“As a result of the specialist and esoteric nature of our practices we, as an industry, have been at the forefront of self-guidance and are very well positioned to accept the mantle of self-regulation.”
Those who are involved in any way in producing theatre know how important it is to fully engage with the framework of legislation that exists to safeguard performers, employers and members of the public. All those operating in the UK are fortunate to be able to refer to a comprehensive legislative structure. This information is relevant to all roles within the industry from company directors to cast and crew. However, this framework seldom explains how in practice they may be met. Indeed, what exactly does “so far as is reasonably practicable*” mean in a theatre, on a show for the performance tonight.
The Theatre Industry has long understood that the only effective regulation must be self-regulation. An extensive industry network has evolved to support this aim and most recently the appointment of a new post by SOLT and UK Theatre has further strengthened the structure. Phill Brown has been appointed as Head of Risk and Technical. This is a new post and will be key to representing and connecting SOLT and UK Theatre into the heart of the sector where the guidance on how to meet the statutory duties is developed and constantly reviewed. Prior to his appointment as Head of Risk and Technical, Phill had been both Group Head of Safety & Environmental Services and Risk Management Director at Ambassador Theatre Group.
Phill’s appointment is very timely. The Health & Safety Executive, responsible for enforcing health and safety legislation, is in general relying more and more upon the resources of individual sectors to provide guidance for both practitioner, regulator and enforcer.
Whereas at one time major industrial sectors might have looked to the HSE to produce the guidance that set out practical measures to achieve compliance, particularly through the production of Approved Codes of Practice, the HSE most certainly no longer has the resources or, they would claim, the remit to produce such guidance. They fully expect that role to fall upon practitioners working in all the sectors of trade and commerce.
The Theatre Industry is well placed to meet this changing approach. The structures that have been developed and continue to evolve within the industry are increasingly recognised by a regulators and practitioners alike. As a result of the specialist and esoteric nature of our practices we, as an industry, have been at the forefront of self-guidance and are very well positioned to accept the mantle of self-regulation. Indeed, many responsible for presenting theatrical productions would vehemently defend self-regulation as being the only appropriate approach to maintaining a healthy and safe industry and one that can continue to be at the forefront of live entertainment.
At the heart of our sector is the Theatre Safety Committee. There are currently ten organisational members of this group: Equity, Musicians Union, BECTU, Stage Management Association, Little Theatre Guild, ITC, Institute of Entertainment and Arts Management, UK Theatre, SOLT and the ABTT. This group seeks to promote safety in our industry both directly and for example in the case of technical matters, by supporting the ABTT in the production of a technical Code of Practice.
To support its role in producing a Code of Practice there is the ABTT Safety Committee, engaged in producing guidance for the sector and providing a forum and safety enquiry and helpline service.
At the core of the technical Code of Practice is Technical Standards for Places of Entertainment, the “Yellow Book”. This is co-published by the ABTT, the Chartered Institute of Environmental Health, the District Surveyors Association, and the Institute of Licensing. The Technical Standards are edited and constantly revised by the Standing Committee for Technical Standards.
SOLT and UK Theatre has its own Technical Committee, which is chaired by Phill in his role as Head of Risk and Technical and which provides a service to SOLT and UK Theatre members and acts as a conduit for communication with the rest of the industry’s structures.
There is also the Safety Advisors Group in Entertainment (SAGE) which has a membership drawn from a broader base of venues and sectors but shares many individual members with the groups already described.
As a whole the theatre and live performance sector connects with the Health and Safety Executive and the legislature via the Joint Advisory Committee for Entertainment.
The technical Code of Practice produced for the Theatre Industryis recognised as an Established Standard by the HSE under the terms of their Enforcement Management Model. This means it has similar standing to standards published by the British Standards Institute (BSI). Although not statutory it is therefore the case that being able to demonstrate compliance with the guidance contained within this Code of Practice is likely to be a defence in law.
It is by these structures and groups that we as industry are able to put in place effective guidance that serves to appropriately regulate our sector. Although by no means new to this world we welcome Phill to continued participation in his new role as Head of Risk and Technical.
*1. It shall be the duty of every employer to ensure, so far as is reasonably practicable, the health, safety and welfare at work of all his employees. Health and Safety at Work etc. Act 1974