OSHA settlements as guides for best practices: Local, national and international potential impacts

Over the past three years, OSHA complaints filed by female hotel housekeepers resulted in a series of actions by state and federal OSHA agencies that have evolved from hazard letters with recommendations to most recently a settlement between CalOSHA and a hotel employer at one specific hotel property that includes enforcement. Some background is provided: 1) in 2010, housekeepers filed OSHA complaints in 8 cities against 13 hotel properties of the same hotel company. Three state OSHA plans issued hazard letters that identified injuries due to repetitive motion hazards of hotel housekeeping and recommended control measures for specific hotel properties; 2)in April 2012, federal OSHA issued a corporate-level letter related to inspections at four hotels that identified ergonomic risk factors associated with housekeeping tasks "such as repeated heavy lifting and carrying,bending, twisting, elevated and extended reaches, pushing and pulling, and forceful gripping" and included recommendations for hazard control; and 3)the 2012 CalOSHA and hotel employer settlement that included the use of job task analysis, controls, interventions such as a housekeeping committee to prevent housekeeper injuries. Can the above recommendations/controls in the form of hazard letters/settlement be considered "best practices"? If so, are these best practices applicable beyond the particular hotel property for which they were specified? Can these best practices become not only corporate-level practices in the U.S. but global best practices world-wide? How many women working as housekeepers could potentially be affected? This presentation will seek to answer these questions and generate a robust dialogue with session attendees.