Broads Authority | Safety by the Water guide | Draft consultation version |September 2019

Broads Authority Safety by the Water guide Draft consultation version September 2019

Contents 1) Introduction ...... 3 2) Consultation on the Safety by the Water Guide ...... 3 3) The ‘ Chain’ ...... 4 4) Water related casualties - Facts and Figures ...... 5 5) National Water Safety Forum and UK Drowning Prevention Strategy ...... 6 6) Legal drivers and case law ...... 6 7) Guiding principles for managing drowning and water safety risks...... 7 8) Safety Management and Risk Assessments ...... 9 7.1 Introduction ...... 9 7.2 Risk Assessments ...... 9 7.3 The Plan-Do-Check-Act model (PDCA) ...... 10 9) Water safety plan ...... 12 8.1 Introduction ...... 12 8.2 Water safety plan guide and template ...... 12 8.3 Keeping the water safety plan up to date...... 12 8.4 More information ...... 12 10) Water Hazards ...... 14 9.1 Introduction ...... 14 9.2 Nature of the water ...... 14 9.3 Consider existing activities and layout of the site and wider area ...... 14 9.4 What would cause people to fall in? ...... 14 9.5 Cold-water shock ...... 15 9.6 Speed of water ...... 15 9.7 Depth of water ...... 15 9.8 Bed of water body ...... 16 9.9 Location – urban area/rural area...... 16 9.10 Risk matrix from other documents ...... 17 9.11 Getting out – what makes this difficult/easy ...... 17 9.12 Construction phase of the scheme and construction workers...... 17 11) Types of water safety features/measures ...... 18 10.1 Sources of information ...... 18 10. 2 Safety features/measures need to reflect the site and how it will be used ...... 18 10.3 The impact of water safety features on an area ...... 18 10.4 Responsibility ...... 19 10. 5 Safety Features/Measures ...... 19 Broads Authority | Safety by the Water guide | Draft consultation version |September 2019

10.6 Social media and apps ...... 19 10.7 Diverting people away from the hazard ...... 19 10. 8 Fencing ...... 19 10.9 Public Rescue Equipment (PRE) – general ...... 20 10.10 Lifebuoys (life rings) ...... 20 10.11 Throw bags/lines with and without floatation devices ...... 22 10.12 Reach Poles/Rescue Poles ...... 24 10.13 Grab chains ...... 24 10.14 Rescue ladders ...... 26 10.15 Hand holds ...... 28 10.16 Signage ...... 29 10.17 Education ...... 29 10.18 Training ...... 30 12) Other considerations ...... 31 12.2 Insurance ...... 31 12.3 Local characteristics – heritage, landscape, wildlife ...... 31 12.4 Permits/licences/notices? ...... 31 13) Sources of information ...... 32 Appendix A: Risk Assessment Template ...... 33 Appendix B: Plan, Check, Do, Act ...... 34 Appendix C: Water safety plan guidance and template ...... 35 Appendix D Privacy Notice ...... 39

Broads Authority | Safety by the Water guide | Draft consultation version |September 2019

1 1) Introduction 2 The Local Plan for the Broads (Policy DM46) has a policy on safety by the water. The policy says that 3 if a development will lead to more people being near to the water, or make it more difficult for 4 people to get out of the water, it needs to consider risks related to water safety and put safety 5 features/measures in place as appropriate.

6 This guide assists in the delivery of the policy DM46. It provides applicants/scheme promoters as 7 well as decision makers (like Development Management Officers at the Broads Authority) 8 information on how to assess and reduce the risk of someone entering the water (who did not 9 intend to). It provides information relating to different safety measures and management options 10 that may be suitable in different locations.

11 The Broads Authority has produced this guide. The guide draws on and refers to various other 12 existing guidance and information. What this guide says is not necessarily anything new; it brings 13 together important considerations and information in one place to assist scheme promoters in 14 specifying safety measures and management strategies to deliver a development where water safety 15 is appropriately managed. We quote the source of the information and provide links to documents 16 that may be of relevance.

17 2) Consultation on the Safety by the Water Guide 18 This version is the draft for consultation. Please tell us your thoughts and suggest any changes you 19 think would make the Guide better and set out your reasons. This consultation runs from xxx to xxx. 20 We will then read each of the comments received and respond. We may make changes if we agree 21 with you. If we do not make changes we will set out why. The final Guide will be adopted at a future 22 meeting of Full Authority. Please email us your comments: [email protected].

23 This consultation document and consultation process have been developed to adhere to the Broads 24 Authority’s Statement of Community Involvement1.

25 Information provided by you in response to this consultation, including personal data, may be 26 published or disclosed in accordance with the access to information regimes (these are primarily the 27 Freedom of Information Act 2000 (FOIA), the Data Protection Act 2018 (DPA), and the Environmental 28 Information Regulations 2004). Please see Appendix D for the Privacy Notice.

29 Are you satisfied that this consultation has followed the Consultation Principles? If not, or you 30 have any other observations about how we can improve the process, please contact us at 31 [email protected].

1 Our current SCI is here: http://www.broads-authority.gov.uk/__data/assets/pdf_file/0006/576609/Final-Adopted-Statement-of- Community-Involvement-November-2014.pdf Broads Authority | Safety by the Water guide | Draft consultation version |September 2019

32 3) The ‘’ 33 Drowning often has complex and multiple causes – but they are preventable with simple and 34 coordinated action. Interventions such as creating safer environments, providing swimming lessons 35 and water safety education can help improve communities. (Source: UK Drowning Prevention 36 Strategy 2016).

37 Site owners/occupiers have a pivotal role in ensuring that the 250 accidental inland drowning deaths 38 a year in UK waters are reduced. However, they are not the sole responsible party, and they have to 39 balance their decisions and potential safety gains with other demands from visitors and the wider 40 community. (Source: Managing Safety at Inland Waters (2018)).

41 Accidental drowning can usually be linked to one or more of the following factors (Source: Health 42 and Safety in Ports (SIP020) – Guidance on Water Safety in Ports Date: April 2014): 43 • failure to provide, or properly maintain buoyancy equipment 44 • disregard, ignorance, complacency or misjudgement of a hazard by those unfamiliar with the 45 port environment (or marina, boatyard or waterbody) (e.g. Tombstoning2) 46 • unsafe behaviour 47 • lack of supervision or training 48 • inability to cope once a problem happens 49 • the absence of rescuers and rescue equipment/measures 50 • failure to take account of adverse weather or tidal conditions 51 • inadequate fencing, access equipment or deployment of equipment

52 The RNLI have identified the ‘Drowning Chain’ and how it can be broken to save lives.

53

2 Tombstoning is a fairly recent craze of jumping into water from heights. Broads Authority | Safety by the Water guide | Draft consultation version |September 2019

54 4) Water related casualties - Facts and Figures 55 These figures are for the Broads (Source: RoSPA 2019). 56 • Between 2009 and 2019 198 people have entered the water unintentionally, this does not 57 include those who are engaged in activities where entering the water is likely. 58 • Over the same period there have been 17 deaths from Drowning.

