Introduction In January 2012, the hotel worker union UNITE HERE filed a petition with Cal/OSHA and requested a specific safety standard to protect hotel housekeepers. The request included a maximum requirement of cleaning 5,000 square feet of room space per eight-hour work shift, the use of fitted bottom sheets as a requirement, and the prohibition of working in stooping or kneeling postures to clean toilets and floors.
From October 2012 to December 2015, Cal/OSHA employed five advisory committees to gather information and talk with key stakeholders
On March 9, 2018, California published a new musculoskeletal injury prevention program (MIPP) standard for hotel housekeepers. The standard went into effect on July 1, 2018.
In issuing the Standard, Cal/OSHA declared that hotel housekeeping is a “high hazard” job task, with a DART rate in the top 10 of California occupations. In fact, according to the Final Statement of Reasons issued by Cal/OSHA, injuries for hotel housekeepers rose from 4,990 in 2010 to 6,116 in 2014, an increase of nearly 23-percent.
Who Does It Affect? The Standard applies to any company that rents rooms, including boutique hotels, inns, and bed & breakfast establishments. In a letter of clarification this author received from Cal/OSHA, if a hotel company operates water-based ships with rented rooms, and if they are already subject to Cal/OSHA, then they are subject to the Standard, and must take the necessary steps to comply.
Requirements Each hotel must create a written MIPP with various components, including stating who is in charge, a system to ensure supervisors and housekeepers comply with the Standard, and a system for communicating with housekeepers, “including provisions designed to encourage housekeepers to inform the employer of hazards at the worksite, and injuries or symptoms that may be related to such hazards without fear of reprisal.”
Hotel companies are also required to identify all housekeeping tasks and to conduct worksite assessments of these tasks. These assessments must include the participation of housekeepers and a union representative, where applicable. There are various ways to assess these hazards, and to get started, many hotel companies may wish to employ qualified professionals using the latest best practices and quantitative assessment tools.
The Standard also presents requirements that hotel companies must notify housekeepers of the results of worksite evaluations in writing, including identified hazards, and make results of the assessments available to housekeepers, their union representatives, where applicable, and the State.
Worksite Assessments Making use of best practices and quantitative assessments means that you are using the latest available science to not only help you comply with the Standard, but also improve your housekeeping jobs. The hazards to be identified and assessed annually, beginning by October 1, 2018, include:
Slips, trips & 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, 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; Inadequate recovery time between tasks.
These assessments require more than just a “checklist” to be effective. For example, when assessing slips, trips & falls, hotel companies must identify reasons the slip, trip & fall hazards exist, and methods to help housekeepers avoid those slips trips and falls.
For “prolonged or awkward static postures,” hotel companies will need to use a more precise definition to help them determine what constitutes such postures, and an assessment that makes use of scientific data, such as the dimensions of segments of the human body, will better define “extreme” and “repetitive” reaches.
Lifting and forceful whole body or hand exertions should be assessed using the latest quantitative assessment tools. Formal lifting analyses should consider the effects of one-handed and team lifting, and force assessments by those with the proper skills and tools will help hotels identify and quantify the true nature of risk.
For nearly 30-years, companies in hospitality and other industries have used the Snook-Ciriello tables to assess pushing and pulling tasks, which are also part of the MIPP. However, these tables do not fully address pushing and pulling limits, which have recently been revised.
The requirements to assess “excessive work-rate” and “inadequate recovery time between housekeeping tasks” are, frankly, vague, and one challenge will be to know how to define and/or quantify those injury risks. The key is to strike the proper balance between the demands of housekeeping tasks, the physical capabilities of housekeepers, and room rates. Thus, it will be important to use quantitative assessment criteria that can stand up to external scrutiny. Assessments must be performed annually of all housekeeper tasks, and whenever new or unknown hazards are identified.
Improvements Once the worksite assessments are complete, hotel companies must make improvements to housekeeping tasks that must be focused on addressing the hazards identified during the assessments. Trusting that quantitative data is gathered during the assessment phase, it should be easier for hotel companies to demonstrate tangible improvements.
Training The Standard requires mandatory annual training in language(s) easily understood for all housekeepers, supervisors and managers. The training should discuss the program and identified hazards, include results of the assessments, and provide methods for housekeeping employees to report physical issues or hazards without any fear of retaliation. Training should also be completed for new housekeepers, supervisors and managers, and whenever new housekeeping jobs or hazards are identified.
Records & Recordkeeping Results of the assessments, as well as assessment notes, must be available for review and copying by housekeepers, their union representative, if applicable, and various State authorities. In addition, records of all program activities must be maintained by hotel companies
This Mandatory Standard took effect July 1, 2018, and ALL hotels must complete the worksite assessments annually, as well as take steps to address any identified hazards.
QP3 ErgoSystems has conducted assessments of hundreds of housekeepers and room attendants at dozens of hotels, and has contributed to a published article about housekeeping tasks.
Call us today at (847) 921-3113 to schedule your MIPP Assessments and Training!
