Venue Managers and Event organisers/professionals are likely hearing about ‘Martyn’s Law’ an increasing amount. This drafted legislation will certainly have a major impact on the management of venues in order to seek increased safety and security within UK venues against terrorism. At present, nothing about the final form of the legislation is truly known, but keeping abreast of the potential implications is certainly sensible. Here I have listed out some of the key facts and features of the suggested legislation I have discovered, hopefully in an attempt to illustrate how impactive this bill will be for events and venues!
Strengthened Security Requirements:
The bill is expected to introduce enhanced security obligations for venues, and the suggestion currently is that it will be a tiered approach with requirements starting from 100 person venues, and then ‘enhanced’ requirements being obligatory for 800+ person venues! As such, the impact of this legislation is likely to be felt by the large majority of public venues. The bill also makes reference to ‘public events’ where they are held at an otherwise non-qualifying venue and expect to attract in excess of 800 people. This will likely make established premises more attractive for event organisers, or add another aspect that temporary events need to consider in their planning. Even the likes of a community fete will have enhanced duties in a number of cases.
The kicker to the legislation for owners, operators and planners is that there is an enforcement aspect of this bill, with powers being drafted for local authorities to inspect, investigate and prosecute breaches. There has also been an interesting differentiation made that states that ‘qualifying venues’ may be included inside other qualifying venues. I.E. A 1000 cap nightclub contained within the confines of a high capacity conference centre would need their own planning and documentation to compliment the centre’s planning and couldn’t just assimilate into the overarching plan.
Risk Assessments and Mitigation:
Venue owners and operators are already required to complete through risk assessments, but the drafted legislation and guidance suggests that you will be required to identify potential issues and vulnerability and plan how to respond in the event of an attack in or near your venue. The issue with this segment is that the planning will likely have to be highly dynamic and the drafted guidance at present is sensibly focusing on establishing how to communicate with your staff and patrons, quickly and effectively locking down or evacuating, rendering immediate aid to injured persons and getting useful information the emergency services. The drafted guidance makes reference to a sensible ‘6 Task Approach’ which attempts to assist organisers and operators in complying with Martyn’s Law effectively.
Communication:
The first aspect of the 6 task plan asks you consider how you will communicate the incident and the implementation of the response plan with your staff and patrons.
This will not be unfamiliar to many in emergency planning or event management. The use of radios, PA systems, codewords and even venue lighting to alert staff to potential issues is not uncommon. However the push is now for consideration of how to communicate required information to your customers. Do you use a PA system and instruct people to evacuate the area through certain doors?
However, while the guidance makes reference to telling patrons and staff an attack is underway, how do you disseminate the information about the attack without causing panic and a potential high injury situation in resulting crush or stampede? The guidance also makes a good point, these evacuation protocols should not be your fire evacuation protocols as these serve a different purpose. As such, you should avoid using fire alarms to alert customers. You’d also need to consider turning back on the house lights, stopping music and such so that this doesn’t hinder evacuation or 999 responders.
Lockdown Procedures:
The second point of the 6 point guidance makes reference to how you will lock down the venue, and stresses the importance in how a quick lock down will save lives, and/or slow the attack.
A large part of this aspect will be physical security arrangements. However the proposed guidance goes further and places an implication on ensuring regular inspection of security measures to ensure their proper operation and effectiveness, and then ensuring staff can operate them in a hurry to use them effectively, and actually makes a point around the effectiveness of a relatively simple change/addition to your security measures, thumb locks. These can be quickly applied to lock a door and slow the attack, and may be a preferred approach for smaller budget venues rather then more expensive shuttering systems and vehicle mitigation systems (companies like Crowdguard have built a specialism around introducing these physical defences in visually unobtrusive ways. The other hidden challenge in promoting this form of venue safety).
There is also an onus placed on making record of any training or drilling done in regards to these lock down drills, which would likely form part of any subsequent inspection by authorities.
There is also a suggestion that you identify hiding spaces within the venue, and in reality, this could form part of your lockdown drills, with staff drawing patrons into these hiding spaces. You could even look to further secure these spaces with simple measures such as internal latches or lighting. Consideration should probably be applied to the ability to communicate from this area though, as having no mobile reception in a basement will likely be unhelpful in the long run response to the incident.
Larger venues that have on-site medical provision will want to make the consideration of how their medical staff will interact in the lockdown phase. It may be beneficial, when placing the medical bay or first aid room that you are making considerations with regards to the lockdown processes so that this area is within the confines of the safety area, potentially with secured access to the outside world where possible, allowing further 999 resource to immediately access a sterile area and tend to the most serious casualties. Your other staff, who should be aware of this location could be instructed to take injured people to this location where safe. Your medical provider should have a comprehensive plan for this sort of incident, which will complement the response to an attack and increase survivability. (We at MEDIREK look to do something similar already, interacting with existing venue/event plans to ensure that our medical planning is bespoke and most effective to the purpose. For instance, the likelihood is that the initial decisions made by your on-site medical team will accentuate the form of the response by additional services as they arrive. The effective implementation of the ten second triage tool could well be the key in reducing casualty numbers and getting effective healthcare to the right people and moving on the ‘walking wounded’)
Of course, lockdown is not going to always be the best option and this is certainly one aspect where any planning needs to save space for a dynamic approach appropriate to the circumstances.