59 These figures are national figures. (Source: Managing Safety at Inland Waters (2018)). 60 • Inland water locations consistently account for more than half of all accidental drowning deaths 61 in the UK, on average 250 each year. 62 • In almost half of all known incidents the person did not mean to enter the water. 63 • Despite visits to waterways reflecting the wider UK population, fatal drowning mainly affects 64 adult males - 8 in 10 of all casualties. It is thought that males may adopt higher-risk behaviours, 65 for example swimming after drinking alcohol, not wearing buoyancy aids or being alone in or 66 near to water. 67 • Across all activities and ages, teenage and middle-aged males are consistently the most frequent 68 casualties. 69 • Among females those aged 55-59 are the most frequent casualties. 70 • Child drowning, among those aged 0-14 years, results in an average of 17 casualties a year. 71 • Two-thirds of all accidental happen along linear waterways, such as rivers/streams 72 and canals (62%). A quarter (23%) happen at enclosed features, such as lakes, reservoirs or 73 quarries. 74 • Communities with the largest population near to the greatest amount of water have a fatality 75 rate up to three times higher than those communities with the least. 76 • On average there are 21 drowning deaths every month but the number of drownings varies with 77 the seasons. Visitor numbers, activities and water temperature are factors which are thought to 78 contribute to this variation. 79 • It is rare but not unknown for rescuers to become victims while responding to emergencies 80 involving pets or people. Multiple fatalities are very rare events, often associated with poor 81 swimmers and/or with hazardous locations such as weirs and fast-flowing rivers. 82 • Overall, the rate of fatal drowning associated with water-based activity is comparable to 83 fatalities associated with everyday road travel. 84 • These rates are lower in a managed water sports facility or coaching scenarios with active 85 supervision and rescue on-hand. 86 • People walking form most of the remaining fatalities, with a small number of cyclists and 87 vehicles also among those who had no intention to enter the water.

88 These figures are national figures. (Source: UK drowning prevention strategy (2016)). 89 • Almost two in every three fatalities happen at inland waters such as canals and rivers, lakes, 90 quarries and reservoirs (62%). 91 • Coastal incidents account for the majority of those requiring a search and rescue response, but 92 result in just over 1 in 3 (38%) of all fatal incidents. Broads Authority | Safety by the Water guide | Draft consultation version |September 2019

93 5) National Water Safety Forum and UK Drowning Prevention Strategy 94 The National Water Safety Forum (NWSF) is a UK-wide association of organisations that have 95 interests in and responsibilities for water safety. It includes sports governing bodies, rescue services, 96 regulators, navigation and harbour authorities, local government, utilities, and other representative 97 groups.

98 The Forum works in partnership with Royal Society for the Prevention of Accidents (RoSPA) who 99 provide technical and administrative support. The National Fire Chiefs Council (NFCC) is a member of 100 the NWSF, as are some 80 local authorities, including the Broads Authority.

101 The Forum’s work is divided between six specialist advisory groups covering: beaches; inland water; 102 the sea; swimming; water sports and information/research and all report to a coordinating 103 committee.

104 The Forum has produced the UK Drowning Prevention Strategy 2016-26, which aims to reduce 105 accidental drowning fatalities in the UK by 50 per cent by 2026, and reduce risk among the highest 106 risk populations, groups and communities.

107 The Strategy's initial three-year phase will address the following targets: 108 • Every child should have the opportunity to learn to swim and receive water safety education at 109 primary school and where required at Key Stage 3; 110 • Every community with water risks should have a community-level risk assessment and water 111 safety plan; 112 • To better understand water-related self-harm; 113 • Increase awareness of everyday risks in, on and around the water; 114 • All recreational activity organisations should have a clear strategic risk assessment and plans 115 that address key risks.

116 The NWSF also provides the Water Incident Database (WAID) designed to provide comprehensive 117 information on risks from water-based activities.

118 There is also a webpage with information and advice: 119 https://www.nationalwatersafety.org.uk/advice-and-information/

120 6) Legal drivers and case law 121 You are strongly advised to read chapter 2 of Managing Safety at Inland Waters (2018) for 122 information on Legal drivers and case law. https://www.rospa.com/safetyatinlandwaters. This 123 chapter should be viewed as a tour of the key principles rather than the definitive position Broads Authority | Safety by the Water guide | Draft consultation version |September 2019

124 7) Guiding principles for managing drowning and water safety risks 125 Source: Managing Safety at Inland Waters (2018)

126 Please note that this may be more related to water related activities. Your scheme may not be an 127 activity as such, but these guiding principles may still be of relevance/importance.

128 There are several agreed principles which can be used to help frame your approach to establishing a 129 well-run site3.

130 Fundamentals 131 No activity can be made completely risk-free. Risks imposed on non-participants and over which 132 they have little or no awareness or control, can only be accepted if they are very low. This is the 133 principle of the voluntary acceptance of risk – no nasty surprises. The benefits of water-related 134 activities will be taken into account when making a balanced judgement of whether risks are 135 acceptable or further risk control measures are necessary. These benefits will include, among others, 136 health and fitness, access to the countryside and coast, social inclusion, economic development, 137 disability access, sporting objectives and building life skill and resilience.

138 As above, all the disbenefits and costs of water-related activity will similarly be taken into account. 139 These include provision of rescue services, access restrictions, and transfer to riskier activities e.g. 140 swimming in docks when pools close. As far as possible, avoid restricting access to water spaces or 141 facilities. Look ahead by assessing the risks that can be foreseen.

142 Learn from the past 143 Records of accidents, near misses and ill health, together with reports from the participants, inform 144 present-day decision-making. As far as possible, avoid additional regulatory controls. These should 145 only be considered where accident rates are high, multiple casualties occur, children, elderly or 146 disabled persons are involved, or the risk is unclear to participants or affects non-participants i.e. an 147 involuntary risk.

148 Responsibility 149 It is important to strike a balance between the self-reliance of the individual participant and 150 management interventions. The greater the competence and risk awareness of the participant, the 151 greater the scope for managing organisations not to intervene. Many benefits of water-based 152 activities can be realised by encouraging self-reliance, not dependency on a managing organisation.

153 Everyone involved in a water-related activity has some responsibility for ensuring their own safety. 154 Includes participants complying with best practice as set down by sports governing bodies, and 155 ensuring they are not impaired by drink or drugs.

156 Recognise that statutory bodies and organisations with management responsibilities may have only 157 limited powers to require or enforce.

158 Avoid as far as possible the use of risk controls which discourage people from participating in the 159 organisation or management of an activity. Many activities rely on the active support of non-

3 Developed by members of the National Water Safety Forum, and designed to help the forum make decisions on water safety issues, they complement the principles promoted by members of the Visitor Safety in the Countryside Group. They reflect aspects in case law along with well-established risk and safety management decision-making practices. Broads Authority | Safety by the Water guide | Draft consultation version |September 2019

160 participants, often given voluntarily. Excessive or insensitively-applied risk controls can discourage 161 this support and even threaten the continuation of the activity.

162 Recognise that children’s risk perception skills will not be fully developed. This must be taken into 163 account in the design of facilities and activities, and by parents/guardians in the supervision of 164 children. Partnership Recognise that people taking part in similar activities will accept different 165 levels of risk. Take this into account when planning facilities or activities. Higher levels of participant 166 competence may offset the need for other types of risk control. Recognise that risk control measures 167 for one participant group may create risks to others. For example, fences erected to prevent people 168 falling into water may impede rescues of people from the water. Work with groups that are 169 representative of participants to promote understanding and resolve conflict. Collect incident data in 170 partnership with others wherever possible. This will increase greatly the value of the collected data.

171 Awareness 172 Ensuring that participants are aware of and understand potential hazards and risks is the key 173 element in ensuring that risks are undertaken voluntarily. There should be no nasty surprises 174 awaiting participants. Information for and education of participants about the nature and extent of 175 hazards, the risk control measures in place, and the precautions which the participants should take 176 are crucial elements of risk control. Wherever possible, align safety information with other 177 information provided to the public. This could include leaflets, interpretation boards and websites.

178 Competence 179 Recognise that some participants overestimate their skills and abilities to a large degree; for 180 example, young men jumping into open water. Recognise that participants will have a range of 181 abilities to recognise any given hazard. Some will overestimate while others will underestimate and 182 sometimes fail to recognise a hazard exists.

183 Communications 184 Managing organisations, Land owners/managers, sports governing bodies and user-representative 185 groups need to effectively communicate the results of risk assessments and risk awareness material 186 to the participants and the public at large. When communicating with your audience take account of 187 the language, literacy and cultural needs of the target audience. Broads Authority | Safety by the Water guide | Draft consultation version |September 2019

188 8) Safety Management and Risk Assessments 189 8.1 Introduction 190 It is vital to approach each site on a risk-led basis, and consider those groups particularly at risk. 191 Different groups will have different risks; the level of voluntarily-accepted risk4 will also be different, 192 in addition to the perception of that risk5 (Source: Drowning prevention strategy).

