Absolutely right (again

). The FRA is going through this very process as we speak.
Just one small point: In H&S employment legislation there is a duty to carry out written risk assessments but there is no such duty in common law – so ROs don’t need to. Of course they must assess and control the risks but ROs and runners do that all the time. It’s not the same as a written document.
Ironically, a written document is often used against employers because of what it does NOT contain, and there is no written risk assessment that I’ve seen (and I’ve seen hundreds) that covers every possible scenario. Most race risk assessments I’ve seen are woefully lacking in that respect so it is actually better not to produce a written document but just to be able to say what steps you took to make the event safe ‘so far as is reasonably practicable’.