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These guidance notes are intended to assist football clubs to produce a statement of their safety policy for spectators at football matches as recommended in Annex A to the Guide to Safety at Sports Grounds ('the Green Guide'). It should not be regarded as a rigid directive but should be adapted as necessary to suit individual circumstances.
A proforma, modelled on one provided by the Health and Safety Executive for the use of small businesses, is attached to this Guidance Note. Clubs are free to use a photocopy of this when drawing up or revising their safety policy statement. Alternatively, clubs may choose to use a different format of an equivalent standard.
The FLA advises that every safety certificate issued by a certifying authority under the Safety at Sports Grounds Act 1975 ('the 1975 Act') should require the certificate holder to produce and maintain a written safety policy to the satisfaction of the Certifying Authority.
A written safety policy demonstrates that clubs have devoted thought and effort towards the safety and welfare of spectators. Having to write the policy down helps concentrate the mind. It also shows whether the policy has been fully thought out in practical terms.
Under the Health and Safety at Work etc Act 1974 ('the 1974 Act') any organisation with more than five employees is under a statutory duty to produce and have available a written safety policy statement covering employee safety. Employers also have a general responsibility for the safety of any person invited on to their premises. Regulations made under the 1974 Act require them to carry out a risk assessment of any significant hazards to their staff and visitors. The statement of safety policy for spectators is therefore both a recognition of the club's general responsibility and an extension of the existing requirement in respect of club staff and visitors.
Safety Policy Statement - suggested format It is recommended that the Safety Policy Statement should consist of three main sections.
his section should provide a general policy statement by the club's Board of Directors which should make clear their intention to fulfil the cub's obligations set out in the safety certificate issued under the 1975 Act.
This should identify each of the club's safety objectives and specify how it intends to achieve them. It should cover as a minimum the ten matters identified in Annex A to the Green Guide. (These are referred to in greater detail on pages 8 - 10 of this booklet.)
It is suggested that Section A 'General Policy' be divided into 3 sub-sections, as follows:
A brief statement is required here which clearly defines who holds overall and final responsibility for safety.
This will normally be the club Chairman or a named senior Board Member whose name should be stated. This is the person who should sign the completed Safety Policy Statement.
This part requires a short formal 'key' statement to the effect that the club's policy is to make and keep safe the ground and the facilities to which spectators are to be admitted.
It is not necessary at this stage to enter detail as to how this is to be achieved. Only the policy needs to be stated.
This statement should be compatible with that provided under the 1974 Act. (See Annex A to the Green Guide.)
This part requires a short formal 'key' statement to the effect that the club's policy is to provide competent staff and safety management systems for the safe admission, accommodation and exit of spectators.
It is not necessary at this stage to enter detail as to how this is to be achieved. Only the policy needs to be stated.
It is suggested that Section B 'Allocation of Responsibility within the Club' be divided into six sub-sections, as follows.
This is the name of the person nominated by the Board to ensure that the safety policy is implemented.
This will normally be a Board Member or a senior club employee who has full access to the Board.
The nominee must have the authority and the resources to deal with any pressing safety policy issue.
Only the name and position in the organisation of the person concerned needs to be recorded at this point.
This is the person nominated to instigate, supervise or undertake detailed safety requirements such as structural tests and keeping records. While some will require action on match days, others will need to be performed on a day to day basis.
The nominee will normally be the club's appointed safety officer.
In some small clubs this might be the same person as in B1 above.
The nominee's job description will need to be compatible with that held by him/her or any other person responsible for carrying out the club's responsibilities under the 1974 Act.
Only the name of nominee, date of issue of the job description and any further explanation necessary to clarify any sharing of responsibility for safety need be recorded at this point.
This is the person who has operational responsibility for the safety of spectators on match days on behalf of the club (in some cases known as the Duty Safety Officer).
At many clubs this will be the same person as in B2 above.
