Stand Up Sit Down send the following letter to the FLA following publication of injury figures for the 2004/5 season:

I am aware that Phill Gatenby (FSF) has already written to you, so will try not to duplicate his points, or go over ground that you and I have already covered many times before.

I was pleased to see that the injury rate has once more reduced and the FLA are to be congratulated for their part in making watching football so safe.

The overall injury rate of 1 in 28,363 is extremely low for such gatherings of large numbers of people, particularly taking into account the traditional link between watching football and alcohol. The fact that treatment for illnesses and pre-existing injuries exceeds that for injuries sustained at the ground, and that most injuries were minor cuts, bruise and scalds, shows just how safe football is.

Of course in an ideal world a single injury is one too many, but as Lord Taylor said, the only way to achieve total safety is to have an empty ground. I appreciate that the FLA must continue to search for further improvements, although with figures so low and many improvements made over the last 15 years, the law of diminishing returns will probably apply.

The impact of safety measures and efforts to reduce injuries on the freedom and enjoyment of supporters is also very relevant, although I appreciate that this may not be part of the FLA 's remit.

You will appreciate that Stand Up Sit Down are most interested in the injury figures as they relate to standing in terrace and seated areas. It is therefore disappointing that again no figures are available to directly compare standing and sitting areas.

I note your comment that the difference between injury rates between all seated grounds and those with terracing is ‘highly suggestive'. Whilst there is a significant difference in injury rates, I believe that there are so many variables that this statement is debatable. For example, in your report you mention the lesser quality of accommodation and fewer resources devoted to safety in the lower divisions. You also mention proximity of first aid post, which may be more accessible in smaller grounds, where there tends to be more movement of spectators, than in the large all seated grounds.

You show figures comparing all seated grounds with those with terracing, but do not break these down by division, However, your figures for all grounds, show that the injury rate is higher in the 1st & 2nd divisions, than the Championship & Premiership. With I believe the exception of Cardiff City , all those grounds with terracing in 2004/5 were in the lower two divisions. This is therefore not a fair comparison, as you acknowledge that other factors (as well as terracing) are at play in the lower divisions. A fairer comparison would be between grounds in divisions 1 & 2 which are all seated and grounds in these divisions which retain terraces, although the number of injuries is so low, that this may not be statistically significant.

You state that accurate statistics of spectators injured while, or as a result of persistent standing in seated areas are not easy to obtain. I agree that without full information on each case it is difficult to apportion blame to standing, and even more difficult to determine whether this was due to ‘persistent standing' or standing at moments of excitement. You state that this is an area of concern, although the FLA has however not published any figures at all to support this.

I believe that it should be possible to analyse data to provide some comparison between the injury rates for sitting and standing in seated areas:

1) Compare figures for areas of grounds where supporters tend to stand for some but not all games. For example, the Kop at Anfield generally stands for major Premiership and European matches, but sits for lesser games.

2) Compare figures for seated areas in grounds where supporters mainly sit and others where they mainly stand. For example the Bobby Moore Lower at Upton Park tend to stand, whilst the Upper Tier usually sits.

3) Compare figures for away supporters who tend to stand (e.g. Cardiff , Man Utd, West Ham, Tottenham) with those who tend to sit. This could be either based on a comparison of injury rates for away fans of all clubs, or for the visitor's area of home grounds, comparing figures for those clubs who's supporters stood, with those who sat.

You will probably be aware that in its standard reply to the many supporters who write to the Government with regard to standing at football, the DCMS uses the argument that the injury rate is higher in grounds with terracing, although does not quote the figures to support this. It does not mention figures for standing in seated areas, even if the letter they receive refers specifically to this. Nor does it mention the low injury rate in the Premiership and Championship, where there is still much standing in seated areas, suggesting that this is not a significant cause of injury.

I do not believe that the FLA have published figures which clearly show a higher injury rate in terrace areas, or any figures relating to standing in seated areas. Given that this is a matter which causes you concern, and about which you are putting much pressure on clubs, I consider that the FLA should be able to provide supporting data on injuries.

