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Introduction

The Health Protection (Coronavirus Restrictions) (No. 5) (Wales) Regulations 2020 ("the Regulations") impose restrictions on individuals and businesses. This has been done to control the spread of coronavirus in Wales and to help protect the public from the spread of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2).

Death of a family member or friend is a very distressing event which is why the Regulations recognise the need to attend funerals in certain circumstances. Funeral services should continue, and funeral providers should consider how they can facilitate this.

Funerals with physical attendance of mourners should continue as long as those attending adhere to the Regulations. Those responsible for regulated premises and for work carried out, including in those premises (as defined in regulation 15 of, and Schedule 7 to the Regulations) are under duties to carry out a coronavirus risk assessment and take reasonable measures for the purpose of minimising the risk of exposure to, and spread of, coronavirus. This guidance is intended to assist people in ensuring they meet those requirements and act in a manner which helps ensure their safety, by setting out how the risk of transmission can be reduced.

Those invited to attend a funeral may have COVID-19 (the Regulations allow people to leave their home if they are self-isolating to attend a funeral of a family member or close friend on compassionate grounds) or are at increased risk should they contract the virus and/or clinically extremely vulnerable. It is a legal requirement for those responsible for premises to take all reasonable measures to ensure that people on the premises maintain physical distancing indoors and anyone on the premises should be aware of the risks of attending a funeral should someone with COVID-19 be present, and of the importance of keeping their distance indoors and taking any additional safeguarding measures put in place by the venue.  

However, although members of the public may attend a funeral, they should be respectful of the fact that there are restrictions that have been imposed as a result of a public health emergency. People should only attend the funeral of their family members and close friends if they need to for compassionate reasons. In order to be able to attend a funeral, they must be invited by the person responsible for arranging the funeral.  

It is advised that the Welsh Government web page on the current Alert Level in place is checked regularly for the latest advice on restrictions in place.

Legal requirements

The Regulations make provisions that apply both to those responsible for a crematorium, place of worship or cemetery at which a funeral or burial is held, and to those working at such premises, including funeral directors.

Places of worship, cemeteries and crematoria, funeral directors, and hospitality businesses which may be used to hold ‘wakes’ all fall within the definition of regulated premises, which are permitted to be open depending on the Alert Level, and associate restrictions in application at the time. Currently, the number who attend depends on the occasion (see below).

The Regulations require those responsible for those premises to undertake a risk assessment and take reasonable measures for the purpose of minimising the risk of exposure to, and spread of, coronavirus. 

Part 2 of the Regulations impose restrictions on people gathering. The specific restrictions, requirements and business closures are set out in separate Schedules for each Alert Level. The Regulations applicable at any time can be found on GOV.WALES.

The guidance related to each Alert Level and any intermediate restrictions can be seen on GOV.WALES.

The restrictions within the four Alert Levels are subject to having a reasonable excuse for gathering. Under Alert Levels 1 to 3, attending a funeral and/or a gathering to celebrate the life of a deceased person are both examples of such reasonable excuses, as is attending a regulated gathering, which could include a wake organised as an event by a business, such as a hotel. In Alert Level 4 it is not permitted to attend gatherings to celebrate the life of a deceased person.

In order to attend a funeral as a mourner you/a person must either be arranging it, have been invited to it, or be the carer of someone attending it. 

The number of people who may attend a funeral is determined by how many people the venue can safely accommodate whilst complying with the indoor physical distancing requirements, following a risk assessment by the person responsible for the venue. Venue owners/managers should plan for allowing 2 metres distance between people in all directions in order to calculate maximum capacity, with allowance for members of the same household or permitted group of up to six people to sit together.            

For celebrations of a deceased person’s life (a wake), the maximum number of people who may attend is dependent upon the Alert Level, and the venue where it will be held.

As of 18 June people are permitted to celebrate a deceased person’s life or hold a wake either indoors or outdoors in the following ways:

Wakes that are organised by a body, including a business or a club.

This means that the reception or wake is organised by a specified type of body, including a business rather than simply being held on business premises (for which see below). The organising body/business must undertake a risk assessment and in light of that take all reasonable measures to minimise the risk of exposure to and spread of coronavirus. The numbers permitted to attend indoors or outdoors will be determined by the risk assessment having regard to the size of the venue and the reasonable measures, which includes maintaining physical distancing indoors.

Wakes that are not organised by a business (etc.)

These may be organised by individuals (e.g. the friends, the family):

  1. on regulated premises, such as hospitality premises; or
  2. on private land, such as the garden of a private dwelling.

Wakes not organised by a business but held on regulated premises

The person responsible (referred to in the Regulations as the “responsible person”) for the regulated premises must undertake a risk assessment in respect of the premises and activities that take place on it and in light of that take all reasonable measures to minimise the risk of exposure to and spread of coronavirus. The numbers permitted to attend indoors will be determined by the risk assessment having regard to the size of the venue and the reasonable measures, which includes maintaining physical distancing indoors. Risk assessments for wakes held outdoors need to consider the reasonable measures required to minimise risk of exposure to and spread of coronavirus.

Wakes not organised by a business but held on private land

If held at a private dwelling:

  1. indoors: any six people (not including children under 11 or a carer of anyone attending) or members of the household or extended household can gather
  2. outdoors: there are no limits on the number of people who may attend

This guidance offers advice on the practical implementation of these legal requirements for the current Alert Levels. A simplified version aimed at members of the public can be found in the Annex.

Taking all reasonable measures to minimise risk of exposure to coronavirus at funerals

A key aspect of the Welsh Government’s response to the public health emergency is to place restrictions on people gathering. Attending a funeral or an associated social gathering, is an exception to the restrictions on gatherings in public places.

