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Case study · Compliance training · Hawaii hotels

Hotel staff training for Hawaii’s new trafficking law

For guest-facing staff at a Waikiki hotel with high staff turnover.

Portfolio build · Fictional hotel · How AI was used

  1. ProblemHawaii’s Act 191 (2026) requires hotels to train every guest-facing worker within 180 days of hire and every two years. With monthly turnover it never ends, and staff who confront can make things worse.
  2. BuiltA slide course: four places in a hotel, three moves (notice it, don’t confront, report it). The kind-hearted risky choice fails, in scenes and in the test. Plus records, a roster, a policy and a sign.
  3. ResultMapped to the Act’s five content parts, with every law and number checked at its source.

What this shows

  • Turning a new law into behaviors, practice and a compliance map
  • Scenario design for a sensitive topic: signs are behavior, not looks, and no heroics
  • Designing for turnover: completion records, 180-day and two-year due dates, and a demo roster that works them out
  • Reusing my own course engine, with accessible HTML and JavaScript

Tools

Action mapping (Cathy Moore) · LTEM · HTML, CSS and JavaScript, no framework · xAPI-style tracking · axe-core

Try it The manager’s roster

40 to 55 minutes in six short sittings, on a phone or a computer. In a hurry? Open any lesson from the training map, or unlock the test there.

The problem

A new law, and staff who change every month

Traffickers use hotel rooms because they are private and paid by the night. Workers can be exploited inside hotels too, often through recruiters and staffing agencies. The people most likely to notice are the hotel’s own staff: the front desk, housekeeping, the valet.

In July 2026 Hawaii made training them a legal duty, starting in 2027. Under Act 191 (HB 1960), every hotel employer, and every staffing contractor that places workers in hotels, must:

  • adopt a prevention and reporting policy by September 1, 2027;
  • train each worker who has contact with guests or access to guest rooms within 180 days of hire, and every two years after, starting by December 1, 2027;
  • post signs in English and any language spoken by at least 10 percent of staff by January 1, 2028;
  • keep records of who was trained.

Each violation can cost up to $100 a day. The training must be the Attorney General’s program, due by July 1, 2027, or one the Attorney General approves. Only a hotel or a staffing contractor can submit one.

For a small hotel with high turnover, the hard part is not the first training day. Every new hire starts a new 180-day clock. The other hard part is behavior: a worker who wants to help may question a guest in front of the person in control, slip a note into the towels, or knock on a door. Each of those can put the person at risk.

Where training can help, and where it can’t

Staff don’t know the signs, or judge by looks

CauseKnowledge. Assumption: common lists mix behavior with appearance, and staff fill the gaps with guesses about accent, age or nationality.

What fixes itTraining: a picture of each place, signs sorted by who they’re about, and cards that are “not a sign on its own.”

They help in a way that does harm

CauseSkill under pressure. Per the federal guidance, the kind-hearted move, asking “are you okay?” in front of him, is the dangerous one.

What fixes itTraining: scenes where that choice plays out and fails, then the learner chooses again.

They wait to be sure, or don’t want to cause trouble

CauseMotivation. Fear of being wrong about a guest.

What fixes itTraining shows that certainty isn’t needed and that the law protects good-faith reports. The hotel has to back it up: no blame for a good-faith report.

Nobody to tell, or new hires slip past day 180

CauseEnvironment. No named person on each shift, and no system that tracks hire dates.

What fixes itThe hotel, not the course: a policy, a manager or security person on every shift, and records. The kit supports this with a roster and a policy template.

Audience

Busy, new, and often working in a second language

Who

Everyone at the hotel who meets guests or goes into guest rooms: front desk, bell and valet, concierge, housekeeping, room service, maintenance and security. That includes contract housekeepers placed by an agency. The hotel, the Seabright, and its people are fictional.

What they already know

Assumption: the building and the guests. Most have heard the word “trafficking,” often from news stories about strangers and borders. Few know what to do on a shift, or what not to do.

