ARTICLE
10 September 2024

Protection Of Premises Legislation: Implications For The Health And Social Care Sector

The UK Terrorism (Protection of Premises) Bill, also known as Martyn's Law, mandates health and social care providers to implement procedural measures to safeguard against terrorist attacks. Key requirements include risk assessments, security plans, staff training, and emergency strategies
United Kingdom Food, Drugs, Healthcare, Life Sciences

Preparing the health and social care sector to be more resilient and better prepared to respond to threats.

The UK Terrorism (Protection of Premises) Bill, published in draft by the UK Government, is a significant step towards improved safety and emergency preparedness in the UK. Named in honour of Martyn Hett, a 2017 Manchester Arena victim, Martyn's Law seeks to fortify security in public spaces, including where healthcare is delivered, and better prepare organisations to respond to terrorist threats.

Below we explore the implications of this highly anticipated legislation for the health & social care sector and ways in which you can prepare your organisation to be more resilient in the face of active assailants regardless of motivation.

Under the impending Protect Duty legislation, re-announced in the recent King's Speech and expected to become law later in 2024, venue operators, including health and social care providers and non-profits/charities, will be required to ensure public safety from the threats of terrorism.

The consultation on the Bill earlier this year sheds some light on what future intention is for the Bill including specific requirements for organisations. These requirements mandate to 'have in place procedural measures' aimed at reducing, as far as reasonably practicable, the risk of physical harm to individuals at the premises in the event of an attack. These measures will cover evacuation, invacuation, lockdown and communication strategies. While the Bill primarily addresses terrorism, many attacks are carried out by lone assailants driven by a variety of personal motivations. Therefore, a broader focus is essential.

The legislation emphasises the importance of proportionality, ensuring that security measures are reasonably practicable and implemented through a tiered approach:

  • Enhanced Tier: Applies to any venues with a capacity of 800 or more. These venues must conduct detailed terrorism risk assessments and implement robust security measures. This includes creating and practicing security plans and providing specific training to staff
  • Standard Tier: Applies to venues with a capacity of 100 to 799. These venues need to have procedures to reduce harm in case of a terrorist attack, such as clear evacuation and lockdown plans. However, they aren't required to make physical alterations or purchase additional equipment

Ultimately, if passed into law, there is likely to be an 18-24 months gap before implementation. The initial focus appears to be on Standard Tier operations. The legislation may not address the Enhanced Tier until the Bill has proven effective for 'Standard' size organisations - a recommendation from the select committee, though not yet formally confirmed.

Does the legislation apply to the health & social care sector?

Simply put, yes.

The former drafting of the Bill defines 'hospital' with a reference to S.275 of the National Health Service Act 2006, which does not make a distinction between NHS or independent hospitals, with the intention that both were captured by this legislation.

UK health and social care providers are considered vulnerable to attacks under the Protect Duty legislation due both the nature of services, locations and type of attack.

Health and social care facilities are often busy publicly accessible spaces that provide critical services, making them potential targets for active assailants. The open and welcoming nature of these environments, combined with the presence of vulnerable individuals, can increase their attractiveness as targets for those who seek to cause significant harm and disruption. The potential for harm is further exacerbated by the high-profile ambassadors or patrons of many sector organisations and the types of events held for fundraising purposes, often attended by high-profile individuals, which can raise the level of risk.

Historically, most UK attacks were the work of organised groups with centralised command structures. Today, however, most attacks are perpetrated by individuals acting alone, often not motivated by terrorism, which can make them more unpredictable and harder to prevent. Sadly, incidents in recent years serve as a reminder that attacks can occur anywhere to anyone.

Providers must keep in mind the diverse threats that may impact their spaces, such as knife or gun violence, explosives, or vehicle assaults, carried by individuals or groups. In addition, providers must also be diligent in evaluating the potential for both general and targeted attacks and the risk of mass harm. There is a need to assess the vulnerabilities of publicly accessible buildings and remain vigilant in updating security plans in response to evolving threat levels.

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The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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