193 The following behaviour traits all increase the risk of drowning or being involved in an accident 194 associated with the water: underestimating risks, lack of knowledge of the risks, lack of competence, 195 ill-informed thrill seeking and lack of parental supervision of children (Source: Drowning prevention 196 strategy).

197 8.2 Risk Assessments 198 The first step in assessing the risk arising because of your proposal is to produce a risk assessment. 199 This will assist in understanding the risk of people entering the water when they had not planned to 200 and guide you in ways to reduce the likelihood of this happening in the first place. The risk 201 assessment will help inform your approach to water safety. It will be an important part of your 202 Safety by the Water Plan.

203 An appropriate risk assessment should incorporate a review of the hazard, who could be harmed, an 204 evaluation of the risks, consideration of current precautions and a decision on whether these are 205 sufficient, a recording of those findings and a review at an appropriate time. (Source: Managing 206 Safety at Inland Waters (2018))6.

207 For more information, see Managing Safety at Inland Waters (2018), page 50. A template for your 208 use, taken from Managing Safety at Inland Waters (2018), is included at Appendix A and the diagram 209 and text below is also from that document.

210 Hazards are anything that may cause harm. Risk is the likelihood, high or low, that somebody could 211 be harmed by these and other hazards, together with an indication of how serious the harm could 212 be.

4 Voluntary risk is associated with activities in which individuals participate by choice, and where they use their own value system and experience to determine if the risk of a voluntary activity is acceptable to them 5 Risk perception refers to people’s subjective judgments about the likelihood of negative occurrences such as injury, illness, disease, and death. 6 Managing for health and safety (HSG65) might also be of relevance: http://www.hse.gov.uk/pubns/books/hsg65.htm. Also Five steps to risk assessment https://www.aber.ac.uk/en/media/departmental/healthsafetyenvironment/riskassessment/indg163(v2).pdf Broads Authority | Safety by the Water guide | Draft consultation version |September 2019

213

214 8.3 The Plan-Do-Check-Act model (PDCA) 215 Source: Managing Safety at Inland Waters (2018).

216 Water safety management must complement the other risk management issues that organisations 217 deal with. The Plan-Do-Check-Act model (PDCA) is suitable for organisations to adopt. It is widely 218 used within occupational safety, environmental and quality management settings and is the basis for 219 the Health and Safety Executive guide, Managing for health and safety 220 http://www.hse.gov.uk/pUbns/priced/hsg65.pdf.

221 It is critical that the organisation recognises that the PDCA approach is an ongoing process. Early on, 222 you may need to go through the cycle several times to reach a position where your organisation is 223 confident that the risks are managed effectively.

224 The aim is to encourage leaders to have a system in place that, should an incident occur, they have 225 confidence that the event was indeed an unforeseen accident and the event was not caused or 226 allowed to happen due to a failure to plan or to manage the inherent risks.

227 The cycle can be broken down into several subsections: Broads Authority | Safety by the Water guide | Draft consultation version |September 2019

228

229 See Appendix B for more details and go to page 40 of Managing Safety at Inland Waters for worked 230 examples. The Safety in docks Approved Code of Practice page 11 also has information on this 231 approach. Broads Authority | Safety by the Water guide | Draft consultation version |September 2019

232 9) Water safety plan 233 9.1 Introduction 234 Policy DM46 says that proposals/planning applications that increase the number of people accessing 235 the water or facilitate the enjoyment of land adjacent to the water or make it more difficult for 236 people to get out of the water, must address water safety and will need to produce a Water Safety 237 Plan.

238 9.2 Water safety plan guide and template 239 The Authority has produced a guide and template to assist developers/scheme promoters in 240 producing a well thought out, site-specific deliverable Water Safety Plan that meets the aim of policy 241 DM46. Please see Appendix C.

242 9.3 Keeping the water safety plan up to date 243 Water safety risks change as new developments are built, new businesses are established and new 244 trends emerge. New risks may be identified through experience. It is important to review the Water 245 Safety Plan regularly and update it as necessary so the interventions and activities within it are 246 having an impact.

247 9.4 More information 248 The following document, process, and considerations may relate to schemes larger than yours, but 249 might be of interest or relevance to anyone producing a Water Safety Plan.

250 There is a practical implementation guide to setting up a Water Safety Action Group and designing a 251 local Water Safety Plan. Go here: www.rlss.org.uk/Handlers/Download.ashx?IDMF=221fa53b-0571- 252 4adb-87eb-f8ecffffcb08

253 When producing the plan, have these questions in mind: 254 1. Is your plan achievable and within your means? 255 2. Do you have the financial and human resource to achieve success? 256 3. Do you have the right stakeholders engaged to ensure you deliver impact?

257 If you answer no to any of these questions, it does not mean activity has to stop but you may 258 consider adjusting your goals or considering what needs to happen to turn a no to a yes. It is 259 important to take stock of budgets and have a real expectation on people’s time when their input 260 may be as a volunteer or may need to be balanced with other work commitments.

261 It should be noted that the Authority takes no responsibility for Water Safety Plans produced for 262 schemes that are not designed or implemented by the Broads Authority. The Authority will provide 263 feedback on the Plan and place conditions on applications relating to the implementation of the Plan 264 and monitor these conditions at some point after permission is granted. Maintenance of and the 265 correct fitting of and training on the use of features is the responsibility of the applicant/landowner.

Broads Authority | Safety by the Water guide | Draft consultation version |September 2019

Broads Authority | Safety by the Water guide | Draft consultation version |September 2019

266 10) Water Hazards

267 10.1 Introduction 268 Understanding how someone might fall in, what would happen to them in the water and how they 269 will get out of the water is important for sites/schemes that mean there are more people near to the 270 water.

271 10.2 Nature of the water 272 Fundamentally, the nature of the water is of relevance. More detail is provided below, but generally, 273 things to think about are: 274 • Temperature, both at the surface and below 275 • Depth 276 • Underwater objects and unclear features such as aquatic plants 277 • Flow state, current, flood conditions 278 • White water and hydraulic features – stoppers and strainers 279 • Visibility 280 • Erosion features such as undercuts, river banks or siphons 281 • Water quality factors.

282 Another relevant issue to consider is the presence of blue-green algae. Bloom and scum forming 283 blue-green algae can produce toxins. Toxin producing blooms are called Harmful Algal Blooms 284 (HABs). In humans, toxins can cause rashes after skin contact and illnesses if swallowed. Illnesses 285 including skin rashes, eye irritation, vomiting, diarrhoea, fever and muscle and joint pain have 286 occurred in people who’ve swallowed or swam through algal scum. These haven’t led to long-term 287 effects or death but, in some cases, the illnesses can be severe. As such, aftercare of someone who 288 has entered the water might be an important consideration.

289 10.3 Consider existing activities and layout of the site and wider area 290 It is important to note that the risk may not necessarily come about as a direct result of the 291 development itself; it may be something already in place that causes the risk. As such, you should 292 ensure you consider an area wider that simply the area subject to the application/development.

293 It is important to note that policy DM46 and this guide applies to your scheme because your 294 proposal: 295 i. Increases the number of people accessing the water 296 ii. Facilitates the enjoyment of land next to water 297 iii. Increases the difficulty in getting out of the water

298 You need to think about what activity is already happening locally to prevent any further incidents of 299 the same nature and in the same locations. Local knowledge is key to this, along with access to any 300 risk assessments or risk profiling that will give an independent view of locations where people are at 301 risk of entering the water, accidentally.

302 10.4 What would cause people to fall in? 303 Assess the following by walking round the site: 304 • Are there any hidden obstacles? Broads Authority | Safety by the Water guide | Draft consultation version |September 2019

305 • Are there any trip hazards? 306 • Are surfaces in disrepair? 307 • Are surfaces slippery? 308 • Can the trip hazards be removed? 309 • Can the surfaces be repaired? 310 • How can obstacles be marked?