What they’re up against

A phone, a few minutes between tasks, and a deadline of day 180. Assumption: many speak Ilocano or Tagalog at home, two of Hawaii’s three most common home languages after English. Some may have lived through exploitation themselves.

Action map

From the hotel’s goal to what a worker does on a shift

Business goal

Every guest-contact worker notices the signs, keeps the moment safe, and reports the same shift. Every worker is trained by day 180 and every two years, with records to show it.

Measured by the share trained by day 180, whether staff report and how well (the same shift, with facts, never on looks), and a monthly spot check: the manager asks three staff “Who do you tell tonight, and what do you say?” Baseline: unknown, no client. Target: 100 percent by day 180, and three of three in each spot check. Fewer reports is not success on its own: a drop to none is a warning sign. Projected
  1. Behavior 1

    Judges by what people do, never by looks

    Reports a guest who can’t speak for herself; doesn’t report a couple for their accent.

    Practice
    • Break-room scene: a coworker wants to knock on a door because a guest “looks foreign”
    • Sign-or-not cards
    Minimum information
    • Force, fraud or coercion
    • A minor in commercial sex
    • Behavior versus looks
  2. Behavior 2

    Keeps the moment normal

    Checks the guests in as usual; hands over the towels and says “no problem.” Doesn’t question, search, photograph or rescue.

    Practice
    • The 11 p.m. check-in
    • Room 514: “No service. Just towels.”
    Minimum information
    • Why confronting puts the victim and the worker at risk
    • Do your normal job
  3. Behavior 3

    Reports the same shift, with facts

    Tells the manager on duty or security: room, time, what was seen, what they did. Calls 911 when someone is in danger now.

    Practice
    • Write the report for room 512
    • The elevator at 1 a.m.: a girl of about 14
    Minimum information
    • Who to tell
    • The four parts of a report
    • 911 for danger now
  4. Behavior 4

    Helps a coworker safely

    Notices held passports and debts; tells the manager on duty before the shift ends; says the hotline number in private. Doesn’t confront the agency.

    Practice
    • Explore the staff entrance
    • What Lina said in the linen room
    Minimum information
    • Labor trafficking signs
    • The hotline: confidential, not police or immigration

Cut because no behavior needs it: federal statute numbers, the history of trafficking, prevalence statistics (none are reliable for Hawaii), and how investigations work. Full action map.

The 12 skills: four places, three moves

The 12 skills the course teaches and tests
PlaceNotice itDon’t confrontReport it
Check-in and lobbyWho answers, who holds the IDServe them as usualManager on duty, privately
Guest roomsDo Not Disturb, towels, visitorsDo your job, never searchSupervisor or security, same shift
Young guestsA minor controlled by an adultDon’t question or take themDanger now: 911 first
Our workforceHeld passports, debtsDon’t confront the agencyManager or HR, or the hotline

Objectives

What a worker can do afterward

  1. O1Given three short hotel situations, pick the one that shows someone may be forced, tricked or pressured into working or selling sex, or a minor in commercial sex.Behavior: judges by what people do
  2. O2Given a guest or coworker situation, sort a sign worth reporting from one that is not a sign on its own, with no answer based on race, nationality, language, an age gap or paying cash.Behavior: judges by what people do
  3. O3Given a picture of a place in the hotel, tap the signs worth noticing and leave the ordinary things alone.Behavior: judges by what people do
  4. O4Faced with a possible case during normal work, choose the response that keeps everyone safe: serve normally, with no questioning, searching, photographing, secret notes or rescue. No dangerous choice.Behavior: keeps the moment normal
  5. O5Given what was seen, report it the same shift to the manager on duty or security, or the manager on call when working alone, with where and when, what was seen, the details, and what they did.Behavior: reports the same shift
  6. O6When someone, especially a minor, may be in danger right now, call 911 first, then tell the manager. Waiting counts as a dangerous answer.Behavior: calls 911 when it can’t wait
  7. O7When a coworker shows signs of labor trafficking or asks for help, report to the manager on duty or HR before the shift ends and say the hotline number in private, without confronting the boss or agency.Behavior: helps a coworker safely

Mastery: 80 percent or more on a 12-question test, one question per skill, with no dangerous answers. The 80 percent is this demo’s choice; the law sets no pass mark. The objectives page shows how each is tested.

