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Quick Hits

  • The 2026 FIFA World Cup, co-hosted by the United States, Canada, and Mexico, poses significant workplace safety risks due to expected large crowds in host cities.
  • Employers that proactively approach address crowd control issues and commuting logistics can help ensure a safe environment for employees during the event.
  • The Occupational Safety and Health Administration’s (OSHA) crowd management guidelines emphasize the importance of anticipating and mitigating hazards posed by surging crowds.

Over the course of the thirty-nine-day event, eleven U.S. cities will host a total of seventy-eight matches (104 across all three countries), bringing millions of fans and potentially causing unprecedented disruption to workplaces nationwide.

For employers—particularly those in host cities like Los Angeles, Miami, Atlanta, Dallas, Houston, Philadelphia, Kansas City, Boston, New York/New Jersey, the San Francisco Bay Area, and Seattle—this is not merely a spectator event. It is a workplace safety event. The legal issues surrounding Occupational Safety and Health Administration (OSHA) compliance, crowd control, and commuting logistics demand attention before the first whistle blows.

Moreover, multiple crowd-control incidents in recent years, including at soccer matches, serve as a warning to authorities in host cities and to employers, particularly those in the hospitality, food service, and entertainment industries, about the potential for crowd-control and safety issues they might encounter.

The General Duty Clause Does Not Take a Holiday

Under the Occupational Safety and Health (OSH) Act, employers are required to provide a safe workplace. Section 5(a)(1), often called the General Duty Clause, mandates that employers keep their workplace “free from recognized hazards that are causing or are likely to cause death or serious physical harm.” That obligation is not diminished because an international soccer tournament is generating massive foot traffic outside the office door.

While OSHA does not have a binding standard for crowd control risks, it has long recognized that large crowds in close proximity to workers pose foreseeable dangers. In 2014, OSHA issued crowd management guidelines for retail settings, stemming from an incident in which a retail worker was trampled during a “Black Friday” sales event. While originally developed for retail environments, the guidance underscores employers’ obligations to anticipate and mitigate hazards posed by surging crowds near their workers.

Employers with facilities near stadiums, fan zones, transit hubs, or watch-party districts face a heightened obligation to evaluate whether those conditions create ingress or egress hazards for their own employees. Employers may want to remain aware of risks posed by blocked or obstructed exits, impeded evacuation routes, and compromised building access.

Crowd Control as an Everyday Obligation

While large events like the World Cup illustrate the potential for crowd-related hazards, the underlying risks of crowd-control issues and employers’ ongoing obligation to maintain safe workplaces are not limited to such unique events. OSHA crowd management guidelines, which apply to any employer with operations that attract large crowds, emphasize maintaining unobstructed exit routes, not exceeding safe occupancy levels, and planning for foreseeable surges.

Commuting and Travel Risks

Employers, even those not hosting or near World Cup crowds, may also want to note the potential risks to employees with commuting and travel related to the event. Employees may face difficulties commuting to and from the workplace and traveling in the surrounding areas. Some employees near stadiums or fan zones may not be able to reach the workplace or exit safely on matchdays. Transit officials have urged commuters in New York City and New Jersey, which are co-hosting matches, to work from home if possible and avoid ride-shares to the extent possible on matchdays as crowds are expected to strain the region’s transit networks. Such circumstances may trigger employers’ obligations to plan for such foreseeable risks or hazards.

Key Takeaways

The World Cup may serve as a reminder that crowd-related hazards are a recurring issue, particularly relevant for employers in retail, hospitality, food service, entertainment, and event management. As such, employers may want to consider:

  • developing a written crowd management action plan tailored to specific events or conditions and staffing, communication protocols, and emergency procedures;
  • ensuring that exit routes are clearly marked and remain unobstructed;
  • recognizing and complying with maximum occupancy limits;
  • training employees on the crowd management plan, crowd management procedures, emergency responses, and how to recognize crowd hazards such as occupancy limits and obstructions to exits;
  • examining workplace spaces to identify specific crowd-related risks; and
  • coordinating with law enforcement, fire protection, and emergency medical services in advance of expected large crowds and consider having trained security personnel on site.

Ogletree Deakins’ Workplace Safety and Health Practice Group will continue to monitor developments and will provide updates on the Hospitality, Retail, Sports and Entertainment, Workplace Safety and Health, and Workplace Violence Prevention blogs as additional information becomes available.

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