Golf Club Management
Lesson 11: Risk, health and safety and statutory requirements
Goal: run a risk assessment for a golf club, explain management’s legal duties for health and safety, and summarise the main South African statutory requirements a club must meet.
Risk management: ISO 31000
ISO 31000:2018 (adopted in South Africa as SANS 31000) is the international standard for risk management. Its process has these steps:
- Scope, context and criteria: what are we assessing, and what level of risk is acceptable (the club’s risk appetite, set by the board)?
- Identify risks: what could happen, why, and what would it affect?
- Analyse: how likely is it, and how severe would the consequences be, given the controls already in place?
- Evaluate: which risks need treatment, and in what order?
- Treat: avoid, reduce, share (insurance, contracts) or accept.
- Monitor and review, communicate and consult, and record throughout.
The output is a risk register, reviewed by management monthly and by the board’s audit and risk committee quarterly. King V expects the governing body to oversee risk this way. Typical club risk categories include strategic risks (membership, competition from estates), financial (cash flow, fraud), operational (course failure, key staff loss, power and water outages), people and safety, security and crime, legal and compliance, environmental (water supply, lightning, heat, flooding), reputational, and technology (cyber, data breach).
The risk matrix and its critics
Most clubs rate risks on a likelihood times consequence matrix (for example 5 by 5) and colour them red, amber or green. Cox (2008) showed that risk matrices can mislead: they can rank risks inconsistently, give the same colour to very different risks, and sometimes perform worse than random. Aven (2016) argues that risk is about uncertainty and the strength of our knowledge, not just a probability times a consequence. Evidence: strong research base for the critique. Use matrices as a communication tool, but write down the reasoning behind each rating and don’t treat the colour as a measurement.
Why accidents happen: the Swiss cheese model
Reason (2000) argued that accidents rarely have a single cause. Each defence (training, procedures, equipment, supervision) is like a slice of Swiss cheese with holes in it. Harm happens when the holes line up. Holes come from active failures (a staff member’s mistake) and latent conditions (a rostering pattern that leaves one tired person doing two jobs). The management lesson is to fix the system, not just to blame the person at the end of the chain.
Health and safety: management’s legal duty
The Occupational Health and Safety Act 85 of 1993 requires every employer to provide and maintain, as far as reasonably practicable, a working environment that is safe and without risk to the health of employees. Section 9 extends that duty to people who aren’t employees but may be affected, such as members, visitors, contractors and caddies. The Act also requires:
- a risk assessment and written safety procedures for hazardous work;
- health and safety representatives for workplaces with more than 20 employees, and a health and safety committee where there are two or more representatives;
- the section 16(2) assignment, in which the CEO (at a club, usually the GM) can delegate specific duties to named managers in writing. The CEO stays accountable;
- compliance with the regulations, including the General Safety Regulations, the Driven Machinery Regulations (mowers, workshop equipment) and the Regulations for Hazardous Chemical Agents, 2021 (pesticides, fuel, cleaning chemicals).
Employees injured at work are covered by the Compensation for Occupational Injuries and Diseases Act 130 of 1993 (COIDA). The club must register with the Compensation Fund, pay its annual assessment and report injuries.
Psychosocial safety and harassment. The Code of Good Practice on the Prevention and Elimination of Harassment in the Workplace (2022), issued under the Employment Equity Act, requires employers to take proactive steps against all forms of harassment. That means a policy, a risk assessment, training and a complaints procedure. It also covers harassment by third parties, which at a club means members and guests. A member who abuses bar staff is the club’s problem in law, not just a matter of manners.
The hierarchy of controls (most to least effective): eliminate the hazard; substitute something safer; isolate or engineer it away; administrative controls (procedures, training, signage); personal protective equipment.
Golf club hazards
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| Hazard | Example controls |
|---|---|
| Lightning (the Highveld has some of the highest lightning densities in the world) | Lightning detection and siren; clear evacuation procedure and shelters; staff trained to clear the course; the rule enforced for members, not just staff |
| Struck by golf balls (staff, members, neighbours) | Course design and netting; staff work procedures when golfers are on the course; “fore” culture |
| Golf carts and machinery | Cart path design; driver rules; machinery guarding; rollover protection; Driven Machinery Regulations training records |
| Chemicals (pesticides, fuel) | Safety data sheets; trained handlers; registered products used as labelled; secure storage; spill kits |
| Security and crime | Perimeter fencing and patrols; access control; panic buttons; procedures for armed robbery on the course; staff transport home after late shifts |
| Kitchen and bar | Burns, cuts, slips; manual handling; aggression late at night |
| Heat | Water, shade and rest breaks for outdoor staff and caddies; heat rules for competitions |
| Water hazards and dams | Signage; access control; rescue equipment |
The Director of Golf owns many of these on the golf side: starters, marshals, caddies, carts, competitions and events.