Design decisions

What I chose, and what I turned down

1. Teach by place, not by topic

Chosen
Four places in the hotel (the desk, rooms, young guests, the workforce) crossed with three moves. The learner gets a map, the test gives one question per cell, and the results show which skills need another look.
Turned down
A course that follows the law’s list: definitions, then indicators, then reporting. It is easy to check against the Act, but a housekeeper would have to translate it back into her own hallway. The law’s list is covered in a separate compliance map.

2. The kind-hearted mistake fails the test

Chosen
In every scene the risky option is the one a caring person would pick: asking “are you okay?” in front of him, slipping a note into the towels, confronting the agency. The consequence shows what that does to the person you meant to help. In the test, any dangerous answer fails the attempt, whatever the score. Waiting while someone, especially a child, is in danger now counts as dangerous too.
Turned down
Scoring by points alone, where 11 of 12 passes even if the one miss was “keep serving, and keep an eye on the boy for the rest of your shift.”

3. Signs are behavior, never looks

Chosen
No sign in the course mentions race, nationality, accent, clothing or an age gap. Those show up only as “not a sign on its own,” in cards and in a break-room scene. The scenes vary who is at risk and who is in control: a woman at the door of Room 514 with a young man behind her, a boy offered at the bar, a guest family’s nanny. The people in the pictures have no facial features, and a range of skin tones is spread across every role, so no tone goes with being at risk or in control. No answer depends on how anyone looks.
Turned down
Common indicator lists that include appearance. They are easy to copy, but in a Waikiki hotel, where many guests and staff come from somewhere else, they teach profiling.

4. Records built for turnover

Chosen
A completion record made only from a real pass. A test unlocked “for review” makes none. The record prints as a certificate and downloads as CSV. A manager’s roster computes each worker’s first due date (180 days after hire, and by our reading of the Act never before December 1, 2027) and refresher date (two years later), and flags who is due or overdue. In this demo the records stay in each browser; a hotel version would send each pass to one place the hotel owns.
Turned down
A certificate alone. It proves one person finished. It doesn’t tell a manager that the valet hired in September is five days from overdue.

5. Length: 40 minutes, not 30

Chosen
Keep the written report in lesson 3 and a full 12-question test. My time model puts the course at 35 to 47 minutes, depending on reading speed, and nearer 55 for a slow reader in a second language.
Turned down
Cutting to 30 minutes by dropping the written report and testing 8 skills instead of 12.
The tradeoff I made
About ten more minutes per worker, every two years, in a hotel where time on shift is short. In return: practice of the hardest behavior, a report a manager can act on, and a test that covers every cell. The cuts are listed in the design document if a client wants them.

The training

What a worker sees

On a computer

The cover slide, on a computer. A dark navy frame around a light slide. The title reads Notice it. Don’t confront. Report it., with who the course is for, four short facts, buttons to skip the introduction or open the pocket card, and a line for anyone it is happening to: call or text the hotline yourself; it is not the police or immigration. On the right, a drawing of the Seabright: a three-floor hotel with lanai rails, an awning over the lobby doors, two palm trees, Diamond Head on the horizon, and a staff member waving.
The cover. The hotline line for a worker it is happening to sits here, not in the fine print.
Introduction slide 3 of 5, on a computer. The title reads Four places in the hotel. Four cards, each with an icon: Check-in and lobby, a man answers every question for the woman with him and keeps her ID; Guest rooms, Do Not Disturb for four days but someone keeps asking for towels; Young guests, a girl who looks about 14 taken to a room at 1 a.m.; Our workforce, a contract housekeeper whose agency keeps her passport.
Where you might see it. Four places, one sentence each, before any lesson starts.
Lesson 2, on a computer. A drawing of the hotel’s front desk at night with six numbered points: a man at the counter holding a woman’s ID, cash on the counter, a woman behind him with her head down and no bag, two men waiting on a sofa. Point 3 is open on the right: Cash, one night at a time. Right: this is not a sign on its own. Plenty of guests pay cash; here it adds to the picture because he also holds her ID.
Decide, then read why. Each point asks first: a sign to report, or not a sign on its own? Paying cash is ordinary until it sits next to real signs.
Lesson 3 scene, on a computer, titled Room 514 says no. On the left, a drawing of a door with a Do Not Disturb sign and a cart, and the story: a woman opens the door a few inches and says no service, just towels; a young man sits on the bed behind her. On the right, the choice to slip a note into the towels, marked Risky, and its feedback: if she finds the note, he may be punished, and that night the room is empty.
Prove it on the job. The kind-hearted choice, a note in the towels, is one of the dangerous ones.
The results page after a pass, on a computer. A completion record for a sample learner: name, role front desk and hotel employee, course version, completed October 7, 2026, score 92 percent, refresher due by October 7, 2028. Buttons: Print my certificate, Download my record as CSV, Open the manager’s roster, Remove my record from this device.
The completion record. Made only from a real pass, with the refresher date already worked out.
The manager’s roster, on a computer, as of March 1, 2028. Summary counts: 6 trained and current, 1 due within 30 days, 2 overdue, 3 not due yet, 1 left the hotel. A table lists sample staff with role, worker type, hire date, last completed, next due and a status tag such as Overdue by 91 days or Due in 5 days.
The manager’s roster. Sample staff, labeled as samples, on a date a few months after the rule takes effect.

On a phone

Lesson 4 on a phone: a drawing of the elevator lobby at ten past one at night, with five numbered points beside a girl in a hoodie, an adult man with her phone in his pocket, and another man with a key card. Point 3 is open: An adult in control.
Young guests. The pins sit beside the people, not on them.
Lesson 4 practice on a phone: which of these is the clearest reason to report? Three choices: two teens at the pool with their grandmother, a girl of about 14 walked to a room at 1 a.m. by an adult who isn’t a parent, a loud group of teens on a sports trip with their coaches.
Practice. Two of the three choices are ordinary families and teams.
The pocket card on a phone. The numbers come first: 911, the trafficking hotline and its text line, TTY, and Honolulu Police, then a line for someone alone on shift, a line for a worker it is happening to, and blanks for the manager and security numbers. The signs by place follow.
The pocket card. On a phone it opens on the numbers. It prints on one page.

Process artifacts

The working documents, and the kit a hotel needs

  • Needs analysis

    The law’s duties and deadlines, why turnover makes them hard, and which gaps training can and can’t fix.

    ReadDownload .md

  • Compliance map

    Each requirement of Act 191, and where the course or kit meets it. Ends with what a real submission still needs.

    ReadDownload .md

  • Action map and objectives

    Goal, behaviors, practice and minimum information; seven objectives with conditions and standards.

    Action mapObjectives

  • Design document

    The grid, the interactions, the safety rules, the test, the records, the length tradeoff, and what changed from the engine it reuses.

    ReadDownload .md

  • Storyboard

    Every screen, every option and its feedback, generated from the same files the training runs on.

    ReadDownload .md

  • Evaluation plan and sources

    What a hotel would measure, from completion to reports on a shift; every law, sign and number with the date it was checked.

    Evaluation planSources

  • The kit

    The pocket card, the manager’s roster, a policy template, a one-page guide for the manager who takes a report, and a draft staff sign. The template, the guide and the sign are marked as drafts; none is legal advice.

    Pocket cardRosterPolicyManager guideSign
Architecture: how the training is built

This course reuses the engine I built for the Property Crew Safety case study. The content and the kit are new.

Architecture of the training A top-to-bottom flow. A source-check gate feeds content.js and test-bank.js, which also feed the storyboard generator and a content validator. The engine, reused from an earlier course, runs them in the learner’s browser. Tracking writes one statement per answer to localStorage. A pass creates a completion record, kept apart from the statements, which the certificate and the manager’s roster read. An accessibility and keyboard gate sits at the end. Gate: each law and sign checked at its source content.js, test-bank.jsLessons, scenes, 26 test items, sources Storyboard andcontent validator The engine (reused)Map, lessons, scenes, test, results The learner’s browserPhone or computer. Works offline. tracking.jsOne statementper answer records-lib.jsCompletion record,dates, CSV Certificateand the manager’sroster localStorageThis browser only. Nothing is sent. Real roll-out: alearning record store Gate: axe-core, keyboard, print checks
Rounded pills are human or automated checks. Solid boxes are files that exist. The dashed box is not built.

In words: every law, sign and number is checked at its source before it goes into content.js and test-bank.js. A validator checks those files, and the storyboard is generated from them. The reused engine runs them in the learner’s browser. tracking.js writes one statement per answer. A real pass creates a completion record, stored apart from the statements, and the certificate and the roster read it. Nothing leaves the browser.

Checks: the findings that mattered
  • Profiling risk. The common indicator lists include clothing and appearance. Every sign in the course was rewritten as a behavior or a situation. Looks appear only as “not a sign on its own.”
  • A report channel that could leak. The engine I reused offered to open the phone’s messages app with the report filled in. For this topic that would put guest and room details into a personal text thread, so it was turned off, and the lesson says “in person or by phone.”
  • Answer length as a giveaway. In the first draft of the test, the keyed answer was the longest option in 11 of 21 questions. It is now the longest, or tied for longest, in 2 of 21, measured by script.
  • Hotspots covering the people. On a phone, the numbered pins sat on top of the figures they described. They now sit beside them, some with a short dotted line to what they mark, and a script fails any pin that covers a person’s head, body or legs at phone or computer width.
  • Dates in Hawaii time. A date written as “2026-10-07” and read the usual way shows October 6 in Hawaii. Dates are built from local parts, and a check runs with the browser set to Hawaii time.

How AI was used

Claude Code, Codex, Gemini and local AI models were used at different steps of my process.

Results

What was checked

  • 0 serious or critical accessibility issues on 116 screen statesScript-checked on the build: axe-core 4.10.2 on every kind of screen at phone and computer widths, through a full pass, a failed attempt and the record form, October 7, 2026. Automated checks miss things; a screen-reader test on a real phone is still open.
    Real
  • 26 test versions, all drawn and scored in three retakesScript-checked on the build: a script plays the test three times and confirms every version appears and scores. A separate run confirms a dangerous answer fails at 92 percent.
    Real
  • 40 to 55 minutes per workerA time model: reading at 150 to 240 words a minute plus a fixed time per interaction. At 120 words a minute, closer to a second-language reader on a phone, it is about 55, so the course says 40 to 55.
    Projected
  • Roster dates: 180 days, the December 1, 2027 floor, two years, February 29Tested by script, with the browser set to Hawaii time, on the sample roster.
    Simulated

What would be measured

For a hotel that adopts it: the share of staff trained by day 180, test results by skill, and the number, speed and quality of reports to the manager on duty, including any based on looks. The evaluation plan sets these out by LTEM tier.

Reflection

What I’d change, and what didn’t work

What didn’t work

  • I aimed for 30 minutes and landed at about 40. Scenes, a written report and a 12-question test take time, and I chose to keep them.
  • The first build spoke only to bystanders. Contract housekeepers are both the audience and the people most at risk, and a learner it was happening to found the hotline only in fine print. It is now on the cover, in lesson 5 and on the pocket card.

What I’d change next

  • Review by a survivor-informed expert and a Hawaii anti-trafficking organization before any hotel sees it.
  • Compare it with the Attorney General’s program when that is published, and with the Department of Law Enforcement’s rules on records and signs.
  • A pilot with about ten staff, including contract housekeepers, to replace the time model with real minutes and test the wording in a second language.

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Or email dean@deanahlgren.com.