Rosa King
PFD Report
All Responded
Ref: 2019-0239
All 2 responses received
· Deadline: 13 Nov 2019
Sent To
Response Status
Responses
2 of 7
56-Day Deadline
13 Nov 2019
All responses received
About PFD responses
Organisations named in PFD reports must respond within 56 days explaining what actions they are taking.
Source: Courts and Tribunals Judiciary
Coroners Concerns
_ 5.1 Conventional firearms not held by Hamerton Zoo Lack of clear national guidelines 5.1.1. Should tiger escape the tiger enclosures at Hamerton Zoo or a keeper should inadvertently find themselves in the same area as a tiger, am concerned that the zoo still does not currently have access to conventional firearms to shoot a tiger in that situation to preserve human life_ 5.1.2 heard evidence that the ZOO taken measures for_two_membersof staff to morning visiting The gates from has obtain firearms' licences and they have received firearms training: However, heard evidence that the zoo has not been approved as premises to hold firearms (action for which rests with the firearms licensing department at the local constabulary) and the zoo has not fitted appropriate firearm secure containers While moving to hold conventional firearms has been made a condition of the zoo's licence under the Zoo Licensing Act 1981 (ZLA), am concerned that more than two years after Rosa's death, the process of the zoo obtaining conventional firearms has still not been completed. This carries a risk of further deaths 5.1.3. Moreover, at present only two members of the zoo staff have been trained to use conventional firearms_ am concerned that this is too few a number to ensure that member of staff trained in conventional firearms will always be on duty when the public have admittance to the zoo. This carries a risk of further deaths. 5.1.4 heard evidence that DEFRA's "Secretary of State's Standards of Modern Zoo Practice" is being redraftedlhas been redrafted but is not yet published. Paragraph 8.20 of the guidance as currently drafted states, 'Where a zoo holds any primate, carnivore, elephant; or hoofed mammal, listed in category of Appendix 12, appropriate firearms must be available, unless a risk assessment has shown that a firearm would not provide the most appropriate means of protection to the public from that animal, and other arrangements have been made. am concerned that the wording of this provision may have contributed to the zoo being able to pass ZLA inspections since it held one form of firearm (a darting gun) and had an arrangement with local police for conventional firearms cover. In contrast, receivved evidence from an independent expert and highly experienced zoo manager, designer and consultant that he was stunned to learn that no firearms were kept on site at Hamerton and they had had tigers since around 2003"_ am concerned that a lack of clear guidance that all Zoos which hold tigers must possess licensed conventional firearms carries a risk of further deaths. 5.1.5 Similarly, the HSE's guidance "Managing Health and Safety in Zoos" states, "63 Firearms andlor dart gunsblowpipes will be needed wherever there are hazardous animals whose escape or uncontrolled movement would represent & high risk to employees or members of the public If your zoo possesses or requires such equipment, you will need to consult with the police, as all firearms must be licensed. You will also need to keep in touch with the police to ensure your procedures are up to date. 64 It is essential that firearms and ammunition are readily available but; at the same time, kept secure in accordance with police licensing requirements In drive - through enclosures containing dangerous animals (see dangerous animals categorisation in Appendix 12 of the Secretary of State's Standard of Modern Zoo Practice) where they are needed at all times, specifically authorised people should be in charge of them: 65 Firearms and dart guns must be properly maintained, cleaned and tested. It is recommended that external specialists should examine them periodically and that firearm testing and examination is recorded. 66 Staff licensed to use firearms or dart guns must be given proper training and undertake practice exercises in their use. Refresher training and assessment is essential. Particular attention should be paid to employees ability to make the right decision in the presence of members of the public, and the training should reflect this The advice of firearms trainers recommended by the police should be sought in this matter Practice exercises will help to test the efficiency of control measures You should ensure that sufficient staff are authorised and trained to use firearms, to provide cover for absences or complex situations (see section 8(20) of the Secretary of State's Standard of Modern Zoo Practice1 and British and Irish Association of Zoos and_Aquariums_(BIAZA)_guidelines in Further yet yet reading):" emphasis added). Absence of air-lock type double keeper to the tiger paddock 5.2.1 am concerned that simple human error on the part of safety-conscious experienced zoo keeper led to a situation whereby tiger could have attacked multiple members of the visiting public Double keeper to the tiger paddock would very likely have prevented this risk were not fitted at the time. 5.2.2 The zoo has since fitted air-lock type gates at the those entrances to their tiger enclosures that are regularly used by keepers. 5.2.3 DEFRA's "Secretary of State's Standards of Modern Zoo Practice" in its current form states, "8.6 All animals should be kept in enclosures so constructed as to avoid escape Gates and doors to enclosures must be securely locked
Responses
Response received
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Dear Mr Moss, Regulation 28: Report to Prevent Future Deaths in relation to Rosa King I am writing to you regarding our letter of 4 September 2019 in response to your 'Report to Prevent Future Deaths', dated 12 July 2019. I wish to update you on the timeline for revising the Secretary of State’s Standards of Modern Zoo Practice (SSSMZP), which we had committed in our response to update by spring 2020. Defra is committed to addressing the issues raised in the Regulation 28 report by creating a robust set of standards which place clear, legally enforceable obligations on zoos, and which are reflected in the zoo inspection reporting process. As set out in our response, the SSSMZP are developed by working closely with the Zoos Expert Committee (ZEC), an advisory body whose purpose is to provide independent, impartial and expert advice to Defra. Defra is working at pace in order to have the new set of standards published by the timescale. However, Defra has been advised strongly by ZEC to allow more time to engage fully with a wider range of experts to ensure that the new SSSMZP meet the intended objectives of securing public safety and improving animal welfare. To allow for the above, we now expect that the consultation on the revised SSSMZP and associated licensing documentation, including the inspection reports and the Guide to the Zoo Licensing Act 1981, will be launched over the summer and publication will take place no later than the end of 2020.