If figures show that the injury rate for standing is a matter for concern, clubs may be less likely to challenge safety measures as mentioned in your report, and supporters may be more inclined to sit if they believe they are at risk of injury. It may be the case that more injuries occur when supporters stand, but if this is to be used as a justification for retaining and enforcing current regulations, there should be data to support it.

I appreciate that injury figures do not provide a full picture, and that every reasonable effort must be made to prevent a major incident causing injuries or even death, occurring at a football match. Your report however makes no mention of any concerns that any indicators have been observed that could lead to such an incident. I would suggest that if the FLA considers that there is a real risk from persistent standing in seated areas, which still occurs at many grounds every week, this should be highlighted in the report.

Currently many supporters and clubs see safety being used as an excuse to try to enforce the ground regulation on standing in seated areas and to resist a change in regulations allowing terracing in the top divisions. We all want grounds to be safe, but if safety is used as a justification for these actions and regulations, it must be supported with evidence. If not it may undermine the regard paid to safety in other areas.

I would therefore ask whether the FLA is able to provide statistics for injuries which objectively compare seating with terrace areas, and standing versus sitting in seated areas. If these figures cannot be provided I do not consider that injury rates should be used as a justification for either opposing terrace accommodation, or managed standing in seated areas.

I look forward to your reply.

Thank you.

Best Regards

Torquay are allocated no seats at their opening League Two fixture at Barnet. On a very hot day the 702 visiting fans all had to stand on a very hot terrace. Most were pleased to stand, but others would have preferred to sit and some older fans found this difficult, with people in the ground requiring assistance from St Johns Ambulance.

Stand Up Sit Down firmly believe that there should be choice for supporters to sit or stand at every ground. To provide only standing accommodation is probably worse than only seats, and is not acceptable.

The following letter is sent (from an individual not under SUSD) to Barnet, copying the FLA , as follows:

‘I am writing to complain that Torquay supporters were allocated no seating accommodation at yesterday's fixture.

Whilst I, and probably the majority of the 700 visiting supporters preferred to stand, there were some supporters who wished to sit and were unhappy that Torquay had been allocated only terrace accommodation.

It was very hot in the covered terrace, and I noticed that your first aid staff were called upon several times to assist supporters, at least twice bringing chairs for them to sit on.

Whilst some supporters simply prefer to sit, for others standing is very difficult, particularly some older supporters and those with young children. I do not therefore consider it acceptable to provide only standing accommodation for visiting supporters.

Last season Torquay were allocated only the all seated South Stand, and there were problems of conflict between supporters wishing to stand and stewards trying to get them to sit. In previous years Torquay have been given both standing and seated areas, and there have been no problems.

I understand that Barnet have moved the away area on safety grounds. I am not aware of the reasons for this, but in doing so you have created additional problems for away supporters.

Most supporters believe that there should be a choice as to whether they can sit or stand to watch football. By denying this choice to away supporters Barnet are making it difficult for some families and older supporters. This is a customer care issue (with possible safety implications) and a major reason why we are told that supporters should not stand in seated areas.

I would have thought that Barnet would want to encourage all supporters to attend matches, but by providing only terracing for visitors you are making it difficult for some supporters to follow their team. I took my twelve year old son with me yesterday and considered taking my six year old too. I am very glad that I didn't, as he would have found it both difficult to see and to stand in such heat for two hours.

I appreciate that Underhill has limited facilities, but given that Barnet rarely fill their ground (the South Stand was almost empty yesterday, despite tickets being given away for free), I do not think it unreasonable that you provide a choice of standing and seated accommodation for visiting supporters. The practice of allocating the end section of terracing and the South Stand seats to Torquay fans appeared to work well every time it was used, and I would ask that Barnet reconsider whether this would be more appropriate than the current terrace only arrangement.

Thank you.