The number of people able to attend a funeral is limited by the capacity of the venue whilst ensuring the indoor physical distancing requirements are applied. Unfortunately this necessitates changes to traditional customs and practices at funerals in so far as this involves interaction between people from different households. The requirement for physical distancing indoors between individuals, households or permitted groups of up to 6 people remains in place. There is no requirement for physical distancing to be maintained outdoors, unless the risk assessment identifies it as a reasonable measure to be taken. If this is the case, the premises/operator’s requirement for physical distancing outdoors must be clearly communicated to staff and members of the public.

Regulation 16 of the Regulations imposes obligation on people responsible for premises open to the public or where work takes place to minimise the risk of exposure to coronavirus on the premises, and to minimise the risk of spread of coronavirus by those who have been on the premises.

Regulation 16 requires the person responsible for indoor “regulated premises” to take the following steps:

  • Step 1: undertake an assessment of the risk of exposure to coronavirus at the premises.
  • Step 2: provide information to those entering or working at the premises about how to minimise the risk of exposure to coronavirus. 
  • Step 3: take all reasonable measures to ensure that a distance of 2 metres is maintained between persons on the premises, except between the members of a group, comprising of no more than 6 persons or members of the same household at Alert Level 1 and 2, or at Alert Levels 3 and 4, comprising of members of the same household. 
  • Step 4: take reasonable measures to mitigate the risk of exposure to coronavirus that arises where persons gather in close proximity to each other. The measures may include seeking to prevent persons experiencing symptoms of COVID-19 from entering the premises, ensuring that people gather outdoors instead of indoors where it is practicable to do so, limiting close face-to-face interaction, seeking to ensure that the premises are well ventilated, and maintaining good hygiene. They may also include measures such as not carrying on certain activities and collecting contact information from persons at the premises.

However, measures taken under Step 4 that mitigate the risk that occurs where people from different households are within 2 metres of each other may be taken into account when considering what reasonable measures to take under Step 3. There may be limited circumstances when 2 metre physical distancing is not always reasonable where other mitigating measures may be sufficient to mitigate the risks without distancing at 2 metres. Where this is the case, a person responsible for premises would be expected to take additional and strengthened measures under Step 4, alongside maintaining as much physical distancing as reasonable.

Those responsible for outdoor “regulated premises” are similarly required to take a risk assessment and provide information in accordance with Steps 1 and 2, they are also required to take reasonable measures under Step 4.  That may include taking measures to limit physical interaction.

Further details to assist the understanding what “taking all reasonable measures” means and what measures should be taken to minimise the risk of exposure can be found on GOV.WALES. The obligation applies to each of the “alert levels” that can be set under the Regulations, however, in practice the nature of the obligation is likely to change depending on which alert level applies.

In most circumstances, in particular whilst indoors,  people are expected to practice physical distancing measures. This means maintaining a distance of 2 metres wherever practical. This does not include between members of the same household, or a carer and the person assisted by the carer, nor to individual groups of any six people (not counting anyone under the age of 11 or a carer of any member of the group). Separate guidance makes it clear that it is not expected that children under 11 maintain physical distancing. However, as young children can still transmit the virus, parents/carers of young children should still exercise their good judgement and take care especially to encourage their children to follow hand hygiene measures and keep close contact to a minimum wherever possible.

In order to safeguard all those in attendance, Funeral Directors and those responsible for premises should assume that there may be clinically vulnerable people, and people with COVID-19 present at all Funeral Services.

Welsh Government workplace guidance for employers and employees provides advice on taking reasonable measures to minimise the risk of exposure to coronavirus in workplaces and premises open to the public, which includes:

  • keeping records of staff, attendees and visitors for test, trace, protect purposes
  • the requirement to wear face coverings in indoor public places
  • reasonable measures to maintain a 2 metre distancing on premises or while anyone is working
  • reducing close face to face interaction
  • enhancing hand and respiratory hygiene
  • There is no requirement for physical distancing to be maintained outdoors, unless the risk assessment identifies it as a reasonable measure to be taken. If this is the case, the premises/operator’s requirement for physical distancing outdoors must be clearly communicated to staff and members of the public

Where close interaction between people is unavoidable or inevitable, and physical distancing cannot be maintained, it is particularly important to focus on other mitigations which should be employed to minimise face to face interaction.

In addition, other reasonable measures to minimise the risk of exposure to coronavirus should be provided, such as controlling the entry to the venue, and displaying signs or other visual aids like floor markings.

Efforts should be made to ascertain if those invited to attend a funeral have tested positive for the virus and will be leaving self-isolation to attend the funeral on compassionate grounds, or if they are at increased risk or clinically extremely vulnerable, to allow for any adjustments to the risk assessment to be made.

Guidance for faith and belief practices that involve close contact with the care of the deceased

Those handling the deceased should be aware that there is likely to be a continuing risk of infection from body fluids and tissues in cases where coronavirus infection has been identified or is suspected.

Given the increased risk of severe illness for clinically extremely vulnerable people from COVID-19, it is strongly advised that they have no contact at all with the deceased and do not participate in any activities such as washing, preparing or dressing the deceased.

Mourners are advised not to take part in rituals or practices that bring them into close contact with the deceased. Where there are aspects of faith which include close contact that contact should be restricted to those who are wearing Personal Protective Equipment (PPE) under the supervision of someone who is trained in appropriate use of PPE. The UK Government has issued guidance on care of the deceased which is of relevance in the context of dealing with deceased individuals.

Given the very significant risk for people at increased risk and clinically extremely vulnerable people who come into contact with coronavirus, it is strongly advised that they have no contact with the body of the deceased. This includes washing, preparing or dressing the body.

