Only Risk Assessment can save us now! A message from JP.

Hi Folks,

So, rather than a sales pitch for business, I’ll put my head above the parapet and express a few of my thoughts. Not everything is bad news, not everything is good news and some things may sound like a stuck record but, here goes……

Monitoring social media and watching a few webinars suggests that there are both good and bad ideas being bandied around, lots of poorly disguised sales pitches and plenty of speculation as to how and when we get to a ‘new normal’ let alone ‘normal’ state of affairs in the event industry. I’ve kept my counsel for a while, quietly helping out where I can and supporting a few clients with ideas for restarting some event related business as the outlook changes. We will all adapt to what we think the rules will be at some unspecified time in the (hopefully) not too far distant future.

Firstly, let’s consider what the public wants in a post-lockdown world – the human race has always felt a need to congregate in groups to celebrate, laugh, worship, eat, drink, dance, fight, comfort and fornicate – to mention just a few! Why do people attend Festivals? Ian Dury had it with ‘Sex and Drugs and Rock’n’Roll’ – depending on your viewpoint, a successful weekend in a field needs a combination of some or all of the above (your own variants of the constituent parts are what makes the human race such a rich palette).

The harsh reality is that that model doesn’t work whilst social distancing is a requirement of our respective governments.

Let’s approach from the other end – the need to get the economy working. Getting people back to work, money circulating and easing the burden on the Government War Chest is a delicate tightrope being walked by the various Governments around the world depending on the local circumstances of prevalence of the Covid-19 outbreak, susceptibility of the population, the R figure and a whole myriad of economic and political drivers.

Here in the UK, the Government is encouraging businesses to re-open and people to explore going back to work where they cannot work from home. Emphasis has gone from an absolute message- ’Stay Home’ - to a softer ‘Stay Alert’ with more scope for interpretation. No doubt, you have all seen how your local population is interpreting things with some returning to far more of an ‘old normal’ than others. The fact that many hundreds of people being simultaneously at an uncontrolled beauty spot/park/beach is now quite ‘legal’ whilst organising a well-managed ‘event’ with social distancing built into the very design remains (currently) ‘illegal’ only shows how quickly the message breaks down when personal ‘gain’ is added in to the mix. 

So, how do we, as event professional/safety professionals make our interpretations and how do we start to reassemble something approximating our old world?

Government guidance refers to’ Covid-19 Secure Workplaces’ but does not, as of today’s date (20 May 2020) give any concise guidance as to what that means and certainly no guidance for the events industry.  From their published information online ( ) there are 5 key steps to follow:

1                    Carry out a COVID-19 Risk Assessment,

2                    Develop cleaning, handwashing and hygiene procedures,

3                    Help people to work from home,

4                    Maintain 2m social distancing, where possible,

5                    Where people cannot be 2m apart, manage transmission risk.

Covid-19 Risk Assessments are increasingly being referred to – see Gov.UK, HSE, IoSH and numerous other websites for today’s references. No doubt there will be many falling over themselves to sell their services as experts in this area. I will limit myself to a statement of caveat emptor – buyer beware!

The law requires all employers to assess the risk of returning to work while the coronavirus outbreak is ongoing and to put steps in place to manage that risk. This should, hopefully, be a familiar trope.

Everyone has a legal duty to behave as a reasonable person under the same or similar circumstances. Here, the key circumstance is how to reopen (a) during a highly contagious global pandemic in which (b) even asymptomatic people can carry/transmit the disease, and (c) most places currently lack widespread reliable testing, contact tracing, or a vaccine.

Everyone needs to assess and manage the risks of COVID-19. As an employer, you also have a legal responsibility to protect workers and others from risk to their health and safety. This means you need to think about the risks they face and do everything reasonably practicable to minimise them, recognising you cannot completely eliminate the risk of COVID-19.

As many of my clients and colleagues will recall, I have frequently referred to the end result of the failure to get things right is to be gripping the brass rail in front of M’Lud explaining your actions (or lack thereof) and no doubt we have all encountered some elements of the enforcement operations where some individuals will be looking forward to their first prosecutions relating to failure to provide a COVID-19 secure workplace. The usual rules apply – arguments can be made over the strength and suitability of your plans and control measures but having none in place will leave you wide open.

This is an area where there are few absolutes and lots of interpretation possible. Hindsight is not a luxury we have access to in creating our current plans. First principles of H&S again, what is ‘reasonably foreseeable’ and what does ‘so far as reasonably practicable’ mean in this context? Clearly, we know that Covid-19 can kill, so the risk to workers/public is likely to be high. Therefore, it is expected that employers/event organisers would put in place sufficient controls to mitigate or eliminate the risk of workers contracting the viral infection in the workplace. It would not be ‘reasonably practicable’ to do nothing but equally it must be accepted that it is not (currently) possible to reduce the risk to zero. Here is the key question that plagues most undertaking a Risk Assessment – what is an acceptable level of risk?

The UK Government has issued various sector specific guidance relating to different types of work ( ). This currently does not include the world of events, but we can look at some of the objectives and see how our thinking can be focused. Looking at outdoor events and using the ‘Construction and other outdoor work’ guidance as perhaps the closest fit there are several objectives that have some resonance (not an exhaustive look at the objectives – there are many areas where the guidance is clear and familiar!):

 Objective 1: That all employers carry out a COVID-19 risk assessment.

