and scholars have focused on developing more studies on sexual harassment in workplaces. Sexual assault becomes difficult to define, as the distinction between sexual harassment and consensual sexual behaviors is not finely delineated. Some occupations require a higher tolerance to sexual behaviors, such as waitresses and tour guides. More specifically, the employers for these occupations expect the workers to comply with the level of sexual interactions the workers would have with the customers. This unquestioned expectation from the employers then pushes the workers to see only two options. The workers would have to accept the sexual harassment from customers as "part of the job", or report the sexual harassment to the manager and get fired. Adding onto the pressure, reporting sexual assault comes with criticism from co-workers, as they see the sexual assault as part of the job requirement. The prevalence of sexual harassment at work is high. For example, a study by the U.S. Merit Systems Protection Board in 1981 shows that among the female government employees, 33 percent experienced sexual comments, 26 percent had unwanted physical touching, and 15 percent was pressured for dates. Moreover, "Nearly 10% had been directly pressured for sexual cooperation, and a similar percentage described repeated telephone calls and unwelcome letters or notes." Other than this example, Fitzgerald states that "the enormity of such figures is difficult to grasp, indicating as they do that virtually millions of women are subjected to experiences ranging from insults to assault—many on an ongoing or recurrent basis— as the price of earning a living." Another form of physical harassment at work is workplace violence. Workplace violence is defined as physical threats and assaults targeted at employees. There are two main perpetrators for workplace violence: criminals who approached as clients, and co-workers. The criminals assert violence through the forms of robberies and homicides, and the rate of homicides in the workplace has risen significantly over the past 20 years. According to the National Institute for Occupational Safety and Health (NIOSH), 9,937 workplace homicides happened in the time period of 1980 to 1992, which averages out to about 800 homicides per year. "In 1989, homicide was the third leading cause of death in the workplace for all employees. By 1993, homicide had become the second-leading cause of death on-the-job for all employees and had become the leading cause of death for women." Most of these homicides are by criminals, as