Primary Requirements. 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 and risk revaluated 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.

 

Training Requirements

 

An “Extensive Training Requirement” is part of the MIPP. It encompasses current and new hires, annual training, change of equipment or job duties, injury recognition and reporting, and training of Supervisors.

All Housekeepers, including their Managers and Supervisors, shall have training and instructions on general and Musculoskeletal Injury Prevention and health practices. Housekeepers and Supervisors shall receive training as follows:

• When the MIPP is first established
• To all new Housekeepers and Supervisors
• To all Housekeepers given new job assignments for which training was not previously provided
• At least annually thereafter
• When new equipment or work practices are introduced
• Whenever the employer becomes aware of a new or previously unrecognized hazard

Training must include, “At a Minimum,” the following elements as applicable to the Housekeeper’s assignment:

• The signs, symptoms, and risk factors commonly associated with MSI (MSD)
• The elements of the employer’s MIPP and how the written MIPP and all relevant records will be made available to Housekeepers
• A system and process for reporting safety and health concerns without fear of reprisal
• Effective body mechanics and safe work practices, including:
  • Identified hazards at the workplace
  • How those hazards are controlled during each housekeeping task
  • The appropriate use of cleaning tools and equipment
  • The importance of following safe work practices and using appropriate tools and equipment to prevent injuries
    
• The importance of, and process for early reporting of symptoms and injuries to the employer
• 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 with a person knowledgeable about Hotel housekeeping equipment and procedures
• Training of Managers and Supervisors on:
  • How to identify hazards
  • Hazard correction procedures
  • How defective equipment can be identified and replaced
  • How to obtain additional equipment
  • How to evaluate the safety of Housekeepers’ work practices
  • How to communicate effectively with Housekeepers regarding any problems needing correction

 

Compliance

 

• The employer must have a system and process which ensures Housekeepers comply with the MIPP
• Utilize tools, use them in the correct manner, follow safe work practices and use the body mechanics skills learned during training

Recordkeeping

 

• 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.

 

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Click here to view Cal/OSHA’s Musculoskeletal Injury Prevention Program Regulation.