#5. Recommendations to Government and Industry to improve Crowd Safety at outdoor events
Part five of Íse’s dissertation into the impact of regulation and legislation on crowd safety at outdoor events.
This final chapter revisits each of the research objectives, summarises the findings, critically appraises the research process and concludes with offering three recommendations to government and industry.
(Please note this was originally produced in 2019-2020.)
Here are the previous chapters for reference:
#1 The Root Cause of Crowd Disasters
#2 Legislation, Regulation and Crowd Safety
#3 The Impact of Legislation on Competency
In summary, the findings are:
- The perspective of Crowd Safety shifted over the last decades, pivoting from crowd control to the safe planning and management of crowds, while research identified that the root cause of disaster was not due to the crowd itself, but failings in management.
- Crowd safety is not the focus of any legislationthat impacts outdoor events, and this has negative consequences in reality.
- The gap in legislation allows events to take place without oversight and no requirement to report incidents, with respondents often witnessing incidents at outdoor events, agreeing that introducing crowd safety legislation is the most important change to improve safety.
In summary, the recommendations are:
- The first recommendation to government is to develop legislation or mandatory requirements for the approval process and management of crowd safety for outdoor events.
- The second recommendation to government and industry is to establish a certification system for crowd safety practitioners.
- The final recommendation is to conduct further research on regulation and crowd safety at events.
First Objective: To critically review literature regarding crowd safety
The literature review revealed that the study of crowds is a relatively young subject area (Abbott and Geddie, 2000) and has shifted in perspective over time from a phenomenon that crowds were seen as a threat, rather than needing protection themselves (Darby et al, 2004; Cocking et al, 2010; Drury and Stott, 2011; Reicher et al, 2014). The shift from the attitude of crowd control to crowd management pivoted after the Hillsborough Disaster (Elliott and Smith, 1993). Since then the call for competency and a legal framework to ensure the safe planning of crowd management emerged in industry and academia, yet is not reflected in reality for outdoor events (Martella et al, 2017).
Furthermore, the research revealed that the root cause of a disaster is “failings in management” or “poor safety culture” (Couto, 1989; Pate-Cornell, 1992; Turner, 1994; Pidgeon, 1997; Lea et al, 1998; Challenger and Clegg, 2011). This evidence further supports the claim that the crowd itself is not the reason for the disaster. When comparing notable disasters or incidents in the UK between sports stadia and outdoor events; there have been none in sports stadia since 1989 (when the SGSA was introduced) and there have been incidents right up to present day in outdoor events.
To conclude, the perspective of Crowd Safety shifted over the last decades, pivoting from crowd control to the safe planning and management of crowds, while research identified that the root cause of disaster was not due to the crowd itself, but failings in management.
Second Objective: To review literature linked to the impact of legislation and guidance on crowd safety at outdoor events
It was clear from the literature that the majority of research on the impact of legislation on crowd safety at events were either regarding sports stadia or the impact of the Licensing Act (LA03) on all licensing objectives except “public safety” (DCMS, 2003; Talbot, 2006; Newton et al, 2007; Foster et al, 2009; Newton and Hirschfield, 2009; Hadfield et al, 2009; Herring et al, 2009; Nicholls, 2015). The LA03 was intended as a single integrated scheme for licensing premises but does not account for outdoor events. Furthermore, the certification system alongside the LA03 is regularly subverted by event organisers in order to secure a TEN rather than applying for the more time consuming, risky and costly Premises Licence.
It became clear that there are a number of legislation and regulations that impact the planning of an event including HSAWA74, CDM15, and RIDDOR13, yet none were designed with outdoor events in mind. Moreover, there is no one piece of legislation that focuses on ensuring crowd safety standards during the approval process and delivery of an event. In addition, there is no legal requirement for an event organiser to hold a qualification in order to plan and deliver events.
Legislation affecting sports stadia is often updated in reaction to a specific disaster, usually following an inquiry into the disaster coupled with political pressure. However, change in legislation usually focuses on the proximate cause of the disaster, rather than considering the system holistically (Smith, 1990; Elliott and Smith, 2006; Johnes, 2007; Melrose et al, 2011). Furthermore, evidence suggests that self-regulation does not work (Ball-King et al, 2012; Elliott and Smith, 2006). Therefore, reality appears to reflect academia as, since 1989 when the Safety of Sports Ground Act 1975 was updated and the SGSA was introduced, there have been no recorded stadia crowd disasters since. It appears that the existence of the SGSA as a regulator has positively impacted crowd safety in sports stadia (Roberts, 2019). There is a potential for this to be an example for legislation regarding crowd safety at outdoor events.
In conclusion, crowd safety is not the focus of any legislation that impacts outdoor events, and this has negative consequences in reality.
Third Objective: To investigate the experiences of licensing authorities and event safety professionals on the impact of legislation on crowd safety at outdoor events.