311 Are more people going to be near water at night because of your proposal?

312 Think about alcohol. The presence of alcohol or drugs is a contributory factor in at least 1 in 5 of all 313 adult drowning deaths, and as high as 1 in 2 for certain activities and ages. The effects of alcohol on 314 motor skills, perception, and behaviours are well known. (Source: Managing Safety at Inland Waters 315 (2018)).

316 10.5 Cold-water shock 317 (Source: Managing Safety at Inland Waters (2018)).

318 Immersion in cold waters below 16°C can be particularly hazardous, especially for those who do not 319 wear wetsuits/dry suits, and those who jump or fully enter the water quickly. A key adverse effect of 320 this is “cold water shock”, which is the body’s physiological response following immersion in cold 321 water. In summary, a person can temporarily lose the ability to control breathing, suffer a spike in 322 heart rate and blood pressure. These responses can be a precursor to sudden heart attack, loss of 323 swimming capacity and drowning through inhalation of small amounts of water.

324 Cold-water shock is considered a principal causal factor in many fatal drownings, especially where 325 the person accidentally falls, or quickly enters the water. Otherwise healthy individuals can become 326 incapacitated, making it extremely difficult for them to reach safety.

327 10.6 Speed of water 328 The faster the speed of water, the further downstream someone could travel and the greater the 329 risk of being knocked over if in the water. The faster the water, the harder it is to swim against to 330 reach safety. You need to identify areas of fast flowing water as this will influence your approach to 331 managing water safety – which Public Rescue Equipment (PRE) is required how many are needed 332 and where should they be located.

333 10.7 Depth of water 334 The depth of water will affect what someone who falls in can do – are they able to stand up, or do 335 they need to swim/tread water? It will also indicate if they will be partly or fully submerged with the 336 associated issue of cold-water shock. Also important is the range of depth – is the area tidal? The 337 distance to the top of the bank/quay heading to surface of the water is important and again this may 338 change subject to the tide.

339 Once in the water, the depth of water and distance between the surface or water and the top of 340 quay heading or bankside will also influence what the person can do to get out of the water and 341 what kind of safety feature/measure (and at what depth) is required. The selection of Public Rescue Broads Authority | Safety by the Water guide | Draft consultation version |September 2019

342 Equipment/measures will be influenced by the vertical distance between the casualty and the 343 rescuer. you will need to measure the height from the top of the bank to the water (perhaps over a 344 week or so).

345 It is important that the waterbody bed profile near the site is assessed as this again will influence the 346 selection of safety features.

347 Knowing this information will help you select the most appropriate safety rescue equipment. 348 Shallow water may just need a reach pole or throw line where deeper water will require some 349 buoyancy device to be deployed to help support the casualty.

350 10.8 Bed of water body 351 What is the bed of the water body near to the scheme? Is there litter, hidden hazards, mud, or 352 aquatic plants?

353 Obstacles could range from litter to shopping trolleys. If there are larger hazards not only could they 354 trap someone or cause them to trip over if they are wading over to the bank, they could cause injury 355 by someone falling on them. Silty mud could result in people sinking or being stuck in the mud. 356 Aquatic plants could tangle around someone.

357 Consider if there is anything you can do to clear the bed, particularly from litter. Knowing what the 358 bed of the water body is like and what risks this could bring will inform your approach to the 359 provision of safety features. If the bed of the water body is hard and gravel then this would provide a 360 surface for someone to walk on. If the bed was deep mud or thick vegetation then the control 361 measure may be different and more extensive to prevent people entering the water rather than 362 education and signage and PRE. It comes down to suitable risk control for the specific hazard.

363 10.9 Location – urban area/rural area. 364 The more people passing the area/coming to the area, the more people could fall in. On the other 365 hand, the more people that are around will make it more likely/quickly someone will be made aware 366 that there is someone in the water and they may be able to assist. However please consider the use 367 of the site at all times of the day and at different days of the week as the risk profile may change as 368 people use the area for different purposes.

369 In more urban areas, the design of a safety feature may not necessarily have as much of an impact 370 on the local character as in a rural area (subject to heritage considerations of course).

371 It is important that any proposals to address safety consider impact on heritage assets, landscape 372 character, ecology and tranquillity issues like dark skies.

373 As set out in the following section, the more rural/less developed, the more likely someone is to be 374 more experienced and take on personal responsibility and the level of hazard management is 375 minimal.

Broads Authority | Safety by the Water guide | Draft consultation version |September 2019

376 10.10 Risk matrix from other documents 377 As referred to in 9.9 and set out in page 4 of Managing Visitor Safety in The Countryside7 the more 378 rural/less developed, the more likely someone is to be more experienced and take on personal 379 responsibility and the level of hazard management is minimal. Conversely, in more urban 380 environments, previous experience is not expected and so the level and type of hazard management 381 is advanced.

382 10.11 Getting out – what makes this difficult/easy 383 If interventions fail and someone does enter the water not meaning to, you have to consider how 384 they will get out safely by self-rescue or someone else helping them.

385 10.12 Construction phase of the scheme and construction workers. 386 Your water safety plan needs to consider the safety of construction workers near to the water. 387 Perhaps workers wear life jackets when working close to the edge of the waterbody or temporary 388 safety features are put in place. The Broads Authority’s own policy is that if staff are working within 389 3m from the edge of the water, they must wear a personal floatation device (life jacket). Your water 390 safety plan needs to address water safety at all phases of the development.

7 Guiding Principles https://vscg.org/documents/uploads/Chapter_2_guiding_Principles.pdf Broads Authority | Safety by the Water guide | Draft consultation version |September 2019

391 11) Types of water safety features/measures

392 11.1 Sources of information 393 The following documents have informed this section: the emerging Tidal River Thames Guidance, 394 Health and Safety Executive Safety in docks (2014)8, Managing Safety at Inland Waters (2018)9 and 395 Health and Safety in Ports10, and Guidance on Water Safety in Ports (2017)11.

396 11. 2 Safety features/measures need to reflect the site and how it will be used 397 The risk assessment findings will direct you to what safety features are appropriate for your site. Any 398 safety feature/intervention needs to be designed and delivered so it targets the specific local issues 399 that are identified. They also need to reflect how the site is going to be used. The safety measures 400 that are considered need to be proportionate to the potential for drowning

401 The key questions are: 402 • What reasonable protection and/or prevention measures would be adequate to prevent 403 someone unintentionally falling into the water? This can reflect the hazard potential. The 404 hazard potential can be dependent on the location, accessibility and who is exposed to the 405 hazard (for example a business, a public house or a children’s playground). The use of fencing, 406 signage, education, social media and supervision should be considered.

407 • What rescue measures should be provided if someone could be in the water? Who (if anyone) 408 should be trained in using the equipment/measures? Any safety measures need to be suitable, 409 sufficient and well maintained to be in line with the UK Drowning Prevention Strategy 2016-26.

410 11.3 The impact of water safety features on an area 411 Sometimes the application of a control measure (such as a barrier, sign, enforcement policy) will 412 conflict with some of the user/visitors’ needs or wishes or the character of the area. This may affect 413 why people go there in the first place. So, when addressing safety by the water, it will be important 414 to understand the character and special qualities of the area. The final approach will need to balance 415 safety gains and possible negative impacts of the changes to the area.

Case Study – Durham12 • Areas by the River Wear have spectacular heritage. • Parts are also a designated UNESCO action area. • 56 water-related incident January 2010 to March 2015. Five resulted in drowning fatalities. • Durham City Centre Safety Group worked with RoSPA to address water safety risks. • Key outcomes, which considered the heritage needs of the area, are: o Improved lighting and safe routing information around the city o Engineered improvements to key sections of the riverside. o Increased provision of public rescue equipment at strategic positions along the riverside

8 Safety in docks. Approved Code of Practice: http://www.hse.gov.uk/pubns/books/l148.htm 9 Managing safety at inland waters guidance: https://www.rospa.com/safetyatinlandwaters 10 Various documents: http://www.hse.gov.uk/ports/publications.htm 11 Guidance on Water Safety in Ports: https://www.portskillsandsafety.co.uk/resources/sip-020-guidance-water-safety-ports 12 Full case study is here: https://www.rospa.com/rospaweb/docs/advice-services/leisure-safety/durham-case-study.pdf Broads Authority | Safety by the Water guide | Draft consultation version |September 2019

o Improved inspection and monitoring systems for the key risk areas o Awareness campaign to highlight new transport and route safety information, as well as alcohol safety awareness messaging and initiatives o New policy to ensure that all new builds are planned with water safety in mind.

