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This guidance is national guidance that applies across Wales. 

Please consider if local restrictions are in place when reading and implementing this guidance.

Introduction

The purpose of this guidance is to inform the owners and operators of indoor play areas in Wales of ongoing legal restrictions and requirements related to the coronavirus, and to help them re-open.

Indoor play areas, also sometimes known as indoor play centres or soft play centres, are indoor playgrounds. They are specifically designed for children to play in, with structures and play equipment often padded to absorb the impact when children fall or bounce around.  As well as specific areas created for the purpose of indoor play, facilities such as these are often found in a range of buildings and services used by parents including pubs, shopping centres and some of the larger tourist attractions. 

The diverse range of facilities means that some parts of the guidance will be more relevant to some play areas than others. 
 

Legal requirements

Requirements and Responsibilities

Persons responsible for indoor play areas or centres have a duty under Regulation 12 of the Health Protection (Coronavirus Restrictions) (No.2) (Wales) Regulation 2020 2020/725 to take reasonable measures for the purposes of minimising the risk of exposure to coronavirus at the premises or the spread of coronavirus by those who have been at the premises.

This duty includes a requirement to:

  1. ensure that a distance of 2 metres is maintained between any persons - on the premises or where a persons are required to wait to enter the premises (except between two members of the same household, or a carer and the person assisted by the carer)
  2. take any other reasonable measures to minimise the risk of exposure to the virus, in particular by limiting close face to face interaction and maintaining hygiene
  3. provide information to those entering or working at premises about how to minimise risk.

The Welsh Government has issued guidance on what is expected under Regulation 12, and regard must be had to the statutory guidance.

This guidance supports owners and operators of indoor play areas to meet these duties and should be read in conjunction with the statutory guidance issued to date. In the event of any discrepancies between this guidance and the statutory guidance, the statutory guidance takes precedence.

This document is not a substitute for legal advice which you should consider obtaining where necessary, nor does it supersede any legal obligations including in relation to health and safety, employment or equalities. 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. Failure to comply with the relevant public health legislation and guidance to control public health risks could result in enforcement action by the relevant authorities.

This guidance contains non-statutory guidance to take into account when complying with these existing obligations. When considering how to apply this guidance, take into account members of the public and customers, as well as employees and contractors, and anyone else on premises.

Purpose

This guidance, is designed to help employers and employees understand how to work safely during the COVID-19 pandemic, with compliance with the Coronavirus Restrictions Regulations. We hope it gives you scope within a practical framework to think about what you need to do to continue, or restart, operations. 

It will be important for all businesses to maintain a strong working relationship with their respective Local Authority to ensure that any plans to re-open take into account any local policy and guidance. Local authorities may adopt local policies and guidance to ensure the safe, and managed re-opening of businesses according to the current response to the pandemic within their communities.

Key considerations

The steps and activity that you plan should be proportionate (i.e. suitable in size, amount and degree in respect of your business), should be reviewed regularly, and must offer a careful, phased approach to re-opening. Organisations should also focus on creating adaptable solutions that can be paused or rapidly reversed in the event of further COVID-19 outbreaks.

Even when the restrictions are lifted, you should only reopen or restart activities when you feel able to do so safely. It is also for each employer to decide when it is the appropriate time to return staff to work from the Coronavirus Government Job Retention Scheme (JRS) also known as “furlough”. The aim is to enable owners and operators of Indoor Play Areas to protect their staff and reopen their workplaces and enable members of the public to enjoy their services whilst also minimising risk.

To help you decide which actions to take, you need to carry out an appropriate COVID-19 risk assessment, just as you would for other health and safety related hazards. This risk assessment should be done in consultation with the recognised trade union or, if there isn’t one, a representative chosen by workers.

This guidance should also be considered in the context of other applicable statutory duties and relevant guidance that will affect the way we move forward. These include, restrictions across Wales on the need to self isolate and arrange a COVID-19 test for individuals and households with symptoms of coronavirus, the need to adhere to social distancing measures and travel guidance. You may also want to consider the guidance on the safe operation of childcare settings

Those extremely vulnerable people who were previously shielding no longer need to do so and have been provided with updated  advice.

Working within coronavirus regulations and guidelines

Timetable for reopening

  • When planning for any reopening, you will need to consider any notice periods or other arrangements required for furloughed or redeployed staff to return to work.

Planning and preparing workplaces/venues/buildings for reopening

  • Plans should be proportionate, should be reviewed regularly, and must offer a careful approach to reopening.
  • As part of the planning for reopening, a number of physical interventions might be required in order to implement many of the measures proposed.
  • You should carry out statutory health and safety buildings checks prior to reopening for staff or visitors (e.g. legionella, water temperature, gas and electrical testing). Local authorities’ Environment Health Officers will be able to give valuable advice on what checks are required prior to re-opening.
  • Where mains water has been turned off since the close of the promises 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 [1] 

Buildings and rooms that have been shut up will need to be thoroughly cleaned and we would expect the issue of ventilation to be addressed. Ensuring good ventilation is a key objective and states that before reopening the checks that need to be made should include:

  • 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.
  • Maintaining good ventilation in the work environment. For example, opening windows and doors frequently, where possible.
  • For fully mechanical centralised air conditioning systems, which both deliver and extract air from multiple rooms it is best practice to avoid recirculation of air. All centralised mechanical ventilation systems should have the facility to turn off recirculation and use only a fresh air supply.
  • Employers are required to ensure an adequate supply of fresh air through natural or mechanical ventilation and this has not changed. 
  • In some cases, general ventilation can be improved by opening doors etc. but HSE is not proposing to issue additional guidance on the subject. Those in control of premises retain a legal duty as per the workplace, health safety and welfare guidance - Regulation 6 to ensure effective ventilation. 
  • For mechanical systems in individual rooms, where recirculation modes enable higher rates of supply of fresh air to be provided to a space, for example by the prevention of cold draughts, then these devices should be allowed to operate. 
  • Fans would obviously recirculate the current air, so wouldn’t be advised.
  • Deep clean public and workforce areas prior to re-opening and implement revised and enhanced cleaning regimes.
  • Provide safer toilets for public use. Refer to guidance for the safe management of toilets used by the public.

