What happened about the fair in May and October in 2020?
The coronavirus pandemic led to the May and October 2020 Fairs being cancelled. The decision to cancel the May Fair was straight forward as little was known about the virus and the organisers cancelled it straight away. Discussions concerning the October Fair were more complex and a letter of intent to issue a Direction was given to the Fair organiser to ensure that the October event did not go ahead, because of the rising rates in the county and across the country. The organiser then agreed to cancel the event.
How many people are expected to attend the Fair on Thursday 13 May?
Organisers have advised us that around 500 people are likely to attend the fair.
What are the rules about events taking place at this time?
Some rules on what you can and cannot do changed on 12th April, and a number of restrictions remain in place. The ‘rule of 6’ still applies, therefore no person may participate in a gathering that consists of more than 6 people outdoors or involves more than two families. However, provided people abide by this rule, outdoor hospitality venues, zoos, theme parks, and drive-in cinemas can operate. Self-contained accommodation such as campsites and holiday lets, where indoor facilities are not shared with other households, can also reopen. This also includes trading such as car boot sales, agricultural events, village fetes, community events and farmer’s markets. The organisers have made a case that this event is a trading fair and community event. More guidance is available here https://www.gov.uk/government/publications/coronavirus-covid-19-organised-events-guidance-for-local-authorities/coronavirus-covid-19-organised-events-guidance-for-local-authorities .
What is the role of the Safety Advisory Group in events?
The multi-agency Safety Advisory Group (SAG) is a partnership exists to advise and support organisers of events to make them as safe as possible. It has no powers to permit or stop an event; these rest with individual agencies. Event organisers are encouraged to engage with the SAG at the earliest opportunity to improve their event plans and risk assessments. If the SAG do not feel the risk assessments are adequate they can suggest improvements. The fair is held on private land and so agencies have limited powers in usual times in relation to the event. The rules relating to Covid are covered below.
How can an event be stopped under the Covid-19 regulations?
The Coronavirus No 3 Regulations give the County Council the power to make Directions in relation to individual premises, events and public outdoor spaces. A Direction can only be made if the following conditions are met:
- Giving a Direction responds to a serious and imminent threat to public health
- The Direction is necessary for the purpose of preventing, protecting against, controlling or providing a public health response to the incidence or spread of infection by Coronavirus in the Local Authority’s area AND
- The prohibition, requirements or restrictions imposed by the Direction are a proportionate means of achieving that purpose
Therefore, the Local Authority would look for evidence that the organisers have considered the safety of participants, usually through a COVID-19 specific Risk Assessment/Event Plan. It is reasonable to request this to ensure that an assessment of the level of threat to public health can take place. In Gloucestershire, this process has been adopted by the SAG with environmental health / public health specific advice requested as appropriate. As part of the County process, an equalities impact assessment is also required to determine whether the measure may disproportionately affect people with protected characteristics.
Where a SAG, or any other person raises concerns about the Covid-19 safety of an event or setting, the County Council Public Health will consult with relevant SAG members. Where there is agreement that agencies believe there is sufficient evidence that the three conditions above are met, the County Council will trigger proceedings for the legal process to be invoked and a Direction to be issued. Usually, the first step would be a letter signalling the County Council’s intent to serve a direction if improvements or information is not provided. So far, Gloucestershire has not needed to move from the serving of the letter to proceeding to a full Direction during this pandemic.
Further information on the regulations is available here: https://www.gov.uk/government/publications/local-authority-powers-to-impose-restrictions-under-coronavirus-regulations/local-authority-powers-to-impose-restrictions-health-protection-coronavirus-restrictions-england-no3-regulations-2020#making-a-direction
How have you assessed the Public Health Risk?
Members of the Safety Advisory Group (SAG) including Gloucestershire County Council, Environmental Health, Gloucestershire Constabulary, Trading Standards and Licensing worked with the event organiser to ensure that they were aware of the requirements to make the event COVID safe.
The organisers have had conversations with SAG members about the following public health matters and the concern of spread of coronavirus infection to the wider public, including (but not limited to):
- Local infection rates – Gloucestershire is currently an area of low prevalence, people will be coming into the county from across the country. However historically local residents close most of their commercial premises and avoid contact with the attendees of this event.
