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Introduction

How to keep your employees and your clients’ safe during COVID-19. 

Reopening Guidance for Beauty, Nails, Holistic and Wellbeing, Acupuncture, Electrocautery, Aesthetics and Beauty Advanced Practices Treatments and Services in Wales.

The UK is currently experiencing a public health emergency as a result of the COVID-19 pandemic. It is critical that all employers, employees, the self-employed and clients take steps to keep everyone safe. This document is to help anyone who works in the beauty, holistic and wellbeing services industry in Wales understand how to operate safely during the COVID-19 pandemic, taking reasonable measures to minimise risk of exposure to coronavirus.

To tackle the spread of COVID-19, the Welsh Government introduced the Coronavirus Regulations in March 2020. These imposed strict restrictions on gatherings, the movement of people, and the operation of businesses (some of which were required to close temporarily, including close contact services).

The Welsh Government prioritises the protection of people, and with this aim, is following a cautious approach to easing the lockdown and reopening workplaces.  We have based our approach to the reopening of businesses on the latest scientific and medical advice of the risk from particular settings, the extent to which other risk mitigations are available and in place, and the level of disease-causing transmission.

Many non-essential services have been permitted to reopen in Wales in a phased approach from 22 June 2020 as part of this easing of the lockdown.

Hairdressers and barbers were permitted to reopen in Wales from 13 July. Welsh Government has now introduced the Coronavirus Regulations (No.2) Regulations, which have replaced the Coronavirus Regulations. These Regulations will permit additional close contact services to be able to reopen from the 27 July 2020. The regulations also include the duties to ensure that other measures are in place to limit face to face interaction, maintain hygiene and provide information to people on minimising the risk of exposure to coronavirus, as well as continuing the duty of taking all reasonable measures to ensure 2 metres’ distance is kept between people on premises and people waiting to enter premises.

This guidance is part of a set of guidance documents about how to work safely in different types of close contact service workplaces in Wales:

  • Guidance for hairdressers and barbers.
  • Guidance for beauty, nails, holistic and well-being, acupuncture, electrocautery, aesthetics and beauty advanced practices treatments and services.
  • Guidance for tattoo and body piercing studios.

About this guidance

This guidance is aimed at practitioners who provide close contact services  (beauty therapists, make–up artists, nail service technicians, massage therapists, holistic, wellbeing and other practitioners, acupuncture, electrocautery, aesthetics and beauty advanced practices treatments and services practitioners) who:  

  • operate in commercial settings such as a hair and or beauty salon, nail bar, makeup studio, tanning salon, well-being and holistic settings, specialist or aesthetics salons or clinics, or within a destination spa, within a hospitality, leisure or day spa environment. ;
  • provide mobile services from their homes and in other people’s homes;
  • operate in retail environments (retail stores demonstrating retail products) and the arts; and  
  • operate in vocational training environments. You may wish to see separate Welsh Government guidance produced for face to face contact in the further education sector.

This guidance is based on government guidelines and contains advice on how the safe working steps set out in this document should be put in place in your business premises or the settings in which you are providing your services or treatments.  The Government has published Statutory Guidance to which all individuals and businesses subject to the new duties to minimise risk of exposure to coronavirus must have regard.  You should ensure that you are aware of the guidance as well as keeping aware of any further regulatory changes.

In the event of any discrepancy between this guidance and the Statutory Guidance, the Statutory Guidance has priority.

This guidance builds on these requirements with practical advice for your specific circumstances to help you think about what you need to do to restart operations during the COVID-19 pandemic to work safely and support your employees’ and clients’ health and wellbeing and not contribute to the spread of the virus.

This guidance does not supersede any legal obligations relating to health and safety, employment or equalities and it is important that as a business or an employer you continue to comply with your existing obligations, including those relating to individuals with protected characteristics: Workplace guidance for employers and employees: COVID-19.

We expect that this document will be updated over time. This version is up to date as of 24 July 2020. You can check for updates at Keep Wales Safe – at work.

This document advises how to open your businesses safely while minimising the risk of spreading COVID-19. In order for you to reopen you must take appropriate steps to safeguard against COVID-19 in 5 essential areas.   The guidance sets out:

  1. What you should do before you reopen your business; 
  2. The action you should take and the safeguards you should put in place to protect yourself and your staff;
  3. The action you should take and the safeguards you should put in place to protect your clients and visitors;
  4. The action you should take and the measures you should put in place to keep your business premises clear of COVID-19.
  5. The circumstances when you should use PPE and the current guidance on the optional use of face coverings.

Each business will need to translate this into the specific actions it needs to take, depending on the size of the business, how it is organised, operated, managed and regulated. Businesses will also need to regularly monitor these measures to make sure they are continuing to protect clients and workers.

You should note that when operational you will be under a duty to take all reasonable measures to ensure 2 meters’ distance is kept between persons, to take any other measure to minimise the risk of exposure to coronavirus, for example measures which limit close face to face interaction and maintain hygiene and to provide information to anyone on your premises on how to minimise that risk. 

It is accepted that as a close contact service you will not be able to maintain 2 metres’ distancing with a client, but you will be required to take other measures to reduce the risk of transmission of coronavirus.  There will be other circumstances, where you will be able to take reasonable measures to ensure distance is kept, for example, when clients are waiting to enter premises.

To help you decide which actions to take, you must carry out an appropriate COVID-19 risk assessment, just as you would for other health and safety related hazards. This risk assessment must be done in consultation with unions or workers.  A link to a blank risk assessment template produced by the National Hair and Beauty Federation is included in the Appendix section of this guidance.  There is also a check list included in the Appendix section to help you introduce the mitigation measures contained in this guidance.

Reopening your business

Section 1: What you should do before you reopen your business

1.1 Assessment of premises - making sure premises are safe to reopen.

You need to be mindful of the need to open up premises carefully. Business premises are not often left empty and you may wish to see the advice on maintaining drinking water quality when reinstating water supplies after temporary closure due to the COVID-19 outbreak, produced by the Drinking Water Inspectorate who are the Regulators and technical experts to everything Drinking water related in England and Wales.

You should undertake an assessment for all your sites, or parts of sites that have been closed, before reopening your premises, this will include undertaking a thorough cleaning of the premises and installing hand sanitisers, before reopening.  

