Formal
Response to the
Consultation Draft – Strategy for
the Horse Industry in
A. Consultee
·
Riding Safely
This response is made from two perspectives:
·
in overall terms as an end-user of horse industry
· considering how
health, safety & environmental risk management issues are being addressed
by the strategy as a safety professional with an insight of the horse industry
B. Strategic aims
Question:
Do you agree with the broad
direction for the future of the industry as expressed in the six strategic
aims? Do you have any comments on it?
Response:
Yes. The six strategic aims
have evolved, developed and widened from the five strategic issues originally proposed
in the Henley Centre report. Considering
the consultees who have contributed to this Consultation Draft it now appears
to embrace the wider industry consensus.
However it is not clear from the Consultation Draft whether the
aims are ranked in order of importance or all carry equal weighting.
While it is appreciated that the aims are closely interlinked it
appears that some carry more weight in ensuring the sustainability of the
industry than others.
For that reason I would rank the aims in the following order of
importance:
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More
Important |
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Aim 1: Enhance the horse industry's image and increase
participation |
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Aim 2: Boost the economic performance of equestrian
businesses |
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Aim 3: Raise equestrian skills, training and standards |
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Aims 4, 5 & 6 carry equal importance. |
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C. Priority actions
Question:
In your opinion, which of the 38
numbered proposals for action in the strategy are most important for the future
of the horse industry? Please choose not
more than six proposals. If you wish, say why you think they are critical.
Response:
The proposals that I am suggesting have been chosen on the basis
that they are strategically key to the future success and sustainability of the
horse industry. While the request was
for not more than six proposals given the opportunity I would have made the
same selection of the first five (i.e. Proposals 1, 3, 7, 8, 10) and all
of the proposals contained within Aim 3 (To raise equestrian skills, training
and standards). Skills and training are key to the future of the horse
industry.
Proposal 1: Central industry communications function.
Why: The industry has been identified as being
fragmented. This will continue and the industry will not improve its image and
maximise performance unless there is better communication between and delivered
to all sectors. I fully support the
statements in 1.1 – 1.5.
There is evidence to support that even those at senior levels
within differing sectors of the horse industry are unaware of initiatives being
undertaken in other sectors thus denying the benefit of economies of scale which
could assist the whole horse industry.
Concern: The action
detailed in the proposal may not be wide enough and requires further amendment.
This is addressed in section D
Proposal 3: The role of
riding schools
Why: The importance
of riding schools must not be underestimated.
The point has already been made in several documents, but
essentially riding schools are the entry point and introduction to the industry,
often leading to the next step of horse ownership.
The future existence of riding schools is under threat and without
them a safely controlled environment in which to learn to ride will be denied
to many. This might impact on welfare
and safety standards.
The Henley Centre Report identified that the economic value from
riding lessons allied with the associated sale of equestrian products are of
major significance to the industry.
Concern: The action
associated with Proposal 3 is not specific.
This is addressed in section F.
Proposal 7: Business
professionalism
Why: The horse industry is often seen as a
cottage industry locked in the culture of the 1970s. There is often a perception of the public (and even end-users) that the horse
industry lacks the business professionalism exhibited in other similar
industries. This perception is dangerous
to the image of the industry. In
addition, internally within the industry a lack of business professionalism may
be leading to poor business performance.
Criticality is adequately explained by sections 2.8 & 2.9 of
the draft and in section 6.3.2 of the Henley Centre report.
Proposal 8: Fiscal and
regulatory constraints
Why: To those sectors of the industry that are
trading in the margins, ensuring a level playing field is critical to their
future existence.
Personal Protective Equipment (riding hats and body protectors) is
relatively inexpensive but essential for the safety to those who use and work
in the industry. Periodic replacement is
required due to the natural deterioration of materials used. These items, essential for safety purposes,
should attract zero rating VAT.
I fully support and endorse the statements 2.13 – 2.16
Proposal 10: Insurance
issues
Why: Increasing insurance premiums are
affecting the viability of many businesses within the horse industry.
Concern: The proposed action only partially goes
towards addressing the problems associated with insurance and in itself is not
a complete strategic solution.
This is addressed in section D
Proposal 21: Skill levels
and training needs
Why: Nothing to add to comments made in 3.10
which I support.