The maximum number who can attend a funeral

The most obvious means of taking all reasonable measures to maintain a 2 metre distance between persons present at a funeral (be that a cremation or burial), is to limit the number who may attend. This number will depend on whether the funeral involves a burial in a cemetery (including the interment of ashes), a cremation in a crematorium or a service in a place of worship.

The appropriate limit for crematoriums or places of worship will depend on the size and layout of the building. The legal requirement is that all reasonable measures are taken to ensure a distance of 2 metres is kept indoors between those attending, other than people from within the same household (not including children under 11), or permitted groups of up to any six people.  In practice, however, it may not always  be practicable to assess in advance how many people from the same households will be sitting together at any particular funeral, however these relaxations should be considered in assessing capacity in order to ensure that people can attend funerals wherever possible.

In considering the capacity, those responsible for the venue should consider that there will be occasions when members of the same household will want to sit together, and other times when groups of up to 6 people may also wish to do the same. Therefore, those responsible for premises should be in a position to accommodate these different needs, whilst also ensuring that those not in permitted groups are able to be physically distanced from others.

Different considerations apply to practising physical distancing in a cemetery, or burial ground or garden of remembrance in a crematorium. There is no requirement for physical distancing to be maintained outdoors, unless the risk assessment identifies it as a reasonable measure to be taken. If this is the case, the premises/operator’s requirement for physical distancing outdoors must be clearly communicated to staff and members of the public. It should also be taken into account that individuals may wish to continue to physically distance themselves from others outdoors.

Grounds surrounding a crematorium are also not required to close, this includes any burial grounds or gardens of remembrance which should remain open to visitors.

Requirement for those attending to be invited

The Regulations at each Alert Level provide that attendance at a funeral as a mourner is limited to those responsible for arranging the funeral, those specifically invited by the organiser of the funeral, and the carer of anyone attending. Those who are officiating/working at the venue are not included in the number of attendees.

When organising a funeral, the person responsible must expressly invite those they wish to attend, and whilst this does not require any formality such as sending an invitation in writing, maintaining a list of those invited for NHS Wales Test, Trace, Protect purposes is strongly advised.

Notwithstanding that people without invitations are not permitted to attend funerals, uninvited mourners affect the ability to maintain physical distance effectively as they reduce the capacity of a room, and thereby not only present a risk to the family and friends of the deceased person whose funeral it is but also increases the level of risk, and anxiety, for those officiating the service, and the wider public. Also uninvited mourners may unknowingly be COVID-19 positive, and may not be contactable via Test, Trace, Protect. 

In view of the risk of people attending funerals uninvited, those organising should limit information concerning the time and location of the funeral and to clearly state that attendance at the funeral is by invitation only

Outdoor funerals are subject to the same restrictions, with the number of attendees is based on the risk assessment of the owner of the venue, and the ability of mourners to socially distance in a safe manner, if this is identified in the risk assessment as a reasonable measure to be taken.

Requirement for those attending to wear face coverings

Those attending a funeral are required to wear face coverings indoors throughout the duration of the ceremony with the exemption of individuals with a reasonable excuse, such as:

  • they are not able to put on or wear a face covering because of a physical or mental illness, or because of a disability or impairment
  • they are accompanying or otherwise assisting somebody who relies on lip reading where they need to communicate

Travelling to and from a funeral

Those attending from the same household or permitted group of up to 6 people (excluding children under the age of 11 of, or carers for any of the permitted group) should seek to travel together and should avoid travel with others from different households. Where a vehicle is used to provide a service of carriage for passengers, all reasonable measures must be taken to minimise the risk of exposure to coronavirus. Read the guidance for the public on travelling safely

You should travel to the venue in a car by yourself or with people from your household or permitted group of up to 6 people (excluding children under the age of 11 of, or carers for any of the permitted group), especially if you are at increased risk or clinically extremely vulnerable. If this is not possible, you are advised to:

  • share your transport with the same people each time
  • open windows for ventilation
  • travel side by side or behind other people, rather than facing them, where seating arrangements allow
  • face away from each other
  • consider seating arrangements to maximise distance between people in the vehicle
  • ensure the car is cleaned between journeys using standard cleaning products, particularly door handles and other areas that people may touch
  • wear a face covering. You are required by law to wear a face covering on public transport, in taxis and private hire vehicles unless you are exempt for health, disability or other reasons. Passengers who are not exempt are legally required to wear a face covering when travelling in a funeral director’s vehicle or hearse. A face covering is also strongly recommended for drivers.

People resident in other UK nations

Travel into Wales from other parts of the UK and wider Common Travel Area is permitted. However, you will need to ensure that you follow the rules regarding travel where you live as these may prevent or place restrictions on your travel arrangements. On arrival in Wales, you will need to comply with Welsh law, including restrictions on gatherings which prevent people from staying overnight in other households except for extended households.

The Regulations provide that you have a reasonable excuse to attend a funeral in Wales if you are the person responsible for arranging it, if you have been invited to attend by the person arranging it or if you are the carer of a person attending. People in these categories travelling into Wales must abide by any restrictions applying in Wales at the time of the funeral. People travelling out of Wales to any of the other UK countries to attend a funeral must abide by any restrictions in place in those countries. Funeral directors will be able to advise on what rules will apply to mourners who live outside the area of the funeral.

The UK Government has in place guidance for areas where there are higher rates of coronavirus circulating which advises people to minimise travel in and out, and for regular testing of people in those areas. Separate rules apply in Scotland and Northern Ireland, where travel may be restricted to or from different places.

