Making Emergency Procedures Accessible Under Martyn's Law
Contrast on a step edge is one of the cheapest safety controls there is, and one of the most useful in an evacuation. Daniel Morgan-Williams, Founding Director, Visualise Training and Consultancy Ltd., explains that the publication of statutory guidance for Martyn's Law has prompted venues, employers and event organisers to examine how they would respond to a terrorist attack. Procedures are being reviewed, staff responsibilities are being allocated, and organisations are working out how they would evacuate, invacuate, lock down and communicate during an incident.
There is a practical question every responsible person should be asking alongside that work. Will those arrangements actually work for somebody who cannot see a sign, hear a public announcement or follow a conventional instruction in a fast-moving emergency?
Who this applies to, and when
It is worth being clear about scope before going further. The Terrorism (Protection of Premises) Act 2025, widely known as Martyn's Law, creates two tiers. The standard tier covers qualifying premises where 200 to 799 individuals may be present at the same time, including staff. The enhanced tier covers premises and events where 800 or more may be present. The Security Industry Authority is the regulator, and the Act is expected to come into force in spring 2027.
That timescale matters, because it means accessibility can be designed into procedures from the outset rather than bolted on later. Retrofitting is always more expensive and usually less effective.
The statutory guidance is explicit that the Act sits alongside other duties rather than replacing them. It states that the Act does not supersede other legislation, and that those with requirements under it may also have obligations under legislation relating to health and safety, fire safety and licensing, as well as under the Equality Act 2010.
That acknowledgement is important. What the guidance does not do is set out in detail how to make emergency communication, evacuation, invacuation and lockdown accessible to people with sight or hearing loss. Turning the broad requirement for effective procedures into arrangements that work for everyone present is left to the organisation.
Do not build the response around one sense
Emergency communication usually means some combination of verbal instructions, signage, posters, staff briefings and audio broadcasts. Any of these can be effective. None of them will reach everybody in every situation.
An audible alarm may not be heard by somebody with hearing loss, particularly where there is machinery, music, crowd noise or hearing protection in use. Hearing aids do not restore hearing to normal, and they amplify background noise along with speech. A public address announcement that sounds loud and clear to one person can be completely unintelligible to another.
Visual information presents a different set of barriers. Someone with sight loss may be unable to read an illuminated sign, identify a safe route or see a member of staff pointing towards an exit. Flashing beacons alert some people with hearing loss, but they are not a complete answer if they cannot be seen from every relevant area, and toilets and quiet rooms are where they are most often missing.
The practical answer is layered communication. Depending on the premises and who uses it, that might combine audible alarms, visual beacons, clear spoken instructions, vibrating alerts, accessible mobile notifications and direct communication from trained staff. The point is not to install everything available. It is to avoid building the entire response around one sense.
Accessibility belongs inside each of the four procedures
Martyn's Law identifies four public protection procedures: evacuation, invacuation, lockdown and communication. Accessibility should be considered within each one, rather than added as a paragraph at the end of the plan.
Evacuation
Can a person with sight loss identify and use the proposed route if lighting is reduced, familiar routes are blocked, or furniture and people have moved? Are staff confident about offering guiding assistance without grabbing or pulling?
Invacuation
If people must move to a safer location inside the building, will directions be understandable without relying on pointing, colour-coded zones or small signs? Can somebody with hearing loss receive updates once they get there?
Lockdown
Will everybody know a lockdown has begun? A person who does not hear a coded announcement could unknowingly walk towards danger. A person with sight loss may not see colleagues silently moving into a secure area.
Communication
How will initial warnings, changes of instruction and the eventual all-clear reach people with different communication needs? It is not enough for a message to be transmitted. It has to be received and understood.
Build it into the practical plan
Organisations do not need to predict every possible circumstance. They do need to examine the points at which a disabled person could be left without information or assistance. Useful actions include:
- Map the complete communication chain, from recognising a threat through to alerting staff, visitors, contractors and the public.
- Use more than one communication method where it is appropriate and reasonably practicable, particularly in noisy, large or complex premises.
- Check whether alarms, announcements and visual alerts can be detected from toilets, meeting rooms, quiet rooms, staff-only areas and external spaces.
- Use simple, direct instructions. Staff should say where somebody needs to move and what hazards are present, rather than relying on gestures or phrases such as 'over there'.
- Agree individual arrangements with employees who have sight or hearing loss, and connect these with existing emergency and evacuation planning, including personal emergency evacuation plans.
- Identify who will provide direct assistance, and establish a backup for absence, shift changes, lone working or reduced staffing.
- Ensure security searches and access controls accommodate guide dogs, mobility aids, hearing equipment and people who need a modified or more private process.
- Test the arrangements through realistic exercises, and include disabled employees rather than excluding them because participation is more complicated.
Train people, not just procedures
Even a well-written plan fails if staff do not know how to apply it. People panic, use inappropriate physical contact, or assume somebody else is responsible for helping.
Staff should understand how to offer an arm and guide a person with sight loss safely, including giving clear warnings about steps, doors, changes of level and obstacles. They should also know that shouting is not a communication strategy. Facing the person, speaking clearly, reducing background noise where possible and confirming that the instruction has been understood will do considerably more.
Training should challenge assumptions too. Sight and hearing loss exist on a spectrum. Two people with the same diagnosis may have very different functional needs, and somebody who manages independently during an ordinary working day may need more support when lighting, noise, layout and routine all change at once.
Use drills to find the weaknesses
An exercise may reveal that a visual beacon cannot be seen from a particular room, that a public announcement becomes unclear when machinery is running, or that the nominated colleague is regularly absent on a certain shift. It may show that a security barrier has narrowed an accessible route, or that staff know how to begin an evacuation but not how to communicate a sudden change to lockdown.
None of that is a reason to avoid testing. It is the reason testing exists. The purpose of an exercise is to find the weaknesses while there is still time to correct them.
Accessible planning is stronger planning
Accessible procedures do not only benefit people who identify as disabled. During a serious incident, smoke, darkness, noise, crowd movement, injury and fear can temporarily affect anybody's ability to see, hear, process information or follow instructions. People lose their glasses, get separated from colleagues, or cannot hear an announcement over alarms and shouting.
Clear instructions, layered communication, trained staff and tested contingencies make emergency arrangements more resilient for everybody in the building.
Martyn's Law is an opportunity to look beyond whether an organisation has a written procedure and ask whether that procedure can be used by every person it is meant to protect. The guidance acknowledges Equality Act responsibilities. The next step is turning that acknowledgement into alarms, communications, training and human support that work in practice.
If a person cannot see the instruction, hear the warning or understand what to do next, the procedure is not yet effective.
About Visualise
At Visualise, we carry out specialist workplace assessments for employees with visual impairment and hearing loss, including people living with both. We work across the UK and Ireland, and our recommendations are independent because we do not sell equipment.
Daniel Morgan-Williams is Founding Director of Visualise Training and Consultancy Ltd. He writes from both professional experience supporting organisations with sensory loss in the workplace, and his own lived experience of visual impairment.