Response received
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Dear Mr Moss, Regulation 28: Report to Prevent Future Deaths in relation to Rosa King I am writing to provide you with a final update on the actions Defra have taken in response to your Regulation 28 report ‘Report to Prevent Future Deaths’ dated 12 July 2019 following the death of Rosa King at Hamerton Zoo (hereafter ‘the Report’). The Report set out your conclusion that there was a need for clearer guidance and more robust inspection processes to protect individuals working with tigers in zoos and to protect the public from the risk that would be caused if a tiger escaped. While the Report is confined to the risks from tigers you asked to consider the desirability of taking action in relation to other animals carrying high risk of fatality in the event of keeper contact and/or animal escape.
At the time, my predecessor wrote to you explaining what Defra’s plans were, in regard to updating the Secretary of State’s Standards of Modern Zoo Practice (SSSMZP) and how we needed to consult on any such changes. My predecessor also wrote to you subsequently to explain a number of delays in taking forward the work of updating the SSSMZP, not least the need to postpone stakeholder engagement due to the coronavirus (COVID-19) pandemic.
I can confirm that between 1 March 2022 and 21 June 2022 Defra undertook a targeted consultation on draft new Standards of Modern Zoo Practice for Great Britain (hereafter the ‘new Standards’). Defra consulted zoos, animal keepers, welfare groups, local authorities and worked with the UK Zoos Expert Committee, an advisory body whose purpose is to provide independent, impartial and expert advice to Defra and UK zoo Ministers, on the new Standards. Following the consultation we have also undertaken extensive further stakeholder engagement to enable us to introduce clearer new
OFFICIAL SENSITIVE
Standards, which will replace the SSSMZP in England and Scotland and the 2004 National Assembly for Wales’ Standards of Modern Zoo Practice in Wales.
The new Standards were published on 24 May 2025. Zoos have been given 24 months to adapt to the new Standards. Further detail on how the new Standards address the relevant actions highlighted in the Report is covered below.
Conventional Firearms
S. 6.2. DEFRA and the HSE have the power to take action to provide further / better guidance on the need for zoos holding tigers to possess and have access to conventional firearms to shoot tigers if necessary for the preservation of human life.
Defra consulted on new Standards that required that any zoo keeping a Category 1 listed primate, carnivore, elephant or hoofed mammal must ensure that suitable and sufficient firearms and ammunition, appropriate for the species housed, are kept on the zoo premises for use by authorised staff to kill escaped animals. We also consulted on a new requirement that at least 1 member of staff who is licensed and trained in the use of firearms must be available on the zoo premises during operational hours and must be able to attend the premises within 20 minutes outside of operational hours. We also consulted on requiring zoos to ensure all members of the zoo’s firearms team undergo quarterly training. We also liaised with the police authority and the Home Office in relation to their role in applying new requirements, e.g. in terms of applications from zoos for firearms licences.
After considering the results of the consultation, and further extensive stakeholder engagement, the new Standards, published on 24 May 2025, introduced a new higher category of hazardous animal – Category 1A ‘Highest Risk’. Tigers are now listed as a Category 1A ‘highest risk’ species. The new Standards require that any zoo keeping a Category 1A or Category 1 listed primate, terrestrial member of the order Carnivora, elephant or hoofed mammal, must ensure that suitable and sufficient firearms and ammunition, appropriate for the species housed, are kept on the zoo premises for use by authorised staff. At least one member of staff who is licensed and trained in the use of firearms must be available on the zoo premises during operational hours and must be able to attend the premises within 20 minutes outside of operational hours. Firearms training must be undertaken on a quarterly basis (four times per year) as a minimum.
We have included a transitional period of 24 months from the publication of the new Standards to ensure zoos have time to obtain a firearms licence where needed.
S. 6.3. Defra has the power to take action to ensure that the need for zoos holding tigers to have access to conventional firearms is robustly assessed in ZLA
OFFICIAL SENSITIVE
inspections carried out nationally by both inspectors nominated by the Secretary of State and those inspectors employed by Local Authorities as the enforcing body for health and safety in zoos.
Defra will now ensure that the standard zoo inspection report templates are updated in line with the requirements in the new Standards as set out in point (6.2) above. During the inspection process the inspector will be expected to confirm that zoos with any Category 1A or Category 1 listed primate, terrestrial member of the order Carnivora, elephant or hoofed mammal have suitable and sufficient firearms and ammunition, appropriate for the species housed, kept on the zoo premises for use by authorised staff, and that at least one member of staff who is licensed and trained in the use of firearms is available on the zoo premises during operational hours and is able to attend the premises within 20 minutes outside of operational hours. Additionally, the inspector should look for evidence that every person licensed to use a firearm and each member of the firearms team (if different) receives structured training and that their competency is assessed by a suitably qualified person. The inspector will also be expected to check that firearms training is being undertaken on a quarterly basis (four times per year) as a minimum.
If a zoo does not meet these requirements, following the new Standards coming into effect on 24 May 2027, inspectors should recommend to the licensing authority that the zoo is in breach of their zoo licence and that the zoo could be served with an enforcement notice requiring the situation to be rectified within a set period. The inspector may also recommend to the licensing authority that the zoo (or part of it) be closed while the situation is rectified. If the zoo fails to comply then the zoo could be closed permanently.
Before the new Standards come into force, Defra will also be providing training to those inspectors nominated by the Secretary of State to ensure they are familiar with the new firearms requirements.
Absence of air-lock type double keeper gates
S. 6.4. Defra and the HSE have the power to take action to provide further / better guidance on the need for double keeper gates to be fitted to tiger enclosures.
Defra consulted on new Standards that required that the keeper entrance for enclosures for any category 1 listed primate, carnivore, elephant or hoofed mammal must consist of a double air-lock type gate or door system. We also consulted on requiring procedures or mechanisms to be put in place to make sure that only one of these doors is open at any time.
After considering the results of the consultation, and further extensive stakeholder engagement, the new Standards, published on 24 May 2025, introducing the new higher
OFFICIAL SENSITIVE
category of hazardous animal – Category 1A ‘Highest Risk’ mentioned above, require that: “Where a portal opens directly into an enclosure, and the animal's behaviour and natural biology dictates a reasonable risk of escape, and that animal may be hazardous to the public or environment, there must be a double-door system in place to prevent escape from the enclosure.”
Procedures or mechanisms must be in place to make sure that only one of the doors is open at any time, and the inner (direct into the enclosure) gates or doors must open into the enclosure rather than outwards into the zoo. The animals covered by this requirement include any Category 1A or Category 1 listed primates or terrestrial carnivores, any Species of Special Concern (invasive non-native species); and all other flying mammals and birds, unless a risk assessment dictates that double-door systems are not required, and this has been confirmed by written agreement with the Licensing Authority.
We have included a transitional period of 24 months from the publication of the new Standards to ensure zoos have time to make alterations to any relevant enclosures.
S. 6.5. Defra has the power to take action to ensure that the need for zoos holding tigers to have double keeper gates fitted to tiger enclosures is robustly assessed in ZLA inspections carried out nationally by both inspectors nominated by the Secretary of State and those inspectors employed by Local Authorities as the enforcing body for health and safety in zoos.
Defra will ensure that the zoo inspection report templates are updated in line with the new Standards as set out in point (6.4) above. If a zoo does not meet these requirements of the new Standards by the time they come into effect on 23, the inspector should recommend to the licensing authority that the zoo is in breach of their zoo licence and could be served with an enforcement notice requiring the situation to be rectified within a set period. The inspector may also recommend to the licensing authority that the zoo (or part of it) be closed while the situation is rectified. If the zoo fails to comply then the zoo could be closed permanently. Before the new Standards come into force, Defra will also be providing training to those inspectors nominated by the Secretary of State to ensure they are familiar with the new double door requirements.
Working hours / night-time hand rearing work for keepers working with tigers
6.7. Defra and the HSE have the power to take action to provide guidance on the risks involved in tigers keepers being involved in hand-rearing of animals during the night, while doing safety-critical work by day.
6.8. Defra has the power to take action to ensure that the risks associated with nighttime hand-rearing of animals being conducted by those doing safety-critical
OFFICIAL SENSITIVE
work with the highest risk category of animals is robustly assessed in ZLA inspections carried out nationally by both inspectors nominated by the Secretary of State and those inspectors employed by Local Authorities as the enforcing body for health and safety in zoos.
We consider that the requirement for double-door systems for enclosures of Category 1A or Category 1 listed primates or terrestrial carnivores, along with a documented ‘Safe System of Work (SSOW) – as set out in 6.9 below - should mitigate the risks posed to public safety by human error due to worker fatigue.
