“Nothing About Us Without Us”: OEHS in Adult Entertainment
This blog post is based on a presentation given by Eva Glosson and Venetia Runnion at AIHce EXP 2022. An expanded version was published in AIHA's 2022 ebook, The Essentials of OEHS Communication.
Like all workers, workers employed in strip clubs—including entertainers colloquially referred to as strippers or dancers—have the right to safe, healthy workplaces. But implementing OEHS programs in strip clubs is complicated by factors including entertainers' status as contractors and the stigma surrounding their work.
In December 2018, a group of entertainers testified before the Washington State Labor and Workforce Standards Committee. They asked for more regulation and better worker safety training and were concerned about bloodborne pathogens and violence in their workplaces. Accordingly, the Washington State Department of Labor and Industries Division of Occupational Safety and Health (DOSH) developed a local emphasis program to investigate hazards in 10 strip clubs in King County, which includes the cities of Seattle and Renton.
Industrial Hygiene Compliance Manager Venetia Runnion, CIH, CSP, led the program, and Eva Glosson, MS, was another key participant. Runnion and Glosson spoke about their work at AIHce EXP 2022 in a session titled "Revealing Exposures: Safety and Health in the Adult Entertainment Industry."
Challenges to Protecting Entertainers
One consideration for implementing and enforcing OEHS programs in strip clubs is that not every club is the same. Laws governing strip clubs are based on municipal codes, and what's considered permissible varies by locale.
Another important factor is that most entertainers are technically contract workers. They pay house fees to the club that, in essence, allow them to rent the club's stage as a place to dance. Entertainers aren't paid directly by the club but receive wages in the form of tips from patrons. There is often confusion as to whether club owners have the obligation to record entertainers' injuries and illnesses or provide them with safety training, as well as whether entertainers have the right to complain.
Before DOSH's local emphasis program, one of the large Seattle area strip clubs was investigated for failing to cover entertainers' occupational injuries under the state's insurance plan. The club's owners argued that entertainers were not eligible, as they were independent contractors and not employees. However, DOSH ruled that entertainers may consider themselves contractors because they were paid by club patrons and not club management, but they were, essentially, club employees because they performed services controlled by the club. The club couldn't exist without them.
The Work Environment and Hazards
Although considered part of the sex industry, a strip club sells patrons entertainment and the experience of a fun night out more than it sells nudity. Entertainers don't only dance or remove their clothing. They're also not the only workers who make strip clubs successful businesses. Other club employees may include security guards, door personnel or cashiers who check IDs and take entry fees, servers who bring patrons food or drink, DJs who provide music, floor watchers who make sure everyone behaves safely, managers, and administrators who handle payroll, taxes, and other business functions.
The environment in a strip club is similar to that of a nightclub, with loud music, dark walkways, and bright stage lighting. Patrons who have paid their admission fees enter the main floor, where they enjoy food or drink (depending on what's permissible under local codes), watch entertainers dance on the main stage, or meet entertainers not engaged in dancing.
The main stage typically features one or two poles. It's critical that these poles are installed by knowledgeable parties to prevent injury to entertainers and patrons. Aside from traumatic injuries resulting from falls, poles can present a number of other hazards. Novice entertainers can injure themselves while learning techniques, and experienced entertainers can re-injure themselves without proper care. Some poles spin or rotate, and spins can be jarring to entertainers' visual and vestibular systems. Other hazards that may be encountered on the main stage and in its vicinity include low levels of light, noise levels exceeding 85 decibels, and slip, trip, and fall hazards.
The entertainers who testified in 2018 were concerned with bloodborne pathogens because the reality of the strip club environment is that some patrons will ejaculate. During inspections, the DOSH team learned that semen was more likely to be encountered in the club's private VIP rooms and a little less likely to be found in semi-secluded areas. Uncontained ejaculate creates bloodborne pathogen hazards for entertainers, janitorial workers, other staff, and other patrons. These hazards must be cleaned, and club management should provide hepatitis B vaccines to entertainers and other staff.
The club's more secluded areas are also where entertainers are at the greatest risk of encountering violence. According to Glosson, the potential for violence in strip clubs is a commonly voiced concern, although violence may occur in any workplace. Prior to beginning the investigation, Runnion found that the Seattle Police Department had responded to 137 calls concerning strip clubs in 2018. The most serious of these incidents involved patrons with weapons who were angry at club management, patrons who threatened door personnel, and patrons who assaulted entertainers. Sometimes club management sided with patrons during these altercations, and entertainers were generally told not to report these incidents—in violation of DOSH requirements.
While higher-quality clubs accommodated entertainers with lockers, on-site laundry facilities, break rooms, and robes to wear when not performing, DOSH found that less reputable establishments sometimes failed to provide working sinks and toilets, soap, water, or toilet paper. Sometimes entertainers' bathrooms lacked doors or there were no separate facilities for patrons and entertainers. Needless to say, these clubs violated DOSH regulations.
DOSH also found smoking rooms and porches, despite local codes prohibiting smoking in clubs or within a certain distance of the facility.
Finally, entertainers may become dehydrated, especially if they haven't taken breaks. In addition to having opportunities to rehydrate, entertainers need to guard their drinks against attempts by patrons to surreptitiously administer incapacitating drugs.