416 11.4 Responsibility 417 When considering the level and extent of responsibility a duty holder (site owner/occupier) (site 418 owner/occupier) owes, there is a clear difference to be acknowledged in respect to people that are 419 employed by the duty holder (site owner/occupier), and those people who are visiting or using the 420 premises lawfully. That is to say that there is a different duty if people are employed by you or if they 421 visit/trespass. See also the legal section in the Managing safety at inland waters13.

422 11. 5 Safety Features/Measures 423 The following pages are examples of safety features. All of them can contribute to breaking the 424 drowning chain. There are a range of ways of addressing safety features and it may be that a few are 425 required to address the risk that you have identified.

426 11.6 Social media and apps 427 The use of apps and social media and other information streams can influence users. They can warn 428 them of the hazards before they visit the site.

Case Study – xxxxx Commented [NB1]: Case study to follow xxxxx

429 11.7 Diverting people away from the hazard 430 This is another way of dealing with a hazard. Lit walkways away from the water’s edge will 431 encourage users to use routes away from the hazard. The use of different textures or vegetation can 432 also be a soft way of informing users where they are expected to access or warn them when they are 433 coming close to the hazard.

Case Study – xxx Commented [NB2]: Case study to follow xxxx

434 11. 8 Fencing 435 Fencing should only generally be considered in urban areas with high footfall. The heritage aspects 436 of the site and adjacent area should be considered when considering fencing.

437 There are various national guidelines for the fencing exist (RoSPA, Port Skills and Safety Limited and 438 the British Standards Institution). If fencing is used, the duty holder (site owner/occupier) 439 (owner/occupier) must also consider if there may be a need to retrieve people from the area being 440 fenced and ensure adequate landing points (i.e., causeways, fixed ladders and gates) are provided. 441 Fencing could be used in areas where deep water or sudden drops into water exist

13 Managing Safety at Inland Water Sites https://www.rospa.com/leisure-safety/water/inland/ Broads Authority | Safety by the Water guide | Draft consultation version |September 2019

442 Where lockable gates are fitted to prevent unauthorised access, a refuge space should be provided 443 at the top of the ladder. That way someone can use the ladder to get out of the water and has 444 somewhere to get off the ladder. It is recommended that the gate should be fitted with a fire 445 brigade padlock so it can be unlocked by the emergency services

446 Fencing/barriers should be designed to prevent people from climbing over or ducking under them. 447 Parapets14 should be designed in a way that prevents people from sitting on them as that will 448 introduce additional hazards.

449 Another method of fencing is the encouragement and maintenance of natural foliage. This can be 450 equally as effective as constructed and installed fencing in preventing access to the waterline. 451 Foliage can also be combined with man-made fencing.

452 11.9 Public Rescue Equipment (PRE) – general 453 ‘PRE’ includes a wide variety of equipment such as lifebuoys, throw lines, grab chains, and rescue 454 ladders, to mention a few. The risk assessment will indicate what kind of PRE is best for your site.

455 If you decide to put PRE in place, you need to: 456 • Display Instructions that show how to use the PRE. 457 • Carry out regular checks on all PRE. Your risk assessment should indicate how often checks 458 should happen. The manufacturer might recommend checks as well. 459 • Consider the likelihood of damage and risk of vandalism, particularly in public areas. 460 • Check the PRE after it has been used and make sure it is put back in place.

461 The PRE put in place needs to be suitable for the section of waterbody. For example, any throw line 462 attached to a needs to be long enough to reach the waterbody, especially from a high bank. 463 Features need to be put where they can be reached or are obvious.

464 The following are types of PRE.

465 11.10 Lifebuoys (life rings) Lifebuoys: • Due to weight and size, cannot be thrown far. • Casualty can hold on to lifebuoy and stay afloat easily • Fairly cheap to install. Buoy and throwline around £40 to £60. Around £145 for post and housing plus installation. • Consider length of rope – needs to reflect width of water body and height of banks. • Can have impact on landscape/heritage, especially with casing/housing • Tend to be left out so can be vandalised Photo source: www.lifejackets.co.uk

14 A parapet is a barrier which is an extension of the wall at the edge of a roof, terrace, balcony, walkway or other structure Broads Authority | Safety by the Water guide | Draft consultation version |September 2019

466 Lifebuoys (due to their weight and size) are particularly effective where the person in the water is 467 relatively close to the shore or rescue craft. Your risk assessment will indicate if these buoys are 468 suitable for your site, where they should be located and how many.

469 When considering installing lifebuoys, the risk 470 assessment needs to understand the flow of the 471 waterbody in the area to see if a lifebuoy is the 472 appropriate device for that location. Lifebuoys tend 473 to be ‘dropped’ rather than thrown. If the casualty 474 could be out of reach due to the flow, a lifebuoy 475 might not be the most appropriate.

476 The line for the device must be able to float15 and 477 the maximum length of line should not exceed 25 478 metres (please allow for any drop from the Photo source: www.theworkplacedepot.co.uk 479 landside/bridge to the waterline).

480 Regular maintenance/inspection of Lifebuoys is essential to check the devices are available when 481 needed. Lifebuoys can be housed fully or partially to protect the equipment from the weather and 482 vandalism.

483 Lifebuoys should have reflective patches so they can be seen in the dark. They should also have grip 484 handles on the outside of the lifebuoy. To pull the person using the life ring to the shore/bank, a 485 throw line needs to be attached to the lifebuoy.

Photo source: www.caerlaverock.org.uk 486 Lifebuoys should be marked with their location and contact details so people who are helping 487 someone in the water knows who to call as well as their exact location. They should also have 488 contact details of maintenance personnel in case the equipment is damaged or missing.

489 If the device is regularly being vandalised/removed there could be grounds for the duty holder (site 490 owner/occupier) (owner/occupier) to consider removing the equipment permanently or considering 491 another intervention/feature.

15 RNLI recommends BS EN 699:1995 which is MCA approved Broads Authority | Safety by the Water guide | Draft consultation version |September 2019

492 A life ring could cost in the region of £40-£60. With accessories like a stand and casing, the cost is 493 around £135. A throw line is around £10.

494 11.11 Throw bags/lines with and without floatation devices Throwbags and lines: • Easy to use – can be thrown further and more accurately than lifebuoys. • Only small head or device or line to hold onto • Fairly cheap to install. Throwline is £10 to £40. Around £140 for post and housing plus installation. • Consider length of rope – needs to reflect width of water body and height of banks. • Can have some impact on landscape/heritage, especially with casing/housing • Can be left out so can be vandalised. Can also be carried around easily by staff for example. Photo source: www.austinkayak.com • Recommended for fast flowing water

Throwbags with floatation: • Easy to use – can be thrown further and more accurately than lifebuoys. • Casualty able to hold on to head and float. • Fairly cheap to install. Throwline with floatation is around £80. Around £140 for post and housing plus installation. • Consider length of rope – needs to reflect width of water body and height of banks. • Can have some impact on landscape/heritage, especially with casing/housing • Can be left out so can be vandalised. Can also be carried

Photo source: www.amazon.co.uk/Glasdon-B-Line- around easily by staff for example. Throw-Bag-Floatation/dp/B076T875MM • Recommended for fast flowing water

495 Throw Bags are lighter than Lifebuoys. The RNLI recommends that they have the same maximum 496 length of floating line as Lifebuoys (around 25m). They are recommended for fast flowing water 497 rescues. Some can incorporate a floatation device for the casualty to hold onto. Others only the 498 small head of the device and/or the floating line to hold onto or tie around themselves. Because 499 they are light, they can be thrown a greater distance and more accurately that lifebuoys. In some 500 situations, particularly where there is a strong tide or current, a throw line may be appropriate 501 either in addition to or in place of a conventional lifebuoy.