Where this is not the same person as in B2, their job descriptions must clearly define how responsibility for safety is divided between them.
Only the name of nominee, date of issue of the job description and any further explanation necessary to clarify any sharing of responsibility for safety need be recorded at this point.
A clear statement is required as to who will assume match day responsibility should the person identified in B3 above not be present. This deputy should be identified either by name or by post as appropriate.
This person could be either a deputy safety officer with a specific match day role or another member of staff capable of taking on the task if required.
The job description of the person identified in this section needs to set out his/her match day responsibilities in the absence of the person identified in B3 above.
This section needs to set out clearly how and by whom the club safety policy is to be made known to all its staff and how and by whom it is to be monitored for the club's Board.
Completion of this section should remind clubs that the role of the club's Board does not end with the issue of a Safety Policy Statement. The safety policy will be of little value if it not made known to and understood by all employees. Similarly the safety policy must be monitored to ensure that it is being implemented as intended by the Board.
This section needs to specify when and how the club's Board will review its safety policy, assess changing risks, evaluate performance, and revise and/or reissue the Safety Policy Statement. It should record the date of the last review.
In completing this section, clubs need to demonstrate an awareness that a Safety Policy Statement is not a static document which is issued and then lasts for all time. Rather it is a living document which needs to be kept under review and updated as circumstances change.
Following any accident or incident, the club should review its policy and procedures. It should record the findings of this review and what action is subsequently taken. In this context:
It is suggested that Section C 'Safety Objectives' be divided into ten sub-sections corresponding with the ten matters identified in Annex A to the Green Guide.
Clubs should use the Safety Policy Statement to record in writing their safety objectives under each of these ten headings together with a summary of how they intend to meet them. The entries in the Safety Policy Statement should identify but should not be a substitute for clubs' detailed plans or arrangements. These should be set out in separate documents as appropriate.
Whilst the key persons responsible for safety at the club have been identified in section B, clubs need to have a chain of command from the most senior person identified in B1 down to the ordinary safety steward. They also need to identify where any safety issue is to be handled outside this chain of command.
In completing this section clubs need to identify not merely the structure of its chain of command but more especially how this operates so as to ensure the implementation of the club's policy on spectator safety.
This section complements section B5 which urges clubs to produce a brief statement regarding the promulgation and monitoring of the safety policy by or for the club's Board. This section is concerned with the club's systems for identifying and tackling safety issues and for ensuring that information about the effectiveness of the club's safety arrangements is communicated up and down the chain of command on a continuing basis.
In completing this section clubs need to record how the club's ongoing performance is to be assessed against its overall safety policy. Among the items that might be referred to (without going into the details) are reports to the Board, pre- and post-match briefings, assessments of known hazards, analyses of injury statistics and formal feed back from training.
The club has a duty to ensure that spectators attending the ground are safely managed during three distinct phases, namely before and while entering (ie from the moment they come on to its property), while within the ground and while leaving, whether under normal circumstances or in an emergency.
This section is concerned with clubs' objectives concerning spectator safety during all three of these phases and with the systems and procedures used to achieve these objectives. Reference might be made (without going into the details) to matters such as the provision of CCTV, turnstile monitoring, public address systems, the publication of information in programmes, signposting, the match day role of the safety officer, steward training and the provision and deployment of stewards.
Each club needs to provide a given number of suitably trained and qualified stewards to enable it to fulfil the requirements of its safety certificate and to ensure the safety of spectators. The number and deployment of stewards will vary according to local circumstances.
In completing this section clubs need to identify their objectives regarding stewarding and how these are to be implemented. In particular they will need to focus on how many stewards they intend to provide, the role these are to play and the standard required. Among other issues to which clubs may wish to refer (though without going into details) are not merely supervision and equipment but recruitment (both male and female), training, dress and remuneration.