1.2 Thinking about Risk - All employers must carry out a COVID-19 risk assessment.

COVID-19 is a public health emergency. Everyone needs to assess and manage the risks of COVID-19, and businesses must consider the risks to their workers and clients.

As an employer, you have a legal responsibility to protect workers and others from risk to their health and safety. This means you need to think about the risks they face and do everything reasonably practicable to minimise them, recognising you cannot completely eliminate the risk of COVID-19.

You must make sure that the risk assessment for your business addresses the risks of COVID-19, using this guidance to inform your decisions and control measures.

You should also consider the security implications of any decisions and control measures you intend to put in place, as any revisions could present new or altered security risks that may require mitigation. A risk assessment is not about creating huge amounts of paperwork, it is about identifying sensible measures to control the risks in your workplace.

If you have fewer than five workers, or are self-employed, you don’t have to write anything down as part of your risk assessment. Your risk assessment will help you decide whether you have done everything you need to. There are interactive tools available to support you from the Health and Safety Executive (HSE).

Employers have a duty to consult their staff on health and safety. You can do this by listening and talking to them about the work and how you will manage risks from COVID-19. The people who do the work are often the best people to understand the risks in the workplace and will have a view on how to work safely.  Involving them in making decisions shows that you take their health and safety seriously. You must consult with the health and safety representative selected by a recognised trade union or, if there isn’t one, a representative chosen by workers. As an employer, you cannot decide who the representative will be.

At its most effective, full involvement of your workers creates a culture where relationships between employers and workers are based on collaboration, trust and joint problem solving.  As is normal practice, workers should be involved in assessing workplace risks and the development and review of workplace health and safety policies in partnership with the employer.

Employers and workers should always come together to resolve issues.  

You should develop communication and training materials for workers prior to returning to site, especially around new procedures for arrival at work.

1.3 What will happen if you do not comply with the relevant public health legislation and guidance to control COVID -19 and other public health risks?

Failure to complete a risk assessment which takes account of COVID-19, or completing a risk assessment but failing to put in place sufficient measures to manage the risk of COVID-19, could constitute a breach of health and safety law.

Where the enforcing authority, such as the HSE or your local authority, identifies employers who are not taking action to comply with the relevant public health legislation and guidance to control public health risks, they are empowered to take a range of actions to improve control of workplace risks. For example, this would cover employers not taking appropriate action to ensure physical distancing, where possible.

The actions the enforcing authority can take include the provision of specific advice to employers to support them to achieve the required standard, through to issuing enforcement notices to help secure improvements.

Serious breaches and failure to comply with enforcement notices can constitute a criminal offence, with serious fines and even imprisonment for up to two years. There is also a wider system of enforcement, which includes specific obligations and conditions for licensed premises.

Employers are expected to respond to any advice or notices issued by enforcing authorities rapidly and are required to do so within any timescales imposed by the enforcing authorities. The vast majority of employers are responsible and will join with the UK's fight against COVID-19 by working with the Government and their sector bodies to protect their workers and the public. However, regulators are carrying out compliance checks nationwide to ensure that employers are taking the necessary steps.

1.4 Managing risk – taking action to reduce risk to the lowest reasonably practicable level by taking preventative measures, in order of priority.

Employers have a duty to reduce workplace risk to the lowest reasonably practicable level by taking preventative measures. Employers must work with any other employers or contractors sharing the workplace so that everybody's health and safety is protected. In the context of COVID-19 this means protecting the health and safety of your workers and clients by working through these steps in order:

  • Ensuring both workers and clients who feel unwell stay at home and do not attend the premises.
  • In every workplace, increasing the frequency of handwashing and surface cleaning.
  • Businesses should take all reasonable measures to ensure 2 meters distance is kept between persons, to take any other measure to minimise the risk of exposure to coronavirus, and where it is not possible to maintain 2 metres distancing with a client, to take other measures to reduce the risk of transmission of coronavirus. You should consider and set out the mitigating actions you will introduce in your risk assessments.
  • Clearly, when providing close contact services, it often may not be possible to maintain 2 metre distancing. As a result, you should consider wearing further protection in addition to that which is usually worn, for example using a face visor.
  • This should take the form of a clear visor that covers the face and provides a barrier between the wearer and the client from respiratory droplets caused by sneezing, coughing or speaking. Visors must fit the user and be worn properly. It should cover the forehead, extend below the chin, and wrap around the side of the face.  Further details about PPE is covered in more detail in Section 5.
  • Beauty therapists, make-up artists, nail service technicians, massage therapists, holistic and wellbeing practitioners, acupuncture, electrocautery, aesthetics and beauty advanced practices treatments and services practitioners are currently not permitted to provide treatments that will bring them within the ‘highest risk zone’ of clients (defined as the area in front of the face where splashes and droplets from the nose and mouth, that may not be visible, can be present and pose a hazard from the client to the practitioner and vice versa).  These ‘high risk zone’ treatments are sect out in section 3.2.

Further mitigating actions include:

  • Further increasing the frequency of hand washing and surface cleaning.
  • Keeping the activity time involved as short as possible.
  • Using screens or barriers to separate clients from one another. If the practitioner is wearing a visor, screens will not provide additional protection between the practitioner and the individual.  Everyone working in close proximity for an extended period of time must wear a visor.
  • Face-to-face working should be avoided if at all possible.
  • Using a consistent buddying system, defined as fixing which workers work together, if workers have to be in close proximity (defined as being within arm’s-length of someone else for a sustained period of time).
  • The closer someone is to the source of the virus, the greater the risk of transmission. If members of your staff must work face-to-face with each other for a sustained period with more than a small group of fixed partners, then you will need to assess whether the activity can safely go ahead.
  • For treatments and services which require practitioners to be within the ‘highest risk zone’ of each other for the entire duration or the majority of the time the service is being provided, they must wear a visor.  Particular attention should also be paid to avoiding contact with surfaces near to the client and thoroughly cleaning those surfaces after each client. No one is obliged to work in an unsafe work environment.   
  • In your assessment you should have particular regard to whether the people doing the work are especially vulnerable to COVID-19. The recommendations in the rest of this document are ones you must consider as you go through this process.
  • You could also consider any advice that has been produced specifically for your sector, for example by industry associations. You must carry out an assessment of the risks posed by COVID-19 in your workplace before you reopen your business. You are likely to have gone through a lot of this thinking already however we urge you to use this document to identify any further improvements you should make.
  • You must review the measures you have put in place to make sure they are working. You should also review them if they may no longer be effective or if there are changes in the workplace that could lead to new risks.