502 They may be kept inside or carried around easily or kept outside. Craft/vessels often carry Throw 503 Bags and/or Throw Lines to supplement the on-board Lifebuoy equipment. Broads Authority | Safety by the Water guide | Draft consultation version |September 2019

504 The general specifications for Throw Bags / Lines are that there should be a positive 505 flotation/buoyancy of at least 40N to assist in supporting a casualty in the water. The line must be 506 able to float, be visible with a maximum length of 25m (additionally there should be an allowance 507 for any expected maximum drop). Rope thickness should be between 6-13.5mm, made of 508 polypropylene staple and coiled in a bag which will deploy freely.

Showing a with floatation. Showing how to throw a throw bag. Photo source: https://uk.glasdon.com/water-safety-rescue-equipment Photo source: https://crewsaver.com

Throw bag casing and housing. Photo source: https://www.aspli.com Photo source: www.aspli.com Broads Authority | Safety by the Water guide | Draft consultation version |September 2019

509 Throw bags and throw lines cost around £30 to £40 depending on the length of the line. With a 510 floatation device they area around £80. A post and housing can cost around £110.

511 11.12 Reach Poles/Rescue Poles

Reach poles: • Can be just a pole, but can have crooks, snares or floatation collars fixed to the end. • Fairly easy to store and longer ones are telescopic. • Vary in length and therefore cost. • 1.5m reach pole can be around £40. 3m can be around £130. Other options with various fittings can be over £2,000. Can be up to 17m long. • Accurately delivers rescue and floatation devices direct to the

Photo source: www.mfc- victim. international.com/home/products/water-rescue/rescue- stick

Telescopic rescue poles offer the ability to accurately deploy a flotation/ rescue device to a casualty in the shortest time possible without the need to enter the water. They can be used as a pole on its own, or can have various attachments like hooks or floatation collars.

Showing how to use a reach pole . Various attachments are available for reach poles Photo source: www.ndiver-rescue.com Photo source: www.alternateforce.net

512 11.13 Grab chains Grab chains: • More than one grab chain at different heights will need to be put in place to reflect tidal range. Photo to follow • Tend to be used with ladders. • Allow the person in the water to hold on and move to a ladder. Broads Authority | Safety by the Water guide | Draft consultation version |September 2019

• Regular clearing of debris/vegetation required. • About £3.00 per metre which includes the brackets that are required to fit them to the piling and the shackles.

513 Grab chains allow a person who has fallen into the water to have a hand hold while awaiting rescue. 514 They can also be used to move through the water to a ladder. Grab chains should be provided on 515 river walls, moorings and marina, piers and abutments. Grab chains need to be put in place at 516 different levels to reflect the tidal range of the area so they can be grabbed no matter what the level 517 of the water is. It might be that 3 or more grab chains are needed at different levels in areas that are 518 subject to large tidal differences. Grab chains join up to ladders. Grab chains can catch debris or 519 vegetation in the water and need to be cleared regularly so they can be used easily.

Potter Heigham. Top most grab chains visible with more below the water. Shows chains combined with a ladder as well as a thrown line.

Photo source: Broads Authority

Showing grab chains with a sign pointing out where the nearest ladder is.

Photo source: Broads Authority

Broads Authority | Safety by the Water guide | Draft consultation version |September 2019

520 11.14 Rescue ladders

Rescue ladders: • Tend to be used with grab chains. • Regular clearing of debris/vegetation required. • Need to extend 1m below the waterline. • Can have up and over hoops to help the person get out, but this may advertise the presence on the land. • If flush to the bank, additional hand hold on the bank needed and designed so that they are not obstructed by ice or dirt and prevent tripping hazards. • Refuge space needed so person can get onto the land from the ladder. • Safety ladders are about £300- £350 each including handles and fittings etc and depending on how many you have made at the same time.

Photo source: Broads Authority

521 Rescue ladders tend to support grab chains. People in the water can use grab chains to move along 522 the grab chains to the rescue ladder so they can climb up the ladder and get out of the water.

523 Ladders should be considered where getting out of the water would otherwise be difficult; for 524 example, if there is a vertical bank or the land/water distance is above, say, 1m. Ladders should be 525 provided on any structure at the water’s edge from which persons may fall into deep water. This 526 includes quays, wharves, river berths and jetties.

527 The following diagram shows example specifications for rescue ladders. This style has up and over 528 rails. Broads Authority | Safety by the Water guide | Draft consultation version |September 2019

529 530 Broads Authority | Safety by the Water guide | Draft consultation version |September 2019

531 Ladders need to be designed to meet the requirements of standard BS 6349-2:201916.

532 Ideally the ladders should form part of the original construction, and be fitted in a suitable recess in 533 the face of the quay to protect them from damage by boats. Alternatively, timber baulks may 534 protect them. Ladders should extend to 1 m below the water line at any foreseeable state of the tide 535 (or to the sea/river bed where there is less than 1 m of water at the foot of the quay at low water). 536 Ladder locations should consider local foreshore topography and existing egress points.

537 In some areas, it might be appropriate to have the ladder finished flush with the parapet but with an 538 additional hand hold to help the person get up and off the ladder. This may reflect the potential 539 landscape character or heritage impact of having up and over rails. Suitable hand-grips will need to 540 be provided on the quayside. They need to be designed so that they are not obstructed by ice or 541 dirt. They should also be recessed or positioned to prevent tripping hazards. In order to make the 542 presence of ladders more obvious up and over hoops in accordance with BS 4211:200517should only 543 be provided if necessary for regular maintenance access etc., or where safety hand railing is 544 provided to the river’s edge.

545 Rescue Ladders should be designed to not to encourage people to access the river, but allow persons 546 to escape in an emergency. Where lockable gates are fitted to prevent unauthorised access, a refuge 547 space shall be provided at the top of the ladder. The gate should be fitted with a Fire Brigade 548 padlock to allow unlocking by the emergency services. You need to consider how ladders can be 549 seen in low light levels. Each ladder should be suitably protected against accidental damage, and 550 should enable someone who reaches it to climb from the water to the quay. All ladders should be 551 properly maintained. Ladders can catch debris or vegetation in the water and need to be cleared 552 regularly so they can be used easily.

553 11.15 Hand holds

Handholds: • The aim being that something is provided for the person in Photo to follow the water to hold onto. • Can have impact on landscape character and heritage. • Cost will vary depending on the material used.

554 Hand holds may take the form of hanging chains (as opposed to horizontal gran chains), fibre ropes, 555 fenders or other suitable material hung from the quayside. The actual bank protection or quay 556 heading may provide handholds. 557 558 Your risk assessment will help determine if hand holds are appropriate for your site and how many. 559 See Safety in docks; Approved Code of Practice for detailed guidance (page 35 and 36)18.

16 BS 6349-2:2019 Maritime works. Code of practice for the design of quay walls, jetties and dolphins: https://www.thenbs.com/PublicationIndex/documents/details?Pub=BSI&DocID=326737 17BS 4211:2005 Specification for permanently fixed ladders: https://www.thenbs.com/PublicationIndex/documents/details?Pub=BSI&DocID=294253 18 Safety in docks; Approved Code of Practice: http://www.hse.gov.uk/pubns/books/l148.htm Broads Authority | Safety by the Water guide | Draft consultation version |September 2019

560 All handholds need to be properly maintained. Care needs to be taken that if there is a substantial 561 tidal range hand holds will provide an adequate handhold at all states of the tide. Where smooth 562 ropes are used, the addition of regular large knots will assist a person in the water. Equally chains 563 with rings inserted at regular intervals will also provide a better grip.

