- The health and safety regime imposed duties on both SMG and Showsec which were relevant to the safety of event-goers.
- The licencing process in Manchester did not consider the risk of a terrorist attack in deciding whether to grant a new licence or what conditions to attach.
- Police officers and staff who consider licensing applications did not consult with expert counter-terrorism police officers, such as CTSAs, before deciding whether to make representations to the local authority on whether to grant a licence and what conditions to attach.
- Manchester City Council’s licensing enforcement regime failed to identify possible breaches of SMG’s entertainment licence. One of those possible breaches may have contributed to the failure to prevent the Attack.
- The SIA’s enforcement regime was insufficiently robust to identify a long-standing practice at the Arena in relation to Showsec’s use of unlicensed stewards to search bags.
- The Security Industry Authority’s investigation into a potential breach of the licensing regime in relation to the use of unlicensed Showsec staff to monitor CCTV at the Arena did not identify that SMG was using staff to monitor CCTV who required a licence but did not hold one.
In this Part, I will consider the three statutory regimes which were particularly relevant to the matters I am investigating. They are the health and safety regime, the licensing regime and the Security Industry Authority regime. Each are regulated by primary legislation.
My review is not intended in any way to be exhaustive, it is confined to aspects of those regimes most obviously important to the events of 22nd May 2017.