Preventing Musculoskeletal Hotel Housekeeping Injuries
Written by: Joe Mangiardi, NES, Inc.
Relief for hotel housekeepers may have arrived with recent Cal/OSHA legislation: the causes of various musculoskeletal injuries are now required to be identified and managed by affected employers.
Standard to Mitigate Hotel Housekeeping Injuries Now in Effect
In January 2018 the California Division of Occupational Safety and Health (Cal/OSHA) unanimously voted to adopt regulations aimed at combating the rising rate of musculoskeletal hotel housekeeping injuries. The new standard, California Code of Regulations (CCR), Title 8, §3345: Hotel Housekeeping Musculoskeletal Injury Prevention, went into effect July 1, 2018, leaving affected hospitality industry businesses three months from that date to comply with the rule’s mandate that a worksite evaluation be performed (or within three months of the opening of a new establishment). Primarily, the standard outlines the requirement that these employers “establish, implement, and maintain an effective, written, musculoskeletal injury prevention program (MIPP) that addresses hazards specific to housekeeping.” The hotel housekeeping regulations also include associated training and recordkeeping components.
Hotel Housekeeping Injuries by the Numbers
Spearheaded for the past several years by UNITE HERE, a largely female- and minority-driven labor union representing 270,000 workers from the United States and Canada across various hospitality and manufacturing industries, the new rule reflects data considered by Cal/OSHA indicating that hotel housekeepers disproportionately suffer musculoskeletal injuries versus the rest of the industry. According to Hospitalitynet article New Regulation To Protect Hotel Housekeepers: Are You Ready?, hotel housekeepers suffer an annual injury rate of 7.9%, the highest among hotel employees (5.2% overall). And between 2010 and 2014 the number of workers’ compensation claims in the accommodation industry has increased by an average of 897 per year.
The Hospitalitynet article also references a study of 941 Las Vegas hotel room cleaners. The study found that “75% of respondents experienced work-related pain during a one-year time period, where more than half of them used sick or vacation time for this pain, and only a third of them reported this pain to management.” This frequency of underreporting of injuries contributes to a heightened occurrence of serious injuries, leading to lost work time and adversely affecting the injured employee and the hotel or other lodging establishment.
Additionally, data from the Bureau of Labor Statistics indicate that 70% of the $500 million paid annually by the hospitality industry for repetitive motion injuries can be attributed to claims made by housekeepers.
Hotel Housekeeping Injuries: Understanding §3345
Complying with the new standard involves implementing its three main components: the MIPP, training, and recordkeeping. But first there are a few definitions from §3345 to understand:
- Control measures: the tools, equipment, devices, work practices, and administrative controls used to effectively correct or mitigate identified workplace hazards that may cause musculoskeletal injuries
- Housekeeper: refers to an employee who performs housekeeping tasks and includes those termed housekeepers, guest room attendants, room cleaners, maids, and housepersons
- Housekeeping tasks: those tasks related to cleaning and maintaining sleeping room accommodations including bedrooms, bathrooms, kitchens, living rooms, and balconies
- Lodging establishment: 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; does not include hospitals, nursing homes, residential retirement communities, prisons, jails, homeless shelters, boarding schools, or worker housing
- Musculoskeletal injury: an acute injury or cumulative trauma of a muscle, tendon, ligament, bursa, peripheral nerve, joint, bone, spinal disc, or blood vessel
Musculoskeletal hotel housekeeping injuries can occur in numerous areas of the body and can be caused by a wide range of workplace activities and conditions.
Additional information can be found on the Cal/OSHA Safety & Health Fact Sheet Preventing Musculoskeletal Injuries in Housekeepers.
The hotel housekeeping musculoskeletal injury prevention program is to be a written document that may either be created as a separate document or be incorporated into an organization’s existing Illness and Injury Prevention Program (IIPP).
To learn more about IIPPs and other employer safety programs, see the December 2017 article California Workplace Injuries and Illnesses Rate Declines.
