Safety at Major Events – Select Committee submission

The SGSA has submitted a written response to the UK Parliament Digital, Culture, Media and Sport Select Committee’s Safety at Major Sporting Events Inquiry.

The submission outlines SGSA’s role and answers the three questions being considered by the Committee:

a. Are UK stadiums and crowd management policies sufficient to maintain the safety of large volumes of fans at major events?
b. What steps can be taken to protect UK fans abroad at major events?
c. Should regulations governing fans attending football matches be reviewed?

Executive Summary

1. The standards, policies and regulations governing spectator safety in the UK, both statutory and those set by sport governing bodies, are complex, having evolved over several decades, but continue to be effective. However, there is no room for complacency as the risks to spectator safety continue to change.
2. While the SGSA has no formal responsibility for the safety of spectators who travel abroad to attend major sporting events, we are committed to strengthening sports grounds safety internationally, through involvement in international partnerships, such as the Council or Europe, or through advisory activities, including with FIFA.

Context

3. This written evidence is submitted in response to the DCMS Select Committee inquiry into Safety at Major Sporting Events which will address three questions:
   • Are UK stadiums and crowd management policies sufficient to maintain the safety of large volumes of fans at major events?
   • What steps can be taken to protect UK fans abroad at major events?
   • Should regulations governing fans attending football matches be reviewed?

4. We have supplied written evidence supplemented with an overview of the SGSA’s regulatory role, regulatory objectives and how it works in partnership across the sector to improve safety at sports grounds. The SGSA would welcome the opportunity to give oral evidence to the Committee to clarify or supplement this written evidence. If it would help the Committee, we would be pleased to facilitate a visit to a sports ground to observe a typical safety management operation.

The role of the SGSA

5. Our predecessor body, the Football Licensing Authority (FLA) was established following the Hillsborough Stadium Disaster Inquiry led by Lord Justice Taylor.
6. The Football Licensing Authority was reformed by the Sports Grounds Safety Authority Act (2011) which established the SGSA and gave the organisation powers to provide advice to other sports and in other territories. The SGSA has over three decades of experience in regulating the safety of football grounds in England and Wales. The 2011 Act did not affect the organisation’s core regulatory role, which is set out below.
7. Under the provisions of the Football Spectators Act 1989 (1989 Act) the SGSA has two regulatory responsibilities:
   • To keep under review the discharge by local authorities of their functions under the Safety of Sports Grounds Act 1975 (1975 Act) in relation to grounds at which designated football matches are played (section 13 of the 1989 Act) which includes the issuing and monitoring of conditions within the General Safety Certificate.
   • To issue licences to admit spectators to any premises for the purpose of watching any designated football match played at those premises (sections 10-12 of the 1989 Act). Licences are renewed annually, informed by SGSA’s matchday inspections and with direct oversight from the SGSA Board, for a fee of £100 per club, which the SGSA gathers on behalf of the Exchequer.
   • Designated football matches are defined as those matches played at the home grounds of clubs in the Premier and English Football Leagues, Wembley, and the Principality Stadium¹. SGSA has published a Oversight and Licensing Policy which sets out how it discharges its duties. The SGSA has no regulatory role in relation to football matches in other parts of the UK or in relation to non-football sporting events.
8. The SGSA is a small organisation (c20 Full Time Equivalents), comprising a regionally based Inspectorate and a secretariat which oversees strategy, policy, communications and corporate services. It is funded primarily through grant-in-aid (c£1.6m per annum), supplemented by income (c£300-400k per annum) from its advisory services. The strategic plan for 2020-2024 sets out the SGSA’s key objectives, which are to:
   • Continuously improve our performance as the safety regulator for football grounds in England and Wales;
   • Raise the profile and status of sports grounds safety in the UK and internationally;
   • Become the strategic safety partner of choice for governments, sports governing bodies and organisers of major events; and
   • Improve our efficiency and performance as a non-departmental public body.
9. The SGSA provides advisory services to other sports on a cost-recovery basis, as permitted within the Sports Grounds Safety Authority Act; for example, the SGSA has a five-year agreement to provide advice and support to the England and Wales Cricket Board, as well as similar long-term arrangement with Sport Northern Ireland. Other current clients include FIFA, the Football Association of Wales and the Scottish Government.
10. The organisation may also provide free advice to event organisers and other partners; for example, the SGSA was the strategic safety partner for Birmingham City Council in relation to the 2022 Commonwealth Games and provides strategic consultancy to the Football Association in relation to the safe growth of the women’s professional game. Further information on SGSA’s statutory and advisory work can be found in its most recent annual report.
11. The SGSA publishes guidance that is used by football, wider sport and the wider events industry as ‘best practice’ in event safety management. Its guidance is also used by architects across the world to ensure modern stadia are designed with good safety principles in mind. The SGSA’s cornerstone guidance document, the Guide to Safety at Sports Grounds (“Green Guide”) is now in its sixth edition and is provided free of charge to each club that we licence and to each local authority that we regulate. In 2021, we published SG03: Event Safety Management which provides further support for venues on the core elements of event safety management.

