Xonsultation on Safety...
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CONSULTATION ON SAFETY CERTIFICATION UNDER THE SAFETY OF SPORTS GROUNDS ACT 1975

Comments are invited on a draft guidance document on the safety certification of sports grounds under the Safety of Sports Grounds Act 1975.

Although the document only applies to grounds that host designated football matches comments are welcome from all parties with an interest in sports ground safety.

The document examines a proposed new form of less directive safety certification based on risk assessments and the production and implementation of an operations manual by the ground management.  While it favours this approach, it recognises that this will not become compulsory.  It therefore also covers the more traditional top-down form of certification, modified to comply with current safety requirements.

Background

Under the current system of safety certification the local authority is required to include in the certificate such terms and conditions as it may consider necessary or expedient to secure reasonable safety at the sports ground.  These conditions must include the number of spectators that may be admitted for specified activities.  The local authority must monitor and enforce these terms and conditions.  Its enforcement powers include reducing capacities, issuing prohibition notices, issuing cautions or initiating prosecutions.

However, the responsibility for spectator safety rests not with the local authority but with ground management.  But this can be obscured by the structure of the safety certificate which may be perceived as placing this responsibility on the local authority.  This in turn can discourage management from engaging fully with the issues.

In other areas of public safety, including fire safety, the requirements are more overtly based upon a series of risk assessments and operations manuals.  This leaves the initiative and the responsibility with the management, which is able to tailor the requirements more closely to its particular needs and circumstances.  The fifth edition of the Guide to Safety at Sports Grounds (the “Green Guide”) reflects this approach.

In line with our usual approach, we have not included a model safety certificate.  We have reservations about providing anything that could be copied by any local authority or ground management without reference to the particular characteristics of the ground.  We are, however, in discussion with the London District Surveyors’ Association which has previously produced a model certificate that was widely adopted by local authorities.

Specific issues

You are invited to comment on any of the issues raised in the document.  We would, however, particularly welcome responses on the following issues.

  • Would the proposed less directive approach enable clubs to take full responsibility for safety by tailoring their operations more closely to the particular circumstances of their individual grounds?

 

  • Would such an approach encourage clubs to raise their safety management standards because they could better reflect this in the provisions of, and resource required under, their operations manuals?
  • Are the procedures for monitoring and enforcement set out in the document sufficient and appropriate to ensure that a less directive approach would not lead to a reduction in safety standards?

 

  • Would a less directive approach assist the local authority by reducing its detailed involvement, leaving it free to concentrate on monitoring and enforcement rather than drafting the detailed requirements itself?
  • Would the longer-term savings for the local authorities outweigh the short-term costs of moving to a less-directive system?

 

  • Do the clubs and local authorities have the necessary skills to undertake the risk assessments and evaluate the operations manuals; if not, how would they acquire these?
  • Would it be sensible for local authorities to adopt a less directive approach for grounds that do not host designated football matches?  (As with other grounds this would be on a voluntary basis.)

 

  • Where a local authority chooses to remain with the present approach to safety certification, how will it reconcile this with the requirements on fire safety and other issues where the ground management already produces a risk assessment?
  • How far should a local authority retaining the traditional approach encourage or allow ground management to produce elements for inclusion in or attachment to the safety certificate, including the calculations of the safe capacity?

 

What next?

You are free to copy this consultation paper to other parties.  However, we would strongly advise against taking any action to implement any of the proposals in the paper during the consultation period without first consulting the Football Licensing Authority.

Click here to download the consultation draft

If you wish to submit any comments please send them to (nikki.rutherford@flaweb.org.uk) by Monday 3rd May 2010.

 


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