D. Major omissions and amendments
Question:
Are there any major omissions
from the draft strategy, or major changes which should be made to it? For
example, would you like to see other proposals for action included, or major
changes made to draft proposals? Why?
Response:
Yes.
1. Major Omission - Health, Safety &
Environmental Risk Management
·
There are no
specific proposals within the draft strategy that address the management of the
risks associated with health, safety and environmental issues that may seriously
impact on public and employee health & safety and affect the public
perception, viability and business performance of the horse industry.
·
Taking the overall scope of the strategy these issues need
to be kept in proportion and perspective but nonetheless share a similar status
as the Welfare Strategy in that their
appreciation and effective delivery of industry wide solutions are vital to all
six strategic aims and the future sustainability of the horse industry.
·
The effects of fragmentation across the horse industry, as
identified in the Henley Centre Report, clearly impact on the areas of health
& safety risk management.
·
There are inherent risks associated with riding or simply
being around horses. Sadly, many of the
accidents that occur are not associated with the inherent risks but with risks
that have not been identified and managed.
·
An understanding and improved management of risks that can
be controlled will lead to reduced accidents, thereby enhancing the horse
industry's image, boosting economic performance, and further address the
problems associated with insurance.
Looking more in-depth at the
industry:
·
There is not a co-ordinated industry led approach to health,
safety and environmental risk management issues and associated training
requirements.
·
Core health, safety and environmental information are not
available. Such information could
substantially benefit the industry through consistency of content and message
allied with economies of scale.
·
In general, documented business orientated health, safety
and environmental information does not appear to be available to businesses
from the societies/trade bodies that represent them. Where it does exist in one sector and could
benefit other sectors the information does not appear to be shared. At a strategic level the left hand of the
industry doesn't appear to know what the right hand of the industry is doing.
·
It is an industry where many businesses are not compliant
with health, safety and environmental legislation. There is evidence to suggest that even where
there is the additional verification through approval processes legal
non-compliance is not being detected.
·
The horse industry is woefully starved of health, safety and
environmental statistical data. There needs to be a mechanism (through the
central industry communications function?) to obtain reliable data from sources
both internal and external to the industry so that it can enable an overview to
determine where the real risks lay and target resources to manage them
accordingly. (Note: the issue raised in
2.22 and Proposal 11 relating to Standard Industrial Classification codes is
also an issue for the collection of health & safety statistical data)
·
There do not appear to be strong established links at a
strategic level with the Health and Safety Executive (HSE) and other similar
external agencies. HSE have been
proactive in the agricultural sector in running
I would suggest an additional proposal to address these issues:
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Proposal 39 –
Managing Health, Safety and Environmental Risks. Action: Set up an
industry working group with external professional advice to: ·
create and implement a health, safety and environmental
risk management strategy Which would include but not be limited to: ·
identifying key industry health, safety and environmental
risks ·
ensuring the development and communication of industry
core information and guidance ·
developing mechanisms to obtain industry specific safety,
health and environmental performance data (both reactive and proactive) ·
ensuring appropriate targeted training Resources: to be
determined Priority: high Timescale: short-term |
2. Re: Proposal
1: Central industry communications
function.
Communication internally with the industry and externally with
agencies and overseas horse industries' is vital to the ongoing success of the
overall strategy. I believe that the
remit of the action associated with Proposal 1 needs to be flexible and
dynamically react to the requirements of the industry. For example the success of Proposal 39 above
would be dependent on the central industry communications function. But clarity is essential between the future
roles of the British Horse Industry Confederation (BHIC) and that of the
Central Industry communications function.
In order to obtain the best quality information from external
agencies when requested there needs to be a single credible mouthpiece for the
horse industry. The BHIC was formed to
satisfy this requirement when dealing with Government. Could this role to be expanded to
communicating with other agencies (e.g. HSE) or overseas horse industries?
This is a subject for internal debate within the industry that
requires resolving. I have no doubt that
an industry based appointed single mouthpiece for dealing externally to the
industry is required.
3. Re: Proposal
10 - Insurance issues
The proposed action only partially goes towards addressing the
problems associated with insurance and in itself is not a complete strategic
solution.
Resisting claims which have no merit are usually client
based. The proposed action will
undoubtedly assist riding schools.
However, the proposed action does not address the increasing
number of civil claims being submitted by employees. Insurers have commented that the key to
preventing claims is by better record keeping and risk management.