International travel restrictions affecting mourners

Mourners arriving in Wales from abroad, who have travelled from countries that are not exempt from the requirement to self-isolate are required to self-isolate from the day they were last in a non-exempt country. However, the Health Protection (Coronavirus, International Travel) (Wales) Regulations 2020 provides an exception from the requirement to self-isolate, in limited circumstances, in order to attend the funeral of a family member or close friend.

The mourner can only leave their place of self-isolation when attending the funeral, and is otherwise expected to self-isolate for the remainder of the isolation period unless another exemption applies. Please note that the list of exempt countries is updated regularly and people travelling must check the self-isolation requirements for the day they arrive and act accordingly.

Restrictions and Regulations for mourners seeking to attend a funeral

People who are symptomatic

Anyone who has symptoms of COVID-19 (a new continuous cough, a high temperature or a loss of, or change in, normal sense of taste or smell), or lives with someone who has symptoms, or someone in their permitted group of 6 has symptoms should avoid attending a funeral wherever possible. The law makes specific allowances for those who are required to self-isolate enabling them to attend funerals of family members or close friends for compassionate reasons.

You should immediately self-isolate, follow the latest guidance, and request a test online, or by contacting NHS 119 via telephone if you do not have internet access.

People who are required to self-isolate

If you have been instructed by Wales NHS Test, Trace, Protect to self-isolate because you have tested positive for COVID-19, or you are the close contact of someone who has tested positive for COVID-19, you should generally not attend a funeral (although please see below in relation to funerals of family members or close friends where attendance is for compassionate reasons).

It is an offence for a person who is required to self-isolate to attend a funeral unless it is to attend the funeral of a family member or close friend.

If you are legally required to self-isolate you may only leave self-isolation for a number of reasons. These include for compassionate reasons, which include attending the funeral of a family member or close friend. You must otherwise continue to self-isolate. People with a legal duty to self-isolate are:

  • anyone who is notified by Test, Trace, Protect (TTP) that they have tested positive for COVID-19. They must self-isolate as instructed by TTP
  • anyone who is notified by TTP that another member of their household or extended household or permitted group of 6  has tested positive. They must self-isolate as instructed by TTP
  • anyone who is instructed by TTP to self-isolate because of close recent contact with a person outside their household or extended household or permitted group of 6 who has tested positive for COVID-19. They must self-isolate for the period instructed by TTP

If you have COVID-19 and you are a family member or close friend of the deceased, we strongly recommend that you attend remotely if possible, to reduce the risk of COVID-19 spreading to other mourners. However, if after careful consideration of the considerable risks you present to others, you choose to attend in person, it is strongly advised that you discuss this with the person arranging the funeral, and take the following precautions:

  • sit apart from others, and maintain a social distance of at least 2 metres between yourself and others at all times. Other mourners need to be aware of this prior to attending
  • practise strict hand and respiratory hygiene by:
    • wearing a properly fitted face mask, to minimise any risk of viral transmission from yourself to other
    • washing your hands more often than usual with soap and water for at least 20 seconds, or using a hand sanitiser
    • avoiding touching your eyes, nose and mouth, and
    • covering your coughs or sneezes

Those responsible for places of worship, crematoriums and funeral directors’ premises must take all reasonable measures for the purposes of minimising the risk of exposure to coronavirus at those premises, or the spread of coronavirus by those who have been at those premises.

If the operator of the place of worship or a crematorium becomes aware that someone who is required to quarantine or self-isolate or someone who is symptomatic or has tested COVID-positive plans to attend a funeral, the operator may insist on that person wearing an appropriate standard of protective equipment and taking other appropriate precautions to minimise the risks to others attending. If that person declines or is unable to comply with those conditions, the operator may refuse to admit them.

Any mourner who comes into close contact with you during the ceremony (for example, to console or otherwise support you) will then be required to self-isolate. Other mourners need to be aware of this prior to attending.

Guidance for households with possible or confirmed coronavirus infection is available.

It is likely that a funeral may have amongst its attendees someone who is at increased risk or clinically extremely vulnerable and someone who is leaving self-isolation. The organisers and the venue should assume that this is a high probability and make advance plans to manage the increased risk. 

Safety precautions for mourners

All mourners should practise careful hand and respiratory hygiene:

  • wash their hands more often - with soap and hot water for at least 20 seconds or using a hand sanitiser
  • avoid touching their eyes, nose, and mouth
  • avoid touching surfaces as far as possible
  • covering their face when coughing or sneezing with a tissue, disposing of the tissue safely, then washing/sanitising their hands, and replacing their face covering immediately if removed to use tissues; and
  • use their own transport and not share cars with people outside their own household where possible

Mourners who are clinically extremely vulnerable (formerly shielding) should be facilitated to attend, with processes put in place to minimise the risk of transmission. They should be advised to minimise their contact with others for their personal protection, especially if someone permitted to leave self-isolation is also attending.

If a person is attending who would otherwise be self-isolating, it is advised that they inform the organiser and the funeral director/venue manager so that every measure can be taken to ensure those who are at increased risk or who are extremely vulnerable are kept as far removed as possible from the person that would ordinarily be self-isolating.

Mourners who are clinically extremely vulnerable should follow the general physical distancing advice and should maintain a distance of 2 metres away from others as a minimum.

Actions to reduce the risk of infection for all attendees by the person arranging the funeral should include:

  • advising mourners who are self-isolating to carefully consider their wish to attend in person given the risk to other mourners
  • advising attendees to consider the safety of other mourners who may be at risk or vulnerable person, and reiterate the need to avoid close contact at any point
  • advising the mourners to travel to the venue via a method that brings them into the least contact with others as possible, preferably in a car by themselves, or with someone from their household
  • considering the additional risk involved if attending the funeral requires travelling by public transport
  • take necessary steps to avoid encouraging those who are not invited to the funeral to congregate outside the funeral venue.

