Alfie Gray

Ms P. Schofield, 
Senior Coroner, 
West Sussex, 
Coroner’s Office, 
Orchard Street, 
Chichester, 
West Sussex PO19 1DD.  

Dear Ms Schofield 

15 September 2016 

Thank you for your letter in regard to the sad death of Alfie Gray. We write in response to your letter 
and Regulations 28 and 29 of the Coroners Regulations 2013. We have been carefully reviewing the 
report and your requests for action.  

I thought it would be helpful to firstly outline the purpose and role of ABTA. We are a trade 
association representing and providing services to our Members who make up a significant part of 
the UK travel industry and who sell a range of travel services including package holidays, flights, 
accommodation and car hire. ABTA provides services to consumers through its consumer affairs and 
arbitration services which deal with a range of consumer issues involving ABTA members. 

ABTA also fulfils a regulatory role in respect of its members through its Code of Conduct and 
financial protection function. In regard to health and safety, ABTA provides guidance to Members 
and raises awareness on key safety issues with consumers and destination authorities. I should 
highlight that Global Travel Group are not an ABTA Member therefore would not generally have 
access to the advice and guidance we provide to Members on health and safety.  

In regard to our Members, we believe they view their customers’ welfare as a priority in their 
assessments and programmes. However each ABTA member will contract properties very 
differently, from solus use of the entire property to ad-hoc allocations of rooms per year. Members 
make their own decisions about their programmes including the choice of properties and whether 
and how they decide to audit these properties from a health and safety or sustainability perspective 
based on their contractual arrangements with the property.  

In the absence of European-wide standards or a directive on tourism accommodation safety UK tour 
operators came together, originally as the Federation of Tour Operators (FTO), to develop the 
Tourism Accommodation Health and Safety Technical Guide best practice guidelines (the Technical 
Guide). The first edition of the Technical Guide was developed in 2000/1 and the current edition (3) 
in 2012 as ABTA/FTO. The guidance enables tour operators to have a common approach to suppliers 
on a non-competitive issue such as safety. The guidance covers key health, safety and security issues 
for accommodation suppliers. Each chapter has been consulted on and developed with experts in 
their field. The Technical Guide is reviewed every few years, and it is currently being reviewed by 
Consultants who are experts on the different safety aspects, the guidance is updated to reflect any 
new evidence based safety changes.  

I address your request in Section 5 in regard to the matters of concern. You draw attention to the 
provision of lifeguards, medical training and communications. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 -2- 

The presence of lifeguards at swimming pools is not a legal requirement in many overseas countries, 
nor is it in the UK. The current Technical Guide section on Pool Safety and Waterparks addresses the 
subject of lifeguards. In the Customer Information section there are clear recommendations on the 
need to inform customers as to whether there is a lifeguard present or not.  

We believe this advice is important for any property that has swimming pools as research shows that 
British nationals of all ages have experienced difficulties when swimming in the UK and overseas. In 
the absence of international standards on the requirement for lifeguards we believe that the 
Technical Guide does reflect current best practice and helps to create a common approach.  

In addition to the Technical Guide we also have an ongoing campaign with the Royal Life Saving 
Society and the Foreign and Commonwealth Office to raise awareness about the potential risks of 
swimming on holiday and to raise awareness about building up swimming ability prior to a holiday. I 
attach a copy of the posters and key messages. 

 The Technical Guide section on Pool Safety addresses emergency procedures from management 
responsibility to appropriate staff training. The Management Responsibility section addresses the 
need to train staff in lifesaving techniques, CPR and first aid. We believe that this reflects current 
best practice and we continue to promote this approach for Members to their suppliers.  

We have drawn your Matters of Concern to the attention of the Consultants currently reviewing the 
relevant sections of the Technical Guide. We do know that there has already been discussion about 
and a review of the information on emergency procedures and the signage at swimming pools. Any 
new guidance on these matters will be built in to the next edition of the Technical Guide. 

I would also highlight that ABTA and our members have been calling for a European Tourism 
Accommodation Safety Directive to create a common framework for all travel across Europe. Whilst 
this would not cover global safety standards we have seen that where European Standards are 
developed these can get adopted in other key tourism destinations. I include a summary of our 
Tourism Accommodation Safety campaign activity. This is a core part of our policy agenda and we 
continue to lobby for change.  

ABTA is not aware of the full facts in the specific case which is the subject of your report and 
therefore is unable to comment on the particular circumstances surrounding the tragic death. We 
wish to offer our sincere condolences, through your office, to the family and friends of Alfie Gray.  

Yours sincerely, 

Mark Tanzer  
Chief Executive 

Encs.