For those of you who are not familiar with the Roberts Review, it was created following several fatal accidents on fairground rides in the 2000 season (6 within 11 months). The regulator at the time, the Health and Safety Commission (HSC) commissioned a report on the safety of the industry. This was prepared by Paul Roberts, an HM Principal Inspector for the HSC.
There were three aims to the Review:
For the sake of brevity, I won’t go through the entire report. However, if you want additional details, please consider attending either one of the Universal Verification Ltd in-person training courses or taking our eLearning course – ‘An introduction to ADIPS and the UK leisure industry’.
The conclusions from the Report were that the scheme (ADIPS) is fit for purpose if followed competently and diligently.
The Review detailed certain recommendations. These are detailed below along with my narrative on where I think we are.
Review recommendation: Additional research should be considered to assess the likelihood of, and preventive strategy for, major accidents at fairgrounds.
UVLtd: Getting accurate data on accidents and near misses will always be challenging. Whilst RIDDOR (Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013) is of some use, there are inherent problems and limitations with self-reporting. This is not just the UK, there are fundamental problems in other countries around the world.
The underlying challenge is that there tends to be reliable, if albeit scarce, information on fatalities, but it’s a small pool of data. As you move down the severity scale where things do not need reporting, the data quickly becomes less reliable.
Since the Roberts Review, associations like BALPPA (British Association of Leisure Parks, Piers and Attractions) and IAAPA (International Association of Amusement Parks and Attractions) have both put significant effort into safety surveys over the years. They have the same issues with self-reporting, but they do provide more detail than RIDDOR does.
There have been several efforts to analyse accidents and incidents and look at ways to make attractions safer.
One of the obstacles is that the HSE themselves have been reluctant to publish reports into accidents, either before prosecution for fear of jeopardising any case by the HSE, or even post prosecution when information can be released into the public domain. This means that anyone researching amusement safety in the UK often ends up relying on unofficial sources. In some cases, this means that people can jump to the wrong conclusions, or not learn lessons that should have been learnt.
While there is now an unprecedented quantity of information on amusement safety, many attractions and inspection bodies have small teams. These teams don’t always have the time and resources to benefit from the research.
There is a risk of a widening gap in standards between the biggest businesses that often have more resources, and the smaller players.
Review recommendation: A model and guidance is needed for children’s developmental stages and behaviour on rides, and the implications if any for containment systems.
UV Ltd: The first edition of EN 13814 was published in 2004 and was last updated in 2019. EN 13814 does provide guidance on this. Of course, children can develop at different rates and there are a lot of individual differences, not to mention the impact of Covid and a growing number of children diagnosed with neurodiverse conditions.
It’s a challenging area with a lot of anecdotal evidence, but EN 13814 gives some much-needed clarity and consistency for the industry.
But is it enough?
Review recommendation: Guidance on “Advice for Inspection Bodies” and “Advice for Design” should be completed as soon as feasible for issue as annexes to HSG 175. This will require resourcing by the HSE as well as the industry. The best way to achieve this might be to set up an intensive drafting session with representatives from that sector of the industry and HSE’s publications section. This would be the fastest way to reach completion, approval, and publication.
UVLtd: Following the Robert’s Review, the ADSC (Amusement Device Safety Council) and the HSE published a number of guidance documents.
These include a guidance document on the design of rides (published 2006), annual in-service inspections (published 2008), NDT (published 2012) and a guidance document on Pre-use Inspection (published 2014).
These were strong documents and provided some important clarity for Inspection Bodies and bought some more consistency to the industry.
The guidance on design has been less important now that EN 13814 provides a lot more detail on the matter, but these other guidance documents are really important. Arguably they could now benefit from being reviewed, updated where necessary, and re-issued.
Perhaps the amendment to HS(G)175 will be the catalyst to start the updates?
Review recommendation: Additional measures are needed to build greater compliance (4 points):
(i) more systematic checking by all the industry associations of full compliance to their members.
