Formal Response to the
Consultation Draft – Strategy for
the Horse Industry in
· 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
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?
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:
Aim 1: Enhance the horse industry's image and increase participation
Aim 2: Boost the economic performance of equestrian businesses
Aim 3: Raise equestrian skills, training and standards
Aims 4, 5 & 6 carry equal importance.
C. Priority actions
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.
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
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?
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:
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
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.
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.
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
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.
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
E. My role
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?
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.
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.
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)?
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
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.
No further comments on individual chapters
H. Any other comments
Do you have any other views you would like us to take into account?
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.
If you would like us to treat your response as confidential, please say so. Otherwise we may publish it.*
My response is not confidential. You are free to publish whatever you choose.
J. Signing off
This response has been made by: