What is this?
This action card relates to the measures hospitality venues must take, by law, in response to the coronavirus pandemic.
Those responsible for these businesses are required to take reasonable measures to minimise the risk of people being exposed to coronavirus, and spreading the virus, at their premises.
As a basis for deciding what measures should be taken, they must also carry out a specific assessment of the risk posed by the coronavirus.
The action card highlights risks generally associated with these venues and considers what reasonable measures could to be taken to mitigate those risks.
This is not an exhaustive list and other reasonable measures not referred to below may be appropriate.
If you have questions or concerns please seek advice from your local authority’s environmental health department as soon as possible. Please be aware and respectful of the fact that their role is to ensure that appropriate reasonable measures are taken so that your venue can operate as safely as possible. However, it is not their role to approve your risk assessment.
Specific risks in these venues
Busy pubs, in particular, pose a significant risk of spreading coronavirus. This is why they are only able to open subject to strict restrictions, in particular the requirement for controlled entry and table service in licensed premises. It is important that businesses which operate venues of this nature appreciate that the pandemic is not over, and that people mixing in these venues could lead to a significant increase in cases of coronavirus. Many of those who attend the venues will be aware of this and wary of the risk. Similarly, the Welsh Government will be closely monitoring the way hospitality venues operate.
While risks will vary from venue to venue, and will depend on the activities being undertaken at the venue and the number of people present, the following risks will be typical:
- close physical interaction, including queuing in close proximity to others before entry and while inside, for example at the bar, toilets and cloakroom;
- increased likelihood of mixing and face to face interaction, exacerbated by the influence of alcohol;
- raising of voices over loud music increasing risk of aerosol transmission;
- potential for poor ventilation, particularly problematic where people spending prolonged periods together (indoors) in these venues.
What reasonable measures should I consider taking to minimise the risk of exposure to coronavirus?
- Businesses must take all reasonable measures to ensure that a distance of 2 metres is maintained between persons when inside the premises, except between people from the same household, or permitted groups of up to 6 people from 6 different households. Where it is not considered reasonably possible or viable to maintain 2 metres of space between tables, businesses may introduce other reasonable measures to minimise the risk of exposure to coronavirus e.g. erecting screens or partitions between tables and maximising ventilation.
- A maximum number of 6 people from 6 different households can meet indoors in regulated premises. This means that up to 6 people (not including children aged under 11 from any of the households gathering or a person who is caring for someone participating in such a gathering) from 6 different households can meet indoors in hospitality premises. People from the same household count towards the total number of 6. Where a single household contains more than 6 people they can all meet together indoors in hospitality premises provided all those present reside at the same address.
Collecting contact information
In all hospitality premises, licensed and non-licensed, a reasonable measure is to collect contact information (name, telephone number, date of visit, arrival / departure time) from each person (including staff and all visitors) to assist with contact tracing. More information on keeping records of staff, customers and visitors is available.
While it is unlikely to be possible to mitigate the risks completely in all premises, some measures are reasonable to take, so must be taken.
You should consider whether the following measures are reasonable to take. The measures you take should be informed by your assessment of the risk of coronavirus spreading at your premises and tailored to your specific circumstances. The Welsh Government has produced a standard template for coronavirus risk assessments, and there is further information available to support you provided by the Health and Safety Executive (HSE).
Face coverings must be worn in indoor public areas of premises to which the public have or are permitted access. However, a face covering may be removed when a person is seated in premises where food or drink is sold, or otherwise provided, for consumption on the premises. Staff and customers must wear face coverings at all other times unless they are under the age of 11, or have a ‘reasonable excuse’ as defined by the regulations.
Controlled Entry in Licensed Premises
In premises authorised to sell or supply alcohol, or where customers are permitted to bring their own alcohol to consume there (licensed premises), there must be controlled entry to the premises, apart from in cinemas and theatres. Controlled entry includes pre-booking wherever possible with details of all members of the group taken as part of the booking and verified on arrival.
Table Service in Licensed Premises
Managed table service must be in place both indoors and outdoors in licensed premises (see definition above), apart from in cinemas and theatres, to minimise the movement of customers and to avoid customers congregating at the bar or counter. Customers are to be seated in the premises in any place other than at a bar:
- when ordering food or drink;
- when being served with food or drink, and
- when consuming food or drink.
But where food is provided at the premises on a buffet basis, customers may select food from the buffet and return to where they are seated.
What other reasonable measures should I consider taking to minimise the risk of exposure to coronavirus?
While it is unlikely to be possible to mitigate the risks completely in all premises, some measures are reasonable and required as part of the Regulations to take, including taking all reasonable measures to adhere to two metres social distancing.
