Here is a short summary of five best practices for hotels reopening in Los Angeles (this is just a summary adopted from a presentation I provided to a group of hotel owners, and not a substitute for reviewing the applicable federal, state and local regulations):

1. Highlights from Los Angeles County’s protocol applicable to hotels.

  • Los Angeles County’s reopening protocol requires hotels to provide accommodations for vulnerable staff. It sets forth that vulnerable staff (those above age 65, those who are pregnant, and those with chronic health conditions) should be assigned work that can be done from home whenever possible, and should discuss any concerns with their healthcare provider or occupational health services to make appropriate decisions on returning to the workplace.
  • Hotels need to develop and have a plan in place for positive cases:
    • Isolate themselves; self-quarantine of all employees who had exposure; should consider plan to have quarantined employees tested.
    • If there are 3 or more known cases within 14 days the hotel must report to Dept. of Public Health.
  • Cleaning & Sanitizing: Consider reducing business hours for extra deep cleaning.
  • Written, worksite-specific COVID-19 plan
  • Copies of protocol distributed to all employees
  • Physical distancing:
    • Housekeeping is only performed when guests are not present
    • Elevators limited to 4 individuals or a family at a time and all riders must wear face covering
  • Facility Safety: To the extent possible, log guests: name, phone number and email address
  • Cleaning & Sanitizing: Housekeepers are provided PPE for cleaning.
    • Housekeeping employees are provided gloves when removing dirty linens. Dirty linen is placed in a single-use, sealed bag.
  • Copy of the protocol posted at all public entrances to facility
  • Guests are notified of policies and procedures prior to arrival
  • Signage is posed at the hotel (see examples in protocol)
    • Employee Health & Hygiene: Reinforce employee training on health and safety guidelines with periodic refresher trainings
    • Facility Safety: Log all employees that come on-premise for purposes of supporting public health contact tracing

2. Los Angeles County’s requirements for face coverings in hotels.

Employees

All employees who have contact with the public or other employees during their shift(s) are offered, at no cost, a cloth face covering. The covering is to be worn by the employee at all times during the workday when in contact or likely to come into contact with others. Employees need not wear a cloth face covering when the employee is alone.

Employees are instructed on the proper use of face covering, including the need to wash their face coverings daily.

Housekeepers and others who must enter guest rooms are directed to wear a cloth face covering.

Bellman/Porters are to wear face coverings and utilize gloves when handling guest baggage. Where possible, baggage deliveries are to be placed in the room by the guest.

Guests

Guests must wear face covering in elevators.

Guests are instructed that they must wear cloth face coverings whenever they are not eating and/or drinking; this includes upon entry to the facility, when walking anywhere in the facility, and when using the restrooms. This applies to all adults and to children over the age of 2. Only individuals with chronic respiratory conditions or other medical conditions that make the use of a face covering hazardous are exempted from this requirement.

Customers who refuse to wear a cloth face covering may be refused service and asked to leave.

Guests will be provided face coverings upon entry to the hotel if they do not have one.

3. Los Angeles City Guidelines.

  • Process to log all employees on site
  • If there is a positive case at the hotel:
    • Inform guests (not clear on this requirement)
    • Ensure all those who have come in contact are tested before returning to work
    • If testing is not possible, inform coworkers that had close contact to self-quarantine and self-monitor for symptoms per public health guidance
    • Consider written plan on how to inform coworkers and how they can get tested/self-quarantine
  • Refresher training courses on social distancing, cleaning, and PPE
  • Provide copy of COVID-19 related safety and health plan to employees and document receipt
  • Presumptive case in affected guest room: shall not be returned to service until undergoing an enhanced cleaning and disinfecting utilizing EPA approved products within CDC guidelines, ideally by a licensed 3rd party
  • Examples of signs located at end of guidance: https://corona-virus.la/sites/default/files/inline-files/20200612%20LA%20Resuming%20Operations%20Playbook%20-%20Hotels.pdf

4. Compliance with City of Los Angeles 5-day notice and priority of recall ordinance.

Under City of Los Angeles Ordinance 186602, the City requires covered employers to offer laid off workers their positions or similar positions based on the workers seniority with the employer.  The Ordinance defines “Hotel Employer” as “owner, operator or manager of a residential building in the City designated or used for public lodging or other related service for the public and either contains 50 or more guestrooms or has earned gross receipts in 2019 exceeding $5 million.  A Hotel Employer includes the owner, operator, manager or lessee of any restaurant physically located on hotel premises.”

Workers have no less than 5 business days to accept or decline the offer for the position.

5. To the extent a hotel operates another facility, such as a restaurant or golf course, the applicable protocol for those industries must also be followed.

County of Los Angeles protocol for in-person dining: http://www.publichealth.lacounty.gov/media/Coronavirus/docs/protocols/Reopening_Restaurants.pdf

County of Los Angeles protocol for golf courses: http://www.publichealth.lacounty.gov/media/Coronavirus/docs/protocols/Reopening-GolfCourses.pdf

The City of Los Angeles website:  https://corona-virus.la/Business

City of Los Angeles Protocol for restaurants: http://publichealth.lacounty.gov/media/coronavirus/docs/protocols/Reopening_Restaurants.pdf