"In many other countries around the world, there are specific prohibi¬tions against psychological harassment or bullying in the workplace, with some of those prohibitions specifically requiring employers to take steps to seek to prevent that conduct from occurring. The law in the United States, however, is both less specific and less certain with respect to the existence of a duty imposed on employers concerning this type of conduct. The reason for this difference is that the law in the United States does not specifically prohibit bullying in the context of the workplace. Instead, employers are under a duty to act with respect to bullying and can face liability for a failure to act only if and to the extent that the bullying vio¬lates some other legal prohibition. While there have been efforts to enact legislation to specifically prohibit workplace bullying, to date those efforts have been largely unsuccessful"

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