Cost of Martyn’s Law for large public venues

Martyn’s Law is due to come into force around 2025/2026. Publicly accessible premises that fall within scope of the law and have a capacity of 800 or more are assumed to be more attractive to terrorists than smaller venues with less capacity. Therefore, they’re expected to have greater (enhanced) counter terrorism measures in place. This article estimates the cost of implementing these enhanced measures. It should act as a guide for owners of large venues who wish to budget for compliance with Martyn’s Law.

There are two kinds of costs

Large public premises in scope with a capacity of 800 or more face costs split broadly into two categories: People cost and Intervention cost.

People cost

The government has published an impact assessment. This outlines three kinds of people costs, all of which are opportunity costs, the cost of taking people away from their usual activity:

1. Familiarisation with the law
2. Training
3. Terrorism risk assessment exercise

1. Familiarisation with the law: £12.31

It’s estimated a manager will take 28 minutes to read the law and given a manager’s average employment cost is £26.39 per hour, the cost of familiarisation is £12.31

2. Training: £2,077

Training consists of three elements:

i) Direct staff training

It’s assumed large public venues will use the government’s free training material to directly train 10% of their staff. Large venues have on average 182.6 staff members. Therefore, the total number of staff being directly trained is 18.26. Training is assumed to take 3 hours and the average staff employment cost is £17.50 per hour.

Therefore, the cost of training 18.26 people x £17.50 employment cost x 3 hours = £959

ii) Indirect staff training

The remaining 90% of staff will be indirectly trained via emails etc which take 10 minutes to read. The total number of indirectly trained staff is 182.6 people x 90% = 164.34 people. Indirect training takes 10 minutes with an employment cost of £17.50 per hour = £2.92 per person training cost.

Therefore, indirect training cost is 164.34 people x £2.92 per person training cost = £479

ii) Preparation of material for indirect staff training

The indirect training of staff will happen through the 10% of directly trained staff sending emails etc. to untrained staff. It’s estimated the preparation of these materials will take 2 hours per person. The number of directly trained staff is 182.26 x 10% = 18.26. The employment cost is £17.50 per hour per staff member.

Therefore, the cost of preparing materials to send to staff for indirect training is 18.26 people x £17.50 x 2 hours per hour employment cost= £639

Total training cost is: £959 (direct staff training) + £479 (indirect staff training) + £639 (Preparation of material) = £2,077

3. Terrorism risk assessment exercise: £880

The risk assessment is assumed to take a similar amount of time as the Management of Health and Safety at Work Regulations risk assessment. It’s thought 7.5 senior staff members will take 4 hours each to undertake the work. And, the employment cost of senior staff is £29.34 per hour.

Therefore, 7.5 people x £29.34 per hour employment cost x 4 hours = £880

Frequency of people costs

The frequency with which these costs are incurred is as follows:

1. Familiarisation with the law: One off
2. Training: Every two years
3. Terrorism risk assessment exercise: Annual but after the first year take half the time

Total people costs each year

The government’s impact assessment suggests the people costs will be incurred over time as follows:

• Year 0 Familiarisation + training + risk assessment
• Year 1 Risk assessment x 50%
• Year 2 Training + risk assessment x 50%

Intervention cost

‘Intervention costs’ are measures necessary to make large public premises compliant with Martyn’s Law. The risk assessment should highlight those measures that are required to be compliant with Martyn’s Law.

The government’s impact analysis lists a number of measures that will help public premises be compliant with Martyn’s Law:

• Business continuity plans
• CCTV
• Communication plans
• Engagement with CTSA and Police
• HVM Barriers
• Panic buttons
• Physical security measures
• Police intervention plans
• Policy for suspicious items
• Search and screen measures
• Security control rooms
• Security guards
• Trauma first aid kits
• Walkie talkies

Not all these measures will be required and it’s likely most premises will have some measures already in place. For example, the impact analysis suggests 90% of premises surveyed already have some CCTV in place. But, the risk assessment may suggest more or different cameras are necessary.

Budget guide: Intervention costs

Below is a budget guide for intervention costs:

• Business continuity plans: Possible for senior staff member to self-deliver but can take a number of days to draft. Review annually.
• CCTV: Installation costs can be from £1k – £100k+. Maintenance cost 5-15% of install cost.
• Communication plans: Usually forms a part of a business continuity plan.
• Engagement with CTSA and Police: Occasional meetings.
• HVM Barriers: The government’s impact assessment suggests install cost of £20k+. Sophistication and location will also drive costs. Annual maintenance required.
• Panic buttons: Install cost from £100 with ongoing connection cost.
• Physical security measures: Could include access control, fences etc. Costs unknown but can be significant.
• Police intervention plans: Cost unknown.
• Policy for suspicious items: Possible for senior staff member to self-deliver in half day if they have suitable experience
• Search and screen measures: Range in costs, from bag search by a trained person to metal detectors.
• Security control rooms: Manning cost can be significant. For example, one operative in attendance 24 hours per day, seven days a week will cost £150k+ per annum.
• Security guards: Budget employment cost of £50k+ per annum for a security guard, Monday – Friday, 9am to 5pm
• Trauma first aid kits: The government’s impact assessment suggests £60 per kit
• Walkie talkies: £10 – £15 per month per walkie talkie

Conclusion

Because many large public premises already have counter terrorism measures in place, along with training and risk assessments, the cost of compliance with Martyn’s Law could be as little as reading the law: £12.31. On the other hand, large venues which do not have any counter terrorism measures or training in place could easily face a cost of £500k+, if security guards and other expensive interventions are necessary.