In addition, the proposed action does not include tackling
legislative issues which increase insurance premiums.
Some but not all of these issues can be addressed through the new
Proposal 39.
However, I would suggest that there may need to be additional
proposals to address all of the problems associated with insurance.
4. Major Omission - Best Practice Abroad
Whilst we work to identify best practice at home it is important
to recognise the best practice of governments, horse industries and their
representative organisations in other countries which could help us achieve a
sustainable future for the horse industry in the
Whilst this may occur already within some sectors of the horse
industry the international sharing of best practice information does not appear
to be occurring with respect to health, safety & environmental risk
management issues.
As an example, Proposal 10 as already discussed is seeking to
address the problems associated with insurance.
However,
An extract from the July 2004 Australian Horse Industry Council
newsletter states:
“Over the past few years the
AHIC has worked to ensure that we can enjoy our horses with the protection of
insurance at an affordable cost. One
aspect of this was to improve the way many horses business were managed,
especially with regard to record keeping and risk management. This led to the development of the Code of
Practice and HorseSafe. This has made it
easier to interest companies in providing us with insurance. Secondly we worked with State governments to
ensure that their laws recognised waivers and acceptance of risk by
participants as a defence against law suits.
The situation is now much improved.”
It goes on to add…
“Over the last couple of years
the AHIC had to concentrate on HorseSafe and the Code of Practice. The insurance scene has settled down somewhat
and we have some other issues to consider.
I am pleased to announce that there will be a number of developments in
the next 12 months that will be of benefit to the horse owners of
Clearly while the
There do not appear to be established formal routes for the
sharing of best practice with other countries, particularly with risk
management issues.
If the proposal to share best practice abroad was adopted it would
be important to determine whether the formal route for contact was established
through the BHIC or Central industry communications function. To gain maximum benefit from Proposal 39
there may be dependencies on Proposal 40.
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Proposal 40 -
Best Practice Abroad Action: Establish links with horse industries
and their representative organisations in other countries with a view to
sharing best practice. Resources: to be
determined Priority: medium Timescale: short-term |
5. Major Omission - Monitoring of known associated strategies and
forthcoming legislation
The draft states
"The welfare of horses is
vital to all six strategic aims. Because
of this special position, it is to be the subject of a separate but related
equine health and welfare strategy, which is being developed as part of the
animal health and welfare strategy for
Whilst this seems sensible, it seems to be an omission from this
strategy not to monitor known associated strategies (i.e. Animal Health and Welfare Strategy for Great Britain Health/Equine
Welfare Strategy for Great Britain and Welfare) and forthcoming legislation
(i.e. Animal Welfare Bill) and
consider the implications of whether there will be any direct impact on the
proposals made in this strategy.
Take for example the licensing of livery yards under the Animal
Welfare Bill proposed secondary legislation. It is estimated that there are currently
10,000 livery yards. The estimated
possible additional cost to meet minimum standards for each establishment could
be between £165 and £1000. All new
owners/managers of livery yards will require a minimum qualification in horse
care. The cost to establishments would include: licence fee; achieving minimum
standards set by statutory code of practice; staff training; and any additional
veterinary fees.
Such licensing, should it occur might result in significant
demands on training resources (as an example).
It could compromise the delivery of actions under Aim 3 to raise
equestrian skills, training and standards.
Unless the Strategy for the Horse Industry has a mechanism to
monitor significant changes happening across the industry, delivery of the
strategy itself may be compromised.
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Proposal 41 -
Monitoring of known associated strategies and forthcoming legislation Action: The Central Industry Communications
Function to monitor known associated strategies and forthcoming legislation for
significant changes that may impact on the horse industry and communicate
pertinent information at an early stage so that appropriate pro-active action
can be implemented. Resources: to be
determined Priority: high Timescale: short-term |
E. My role
Question:
Which of the numbered proposals
in the draft strategy (or any additional proposals you have made in section D)
would you expect to participate in?
Response:
I would expect to participate in any of the proposals where it is
identified that an input on health, safety & environmental risk management
issues is required.
If adopted, I would be happy to take a leading role on new
proposal 39.
Proposals where my area of expertise may be helpful could be 1, 7,
10, 11, 19, 21, 22, 23, and 29.