Actions to reduce the risk of infection for all attendees by those responsible for premises where funerals are conducted must include:

  • provision of information to those entering or working at the premises about how to minimise the risk of exposure to coronavirus, including signage, advance communication of controls in place

Taking other actions on the premises that could include:

  • providing hand sanitiser stations at the entrance point
  • changing the layout of premises including the location of furniture and workstations
  • controlling use of entrances, passageways, stairs and lifts
  • controlling use of shared facilities such as toilets and kitchens
  • otherwise controlling the use of, or access to, any other part of the premises
  • installing barriers
  • providing or requiring use of face coverings
  • ventilation of the venue (see appendix 1 for further details)
  • taking additional preventative measures if a COVID positive or symptomatic person is attending the funeral

All mourners should assume that there may be someone in attendance who is at increased risk or clinically extremely vulnerable, and therefore everyone should adhere to rigorous hand and respiratory hygiene at all times. In addition, for those who are at increased risk or clinically vulnerable they should take particular care whilst out of the home environment. Hand sanitiser or sanitising wipes should be used regularly whilst outside of the home

During the funeral

Arrangements should be put in place to ensure that upon arrival at a crematorium, place of worship or cemetery, those attending can be kept apart and are not required to congregate in confined spaces. This is particularly important while waiting to go into a crematorium or place of worship.

Those attending should then be shown to their seats in accordance with arrangements put in place in advance that ensure that all those from different households or permitted groups can maintain a 2 metre distance. Particular care should be taken to ensure the safety of those who are at risk or clinically extremely vulnerable, especially if someone is leaving self-isolation to attend is also present.

Those attending should be advised not to touch, kiss or come into contact with the coffin. This includes bearers who may accompany the coffin at appropriate distances but should avoid carrying the coffin on their shoulders. Where possible the coffin should be moved using wheeled biers and lifted as required by the funeral director.

Processes should be put in place to allow a suitable time to clean and disinfect the area in which a service has taken place both before and after each service, paying attention to frequently touched objects and surfaces, using regular cleaning products. They should also ensure that handwashing facilities are available and clearly signposted. Hymn books should be removed making use of bespoke order of service pamphlets for all purposes instead.

Steps should be taken to arrange online  collections rather than at the crematorium or place of worship.

It is important also to limit the extent that people from different households congregate after a funeral, although outdoors, physical distancing is not a requirement, unless a risk assessment identifies it as a reasonable measure. That may be outside a crematorium or place of worship, or at a graveside. Arrangements should be put in place to ensure that those attending can pay tribute to the deceased with dignity, and to greet family and friends as appropriate, while ensuring physical distance is maintained where appropriate.

Singing, chanting and the use of musical instruments

We recognise the importance of music, singing and chanting in worship, religious and belief ceremonies. However, there can be increased risks associated with playing wind instruments and with singing or chanting.

The risks are associated with the increased spread of droplets or aerosol which rise alongside volume. Respiratory particles in the form of both droplets and aerosols exist in human exhaled breath, and activities such as speaking loudly, singing, sneezing and coughing will result in greater aerosol generation. Some studies suggest singing may result in a 20-30 fold increase in particle generation while loudness of speaking or singing is also important in determining the amount of aerosol emitted.

Infected individuals shed the virus prior to the onset of symptoms, meaning that focusing on symptoms as a basis for preventing infection is not sufficient to prevent transmission. There is also compelling evidence that a significant proportion of cases show no symptoms at all. This means that strategies for control of the virus must include measures that reduce the probability of infected individuals who are not showing symptoms from infecting others, which requires an understanding of the risks associated with singing and playing wind instruments.

Over the course of the pandemic a number of ‘super-spreading’ events have been associated with gatherings where a ‘vocal’ element plays a role in transmission. These include choir practise and recitals, concerts, weddings and worship. The risks of singing, chanting and playing of wind instruments are then significant. However, scientific advice has concluded these risks are manageable where the community transmission rate is low. For this reason singing and the playing of wind instruments as part of worship practice can take place, but this must be in light of  a risk assessment having been undertaken and appropriate mitigations being put in place for the purposes of minimising the risk of exposure to and spread of coronavirus. If, as a result of an assessment, it is considered that mitigations cannot reasonably be put in place, then singing should not take place. This would include both indoors and outdoors, as well as both performance and congregational singing. However, it is emphasised that extreme caution should be exercised, especially in relation to large groups indoors.

Related guidance that may be applicable to funerals are the Guidance for managing the safe opening of places of worship and prayer during the coronavirus pandemic, and Guidance on coronavirus and working safely in performing arts industries. These both provide advice for conducting risk assessments for those responsible for premises where music may be part of the activity at the venue.

In the case of wakes, music should not be played at levels that make normal conversations difficult. This is because raised voices or shouting significantly increase the risk of transmission through aerosol and droplets, and even more so with  increased risks of transmission through  new variants. Where a band or recorded music is playing in the case of a venue for a wake it is advisable to stress to those in attendance the importance of avoiding singing and organisers should consider the impact of the volume or sustained length of music on the likelihood that people will converse with raised voices.

Ringing of bells, or similar, may take place. The risk assessment should consider the number of people attending to peal the bells; how they will enter and leave the building, room or bell tower; how they will maintain 2 metre distance between individual bell ringers and if this is not possible what other mitigations will be put in place; the protocols for hand hygiene while pealing the bells and how they will maintain physical distancing between other members of the congregation.

