The hotel industry is on the radar of the Occupational Safety and Health Administration. Attention was amped up in October 2010, when OSHA launched a Local Emphasis Enforcement Program (LEP) for Virgin Island hotels. The area’s hotels came under OSHA scrutiny because they recorded a significant number of workplace injuries.

With OSHA taking a proactive stance, that attention — and associated inspections — will likely spread into other parts of OSHA Region 2, including New York, New Jersey and Puerto Rico, says Eric J. Conn, who leads the OSHA practice group of Epstein Becker & Green in Washington, D.C. It could spread, he suggests, throughout the country.

While he doesn’t have a crystal ball, Conn says “I know that they’re doing inspections pursuant to employee complaints across the U.S. This may have been a pilot program. Before they [OSHA] launch a more broad emphasis, they usually start in one local area to work out kinks and find out if it’s useful. If they find the hazards they are expecting, they go broader.”

He attributes OSHA attention to Unite Here complaints to the agency in late 2010. At that time housekeepers at 12 Hyatt hotels reported to OSHA they were sustaining repetitive motion and other injuries on the job.

Conn’s colleague and firm associate Casey M. Cosentino speculates that some of the complaints were a union-organizing ploy. Regardless of their political intent, they got the attention of OSHA and hotels must take notice.

That includes double-checking OSHA compliance. “The best time to avoid an OSHA citation is before it’s issued,” says Cosentino, “to be prepared in advance for an inspection.”

Conn notes, “The frequently cited standards are a good place to start to be sure your programs are in compliance.”

Among the top issues, for example, are electrical and fire safety. That means assuring exits are adequately marked and lit, exit pathways are clear and fire extinguishers are checked periodically. Hazard communication should be another top priority, Conn adds.

The number of significant hospitality citations nationwide in 2010, by order of importance reported by OSHA, include:

• Electrical Safety
• Hazard Communication
• Personal Protective Equipment
• Bloodborne Pathogens
• Respiratory Protection
• Asbestos
• Lockout/Tagout
• Recordkeeping — Annual Summary

While it’s last on the list, recordkeeping is the place a hotel should examine first, he says. “Are you keeping an OSHA log? Is it up to date and accurate? It’s the first thing they’ll look at. You can either set a good first impression or bad first impression,” says Conn.

Previous violations are an important place to start. They carry more serious penalties. Beware that they can be decidedly unfair. If a sister facility — under the same flag, though not under the same ownership or management — is cited once, you’re violation could be considered a second.

“They’re treating multiple workplaces as part of a single entity,” says Conn.

For example, say a Hampton Inn outside Chicago is cited for a minor electrical violation. Then, a year later, a Hampton Inn in suburban Rochester, NY, is cited for a similar issue. The second Hampton — despite a lack of ownership/management connection — would be considered a second offense because it bears the same franchise flag.

“My expectation is it’s not going to change soon,” he says. “The agency changes it philosophy every four or eight years. The tenor could change in the next couple of years, depends on who appoints the secretary of labor. Right now [OSHA] is very aggressive.”