Hotel Housekeeping Injury Prevention Standard

This standard, which became effective July 1, 2018, was developed and adopted in an effort to reduce the occurrence of musculoskeletal injuries -- particularly to the back, shoulders, and upper extremities -- experienced by hotel housekeeping staff. It is the first ergonomic standard in the nation written specifically to protect hotel housekeeping staff, and will be enforced by the California Occupational Safety and Health Administration (Cal/OSHA). This article focuses on the key points only. The full text of the standard can be found in Title 8, California Code of Regulations (CCRs), California Hotel Housekeeping Musculoskeletal Injury Prevention Standard, §3345. In addition, a fillable MIPP template is available on the Cal/OSHA website to assist employers in writing their program.

Musculoskeletal Injury Prevention Program (MIPP)
All applicable employers (see FAQ #1 below) are required to develop a written MIPP which may be incorporated into their written Injury and Illness Prevention Program (IIPP), or be maintained as a separate program. The MIPP must include the following:

1. Names or job titles of the persons with authority and responsibility for implementing the MIPP at each worksite.
2. A system for ensuring that supervisors and housekeepers substantially comply with the MIPP, including recognition of employees who follow the employer’s safe workplace housecleaning practices and use the appropriate tools and equipment, training and retraining programs, disciplinary actions, or other means of compliance.
3. A system for communicating with housekeepers in a form readily understandable by all housekeepers on matters relating to occupational safety and health, including provisions designed to encourage housekeepers to inform their employer of hazards at the worksite, and injuries or symptoms that may be related to those hazards without fear of reprisal.
4. Procedures for identifying and evaluating housekeeping hazards through a worksite evaluation. When a new lodging establishment is opened, this evaluation must be completed within three months of its opening. Housekeepers and their union representative must be provided a means of being involved in designing and conducting these evaluations. Results of the worksite evaluation must be made available to housekeepers in writing or by posting them in a location readily accessible to them during each workshift and in a language easily understood by them.  Multiple methods, procedures, and/or tools for accomplishing tasks safely may be used, based on the employer’s evaluation.
5. Procedures to investigate musculoskeletal injuries to housekeepers. This includes any control measures that were available and in use, why those measures were or were not used appropriately; and input from the housekeeper, their union representative or supervisor, as to whether a control measure would have prevented the injury. Provisions must encourage housekeepers to report hazards, injuries, or symptoms without fear of reprisal.
6. Procedures for correcting, in a timely manner, hazards identified in the worksite evaluation or investigation of a musculoskeletal injury to housekeepers. This must include the involvement of housekeepers and their union representative in identifying and evaluating possible corrective measures, a means for evaluating, implementing, and re-evaluating corrective measures  It also must include a means of providing and making readily available appropriate housecleaning equipment, protective equipment and tools to each housekeeper; as well as procedures for procuring, inspecting, maintaining, repairing, and replacing housecleaning tools and equipment.
7. An annual review of the MIPP. The Cal/OSHA Form 300 log and other relevant records such as Cal/OSHA Form 301 incident reports must be included in this review.

Inclusion of Housekeeper and Union Input. A unique aspect of this standard is that it requires procedures for involving housekeepers and their union representative. Cal/OSHA determined that this worker involvement is critical due to their knowledge of the details of the work tasks and work practices. This requirement applies whether or not the business has a collective bargaining agreement with a union.

Training.  Housekeepers and supervisors must be trained when the MIPP is initially established, at least annually, and when new equipment or work practices are introduced, or whenever the employer becomes aware of a new or previously unrecognized hazard. This training must include practice using the types and models of equipment and tools that the housekeeper will be expected to use, as well as provide an opportunity for interactive questions and answers with a person knowledgeable about hotel housekeeping equipment and procedures. Communication must be provided in a form readily understandable by all housekeepers on matters relating to occupational safety and health.

Frequently Asked Questions (FAQs)

1. What is considered a Lodging Establishment for the purposes of this standard?
   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.  It does not include hospitals, nursing homes, residential retirement communities, prisons, jails, homeless shelters, boarding schools, or worker housing.
2. What is considered “Housekeeping Tasks”?
   Tasks related to cleaning and maintaining sleeping room accommodations, including bedrooms, bathrooms, kitchens, living rooms, and balconies.  These include, but are not limited to, the following: 
   • Sweeping, dusting, scrubbing, mopping and polishing of floors, tubs, showers, sinks, mirrors, walls, fixtures, and other surfaces
   • Making beds
   • Vacuuming
   • Loading, unloading, pushing, and pulling linen carts
   • Removing and supplying linen and other supplies in the rooms
   • Collecting and disposing of trash
   • Moving furniture
3. How often must the worksite evaluation 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.
   • At least annually for each worksite
4. What types of risks must be identified in the workplace evaluation? (Additional information is found in Appendix A of the standard)
   
   • 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
   • Inadequate recovery time between housekeeping tasks

For additional information on this subject, see the ErgoMatters article, Tips for Hotel Room Attendants, available on the www.statefundca.com website.

The above information is provided by the Department of Industrial Relations from its Web site at www.dir.ca.gov. Appendix A of this standard provides reference materials to aid in conducting worksite evaluations. 

The information herein is for reference only and State Fund does not warranty its accuracy or fitness for a particular purpose. Any products, references, or links to Web sites are not an endorsement by State Fund or its employees, but serve only as examples to assist you with your workplace design changes. State Fund cannot be held liable or accountable for content on linked Web sites.

Revised: 12/2018