UVLtd: This is a difficult one. Compliance of the scheme by the industry associations.
It’s relatively unusual for a ride to be operated without a DOC (although the HSE did find several in 2025). It’s known which trade associations these controllers were members of, if any.
The fact is that controllers know that they need a DOC. That’s the easy part. The difficulty is that some controllers do not know or understand the system. They don’t know the requirements of HS(G)175 and the responsibilities of the duty holders.
Should the industry associations do more? Yes, without a doubt.
Will they? Probably not. Unless they are made to.
This is where the HSE should do more (honestly, don’t get me started on this one, either!).
(ii) some simple form of guidance should be delivered to enable the whole of the industry to understand and improve the depth of understanding of the ADIPS scheme. An urgent programme of industry seminars with some support from HSE seems to be the best option in the short term, along with the production of an explanatory video (demonstrating in a practical way the main responsibilities) as a possible option in the longer term.
UVLtd: It’s difficult to measure the how well the industry understands ADIPS and HS(G)175.
As mentioned above, many controllers are not aware of the requirements in HS(G)175. I’ve seen induction programmes for new management staff at attractions consist of reading HS(G)175 and reviewing the last annual inspection reports.
Reading the guidance is nowhere near good enough to obtain an understanding of the industry.
Again, in my opinion, and this is a hill I’m willing to die on, the associations have a duty here to educate.
Should the industry associations do more? Yes, without a doubt.
Will they? Probably not. Unless they are made to.
(iii) publicity for the scheme based perhaps on the release of this review with an emphasis on the benefits in terms of low risks and on examples of enforcement action.
UVLtd: The HSE does attend several conferences organised by BALPPA and ADIPS to discuss the findings from their NFIT (National Fairground Inspection Team). These talks are useful to those who attend them. However, the right people often do not attend them.
Also, it has been stated that the HSE will no longer attend the ADSC (Amusement Device Safety Council) BALPPA and ADIPS SHAD days in 2026 due to resourcing issues and will only attend the FJAC (Fairground Joint Advisory Committee).
Personally, I think this is a retrograde (backwards) step. The HSE should be attending these conferences to ensure all stakeholders hear HSE requirements first hand.
(iv) the industry should report to HSE any sites or rides thought not to be in compliance with ADIPS using the formal HSE complaints procedure and the agency should liaise specifically with NAFLIC to identify such sites and take follow up action.
UVLtd: Getting an industry to report on itself is always going to be challenging.
When complaints have been made, there has historically been a delay or perceived lack of movement by the industry and regulators. This makes it difficult to encourage people to report noncompliance.
I won’t discuss recent issues here but a quick internet search will find a plethora of instances where a lack of perceived movement by the regulator has resulted in industry apathy.
A positive I’ve seen recently is PIPA (Inflatable Play Inspection Scheme). This allows anyone to report a concern with a PIPA inspector, a PIPA member of a device inspected under the PIPA scheme. They’re not a regulator, so can’t prosecute etc. But they can, as an association, bring valid concerns to the regulator.
There doesn’t appear to be a similar reporting system for amusement rides, yet.
Review recommendation: Work should be done to establish a model and guidance for design to take account of the behaviour of younger children.
UVLtd: EN 13814 has certainly increased guidance on ride design. There have been improvements in the design of children’s rides, for example with magnetic braking and better containment systems, including hydraulic restraints and more grab handles.
Some older rides have had height restrictions raised or accompanied height restrictions introduced. This has often been instigated by the manufacturer of the ride, which could be an issue for older children’s rides where the manufacturer is now defunct. Some older children’s rides have also had their speed reduced to reduce accidents.
One challenge is that a lot of UK attractions have old legacy rides, meaning they don’t take advantage of new technologies. Deciding whether a dated ride system is suitable or sufficient is complex and often very subjective. Modifying older rides can also be challenging.
