The California Occupational Safety and Health Administration (Cal/OSHA) is now enforcing a new ergonomics standard called the “Hotel Housekeeping Musculoskeletal Injury Prevention Program” (MIPP) under Section 3345 of Title 8 of the California Code of Regulations.
The regulation—the first of its kind to introduce an ergonomics standard written specifically for the hospitality industry—is intended to control the risk of musculoskeletal injuries and disorders to housekeepers in hotels and other lodging establishments.
According to the definitions section of the regulations, a “lodging establishment” refers to an establishment that contains sleeping room accommodations that are rented or otherwise provided to the public, such as hotels, motels, resorts and bed and breakfast inns.
A lodging establishment does not include hospitals, nursing homes, residential retirement communities, prisons, jails, homeless shelters, boarding schools or worker housing.
“Hotel housekeepers have higher rates of acute and cumulative injuries compared to workers in other industries, and data shows those injuries have steadily increased,” Cal/OSHA Chief Juliann Sum said in a release. “This regulation requires employers to identify, evaluate and correct housekeeping-related hazards with the involvement of housekeepers and their union representative.”
The regulation requires lodging establishment employers to implement and maintain an effective MIPP to prevent housekeepers from suffering musculoskeletal injuries when lifting mattresses, pulling linens, pushing heavy carts, and slipping, tripping or falling while cleaning bathrooms.
The MIPP needs to be in writing as part of the already existing Injury and Illness Prevention Program (IIPP) or as a separate program. The written program must be readily accessible to employees to read at each work shift. An electronic copy is sufficient if there are no barriers to employee access as a result of using an electronic option.
The MIPP requirements are similar to those for the IIPP, and are as follows:
- The name or job title of the person or persons responsible for implementing the MIPP.
- A system to ensure all persons affected by the MIPP comply and follow the safe workplace housecleaning practices and use the appropriate tools to safely accomplish the required tasks.
- A system to communicate with housekeepers on occupational safety and health that is understandable and encourage the housekeepers to inform the employer of worksite hazards without reprisal.
- Develop procedures for identifying and evaluating housekeeping hazards, initially to be accomplished within three months after the effective date of the regulation (October 1, 2018) or after the opening of the new lodging establishment. The MIPP must include an effective means of involving housekeepers and their union representative in designing and conducting the worksite evaluation. Housekeepers shall be notified of the results of the worksite evaluation in writing or by posting it in a location readily accessible to them. The results of the worksite evaluation shall be in a language easily understood by housekeepers.
The worksite evaluation shall be reviewed and updated:
- Whenever new processes, practices, procedures, equipment or guest room renovations are introduced that may change or increase housekeeping hazards;
- Whenever the employer is made aware of a new or previously unrecognized housekeeping hazard based on information such as, but not limited to, the findings and recommendations of injury investigations.
- At least annually for each worksite.
- The worksite evaluation shall identify and address potential injury risks to housekeepers including, but not limited to: slips, trips and falls; prolonged or awkward static postures; extreme reaches and repetitive reaches above shoulder height, lifting or forceful whole body or hand exertions; torso bending, twisting, kneeling, and squatting; pushing and pulling; falling and striking objects; pressure points where a part of the body presses against an object or surface; excessive work-rate; and inadequate recovery time between housekeeping tasks.
Procedures to investigate musculoskeletal injuries to housekeepers. Injury investigations shall include, at a minimum:
- The procedures or housekeeping tasks being performed at the time of the injury and whether any identified control measures were available and in use;
- If required tools or other control measures were not used, or not used appropriately, a determination of why those measures were not used or were not used appropriately; and
- Input from the injured housekeeper, the housekeeper’s union representative, and the housekeeper’s supervisor as to whether any other control measure, procedure, or tool would have prevented the injury.
- Methods or procedures for correcting, in a timely manner, hazards identified in the worksite evaluation or in the investigation of musculoskeletal injuries to housekeepers, including procedures for determining whether identified corrective measures are implemented appropriately.
These procedures shall include:
- An effective means of involving housekeepers and their union representative in identifying and evaluating possible corrective measures;
- A means by which appropriate equipment or other corrective measures will be identified, assessed, implemented, and then reevaluated after introduction and while used in the workplace; and
- A means of providing and making readily available appropriate housecleaning equipment, protective equipment, and tools to each housekeeper, including procedures for procuring, inspecting, maintaining, repairing, and replacing appropriate housecleaning tools and equipment.
- Procedures for reviewing, at least annually, the MIPP at each worksite, to determine its effectiveness and make any corrections when necessary, including an effective procedure for obtaining the active involvement of housekeepers and their union representative in reviewing and updating the MIPP. The procedures shall include a review of the Cal/OSHA Form 300 log and Cal/OSHA Form 301 incident reports.
Training
The employer shall provide training to housekeepers and their supervisors in a language easily understood by these employees.
Training shall be provided:
- To all housekeepers and supervisors when the MIPP is first established;
- To all new housekeepers and supervisors;
- To all housekeepers given new job assignments for which training was not previously provided;
- At least annually thereafter; and
- When new equipment or work practices are introduced or whenever the employer becomes aware of a new or previously unrecognized hazard. The additional training may be limited to addressing the new equipment or work practices.
Training shall include at least the following elements as applicable to the housekeeper’s assignment:
- The signs, symptoms, and risk factors commonly associated with musculoskeletal injuries,
- The elements of the employer’s MIPP and how the written MIPP and all records will be made available to housekeepers;
- The process for reporting safety and health concerns without fear of reprisal i.e. anonymously.
- Body mechanics and safe practices including: identification of hazards at the workplace, how those hazards are controlled during each housekeeping task, the appropriate use of cleaning tools and equipment, and the importance of following safe work practices and using appropriate tools and equipment to prevent injuries;
- The importance of, and process for, early reporting of symptoms and injuries to the employer;
- Practice using the types and models of equipment and tools that the housekeeper will be expected to use;
- An opportunity for interactive questions and answers with a person knowledgeable about hotel housekeeping equipment and procedures; and
- Training of supervisors on how to identify hazards, the employer’s hazard correction procedures, how defective equipment can be identified and replaced, how to obtain additional equipment, how to evaluate the safety of housekeepers’ work practices, and how to effectively communicate with housekeepers regarding any problems needing correction.
Recordkeeping:
- Records of the steps taken to implement and maintain the MIPP, including any measurements taken or evaluations conducted in the worksite evaluation process.
- Records of scheduled and periodic inspections to identify unsafe conditions and work practices, including person(s) conducting the inspection, the unsafe conditions and work practices that have been identified and action taken to correct the identified unsafe conditions and work practices. These records shall be maintained for at least one (1) year; and
- Documentation of training for each employee, including employee name or other identifier, training dates, type(s) of training, and training providers. This documentation shall be maintained for at least one (1) year.
- A copy of the MIPP and all worksite evaluation records required shall be available at the worksite for review and copying by housekeepers and their designated representative.
- All records shall be made available to the Cal/OSHA Compliance Safety and Health Officer within 72 hours of request.
- Records of occupational injuries and illnesses shall be created and maintained.
Ultimately, lodging establishment industry employers in California must have their written MIPP now (deadline July 1, 2018) and have procedures for identifying and evaluating housekeeping hazards, initially to be accomplished by October 1, 2018.
If you have any questions related to this update, please don’t hesitate to contact me.