The statutory map
| Area | Law and what it means for a club |
|---|---|
| Legal form and governance | Companies Act 71 of 2008 for an NPC: MOI, directors’ duties, minutes, annual financial statements. A voluntary association depends on its constitution. King V sets governance principles for both |
| Tax | Income Tax Act 58 of 1962, section 30A: approval as a recreational club and partial exemption, with limits on trading income |
| Health and safety | OHS Act 85 of 1993 and its regulations; COIDA registration and returns |
| Labour | Basic Conditions of Employment Act, Labour Relations Act, the National Minimum Wage Act; caddie arrangements must be checked (employee or independent contractor?) |
| Employment equity | Employment Equity Act 55 of 1998: a club with more than 50 employees is a designated employer and must have an EE plan aligned to the sectoral numerical targets (plans run from 1 September 2025 to 31 August 2030) and report annually |
| Harassment | The 2022 Code of Good Practice: policy, risk assessment, training, procedure; covers members and guests as third parties |
| B-BBEE | Broad-Based Black Economic Empowerment Act 53 of 2003 and the Codes of Good Practice (below) |
| Liquor | Provincial acts. In Gauteng the Gauteng Liquor Act 2 of 2003 sets the rules for a club licence: the club must be a bona fide club with at least 15 ordinary members, management elected by members holding minuted meetings, only members paying for liquor and refreshments, limits on guests, a register of members, annual subscriptions, and no individual profiting from liquor sales. A club must keep meeting these conditions, not just at application |
| Privacy | Protection of Personal Information Act 4 of 2013 (POPIA): register an Information Officer with the Information Regulator; meet the eight conditions for lawful processing; get consent for direct marketing; keep a PAIA manual. Since 1 April 2025, every security compromise must be reported to the Regulator through its eServices portal, with no materiality threshold, and the affected people told |
| Consumers and public liability | Consumer Protection Act 68 of 2008: section 49 requires notices that limit the club’s liability (indemnity boards, scorecard wording) to be drawn to the person’s attention in plain language. Claims by injured visitors are decided under the law of delict |
| Safeguarding children | Children’s Act 38 of 2005 (Child Protection Register) and the Criminal Law (Sexual Offences and Related Matters) Amendment Act 32 of 2007 (National Register for Sex Offenders): staff, volunteers and coaches working with juniors must be checked, and people on the registers may not work with children |
| Water and environment | National Water Act 36 of 1998 (licensed or authorised water use, including boreholes); National Environmental Management Act 107 of 1998, section 28 duty of care for pollution (Lesson 12) |
Public liability insurance is essential. Check its limit, what it excludes (coaching may need separate professional cover), and that contractors and the pro shop lessee hold their own cover.
B-BBEE in practice
B-BBEE scores organisations on ownership, management control, skills development, enterprise and supplier development, and socio-economic development. Size decides which scorecard applies. An exempted micro enterprise (annual revenue of R10 million or less) is deemed a Level 4 contributor. A qualifying small enterprise (R10 million to R50 million) uses a simpler scorecard, and larger entities use the generic scorecard. A members’ club has no shareholders, so ownership is treated differently. Ask a SANAS-accredited verification agency how your club is measured.
The practical levers are management control (who is on the board and in senior jobs, which links to employment equity), skills development (learnerships and training pathways for greenkeepers, caddies, chefs and golf operations staff), procurement from B-BBEE-compliant and black-owned suppliers, and community development programmes. Sponsors, corporate golf day clients and municipalities (where a club leases land) often ask for a certificate. Treat this as a strategic issue for the board, not only a compliance task.
Compliance as a system
Keep a compliance register: each obligation, its source (Act, licence condition, contract), the owner, how often it must be checked and the evidence that it was. Examples include the liquor licence and its conditions, COIDA registration and returns, the EE plan and annual report, the B-BBEE certificate, health and safety representative appointments, chemical registers, the Information Officer registration and PAIA manual, safeguarding checks for junior coaches and volunteers, fire equipment inspections, and the certificate of acceptability for the kitchen.
Critical view
- Compliance can crowd out risk thinking. A club can tick every box and still miss its biggest risk (dependence on municipal water, or one key person).
- Laws change. Every statute in this lesson should be checked against the current version before you rely on it. This lesson is not legal advice.
Seminar questions
- Use the Swiss cheese model to explain a golf cart rollover on a wet slope. Which slices had holes?
- Under the 2022 harassment code, how should a club manage a member who regularly abuses bar staff? What if he’s a past president?
- Should B-BBEE and employment equity be treated as compliance or as strategy for a South African club?
Workplace task 11
Build a risk register for your club with ten risks across at least five categories, including lightning and security. For each one record the cause, existing controls, rating, treatment and owner. Then pick the three highest risks and explain how you would explain them to the board.
Watch
Sources
- Aven (2016), Risk assessment and risk management: review of recent advances on their foundation, European Journal of Operational Research
- Cox (2008), What’s wrong with risk matrices?, Risk Analysis
- Reason (2000), Human error: models and management, BMJ
- ISO (2018), ISO 31000:2018 Risk management: Guidelines (SANS 31000)
- Department of Employment and Labour, Code of Good Practice on the Prevention and Elimination of Harassment in the Workplace; Bowmans, Employers’ obligations under the new code
- Cliffe Dekker Hofmeyr (2025), Sectoral targets under the Employment Equity Act amendments
- Gauteng Liquor Act 2 of 2003 (Laws.Africa)
- Information Regulator, POPIA; Moonstone (2025), Data breach reporting must be online
- SARS, Tax Exemption Guide for Recreational Clubs
- GolfRSA (2019), Transformation Charter 2019 to 2023
Draft module material for the PGA of South Africa Director of Golf certificate, for discussion. South African law applies throughout. It is general education, not legal or financial advice: Acts, regulations and codes change, so check the current version and take advice before acting on them.