Human Trafficking Training for Hotels: What, How, Why
Despite crossing paths with hotel staff, nearly all victims indicated that they never received any assistance. In this blog, we’ll unpack what human trafficking training requirements exist today for hotels.
After assessing a decade worth of statistics, the Polaris Project found that 75% of human trafficking survivors reported coming into contact with hotels at some point during their trafficking situation.
Despite crossing paths with hotel staff, nearly all victims indicated that they never received any assistance.
This has led to a series of state laws requiring hotels to either display awareness posters or provide training to their staff on how to identify signs of human trafficking.
In this blog, we’ll unpack what human trafficking training requirements exist today for hotels.
State Laws for Loding & Hospitality Industries
In addition to criminal liabilities, States may mandate awareness posters for lodging facilities and training requirements for hospitality industry employees in an effort to combat human trafficking.
Let’s look at the characteristics of these legislative efforts.
Human Trafficking Awareness Posters
Nearly half of the United States have laws mandating the use of human trafficking awareness posters for hotels.
Instead of mandating this requirement for all hotels, some states have elected to extend their requirement only to those found to be a public nuisance.
Kansas only applies its requirement to “Adult Motels”, which offer stays of less than 10 hours. New Mexico applies its requirement to any business subject to the minimum wage act. Texas and North Carolina extend their requirements to businesses with Alcohol Licenses.
Some of these laws contain specific requirements that govern the languages specified on the signage, poster size, font size and the text contained. Most states that mandate specific languages chose English and Spanish but Louisiana also mandated Louisiana French.
Maryland only requires signs to be 3” x 5” while every other state that mandates their size sets 8.5” by 11” as the minimum poster size. Florida has the largest minimum size requirement of 11” x 15”. Florida also has the largest mandated font size of 32 pts, while most other states require only 14 pts to 16 pts.
Laws Governing Signage by State
- English & Spanish languages with a minimum size of 8.5” x 11”, no font specifications.
- Specific text to display & specific posters required: English Poster; Spanish Poster.
- English & Spanish languages with a minimum size of 8.5” x 11”, no font specifications.
- Specific text to display & specific posters required: English & Spanish Poster.
- English & Spanish languages with a minimum size of 8.5” x 11”, 16-point font size.
- Specific text to display but no specific posters required.
Connecticut General Statutes 54-222 & 54-234a
- No languages specified, no minimum poster size, no minimum font size.
- Specific text to display & specific poster required: Multilingual Poster.
- No languages specified, no minimum poster size, no minimum font size.
- Specific text to display & specific poster required: English Poster; Spanish Poster.
- English & Spanish languages with a minimum poster size of 11” x 15”, 32-point font size.
- Specific text to display but no specific posters required.
- English & Spanish language with a minimum size of 8.5” x 11”, 16-point font size.
- Specific text to display, model Multilingual Poster.
- English & Spanish language with a minimum size of 8.5” x 11”, no minimum font size.
- Specific text to display, model English Poster.
Illinois Statute 775 ILCS 50/5(c)
- English & Spanish language with a minimum size of 8.5” x 11”, 16-point font size.
- Specific text to display but no specific posters required.
- English & Spanish language with no minimum poster size and no minimum font size.
- No specific text to display, model English Poster; Spanish Poster.
- English, Spanish & Louisiana French with a minimum size of 8 ½” x 11”, 14-point font size.
- Specific text to display, but no specific posters required.
- No languages specified, no minimum poster size, no minimum font size.
- Specific text to display, and multiple posters to choose from.
Maryland Business Regulation 15-207
- English & Spanish language with a minimum size of 3” x 5”, no minimum font size.
- Specific text to display, model full-size poster, half-size poster, 3” x 5” poster.
Michigan Compiled Laws 752.1033 & 752.1035
- English & Spanish language with a minimum size of 8 ½” x 11”, 14-point font size.
- Specific text to display, model English Poster; Spanish Poster; additional languages.
- No languages specified, no minimum poster size, no minimum font size.
- No specific text to display, model English Poster (page 18)
- English & Spanish languages with a minimum size of 8 ½” x 11”, no minimum font size.
- Specific text to display, model English & Spanish Poster
New Jersey Admin Code 5:10-29.1
- No languages specified, no minimum poster size, no minimum font size.
- No specific text to display, specific poster required English Poster; Spanish Poster
- English & Spanish languages with a minimum size of 8 ½” x 11”, no minimum font size.
- Specific text to display, model English Poster; Spanish Poster; Navajo Poster
New York General Business Law 206-F
- No languages specified, no minimum poster size, no minimum font size.