As explained in ’s letter of 4 September 2019, we believe that in relation to the risks posed to keepers as a result of worker fatigue, these fall outside the remit of the new Standards and the zoo inspection process. Licensing Authorities are prohibited by section 5(7) of the Zoo Licensing Act 1981 from attaching conditions to a licence that "…relate only or primarily to the health, safety or welfare of persons working in the zoo".
However, BIAZA’s (the British and Irish Association of Zoos and Aquariums) Health and Safety Guidelines for Zoos and Aquariums (2020) – written with the support of the HSE - addresses the issue of working hours for keepers and others working with animals. The Guidelines advise keepers’ working hours should be monitored to ensure keepers have sufficient time away from work, so they are rested and alert whilst with the animals.
Risk of fatalities from systems that are solely dependent on the human reliability of tiger keepers
6.9. Defra and the HSE have the power to take action to publicise and provide better / further guidance on:
· The human factor risks for zoo keepers working with tigers; · The unacceptability of having the human reliability and training of individual tiger keepers as the only control measure for safe entry into tiger enclosures.
Defra consulted on new Standards that updated requirements on public safety with a proposed new requirement on zoos to have a documented Safe Operating Procedure (SOP) where an enclosure contained any (then) category 1 or 2 listed hazardous animals. The SOP must outline all aspects of the safe operation of the enclosure, which staff must follow. Where the enclosure contained (then) category 1 listed animals and lone working occurred, there must be a system of communication to other staff members when a member of the team enters the enclosure and exits the enclosure, and a procedure as part of the SOP with steps to be taken if there is a failure of notification within an expected time period.
OFFICIAL SENSITIVE
After considering the results of the consultation, and further extensive stakeholder engagement, the new Standards, published on 24 May 2025, introducing the new higher category of hazardous animal – Category 1A ‘Highest Risk’ mentioned above, require that: “Where an enclosure contains Category 1A, Category 1 or Category 2 listed animals, there must be a documented Safe System of Work (SSOW) in place that outlines all aspects of the safe operation of the enclosure, which staff must follow. For each hazardous species, a risk assessment must be conducted and used as the basis for formulating a SSOW for that species. Staff responsible for working with hazardous animals must be trained in following the SSOWs and such training must be recorded.”
Where an enclosure contains Category 1A or Category 1 listed animals and lone working occurs, there must be a system of communication to other staff members when a member of the team enters, and exits, the enclosure, as part of the SSOW with steps to be taken if there is a failure of notification within a defined time period as documented in the SSOW.
We consider that the requirement for double door systems for enclosures of Category 1A or Category 1 listed primates or terrestrial carnivores, along with a documented SSOW and implementation of a lone worker policy for keepers should be sufficient to mitigate the risks posed by human reliability factors.
6.10. Defra has the power to take action to ensure that systems for entering tiger enclosures that are solely dependent upon the human reliability /training of individual keepers are identified and corrected as part of ZLA inspections carried out nationally by both inspectors nominated by the Secretary of State and those inspectors employed by Local Authorities as the enforcing body for health and safety in zoos
Defra will ensure that the zoo inspection report templates are updated in line with the requirements in the new Standards as set out in point (6.9) above. During inspections the inspector should look for evidence that the zoo has in place a documented SSOW for keepers working with all Category 1A, Category 1 or Category 2 listed animals. The inspector should look for evidence that the SSOW is implemented and that the zoo has implemented a programme of regular staff training for staff working with Category 1A, Category 1 or Category 2 listed animals.
If a zoo does not meet these requirements, following the coming into effect of the new Standards, the inspector should recommend to the licensing authority that the zoo is in breach of their zoo licence and could be served with an enforcement notice requiring the situation to be rectified within a set period. The inspector may also recommend to the licensing authority that the zoo (or part of it) be closed while the situation is rectified. If the zoo fails to comply then the zoo could be closed permanently.
OFFICIAL SENSITIVE
The new Standards are published on Standards of modern zoo practice - GOV.UK. The current Standards will remain in effect until 23 May 2027.
If you have any questions about the new Standards please contact the lead policy official at Defra.
At the time, my predecessor wrote to you explaining what Defra’s plans were, in regard to updating the Secretary of State’s Standards of Modern Zoo Practice (SSSMZP) and how we needed to consult on any such changes. My predecessor also wrote to you subsequently to explain a number of delays in taking forward the work of updating the SSSMZP, not least the need to postpone stakeholder engagement due to the coronavirus (COVID-19) pandemic.
I can confirm that between 1 March 2022 and 21 June 2022 Defra undertook a targeted consultation on draft new Standards of Modern Zoo Practice for Great Britain (hereafter the ‘new Standards’). Defra consulted zoos, animal keepers, welfare groups, local authorities and worked with the UK Zoos Expert Committee, an advisory body whose purpose is to provide independent, impartial and expert advice to Defra and UK zoo Ministers, on the new Standards. Following the consultation we have also undertaken extensive further stakeholder engagement to enable us to introduce clearer new
OFFICIAL SENSITIVE
Standards, which will replace the SSSMZP in England and Scotland and the 2004 National Assembly for Wales’ Standards of Modern Zoo Practice in Wales.
