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Food served during performance...


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Hey y'all,

 

I'm working on a big top touring circus and music show from France. The company have had no problems in France and I'm worried I'm about to open a huge can of worms but here goes...

 

As part of the show as the audience are welcomed the company cook crepes inside the big top and share them with the audience along with a small glass of wine or soft drink. They mingle with the audience playing their instruments and performing tricks for around 20 mins before the show really begins. My questions are as follows...

 

- should we be getting a TEN for the giving away of the free drink (this has not been marketed as a free drink included in the ticket price it should be noted - its more of a spontaneous thing the audience are not expecting)

- should we being undergoing all the procedures a food trader would have to for the giving away of the crepe which is cooked - I.e registering with the local authority? We will have food safety procedures in place such as hand washing facilities, avoiding contamination etc...

 

Any advice appreciated!

 

Thanks

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When it comes to alcohol, it's usually the supply of rather than the sale of alcohol that's significant. Giving it away doesn't help.

How big is your audience?

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That's a tricky one. Especially since it's not advertised and is effectively a part of the show.

It's one of those situations where you could ask and either get a sympathetic response regarding it being an art thing or you could get an officious response demanding that all boxes be ticked.

 

I wonder what churches do when they're handing out communion wafers and wine.

 

Perhaps you could be inviting the audience to "communion".

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You need some form of "Licence" under the Act even to give away free wine but do check with the relevant LA's and licensing officers. We swerved it by never charging admission with the cooperation of local police and LA but you are a commercial enterprise not a charity as we were. You probably require at least TENs.

 

If you are cooking food then you need to be registered, you don't need to sell, just prepare, cook and handle. HACCP is fairly standard now but in Wales you might even need to display hygiene inspection signs. Again, check with the LAs and EHOs you will be visiting. Enforcement and oversight varies wildly from one LA to the next and what is acceptable in one is banned outright in another. You might get away with it right through the tour ... then again you might not!

 

I might research the possibility of touring with a licensed caterer and piggy-backing on his licensing. Just a thought.

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Alcohol is treated in a different way in France, Adults drink wine and it's fine for parents to offer their children wine. In the UK the law is very strict on the provision of alcohol to children.

 

Food may well be licensable with some ease, serving wine when there could be (legal) children about may offer more challenges.

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Serving food then you need to be registered. For alcohol then you will need a TEN ( Temporary Events Notice )

 

For TEN more info is at https://www.gov.uk/temporary-events-notice

 

For food https://www.food.gov.uk/business-guidance/registering-and-managing-a-food-business

 

The best thing to do is to contact the local authority for help and guidance and you will have to speak to them anyway for the licenses.

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You may well require product liability insurance for the food. Remember too that the number of TENs allowed on a particular premises is limited to 15 approvals/21days total a year. In some parks this could well be used up by the time you get there, as could the 14/28 day GPD. It may also be a chore but I would advise looking at the licensing policies for every authority on your itinerary - they all have different priorities but it will be laid out in their licensing policy.
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If you’re putting up a Bigtops and putting on a show then you will need a TEN or be utilising a ground that already has appropriate events license in place that your event falls under because the bigtop / show itself is a licensable activity in and of itself.

 

All requirements and restrictions relating to alcohol are for the PROVISION not specifically the selling so if you are providing alcohol for anything other than a completely private party (and your event is definitely not a private party) then all the regulations, restrictions and local alcohol policies for each and every site you visit will apply. Ie some places will require you to have official bouncers, some will insist on plastic glasses only, some will not have any restrictions, some will have strict operating hours. All will require you to sign up/comply with the local challenge 21 type programs.

 

We literally have a room of people who deal with the many complicated licensing issues that touring shows in bigtops produces.

 

Just for some background - France essentially operates a national registration program (you have everything inspected/ tested once, have the paperwork checked by one local authority, then your show can tour for 2 years and just provide copies in each local authority area you visit where it will be accepted) which makes touring a show easier because you have the exact same setup for the whole tour

 

And to add; if you want to DM me with more specific questions I’m happy to help but this is a very big can of very wiggly worms

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Quick question for Tom just to clarify.

If the OP uses events sites with existing premises licences wouldn't that then raise the problem of personal licences and designated persons? If so then my suggestion of taking along a caterer with all the necessary paperwork already sorted gains even more ground.

 

As you say, can of worms and an awful lot of bumff. If I were the OP I would leap on your offer and grasp it with both hands and clenched knees.

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If the site already has license for shows AND alcohol sales then there’s probably someone down as the designated person and you have to work with them. If there’s entertainment/premises license in place but no alcohol sales then you need your own approved person to be the named individual on the license or TEN you apply for.

 

There’s zero standardisation though - there’s sites where they have blanket (and very well written) license and permissions in place for 20,000 people and staff who will help you squeeze your event in with the minimum of fuss. There’s sites where one person owns the site but licenses are held by someone else (often a funfair or local catering company) who will be a nightmare to work with. There’s sites where there’s nothing in place so you have to apply for everything from scratch. There’s sites where they have local alcohol abuse issues or militant neighbours so you have to jump through 1000 hoops just to get the most basic stuff in place.

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