Spectator safety

12. Safety is a broad term which means that people present at a sports ground are protected against dangers of physical harm or injury arising from being present. In today’s changing world, such dangers could arise from a range of factors including sports ground structures, safety management arrangements, terrorism, crowd disorder and other anti-social behaviour by individuals or groups which may cause physical harm or injury. Safety at a sports ground is not limited to the safety of spectators; it includes the safety of all people present at the ground. This will include measures to ensure the protection of groups such as club employees, stewards, agency staff, medical staff, players and officials during an event.
13. Responsibility for safety at a ground where designated matches are played rests with ground management. This is regulated by the safety certificate issued by a local authority under the 1975 Act. In overseeing how local authorities discharge their functions and in taking licensing decisions, the SGSA seeks to satisfy itself that appropriate provision is being made to secure reasonable safety at a ground. The SGSA therefore works in partnership and seeks to ensure the provision of reasonable safety at sports grounds at which designated football matches are played through education, guidance and persuasion. If such an approach fails and the SGSA is concerned that reasonable safety is being compromised by the actions or inactions of others, the SGSA will use its regulatory powers to ensure reasonable safety is maintained.
14. The SGSA takes a risk-based approach to all its regulatory activity, ensuring that the focus of attention is on those sports grounds where the actions or inactions of the ground management or the local authority threaten to compromise the reasonable safety of those at the ground.
15. The scope of sports ground-specific legislation is limited to stadia and their immediate environs and does not extend to the main pedestrian and vehicle routes leading to and from stadia, including public car parks, local train stations, bus stops and so on. This area, known as “Zone Ex” (the External Zone) or the ‘Last Mile’, is in the public domain and must be managed and policed accordingly. The successful management of “Zone Ex” relies on close, effective co-operation between event organisers, police and other stakeholders convened by the relevant local authority.

Are UK stadiums and crowd management policies sufficient to maintain the safety of large volumes of fans at major events?

16. The safety and security of the public are managed through mature arrangements between ground management and the relevant local Safety Advisory Group (SAG), which will be chaired by the local certifying authority and incorporate emergency services and other partners. The SAG will offer advice to the local certifying authority on the safe running of an event which may include for example recommendations on the safe capacity of the venue.
17. All venues holding football matches will have a detailed operations manual that provides appropriate assurance and resources for the safe management of the event. This includes an appropriate stewarding plan, fire, evacuation and medical provision. Further details on what should be covered within an operations plan are available in guidance, copies of which can be made available to the Committee.
18. Despite these well-established arrangements, new threats and behaviours will continue to emerge and there can be no room for complacency, as evidenced by:

• The disorder associated with the rescheduled UEFA Euro 2020 final in July 2021;
• Increases in anti-social behaviour and disorder since spectators were re-admitted to sports grounds following the COVID-19 pandemic;
• Poor planning and co-ordination between partners responsible for staging the 2022 UEFA Champions League Final at the Stade de France;
• Significant resourcing challenges in local government and the police, together with a challenging financial climate for football clubs operating outside of the Premier League;
• Challenges in ensuring the sustainable supply of competent stewards to meet the safety, security and customer care requirements of the sports sector; and
• The threat level of terrorism remains substantial with sports grounds, as with other crowded places, now recognised as potential targets.