The primary research approach selected for this study took a c_onstructivist approach,_ as the phenomena studied are interpreted by the social actors involved. Using an induction approach uncovered relationships between variables such as safety, regulation and competency. Social actors were asked to give their perceptions on the current environment regarding crowd safety at outdoor events, legislation and how crowd safety could be improved, through the evaluative strategy of surveys taken at a fixed point in time. This interpretivist approach allowed for an understanding of the current crowd safety environment.
The utilisation of surveys allowed me to disseminate to a wide range of potential participants with few challenges to resource. The online survey allowed access to cluster samples around the UK and short turnaround time for responses. The ease and time limit of the survey promoted full completion. Allowing a number of free text responses enabled further understanding of respondents experiences and perceptions. However, it restricted capacity for deeper layers of understanding participants’ experiences.
In conclusion, the use of descriptive surveys to understand the perceptions of social actors offered a broad understanding of the population, however further analysis by in depth interviews may have unearthed connections to respondents answers.
Fourth Objective: To analyse the perceptions of licensing authorities and event safety professionals in relation to legislation on crowd safety at outdoor events
The findings identified that Presenters have higher competency indicators and understanding of crowd safety than Assessors. SAG members/Assessors holding crowd safety qualifications was the most important factor influencing their competency, as well as the experience of large scale or major events. Furthermore, it appears that Assessors may not hold appropriate competency in assessing crowd safety plans, however there is currently no legal requirement for them to carry out this role. In addition, they lack support and guidance in order to do so.
The most revealing factor from these results was that over half of events that do not go through an approval process are due to ‘low capacity’ ranging from 500 - 5000 people. These results revealed a gap where events could be taking place without any oversight, assessment or approval. It highlights inconsistency in the approval process for outdoor events. In addition, respondents stated they sometimes or often witness crowd safety incidents at outdoor events.
Without a legal reporting requirement in place, there is no requirement to report these incidents. The literature states that disaster results from an accumulation of smaller incidents that go unnoticed (Turner, 1978, 1994; Paté-Cornell, 1992; Lea et al, 1998; Challenger and Clegg, 2011). Is this a warning that the industry could be one small incident away from a crowd disaster? Further evidence from data analysis depicts in Table 2‑1 and Table 2‑2, where crowd incidents have reduced to almost none in stadia yet continue to present date in outdoor events, and in Figure 3, where respondents report witnessing crowd incidents more often than not.
The analysis of respondent’s belief whether legislation was fit for purpose regarding crowd safety correlates with findings in the literature. Although the LA03 is most closely linked to crowd safety at outdoor events, it was listed third out of five on a list of legislation surrounding outdoor events. In addition, the mean result was almost the same as the SSGA75, meaning respondents believed they had the same level of influence, although the SSGA75 does not apply to outdoor events. The Temporary Event Notice (TEN), as part of the LA03, was deemed least fit for purpose regarding crowd safety, which correlates with the literature claiming that the TEN is misused by event organisers to circumvent licensing conditions. In addition, respondents neither agreed or disagreed the NVQ qualifications were fit for purpose and interestingly, the average qualification of respondents was Level 5 or above when a Level 4 is required to be a stadium Safety Officer. All respondents agreed that the qualification and certification of those who practice crowd safety, in both assessing and presenting roles, is the most important factor to improving crowd safety at outdoor events.
In conclusion, the gap in legislation allows events to take place without oversight and no requirement to report incidents, with respondents often witnessing incidents at outdoor events, agreeing that introducing crowd safety legislation is the most important change to improve safety.
Research Evaluation
As there are few regulations specific to crowd safety at outdoor events, there was little data available to critically analyse. The only evidence to seek out were the experiences and perspectives of those who work at and attend events. Therefore, the limitations of this research is that it is based on perceptions of 108 participants with an imbalance regarding role. Furthermore, as the approval process for outdoor events is not standardised, it was difficult to capture all the types of roles and scenarios involved. For example, a SAG does not exist in every event planning scenario, sometimes it is the local authority events team processing applications or a private landlord with their own events team.
In addition, there was a relatively low number of responses, where the desire was to have over one thousand responses. This “law of small numbers” (Kahneman, 2012) allows the views of those who did respond to be emphasised, and possibly alter the view of the population sample. Moreover, the respondents were connected to the author’s network and therefore bias may be present regarding qualifications and experience. Perhaps if this study were to be repeated, that a selection of senior officials from both local authorities, event organisers and crowd safety professionals would be invited to interview. However, a benefit of the population sample was that those who did respond, had high competency indicators.
Although this study is investigating crowd safety at outdoor events, it leans heavily towards crowd safety in sports stadia, due to the wealth of research regarding stadia and the evolution of the legislative framework surrounding it. Additionally, as stadia disasters are deemed focusing events, there is more detailed information available regarding each incident compared to those that occurred in outdoor events.