1.5 Sharing the results of your risk assessment

  • You must share the results of your risk assessment with your workforce.
  • If possible, you should consider publishing the results on your website; we would expect all employers with over 50 workers to do so.
  • We would expect all businesses to demonstrate to their workers, clients and guests that they have properly assessed their risk and taken appropriate measures to mitigate this. You should do this by displaying a notification in a prominent place in your business and on your website, if you have one.

Managing the risk

Section 2: What you should do to keep yourself and your staff safe from COVID-19  

When considering how to apply this guidance, take into account agency workers, contractors and other people, as well as your employees.

Employees have a legal responsibility to their employer and to each other to follow instructions about safe working practices.

The government is clear that workers should not be forced into an unsafe workplace. The health and safety of workers and clients, and public health, should not be put at risk.

This document has been prepared by the Welsh Government with input from unions and industry bodies and Local Authority Environmental Health Officers and in consultation with Public Health Wales (PHW) Health Inspectorate Wales (HIW) and the Health and Safety Executive (HSE).

Mobile nail, beauty and holistic and wellbeing practitioners who provide treatments and services in other people's homes, should also refer to the guidance on working safely during COVID-19 in other people’s homes. https://www.gov.uk/guidance/working-safely-during-coronavirus-covid-19/homes

2.1 Who should go to work?

It is recognised that for most workers providing these services, it is often not possible to work from home.

People who can work from home for example those providing back office functions, should continue to do so.

Employers should decide, in consultation with their workers, whether it is viable for them to continue working from home.  For employees who are clinically vulnerable you should discuss and agree the measures to be taken to protect and keep them safe. Further guidance on these measures is set out in section 2.2.

Where it is decided that workers should come into their place of work then this will need to be reflected in the risk assessment and actions taken to manage the risks of transmission in line with this guidance.

You should monitor the wellbeing of people who are working from home and help them stay connected to the rest of the workforce, especially if the majority of their colleagues are on-site.

You should keep in touch with off-site workers on their working arrangements including their welfare, mental and physical health and personal security.

You should provide equipment for people to work from home safely and effectively. For administrative roles, this may include access to work systems.

2.2 Protecting people who are clinically extremely vulnerable and clinically vulnerable and at higher risk

Clinically extremely vulnerable individuals and clinically vulnerable individuals have been advised not to work outside the home. 

Clinically vulnerable individuals, who are at higher risk of severe illness (for example, people with some pre-existing conditions, have been asked to take extra care in observing social distancing and should be helped to work from home, either in their current role or in an alternative role: Guidance on who is in this group.

If clinically vulnerable (but not clinically extremely vulnerable) individuals cannot work from home, they should be offered the option of the safest available on-site roles, ensuring that they maintain the required distance away from others. If maintaining the 2 metre distance from others is unavoidable, you should carefully assess whether this activity should continue.  If so, further mitigating actions should be taken to reduce the risk of transmission between staff (see Section 2.9 for examples of actions that can be taken).

As for any workplace risk you must take into account specific duties for those with protected characteristics, including, for example, expectant mothers who are, as always, entitled to suspension on full pay if suitable roles cannot be found. Particular attention should also be paid to people who live with clinically extremely vulnerable individuals.

2.3 People who need to self-isolate

You must make sure that any employees who have been advised to stay at home under existing government guidance to stop infection spreading do not physically come to work.

This includes individuals who have symptoms of COVID-19, those who live in a household or are in an Extended Household with someone who has symptoms and those who are advised to self-isolate as part of the government's test and trace service. The COVID-19 online symptom checker (on NHS 111 Wales) can tell you if you need medical help.

The steps you should take:

  • Enable workers to work from home while self-isolating if appropriate.
  • See current guidance for employees and employers relating to statutory sick pay due to COVID-19.
  • See current guidance for people who have symptoms and those who live with others who have symptoms 
  • Ensuring both workers and clients who feel unwell stay at home and do not attend the workplace or location where the service is being provided.
  • Workers should follow the self-isolation guidance
  • If they suspect that they might have the virus this link tells them how to  apply for a coronavirus test

2.4 Equality in the workplace – your responsibility to make sure that nobody is discriminated against  

In applying this guidance, employers should be mindful of the particular needs of different groups of workers or individuals.

It is unlawful to discriminate, directly or indirectly, against anyone because of a protected characteristic including age, sex, disability, race or ethnicity.

Employers also have particular responsibilities towards disabled workers and those who are new or expectant mothers.

The steps you should take:

  • Understand and take into account the particular circumstances of those with different protected characteristics.
  • You should involve and communicate appropriately with workers whose protected characteristics might either expose them to a different degree of risk, or might make any steps you are thinking about inappropriate or challenging for them.
  • You should consider whether you need to put in place any particular measures or adjustments to take account of your duties under the equalities legislation.
  • You should make reasonable adjustments to avoid disabled workers being put at a disadvantage, and assess the health and safety risks for new or expectant mothers.
  • Making sure that the steps you take do not have an unjustified negative impact on some groups compared to others, for example those with caring responsibilities or those with religious commitments.

2.5 Workforce management – organising shift patterns and working groups to reduce the number of contacts each worker has.

The steps you should take: 

  • As far as possible, where workers are split into teams or shift groups (particularly for businesses that have extended their hours of business), or assigned to specific tasks, you should fix these teams or shift groups so that where contact is unavoidable, this happens between the same people.
  • You should identify areas where people have to directly pass things to each other and finding ways to remove direct contact such as by using drop-off points or transfer zones.
  • Use a defined process to help maintain social distancing during shift handovers.
  • Limit role/task rotation including remaining at a consistent workstation where possible.
  • Stagger shift start times, minimising worker congregation such as at entrances and exits.
  • Create a schedule for staff detailing in advance how treatments will take place and what arrangements have been made with clients.
  • You should assist the test and trace service by keeping a temporary record of your staff shift patterns for 21 days and assist NHS Test and Trace with requests for that data if needed. This could help contain clusters or outbreaks.

2.6 Work related travel – avoid unnecessary work travel and keep people safe when they do need to travel between locations.