- Social distancing – Ensuring that people maintain social distancing continues to be very important. All visitors would need to stay 2 metres apart from those who are not in their own household or support bubble where possible, or 1 metre with extra precautions in place (such as wearing face coverings) if they are unable to stay 2 metres apart.
- Protecting health – The organiser will need to demonstrate plans for protecting attendees and workers from increased risk of infection whilst organising or attending the event as they are likely to come into contact with large numbers of people. As the event is taking place outside, the risk of infection is low, provided other measures such as social distancing are followed.
- Staying in groups of 6 (or 2 households) – In addition to the business aspects of the event such as market stalls, it is proposed that there will be overnight stays. Overnight stays are permissible in self-contained accommodation. Social gatherings of over 6 people are not currently permissible as they are recognised as a primary source of outbreaks. When people meet together in a social gathering, they are less likely to maintain social distancing. Ensuring that visitors and those staying overnight remain in groups of 6 (or 2 households) will need to be a priority for the event organisers.
- Track and trace – Communities of Gypsy/Roma Travellers are by their nature transient and in previous outbreak scenarios, this has posed many challenges in public health management. It has been very difficult to identify and trace all affected individuals which has posed a further risk to public health. The organisers have agreed to collect details of attendees to mitigate this risk.
- Risk assessment – The Fair organiser has provided a risk assessment and event plan that sets out measures that will help to mitigate COVID-19 risk, providing assurance that the event could take place in a COVID-19 safe manner.
Why haven’t you stopped this event?
Coronavirus regulations have given powers for events to be cancelled if there is deemed to be a serious and imminent risk to public health. At this time, the organisers have provided sufficient information to show that they understand the Coronavirus rules, and that they will implement measures to make this a safe event under Covid-secure guidance (see FAQ on measures to be taken). This means that the three tests required for a Direction to be served are not met.
Is it a risk that people are coming from other parts of England?
There is of course still a risk from Covid as the various restrictions are lifted and as the vaccine roll out continues, for example many people are travelling more for work and holidays to and from the county. Rates are currently significantly lower everywhere in England and the availability and take up of testing is much better than it has been previously.
In relation to the Fair specifically, the organiser has been asked to encourage travellers to take a Covid-19 test when they arrive and to follow all necessary steps should they test positive
Why can this event go ahead, but others can’t?
As a number of the Government’s roadmap milestones have been reached similar events are already taking place and we had to compare with these e.g. car boot sales, farmer’s markets, zoos and similar attractions and the ability for people to stay in self-contained accommodation, for example on campsite. We also need to act proportionately and only issue a Direction where other options to allow the event to run safely have been explored and are unable to be implemented.
How have local residents been consulted?
Whilst there hasn’t been a direct consultation with local people, community views have been represented in SAG discussion. Ultimately though, the decision as to whether or not there are sufficient grounds to use legal powers has to be based solely on an assessment of the risk to public health and whether or not organisers have sufficient mitigation measures in place.
What measures will the organisers put in place?
The organisers have stated that they will take the following necessary steps to ensure the event goes ahead in line with their risk assessment and event plan:
- Record visitors’ details to help with contact tracing, if required
- Provide a QR code to all attendees to support contact tracing, if required
- Ensure adequate spacing between vehicles
- Encourage visitors to wear face coverings in line with current national advice
- Display COVID safety reminder signage across the site
- Ensure sanitizer is available for visitors
- Encourage/promote symptomatic and asymptomatic testing
- Have extra staff on duty to remind and encourage all visitors to follow all necessary advice including social distancing and rule of 6/two households
What will organisations be doing to ensure organisers take the necessary steps to make the event safe?
To monitor compliance with these requirements, additional Covid support officers will be on duty for the duration of the event and will engage with visitors and the organisers to minimise the risk to all concerned.
We are organising a testing unit to be located in the vicinity of the fair, to provide easy access to testing. Appropriate advice will be given to anyone who does test positive to minimise the risk of onward transmission.