Review recommendation: The industry and HSE should actively support efforts to establish international standards.
UVLtd: There is now a much more developed set of international standards, particularly with EN 13814. It’s difficult for a standard to cover everything because of how varied rides are, but EN 13814 does have some specific standards, at least on the design of rides.
There are arguments about the pros and cons of EN 13814, for example compared to their American ASTM equivalents. However, this is an international issue that the UK’s HSE will only have a limited influence over. Regardless of any potential drawbacks, EN 13814 has been a massive step forward.
Review recommendation: The display of certificates should be specified by the scheme both to inform customers and to facilitate identification of voids that have not been inspected. Where this is not feasible a system of stickers should be developed.
ADIPS initially had stickers for controllers to place in ride windows. These were phased out and replaced with an online only system. In the last few years ADIPS has re-introduced the stickers system, which now contain QR codes. Re-introducing the stickers seems to have been a positive step for making sure the system is transparent.
The Robert’s Review did suggest making it compulsory to display an ADIPS sticker, so that anyone can easily check that a ride’s DOC is in date. At the moment, displaying them is optional.
Review recommendation: HSE should give more information to inspectors on the application of PUWER and LOLER, consulting the industry along the way.
UVLtd: The HSE was already providing free guides to help businesses comply with LOLER and PUWER. These guides make the legislation clearer and easier to understand. The growth of the Internet has helped to spread access to these.
However, some inspection bodies and controllers still do not understand the relevance and importance of the regulations detailed within HS(G)175.
Did I mention I believe that the associations should have a duty to educate?
Review recommendation: The industry should move as soon as possible towards formal independent accreditation of ride inspectors using UKAS with periodic monitoring of the inspector’s work.
UVLtd: UKAS accreditation is mentioned frequently in the Robert’s Review. Whilst a few larger Inspection Bodies have UKAS accreditation, they are very much in a minority.
The HSE has recently indicated that they aren’t planning to stipulate UKAS accreditation for individual IBs, but in the next edition of HS(G)175 it will become a requirement for any certification schemes (ADIPS, LEAPS, UVLtd etc) to be accredited.
Personally, I think that this is a good move (but I know people that strongly disagree!).
Review recommendation: In the meantime, the HSE should audit all ride inspection bodies as soon as feasible.
UVLtd: The HSE doesn’t have the resources to audit all the Inspection Bodies. All the ADIPS Inspection Bodies are audited independently by ADIPS approved auditors. This audit covers In-service annual inspections.
Again, my personal opinion is that the audits should focus on the technical aspects of the ride inspections and should not be penalising small single-person inspection bodies for not performing a management review.
Personally, I also think that the audits should be extended to include PUI (Pre-Use Inspection) activities as this is an area which needs considerable improvement. There are many Design Reviews out there which are not fit for purpose. I may have mentioned this a few times at the ADIPS SHAD last week.
Review recommendation: The importance of regular maintenance needs to be stressed and the recommendation is that this should be covered explicitly in new measures to build awareness and diligent compliance (eg regional seminars by the industry with some HSE support) and in HSE inspections.
UVLtd: OK, don’t get me started here. I’m writing a book on this, and I can literally speak for hours on this subject.
There are a number of conferences by different trade associations such as BALPPA, IAAPA and ADIPS. None of these focus on maintenance. To me, a vitally important aspect of the industry is being ignored. It’s just not good enough.
The UK has never had an equivalent of AIMS in the US, which offers very targeted classes and courses on different aspects of maintenance.
Can we do the same in the UK? Yes, 100%.
Why don’t we? Answers on a postcard.
Review recommendation: Industry associations are recommended to consider the development of training and quality standards for members.
UVLtd: As with the previous point, specialist training is often difficult because trade association members can be very diverse, with very diverse needs. Often maintenance issues are too niche for the kind of conferences we have in the UK.
Imagine that the associations develop training courses, or better still, they speak to companies that have already developed these courses (hello) and run them for their members.