The steps you should take:

  • Avoid using public transport, and aiming to walk, cycle, or drive instead. If using public transport is necessary, wearing a face covering will be a mandatory requirement in Wales from the 27 July.  
  • Minimise the number of people outside of your household or Extended Household travelling together in any one vehicle, using fixed travel partners, increasing ventilation when possible and avoiding sitting face-to-face.
  • Avoid staff car sharing 
  • Putting in place procedures to minimise person-to-person contact during deliveries to other sites.
  • Minimising contact during payments and exchange of documentation, for example by using electronic payment methods and electronically signed and exchanged documents.
2.7 Communications and Training – making sure all workers   understand COVID-19 related safety procedures and are kept up to date with how safety measures are being implemented or updated.

As the employer is it your responsibility to ensure your employees read, understand and fully comply with the COVID-19 related safety procedures. 

The steps you should take:

  • Provide clear, consistent and regular communication to improve understanding and consistency of ways of working.
  • Engage with workers and worker representatives through existing communication routes to explain and agree any changes in working arrangements.
  • Develop communication and training materials for workers prior to returning to site, especially around new procedures for arrival at work.
  • Ensure staff understand how to use and clean their PPE.

Keeping them updated:

  • You should undertake ongoing engagement with workers (including through trade unions or employee representative groups) to monitor and understand any unforeseen impacts of changes to working environments.
  • You should be aware and focus on the importance of mental health at times of uncertainty.
  • Use simple, clear messaging to explain guidelines using images and clear language, with consideration of groups for which English may not be their first language and those with protected characteristics such as visual impairments.
  • Using visual communications, for example whiteboards or signage, to explain changes to appointment schedules or stock shortages without the need for face-to-face communications.
  • You will need to provide information to people on your premises about the measures needed to minimise the risk of exposure to coronavirus.  This will include to clients as well as to staff, suppliers or trade bodies to help their adoption and to share experience, such as with emails or social media.

For mobile beauty therapists, make-up artists, nail service technicians, massage therapists, holistic and wellbeing practitioner businesses

  • You should communicate with households before arrival to discuss the steps required to safely provide close contact services in the home.

Physical distancing

2.9. Physical distancing for workers – making sure employees maintain physical distancing guidelines

You should take all reasonable measures to ensure 2m distance is kept between people waiting to enter premises and when in the premises, where this is not possible you must consider other measures to minimise the risk of exposure to coronavirus.

The steps you should take:

  • You must maintain physical distancing in the workplace wherever possible.
  • When providing close contact services, the nature of the work is such that maintaining social distancing will not usually be possible when actively serving a client. In these circumstances, both employers, employees and the self-employed should do everything they reasonably can to reduce risk. Mitigating actions include:
  • Further increasing the frequency of hand washing and surface cleaning
    • Keeping the activity time involved as short as possible
    • Using screens or barriers to separate clients from one another. If the practitioner is wearing a visor, screens will not provide additional protection between the practitioner and the individual
    • Consider screens at payment desk where face-to-face interaction is more likely
    • Avoid face-to-face working whenever possible
    • Using a consistent pairing system if workers have to be in close proximity to each other
    • only opening client waiting areas and relaxation spaces where social distancing can be maintained
    • maintaining physical distancing between the service areas, such as guest seating, client chairs or treatment beds.
  • Physical distancing applies to all parts of a business, not just the room where the service is delivered, it will also include a client’s home when mobile close contact services are being provided.  Waiting rooms, corridors and staircases, where applicable are often the most challenging areas to maintain physical distancing and it is your responsibility to ensure workers are specifically reminded about the need to maintain safe distancing in these areas.

2.9.1 Maintaining physical distancing while coming to work and leaving work

You should put arrangements in place to maintain physical distancing wherever possible, on arrival and departure and to enable handwashing upon arrival.

The steps you should take:

  • Staggering arrival and departure times at work to reduce crowding into and out of the workplace, taking account of the impact on those with protected characteristics.
  • Providing additional parking or facilities such as bike-racks to help people walk, run, or cycle to work, recognising this may not be possible in smaller workplaces.
  • Reducing congestion, for example, by having more entry points to the workplace, where possible.
  • Using markings and introducing one-way flow at entry and exit points, where possible.
  • Providing handwashing facilities (or hand sanitiser where not possible) at entry and exit points.
  • Discussing with clients before arrival whether parking facilities are available for mobile businesses that provide services in the home.
  • Collaborating with other businesses who may share the premises to minimise the numbers of people on site.

2.9.2 Moving around salons, spas, premises and other people’s homes - maintaining physical distancing as far as possible while people travel through the workplace.

The steps you should take:

  • Introduce physical changes like barriers or screens between, behind or in front of workstations where possible, such as between clients and guests, for example in reception areas and relaxation spaces. 
  • Introducing one-way flow in high traffic areas.
  • Providing floor markings and signage to remind both workers and clients to maintain physical distancing wherever possible, particularly in client/guest interaction zones.
  • Making sure that people with disabilities are able to access lifts in larger workplaces or businesses based in multi-storey buildings.
  • Discussing with the client ahead of a mobile appointment in other people’s homes to ask that physical distancing and other measures to minimise risk are maintained by other people in the household.

2.9.3 Workplaces and workstations - maintaining social distancing between individuals when they are at their workstations.

For people who work in one place, workstations should allow them to maintain physical distancing wherever possible.

The steps you should take: 

  • You should assign individual workstations as much as possible. If they need to be shared, they should be shared by the smallest possible number of people and be frequently cleaned.
  • Reviewing layouts to maintain physical distancing between clients to minimise the risk of exposure to coronavirus, ensuring there is sufficient spacing between guest and client chairs and treatment beds, for example, closing off alternate chairs or treatment beds. 
  • Using floor tape or paint to mark areas to help people comply with physical distancing.
  • Avoiding overrunning or overlapping appointments and contacting clients virtually to let them know when they are ready to be seen, where possible.
  • Asking clients to arrive at the scheduled time of their appointment and only providing a waiting area if physical distancing can be maintained.  
  • In a spa setting where guests are unlikely to depart immediately after treatment, physical distancing should be observed in shared areas, including waiting areas and relaxation spaces.
  • Using screens to create a physical barrier between workstations, where this is practical. This will not be required between the practitioner and client when the practitioner is wearing a visor.
  • Using a consistent buddying system, defined as fixing which workers work together, if workers have to be in close proximity.
  • Minimising contacts around transactions, for example, considering using contactless payments including tips, where possible. If contactless payment by bank card or smart phone is not possible. Undertake regular cleaning of the machine and consider use of screens at payment desks.
  • Minimising how frequently equipment is shared between workers, frequently cleaning between uses and assigning equipment to an individual where possible.
  • Using disposable items where possible, and ensuring non-disposable items are cleaned and laundered between uses.

