The most important phrase in Martyn’s Law for hospitality operators isn’t “procedures” or “measures” or “inspection.” It’s “so far as is reasonably practicable.”

This phrase calibrates the depth of your preparation to the nature of your premises, your resource, and what it takes to implement. Understanding how it works is the difference between under-preparing, over-preparing, and preparing appropriately.

“So far as is reasonably practicable” is long-established in UK regulatory practice. It appears in the Health and Safety at Work etc. Act 1974 and has been developed through decades of case law.

In Martyn’s Law, it’s used the same way: you do what’s reasonable given the nature of your site , the resources available, and the cost or effort of the preparation.

Three factors shape what’s reasonably practicable for a given premises:

1. The nature of the risk

A city-centre premises with 750 expected attendance on a typical Friday night faces different risk considerations than a country pub with 220 at a local sports event once a quarter. Both are in scope. The level of preparation expected differs.

2. The resources available

A mid-sized independent operator doesn’t have the resource of a 200-site chain. The Act recognises this. What’s “practicable” for a multi-million-pound hospitality group is not what’s “practicable” for a single-site independent.

3. What it takes to implement

If a specific approach would require significant expense or operational disruption disproportionate to the risk reduction it delivers, the Act doesn’t require it. Proportionality sits at the heart of “reasonably practicable.”

Single independent pub (200 to 400 expected)

• Four procedures, premises-specific but not elaborate
• Staff training during an existing team meeting once a year
• Tabletop exercise with the management team annually
• Evidence kept in one place (platform or simple shared folder)

Proportionate preparation for a small team. The regulator would expect to see this level; they wouldn’t expect multi-site dashboards or formal board-level rationale.

Multi-site hospitality group (10 to 50 sites)

• Four procedures per site, with central templating but site-specific detail
• Staff training rolled out via a central learning system
• Exercise schedule across sites on a rotation
• Central dashboard showing readiness status per site
• Board-level oversight of the programme

Proportionate preparation for a group with the resource to coordinate across sites. The regulator would expect to see central coordination; they would spot gaps if sites were left to figure it out individually.

National hospitality operator (100+ sites)

• Standardised procedures with per-site customisation
• Learning and development infrastructure integrated with Martyn’s Law content
• Quarterly exercise cadence across the estate
• Senior compliance ownership with reporting to the board
• Ability to demonstrate consistency and programme quality across the estate

Proportionate preparation for a national operator. The regulator would expect programme-level governance, not just site-level preparation.

Two common misinterpretations are worth addressing:

• “If it’s a hassle, I don’t have to do it.” Reasonably practicable doesn’t mean “convenient.” It means “proportionate to the risk and resource.” Inconvenience isn’t a valid reason to skip a duty.

“Large organisations have to do more than everyone else.” Large organisations do have more resource and scope for more sophisticated preparation. But every in-scope premises, regardless of size, has to prepare the four procedures, train staff, run an exercise, and evidence it. The depth varies; the duty doesn’t.

For hospitality operators, the evidence layer is particularly important. In hospitality premises with high staff turnover, seasonal peaks, and operational pressure, keeping procedures, training records, and exercise outcomes current takes genuine effort.

A purpose-built platform handles this by updating evidence automatically as training is completed and procedures change. Without one, the evidence layer is where most hospitality preparation breaks down.

The fastest way to know is our free Am I in Scope? tool. A handful of questions, a clear answer, no account needed.

If you already know you’re in scope, Get Started with Prova Risk to prepare your public protection procedures, train your staff, and keep the evidence you’ll need if inspected. £399 per year per site.

• For the Leisure and Hospitality Sector
• Martyn’s Law for Pubs: What Ready Looks Like
• Multi-Site Martyn’s Law Management
• What Are Public Protection Procedures?
• Cost Per Premises Under Martyn’s Law