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Martyn’s Law by sector: the small venues in the middle

by Mark Rowe

This year, Professional Security Magazine as part of its coverage of Martyn’s Law has focused on sectors – such as places of worship, and pubs and clubs. Andrew Wood writes that most of the talk about Martyn’s Law has been about stadiums, arenas and universities. But most of the premises the Act covers are much smaller: the village hall, the social club, the parish church, the community theatre, the independent music venue. These are standard-tier premises, and they are where most of the work – and most of the confusion – will be.

The duties are not yet in force. The government has committed to an implementation period of at least 24 months from Royal Assent in April 2025, so there is time. But small premises rarely have a security manager, and many are run by volunteers. The sooner they understand what is actually being asked of them, the better.

Who is in the standard tier?

Premises are in scope if they are a building (or a building and other land), they are used wholly or mainly for one of the uses listed in Schedule 1 of the Act – such as retail, food and drink, entertainment, places of worship, visitor attractions and community halls – and it is reasonable to expect 200 or more people to be there at the same time. From 200 to 799 is the standard tier. From 800 upwards is the enhanced tier.

The test is what it is reasonable to expect, not what happens on a quiet Tuesday. A hall that holds a 250-person dance a few times a year is in scope and needs to take that seriously. A venue that will never see more than 120 is not in scope and does not.

What the standard tier asks for

For most small premises, it comes down to three things.

• Tell the SIA. Whoever controls the premises (the responsible person) must notify the Security Industry Authority that they are responsible for them, and keep that information up to date. For a small venue, the responsible person could be the owner or, for a village hall or club, the management committee.
• Have public protection procedures in place. Section 5 lists four: evacuating people; moving them to a safer place inside (invacuation); stopping people getting in or out (lockdown); and giving people information. The test is what is reasonably practicable for that building and those people.
• Co-operate where you share. Where more than one person is responsible, or premises sit within other qualifying premises, the Act expects them to co-ordinate and co-operate.

Just as important is what the standard tier does not ask for. There is no requirement to install physical security measures – that duty applies to enhanced-tier premises and qualifying events. There is no legal requirement to produce a formal document and send it to the regulator; that too is for the enhanced tier and events. And there is no need to designate a senior individual. Writing your procedures down is still sensible, because it is the easiest way to make sure everyone knows them – but the law asks for procedures that are in place, not a binder on a shelf.

Where small premises are most likely to get it wrong

• Counting. Some will assume they are too small, or exempt, without checking their busiest days. Others will work from the fire certificate maximum and put themselves in the wrong tier. The answer should be a reasoned number you can explain.
• Buying what they don’t need. The Act has already attracted sellers. A standard-tier hall does not need bollards, scanners or a full security consultancy. It needs people who know what to do.
• A plan nobody knows. Procedures only work if the person on duty knows them. Who can call a lockdown, and what’s the signal? Which doors can be secured, and how quickly? Where do people go if they can’t get out? If the answers live in one person’s head, the procedure isn’t really in place.
• Forgetting volunteers and hirers. At many small premises the person on duty on a Saturday night is a volunteer key-holder or someone who has hired the hall. The responsible person – the owner, management committee or whoever controls the premises – stays responsible, even when they aren’t there. That means briefing those people and building the procedures into the hire agreement.

What to do now

None of this needs to be expensive. A sensible start for any small premises is to:

• Work out, and note down, how many people you can reasonably expect at your busiest.
• Decide who the responsible person is – the owner, the management committee, or whoever else controls the premises.
• Walk the building and think through each of the four procedures: how you would get people out, where they could shelter, how you would stop people coming in, and how you would tell everyone what is happening.
• Brief the people who are actually on duty, including volunteers and regular hirers, and run through it with them.
• Use the free material already available – ProtectUK guidance and the ACT Awareness e-learning are a good place to start.

Standard tier is deliberately proportionate. It recognises that a village hall is not a stadium. Done well, it should mean that if the worst ever happened, the people on duty would know what to do in the first few minutes – which is when it matters most.

About the author

Andrew Wood is managing partner of arx Partners, which develops the Martyn’s Law Workbook (www.martynslawworkbook.co.uk).

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