated for Ohio. The Ohio requirements build on what California already required. The program scales. For more on this approach, see our national healthcare compliance guide.
The Ohio Nurses Association has published resources on HB 452 compliance. The Ohio Department of Health publishes attestation instructions and platform access guidance for HB 452 — consult ODH directly for the current submission path. For the full text of the statute, see Ohio Revised Code Sections 3727.181 and 3727.182.