Finally, if there was more time available to gather data, I would have aimed for higher response. The challenge in this is that I was unable to send out more than one email to mailing lists held by organisations with no option of sending reminders. Another potential of more time was that I could have developed a mixed methods research strategy to conduct in depth interviews with a select number of respondents. This is a recommended approach for any further studies in this area.
First Recommendation
The first recommendation to government is to develop legislation or mandatory requirements for the approval process and management of crowd safety for outdoor events. This framework could begin with a mandatory licensing of all outdoor public events, either ticketed or non-ticketed, and over a certain capacity, such as 100 people. In order to secure a licence for these events, an application should be made to the local authority. Either the licensing team or the events team within the local authority will have qualified crowd safety professionals on their staff in order to assess the applications. The suggestion that each team have at least one member of staff holding the qualification, who will lead any Safety Advisory Groups or meetings, with other team members in training towards it. The legislation will give powers to the local authority and police to object to the licence if the application does not match the required conditions. Additionally, a national body (such as the HSE), or a new governing body will also hold powers over this legislation.
The required conditions for a successful application include a crowd safety plan which includes strategies for ingress, circulation and egress and details emergency procedure. A guidance document will be produced to support both event organisers in planning the event and the local authority on assessing applications and event plans. The crowd manager on the event will hold an in-date licence and an appropriate qualification. Depending on the capacity of the event, they will need to provide evidence of successful crowd management at previous events of a similar scale.
During the event, the qualified crowd safety professional in the licensing authority or emergency services will hold powers of inspection to ensure that the event is managed as per the agreed and licenced plan. Furthermore, any crowd incidents or near misses during an event will be required under legislation to be reported to the governing body (such as the HSE).
This legislation could be introduced through an amendment of the Licensing Act 2003 to either update the “Public Safety” objective to detail measures necessary to ensure the safety of the crowd at an event or add a new objective. In addition, the Temporary Event Notice should be updated alongside this in order to maintain consistency. Either it is replaced by a new system, or become subject to further scrutiny in order to secure an event licence.
Alternatively, a new “crowded places” law could be introduced that covers all spaces where organised crowds gather not just outdoor events, using a more non-prescriptive approach such as the HSWA74. This law could place duty on the organiser to be responsible for the safety of those who attend the event or place. Also, the organiser is required to hold an in-date licence and appropriate qualification or have a member of staff delegated to this role.
From this research, I believe developing a legislative framework can help create safe standards, aid in reducing the risk of incidents and improve the quality of crowd safety management at events in the UK. Although it places responsibility on the local authority, it may ultimately reduce resource demand on emergency services and local authorities, as events will be organised at a higher calibre due to these new safety requirements. Furthermore, if there is an agreed and transparent process in place, it can save time and resource by reducing confusion and challenging of local authority officers decisions.
Second Recommendation
The second recommendation to government and industry is to establish a certification system for crowd safety practitioners. In order for a crowd safety professional to work in either organising events, consulting on events or working for a local authority, they must hold an in-date licence to allow them to practice.
The government could delegate authority for issuing the licence to an organisation (such as UK Crowd Management Association), or set up its own. This licensing authority would manage the administration and regulation of crowd safety licences in the UK. In order for a practitioner to secure a licence, they must satisfy a number of conditions to prove competency. Suggestions of conditions include that they hold at minimum a Level 5 RQF in crowd safety management or similar, demonstrate years of experience they hold in the field, how many events they have worked and at what capacity, and the level of continuing professional development (CPD) they are undertaking. To support new crowd safety practitioners, there could be an apprentice or second level licence that allows a practitioner to work with someone who has a full licence in order to gain experience and develop competence to secure a full licence.
This licence will apply to both Presenters and Assessors, ensuring a level of consistency in competency between event organisers and local authorities.
The benefit of this is to set an accepted standard of competence required to carry out this role and _ensures that crowd safety practitioners are consistently updated with latest legislation and guidance through the necessity of expiring certification coupled with continuing professional developmen_t. This can support better practice of crowd safety at outdoor events in the UK, including reducing demand on emergency services and local authorities as it reduces the risk of a crowd disaster happening. This will benefit organisations as they will have a competent professional responsible for crowd safety which can reduce the risk of incidents, improve safety and experience for attendees and improve resource management.
Third Recommendation
The final recommendation is to conduct further research on regulation and crowd safety at events. It was clear from the literature review that self-regulation is not successful, and the presence of a regulator improves safety. However, what arose in the data analysis was that respondents did not believe a regulator was important to improving crowd safety. Therefore, the recommendation to industry and academia is for further research on the impact of a regulator on crowd safety at events. This conflicting information arising in the study provides an opportunity for learning as to the disparity between industry and academia. Further research is required to advance discourse on crowd safety at outdoor events, to improve responsibility, manage risk appropriately and enable a positive experience for the whole crowd.
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