Yours sincerely

Lou Elliston, FLA Inspector for Barnet, very promptly responds to the letter expressing concern that Torquay fans were allocated no seats at Underhill, saying:

Dear Mr Caton

I agree with you. I haven't been to Barnet in the last few weeks and due to holidays I missed the last meeting and was unaware of the current arrangements. The position at Barnet was that during last season I found there were problems with the toilet block at the South end. They were blocking and there was an inadequate water supply. This was difficult to rectify at the time and to provide away supporters with adequate facilities they were moved to the top end of the East terrace. During the closed season work has been undertaken which included repairing the drains and providing an additional water supply so all the ground should be available again. Your letter makes a very reasonable point about the conditions at the time and I certainly shall enquire why they couldn't have shown more flexibility and whether away supporters can be given the choice of terracing or seated accommodation for future games.

Ms Elliston also gives an update on developments at Ipswich , following concerns raised about congestion and lack of facilities for away supporters in big matches at Portman Road :

For your information I was at Ipswich last week and viewed the new facility they have created for away supporters by converting the old club chop. This has provided additional refreshment and toilet facilities at ground level, but which can be accessed from either vomitory on the upper level and the side staircase. So should you visit Ipswich during the course of the season I am sure you will find it a much more comfortable experience.
Regards
Lou Elliston

A Stand Up Sit Down Member obtains minutes of Norwich City Safety Advisory Group meetings through the Freedom of Information Act. He comments:

The minutes indicate that the SAG are happy that persistent standing amongst home supporters is fairly stable and they know what to expect from us, but find it harder to deal with away fans as they can never be certain how each different set of supporters is going to react.

In two different sets of minutes Leeds and Cardiff are identified as clubs whose supporters persistently stand. Unfortunately, one of the safety reports that wasn't sent was from the Leeds match, though for the Cardiff match, despite the report showing that 300 Cardiff fans stood throughout the match, no comment is made about it. This compared to the report for the Millwall match 2 weeks previously which states '100-120 standing, total disregard to stewards requests to sit. Ejections could have provoked a public disorder problem.' The same can be said about the West Ham cup tie in January. Despite the numbers of West Ham standing as 3000, no comment is made.

The other debate that some of the reports raise is what is considered as persistent standing. The numbers given as standing seem to be a lot lower than the numbers I believe stand throughout Norwich matches. In the PNE match the notes state that between 1500-2000 stood but not persistently, the number of persistent standers has to be written in a box and is given simply as 'up to 200'. This is also reflected for the Leicester match, the only game throughout the whole season where it states that no home supporters were persistently stood. Why? Because everyone sat down for at least 2-8 minutes at some point during the match.

There are also reports from matches which state that stewards focused on keeping gangways clear as a priority as opposed to getting supporters to sit and also where hundreds are reported to have stood yet comments are made that 'no safety or customer care issues reported'.

FLA Chief Executive John De Quidt replies to our letter regarding injury statistics. Mr De Quidt says:

‘Thank you for your letter of 5 th August about the injury statistics for the 2004/05 season. It is always nice to know that somebody is dreading our website. I hope you will forgive me for the brevity of this reply ----‘

We have never sought to conceal the fact that the injury statistics are far from complete. This is for two reasons:

•  We can only report on the number of people treated. However, we are aware from our own observations that not all injured spectators seek treatment – for a variety of reasons.

•  Secondly, there is no obligation on the spectator seeking treatment to disclose to the first aid or medical staff how the injury occurred, nor is there any guarantee that whatever they say is necessarily accurate.

We have witnessed various unrecorded incidents where spectators have been injured while standing in seated areas. However, whenever we have sought to use these in support of our arguments, our critics have dismissed them as ‘anecdotal' or have sought to argue that they are ‘different'. In interpreting the statistics we need to have regard not merely to the raw data but also to our own observations and experience.