2.9.4 Common Areas - maintaining social distancing while using common areas.

The steps you should take:

  • Staggering break times to reduce pressure on the staff break rooms or places to eat and ensuring physical distancing is maintained in staff break rooms.
  • Using safe outside areas for breaks.
  • Creating additional space by using other parts of the working area or building that have been freed up by remote working. Installing screens to protect workers in receptions or similar areas.
  • Encouraging workers to bring their own food and drinks. Do not provide food or drink for clients only water in disposable cups or bottles and not allowing food or drink to be consumed in the salon by clients other than water in disposable cups or bottles. Different procedures might be in place within a destination spa, hospitality, leisure or day spa environment, for the procedures in spas you should refer to separate Welsh Government guidance: https://gov.wales/guidance-holiday-accommodation-businesses-reopening-coronavirus.
  • Reconfiguring seating and tables, such as in waiting areas, to optimise spacing to maintain 2 metre distancing and reduce face-to-face interactions.
  • Encouraging workers to remain on-site for their shift.
  • Considering use of physical distance marking for other common areas such as toilets, staff rooms, changing rooms and in any other areas where queues typically form.
  • Preparing materials and equipment in advance of scheduled appointments, such as products and consumables, to minimise movement to communal working areas.
  • Scheduling appointments to avoid client congestion in waiting areas, particularly in establishments with smaller waiting areas. 
  • Only the client should be present in the same room for mobile appointments in the home.
  • Removal of magazines and newspapers from the waiting areas and relaxation spaces.

2.9.5 Accidents, security and other incidents

During these incidents the priority is safety. 

Where possible, first aiders should try to assist from a safe distance, directing the casualty to do things for themselves. Where this is not possible, in an emergency scenario for example, it is unlikely to be possible to maintain 2m distance.

Individuals providing close contact first aid to others should pay particular attention to sanitation measures immediately afterwards including washing hands.

If CPR is necessary to preserve life whilst waiting for the emergency services, both the Resuscitation Council’s guidance and HSEs website currently advises compression only and the early use of defibrillation equipment.

The steps you should take:

  • Review your incident and emergency procedures to ensure they reflect the social distancing principles as far as possible.
  • Consider the security implications of any changes you intend to make to your operations and practices in response to COVID-19, as any revisions may present new or altered security risks which may need mitigations. 

Section 3: What you should do to keep your clients and visitors safe – minimising the risk of spreading COVID-19

3.1 Permitted treatments and services that can be provided safely during COVID-19.

Nail technicians, beauty therapists and holistic and wellbeing therapists

Are able to provide the following treatments and services safely under the current government guidelines for safe working in close contact services:    

  • Manicure
  • Pedicure
  • Reflexology
  • UV tanning and
  • Nail treatments and enhancement services

The following level 3 treatments and services can also be provided safely, as long as they are restricted to treatments on the body only (i.e. excluding facial treatments in the high-risk zone) these include: Body waxing, sugaring or threading services Massage treatments and therapies

  • Advanced body technical (electrical or mechanical) therapy
  • Massage and Ayurveda treatments  
  • Body scrubs, body brushes and body wraps
  • Thermal therapy treatments
  • Self-tanning
  • Sports massage/therapy 

In addition:

  • Indian Head Massage
  • Thermal auricular.
  • Earlobe piercing

Can also be provided safely providing it is on the basis that the therapist must wear a visor and the treatments can only be completed if the therapist avoids prolonged periods of activity in the high-risk zone (the area directly in front of a client’s eyes, nose and mouth) for the majority of the time that it takes to complete the close contact treatments.

Acupuncture, electrocautery, aesthetics advanced practices treatments and services practitioners

Are able to provide the following treatments and services safely on the body only under the current government guidelines for safe working in close contact services include:    

  • Lasers and IPL (laser, intense pulsed light and lighter emitting diode)
  • Micro-pigmentation
  • Skin blemish removal (electrocautery)
  • Electrical epilation
  • Acupuncture

3.2 High risk treatments on the face that cannot be provided safely during COVID-19 under the current guidelines. 

These include:

  • Face waxing, sugaring or threading services
  • Facial treatments (manual)
  • Advanced facial technical (electrical or mechanical)
  • Eyelash treatments
  • Make-up application
  • Dermarolling
  • Dermaplaning
  • Microblading
  • Electrical epilation on the face
  • Eyebrow treatments
  • Botulinum toxins and dermal fillers
  • Lasers and IPL (laser, intense pulsed light and lighter emitting diode)
  • Chemical peels
  • Microneedling
  • Semi-permanent make-up (i.e. Micro-pigmentation, Micro-blading and

Scalpology)

  • Skin blemish removal (electrocautery and electrolysis)
  • Electrical epilation
  • Acupuncture

Public health advice is clear that these are high risk activities that can bring practitioners within the high risk zone for prolonged periods of time. Public Health Wales is concerned that these treatments cannot be managed safely at this time.  Whilst these procedures are not aerosol generating, they do require work in close proximity to the mouth / nose / and respiratory secretions of the client, which in most cases, whilst the client cannot wear a mask themselves.  They recommend that businesses to not provide these treatments unless they can access correct PPE and have sufficient training in the donning and doffing of PPE and standard infection control precautions.  

As an employer, you have a legal responsibility to protect workers and others from risk to their health and safety. This means you need to think about the risks they face and do everything reasonably practicable to minimise them, recognising you cannot completely eliminate the risk of COVID-19.

You will be under a duty to take all reasonable measures to ensure 2 meters’ distance is kept between persons, to take any other measure to minimise the risk of exposure to coronavirus, for example measures which limit close face-to-face interaction and maintain hygiene and to provide information to anyone on your premises on how to minimise that risk. 

Welsh Government recommends that you consider what a safe practice is and that you only provide treatments and services that can be delivered safely.

If the above treatments in the high risk zone cannot be carried out without the ability to be provided from the side of the face or behind the head and therefore require prolonged periods in the highest risk zone then we strongly recommend that you do no offer these treatments during this review phase. 

