Check-In Time For Los Angeles County's Hotel Worker Protections Ordinance

Seyfarth Synopsis: The Los Angeles County Board of Supervisors recently passed a Hotel Worker Protections Ordinance for the unincorporated areas of Los Angeles. Beginning April 1, 2026, covered employers will need to comply with new safety mandates, housekeeping workload caps, and overtime limitations. The Ordinance's training requirements will take effect October 1, 2026. This is the latest effort to regulate the hospitality industry within the greater Los Angeles area. Similar ordinances are already in effect in the cities of Los Angeles, Santa Monica, and West Hollywood.

Hotels in the unincorporated areas of Los Angeles County will need to prepare for more than guests checking in when the County's Hotel Worker Protections Ordinance (HWPO) takes effect on April 1, 2026. The County joins Los Angeles, Santa Monica, and West Hollywood in requiring safety measures for covered hotel employees, workload and overtime limitations, and mandatory training.

Who's Covered?

The HWPO broadly applies to all hotels in the unincorporated areas of the County with two limited exceptions:

1. County Waiver: Hotel employers can seek a limited one-year waiver from the Los Angeles County Department of Consumer and Business Affairs if compliance with the HWPO would require the hotel, in order to avoid bankruptcy or closure of the hotel, to reduce its workforce by more than 20% or reduce hotel workers' total hours by more than 30%.
2. CBA Waiver: A collective bargaining agreement can waive the HWPO if the waiver is explicitly set forth in clear and unambiguous terms.

All workers employed by a covered hotel are entitled to the HWPO's protections except for managerial, supervisory, or confidential employees.

Protections From Violent or Threatening Conduct

Covered hotels must provide personal security devices at no cost to employees assigned to work alone in guest rooms or restroom facilities. The devices are intended to be used by employees in the event of conduct involving physical violence or the threat of physical violence that is, or will imminently occur in the employee's presence. With this purpose in mind, the devices must include a panic button that can summon designated hotel security officers, managers, or other supervisory hotel staff who must be available at all times to provide immediate assistance when a device is activated.

If an employee alerts the hotel of a guest's violent or threatening conduct, the hotel must:

1. Allow the employee paid time off to report the conduct and consult with a counselor or advisor of the employee's choosing.
2. Upon request, provide a reasonable accommodation to the employee including a modified work schedule, reassignment to a vacant position, or other reasonable adjustment.

Covered hotels must also (1) post notices in guest rooms and restroom facilities that the hotel provides personal security devices to its employees; and (2) annually train employees on how to use and respond to the devices.

Housekeeping Workload Limitations

Like its neighboring jurisdictions, Los Angeles County caps the amount of space room attendants may clean each day without triggering double-time:

1. Hotels with at least 40 guest rooms: a 3,500 sq. ft. cap per 8-hour workday.
2. Hotels with less than 40 guest rooms: a 4,500 sq. ft. cap per 8-hour workday

These square footage calculations must be prorated for employees who work fewer than eight-hour shifts and for overtime worked. Additionally, the calculations can be impacted by the type of room a room attendant is assigned to clean, including if it has a cot or rollaway bed or is being cleaned due to the guest checking out.

Overtime Limitations

Under the HWPO, covered employees cannot work more than 10 hours in a single workday without the employee's written consent. Employers must give employees at least seven days' notice before seeking the consent that they can refuse to work greater than 10-hour workdays without fear of retaliation.

Training Requirements Beginning October 1, 2026

Beginning October 1, 2026, covered hotel employees must complete at least six hours of live, interactive training from a County-certified training organization addressing:

1. Rights and obligations under the HWPO;
2. Responding to suspected trafficking, domestic violence, or threatening conduct;
3. Cleaning and disease-prevention best practices;
4. Identifying/Avoiding pest infestations; and
5. Recognizing and responding to signs of criminal activity.

After completing the training program, covered employees must take an exam administered by the training organization to obtain a Public Housekeeping Certificate. Employees will be unable to work as a room attendant for more than 120 days without this certification.

Notice and Record Keeping Obligations

Beginning April 1, 2026, covered employers must provide notice to all employees and new hires of the HWPO's requirements. The HWPO also requires covered employers to maintain records for three years of: (1) incident reports for personal safety device activations; and (2) each room attendant's name, rate of pay, pay received, rooms cleaned or total square footage cleaned each workday, overtime hours worked for each workday, and any written consents obtained.

Additionally, hotel employers must keep records demonstrating compliance with the training requirements. However, the three-year duration does not apply to these records.

Available Remedies

The HWPO authorizes the County and private individuals to bring civil actions for noncompliance. Available remedies include damages, injunctive relief, and attorneys' fees and costs for a prevailing plaintiff.

Workplace Solutions

Just like planning for a vacation at your favorite hotel, employers subject to the HWPO should make a compliance plan early. Covered employers may want to consider reviewing personal security device options, updating workplace violence and reporting policies, revising recordkeeping practices, and auditing square-footage and workload capacities of room attendants, among other things. The authors or your favorite Seyfarth attorney are here to help you prepare and advise on compliance with this Ordinance.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.