- No specific text to display, model English Poster; English Index Card; Additional Languages
North Carolina Statute 108B-1003
- No languages specified, no minimum poster size, no minimum font size.
- No specific text to display, English, Spanish & Arabic Posters
Pennsylvania Statutes 1492 & 1493
- English & Spanish languages with a minimum size of 8 ½” x 11”, no minimum font size.
- Specific text to display, model English Poster; Spanish Poster
Rhode Island General Law 11-67.1-20
- No languages specified, no minimum poster size, no minimum font size.
- Specific text to display but no specific posters required.
- English & Spanish languages with a minimum size of 8 ½” x 11”, 16-point font size.
- Specific text to display, model English & Spanish Poster
Texas Alcoholic Beverage Code 104.07
- English & Spanish languages with a minimum size of 8 ½” x 11”, no minimum font size.
- Specific text to display but no specific posters required.
- English & Spanish languages with a minimum size of 8 ½” x 11”, no minimum font size.
- No specific text to display, model English & Spanish Poster
Employee Training Requirements
Seven states and two cities currently require hotel workers to take training about human trafficking. Virginia will become the eighth state on January 1, 2023.
About half the country offers training from the state that hotels and other at-risk businesses with high statistical incidences of human trafficking can take for free voluntarily.
Although voluntary, if hotels don’t receive a certification for training all staff under Iowa’s law, no state employee can use public funds at their facility.
Arizona is the only state to offer training as a mitigating factor in the event of a conviction at their facility.
Of those that do require training, Connecticut and New Jersey mandate hotel workers to complete the training created by the state.
Virginia will follow suit with a state-created training course. Florida, Minnesota and Baltimore (MD) provide guidelines on what to include in the training. California, Illinois, Texas and Houston (TX) provide guidelines as well but also incorporated a minimum training time requirement of 20 minutes.
When looking at the requirements within the four states and one city that provide them, we found the following…
- Definition of human trafficking and commercial exploitation of children. (CA) (FL) (IL) (TX) (Houston)
- Guidance on how to identify individuals who are most at risk for human trafficking. (CA) (IL) (MN) (TX) (Houston)
- The difference between labor and sex trafficking specific to the hotel sector. (CA) (FL) (IL) (MN) (TX) (Houston)
- Guidance on the role of hospitality employees in reporting and responding to this issue. (CA) (FL) (IL) (MN) (TX) (Houston)
- The contact information of appropriate agencies, including, but not limited to, the National Human Trafficking Hotline and the telephone numbers of the appropriate local law enforcement agencies. (CA) (TX) (Houston)
- Activities commonly associated with or how to recognize human trafficking (FL) (MN)
- Experience of human trafficking victims (TX) (Houston)
- How and why human trafficking takes place in the hospitality industry (TX) (Houston)
- If online, a pacing mechanism requiring the trainee to complete all coursework (TX) (Houston)
Laws Governing Training by State
California Senate Bill No. 970
- The minimum training time of 20 minutes, training should cover specific content.
- Training should occur once every two years, with no requirements to retain or submit records.
- Course provided by the state.
- Training should occur once every year, and records retained in the employee file.
- No minimum training time, training should cover specific content.
- Training should occur once every year, and records made available by state request.
- Minimum training time of 20 minutes, training should cover specific content.
- Training should occur once every two years, no requirements to retain or submit records.
- No minimum training time, training should cover specific content.
- Training should occur once every year, and records retained in the employee file.
- Course provided by the state.
- Training should occur once, and records retained in the employee file.
- Minimum training time of 20 minutes, training should cover specific content.
- Training should occur once every year, and records made available by state request.
- Course provided by the state.
- Training should occur once every two years, and records retained in the employee file.
- No minimum training time, training should cover specific content.
- Training should occur once every two years, no requirements to retain or submit records.
Houston (Texas) Ordinance 28-212
- Minimum training time of 20 minutes, training should cover specific content.
- Training should occur once every year, records made available by city request.
Conclusion
Hotel operators and employees are on the front line in the battle against human trafficking.
Although slight variations exist amongst state laws mandating the display of informational posters and awareness training, there’s an underlying theme that remains the same.
Having a staff that knows who to look for, what to look for, and how to respond is the most effective way to intervene and save those who are unable to free themselves.
As Etactics continues to provide resources helping organizations remain compliant, we turned to a subject matter expert, Bill Woolf, to help us create a more effective and impactful training course on human trafficking awareness for hotels. In his 15 years of experience combating human trafficking, Bill has found the most effective way to train citizens is through scenario-based training.
In June of 2022, Etactics and Bill Wolf partnered to produce a scenario-based training course for hotel operators and law-enforcement. This training will be available by August 2022 through the Etactics Learning Management system K2 Akademy.
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