We will continue to closely monitor the provision of close contact services in Wales, and if we feel that the requirements to take all reasonable measures to minimise risk of exposure to coronavirus are not being complied with, in accordance with the measures set out in Regulation 12b of the Welsh Government Coronavirus Regulations introduced in March 2020 we may introduce legislation to prohibit these high risk treatments unless specific conditions can be met.   

It should also be noted that in door gyms and swimming pools are not yet being permitted to reopen in Wales.  In Leisure and destination spas this restriction is also extended to:

  • Hydrotherapy pools.
  • Spa pools
  • Saunas and Steam rooms.

3.3 Booking appointments – measures that will keep people safe and allow us to track the virus. 

Close contact service businesses being permitted to reopen in Wales should endeavour to do so on an appointment only basis. No walk-ins.  The opening up of the economy following the COVID-19 outbreak is being supported by NHS Test and Trace. Acknowledging that you will owe duties under GDPR, you should try to assist this service by keeping a temporary record of your clients and visitors for 21 days, in a way that is manageable for your business, and assist NHS Test and Trace with requests for that data if needed. This could help contain clusters or outbreaks. Many nail, beauty and holistic and wellbeing businesses that are taking bookings in preparation for their reopening already have systems for recording their clients and visitors. If you do not already do this, you should do so to help fight the virus. We will work with industry and relevant bodies to design this system in line with GDPR legislation, and set out details shortly. 

All premises should ensure that steps are taken to avoid people needing to unduly raise their voices to each other. This includes, but is not limited to, refraining from playing music or broadcasts that may encourage shouting, including if played at a volume that makes normal conversation difficult. This is because of the potential for increased risk of transmission, particularly from airborne

The steps you should take:

Before bookings take place

  • You should operate a pre-booking only – walk-in appointments should not be permitted.
  • You should calculate the maximum number of clients that can reasonably follow physical distancing guidelines and seek to limit the number of appointments at any one time accordingly.  Take into account total floorspace as well as likely pinch points and busy areas. 
  • Allow at least 2m between workstations. This may mean removing chairs or treatment beds or guest chairs from the salon floor and relaxation areas or taping them off and using ‘not in use’ signs. Whilst an appointment system should minimise this risk, any calculations in regard to physical distancing you should consider any waiting areas which may need to be utilised. 
  • Determine if schedules for essential services and contractor visits can be revised to reduce interaction and overlap between people.
  • If you determine that you will not be able to provide high risk treatments safely, before you take the booking, you should advise the client that you will be unable to take all reasonable measures to minimise risk of exposure to coronavirus in order to keep both the client and practitioner safe.  
  • Before you take the booking you should ask the client COVID-19 related screening questions before you can confirm the booking.
  • You should Inform the client that you will be contacting them 48 hours before the date of their appointment to ask the following COVID-19 related screening questions before you can confirm the booking:
  • Have you tested positive for coronavirus?
  • Are you waiting for the result of a test for coronavirus?

or

  • Have you had the recent onset of a new continuous cough (this means coughing a lot for more than an hour, or three or more coughing episodes in 24 hours  - if they usually have a cough, is it worse than usual)?
  • Do you have a high temperature (this means do they feel hot to touch on their chest or back – they do not need to measure their temperature)?
  • Have you noticed a loss of, or change in, your normal sense of taste or smell (this means they have noticed they cannot smell or taste anything, or things smell or taste different to normal)? 
  • If you are a mobile business also check if anyone in the house is self-isolating or shielding.

Most people with coronavirus have at least one of these symptoms. If the client has any of these symptoms, however mild, they should stay at home and reschedule their appointment.  

You might refer them to the Check and report coronavirus symptoms.

  • You should also tell them that they must comply with your COVID-19 health and safety measures during their appointment. Informing clients and contractors of guidance about visiting the premises prior to and at the point of arrival, including information on websites, on booking forms and in entrance ways.
  • When booking an appointment, you should ask the client if they can attend on their own, where possible.  
  • If clients are accompanied by children they should be responsible for supervising them at all times and should follow social distancing guidelines. If at all possible persons attending for appointments should not attend with any other person(s) to avoid compromising social distancing requirements.

On the day of the appointment

  • On the day of the appointment you should ask the client the same set of COVID screening questions set out above. You should also ask them to provide their contact details. 
  • The Welsh Government has published guidance on employers' responsibilities to help with COVID-19 testing and contact tracing. Contact tracing is an important part of Test Trace Protect strategy which will help us live and work alongside the virus while research continues to find more effective treatments and a vaccine.
  • If clients refuse to provide the information you should consider whether you wish to proceed with the appointment.
  • If they answer yes to any of the questions you should not proceed with the appointment and suggest that the client self-isolates. 
  • You should encourage clients to use hand sanitiser or handwashing facilities as they enter the premises or before the treatments and services.
  • Adjusting how people move through the premises to reduce congestion and contact between clients, for example, queue management or one-way flow. This may only be possible in larger establishments
  • Ensuring any changes to entrances, exits and queue management take into account reasonable adjustments for those who need them, including disabled clients. For example, maintaining pedestrian and parking access for disabled clients.
  • Queues should be avoided by the operation of a strict appointment only system, with the avoidance of the need for clients to wait in queues. Clients should be advised to arrive promptly for appointments to minimise delays later in the day but not too early so as to not overlap with other clients.
  • Day spa guests should be asked to arrive promptly and occupancy levels should be carefully managed.
  • Queues which do form outside should be managed to ensure they do not cause risk to individuals or other businesses, for example by introducing queuing systems, using barriers and having staff direct clients.
  • Minimising contact between different workers whilst serving a client.
  • Reviewing working practices to minimise the duration of contact with the client.
  • Maintaining physical distancing in waiting areas when clients wait for their appointments. When waiting areas can no longer maintain physical distancing, consider moving to a ‘one-in-one-out’ policy.
  • Working with neighbouring businesses and local authorities to provide additional parking or facilities such as bike-racks, where possible, to help clients avoid using public transport.

3.4 Client toilets – ensure and promote good hygiene, physical distancing, and cleanliness in toilet facilities.

Public toilets, portable toilets and toilets inside premises should be kept open and carefully managed to reduce the risk of transmission of COVID-19.