564 Handholds should not impact on the character of the area. They should be suitable for use and be 565 protected where possible to avoid damage both to and from boats. In deciding whether these are 566 adequate, remember that someone in the water is likely to be cold, shocked, exhausted, and 567 possibly injured. Handholds should therefore be suitable for use in such a situation.

568 11.16 Signage 569 Your risk assessment may result in the need to use signs. The use of signs will need to consider the 570 impact on local character however.

571 All signage should conform to National and European standards and be pictorial. Hazards may need 572 to be clearly identified (i.e., deep water, fast flowing currents, and deep mud).

573 The RNLI has created a family of signs to direct to and identify the locations of 574 equipment/measures such as lifebuoys and emergency telephones.

575 Warning signs identify and inform when a hazard remains even after all other control measures are 576 in place. Signs must follow the national water safety standards.

577 Directional signage to assist in locating PRE including location identification information and 578 emergency telephones should also be considered

579 Instructions in languages or pictorial other than English should also be considered for non-English 580 speakers and tourists.

581 The following are of relevance for signage: 582 • RNLI ‘A guide to coastal public rescue equipment: https://rnli.org/-/media/rnli/downloads/rnli- 583 guide-to-coastal-public-rescue- 584 equipment.pdf?la=en&hash=CFB4DC27A02B8ABD8936CBB57FD97C45D60670A2 585 • ISO 7010:2019. Graphical symbols -- Safety colours and safety signs -- Registered safety signs 586 https://www.iso.org/standard/72424.html 587 • BS ISO 3864-1:2011 Graphical symbols. Safety colours and safety signs. Design principles for 588 safety signs and safety markings (published September 2011). 589 https://www.iso.org/standard/51021.html

590 11.17 Education 591 Water safety education is an important element of preventing unplanned entry into the river and 592 should be considered in addition to safety measures. The style and content need to be appropriate 593 to those who could be exposed to the hazards. For example; posters and flyers for riverside pubs 594 (water and alcohol do not mix), talks for local schools. There is much supporting material for 595 example the RNLI’s Respect the water campaign. Broads Authority | Safety by the Water guide | Draft consultation version |September 2019

596 National campaigns can provide a useful framework on which to hang local messages. The NFCC, 597 RNLI, and the Royal Lifesaving Society's Drowning Prevention Week and Don't Drink and Drown 598 campaigns are good examples. 599 • National Fire Chief Council’s Water Safety Week 600 • Don’t Drink & Drown Campaign 601 • Respect the Water 602 • Runners and Walkers Campaign 603 • Spring Clean 604 • Drowning Prevention Week

605 11.18 Training 606 Where a high-risk area has been identified and the duty holder (site owner/occupier) has employees 607 working/supervising in that area such as employees, bar staff, security personnel etc., they should 608 be trained in the use (and limitations) of the various public rescue equipment and basic 609 (including the treatment of cold-water shock). This training will improve the effectiveness of the 610 deployment of the equipment and assist in rescuing a casualty from the river and in achieving a 611 positive outcome for the casualty and rescuer.

612 There are a series of already established training programmes, used and designed by a variety of 613 water safety organisations. Below is a list of training programmes, initiatives and points to explore 614 that could provide solutions to your specific challenge: 615 • National Water Safety Management Programme – Programme for a variety of environments, 616 sectors and training needs https://www.rlss.org.uk/national-water-safety-management- 617 programme 618 • National Vocational Beach Qualification – For well-trained beach 619 https://www.rlss.org.uk/national-vocational-beach-lifeguard-qualification 620 • National Pool Lifeguard Qualification - For well-trained pool lifeguards 621 https://www.rlss.org.uk/national-pool-lifeguard-qualification 622 • Open Water Lifeguard - For well-trained lifeguards for open water spaces 623 https://www.rlss.org.uk/open-water-lifeguard-qualifications 624 • Community training and response – throw bag training, CPR (resuscitation), first responders. 625 Explore First Responder initiatives such as The GoodSam App 626 https://www.goodsamapp.org/ 627 • Project Shout – Progressing safety in open water activity and at open water venues 628 https://www.rlss.org.uk/pages/category/sh2out Broads Authority | Safety by the Water guide | Draft consultation version |September 2019

629 12) Other considerations 630 631 12.2 Insurance 632 You may want to explore insurance issues in line with the legal section at chapter xxx.

633 12.3 Local characteristics – heritage, landscape, wildlife 634 The Broads is a protected landscape. Any measure put in place needs to consider the impact on the 635 local character – landscape, heritage and wildlife.

636 12.4 Permits/licences/notices? 637 i. Planning 638 Waterside development, including new and replacement works, usually requires planning 639 permission. The Broads Authority is the local planning authority for the Broads. More information 640 can be found on the Broads Authority’s website or you can contact us for free advice.

641 ii. Works Licence 642 A licence will be necessary for the design and timing of installation of work which affects a publicly 643 navigable stretch of river. The Broads Authority is responsible for issuing the Works Licence. Full 644 details can be found on the Authority’s website.

645 iii. Environment Agency 646 rior written consent of the Environment Agency is required for any proposed works or structures in, 647 under, over or within nine metres of a main river or a flood/sea defence. Depending on the length 648 and type of works proposed a water framework assessment may be needed. Full details and how to 649 contact the agency can be found on the relevant section of the Government website.

650 iv. Landowner 651 You will need permission from the landowner of the riverbed over which your proposal will be 652 installed. You can find this information from the Land Registry.

653 v. Marine Management Organisation 654 You may need a marine licence from the Marine Management Organisation for carrying out works 655 There are certain exempted activities and more information on this and how to apply for a licence 656 can be found on the relevant section of the Government website.

657 vi. Notice to Mariners 658 If any machinery work or the scheme itself significantly affects navigation, the Broads Authority may 659 need to let boat users know. This involves a public notice placed in a local newspaper at least 35 660 days in advance of work. This will be at your cost but is administered by us. You can find full details 661 on our website.

Broads Authority | Safety by the Water guide | Draft consultation version |September 2019

662 13) Sources of information

663 • The UK national drowning prevention strategy 2016-2026 664 www.nationalwatersafety.org.uk/strategy/

665 • Visitor Safety in the Countryside Group Guidance 666 • Guide on managing safety in the historic built environment 667 https://vscg.org/publications/

668 • Safety in docks. Approved Code of Practice 669 www.hse.gov.uk/pubns/books/l148.htm

670 • RoSPA guidance on managing safety at inland waters 671 www.rospa.com/leisure-safety/water/inland/

672 • Local Government Association water safety toolkit 673 www.local.gov.uk/topics/community-safety/water-safety-toolkit

674 • Health and Safety in Ports (SIP020) – Guidance on Water Safety in Ports 675 www.portskillsandsafety.co.uk/sites/default/files/2017-05/SIP020%20- 676 %20Guidance%20on%20water%20safety%20in%20ports%20-%20issue%201%20- 677 %20April%202014.pdf

678 • A practical implementation guide to setting up a Water Safety Action Group and designing a 679 local Water Safety Plan 680 www.rlss.org.uk/Handlers/Download.ashx?IDMF=221fa53b-0571-4adb-87eb-f8ecffffcb08

681 • Health and Safety Executive: Risk Assessments 682 http://www.hse.gov.uk/simple-health-safety/risk/index.htm

683 • Health and Safety Executive: Plan, Do, Check, Act 684 http://www.hse.gov.uk/pubns/indg275.pdf Broads Authority | Safety by the Water guide | Draft consultation version |September 2019

Appendix A: Risk Assessment Template Source: Managing Safety at Inland Waters (2018). Go to page 37 of the Managing Safety at Inland Waters document for a worked example.

Location: Hazard: People at risk: Outcome:

Key risks:

Other site factors:

Findings and options Decision Actions Who / when / status

Broads Authority | Safety by the Water guide | Draft consultation version |September 2019

Appendix B: Plan, Check, Do, Act Source: Managing Safety at Inland Water Sites (2018)

Appendix C: Water safety plan guidance and template

C1 Introduction Policy DM46 says that proposals/planning applications that increase the number of people accessing the water or facilitate the enjoyment of land adjacent to the water must address water safety will be required to produce a Water Safety Plan.