Evacuation
As mentioned, lock down is unlikely to be suitable in all circumstances. However Evacuation is also going to likely come with a number of other crowd management challenges, particularly at larger capacity venues. It’s highly unlikely that you’ll encounter a calm, compliant crowd when you declare there’s a marauding terrorist working their way through the disco room. Unfortunately, the draft guidance does not make any consideration for this challenge at present and so you’ll likely want to engage the services of consultants and companies who can produce crowd management plans taking into account the implications of your Martyn’s Law Planning (For instance, The 202 Group LTD produce bespoke, pragmatic crowd management plans which when applied with an effective and responsive security team will quite literally be the difference between life and death).
However, it is again stressed that fire alarms and fire evacuation procedures should be separate to any Martyn’s Law evacuation plans and makes reference to identifying and communicating where the danger is so that you don’t evacuate towards it, and that once they are out the venue they should disperse from the area as quickly as possible, rather than mustering outside.
Contacting Emergency Services
Potentially one of the most critical parts of any response to an attack for an venue/event operator will be alerting the emergency services and getting the most effective and useful information them. Clearly, the 999 services will have their own protocols for how they will respond to this attack, but it’ll be most effective to call the police who will subsequently then arrange further 999 services to attend in due course. The guidance makes reference to not making the assumption the call has been placed, and actually stipulates that you should ensure that all relevant staff at the venue can contact police where required and, as mentioned earlier, if there is not access to a fixed landline then you need to make consideration for whether the mobile coverage in the venue is sufficient.
On the topic of actually making the call, The caller should – in simple language – tell the police who they are, their location, their phone number, what has happened, and that there is a suspected terrorist incident. If possible, they should estimate the number of attackers, give a description of them (paticuarly if they are disguised as aid or security personnel) and their locations, flag any weapons seen (e.g Vehicle attack, knife attack, firearms threat), indicate the estimated number of casualties, and mention if access routes have been compromised. This is where it may also be pertinent to consider the emergency access routes into a venue post lock-down or evacuation and how patients might be best removed from your first aid room in a quick and effective manner. A number of police, fire and ambulance resources will need to attend, and while the 999 services will locate and manage these (they often even designate a staff member to be in charge of the ‘parking’ where multiple ambulances attend an incident), having consideration in the design and layout of event spaces for this to occur effectively will pay dividends in the event of an attack. As such, when the call is placed, the caller can make reference to the best way to access the area.
The guidance also suggests having posters in place containing the above information. However, having this poster in useful locations is likely to be the challenge, and I envision that said poster will end up co-located with the obligatory dusty ‘Health and Safety at Work’ poster workplaces have to display.
Use available first aid and fire equipment
The next aspect of the draft guidance asks venue operators to make use of any available first aid and fire fighting equipment where safe to do so. However, as part of your compliance with this legislation, you’ll want to ensure that your equipment is serviceable, in-date and useful for the application. Pleasingly, there is a mention for ‘Public Access Trauma Kits’ (PAcT) or tourniquets to be available at the venue and that additional fire-fighting equipment is made available at likely attack points.
What this looks to mean is that on top of having an AED and first aid kit, you’ll also need to be considering bleed control equipment and then appropriate training in how to use it. This will be eased slightly in that the Security Industry Authority have made it mandatory for license holders to have more enhanced medical training, which should include the effective, initial management of catastrophic bleeds.
The issue will come in ensuring the compliance around this equipment, and your security personnel are likely to be somewhat preoccupied and unable to render aid to the injured effectively. This point will also likely coincide quite strongly with obligations around medical provision as outlined in the purple guide anyway, and as such it may be preferable to have an outside medical contractor responsible for medical planning at your venue. For instance, as part of our venue safety service at MEDIREK we can look to provide ‘Cat-Bleed’ kits in addition to our primary provision to be made co-located in high traffic areas, taking away the compliance exercise of ensuring the equipment is in date, as well as briefing venue staff at the start of each event day in the usage of the kit and how to best assist our staffing in their function.
Working with your neighbours
Lastly, the draft guidance asks operators to work with neighbouring venues to ensure that your Martyn’s Law plans do not conflict with one another (for instance, both evacuating large numbers of people into the same area, prime for secondary attack).
They also mention the effectiveness of shared radio networks like shopsafe and pubwatch in this segment, making use of the networks these provide for early warning and ease of planning as similar venues are likely to have similar plans. Many areas now feature ‘BIDs’ or Business Improvement Districts (such as Experience Guildford) that operate such schemes, and they carry a host of safety enhancing features too such as notifying you to disruptive individuals and occasionally providing support staff in case of first-aid or security incidents.
Crucially, the onus it appears that Martyn’s Law will place on venues and events is to ensure that the worst case scenarios have been considered and accounted for. Any plans that are created should then be fluid and subject to regular review. At present, the draft guidance is suggesting annually. As such, the administrative burden of complying with the legislation is likely to be quite sizeable.
It’s also important to note that this legislation is still in draft form, and could still change quite dramatically before it comes into force. As such, any ‘Martyn’s Law Training Courses’ are going to be purely speculative, but not necessarily ineffective.
Note: The information in this post is based on the potential implications of the Terrorism (Protection of Premises) Bill, as of my knowledge formed from available, governmental sources. Please refer to official sources and consult legal professionals for the most accurate and up-to-date information.