As you will appreciate, it would be quite wrong of us to make absolute statements about relative injury rates between divisions unless we could prove direct cause and effect. In practice, as you yourself have said, the interrelationship between ground condition, crowd managements and injuries is more subtle. Hence, even where we consider the arguments to be persuasive, they must nevertheless be qualifies, as in our report. Ultimately this must be a matter of judgement.

The FLA has always made it clear that the case for requiring all spectators to sit has to be addressed under three separate but interrelated headings: safety, crowd management and customer care. If it could all be resolved on the basis of comparative statistics of past injuries we would not be having this debate. However, the issues are far more complicated than that. We must continue to look at them in the round.

am aware that some supporters will not accept that standing in seated areas is unsafe unless or until there is a major disaster and maybe not even then. My duty, however, is to do everything within my powers to prevent spectators being injured. I cannot wait until someone is killed or seriously injured before I take such action as I consider necessarily to secure their reasonable safety.'

In reply to letters regarding injuries and safety at the Take That concerts held at Manchester City 's ground, the FSF received the following reply from the Government Department of Culture, Media & Sport:

'I have discussed the concert you refer to with the Unit Manager of the Licensing Section at the ( Manchester City ) Council. He confirmed that the council are content that the safety systems for this event worked effectively. However, as with any concert, the council will be holding a thorough de-brief with the promoters, during which safety systems will be reviewed.

The Government remains satisfied with the current arrangements covering the safety of music fans at concerts'.

tand Up Sit Down would once again highlight the different in Government policy with regard to football and concerts. They are happy with safety arrangements for concerts, where injury figures are far higher than at football matches, yet use debatable figures with extremely low injury rates to help justify refusing to relax the regulations on standing at football.

Around 90% of Villa's away support at The Emirates Stadium stand throughout.

A Leicester supporter reports on his team's visit to Coventry :

I was at Coventry v Leicester on Friday night. Around 350 ish Coventry fans stood to the right of the Leicester fans. Around 75 Leicester fans were stood at the start of the match however stewards and police came up all staircases and made sure all fans sat down leading to confrontations. Most sat as police and stewards maintained their positions in the staircases in an intimidating manner.
In the Coventry end it seemed a nightmare, fans were constantly being dragged out for what appeared little more than standing. Police and stewards forced their way into the centre of their standing block and ejected people. This lead to confrontations and one or two scuffles, much to the amusement of Leicester fans singing "cherio, and fock off" etc. this didn't help the situation and I was left thinking it must have been better if they didn't drag out these 7 odd people for standing therefore avoided these confrontational scuffles.

Leicester and Coventry fans wishing to stand had police and stewards watching them from about 2 yards and riot squads from the exits below.
This left many supporters feeling intimidated and even though this is a local derby is this heavy handedness really necessary.

A policeman even disturbed 5 fans to ask me to sit down properly on my seat because I was sitting on it whilst it was upright, not on the main flat bit even though everyone behind could see properly.'

Stand Up Sit Down send the following letter to the Premier League, in response to Chief Executive Richard Scudamore's comments that a measure of standing should be tolerated:

Dear Sir
We were pleased to read of your comments regarding standing in seated areas made at the meeting earlier this year hosted by the Minister for Sport, with regard to which the following was recorded in the minutes of the FLA board Meeting held in May:

• The football authorities confirmed that they had no desire to reintroduce standing accommodation and that seating was the safest form of accommodation. However, the Chief Executive of the Premier League had argued that:

• it had not been proved that persistent standing presented a safety problem;

• the FLA were on the wrong track and all the measures we were taking were wrong and failing; and

• a measure of persistent standing should be tolerated.

Stand Up Sit Down are delighted that The Premier League appear to agree with us that standing in most seated areas does not present a significant safety problem and that some standing should be tolerated.

We are not seeking a return to terraced standing, or indeed any changes to grounds, but simply for selected areas to be allocated for those supporters who wish to stand in front of their seats.

We do not want uncontrolled standing (as currently occurs at many grounds), because this causes customer care problems, but are proposing a system of managed standing, where in one or two areas of each ground standing would be permitted. Home supporters would have the choice to buy tickets for standing or sitting areas, and away allocations would generally be split (e.g. by tier or rows), again allowing a choice for all fans.