19. To ensure co-ordination of organisational responses to emerging trends, the SGSA convenes regular meetings of its Safety Committee which is attended by representatives from DCMS, the Football Association (FA), Premier League, English Football League, UK Football Policing Unit (UKFPU), Football Safety Officers Association, the Local Authority Safety Advisory Group Regional Chairs Network, and the Football Supporters Association.
20. The SGSA supported Baroness Casey’s independent review into events surrounding the UEFA Euro 2020 Final at Wembley Stadium and has subsequently worked with partners represented on the Safety Committee to implement its key recommendations. For example, the SGSA has commissioned primary research, on behalf of DCMS, into the sustainability of stewarding in the live events sector. A report of this research will be published in due course.

What steps can be taken to protect UK fans abroad at major events?

21. The SGSA plays an active role in promoting safety abroad, primarily through its work with the Council of Europe. The SGSA is represented on the Council of Europe’s the Standing Committee on the development of the European Convention on integrated safety, security and service (the ‘Saint-Denis Convention’) at football matches and other sports events to ensure the safety of spectators at sports events.
22. The convention entered into force on 3 July 2016 and covers all sports in general, but, in particular, football. It commits the 41 countries to take practical measures to prevent and control safety security and service. It also sets out measures for identifying and prosecuting offenders. Under the Convention, to which the UK became a signatory in May 2019, the Standing Committee was set up to follow the implementation of the Convention, to adopt recommendations and to respond to new challenges. The committee is made up of representatives of each government along with partners such as UEFA, FIFA, Football Supporters Europe and the European Professional Football Leagues and has helped produce the principal measures recommended by the convention on matters such as ticketing and the deployment of public order resources.
23. Beyond its work with the Council of Europe, the SGSA has no formal role in the safety of UK spectators who travel abroad to attend major sporting events.

Should regulations governing fans attending football matches be reviewed?

24. Regulations governing spectator safety have evolved over time, with major changes made following the Hillsborough Stadium Disaster Inquiry report including the creation of the Football Licensing Authority, which was reformed via the Sports Grounds Authority Act 2011.
25. The legal framework for spectator safety is regularly reviewed to maintain public safety. For example, in July 2022 the Government announced the introduction of licensed standing in seated areas following evidence-based research commissioned by the SGSA which demonstrated that installing barriers reduces the risk of a progressive crowd collapse.
26. In line with good practice, SGSA has recently undergone an organisational review, commissioned by the DCMS Arms-Length Body team on behalf of the Cabinet Office, which has considered the role and function of the SGSA and made a number of recommendations which may entail legislative change.
27. The growing popularity of the women’s game, which will be fueled further by the success of the England Women’s national football team in the UEFA European Championships 2022, is one example of an area where a review of regulations might be needed to ensure they remain fit for purpose.
28. Whilst SGSA is the government regulator for football in England and Wales, it should be noted that the football governing bodies (Premier League, EFL and FA) all have their own competition rules which have been used to promote safety. For example, recent changes have been brought in by these bodies to counter the reported rise in anti-social behaviour and disorder during the 2021/22 football season.
29. Overall, SGSA’s view is that the legal framework governing spectator safety at designated football matches in England is world-leading and the safety certification of wider sporting events continues to be effective. However, the risks to spectator safety continue to change and it is therefore incumbent on all parties with responsibility for spectator safety to guard against complacency and to ensure that relevant regulations are continuously reviewed and that those with responsibility for spectator safety have the necessary capacity and capabilities.