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The Maryland Department of Labor Urges "Black Friday" Shopping Precautions for Retailers - MOSH

Maryland retailers are being advised to take greater precautions with their Black Friday shopping events to avoid crowd-related injuries. Crowd-related injuries and the death of a worker who was trampled by customers in New York during special retail sales and promotional events have increased during recent years. In addition, several injuries are attributed to special sales events nationwide.

Under the Maryland Occupational Safety and Health Act, employers are responsible for providing their workers with safe and healthy workplaces. Maryland Occupational Safety and Health (MOSH) encourages employers to adopt effective safety and health management systems to identify and eliminate work-related hazards, including those caused by large crowds at retail sales events.

MOSH has adopted these guidelines to help employers and store owners avoid injuries during the holiday shopping season, or other events where large crowds may gather. Ideally, crowd control planning should begin days, weeks or even months before events that are likely to draw large crowds, and crowd control, pre-event setup, and emergency situation management should be part of event planning. MOSH recommends that employers planning a large shopping event adopt a plan that includes the following elements.

Planning:

  • Where large crowds are expected, have trained security or crowd management personnel or police officers on site.
  • Create a detailed staffing plan that designates a location for each employee. Based on the size of the crowd expected, determine the number of employees that are needed in various locations to ensure the safety of the event (e.g. near the door entrance and throughout the store).
  • Ensure that employees are properly trained to manage the event and anticipated crowd.
  • Contact local fire and police agencies to determine if the event site meets all public safety requirements, and ensure that all permits and licenses are obtained and that local emergency services, including the local police, fire department, and hospital, are aware of the event.
  • Designate an employee to contact local emergency responders if necessary.
  • Provide legible and visible signs that describe entrance locations, store opening times, and other important information such as the location of major sale items.
  • Prepare an emergency plan that addresses potential dangers facing employees and prevention methods, including those associated with overcrowding, crowd crushing, being struck by the crowd, violent acts and fire. Share emergency plan with all local public safety agencies.
  • Train employees in crowd control procedures and the emergency plan. Provide them with an opportunity to practice the special event plan. Include local public safety agencies if appropriate.

Pre-Event Setup:

  • Set up barricades or rope lines for crowd control well in advance of customers arriving at the store.
  • Make sure that barricades are set up so that the customers' line does not start right at the entrance to the store. This will allow for orderly crowd control entry make it possible to divide crowds into small groups for the purpose of controlling entrance.
  • Ensure that barricade lines have an adequate number of breaks and turns at regular intervals to reduce the risk of customers pushing from the rear and possibly crushing others, including employees.
  • Designate employees and provide signage to explain approach and entrance procedures to the arriving public, and direct them to lines or entrances.
  • Make sure outside personnel have radios or some other way to communicate with personnel inside the store and emergency responders.
  • Consider using mechanisms such as numbered wristbands or tickets to provide the earlier-arriving customers with first access to sale items.
  • Consider using internet lottery for "hot" items.
  • Locate shopping carts and other potential obstacles or projectiles inside the store and away from the entrance, not in the parking lot.
  • If appropriate, provide public amenities including toilets, washbasins, water and shelter.
  • Communicate updated information to customers waiting in line. Distribute pamphlets showing the location of entrances, exits and location of special sales items within the store.
  • Consider controlled access for customers reducing the number of customers who will enter the store at any given time. ( example: only 10 customers will be allowed to enter every 30 seconds).
  • Shortly before opening, remind waiting crowds of the entrance process (i.e., limiting entry to small groups, redemption of numbered tickets, etc.).

During the Sales Event:

  • Make sure all employees and crowd control personnel are aware that the doors are about to open.
  • Staff entrances with uniformed guards, police or other authority personnel.
  • Use a public address system or bullhorns to manage the entering crowd and to communicate information or problems.
  • Position security or crowd managers to the sides of entering (or exiting) public, not in the center of their path.
  • Provide crowd and entry control measures at all entrances, including the ones not being used. If possible, use more than one entrance.
  • When the store reaches maximum occupancy, do not allow additional customers to enter until the occupancy level drops.
  • Provide a safe entrance for people with disabilities.

Emergency Situations:

  • Do not restrict egress, and do not block or lock exit doors.
  • Know in advance who to call for emergency medical response.
  • Keep first aid kits and Automated External Defibrillators (AEDs) available, and have personnel trained in using AEDs and CPR onsite.
  • Instruct employees, in the event of an emergency, to follow instructions from first responders, regardless of company rules.

This Fact Sheet is advisory in nature and informational in content. It is not a standard or regulation, and it neither creates new legal obligations nor alters existing obligations created by MOSH standards or the Maryland Occupational Safety and Health Act.