California’s long-awaited standard on “Hotel Housekeeping Musculoskeletal Injury Prevention” is finally here, coming into effect for California hotels and other lodging establishments on July 1, 2018. The standard is designed to control the risk of musculoskeletal injuries to housekeepers.  The standard applies to “lodging establishments,” such as hotels, motels, resorts, and bed and breakfast inns.

By July 1, covered employers must establish, implement, and maintain a musculoskeletal injury prevention program (“MIPP”) that addresses risk factors specific to housekeepers. The written MIPP may be incorporated into the IIPP or kept as a separate program.  The MIPP must include:

  • Names or job titles of persons with authority for implementing the MIPP at each worksite;
  • A system for ensuring that supervisors and housekeepers follow the safe work practices and implement the controls required by the MIPP;
  • A system for communicating safety and health requirements with housekeepers that is understandable to them;
  • Procedures for identifying and evaluating housekeeping hazards through a worksite evaluation (to be initially completed by October 1, 2018);
  • Procedures for investigating musculoskeletal injuries to housekeepers;
  • Methods or procedures for correcting hazards in a timely manner; and
  • Procedures for reviewing, at least annually, the MIPP at each worksite.

In addition to the MIPP, housekeepers must be trained in:

  • Signs and symptoms of musculoskeletal injuries;
  • The elements of the MIPP;
  • The process for reporting safety and health concerns without fear of reprisal;
  • Good body mechanics and the use of controls in the workplace;
  • The importance of reporting symptoms early; and
  • Practice of using identified controls and tools.

Training must occur when the MIPP is first established, to all new housekeepers and supervisors, to all housekeepers given new assignments for which training was not previously provided, and at least annually thereafter.

To ensure compliance with the new standard, covered employers in California should develop their MIPP by July 1, 2018 and train housekeepers on its contents. In addition, employers should plan to begin conducting worksite evaluations to ensure that they are completed by October 1, 2018.

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Photo of Bradford T. Hammock Bradford T. Hammock

Brad Hammock is a Principal in the Washington, D.C. Region office of Jackson Lewis, practicing exclusively in the safety and health area. He heads Jackson Lewis’ Workplace Safety and Health practice group.

He joined the firm in 2008 after serving for ten years…

Brad Hammock is a Principal in the Washington, D.C. Region office of Jackson Lewis, practicing exclusively in the safety and health area. He heads Jackson Lewis’ Workplace Safety and Health practice group.

He joined the firm in 2008 after serving for ten years as an OSHA attorney within the Department of Labor including, most recently, for more than three years as lead counsel for safety standards. As lead counsel, Mr. Hammock managed attorneys who worked with OSHA on regulatory initiatives, compliance assistance, and enforcement policy. He had direct responsibility for more than 20 major OSHA regulatory initiatives, including rulemakings on personal protective equipment, confined spaces, and crane safety.

Before his promotion to lead counsel, Mr. Hammock worked as a regulatory attorney for OSHA, focusing on ergonomics. He was one of the lead attorneys during the development of the OSHA ergonomics standard in 2000 and had primary responsibility for the Department of Labor’s comprehensive approach to ergonomics in 2002. Mr. Hammock is widely regarded as one of the nation’s most experienced attorneys on ergonomics.

Education

  • University of Virginia/Bachelor of Arts in American Government/1992
  • Syracuse University College of Law/Juris Doctor, magna cum laude/1996

Bar Admissions

  • District of Columbia
  • Virginia