I own a small motel and bed and breakfast. How are the new regulations adopted by the Occupational Safety and Health Standards Board (OSHSB) for musculoskeletal injury prevention going to affect my business?
Housekeepers in lodging establishments such as hotels, motels, resorts, and bed and breakfast inns will be affected by the new requirements for a hotel housekeeping musculoloskeletal injury prevention program (MIPP), which have been added to the General Industry Safety Orders as Section 3345 and will take effect July 1.
Lodging establishments not affected include prison or jail facilities, medical facilities or nursing homes, residential communities, homeless shelters, boarding schools, or worker housing.
The MIPP is to be in writing and may be incorporated into the written workplace Injury and Illness Prevention Program (IIPP) or maintained as a separate program. The MIPP is to be readily accessible to the affected employees in the establishment where they work.
The primary requirements for the MIPP are like those for the IIPP. The MIPP must:
• Include the name or job title of the person or persons responsible for implementing the MIPP.
• Have a system to ensure all persons affected by the MIPP comply and follow the employer’s safe workplace housecleaning practices and use the appropriate tools to safely accomplish the required tasks.
• Have a system to communicate with housekeepers on matters of occupational safety and health that is readily understandable and to encourage the housekeepers to inform the employer of worksite hazards.
• Develop procedures for identifying and evaluating housekeeping hazards, initially to be accomplished within three months after the effective date of this regulation or after the opening of a new lodging establishment. The employees and their union representative will be involved in this process. The worksite evaluation will be reviewed periodically and updated as necessary as stated in the regulation, but will be reviewed at least once a year.
• Include procedures to investigate musculoskeletal injuries of housekeepers. There will be input from the injured, the union representative, and immediate supervisor.
• Include methods or procedures for correcting observed and identified hazards from injury investigations. An effective means of involving the employees and the union representative to assist in identifying and possible corrective measures will be provided.
• Establish procedures to review the MIPP at least annually to determine its effectiveness and make changes if necessary. Housekeepers and their union representative are to be involved in the process.
An extensive training requirement is part of the new MIPP. It encompasses new hires, annual training, change of equipment or job duties, injury recognition and reporting, and training of supervisors.
The employer must maintain records of the steps taken to implement and maintain the MIPP. All worksite evaluations are to be maintained in accordance with Section 3203(b), part of the IIPP.
A complete copy of the MIPP regulation can be found on the Cal/OSHA Standards Board website at www.dir.ca.gov.
Column based on questions asked by callers on the Labor Law Helpline, a service to California Chamber of Commerce preferred and executive members. For expert explanations of labor laws and Cal/OSHA regulations, not legal counsel for specific situations, call (800) 348-2262 or submit your question at www.hrcalifornia.com.