The new Standards were published on 24 May 2025. Zoos have been given 24 months to adapt to the new Standards. Further detail on how the new Standards address the relevant actions highlighted in the Report is covered below.
Conventional Firearms
S. 6.2. DEFRA and the HSE have the power to take action to provide further / better guidance on the need for zoos holding tigers to possess and have access to conventional firearms to shoot tigers if necessary for the preservation of human life.
Defra consulted on new Standards that required that any zoo keeping a Category 1 listed primate, carnivore, elephant or hoofed mammal must ensure that suitable and sufficient firearms and ammunition, appropriate for the species housed, are kept on the zoo premises for use by authorised staff to kill escaped animals. We also consulted on a new requirement that at least 1 member of staff who is licensed and trained in the use of firearms must be available on the zoo premises during operational hours and must be able to attend the premises within 20 minutes outside of operational hours. We also consulted on requiring zoos to ensure all members of the zoo’s firearms team undergo quarterly training. We also liaised with the police authority and the Home Office in relation to their role in applying new requirements, e.g. in terms of applications from zoos for firearms licences.
After considering the results of the consultation, and further extensive stakeholder engagement, the new Standards, published on 24 May 2025, introduced a new higher category of hazardous animal – Category 1A ‘Highest Risk’. Tigers are now listed as a Category 1A ‘highest risk’ species. The new Standards require that any zoo keeping a Category 1A or Category 1 listed primate, terrestrial member of the order Carnivora, elephant or hoofed mammal, must ensure that suitable and sufficient firearms and ammunition, appropriate for the species housed, are kept on the zoo premises for use by authorised staff. At least one member of staff who is licensed and trained in the use of firearms must be available on the zoo premises during operational hours and must be able to attend the premises within 20 minutes outside of operational hours. Firearms training must be undertaken on a quarterly basis (four times per year) as a minimum.
We have included a transitional period of 24 months from the publication of the new Standards to ensure zoos have time to obtain a firearms licence where needed.
S. 6.3. Defra has the power to take action to ensure that the need for zoos holding tigers to have access to conventional firearms is robustly assessed in ZLA
OFFICIAL SENSITIVE
inspections carried out nationally by both inspectors nominated by the Secretary of State and those inspectors employed by Local Authorities as the enforcing body for health and safety in zoos.
Defra will now ensure that the standard zoo inspection report templates are updated in line with the requirements in the new Standards as set out in point (6.2) above. During the inspection process the inspector will be expected to confirm that zoos with any Category 1A or Category 1 listed primate, terrestrial member of the order Carnivora, elephant or hoofed mammal have suitable and sufficient firearms and ammunition, appropriate for the species housed, kept on the zoo premises for use by authorised staff, and that at least one member of staff who is licensed and trained in the use of firearms is available on the zoo premises during operational hours and is able to attend the premises within 20 minutes outside of operational hours. Additionally, the inspector should look for evidence that every person licensed to use a firearm and each member of the firearms team (if different) receives structured training and that their competency is assessed by a suitably qualified person. The inspector will also be expected to check that firearms training is being undertaken on a quarterly basis (four times per year) as a minimum.
If a zoo does not meet these requirements, following the new Standards coming into effect on 24 May 2027, inspectors should recommend to the licensing authority that the zoo is in breach of their zoo licence and that the zoo could be served with an enforcement notice requiring the situation to be rectified within a set period. The inspector may also recommend to the licensing authority that the zoo (or part of it) be closed while the situation is rectified. If the zoo fails to comply then the zoo could be closed permanently.
Before the new Standards come into force, Defra will also be providing training to those inspectors nominated by the Secretary of State to ensure they are familiar with the new firearms requirements.
Absence of air-lock type double keeper gates
S. 6.4. Defra and the HSE have the power to take action to provide further / better guidance on the need for double keeper gates to be fitted to tiger enclosures.
Defra consulted on new Standards that required that the keeper entrance for enclosures for any category 1 listed primate, carnivore, elephant or hoofed mammal must consist of a double air-lock type gate or door system. We also consulted on requiring procedures or mechanisms to be put in place to make sure that only one of these doors is open at any time.
After considering the results of the consultation, and further extensive stakeholder engagement, the new Standards, published on 24 May 2025, introducing the new higher
OFFICIAL SENSITIVE
category of hazardous animal – Category 1A ‘Highest Risk’ mentioned above, require that: “Where a portal opens directly into an enclosure, and the animal's behaviour and natural biology dictates a reasonable risk of escape, and that animal may be hazardous to the public or environment, there must be a double-door system in place to prevent escape from the enclosure.”
