Plan, Prevent, Protect – Sooner Better than Later
HR Advisor feature article | September 2010
In its Spring 2010 Regulatory Agenda, the U.S. Department of Labor (DOL) had issued a new regulatory and enforcement strategy for all businesses referred to as "Plan/Prevent/Protect."
While the specifics of program are still being defined, the new program involves the following:
Plan: The DOL will propose a requirement that employers create a plan for identifying and remedying risks of legal violations and other risks to workers. The employer would provide their employees with opportunities to participate in the creation of the plans. In addition, the plans would be made available to workers so they can fully understand and help monitor their implementation.
Prevent: The DOL will propose a requirement that employers completely implement the plan in a manner that prevents legal violations. The plan cannot be a simple paper process; the employer cannot draft a plan and then ignore it. The plan must be fully implemented for the employer to comply with the "Plan/Prevent/Protect" compliance strategy.
Protect: The DOL will propose a requirement that employers ensure that the plan's objectives are met on a regularly. Not any plan will do. The plan must actually protect workers from violations of their workplace rights.
While the DOL continues to work on the specific details of what an employer's compliance initiative should look, employers should at least consider starting to develop and establish an HR compliance action plan.
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