The MIPP must be available to housekeepers during every work shift in either physical or electronic format (if the latter, all affected personnel must be able to access it). The MIPP is to include:
- Names and titles of those authorized and responsible for implementing the MIPP
- Details for a system that will be used to ensure managers and housekeepers comply with the MIPP
- A system for keeping employees aware of their responsibility to inform their employer of any hazards observed or hotel housekeeping injuries sustained (this includes the assurance that such reports will not be met with retaliatory action)
- Worksite evaluation procedures to identify housekeeping hazards
Worksite evaluations must meaningfully include feedback from housekeepers (and their union representative) and are to be completed initially (within three months), annually thereafter, and/or whenever there is an impactful change in workplace conditions, equipment, processes, practices, procedures, etc. In performing the worksite evaluation, lodging establishments are to consider any work activities that could result in or involve slips/trips/falls, repetitive, prolonged, and/or awkward postures or reaches, extreme lifting, aggravation of pressure points, overexertion, or inadequate recovery time between tasks.
Hotel housekeeping injuries can result from various commonly performed tasks.
The MIPP must also contain:
- Protocols for the investigation of any musculoskeletal injuries sustained by housekeepers
- Methods for correcting identified hazards in a timely manner including employee/union input and a means for providing and properly maintaining the appropriate housecleaning and protective equipment
- Annual MIPP reassessment procedures, which are to include the Cal/OSHA Form 300 log and Cal/OSHA Form 301 incident reports
Training is to be provided to housekeepers and management in a language that can easily be understood by all employees. The training is to occur annually and must be completed following establishment of the MIPP and whenever new employees are hired, current employees are assigned duties on which they were not previously trained, new equipment is introduced, and/or previously unknown hazards are identified. Training is to include the following elements:
- Common signs, symptoms, and risk factors of musculoskeletal injuries
- The MIPP and how it and associated records will be made available to housekeepers
- The process for, and importance of, reporting hazards and injuries in a timely manner, which will be without employer retaliation
- Body mechanics and safe practices including identification and control of workplace hazards and hands-on instruction on the proper use of necessary equipment
- Q&A with an individual well-versed in hotel housekeeping equipment and procedures
- Instruction for management on how to properly and effectively identify and correct hazards, defective equipment, and/or unsafe work practices
Records must be kept on how the MIPP is implemented and maintained. These records are to include findings and corrective actions that resulted from worksite evaluations. Records are to remain available at the worksite and be furnished, as appropriate, to regulators within 72 hours of request. Occupational injury and illness records are to be maintained in accordance with 8 CCR, Division 1, Chapter 7, Subchapter 1.
The above poster can be downloaded from Cal/OSHA here.
The Argument Against Adding §3345
The legislation that is now 8 CCR §3345 was not developed without opposition from industry stakeholders. Commonly argued has been a perceived redundancy presented by §3345 given its similarity to existing regulations contained in 8 CCR §3203: Injury and Illness Prevention Program and §5110: Repetitive Motion Injuries. Cal/OSHA defends such claims by pointing out that §3203 is structured to prevent injuries and illnesses in all industries but does not specifically address musculoskeletal injuries or require employers to correct identified hazards and update their IIPP; and §5110 merely advances response protocols for injuries rather than preventing them and, again, does not explicitly address musculoskeletal injuries (e.g., strains/sprains caused by acute trauma or slips/trips/falls).
Hotel Housekeeping Injuries Prevention: Conclusion
This legislation aimed at preventing hotel housekeeping injuries is particularly meaningful because its passage marks the first time in history that an ergonomics-based standard has been enacted especially for the hospitality industry. Some have noted that it sets a precedent; moving forward, other, similar-such legislation may follow in California and beyond. The hope is that the reduction in employee injuries and the accompanying decrease in lost work time and workers’ compensation claims will add up to money saved and a better quality of life for all affected.
Hospitalitynet Article: New Regulation To Protect Hotel Housekeepers: Are You Ready?
Cal/OSHA Safety & Health Fact Sheet: Preventing Musculoskeletal Injuries in Housekeepers
Bolton & Company Article: Cal/OSHA: California Hotel Housekeeping Musculoskeletal Injury Prevention Regulation in Effect Now