Game shooting can be exempt from restrictions on meeting outdoors where it qualifies as an organised sport. But what should operators do to ensure compliance with the rules?
Although the COVID-19 guidance currently varies depending on your location in Scotland, for now, non-contact, outdoor organised (i.e. generally, run by a business, or a club) sport is currently allowed in all regions. This means that the limit of six people from a maximum of two households meeting outdoors does not apply to organised game shoots. However, this exemption does not mean that the activity can continue as normal with no restriction.
Perhaps most significantly, restrictions on travel into and out of level three areas will apply to game shoots because travel for organised sports does not qualify as "essential travel". This means that where the event is hosted in a level three area, it will only be possible for those resident in the same local authority area to attend and people living in level three areas will not be able to travel outside of their local authority area to attend shoots.
Where travel restrictions do not apply then - as with almost everything at present - employees and participants from different households should socially distance, and practice good hand hygiene. Organisers should take steps to avoid those infectious with COVID-19 from attending and should have systems to allow for effective tracing of attendees if someone attending later tests positive for the virus.
What does that mean in practice?
Token gestures or paper exercises are not enough; substantive and effective measures have to be taken - even if they hamper the enjoyment or the profitability of the event.
A risk assessment should be carried out to cover all the day's activities, including the specifics of arrival, transport and hospitality. A system should then be devised that reduces the risks identified to the lowest level reasonably achievable, and staff should be trained.
However, it is not enough to simply devise a system and then inform employees and participants what is required of them; ensure that it is actually understood and followed. There should be a process for removing those who do not comply. It is not acceptable for employees or participants to behave in a reckless way, even if they are only putting themselves at risk – but importantly, the event organiser is responsible for ensuring that any risks are reduced to the lowest level reasonably practicable. The rationale for exempting organised sport is the understanding that the event will be controlled, and the guidance enforced, by the organiser.
Before the event
Make clear to participants that they cannot attend if they, or someone in their household, has tested positive, is self-isolating or is displaying symptoms. Written confirmation should be obtained from participants that they have received and understood the guidance, and meet the requirements. Participants should also provide test and protect information before they attend.
On the day
Consider screening participants by taking their temperature on arrival.
A record should be kept of those attending, their test and protect details and their confirmation that they and their household are free from the need to self-isolate.
You should provide good facilities for handwashing or sanitisation, in particular when people are moving from outdoors to indoors, or using transport.
Equipment can be shared, but must be cleaned in between users.
Key areas of concern
Much of the activity on a shoot should be capable of being carried out in compliance with social distancing requirements, however there are some group aspects that could prove more difficult to manage.
- Transport
- Hospitality
- Group briefings
- Accommodation
Ideally participants and employees should walk from point to point during the shoot, or travel in vehicles with members of their own household. However, that will not always be possible and communal transport can be used where necessary, if good systems are put in place.
This is likely to mean that the number of passengers in communal vehicles is reduced, with empty seats set aside to create space. Face coverings should be worn when inside the vehicle and the vehicle should be well ventilated. There should also be a system whereby passengers are returning to the same seats in the same vehicle during the event, to reduce exposure to surfaces contaminated by others. Passengers should not sit opposite each other, and it may be possible to erect physical barriers in vehicles to avoid this happening.
Where possible this should be offered outdoors, however with the seasons changing, indoors may be the only option. In any event hospitality should comply with the COVID-19 requirements for that sector. Given the regional variations in relation to restrictions, it is important to confirm what is in place for your area.
However at present this broadly, means that no more than six people from two households should be in a group and two or one metre social distancing should be observed between people who are not from the same household. Eating and drinking should only take place when seated and masks should be worn when indoors unless eating or drinking. Ventilation should be optimised and queuing should be avoided.
It is important that these continue and include directions in relation to behaviour required for compliance with the COVID-19 guidance.
When delivering a briefing, it may be easiest to have participants seated in the same arrangement as will be used for hospitality; to ensure social distancing and to allow greater control of people arriving and leaving.
It is not possible for people to share self-catering accommodation unless they are from the same household. Hotel accommodation can be used by members of different households, so long as each household has its own room and facilities.
Further guidance available
Further guidance on how to safely operate shoots and other activities in the Country Sports sector has been jointly prepared by various sector organisations including the Scottish Association of Gamekeepers, Scottish Land & Estates and the British Association for Shooting and Conservation.
The obligations on those organising game shoots are not insignificant, however they are achievable with good advance planning and discipline on the day.
Contributor
Legal Director
