Bonamie Armitage

MFH ASSOCIATION

Overley Barn, Daglingworth, Cirencester, Gloucestershire. GL? 7HX

Email: office@mfha.co.uk
Website: www.mfha.co.uk

24th July, 2017

Ms. K. Skerrett,

Senior Coroner for Gloucestershire,
Gloucestershire Coroner’s Court,
Corinium Avenue,

Barnwood,

GLOUCESTER.

GL4 3DJ

Dear Ms. Skerrett,

Inquest into the death of Bonamie Elena Miriam Armitage
Regulation 28 Report to Prevent Future Deaths

As the Director of the Master of Foxhounds Association (MFHA), I am writing in response to the
Report sent to my organisation dated 25th May, 2017.

You have determined in paragraph 6 of that Report that in your opinion action should be taken to
prevent future deaths and that my organisation has the power to take such action. You should be
aware that the powers of the MFHA are limited. Whilst we as an organisation regulate hunting there
are many Hunts that are outside any jurisdiction that we might have. By way of example, the MFHA
does not regulate Hunts that operate through the Association of Masters of Harriers and Beagles, under
the Masters of Deerhounds Association and the Masters of Draghounds and Bloodhounds Association.
In addition, there are a number of unregistered Hunts with which the MFHA has no contact.

The MFHA does have authority over its own members and listed below are the relevant powers
extracted from the MFHA Constitution Rules and Recommendations 2008.

A.4(3) - Power to regulate Recognised Hunts

A.A(5) - Power to recommend new or revised Rules for approval by the AGM.

A.4(7) - Power to issue instructions, which will only be valid for 12 months when they either have to
be renewed or incorporated in the Rules.

A.4(8) - Power to issue Guidance Notes.

The MFHA regulates the activity of hunting, including, the management of a Hunt country, and the
welfare and breeding of hounds. It has never sought to regulate those who participate in hunting,
including staff employed by individual Hunts. The MFHA is not a regulatory body like, for example,
the Football Association or the British Board of Boxing Control, both of which regulate commercial
operations with significant budgets and large numbers of professional staff, neither of which the
MFHA has. Furthermore, the MFHA has virtually no sanctions apart from expulsion, which is rarely
used, and obviously only then in extreme circumstances. The sanction of expulsion would have the
consequence of the Hunt concerned operating independently. It would not prevent the Hunt from
operating.

Director: Tim Easby

-2-

Hunting is fundamentally a voluntary community activity, with no commercial operators or activities.
While most Hunts may employ one or two, and sometimes more, professional staff - not all of whom
are mounted, the activity of hunting is entirely dependent upon a large number of supporters, at a local
level, doing an enormous amount of voluntary work to enable their local Hunt to operate on two, three
or four days each week throughout the season.

The Rules set out above show that the MFHA has wide powers to adopt, instigate and enact new
Rules. Proposed new Rules are discussed by the Committee at its regular meetings and, if agreed, are
then put to the next Annual General Meeting for the members to approve or otherwise. However, the
Committee is unlikely to recommend Rules that it believes would not be widely accepted and adhered
to by members and the wider hunting community and in these circumstances the voluntary nature of
hunting lends itself better to the issuance of Guidance Notes. The Association cannot compel
members to follow any guidance issued.

MFHA Guidance

The MFHA has issued guidance in the past relating to health and safety of Hunt staff, but has never
sought to regulate hunting by way of guidance to those who subscribe to Hunts or who ride with Hunts
as guests. The MFHA maintains no records of Hunt followers and has no rules about the way in which
they conduct themselves. We have in the past issued guidance on such matters as headgear, which is
relevant both to Hunt staff and to followers. This organisation has no power to compel individuals to
follow that guidance, nor to enforce any steps that we might recommend.

Bearing those factors in mind, I have reviewed the matters of concern set out in paragraph 5 of the
Regulation 28 Report. I have also liaised with the Cotswold Hunt - which is a Hunt which is within
the membership of the MFHA - because I am aware that the Hunt has been reviewing its Risk
Assessments following the death of Bonamie Armitage. My response in relation to each matter of
concern (speaking on behalf of the Association) is as follows:

MATTERS OF CONCERN
1. There is no mandatory requirement that all child participants in a Hunt are required to wear
personal protective equipment:

Response:
I note that the Hunt propose to include within the Risk Assessment which relates to trail

hunting activities, that all children are to wear headgear and body protectors which conform
to current EU safety standards. I am prepared to issue guidance to the membership of the
MFHA that this is the recommended practice for all Hunts.

2. There is no mandatory requirement that all child participants in a Hunt are required to
demonstrate an established level of competence before participating in a Hunt:

Response:
At present the proposed Risk Assessment states that children aged 14 to 17 may ride

unsupervised provided that they hold the Pony Club C Test, or an equivalent qualification, or
have demonstrated their competence by previous experience. | understand that at the Inquest
the Health and Safety Authority indicated that children from the age of 11 upwards would be
able to ride independently if they held the C Test. In my experience, an established level of
competence can be obtained through children’s Hunts and through riding whilst accompanied
by a more experienced participant (often a parent). Thereafter, the level of competence is
secured by experience, which is the case in many sports which carry an element of risk.

Director: Tim Easby

= oe

There are many very competent riders who hunt with our membership and who are too young
to actually take the C Test. On that basis, I would not wish to limit entry to hunting to those
who are 11 or over. I am prepared to recommend to the membership that they follow the
approach taken by the Cotswold Hunt to establish that young riders either have the C Test or
the requisite experience to participate.

3. There is no mandatory requirement that children are supervised by adult riders when
participating in a Hunt, and no ratio of adult supervisors to child riders is stipulated:

Response:
Many of the most talented riders engaging in hunting will be in the age bracket of 11 to 17.

Some of those riders will be of an International standard for equestrian events. To that extent,
it would not be necessary or desirable that riders of considerable ability and experience
should require supervision from an adult who may well be less competent. In my experience,
and the experience of our members, most of the occasions where unsafe riding is identified,
will be amongst the adult contingent. Hunts will determine for themselves whether any
formal Rules are required in relation to supervision, but I regard the view taken by the
Cotswold Hunt is to be a sensible approach.

It can be summarised as follows:

(a) Children under 5 years of age will be on a lead rein;

(b) Children aged 6 to 13 (although they may well change that to 11 given the
observation above), will be supervised; and

(c) Children aged 14 to 17 (again this may be altered to 11) may ride unsupervised
provided that they satisfy the matters set out in 2 above.

The category of children from 6 to 11 falls between the other groups. For the first group
under 5 there is complete supervision. For the third group there is no supervision on the
proviso that there is either a Club C Test held or sufficient experience. Within the middle
group there will be extremely competent riders and everything that I have read suggests that
Bonamie Armitage was in that category. The degree of supervision will therefore be
variable. There may be days when a competent 10 year old requires very little supervision.
There may be other days — perhaps on a different pony — where a considerable amount of
supervision will be required. It is because of those variables that I do not consider that a
pre-determined ratio is required. The best information available on the proficiency of both
pony and rider will almost invariably come from the supervising adult. Having those
supervision arrangements in the hands of those that know the child or children well, is in my
view, a far safer option than an arbitrary ratio.

The MFHA will obviously continue to keep issues of safety under review. Obviously the death of
Bonamie Armitage was a tragedy, but accidents involving young riders in the hunting field are very
rare. More frequent are the accidents involving adults which reflects the fact that following hounds
across country on an undetermined route can never be entirely free of risk.

Yours sincerely,

—_

Director: Tim Easby