Information contained in this publication is intended for informational purposes only and does not constitute legal advice or opinion, nor is it a substitute for the professional judgment of an attorney.
On July 1, 2018, the newly implemented Hotel Housekeeping Musculoskeletal Injury Prevention Program (MIPP) regulation took effect.1 This program requires all California hotel/motel employers to institute and maintain written policies and training practices regarding housekeeping-related workplace hazards. The new Cal-OSHA regulation, which is intended to prevent and reduce work-related injuries to housekeepers in the hospitality industry, specifically requires that the MIPP be part of the employers Injury Illness and Prevention Program (IIPP) and that it be in writing, readily accessible to employees during their shift, and include the following components:
- Procedures for identifying and evaluating housekeeping hazards through a worksite evaluation. The initial worksite evaluation must be completed by October 1, 2018, or within three months after the opening of a new lodging establishment. The procedures must include an effective means of involving housekeepers and their union representative in designing and conducting the worksite evaluation. Additionally, the employer must notify housekeepers of the results of the evaluation in writing or by posting it in a location readily accessible to them. The results of the worksite evaluation must be in a language easily understood by housekeepers. Evaluations must be reviewed and updated at least annually and whenever new processes may change or increase housekeeping.
- Procedures to investigate musculoskeletal injuries to housekeepers. These procedures may include reviewing housekeeping tasks that are performed and tools and equipment used, in addition to eliciting input from the injured housekeeper, the housekeeper’s union representative and the housekeeper’s supervisor regarding injury prevention.
- Methods or procedures for correcting hazards. The employer must describe how it will correct, 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.
- Procedures for review. Employers must identify how they will review, 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 MIPP also requires that employers provide specific training to all housekeepers and supervisors in a language easily understood by these employees. At a minimum, training must include the signs, symptoms, and risk factors commonly associated with musculoskeletal injuries; the elements of the employer's MIPP and how records will be made available to housekeepers; a description of body mechanics and safe practices; the importance of early reporting; 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; and additional training of supervisors.
Finally, the MIPP requires that employers maintain records of the steps taken to implement and maintain the MIPP, including any measurements taken or evaluations conducted in the worksite evaluation process and training. Additionally, a copy of the MIPP and all worksite evaluation records must be available at the worksite for review and copying by housekeepers and their designated representative.
Hotel and motel and other businesses in California that employ housekeepers should immediately update their Injury Illness and Prevention Programs to include a MIPP. This can be done by integrating the MIPP into the IIPP, or creating a standalone MIPP, which is incorporated by reference. Employers should also immediately implement the MIPP and provide training to both housekeeping personnel as well as supervisors and other management employees as required by the regulation. Training records showing the training took place should also be updated.
1 Title 8 Code of Regulations Section 3345.