Broadcasting, online condolence and memorial at a later date

The restrictions imposed on funerals may be upsetting to those close to the deceased at a very distressing time. Attending funerals, often in great numbers, is an important part of Welsh culture. Those closest to the deceased take consolation from friends and family attending the funeral of their loved one. This will not be possible during the public health emergency, but solace may be achieved in other ways.

It is possible for funerals to be broadcast online (if broadcasting requires a technician or someone to manage the filming that the number should be the absolute minimum and considered in the calculation of how many can attend), and those who wish to do this should be helped to do so. Similarly those organising a funeral should be encouraged to open books of condolence and collections online, or to facilitate tributes to be paid by electronic communications or on social media. Alternatively, or in addition, there could also be a memorial service or celebration of life for the deceased after the public health emergency has come to an end.

Celebrating the life of the deceased or ‘wakes’

In order to reduce the risk to the public, celebrating the life of a deceased person, through a wake or reception is dependent upon public health conditions in Wales in relation to COVID-19.

The maximum number of people who may attend is therefore dependent upon the Alert Level, and the venue where it will be held.

As of 18 June people are permitted to celebrate a deceased person’s life or hold a wake either indoors or outdoors in the following ways:

Wakes that are organised by a business or club

This means that the reception or wake is organised by a specified type of body, including a business rather than simply being held on business premises (for which see below). The organising body/business must undertake a risk assessment and in light of that take all reasonable measures to minimise the risk of exposure to and spread of coronavirus. The numbers permitted to attend indoors or outdoors will be determined by the risk assessment having regard to the size of the venue and the reasonable measures, which includes maintaining physical distancing.

Wakes that are not organised by a business or club

These may be organised by individuals (e.g. the friends, the family):

  1. on business premises such as hospitality premises; or
  2. on private land such as the garden of a private dwelling.

Wakes not organised by a business but held on business premises

The person responsible (referred to in the Regulations as the “responsible person”) for the business premises must undertake a risk assessment in respect of the premises and activities that take place on it and in light of that take reasonable measures to minimise the risk of exposure to and spread of coronavirus. The numbers permitted to attend indoors or outdoors will be determined by the risk assessment having regard to the size of the venue and the reasonable measures, which includes maintaining physical distancing.

Wakes not organised by a business but held on private land

If held at a private dwelling:

  1. indoors: any six people (not including children under 11 or a carer of anyone attending) or members of the household or extended household can gather; or
  2. outdoors: there are no limits on the number of people who may attend.

A marquee situated outside, which does not have more than 50% open sides is regarded by the law as indoors. If it has more than 50% open sides it is outdoors.

Although there is no requirement for physical distancing outdoors, it is recommended that you should seek to maintain physical distancing outdoors from anyone you do not live with or who are not part of your extended household. You should avoid sharing or using the same items as people outside your household or extended household, for example plates, cups, food packages towels, blankets etc. Any item that is passed between people in different households will increase the risk of the spread of the virus. If a venue has identified in their risk assessment that physical distancing outdoors is a reasonable measure to be employed, then you should follow their instructions.

If the wake is held outdoors at a private dwelling, including a garden, people may enter the house for the purpose of using the toilet, but should keep the amount of time indoors to a minimum. They should only be permitted to enter the house for this purpose one at a time (with a care giver, if assistance is required because of age or ability). Householders should keep any toilet/bathroom window open and clean toilet and bathroom facilities thoroughly and regularly, preferably after each use. Towels should not be shared if at all possible and should be changed regularly. Children should be helped to use the toilet and wash their hands thoroughly (according to their age and abilities), and all adults, should wash their hands thoroughly before and after assisting children. Older children and young people should be reminded regularly of the importance of washing their hands thoroughly and often and not touching their face.

Under all Alert Levels, you cannot attend a celebration of a deceased person’s life, wake, or reception if you have been advised to self-isolate by Wales NHS Test, Trace, Protect, or you have symptoms of coronavirus, live with someone who has symptoms or has tested positive, someone in your permitted group has symptoms or has tested positive or if you are in quarantine following international travel.

The celebration of the life of the deceased, or wake  must be directly associated with a funeral which took place on or after 26 March 2020, the date on which the first lockdown began. Whether these gatherings are permitted depends upon the Alert Level and associated restrictions, and must take place in compliance with the duties on organisers specified in the Regulations.

Guidance has been prepared, in partnership with the hospitality industry, relating to many of the activities which may form part of such an event, when permitted. This guidance can be found here:

Those responsible for organising regulated events or responsible for regulated premises are required to carry out risk assessments. Therefore, it is essential that protocols are put in place to help attendees remain safe. These protocols will depend on the nature of the venue itself but should include:

  • no buffet service, food and beverage provision should be table service only
  • loud noises, which will require people to raise their voices or shout and therefore increase aerosol spread, should be avoided where possible
  • to that end businesses should ensure that TV broadcasts and recorded music are kept at background level.
  • live performances can take place subject to businesses undertaking a full risk assessment for each venue in line with all guidance in place for hospitality settings and our guidance for a phased return for Rehearsing, performing and taking part in the performing arts.
  • businesses need to be mindful of any noise nuisance from the premises at all times.; and
  • speeches can be allowed, but there should be no sharing of microphones. Volume levels to be kept to a reasonable level so guests do not have to raise their voices.

Celebrating the life of a deceased person, wakes or receptions held in private homes are only allowed for members of the same household or extended household or otherwise for up to six people, not including children under 11.

See further details regarding alert levels.

Annex

Guidance to members of the public on the impact of coronavirus restrictions on funerals 

Funerals can be a distressing experience, and the impact of coronavirus is making it even more difficult to make practical arrangements. This guidance has been prepared to help people at this very difficult time.