The steps you should take:

  • Using signs and posters to build awareness of good handwashing technique, the need to increase handwashing frequency and to avoid touching your face, and to cough or sneeze into a tissue which is binned safely, or into your arm if a tissue is not available. 
  • To enable good hand hygiene consider making hand sanitiser available on entry to toilets where safe and practical, and ensure suitable handwashing facilities including running water and liquid soap and suitable options for drying (paper towels if possible) or hand dryers are available. 
  • Signage should be provided on the requirement to maintain a 2m distance from other clients and therapists when not receiving a close contact service.  
  • Adopt measures to limit the number of users at any one time. Consider the use of clear physical distancing marking for queues, and the adoption of a limited entry approach, with one in, one out (whilst avoiding the creation of additional bottlenecks).
  • Keep the facilities well ventilated, where possible doors to toilet blocks may be wedged open to maximise fresh air, to allow users to assess numbers inside, and to limit hand contact.
  • Setting clear use and cleaning guidance for toilets, with increased frequency of cleaning in line with usage. Use normal cleaning products, paying attention to frequently hand touched surfaces, and consider use of disposable cloths or paper roll to clean all hard surfaces.
  • Special care should be taken for cleaning of portable toilets and larger toilet facilities.
  • Putting up a visible cleaning schedule can keep it up to date and visible. Providing more waste facilities and more frequent rubbish collection. Read public health guidance on cleaning and disinfection in non-healthcare settings.

For further advice see Welsh Government guidance: Providing Safer toilets for public use: Coronavirus which provides guidance on the safe management of toilets used by the public during the coronavirus pandemic including for commercial or business premises where toilet access is provided to the public.

3.5 Providing and explaining available guidance – making sure people understand what they need to do to maintain safety.

The steps you should take:  

  • Providing clear guidance on expected client/guest behaviours, social distancing and hygiene to people before arrival, when scheduling their appointment, and on arrival, for example, with signage and visual aids.  Explaining to guests and clients that failure to observe safety measures may result in services not being provided.  Promotion of this message could be done via your web pages or other social media channels.
  • Providing written or spoken communication of the latest guidelines to both workers and clients/guests inside and outside the premises.
  • Displaying posters or information setting out how clients should behave on your premises to keep everyone safe. Consider the particular needs of those with protected characteristics, such as those who are hearing or visually impaired.
  • Providing a safety briefing of on-site protocols, rules for shared areas and key facilities, for example, handwashing, in particular for freelance workers who may work at multiple locations. 
  • Ensuring latest guidelines are visible throughout the entire premises. Informing clients that they should be prepared to remove face coverings if asked to do so by police officers and staff for the purpose of identification.

3.6 Receiving and dispatching goods and products – maintaining physical distancing and avoid spreading the virus on surfaces when goods enter and leave the premises.

Steps you should take:

  • Minimise unnecessary contact for deliveries. For example, non-contact deliveries where the nature of the product allows for use of electronic pre-booking.
  • Consider ways to reduce frequency of deliveries, for example by ordering larger quantities less often.
  • Where possible and safe, having single workers load or unload vehicles or meet delivery people at the front door.
  • Scheduling deliveries for outside of client appointment times.
  • Re-stocking/replenishing outside of workplace operating hours.

Cleaning

Section 4: What you should do to keep your business premises, spas and workplaces free of COVID-19  

4.1 Cleaning the workplace – making sure that any site or location that has been closed or partially operated is clean and ready to restart  

Steps you should take:

  • Checking whether you need to service or adjust ventilation systems, for example, so that they do not automatically reduce ventilation levels due to lower than normal occupancy levels.
  • Most air conditioning systems do not need adjustment, however where systems serve multiple buildings, or you are unsure, advice should be sought from your heating ventilation and air conditioning (HVAC) engineers or advisers.

4.2 Keeping the workplace clean – preventing spreading the virus by touching and contaminating surfaces

The steps you should take:

  • Spacing appointments to allow for frequent cleaning of work areas and equipment between uses, using your usual cleaning products.
  • Frequent cleaning of objects and surfaces that are touched regularly, including door handles or staff handheld devices, and making sure there are adequate disposal arrangements for cleaning products.
  • Clearing workspaces and removing waste and belongings from the work area at the end of a shift.
  • Remove items that clients usually handle including not providing reading materials such as magazines in client waiting areas and relaxation spaces.
  • Sanitising any reusable equipment, including client chairs, treatment beds, and guest seating, including relaxation spaces and equipment used after each appointment, and at the start and end of shifts.
  • In salons and clinics using disposable gowns for each client. Where this is not possible, use separate gowns (and towels in the normal way) for each client, washing between uses and disposing appropriately as required.
  • Encouraging staff not to wear their uniforms at home or to and from the workplace, to change uniforms on a daily basis and to wash immediately after use.
  • Maintaining good ventilation in the work environment, for example keeping windows or doors open.
  • Cleaning high touch objects and surfaces such as door handles

4.3 Hygiene (handwashing, sanitation facilities) – help everyone keep good hygiene through the working day

Steps you should take:

  • Using signs and posters to build awareness of good handwashing technique, the need to increase handwashing frequency and avoiding touching your face.
  • Adopting good handwashing technique and increasing handwashing in between appointments. For mobile operators, in the absence of handwashing facilities, you must use hand sanitiser.
  • Providing clients access to tissues and advising that if they do need to sneeze or cough, they could do so into the tissue and then discard them in the bins provided and suggest that they wash their hands thoroughly or use hand sanitiser after using a tissue.
  • Providing regular reminders and signage to maintain hygiene standards.
  • Providing hand sanitiser in multiple locations in premises in addition to washrooms.
  • Setting clear use and cleaning guidance for toilets to ensure they are kept clean and social distancing is achieved as much as possible.
  • Enhancing cleaning for busy areas.
  • Providing more waste facilities and more frequent rubbish collection.
  • Providing hand drying facilities – either paper towels (preferably paper towels) or electrical dryers.

4.4 Changing rooms and showers – minimising the risk of spreading the virus in changing rooms and showers.

It is advised that changing rooms and showers should only be provided for staff, guests and clients if absolutely necessary at this time. 

Steps you should take:

  • Where shower and changing facilities are required, setting clear use and cleaning guidance for showers, lockers and changing rooms to ensure they are kept clean and clear of personal items and that physical distancing is achieved as much as possible.
  • Introducing enhanced cleaning of all facilities regularly during the day and at the end of the day.