The Local Emphasis Program
DOSH's team of six women industrial hygienists, including Runnion and Glosson, began by inspecting clubs one Friday evening. Although the compliance officers tried to be discreet, they still stood out due to the clipboards they carried and the blacklights they used to check for bloodborne pathogen hazards. Several entertainers who worked in the clubs took to social media after the inspections to express their belief that the businesses had been targeted by FBI sting operations—evidence of the mistrust that often develops between adult entertainers and outsiders, particularly individuals associated with government.
"Unsurprisingly," said Runnion, "none of the clubs had been inspected before, likely because entertainers and other employees didn't know they had the right to complain." All 10 clubs received citations and notices for penalties ranging from $7,000 to $40,000, depending on the size of the club. However, the intent of the local emphasis program wasn't only to penalize the clubs. Visiting the clubs helped DOSH staff understand the reality of entertainers' work, the hazards they faced, and how to address them with controls tailored to the environment.
For example, the DOSH team assisted the clubs in creating a protocol for identifying and cleaning stains caused by semen. They found that under ultraviolet light, semen fluoresces and can be seen by a person wearing yellow or orange eyeglasses—but so can other liquids, such as spilled drinks. Identifying semen required knowledge of the workplace, including areas where ejaculation was likely to occur, common areas of deposit, and splatter patterns. DOSH also found a presumptive test that could positively identify semen. Meanwhile, the team found the chemical luminol, which glows blue when mixed with an oxidizing agent, to be ineffective and messy, leaving a sticky residue where it was applied.
Under the local emphasis program, club management underwent bloodborne pathogen training and was taught the importance of sanitizing surfaces and offering hepatitis B vaccinations to prevent infections among workers. All 10 clubs now have their own blacklights, bloodborne pathogen kits, and a protocol for cleaning "spill events." After an entertainer reports an event to management, management makes sure they don't need medical care, escorts the responsible patron off the property, and cleans the mess.
DOSH also helped the clubs evaluate the most effective protocol for cleaning dancing poles. They found that cleaning with isopropyl alcohol and a microfiber cloth, while allowing adequate contact time for the alcohol to work, was effective to remove oil and residue and disinfect the poles between sets.
The local emphasis program also addressed entertainers' concerns about occupational violence. Washington Administrative Code 296-831, promulgated as a result of the program, requires panic buttons to be installed in all areas where entertainers could be alone with patrons and for entertainers to be taught how to use them. The code also stipulates that clubs maintain lists of patrons who have committed acts of violence against entertainers. Offending patrons must be banned from all clubs for five years.
The logistical and legal challenge of enforcing health and safety training requirements for independent contractors was overcome by adding a training requirement to entertainers' annual license renewal. Entertainers must be licensed by each municipality where they work and renew their license each year. The training ensures entertainers understand that they have the right to a safe and healthy workplace.
Glosson and Runnion briefly discussed controls for additional hazards, including:
- LED strip lights installed on stairs, corners, and the edge of the main stage to help entertainers navigate dark areas and avoid falls
- collaboration between management and DJs to ensure that speakers are not pointed toward entertainers and that music volume is reduced when the crowd is energized
- frequent check-ins to ensure entertainers take breaks and are hydrated between songs
- maintaining separate sets of barware or glasses for entertainers and patrons to ensure drinks don’t get swapped
Controls such as these are tailored to allow the club to be a high-energy environment where patrons can have fun while entertainers work safely. All staff members’ responsibility to keep each other safe is a key component.
"Nothing About Us Without Us"
"Nothing about us without us" conveys that any policy must be created with the full participation of the community affected by that policy. This phrase entered U.S. political discourse in the 1990s with disability rights activist James Charlton's book by the same name, and it's since been adopted by a range of stigmatized and marginalized communities.
Runnion and Glosson both described the local emphasis program as a resounding success, not only because all code violations were abated, but because the principle of "nothing about us without us" was followed during hazard abatement and the development of Engrossed House Bill 1756, which codified protections for adult entertainers. DOSH worked with entertainers to develop the bill's new training program. HB 1756 also directed the creation of an advisory committee to help implement the bill's safety and training requirements and consider additional measures. At least half of the members of this committee must be current or former licensed entertainers for at least five years, and at least one member must represent an adult entertainment establishment that is licensed and operating in Washington.
Efforts toward inclusion will not go unappreciated by affected workers. Runnion explained that she considered the local emphasis program for strip clubs one of the most rewarding in her career because entertainers thanked her personally for making a difference. "And that's why we're all in this field," she added.
Further reading: Eva Glosson is also the author of "Revealing Exposures: Health and Safety Concerns in Strip Clubs" in the April 2022 Synergist, "Last Day on the Job: Workplace Violence and Occupational Homicide" in the May 2023 Synergist, and "Mortal Exposures: Industrial Hygiene in the Death Care Industry" in the March 2019 Synergist.
Glosson, Eva, and Runnion, Venetia. "Revealing Exposures: Safety and Health in the Adult Entertainment Industry." AIHce EXP, AIHA, May 24, 2022, virtual. Conference Presentation.
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