Football Governance

Written evidence submitted by the Football Licensing Authority (FG 75)

1. I am writing as the Chief Executive of the Football Licensing Authority in response to the invitation to submit written evidence on matters of relevance to the Select Committee Inquiry into football governance.

2. Given our remit, this response relates primarily to governance in so far as it affects spectator safety. I recognise that this is a specific issue, but it is an important one, and some of the points raised are likely to be applicable to wider governance issues.

Summary

· While the Football Licensing Authority regulates local authorities in their roles in relation to safety at football grounds, it is primarily football clubs who are responsible for spectator safety. Good governance and a clear commitment from the highest levels within a club are critical to successful safety management.

· We believe it remains important to regulate in this area, but we are committed to doing so in a light touch way, through a combination of guidance, assistance and monitoring. We aim to help bring about the permanent change of culture whereby consistently high standards of safety are maintained by clubs or ground management taking responsibility on their own initiative.

· Improvements to spectator safety in football over the past twenty years have been significant. In a number of cases the requirements placed upon football are more rigorous than those placed on other sporting or commercial organisations. The role of the UK in addressing spectator safety is internationally recognised, and football must claim its share of the credit for raising standards and making stadia both safer and more inclusive.

The Role of the Football Licensing Authority (FLA)

3. The FLA is an independent public body set up under the Football Spectators Act 1989, and funded by the Department for Culture, Media and Sport. It has a statutory responsibility to keep under review the discharge by local authorities of their functions under the Safety of Sports Ground Act 1975. This legislation covers Wembley Stadium, the National Stadium Cardiff and all Premier and Football League grounds.

4. Our primary role relates to spectator safety. The FLA works with 92 league football clubs and 81 local authorities. We issue annual licenses to each of those clubs and provide advice, training and support to them and a wide range of related bodies. We have played a critical role in transforming spectator safety at football grounds over the past 20 years, and we are widely regarded as a world leader in this field.

5. While the local authority will issue a safety certificate for a particular football ground, the responsibility for the safety of spectators rests not with the local authority but with ground management (usually the football club). Our interest in good governance within football therefore primarily relates to its impact on spectator safety, and our role as the Government’s main advisor and regulator in this area.

6. It is our experience that good governance, and having proper policies, procedures and training arrangements in place within clubs is critical in relation to spectator safety. Anecdotal evidence suggests that a clear commitment and understanding of the issues from the highest levels within a club can have a very positive impact on safety management and standards.

7. One example of this relates to the training of stewards. It is the responsibility of sport ground management to ensure that all safety personnel are trained and competent to undertake both their normal duties and their roles under the management’s emergency and contingency plans. Training should be conducted by occupationally competent persons using suitable training resources and material that will provide the relevant underpinning knowledge to satisfy the requirements of the National Occupational Standards for those relevant vocational qualifications.

8. With many clubs facing financial pressures, and a reported reduction in the level of external funding available for steward training, many who work within football safety are concerned about the possible impact on spectators. The football authorities (the Football Association, the Premier League, the Football League and the Football Safety Officers Association) have developed resources to help stewards achieve vocational qualifications and develop relevant skills, knowledge and attitudes [1] , and clubs can demonstrate a clear and ongoing commitment to safety through the training and development they provide at a local level. Failure to invest now in training and development could lead to a detrimental impact over the longer term. In the case of reduced steward training, levels of qualified stewards could drop, clubs might not have the resilience to deal with staff turnover, and levels of safety for spectators could be affected. While this example relates specifically to a safety issue, the questions it raises (such as how to secure and sustain investment in the current climate for activities which may be perceived to be of lower commercial value, or as ‘back of house’ functions) could be applicable across a range of other areas.

New Style Safety Certification and light touch regulation

9. While we strongly believe that there is an ongoing role for the FLA as a regulator in the area of football spectator safety, we are encouraging football clubs and local authorities to move towards a less prescriptive approach to safety certification, whereby clubs are positively engaged in identifying and implementing appropriate conditions and safety procedures to which it can fully subscribe and that provide the appropriate level of safety for spectators.

10. We believe this approach will bring the regulation of spectator safety at sports grounds into line with other areas of public safety where requirements are more overtly based upon a series of risk assessments and operations manuals. This leaves the initiative and the responsibility with the management, which is able to tailor the requirements more closely to its particular needs and circumstances. However, for such an approach to be successful there needs to be a safety culture throughout all levels at the club, and particularly within the board.

11. Part of the FLA’s role is to bring about, through advice and persuasion, a permanent change of culture whereby consistently high standards of safety are maintained at every Premiership, Football League and international football ground by the clubs or ground management taking responsibility on their own initiative rather than in response to requirements imposed by other bodies. We will continue to work with the football authorities to achieve this aim.

Football’s role in raising standards and making stadia safer

12. One question posed by the Committee was "Are there lessons to be learned from football governance models across the UK and abroad, and from governance models in other sports?"

13. In relation to spectator safety at football grounds, the UK is seen by many to be leaders in the field. In November 2010, Sepp Blatter, President of FIFA, said to the Prime Minister "You have given to the world security in the stadiums. You have built all your stadia, there are no fences and everyone is sitting. This is a big legacy, an important legacy you have given to the world. If only all the national associations in the world, and their leagues had stadiums like this, we would have more fair play in our game."

14. Spectator safety at football grounds has been transformed over the past 20 years, and the UK has been at the forefront of many of the improvements. The Football Licensing Authority is the author of the World’s leading sports safety publication (the ‘Green Guide’) which is used around the world. Recently the Kenyan Premier League used it to develop guidance after a tragic incident at the Nyayo stadium in 2010. This is not the only example of our advice or guidance being used internationally. While our remit currently extends to England and Wales the Sports Ground Safety Authority Bill, which is currently passing through Parliament, would, if enacted, see our role expand with the possibility of advising other sports and other countries. This will help provide greater consistency in the application of sports grounds safety advice, both nationally and internationally.

15. While coverage is often given to problems within football governance, it is important to acknowledge where improvements have been made, and those areas in which the UK leads the field, such as sports ground safety. Some might suggest that improvements to spectator safety in football clubs in England and Wales are in spite of, rather than because of, the level of corporate responsibility for safety within management boards of football authorities and clubs. I would hope that it is not the case, and want the FLA to continue to develop and maintain strong relationships with football authorities and clubs at all levels, and to build together on the successes and achievements in this important area.

16. I appreciate that the committee will wish to consider a much broader range of issues than spectator safety when reaching conclusions on football governance, but it may be illustrative of some of the wider issues faced, and is hopefully of interest in relation to the questions posed about how football serves spectators.

17. The FLA has previously said that it believes that true safety comes when those who are responsible understand and believe in it for themselves. It cannot be imposed through external regulation, and we therefore seek always to educate, advise and persuade. We do not rely upon our statutory powers unless there is no reasonable alternative. By and large this has been an approach which has ensured that, in terms of their safety at sports grounds at least, current and future generations of football supporters of clubs across the country are very well-served.

18. We would be happy to provide more information if that would be helpful.

January 2011