You should consider whether the following measures are reasonable to take. The measures you take should be informed by the Regulations in place as well as your assessment of the risk of coronavirus spreading at your premises and tailored to your specific circumstances.
The Welsh Government has produced a standard template for coronavirus risk assessments, and there is further information available to support you provided by the Health and Safety Executive (HSE).
Reduce the chance of coronavirus being present
The best way of preventing spread of coronavirus in any premises is to reduce the risk of the virus being on the premises in the first place.
- Consider advising staff and or customers to take a LFD test before they enter your premises.
- Requiring staff and (where feasible) customers to show that they have been vaccinated before they enter your premises.
- Asking customers if they have been vaccinated, have recently been tested or if they have COVID-19 symptoms before they enter your premises.
- Informing customers and staff that anyone who is symptomatic, has tested positive, is awaiting a test result or has been asked to self-isolate by NHS Wales Test Trace Protect, must not enter your premises.
Under the Regulations it is an offence to participate in a gathering of more than 30 people indoors
There are no longer any restrictions in place on numbers when gathering anywhere outdoors, including in private gardens, public parks and beaches, outdoor areas of regulated premises or for outdoor activities and events. However you must still conduct a specific coronavirus risk assessment and take reasonable measures to minimise exposure to and spread of the virus.
Even at these numbers, considerations must be given to:
- Limiting numbers or controlling movement of people so that customers can safely distance themselves from others. As examples use one way systems to walk around the premises and control the movement of people coming together in confined areas such as toilets and bars, and maintain distance between tables. Physical distancing between individuals and between groups remains an effective control measure in premises where there is mixing of different groups of people.
- In unlicensed premises, controlling entry and exit points to prevent people coming together.
- In unlicensed premises, adopting a table service system at busy times.
Limit your capacity
- Where this is economically viable, reducing the number of people who may be inside your premises at any one time. Limiting numbers will reduce the extent to which close physical interaction will occur, in particular by reducing the potential for crowding.
- Spreading people evenly across the venue so that they don’t gather in disproportionate numbers in one room or space.
Improve your ventilation or go outside
- Enhancing airflow by opening windows and propping open internal doors (but not fire doors) where possible and consider maximum capacities.
- If there is a lack of natural ventilation, ensuring mechanical ventilation systems provide 100% fresh air and do not recirculate air from one space to another.
- Make sure mechanical ventilation systems are effectively maintained and have been serviced.
- Monitoring CO2 levels to identify areas where ventilation may be poor.
- Encouraging use of outdoor space instead of staying indoors.
Keep your premises clean
- Minimising the number of surfaces and objects people can touch. For example, limit contact with menus, use apps to order and pay for food or drink, use contactless technology.
- Thorough and regular cleaning using disinfectant in high footfall areas and in high contact touchpoints such as counter tops, tables and door handles.
- Placing hand sanitisers in multiple locations, particularly at entry points and elsewhere at key touchpoints, and providing automated soap dispensers, water and paper towels in washrooms.
Keep the noise down
- Loud noises, which will require people to raise their voices or shout and therefore increase aerosol spread, should be avoided indoors. Businesses should ensure that TV broadcasts and recorded music are kept at background level. Live performances can take place subject to businesses undertaking a risk assessment for the venue. To maintain social distancing and to prevent the increase of aerosol spread, dancing, communal singing and chanting should not be allowed.
Look after your staff
- Implementing systems to minimise contacts between staff. For example, stagger staff shifts, break times and deliveries; set a maximum number for kitchens, staff rooms, changing rooms and areas such as smoking shelters.
- Providing staff with face coverings or other PPE.
- Erecting screens to protect staff, for example in the bar area or where people pay.
- Enabling staff to work from home where reasonably practicable in accordance with the legal requirements;
- Enabling staff to obtain their vaccinations and boosters;
- Facilitating (and not preventing) members of staff that have symptoms, test positive or who have been identified as a close contact by Test Trace Protect (and are not exempt by way of age or vaccine status) to self-isolate. Self-isolating when a person has tested positive is required by law.
Remember face coverings
- Helping to ensure that guests present comply with their legal obligation to wear a face covering, with the exception of when eating and drinking whilst seated, by providing face coverings where necessary.
Help Test, Trace, Protect
You have a legal obligation to provide information to those entering or working at your premises about how to minimise the risk of exposure to coronavirus. This includes, in particular, information to all those present about their risk of exposure to coronavirus identified in the risk assessment and the measures to be taken at the premises to minimise this risk.
This could include announcements, clear signage (e.g. signs, floor tape or paint) for limits on the number of people present in a particular area or room, queuing systems and one way systems.