Clubs' overall objective should be to ensure that their grounds are safe for spectators. This is not a once off process. Clubs need to put in place a system of routine inspections and internal safety reviews. These would include pre- and post-match checks, annual inspections, electrical certification and full structural surveys.
In completing this section clubs need to record the Board's commitment to maintaining a safe ground and arranging for the tests and inspections necessary for this purpose. Reference should be made (without going into details) to the range of tests and inspections used to carry out the Board's policy.
A Safety Policy Statement remains valueless unless its contents are communicated effectively to all those both inside and outside the club whose roles affect overall ground safety, as well as to spectators. Good communications start at the top at club Board level.
In completing this section clubs need to formulate clear policy objectives for communicating with their own staff, with the police and other agencies and with spectators. They should identify the lines of communication which ought to be established and (without going into details) identify systems and procedures for achieving this. Among examples of good communications with other agencies which might be referred to are liaison groups, joint exercises, and pre- and post-match briefings. Means of communicating with supporters could include meetings with supporters' clubs, clear safety instruction notices, safety articles in match day programmes, and stewards' relationships with spectators.
There is a risk from fire at every ground. The level of this risk will vary from minimal to substantial depending on many factors, including the age, design and fabric of the ground. Clubs' Boards need to be aware of the nature and level of risk within their ground and of the measures required to nullify or reduce the risk. They should formulate clear objectives for this purpose. They would be well advised to do this in consultation with the Local Authority Fire Service.
In completing this section clubs need to set out how they will use risk assessment to identify the nature, level and significance of the risk from fire. They should also refer to the procedures adopted by the club for removing, reducing or containing such risks. Among matters which they might mention (without going into detail) are policies on smoking, the use of fire stewards, tackling litter and the use of fire detection/early warning systems.
The requirement to provide first aid and medical cover is set out in a club's safety certificate issued by the certifying authority under the 1975 Act. It is, however, not sufficient for clubs to regard first aid and medical cover as a service provided by others at the insistence of the certifying authority. Instead, clubs themselves must have a positive interest in and commitment to the level and quality of the cover provided, which they should treat as an integral part of their safety management. Indeed, in some cases, clubs may wish to arrange for a higher standard of cover than is required.
In identifying their objectives under this section clubs should affirm their Board's policy of providing first aid and medical cover to the requisite standard as part of their overall commitment to safety and should identify (without going into detail) how this is to be achieved.
The safety certificate issued by the certifying authority under the 1975 Act requires clubs to draw up contingency plans. It is essential, however, that clubs do not treat this as a burden imposed from outside but as an essential element of their safety management. Club Boards therefore need to be fully committed to producing, keeping under review and, where necessary, revising a sufficient range of contingency plans. Further detailed guidance on contingency planning has been published by the FLA.
In completing this section clubs need to record their Board's commitment to drawing up and maintaining contingency plans of a sufficient standard. (These will need to address the safety not merely of spectators but of staff, players and officials also.) Clubs should identify their objectives and how these are to be achieved. Among the points to which clubs might refer (without going into detail) are liaison with the emergency services, training, exercises and debriefing after incidents.
The requirement to keep records is set out in the safety certificate issued by the certifying authority under the 1975 Act. Clubs need to recognise, however, that maintaining effective detailed records is in their own interest and is an essential element of the safe management of their ground. Such records enable clubs to monitor their own performance and to identify shortcomings. Club Boards need therefore to be specifically committed to a policy of keeping clear and accurate records.
These records should not be confused with the health and safety at work records required to be kept under the 1974 Act and related Regulations.
In completing this section clubs need to set out their Board's commitment to maintaining and monitoring good quality records. They should identify how and by whom this objective is to be implemented. Among the records to which they might refer (without going into detail) are structural and other surveys, ground improvements, reports of match day safety checks, incident reports, injury statistics and stewarding records.
Approval and signature
After completion, the Safety Policy Statement must be approved by the board of Directors and signed by the person identified in Section A1.
Copyright © The Football Licensing Authority 2007