Procedures or mechanisms must be in place to make sure that only one of the doors is open at any time, and the inner (direct into the enclosure) gates or doors must open into the enclosure rather than outwards into the zoo. The animals covered by this requirement include any Category 1A or Category 1 listed primates or terrestrial carnivores, any Species of Special Concern (invasive non-native species); and all other flying mammals and birds, unless a risk assessment dictates that double-door systems are not required, and this has been confirmed by written agreement with the Licensing Authority.
We have included a transitional period of 24 months from the publication of the new Standards to ensure zoos have time to make alterations to any relevant enclosures.
S. 6.5. Defra has the power to take action to ensure that the need for zoos holding tigers to have double keeper gates fitted to tiger enclosures is robustly assessed in ZLA inspections carried out nationally by both inspectors nominated by the Secretary of State and those inspectors employed by Local Authorities as the enforcing body for health and safety in zoos.
Defra will ensure that the zoo inspection report templates are updated in line with the new Standards as set out in point (6.4) above. If a zoo does not meet these requirements of the new Standards by the time they come into effect on 23, the inspector should recommend to the licensing authority that the zoo is in breach of their zoo licence and could be served with an enforcement notice requiring the situation to be rectified within a set period. The inspector may also recommend to the licensing authority that the zoo (or part of it) be closed while the situation is rectified. If the zoo fails to comply then the zoo could be closed permanently. Before the new Standards come into force, Defra will also be providing training to those inspectors nominated by the Secretary of State to ensure they are familiar with the new double door requirements.
Working hours / night-time hand rearing work for keepers working with tigers
6.7. Defra and the HSE have the power to take action to provide guidance on the risks involved in tigers keepers being involved in hand-rearing of animals during the night, while doing safety-critical work by day.
6.8. Defra has the power to take action to ensure that the risks associated with nighttime hand-rearing of animals being conducted by those doing safety-critical
OFFICIAL SENSITIVE
work with the highest risk category of animals is robustly assessed in ZLA inspections carried out nationally by both inspectors nominated by the Secretary of State and those inspectors employed by Local Authorities as the enforcing body for health and safety in zoos.
We consider that the requirement for double-door systems for enclosures of Category 1A or Category 1 listed primates or terrestrial carnivores, along with a documented ‘Safe System of Work (SSOW) – as set out in 6.9 below - should mitigate the risks posed to public safety by human error due to worker fatigue.
As explained in ’s letter of 4 September 2019, we believe that in relation to the risks posed to keepers as a result of worker fatigue, these fall outside the remit of the new Standards and the zoo inspection process. Licensing Authorities are prohibited by section 5(7) of the Zoo Licensing Act 1981 from attaching conditions to a licence that "…relate only or primarily to the health, safety or welfare of persons working in the zoo".
However, BIAZA’s (the British and Irish Association of Zoos and Aquariums) Health and Safety Guidelines for Zoos and Aquariums (2020) – written with the support of the HSE - addresses the issue of working hours for keepers and others working with animals. The Guidelines advise keepers’ working hours should be monitored to ensure keepers have sufficient time away from work, so they are rested and alert whilst with the animals.
Risk of fatalities from systems that are solely dependent on the human reliability of tiger keepers
6.9. Defra and the HSE have the power to take action to publicise and provide better / further guidance on:
· The human factor risks for zoo keepers working with tigers; · The unacceptability of having the human reliability and training of individual tiger keepers as the only control measure for safe entry into tiger enclosures.
Defra consulted on new Standards that updated requirements on public safety with a proposed new requirement on zoos to have a documented Safe Operating Procedure (SOP) where an enclosure contained any (then) category 1 or 2 listed hazardous animals. The SOP must outline all aspects of the safe operation of the enclosure, which staff must follow. Where the enclosure contained (then) category 1 listed animals and lone working occurred, there must be a system of communication to other staff members when a member of the team enters the enclosure and exits the enclosure, and a procedure as part of the SOP with steps to be taken if there is a failure of notification within an expected time period.
OFFICIAL SENSITIVE
After considering the results of the consultation, and further extensive stakeholder engagement, the new Standards, published on 24 May 2025, introducing the new higher category of hazardous animal – Category 1A ‘Highest Risk’ mentioned above, require that: “Where an enclosure contains Category 1A, Category 1 or Category 2 listed animals, there must be a documented Safe System of Work (SSOW) in place that outlines all aspects of the safe operation of the enclosure, which staff must follow. For each hazardous species, a risk assessment must be conducted and used as the basis for formulating a SSOW for that species. Staff responsible for working with hazardous animals must be trained in following the SSOWs and such training must be recorded.”
Where an enclosure contains Category 1A or Category 1 listed animals and lone working occurs, there must be a system of communication to other staff members when a member of the team enters, and exits, the enclosure, as part of the SSOW with steps to be taken if there is a failure of notification within a defined time period as documented in the SSOW.