We have written to the Premier League on previous occasions, and met with Cathy Long some time ago, but in case you do not have these, I have enclosed a summary of our proposals and their benefits. Further information and reports can be seen on our website.

I am sure you are aware of the strength of feeling of many supporters on this issue. Stand Up Sit Down has almost 5000 members, covering all ages and every league club. We are aware of much concern about reduced atmosphere, conflict with stewards trying to enforce the current regulation and between supporters due to blocked views. We are also aware that a significant number of supporters are no longer attending Premier League matches, either because they are fed up with being unable to stand and with conflict with stewards, or because they have had problems with views blocked by others standing. Our proposals would overcome these issues.

We would also draw your attention to the recent report by the Football Foundation, which makes similar comments with regards to atmosphere and calls for the Government to reconsider permitting standing areas.

We hope that the Premier League will now feel able to express its support for our proposals and that in due course supporters will once again be able to have the choice that so many want.

As a supporters organisation , we hope that you will feel able to give us a personal reply, as we are aware of individual supporters who have written to the Premier League and received what appears to be a standard letter on the standing issue.

We would be very pleased to meet with you to discuss this in more detail.

Yours sincerely
Stand Up Sit Down

As Spurs play Sheffield United around half of the Park Lane lower stand for the whole game, as do the Shelf corner.

Season tickets in the Park Lane have now sold out, which supporters believe is because fans want to be in an area where there is standing.

With the exception of around a dozen in the front row, all West Ham's 2000 fans at Watford stand for the whole game, with no attempts made to get them to sit. Those who sat were mainly older supporters, who may have requested front row seats from West Ham's ticket office.

Despite having their allocation cut due mainly to persistent standing in previous seasons, Manchester United's entire away support stand throughout the game at The Valley, as do around 300 Charlton fans.

Dynamo Zagreb 's entire away support stand and jump around throughout their Champions League fixture at Arsenal.

Stewards spent the whole game trying to get Manchester City supporters to sit behind the goal (with success only at the front), yet no attempts are made to stop visiting Portsmouth fans from standing.

Around 2000 Middlesbrough fans stand for the whole of their home match v Chelsea , and another 5000 stand for the 2 nd half.

All of West Ham's away support (bar a handful in the front row) stand throughout the match at Anfield. Other than a note sent with tickets, no attempts were made to stop supporters standing, which contrasts with last season when stewards constantly asked the front rows to sit.

A Stand Up Sit Down member reports on Leicester v Southend:

‘ Arguably our most dull fixture of the season hence less standing than there could be

Around 150 Leicester fans stood next to the away fans and around 15 the other end behind the goal. no Southend fans stood persistently throughout- maybe 5 on a back row.

An extremely heavy police presence causing tension within the Leicester fans- total waste of money. and the police have built a special scaffolding in between the fans and stand there with a video camera. very antagonistic. still an improvement of last year where around 10 people a match where ejected when the police where there.

All Man United's support stand for the whole game at Watford .

A significant number of Manchester City fans stand at home to Arsenal.

Newcastle 's entire allocation stands throughout the match v Aston Villa at Villa Park .

The Manchester Evening News carries a story about a drum playing 17 year old Stockport County fan was ejected from Edgeley Park after stewards branded him a safety risk. The report says that he has become a firm favourite with County fans by leading the chants with his bass drum. But he was ordered out of the ground by stewards because they said he was in breach of safety regulations - not for banging the drum, but for persistently standing up!

He is reported as saying 'When I was allowed back in, I was put at the front with the drum, but it doesn't work. It's up at the back where we create the atmosphere - there should be a bit where we can stand and sing and drum'

County's Managing Director, Keith Agar is reported saying 'I love the drum, but I cannot condone what he has done. The FA regulations are against people standing for too long. It's a safety issue and that's why he was removed.'