Question:
If you represent an
organisation, do you accept responsibility for implementing any of the numbered
proposals (or additional proposals you have made)? If you do, please identify
the proposals, describe your role, and say what resources you would expect to
commit to them.
Response:
Not applicable
F. Implementation
Question:
Do you think the draft strategy
stands a good chance of being implemented? How can we best ensure effective
implementation? Do you have any ideas about where the resources should come
from (apart from any comments in section E above)?
Response:
Possibly.
It is dependent on how the strategy is progressed and implemented once
agreed.
The Consultation Draft makes no mention of ongoing management,
communication or implementation of the strategy
(Note: a similar approach to that taken in the Animal Health and Welfare Strategy for Great Britain -- Chapter 9 --
Putting the strategy into practice -- which advises on measuring success,
managing strategy and communicating strategy would be useful to be included in
the final Horse Industry Strategy).
It clearly requires an implementation plan that is based on SMART
objectives.
(SMART = specific, measurable,
achievable, relevant personnel & resources, time based)
As an example, I would not consider the following actions to be
specific and therefore not measurable - 3, 6, 7, 14, 15, 18
Put plainly, some of the actions are "woolly" and
require review to ensure that they become more detailed and specific.
I support section 7.1.3 of the Henley Centre Report and suggest that this should be taken into account
in any implementation strategy:
“Five steps to strategic implementation
a) Establish an implementation
team of high calibre individuals from across the industry
who are signed up to the
principles of the strategy, the notion of cooperative working,
and who are genuinely committed
to long term strategic development and growth
within the horse industry.
b) Develop a national strategy
and a blueprint for local level implementation, which will
then need to be ‘localised’
according to geographical specificities.
c) Establish who will be doing what and when. Identify
how success will be judged.
Remember that few organisations
can manage to implement more than five strategic
goals at any one time.
d) Identify short term ‘wins’
and longer term goals and time lines for implementation.
e) Undertake to identify and
promote best practice at the local level, thus encouraging
continual engagement with the
‘grass-roots’”
G. Individual chapters
Question:
If you have any comments on the
introduction and the chapters on the six strategic aims - in addition to what
you have already said in sections B to F above - please include them here.
Please head comments on the introduction 'Introduction', comments on the
chapter on strategic aim 1 'Aim 1', and so on.
Response:
No further comments on individual chapters
H. Any other comments
Question:
Do you have any other views you
would like us to take into account?
Response:
Yes.
1. The strategy lacks clarity in the
classification of priorities.
There are nine proposals identified with the priority as
"short-term" (i.e. within one year) detailed in the strategy.
The proposals are:
• Bring the industry together nationally
• Raise standards of business performance
• Encourage targeted continuing professional development
• Address problems associated with insurance
• Promote the UK as a source of quality goods and services through preparation
of a promotional guide
• Identify skill levels and training needs
• Extend British Equestrian Federation's coaching development programme
• Share British Equestrian Federation's facilities strategy with other riding
bodies
• Encourage unaffiliated bodies to engage
Within
the strategy the priorities are defined as short/medium/long term. These are
timescales. Priorities usually relate to importance and may be defined as
high/medium/low. In the strategy it is not clear whether short-term equates to
high priority. Where items are identified as short-term is it because they are
high priority or simply easy to achieve within the proposed timescale?
For example, taking proposal 8 of the Strategy -- Ensure a level fiscal and
regulatory playing field -- this is assigned a "medium term"
priority. To many this issue is a very high priority, particularly the
"many" that are trading in the margins. Could it be that it is a high
priority but will require a medium term timescale (1 -- 5 years) to resolve?
By assigning timescales as priorities rather than a hierarchical priority scale
it is difficult to determine where the real priorities are. I feel that this is
a fundamental flaw of the document.
2. Monitoring the effectiveness
of the Strategy
In the Executive Summary under "Resources and
monitoring" section 21 states "We
will monitor the effectiveness of the strategy, and report annually on its implementation". Has a monitoring methodology been established
and criteria set? If so it would be
useful to include these details in the final Horse Industry Strategy.
I. Confidentiality
Question:
If you would like us to treat
your response as confidential, please say so.
Otherwise we may publish it.*
Response:
My response is not confidential. You are free to publish whatever you choose.
J. Signing off
This response has been made by:
Dated: