In anticipation of the holiday season and an increase in holiday shoppers lured by the promise of big sales, OSHA sent a letter to major retailers last week.  The letter serves as a reminder to retailers of their responsibility to protect their employees and ensure a safe working environment under the General Duty Clause of the Occupational Safety and Health Act of 1970.  The letter directs retailers to consider adopting the safety guidelines contained in the published Fact Sheet entitled, “Crowd Management Safety Guidelines for Retailers”.  The fact sheet and letter are in response to the trampled death of a worker in 2008 as shoppers stormed through the store doors on “Black Friday” and OSHA’s concern regarding crowd management during the holiday season. 

OSHA’s “Crowd Management Safety Guidelines for Retailers” details how retailers can prepare for crowd-drawing sales events.  The guidelines are divided into three sections:  planning for the event; pre-event setup; and how to respond in Emergency Situations.  In brief, OSHA advises stores to plan ahead to ensure proper staffing levels and having trained security personnel or police officers onsite.  OSHA also advise that retailers implement crowd control measures outside the store, such as having barricades or rope lines positioned away from the immediate store entrance and explaining the entrance procedures to the people waiting in line.  Other measures that may be adopted for crowd control include making sure that outside personnel have radios or some other way to communicate with personnel inside the store and emergency responders; using mechanisms such as numbered wristbands or tickets to provide the earlier arriving customers with first access to sale items; using Internet lottery for “hot” items; and locating sale items in different parts of the store to prevent overcrowding in one place.

During the sales event, OSHA recommends providing a separate store entrance for staff, making sure that all employees and crowd control personnel are aware that the doors are about to open, positioning security or crowd managers to the sides of entering (or exiting) public and not in the center of their path, and using more than one entrance. 

OSHA also emphasizes the need to be prepared for emergencies by making sure exits are not blocked, knowing who to call in an emergency, keeping first aid kits and Automated External Defibrillators available and having people trained in first aid and CPR onsite, as well as ensuring that employees know to follow instructions from authorized first responders.  OSHA takes the approach that with good planning, proper training, and clear communication, employees can enjoy a safe work environment during holiday shopping season.

OSHA’s guidance on crowd management can be found at:  https://www.osha.gov/OshDoc/data_General_Facts/Crowd_Control.html.