Objective 1.1: To reduce risk to the lowest reasonably practicable level by taking preventative measures.

Objective 3: To maintain 2m social distancing wherever possible, including while arriving at and departing from work, while in work, and when travelling between sites.

Objective: 3.6 To prioritise safety during incidents.

Objective 4.1: To minimise the number of unnecessary visits to the worksite.

Objective 4.2: To make sure people understand what they need to do to maintain safety.

Objective7.1: To change the way work is organised to create distinct groups and reduce the number of contacts each worker has.

Objective 7.2.1: To avoid unnecessary work travel and keep people safe when they do need to travel between locations.

Objective 7.3.2: To make sure all workers on site are kept up to date with how safety measures are being implemented or updated.

The common theme that we are seeing here is (and now is the time to befriend your local competent Safety Officer!) RISK ASSESSMENT! 

The IoSH COVID-19 risk assessment guide ( ) contains a timely reminder of the hierarchy of control. Elimination of COVID-19 and substitution, the two most effective control measures are not (currently) possible and hence the highest level of control lies at engineering control level with administrative and finally PPE as last resort. For all those new ‘Safety Experts’ who have sat through an hour or so of webinar during their furlough, please note – PPE does not equate to Safety! The UK guidance does not, currently, make face covering mandatory. People in England are being advised to wear face coverings in enclosed spaces where they come into contact with other people – including on public transport - nothing is mandatory.

The risk assessment must recognise the virus as a hazard. It should also reflect that the virus is spread in minute water droplets that are expelled from the body through sneezing, coughing, talking and breathing. The virus can be transferred to the hands and from there to surfaces. It can survive on surfaces for a period after transfer (depending on such things as the surface type, its moisture content and temperature). The risk assessment should conclude that if it is passed from one person to another, while many survive infection, some may die from the disease. It must be regarded as a high hazard.

Any mitigation controls devised and implemented must reduce exposure of employees and anyone else who could be infected by your employees. Control considerations must include means of identification of those who may have the disease, preventative measures and what to do if you find if an employee/visitor has contracted the disease.

The risk assessment that you will need to produce should be specific to the needs of your business/event/event site – whilst generic solutions can help, every circumstance is different and, as I’ve already pointed out, the stakes here are high. Not only are your reputation, livelihood and profitability at stake, lives are seriously at risk.

An event/venue specific Covid-19 Risk Assessment will need to be developed to sit alongside the normal event and fire risk assessment. The items below provide some initial thoughts on issues that may be relevant to this process and can be used to guide the drafting of the risk assessment and the procedures and protocols to achieve a ‘COVID-19 Secure’ working environment and place for managed public gathering. 

Where there are differences from ‘normal’ behaviours or expectations, these will need to be fully briefed into the relevant persons so that adherence to the expected new conditions can be maximised. The key here is the perception of understanding in your communication – does simply sending out an email, as an example, to all staff really have the reach and understanding you aim to achieve?

As previously highlighted, where the first two of the Hierarchy of Controls (Elimination/Substitution) are not currently possible, you must also consider the last of the controls, Personal Protective Equipment. There has been a variety of understanding reported over the past few months, as to how additional items of PPE can assist in reducing transmission, and it appears that there is sometimes a lack of understanding around the control and protection that varying items of protective equipment offer to the wearer. You should ensure that you know the benefits of each item of protective equipment, but also the pitfalls, before you implement across the workforce. Wearing one pair of disposable gloves all day on your delivery rounds can offer a misplaced sense of security and could be potentially more dangerous than wearing no gloves at all.

It must be appreciated that no environment can currently be guaranteed to be 100% Covid-19 Secure given the potential for an individual to be asymptomatic. These considerations however will assist in the event organisers and stakeholders doing what is reasonably practicable given the data available and the UK Government advice as it stands.

Considerable emphasis has to be placed on communication of expectations on crew and event audience to limit risk of control measures being breached significantly. Use all appropriate channels including direct communication, use of event website, ticket conditions and apps etc. Beware overcomplication – the key messages may be lost in the noise.

I can’t tell you now how to solve all of the issues related to your venue/event as every situation is unique and these words will rapidly become out of date. However, the principle has to be clear. Do a RISK ASSESSMENT.

For your own circumstances consider:

o  How to maintain 2m social distancing (where possible)

o  How to manage Transmission Risk

o  Reinforce Cleaning Processes

o  Management of expectations

o  Importance of Record keeping and communication

o  Ingress/Egress/Circulation/Emergency – different phases of the event may need different controls

o  What does a failure of your system look like – ref HSE RIDDOR requirements for COVID-19 and subsequent investigation/prosecution?

o  Is all of the above deliverable and financially viable?

And as a final note of caution, remember that your crew and audience are human beings, with all the goal driven behaviours that they come to your events with normally and that purely statistical based crowd models and the like are not going to provide reliable data unless you can control your crew/manage your audience movements. 

So – whilst an early return to mass gatherings in the familiar format is not on the cards (and won’t be whilst social distancing is still an expectation) there are ways in which we, in the events industry, can start to prepare to slowly get back to doing what we, as a collective, do so well – entertain and engage huge numbers of people in a creative, economic and safe manner.

Remember that the risk assessment process will underpin all of the above and the very familiar cycle of PLAN – DO – CHECK – ACT will help you in this process.

Stay Safe – Stay Optimistic