The Welsh Government has put in place restrictions to control the spread of coronavirus in Wales and to protect people’s health. This includes temporary restrictions on gatherings of people in Wales. What is allowed at any time is dependent upon the Alert Level and any additional temporary modifications in place. Information on the four Alert Levels can be seen here, along with guidance on what is permitted at each level and any transitional arrangements.

These have an impact on how funerals are organised but they do enable funerals to go ahead because we recognise it is important for people to say goodbye to a loved one. Funeral directors have been given specific advice about how to organise funerals during the pandemic. They will be able to guide you through the process and help you make arrangements, making sure that you receive the advice and support you need. 

The following information will help you to understand some of the main restrictions that are in place.

People can attend a funeral if:

  • you are the person organising the funeral;
  • you have been invited to the funeral by the person responsible for arranging the funeral; or
  • you are the carer of a person who is attending the funeral (either because they are the organiser or they have been invited).

Everyone attending a funeral, whether at a crematorium, place of worship or cemetery, should take all reasonable measures to stay 2m away from someone they don’t live with, care for or within their permitted group. This will help to reduce the spread of coronavirus. Those responsible for running the crematorium, place of worship or cemetery will make arrangements to maintain this distance between people and any other reasonable precautions they feel are necessary to reduce the risks of people contracting coronavirus. 

This will mean there are limits on the maximum number of people who can physically attend a funeral, dependent on the size of the venue and ability to comply with the physical distancing requirements. This will be clearly communicated to you before the funeral takes place. To help protect against the spread of coronavirus, funerals must be by invitation only.

The death of anyone close to you is a very distressing and sad event. But at this time, we ask you to only attend funerals of your closest family and friends and only if you have been invited by the person responsible for arranging the funeral.

If you have symptoms of coronavirus – a high temperature, a new, persistent cough, or loss of taste or smell – you should not attend but self-isolate and apply for a test. If you are self-isolating due to a possible case of coronavirus in your household, or as advised by Wales NHS Test, Trace, Protect, you should not attend, unless the deceased is a family member or close friend and your attendance is for compassionate reasons. If this is the case and you decide to attend, you should inform the organiser, the funeral director and/or the venue operator. These people have legal responsibilities in relation to COVID-19 secure arrangements and will need to ensure appropriate measures to facilitate your attendance whilst managing the risk to others.

You should also advise the funeral director, and venue manager in advance that you are in self-isolation as additional safeguards will need to be in place to facilitate your attendance.

Mourners coming into Wales who have travelled to Wales from countries that are not exempt from the requirement to self-isolate can leave their place of self-isolation in limited circumstances including on compassionate grounds. This includes attending a funeral but they are expected to self-isolate for the remainder of the specified 10-day period unless another exemption applies. Anyone travelling to Wales for a funeral must follow Welsh regulations. You may also travel to the other UK countries if you have been invited to a funeral, and must follow the restrictions in place in the country you go to. The funeral organisers can advise on what restrictions are in place in the area.

Funerals can be broadcast and livestreamed so people who cannot be physically present can attend the ceremony virtually. In addition, books of condolence can be opened online and other tributes paid through electronic communications or social media.

In order to reduce the risk to the public, celebrating the life of a deceased person, a wake or reception is dependent upon public health conditions as Wales seeks to transition through the Alert Levels.

As of 18 June people are permitted to celebrate a deceased person’s life or hold a wake either indoors or outdoors in the following ways:

Wakes that are organised by a business or club

This means that the reception or wake is organised by a specified type of body, including a business rather than simply being held on business premises (for which see below). The organising body/business must undertake a risk assessment and in light of that take all reasonable measures to minimise the risk of exposure to and spread of coronavirus. The numbers permitted to attend indoors or outdoors will be determined by the risk assessment having regard to the size of the venue and the reasonable measures, which includes maintaining physical distancing.

Wakes that are not organised by a business or club

These may be organised by individuals (e.g. the friends, the family):

  1. on business premises such as hospitality premises; or
  2. on private land such as the garden of a private dwelling.

Wakes not organised by a business but held on business premises

The person responsible (referred to in the Regulations as the “responsible person”) for the business premises must undertake a risk assessment in respect of the premises and activities that take place on it and in light of that take reasonable measures to minimise the risk of exposure to and spread of coronavirus. The numbers permitted to attend indoors or outdoors will be determined by the risk assessment having regard to the size of the venue and the reasonable measures, which includes maintaining physical distancing.

Wakes not organised by a business but held on private land

If held at a private dwelling:

  1. indoors: any six people (not including children under 11 or a carer of anyone attending) or members of the household or extended household can gather; or
  2. outdoors: there are no limits on the number of people who may attend.

A marquee situated outside, which does not have more than 50% open sides is regarded by the law as indoors. If it has more than 50% open sides it is outdoors.

You should seek to maintain physical distancing indoors from anyone you do not live with or who are not part of your extended household or permitted group of 6 and should avoid sharing or using the same items as people outside your household or extended household, for example plates, cups, food packages towels, blankets etc. Any item that is passed between people in different households will increase the risk of the spread of the virus.

If the wake is held outdoors at a private dwelling, including a garden, people may enter the house for the purpose of using the toilet, but should keep the amount of time indoors to a minimum. They should only be permitted to enter the house for this purpose one at a time (with a care giver, if assistance is required because of age or ability).

Householders should keep any toilet/bathroom window open and clean toilet and bathroom facilities thoroughly and regularly, preferably after each use. Towels should not be shared if at all possible and should be changed regularly. Children should be helped to use the toilet and wash their hands thoroughly (according to their age and abilities), and all adults, should wash their hands thoroughly before and after assisting children. Older children and young people should be reminded regularly of the importance of washing their hands thoroughly and often and not touching their face.