Applicants will be required to consider the risks of people falling into the water and put in place means to help people while in the water and a safe way for them to get out.

The Authority has produced this guide and template to assist developers/scheme promoters in producing a well thought out, site specific deliverable Water Safety Plan. The Water Safety Plan template and guide are intended to meet the aim of policy DM46 and indeed the UK Drowning Prevention Strategy – to reduce accidental drowning fatalities in the UK by 50% by 2026 and reduce risk amongst the highest risk populations, groups and communities.

It should be noted that the Authority takes no responsibility for Water Safety Plans produced for schemes that are designed or implemented by the Broads Authority. The Authority will provide feedback on the Plan and place conditions on applications relating to the implementation of the Plan and monitor these conditions at some point after permission is granted. Maintenance of and the correct fitting of and training on the use of features is the responsibility of the applicant/landowner.

C2 Key questions When producing the plan, have these questions in mind: a) Is your plan achievable and within your means? b) Do you have the financial and human resource to achieve success? c) Do you have the right stakeholders engaged to ensure you deliver impact?

C3 Assistance in producing a Water Safety Plan Organisations like RoSPA and the Royal Life Saving Society has consultancy services that may be of assistance to you. For example: https://www.rlss.org.uk/consultancy-services

There are also other guides that may be of assistance: • Visitor Safety in the Countryside Group Guidance and also a guide on managing safety in the historic built environment: https://vscg.org/publications/ • Safety in docks. Approved Code of Practice: http://www.hse.gov.uk/pubns/books/l148.htm • RoSPA guidance on managing safety at inland waters: https://www.rospa.com/leisure- safety/water/inland/ • National Water Safety Forum UK Drowning prevention strategy: https://www.nationalwatersafety.org.uk/media/1005/uk-drowning-prevention-strategy.pdf • Local Government Association water safety toolkit: https://www.local.gov.uk/topics/community-safety/water-safety-toolkit

Page 35 of 40

Section 1: About the Water Safety Plan (WSP) This section simply provides details about the WSP – who produced it and when. Information required Your response

1. Date of Water Safety Plan:

2. Water Safety Plan produced by:

3. When will the Water Safety Plan be reviewed?

Section 2: About the site/scheme This section identifies the location of the site, links the WSP to the relevant planning application that required the WSP to support it, describes what the planning application was for as well as provides some context to the site. Information required Your response

4. Planning Application reference number:

5. Site address:

6. Summary of planning application

7. what is in place now? What do people do at the site now? Do people come to the site already? 8. What do/will people do there? How many people do you think will visit the site? Please provide a site plan. 9. Is the site close to/within a heritage asset such as a conservation area, listed building (including locally listed)?

10. Is the site in a dense urban area / less dense

urban area / urban rural fringe / rural area?

11. How would you describe the riverbanks? Natural, less intensive stabilisation method (state) or quay headed for example.

12. Is mooring allowed? What type of mooring

(private or public for example)

13. Will the scheme involve quay heading or raising current levels? Could this make it Page 36 of 40

Information required Your response more difficult for someone to get out of the water? 14. Are there any hidden obstacles? 15. Are there any trip hazards? 16. Are surfaces in disrepair? 17. Are surfaces slippery? 18. Can the trip hazards be removed? 19. Can the surfaces be repaired? 20. How can obstacles be marked?

Section 3: Specific details about the water body of interest Water bodies are different in their characteristics. This section discusses the specific nature of the water body and behaviour of water in the area of interest. Information required Your response 21. What is the depth of water?

22. What is the speed of flow of water?

23. How would you describe the bottom of the water body? Is it muddy, has aquatic plants, rocky, littered or stable for example?

24. What is the distance between the surface of the water and the top of the bank/quay heading.

25. What is the tidal range of the area?

26. What safety features/measures are in place at the moment?

Section 4: Risks This section discusses what the risks are of someone falling into the water, and who is likely to be exposed to the risk as a direct result of the proposed development. It then goes on to discuss how the risk will be minimised. This section is linked to the risk assessment but does not replace it. Information required Your response 27. Do you have a current Risk Assessment for the proposal? Is it up to date? Have you

completed a new risk assessment for the proposal (see section xxx of this guide) 28. How would you describe the people who will be using/visiting the site? (for example, likely Page 37 of 40

age)

29. Do you think it is possible that someone may

fall into the water here?

30. What could be the cause of people falling into the water? (for example alcohol, trip hazards, use in the dark) 31. How can these causes be mitigated / addressed to reduce the likelihood of someone falling into the water? Please note that this section is not about safety features like throw lines, but about reducing the likelihood of people falling in the water in the first place. 32. Could those constructing the site be at risk

of falling in the water? If yes, how have

these risks been mitigated? If No, please

explain why.

Section 5: About the safety features that are to be provided Having identified how the likelihood/risk of someone falling into the water will be reduced, this section goes on to identify what safety measures will be put in place if someone does fall into the water. Please see pages xxx for more information on specific safety features. The previous sections of the WSP will help guide you to what safety feature is suitable and appropriate to your scheme. Information required Your response 33. What safety features will you put in place to help those who have fallen in the water? As well as describing them, please provide an

annotated plan that shows the precise location of these features and identifies what they are. 34. How do you think these features are appropriate for the characteristics of the water body of relevance? 35. How do you think these features are appropriate for the characteristics of the

local area? (for example, impact on landscape, heritage and access)19

36. Please set out how the features will be

maintained.

37. What safety features will be in place for those constructing the scheme? Will these be temporary or permanent?

38. When do you intend to install the safety

features?

19 Measures such as bright plastic covers on life rings may detract from the scenery or setting. Less visually intrusive, but equally effective forms of safety equipment can be provided in such locations.

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Appendix D Privacy Notice

Personal data The following is to explain your rights and give you the information you are entitled to under the Data Protection Act 2018. Our Data Protection Policy can be found here: http://www.broads- authority.gov.uk/__data/assets/pdf_file/0003/1111485/Data-Protection-Policy-2018.pdf.

The Broads Authority will process your personal data in accordance with the law and in the majority of circumstances this will mean that your personal data will be made publicly available as part of the process. It will not however be sold or transferred to third parties other than for the purposes of the consultation.

1. The identity of the data controller and contact details of our Data Protection Officer The Broads Authority is the data controller. The Data Protection Officer can be contacted at [email protected] or (01603) 610734.

2. Why we are collecting your personal data Your personal data is being collected as an essential part of the consultation process, so that we can contact you regarding your response and for statistical purposes. We may also use it to contact you about related matters. We will also contact you about later stages of the Local Plan process.

3. Our legal basis for processing your personal data The Data Protection Act 2018 states that, as a Local Planning Authority, the Broads Authority may process personal data as necessary for the effective performance of a task carried out in the public interest, i.e. a consultation.

4. With whom we will be sharing your personal data Your personal data will not be shared with any organisation outside of MHCLG. Only your name and organisation will be made public alongside your response to this consultation.

Your personal data will not be transferred outside the EU.

5. For how long we will keep your personal data, or criteria used to determine the retention period. Your personal data will be held for 16 years from the closure of the consultation in accordance with our Data and Information Retention Policy. A copy can be found here http://www.broads- authority.gov.uk/about-us/privacy.

6. Your rights, e.g. access, rectification, erasure The data we are collecting is your personal data, and you have considerable say over what happens to it. You have the right: a) to see what data we have about you b) to ask us to stop using your data, but keep it on record c) to ask to have all or some of your data deleted or corrected

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d) to lodge a complaint with the independent Information Commissioner (ICO) if you think we are not handling your data fairly or in accordance with the law. You can contact the ICO at ttps://ico.org.uk/, or telephone 0303 123 1113.

7. Your personal data will not be used for any automated decision making.

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