We consider that the requirement for double door systems for enclosures of Category 1A or Category 1 listed primates or terrestrial carnivores, along with a documented SSOW and implementation of a lone worker policy for keepers should be sufficient to mitigate the risks posed by human reliability factors.
6.10. Defra has the power to take action to ensure that systems for entering tiger enclosures that are solely dependent upon the human reliability /training of individual keepers are identified and corrected as part of ZLA inspections carried out nationally by both inspectors nominated by the Secretary of State and those inspectors employed by Local Authorities as the enforcing body for health and safety in zoos
Defra will ensure that the zoo inspection report templates are updated in line with the requirements in the new Standards as set out in point (6.9) above. During inspections the inspector should look for evidence that the zoo has in place a documented SSOW for keepers working with all Category 1A, Category 1 or Category 2 listed animals. The inspector should look for evidence that the SSOW is implemented and that the zoo has implemented a programme of regular staff training for staff working with Category 1A, Category 1 or Category 2 listed animals.
If a zoo does not meet these requirements, following the coming into effect of the new Standards, the inspector should recommend to the licensing authority that the zoo is in breach of their zoo licence and could be served with an enforcement notice requiring the situation to be rectified within a set period. The inspector may also recommend to the licensing authority that the zoo (or part of it) be closed while the situation is rectified. If the zoo fails to comply then the zoo could be closed permanently.
OFFICIAL SENSITIVE
The new Standards are published on Standards of modern zoo practice - GOV.UK. The current Standards will remain in effect until 23 May 2027.
If you have any questions about the new Standards please contact the lead policy official at Defra.
Action Should Be Taken
In my opinion action should be taken to prevent future deaths and believe that: Conventional firearms 6.1 Jf Hamerton Zoo and the Chief Constable of Cambridgeshire Constabulary between them have the power to take action to speed up the steps necessary for the zoo to obtain suitable conventional firearms and ensure that a suitable number of zoo staff are licensed and trained in the use of such weapons: see paragraphs 5.1.1 ~ 5.1.3 above. 6.2 DEFRA and the HSE have the power to take action to provide further better guidance on the need for zoos holding tigers to possess and have access to conventional firearms to shoot tigers if necessary for the preservation of human life: see paragraph 5.1.4 -5.1.5 above_ 6.3 DEFRA and the Local Government Association have the power to take action to ensure that the need for zoos holding tigers to have access to conventional firearms_is_robustly assed in ZLA_inspections _ carried out_nationally by both every Tiger entry due They safety the inspectors nominated by the Secretary of State and those inspectors employed by Local Authorities as the enforcing body for health and safety in zooS_ See paragraph 5.1.4 above. Absence of air-lock type_double keeper gates 6.4 DEFRA and the HSE have the power to take action to provide further better guidance on the need for double keeper to be fitted to tiger enclosures. See paragraphs 5.2.3 5.2.4, 5.2.6 above: 6.5 DEFRA and the Local Government Association have the power to take action to ensure that the need for zoos holding tigers to have double keeper gates fitted to tiger enclosures is robustly assed in ZLA inspections carried out nationally by both inspectors nominated by the Secretary of State and those inspectors employed by Local Authorities as the enforcing body for health and safety zoos_ See paragraphs 5.25-5.26 above Working_hours night-time _hand-rearing work for keepers working with_tigers 6.6 of Hamerton Zoo and of Sphere Health and Safety Management Ltd have the power t0 take further action to take advice assess, ad reduce the risk of tiger keepers at Hamerton Zoo working during the night in the hand-rearing of animals, having regard to best practice for working patterns/hours for those engaged in critical tasks carrying a risk of fatalities See paragraphs 5.3.1 5.3.3, above_ 6.7 DEFRA, the HSE and the Local Government Association have the power to take action to provide guidance on the risks involved in tiger keepers involved in hand-rearing of animals during the night; while safety-critical work by day: See paragraph 5.3.4, above 6.8 DEFRA and the Local Government Association have the power to take action to ensure that the risks associated with night-time hand-rearing of animals being conducted by those safety-critical work with the highest risk category of animals is robustly assessed in ZLA inspections carried out nationally by both inspectors nominated by the Secretary of State and those inspectors employed by Local Authorities as the enforcing body for health and safety in zoos_ See paragraph 5.3.4 above. Risk of_fatalities_from systems_that are solely dependent on_the_human reliability of Tiger Keepers 6.9 DEFRA, the HSE and the Local Government Association have the power to take action to publicise and provide further better guidance on: the human factor risks for zoo keepers working with tigers; unacceptability of having the human reliability and training of individual tiger keepers as the only control measure for safe into tiger enclosures_ See paragraph 5.4.5 above 6.10 DEFRA and the Local Government Association have the power to take action to ensure that systems for entering tiger enclosures that are solely dependent upon the human reliability training of individual keepers are identified and corrected as part of ZLA inspections carried out nationally by both inspectors nominated by the Secretary of State and those inspectors employed by Local Authorities as the enforcing body for health and safety in zoos See paragraph 5.4.6 above_
Report Sections
Investigation and Inquest
On 30 May 2017, the Senior Coroner commenced an investigation into the death of ROSA ANN KING, aged 33. The investigation concluded at the end of the inquest on 10 2019. The conclusion of the inquest was: Medical Cause of Death: 1a traumatic injuries How, when and where the deceased came by her death: Rosa King was the senior carnivore keeper at Hamerton Zoological Park, Hamerton, near Sawtry , Cambridgeshire_ On 29 May 2017 , at sometime between 09.38
a.m. and 10.45
a.m she died when she was attacked by the Malayan Tiger, as she went to exit the Zoo's Malayan tiger paddock She entered the paddock when all the tiger slides between the tiger paddock and the tiger den were open_ There was no mechanical failure with the keeper or the tiger slides and associated_pulleys July Cicip, gates
The system for a keeper entering any part of the tiger enclosure required the tiger to be excluded that area by a tiger slide before the keeper entered: That system depended entirely on the keeper reliably following their training: Conclusion of the as to the death: Accident.
a.m. and 10.45
a.m she died when she was attacked by the Malayan Tiger, as she went to exit the Zoo's Malayan tiger paddock She entered the paddock when all the tiger slides between the tiger paddock and the tiger den were open_ There was no mechanical failure with the keeper or the tiger slides and associated_pulleys July Cicip, gates
The system for a keeper entering any part of the tiger enclosure required the tiger to be excluded that area by a tiger slide before the keeper entered: That system depended entirely on the keeper reliably following their training: Conclusion of the as to the death: Accident.
Circumstances of the Death
4.1 Background. Rosa King (Rosa) was a senior and experienced zoo keeper with 13 years' experience_ of which 8 had been as head of the zoo's carnivore section. All the evidence suggested that she was conscientious about safety, instructed others in safety regarding the tiger enclosure, and was fully aware of the importance of never entering any part of the tiger enclosures if a tiger was present: 4.2 Working hours night-time hand-rearing work for keepers working with tigers Rosa's summertime working hours were 45 hours per week, with a six working week_ She worked 9.5 hours overtime in the month leading up to her death: In addition; she volunteered to hand-rear a serval kitten belonging to the zoo, which had been abandoned by its mother: From 22 May the kitten required feeding/care roughly three hours. Rosa took care of the kitten for 14 nights between 1 - with a pattern of feeds at (roughly) 10/1 pm, 2/3 am, and 6/7
a.m, Each feed might take only 10 minutes_ From 22 29 May_ the night-time feeding regime reduced to a feed at about midnight and 6 am Rosa did 4 of these reduced night time feeds in the week before her death, including on the Saturday and Sunday nights before her death on Monday 29 2017. Whilst a significant number of witnesses stated that Rosa was her normal cheerful self on the morning of her death, there was some evidence that she was tired. 4.3 The safety system in brief outline. On the day of the accident; Rosa had entered the tiger paddock to clean the windows of the visitor building within the tiger enclosure The process to be followed for this task involved checking where the tigers were physically located; isolating them into one of the areas away from the paddock by use of one of the vertical (guillotine-type) tiger slides; checking the slides were in place; before then entering the paddock 4.4 The immediate circumstances. When Rosa entered the paddock, the critical slide that should have been closed was in fact locked in the open position. It is possible that Rosa had left that slide open the evening before_ and then failed to notice that it was open before entering the paddock on the Monday morning: There was good visibility of the slide's position both the tiger service area and the metal security that gave entry to the paddock. Despite knowing the system well, and knowing the risks, Rosa entered the paddock when the critical slide was in the open position: There was no evidence that she would have done
a.m, Each feed might take only 10 minutes_ From 22 29 May_ the night-time feeding regime reduced to a feed at about midnight and 6 am Rosa did 4 of these reduced night time feeds in the week before her death, including on the Saturday and Sunday nights before her death on Monday 29 2017. Whilst a significant number of witnesses stated that Rosa was her normal cheerful self on the morning of her death, there was some evidence that she was tired. 4.3 The safety system in brief outline. On the day of the accident; Rosa had entered the tiger paddock to clean the windows of the visitor building within the tiger enclosure The process to be followed for this task involved checking where the tigers were physically located; isolating them into one of the areas away from the paddock by use of one of the vertical (guillotine-type) tiger slides; checking the slides were in place; before then entering the paddock 4.4 The immediate circumstances. When Rosa entered the paddock, the critical slide that should have been closed was in fact locked in the open position. It is possible that Rosa had left that slide open the evening before_ and then failed to notice that it was open before entering the paddock on the Monday morning: There was good visibility of the slide's position both the tiger service area and the metal security that gave entry to the paddock. Despite knowing the system well, and knowing the risks, Rosa entered the paddock when the critical slide was in the open position: There was no evidence that she would have done
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Data sourced from Courts and Tribunals Judiciary under the Open Government Licence.