Under all Alert Levels, you cannot attend a celebration of a deceased person’s life, wake, or reception if you have been advised to self-isolate by Wales NHS Test, Trace, Protect, or you have symptoms of coronavirus or live with someone who has symptoms or has tested positive, or someone in your permitted group of 6 has symptoms or has tested positive. You can only leave self-isolation to attend the funeral itself.

Celebrating the life of a deceased person, a wake or reception held indoors in private homes are not allowed at this time unless limited to the household, extended household or permitted group of 6. A privately arranged celebration of up to 30 people (not including children under 11 or carers of those attending) is allowed outdoors, including in private gardens.

It is important that you do not delay the funeral of your loved one. We understand how difficult this will be for their families and friends, however the current guidance will be in place for the foreseeable future for the safety of the public and to ensure that funeral directors, crematoriums and burial grounds can continue to offer as normal a service as possible.

Below is a form of words that could be issued (by the funeral organiser, and the Funeral Director) to all those invited to a funeral in order to inform them of the risk of coming into contact with one or more people who may have or be a contact of someone with COVID-19.

Please read the following before attending the funeral

While COVID-19 is circulating there is always a possibility that one or more people attending the funeral will have the virus and may be infectious.

Please follow the advice of the person arranging the funeral and the Funeral Director and adhere to the mitigation measures in place in order to protect all those attending the funeral.

People who are self-isolating because they are symptomatic, a confirmed case or a contact of a case are allowed to leave self-isolation to attend the funeral of a close friend or family member on compassionate grounds. They do not have to disclose to anyone that they are self-isolating but are strongly encouraged to do so.

If you are self-isolating for COVID-19 reasons and you intend to attend the funeral during your self-isolation period, whilst you do not have to disclose to anyone that you are self-isolating, it is strongly advised that you inform the person arranging the funeral and the Funeral Director that you are leaving self-isolation to attend. You must travel directly to the funeral and return back into self-isolation immediately afterwards. You should endeavour to travel in the safest way possible, avoiding the use of public transport or taxi services, if possible.

If you have been informed you are clinically extremely vulnerable or have previously been on the shielded patient list please consider your intention to attend the funeral very carefully as it is not possible to know who might pose a risk to you while you are there.  While you may choose not to disclose that you are clinically extremely vulnerable, it is strongly advisable you discuss your decision to attend with the person arranging the funeral and/or the Funeral Director before making your decision.

Appendix 1

Those in control of a premises have a legal duty to ensure effective ventilation.

The Health and Safety Executive (HSE) has updated and expanded its advice to help employers provide adequate ventilation in their workplaces and premises during the pandemic. The guidance builds on helping you to identify and take action in poorly ventilated areas. It also provides guidance on other factors to consider when assessing the risk from aerosol transmission, and determining whether adequate ventilation is being provided to reduce this risk.

You should be maximising the fresh air in a space and this can be done by:

  • natural ventilation
  • mechanical ventilation
  • a combination of natural and mechanical ventilation, for example where mechanical ventilation relies on natural ventilation to maximise fresh air

Read the updated guidance on air conditioning and ventilation and find out how you can provide adequate ventilation in your workplace, helping to protect workers and other people from transmission of coronavirus.

There is also advice available for building services, particularly around ventilation of buildings, both in use and when returning to buildings which have been closed from the following:

If buildings have been closed or had reduced occupancy water system stagnation can occur due to lack of use, increasing the risks of Legionnaires disease. See HSE guidance covering water management and legionella. (Where mains water has been turned off since the close of the premises at lockdown, when it is reconnected it will need running through to flush away any microbiological or chemical residues built up while the water supply was disconnected).

Steps that will usually be needed:

Checking any water supplies - mains water supplies that have to be reconnected (because they were turned off when a premises was closed) will need running through to flush away any microbiological or chemical residue that might have built up while it was disconnected.

  • The Drinking Water Inspectorate, who are the Regulators and technical experts in England and Wales, has produced this advice on maintaining drinking water quality when reinstating water supplies after temporary closure due to the COVID-19 outbreak
  • 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 can be sought from your heating ventilation and air conditioning (HVAC) engineers or advisers.
  • Removing any fans from, for example, workstations, to avoid the recirculation of air.
  • Opening windows and doors frequently to encourage ventilation, where possible, and if it is safe to do so.

Ventilation and the new variants (technical details for those with mechanical systems)

Ventilation is a key mitigation measure to control the far-field (more than 2 metres) transmission of COVID-19 by aerosols between people who share the same indoor space. Ventilation is not likely to have significant impacts on close range transmission by droplets and aerosols (within 1 to 2 metres) or transmission via contact with surfaces (high confidence).

Higher viral load associated with people who have the new variant could have significant implications for transmission via the air, as previous scientific modelling suggests that viral load is a major determinant of airborne transmission risks. SAGE before the emergence of the new variants stated; for most workplaces and public environments adequate ventilation equates to a flow rate of 8-10 l/s/person based on design occupancy, although guidance for some environments allows for lower flow rates of 5 l/s/person. Since the introduction of the new variant, SAGE has recommended where possible, increasing ventilation flow rates mentioned above by a factor of 1.7 (70%) to account for the increase in transmissibility.

For some existing and older buildings, ventilation systems may not have been designed to meet current standards and additional mitigations may be needed. As a precautionary measure it is recommended that ventilation is included as part of any workplace or public indoor environment COVID secure risk assessment, and the necessary mitigation measures are adopted.

In most buildings, maintaining comfortable temperatures and humidity above 40-60% relative humidity is likely to be beneficial to reducing the survivability of the virus. However, this is likely to be less important than the ventilation rate mentioned above (medium confidence).

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