Risk and compliance - festival planning in 2021


Festival organisers are justifiably keen to provide large scale events in 2021, but what challenges are there in organising an event under the Covid roadmap? In this article, Piers Warne, who contributed to the recent redrafting of the Purple Guide interim note, looks at Covid risk management and how to put yourself on the best footing, including the likely risks, issues with compliance and the key differences compared to ‘normal’ years.

Because of the different legislative regimes, this article concentrates solely on the rules as they apply in England. 

Risks

There are significant potholes that need to be avoided as organisers tentatively follow the path out of lockdown. Covid-19 is a dynamic ‘unknown’ so as well as looking at what’s in front of you, organisers need to anticipate what effects potential mutations, transmission, the speed of vaccine rollout and achieving herd immunity will have on event planning. 
 
The recent experiences in India demonstrate just how quickly this dynamic can shift, and the likely consequences should something akin to that happen here. 
 
The English roadmap seeks to allow us to move forward provided the scientific evidence says it is safe to do so. For large scale events, this requires moving to, and beyond, Step 4, slated to be no earlier than 21 June. However, the current regulations, due to expire on 30 June, only set out steps 2 and 3. As such, the precise ‘look’ of Step 4 can only be gleaned from the roadmap document. 
 
Until the relevant regulations are released and the guidance is updated, organisers must factor in the possibility of significant changes to the rules. Put simply, the sooner you intend to host your event, the more likely it is that these dynamic changes will affect the event’s scope, scale and viability.

Compliance 

In the ordinary course of events, compliance is usually handled under an event management plan (EMP) and appended individual policies. Often, additional requirements are placed on an event by the premises licence and planning permission. 
 
Preparing for Covid-19 requires a further risk assessment that will touch on almost all elements of the usual compliance documentation, from traffic management and queueing to event capacity and security. Talk of potential vaccine passports may also need to be factored in. 
 
The Purple Guide, which covers the majority of these matters, proposes a ‘parallel track’ approach where the Covid risk assessment runs alongside the EMP, rather than being integrated into it. This makes sense, given that EMPs for longstanding events have been crafted and revised over time. As such, a complete re-writing of these documents to incorporate the Covid risk assessment would be exceedingly time consuming and difficult, whereas a separate Covid risk assessment feeding into the EMP can be simply adapted and amended as the regulations and guidance updates. 

Key differences

Organisers need to recognise that Covid mitigation is not just a health issue, but a PR issue too – both for the event’s success, but also for the integrity of the regulatory authorities. 
 
The early appointment of a dedicated Covid manager who feeds into the EMP team will likely be mirrored by the Safety Advisory Group appointing a health and safety manager for the same purpose. A joined up approach will persuade both the council that you are on top of matters, as well as the paying public who will be looking for reassurance that the events they attend are Covid safe and secure.   

This article was first published by Access All Areas 

This publication is intended for general guidance and represents our understanding of the relevant law and practice as at April 2021. Specific advice should be sought for specific cases. For more information see our terms & conditions.


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