4.5 Handling products, goods and other materials – reducing the spread of the virus through contact with objects in the premises.

The steps you should take:

  • Encouraging increased handwashing and introducing more handwashing facilities for workers and clients or providing hand sanitiser where this is not practical.
  • Implementing enhanced handling procedures of laundry to prevent potential contamination of surrounding surfaces, to prevent raising dust or dispersing the virus.
  • Putting in place picking-up and dropping-off collection points where possible, rather than passing goods hand-to-hand.
  • Enforcing cleaning procedures for goods and products entering the site.
  • Regularly cleaning equipment that employees may bring from or take home. Cleaning should also take place before and following client use.
  • Minimising person-to-person contact when accepting deliveries by creating pick-up and drop-off collection points for deliveries entering the premises.
  • Ensuring that equipment entering a person’s home is thoroughly cleaned before use and between clients, with usual cleaning products.
  • Minimising client contact with testers, for example, employees demonstrating testers from a distance or facilitating the use of testers.

Section 5. The use of Personal Protective Equipment (PPE) and Face Coverings  

PPE protects the user against health or safety risks at work. It can include face masks, visors, disposable gloves, gowns and aprons. 

In Section 4 of this document we described the steps you need to take to manage COVID-19 risk in the workplace.  When managing the risks of COVID-19, additional PPE beyond what you usually wear will not be beneficial in the majority of workplaces. This is because COVID-19 is a different type of risk to the risks you normally face in a workplace, and needs to be managed through social distancing, hygiene and fixed teams or partnering. Physical distancing and hygiene measures are by far the most effective ways to protect yourself and others from COVID-19 however for people who are providing close contact services (such as beauty therapists and  holistic and wellbeing therapists, acupuncture, electrocautery, aesthetics and beauty advanced practices treatments and services technicians because of the period of time spent in close proximity to a person’s face, mouth and nose) they should wear further protection in addition to any that they might usually wear.

In workplaces such as nail, beauty and holistic and wellbeing salons, specialist or aesthetics salons or clinics and within a destination spa, within a hospitality, leisure or day spa environment it is likely to be difficult to maintain social distancing, as employees need to work in close proximity to their clients, usually for an extended period of time.

An extended period of time refers to the majority of the working day, irrespective of the number of clients completed during the day.

The practitioner/technician providing a service, for example a nail technician who spends time in close proximity to a client’s front, and therefore the person’s face, mouth and nose, should wear further protection in addition to any that they might usually wear.

This should take the form of a clear visor that covers the face and provides a barrier between the wearer and the client from respiratory droplets caused by sneezing, coughing or speaking. Visors must fit the user and be worn properly. It should cover the forehead, extend below the chin, and wrap around the side of the face.

Both disposable and re-usable visors are available. A re-usable visor should be cleaned and sanitised regularly using normal cleaning products. There is no requirement for the client to wear any additional protection such as a mask or face covering, when the practitioner is wearing a visor. There is no benefit to either the client or the practitioner of wearing additional PPE to that which they would usually use, beyond the clear visor mentioned above.

It should be noted that the wearing

The most effective methods of preventing the transmission of COVID-19 are still physical distancing and regular handwashing. These steps must still be followed as much as possible, even when practitioners are wearing protective equipment.

In instances where you are contacted via the test and trace service, having been in contact with someone who has tested positive for COVID-19, you will still need to self-isolate even if you are wearing a visor at work. This is because the risk of transmission cannot be ruled out, even if wearing a visor reduces that risk.

5.1 Face coverings

At the present time, the widespread use of masks by healthy people in the community is not supported by scientific evidence. Physical distancing and hygiene measures remain the most effective measures for reducing transmission of COVID-19.

There may be some circumstances when wearing a face covering may be marginally beneficial as a precautionary measure. However, face coverings are not an alternative to wearing a visor in close contact services.

When clients are not having a service, both the practitioner and client should maintain physical distancing and so a face covering will not be required. Clients and employees should follow existing guidance on face coverings when they are not in close proximity, as explained below.

In Wales wearing a face covering is optional and is not required by law, including in the workplace. However, Welsh Government supports the right of the owners of nail, beauty and holistic and wellbeing salons, specialist or aesthetics salons or clinics and destination, hospitality, leisure or day spa businesses to decide whether they wish to ask their clients/guests to wear face coverings whilst on their premises. 

The evidence is clear that the most effective way to protect yourself and others from the infection is to follow safe-distancing rules, avoid touching surfaces and your face and to wash your hands regularly. Evidence suggests that wearing a face covering does not protect you, but it may protect others if you are infected but have not developed symptoms. However, clients and workers who want to wear a face covering should be allowed to do so. If you choose to wear one, it is important to use face coverings properly and wash your hands before putting them on and before and after taking them off.

A face covering can be very simple and may be worn in enclosed spaces where physical distancing isn’t possible. It just needs to cover your mouth and nose. It is not the same as a face mask, such as the surgical masks or respirators used by health and care workers.

Similarly, face coverings are not the same as the PPE used to manage risks like dust and spray in an industrial context. Supplies of PPE, including face masks, must continue to be reserved for those who need them to protect against risks in their workplace, such as health and care workers, or for protecting against dust hazards in industrial settings.

It is important to know that the evidence of the benefit of using a face covering to protect others is weak and the effect is likely to be small, therefore face coverings are not a replacement for the other ways of managing risk, including minimising time spent in contact, using fixed teams and partnering for close-up work, and increasing hand and surface washing. These other measures remain the best ways of managing risk in the workplace and government would therefore not expect to see employers relying on face coverings as risk management for the purpose of their health and safety assessments.

Employers should support their workers in using face coverings safely if they choose to wear one. We are advising the use of three-layer, non-medical face coverings. Welsh Government has produced guidance on how to make three-layer face coverings.

This is in line with the World Health Organisation’s latest technical advice.

This means telling workers: 

  • Wash your hands thoroughly with soap and water for 20 seconds or use hand sanitiser before putting a face covering on, and before and after removing it.
  • When wearing a face covering, avoid touching your face or face covering, as you could contaminate them with germs from your hands.
  • Change your face covering if it becomes damp or if you’ve touched it.
  • Continue to wash your hands regularly.
  • Change and wash your face covering daily.
  • If the material is washable, wash in line with manufacturer’s instructions. If it’s not washable, dispose of it carefully in your usual waste.

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