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Stewarding factsheet 6 – SIA stewarding exemption

Stewards are subject to different regulations and training requirements depending on the activities they undertake.

Under section 4(6) of the Private Security Industry Act 2001, in-house stewards (i.e. directly employed by the ground) carrying out licensable activities at certified sports grounds are exempt from licensing by the Security Industry Authority (SIA) as long as the sports ground is covered by a safety certificate. This exemption is commonly known as the ‘SIA sports ground exemption’.

The exemption was granted in 2006 on the basis that stewards were trained and vetted to standards equivalent to the training and vetting required of SIA licence holders. It applies at any ground subject to a General Safety or Regulated Stand Certificate.

‘SIA Licensable activities’ at sports grounds are:

  1. Stewards searching spectators on their entry to the ground.
  2. Stewards specifically tasked with physically intervening against and ejecting spectators who are in breach of ground regulations. This includes decisions on refusal of entry.
  3. The supervisors of those stewards in categories a and b immediately above.
  4. In a non-front-line capacity, safety officers and chief stewards.

(The full list of ‘Licensable activities’ under the Private Security Industry Act 2001 are outlined on gov.uk.)

Stewards in safety or non-safety critical (service) roles whose duties do not include searching, ejections or physically intervening where spectators are in breach of ground regulations are NOT carrying out licensable activities.

Any steward undertaking SIA licensable activities must have an SIA door supervisor licence.

HOWEVER

Under the sports ground exemption, in-house sports ground staff do not need a licence.

INSTEAD

In-house staff conducting the SIA licensable activities must have an equivalent level of training and vetting.

What does it mean in practice

Searching during ingress

  • In-house steward: Exempt from needing licence. But must be qualified and vetted.
  • Agency steward: Must have an SIA Door Supervisor licence, along with the required Level 2 qualification.

Pitch perimeter

  • In-house steward: Exempt from needing licence. But must be qualified (including physical intervention training) and vetted.
  • Agency steward: Must have an SIA Door Supervisor licence, along with the required Level 2 qualification.

Response team

  • In-house steward: Exempt from needing licence. But must be qualified (including physical intervention training) and vetted.
  • Agency steward: Must have an SIA Door Supervisor licence, along with the required Level 2 qualification.

In vomitory advising spectators

  • In-house steward: Not licensable activity so exemption doesn’t apply. But must be qualified (or working towards qualification).
  • Agency steward: Not licensable activity so SIA licence not needed. But must be qualified (or working towards qualification).

Guidance and enforcement for football grounds

The SGSA has published policy guidance for football grounds it regulates. This has directed local authorities of designated football grounds to insert conditions in the General Safety Certificate on the training and vetting of in-house stewards carrying out licensable activities.

The SGSA will be assessing compliance, for example via its local authority audit programme and regular matchday inspection activity.

Application to sports other than football

Ground management of designated sports grounds other than football should adopt the principles set out in the SGSA’s guidance and consult their relevant governing body where further clarity is needed.

Local authorities are directed by the Department for Culture, Media and Sport (DCMS) to insert licence conditions into Safety Certificates and Regulated Stand Certificates to reflect the training and vetting requirement of in-house stewards carrying out licensable activities.

Quick Q&A

Are the roles of ALL stewards licensable?

No. The key considerations are a) whether a steward is ‘in-house’, i.e. directly employed by the ground, and b) whether their duties include one or more of the licensable activities detailed in the key principles section.

Do I need to vet all in-house stewards?

No, not all in-house stewards are scope of this guidance, as the vetting requirement only applies to those carrying out licensable activities.

What if a steward is just used to spot but not intervene?

Stewards (in-house or agency) simply ‘spotting’ or advising against breaches of ground regulations are not undertaking licensable activity.

However, staff called to address such breaches of ground regulations would be undertaking licensable activity. If they are in-house, they are subject to the SIA exemption.

Who can search spectators?

Searching is a licensable activity. Therefore, only agency staff with a SIA Door Supervisor licence or in-house staff with equivalent training and vetting can carry out.

It could be argued that many stewards do not undertake licensable activities. Is that right?

Yes, that’s right. In many events, the majority of stewards will not perform licensable activity as part of their normal duties.

Can in-house stewards perform physical intervention roles and eject spectators?

Yes, if they are appropriately trained; for example, the SIA Physical Intervention unit (an optional unit offered to those undertaking Level 2 Spectator Safety qualifications).

Stewards who have not previously been trained to perform physical interventions should not be deployed to these roles.

Do exemptions for music events only applies to in-house staff?

Where a certificated sports ground is being used to host an outdoor live music event under a special safety certificate, the in-house staff are exempted from SIA licencing.

To clarify, staff outside the regulated stand are not exempt?

The SIA sports ground exemption only applies where a safety certificate is in place. Areas outside of the stand are not included in the certificate therefore staff in these outside areas are not exempt from SIA licensing.

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