A Statement by Music Venue Trust on The Scottish Government's Announcement re: Vaccine Certification for Venues10 September 2021 - Press release
A Statement from Music Venue Trust on the Scottish Government’s Decision to Introduce Vaccine Certification as a Requirement for Entry Into Music Venues, Nightclubs & ‘Analagous Premises’
“As it stands this Scottish government policy amounts to an attempt to exclude some people from going somewhere at some time, without providing adequate information on when, where, who or how.”
The new Scottish government policy announcement on the requirement for double vaccination for entry to some premises is unclear, lacking in detail and liable to provoke confusion among both the public and venue operators.
While we are pleased to see smaller gatherings for live music recognised in the framework as lower risk and therefore excluded from the policy, the statement issued by Scottish government acknowledges that it does not yet contain a definition of the type of premises to which it wishes to apply these entry requirements. It suggests it will apply to ‘nightclubs and analogous premises’ and that it is ‘consulting with the relevant sectors’ to create an appropriate definition of the term ‘nightclubs’.
For clarity, Music Venue Trust has provided extensive information to Scottish government on the challenges this policy provokes without any acknowledgment or via any method of formal consultation. The issues we raised about the implementation of this policy are not answered in the government statement, and have not been responded to or resolved elsewhere. In fact, the challenges with definitions and implementation we made clear to Scottish government are recognised in the statement without offering any solutions or decisions on them.
The activity Scottish government asserts presents a serious enhanced risk is dancing closely together in enclosed spaces. The ‘analogous premises’ in which such activity takes place therefore potentially covers a huge range of pubs, bars, restaurants, wedding venues, hotels, conference centres and pretty much everywhere where celebrations through a community activity are being enjoyed.
As it stands this Scottish government policy amounts to an attempt to exclude some people from going somewhere at some time, without providing adequate information on when, where, who or how. In doing so it potentially disproportionately penalises young people, excluding one in four of them from the late night economy, and people from diverse backgrounds, excluding nearly 50% of them from the late night economy.
There are no details provided on how exemption should be managed, and we therefore assume that the Equality Act 2010 must be applied in full with the resulting confusion around evidence required to be shown to establish exemption.
No financial support has been offered to deliver this policy, and none offered to mitigate the impacts it will have on business. This is despite details of the cost of delivery and likely business impact being provided to Scottish government by Music Venue Trust and many others.
Music Venue Trust is not in favour of or opposed to the imposition of health certification; it is not the role of the charity to seek to lead on health policy. We remain committed to working with Scottish government to ensure the protection of public health through any deliverable, reasonable and equitable control measures that the government believes will have a practical impact on transmission risk. The policy as it stands fails all these tests.
We hope that Scottish government will now actively engage with the sector to seek to resolve these challenges. This must happen swiftly so that public confidence in the policy, specifically public confidence among the actual participants in the night-time economy, is established.