Review recommendation: The FJAC should agree to include on the committee, with the status to be determined, more consumer worker and local authority representatives, and that the HSE should help to identify people who might act as such.
UVLtd: No comment!
OK, If I need to comment, the FJAC (and ADSC for that matter) are completely under represented by some stakeholders.
There needs to be diverse thinking (that’s cognitive diversity, for the clever people) on all industry committees.
There’s a famous quote (I think it’s by Henry Ford): “if you always do what you’ve always done, you will always get what you’ve always got“
We need a different approach.
Review recommendation: The legal definitions and enforcement allocation rules for fairgrounds should be simplified as part of the current review of the health and safety enforcing authority’s regulations.
UVLtd: This concerned itself with where the line is drawn between what the HSE investigates and enforces, and what a Local Authority investigates and enforces.
Health and safety is quite fragmented in the UK with different enforcement bodies for different areas of safety, including the HSE, Local Authorities, Country Councils, the police, and the fire brigade. More joined up thinking could lead to better regulation.
Review recommendation: FOD (Field Operations Directorate) should as far as consistent with other responsibilities make fairground inspections a more specialised topic and ensure continuity of expertise both in the sector and the field.
UVLtd: Ride inspection is a very specialised job, and within it there can be niches such as wooden roller coasters, where an understanding of wood types and grades could be advantageous.
For ADIPS there is a trade-off between making standards more rigorous, and making sure there are still enough inspectors for all the rides that need inspecting.
Inspectors do have to go through an induction process including proving engineering qualifications, being assessed by an industry panel, and going through a probationary process.
ADIPS does provide a number of opportunities for CPD (Continuing Professional Development) including their annual conference. At the moment it is largely optional.
Review recommendation: The existing complaints procedures should be publicised to the industry.
UVLtd: The process for reporting concerns with an attraction does not appear to be well advertised. Since the Robert’s Review there have been big cutbacks to funding for the HSE, and a big reduction in the number of staff at the HSE and the number of inspections.
Review recommendation: Fairground ride investigation protocol should be drawn up.
UVLtd: There is a lack of transparency around investigations. In most cases reports aren’t published. Occasionally they have been after a FOI (Freedom of Information Request), but typically these are rejected on the grounds that it isn’t in the public interest.
The main benefit to publishing reports would be to help other attractions learn from incidents. They could also raise confidence in the process, and help controllers understand what evidence the HSE is likely to want to see if they’re investigating an incident.
The previous point was concerned with how easy it is for people to report concerns to the HSE. If the public and employees could see that incidents are investigated fairly and adequately it would build trust with the HSE and make people more likely to report concerns
Since the Roberts Review there have been some big improvements to safety in the industry.
On the other hand, significant cutbacks to the HSE and a lack of transparency around accident investigations has created weak points in the system.
Whilst there might be some element of self-regulation, it’s reasonable to expect trade associations to promote good safety, expecting them to police their members is perhaps unrealistic.
Whilst there is some excellent guidance out there, it is spread between a number of different sources, some of which cost money to access, which is a barrier to smaller controllers.
Whilst new technology is helping improve safety for some controllers, other controllers might be left with aging rides that are reaching the end of their design lives.
There is a risk of the gap between the standards at the leading attractions and those at the bottom getting wider.
The next edition of HS(G) 175 has been delayed, but when it eventually comes out it should help to make sure the sentiments of the Robert’s Review are still being followed, including the harmonisation with BS 14200 and the UKAS accreditation for the inspection schemes.
At Universal Verification we believe there are skill gaps in the system, which we’re attempting to plug with our specialist training courses.
We also believe that while the Annual In-Service Inspection helps to make sure rides are well maintained, there are gaps in terms of the maintenance in between, and a lack of third-party expertise on operations.
We can see the gaps.
As an industry, we need to come together to close these gaps.
Will we?
