Martyn’s Law Capability for Shopping Centres

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It is a busy Saturday afternoon. Thousands of people are moving through a shopping centre when several people suddenly start running from one of the main entrances.

A security officer reports a possible serious incident. The control room checks CCTV while calls begin coming in from retailers. The information is confused and nobody yet has a complete picture of what is happening.

Centre management wants answers. Should people be evacuated? Should entrances be secured? What should retailers be told? Who makes the decision?

The shopping centre has emergency procedures.

The question is whether its people have the capability to use them.

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Why Shopping Centres Present a Different Challenge

A shopping centre is not simply one building controlled by one management team.

It can contain hundreds of retailers, restaurants and other businesses, together with security officers, cleaning teams, maintenance staff, contractors and thousands of members of the public. Multiple entrances, car parks, service areas, transport connections and shared spaces add further complexity.

Back in the control room, that complexity is becoming very real. One retailer reports seeing people running. Another asks whether it should close its unit. A security officer provides information from the entrance. CCTV operators are trying to establish what has happened.

Different people know different parts of the story.

Current Martyn’s Law guidance recognises the coordination challenges created by premises within larger complexes such as shopping centres. Actions taken in one part of the centre can affect people and organisations somewhere else.

The security problem therefore cannot be considered in isolation. Information, decisions and actions have to work across the wider environment.

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Recognising and Assessing What Is Happening

The first challenge is understanding the problem.

Initial information during a serious incident may be incomplete, contradictory or wrong. What somebody believes they saw may be different from what CCTV shows. Reports may arrive from different locations and at different times.

The control room now has several pieces of information, but still no complete picture.

This is where judgement matters.

What is known? What is assumption? What needs confirming? What requires immediate action? Who needs to know?

Waiting for perfect information may delay an important decision. Acting on an untested assumption may create another problem.

The objective is not perfect situational awareness. It is to develop enough understanding to make a credible decision and continue assessing what is happening as new information arrives.

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Making the Right Decision for the Situation

The first instinct during an emergency may be to evacuate. But the reported incident is close to one of the shopping centre’s main entrances.

Moving large numbers of people towards that area could move them towards the danger rather than away from it.

Now the decision becomes more complex. Should one part of the centre evacuate while another remains secure? Should people outside be brought inside? Should particular entrances be secured? Could some areas remain operational while others are isolated?

This is why evacuation, invacuation, lockdown and communication cannot simply exist as separate procedures.

The people making decisions need to understand how those procedures relate to the actual environment and the situation developing in front of them. Entrances, exits, pedestrian flows, shutters, barriers, safer areas and service routes can all influence what is possible.

The procedure provides options. Capability determines how those options are used.

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Communication Turns the Decision Into Action

A retailer calls the control room asking whether it should secure its unit. At almost the same time, a security officer reports that customers are already being directed towards an exit. Another retailer has heard something different and is telling people to remain inside.

The organisation now has a communication problem as well as a security problem.

A sound decision has little value if the people who need to act do not receive clear information.

A shopping centre may need to communicate with security officers, control room staff, centre management, retailers, contractors, members of the public and emergency services. Each may require different information, but their actions still need to support the same objective.

Conflicting instructions can quickly create confusion. One team moves people while another tries to keep them in place. Retailers make their own decisions because they do not know what is happening. Emergency services receive different versions of the incident.

Communication is therefore not simply about having radios, telephones or a public address system. It is about getting the right information to the right people quickly enough for them to act.

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Coordination Has to Exist Before the Incident

The incident is now affecting more than the security team. Centre management is involved. Retailers want direction. Security officers need instructions. The control room is managing information and emergency services need an accurate picture of what is known.

This is the wrong time to discover that different organisations have different assumptions about their responsibilities.

Who can initiate a public protection procedure? Who communicates with retailers? Who makes public announcements? Who contacts the emergency services? How does information move between the control room and decision makers? What happens if the person normally responsible is unavailable?

These questions need answers before the incident.

For a complex environment such as a shopping centre, coordination is not an administrative exercise. It determines whether people and organisations work together or unintentionally create additional confusion.

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Then the Situation Changes

New information reaches the control room. The initial report about the location of the threat may not have been accurate, which means decisions already made now need to be reconsidered.

This is another point where capability becomes visible.

Real incidents do not necessarily develop according to the assumptions used when procedures were written. Information changes. Routes may become unavailable. People may react unexpectedly.

A capable organisation does not simply initiate a procedure and assume the problem is solved. It continues to assess what is happening, communicates changes and adapts its actions when necessary.

That requires people who understand the purpose behind the procedure rather than simply the words written within it.

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How Do You Know the Capability Will Work?

The shopping centre scenario described in this article does not need to happen for real before an organisation discovers where its weaknesses are.

Run it as an exercise.

Start with an incomplete report of a serious incident at an entrance. Who receives the information? Who assesses it? Who makes the first decision? What happens to people close to the reported threat? What are retailers told? How are emergency services contacted?

Then introduce new information. The original location may be wrong. What changes?

Does information move quickly enough? Do people understand their responsibilities? Are decisions coordinated? Can the organisation adapt, or does everybody continue following the original plan?

A relatively simple scenario can expose assumptions that a written procedure never reveals.

The purpose is not to catch people out. It is to identify weaknesses in knowledge, responsibilities, communication, decision making and coordination while there is still time to correct them.

That is how procedures begin to become organisational capability.

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From Martyn’s Law Requirements to Operational Capability

Martyn’s Law provides an important framework for public protection. Qualifying premises and events are required to have appropriate public protection procedures, so far as is reasonably practicable, concerning evacuation, invacuation, lockdown and communication.

But legislation cannot make decisions during an incident. People do that.

For a shopping centre, operational capability means understanding how those procedures work across a complex environment, who makes decisions, how information is shared, how different stakeholders coordinate and whether people can adapt when circumstances change.

The real test is whether all of those elements can work together when they are needed.

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Build Capability Before It Is Tested for Real

Return to that busy Saturday afternoon.

The first report is incomplete. Retailers are asking questions. People are moving. Information is changing and decisions have to be made.

There is no time to start interpreting a plan, clarify responsibilities or discover that different stakeholders expected different things to happen.

The question for a shopping centre is therefore not simply:

Do we have Martyn’s Law procedures?

It is:

Can our people actually deliver them when it matters?

That is the capability that protects people.

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Develop Your Crisis Management Capability

The Mildot Group Crisis Management and Business Continuity Programme develops the practical capability to manage serious incidents when information is incomplete, decisions need to be made and different stakeholders need to work together.

Designed for protective security and counter terrorism practitioners, the three hour accredited programme covers incident response and recovery, crisis decision making, incident response planning, communication, interoperability and maintaining control as circumstances change.

The programme focuses on terrorism and hybrid threats, with the principles providing wider capability for other serious incidents and organisational crises.

Develop the judgement and practical capability to manage the response when an incident becomes a crisis.

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