Equality and diversity

  • You must consider the rights of those with protected characteristics and how they can continue to safely access your venue and services.
  • You must consider how you will continue to comply with Welsh language duties when implementing any changes in your activities or services.
  • Remember that some people do not have internet access. You should make provision for them to be able to make bookings and enquiries offline.

Security and emergency preparedness

  • You must consider the security implications of any changes you make to your ways of working. Be mindful of any new vulnerabilities you might inadvertently create when implementing new ways of working. Do not remove any security features without considering protective security in the round.
  • You must ensure any COVID-19 adaptations support your emergency preparedness. Issues could include your fire alarm muster stations, access for emergency response teams, dealing with violent or aggressive people and other threatening situations. Check that trained first-aiders are still willing to undertake these roles and update any first aid training to include COVID-19 protocols.

Health

  • Ensure staff and visitors and members of the public adhere to the social distancing measures  at all times. The use of notices, signage, one way flows etc will assist compliance with this.
  • Ensure staff with symptoms  of COVID-19 or who have tested positive for COVID-19 or are part of a household or extended household where someone has symptoms or tests positive do not attend the workplace but should self isolate at home (those with symptoms should stay at home and arrange a COVID-19 test) 
  • Ensure members of the public and visitors with symptoms of COVID-19 or are required to self-isolate do not attend.
  • Ensure a constant supply of hot water and soap (via automatic soap dispensers if possible) are available to meet COVID-19 hand hygiene requirements. Also supplies of hand sanitiser where appropriate – e.g. entrance and exit points etc 
  • Employers to ensure physical distancing and other considerations in the workplace for their employees. 
  • The Test, Trace, Protect strategy exists to enhance health surveillance in the community, undertake effective and extensive contact tracing, and support people to self isolate where required to do so.
  • 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 the 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. There is a contact tracing question and answer document published by Welsh Government to refer to alongside the guidance above.

Communications

  • Public confidence will be key to supporting a successful and commercially viable return to business, and good communications can help to create this.
  • People may feel anxious about public gatherings, especially those that take place indoors, for a long period of time (see social distancing guidance ). Plans for reopening will need to take into account public perceptions and due consideration will also need to be given to local communities in which your organisation exists and operates. Good, sustained communication and links with local communities will be key to increasing confidence in the preparations that have been implemented to minimise the spread of COVID-19.

Review

  • Ensure that all measures are reviewed regularly (at least weekly) and particularly in light of changes to legislation, government guidance, lessons learned and any other examples of best practice elsewhere and any local restrictions that may be enforced at short notice.
  • Also focus on creating adaptable solutions that can be paused or rapidly reversed in the event of further COVID-19 outbreaks (i.e. consider how you would revise your operating practices swiftly should the need arise).


[1] Department for Education: Managing school premises during the coronavirus outbreak

[2] Health and Safety Executive: Legionella risks during the coronavirus outbreak

[3] Drinking Water Inspectorate: Advice Letter on maintaining drinking water quality when reinstating
water supplies after temporary closure due to the CoViD-19 outbreak

[4] Drinking Water Inspectorate. Guidance on Drinking Water Supply Operations in Response to Coronavirus (CoViD-19)

How to use this guidance

This document sets out guidance on how to work safely and provide a safer service to the public. It gives practical considerations of how this can be applied in the workplace.

This guidance should be read in conjunction with the following workplace guidance for employers and employees: COVID-19 issued by Welsh Government.

You must also have regard to the statutory guidance on taking all reasonable measures  measures to maintain physical distancing in the workplace, quick links to which are at the end of this section.

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

Each business will need to translate this guidance into the specific actions it needs to take, depending on the nature of their business, including the size and type and how it is organised, operated, managed and regulated.

Thinking about risk

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. A risk assessment is not about creating huge amounts of paperwork, but rather about identifying sensible measures to control the risks in your premises. Your risk assessment will help you decide whether you have done everything you need to.

HSE working safely new guidance and also a guide on "things to consider in a risk assessment" document.

Transmission of COVID-19 is most strongly associated with close and prolonged contact in indoor environments. The highest risks of transmission are in crowded spaces over extended periods and physical distancing is an important mitigation measure. Where a situation means that 2 metre face to face distancing cannot be achieved it is strongly recommended that additional mitigation measures including (but not limited to) face coverings and minimising duration of exposure are adopted.

Selecting prevention and mitigation measures should use a “hierarchy of control” approach which considers all the potential transmission routes and are bespoke to each setting and activity.

Risks should be reduced to the lowest reasonably practicable level by taking preventative measures, in order of priority. This is what is meant by a hierarchy of control. The list below sets out the order to follow when planning to reduce risks you have identified in your workplace. Consider the headings in the order shown, do not simply jump to the easiest control measure to implement.

  1. Elimination - Redesign the job or substitute a substance so that the hazard is removed or eliminated.
  2. Substitution - Replace the material or process with a less hazardous one.
  3. Engineering controls - for example use work equipment or other measures to prevent falls where you cannot avoid working at height, install or use additional machinery to control risks from dust or fume or separate the hazard from operators by methods such as enclosing or guarding dangerous items of machinery/equipment. Give priority to measures which protect collectively over individual measures.
  4. Administrative Controls - These are all about identifying and implementing the procedures you need to work safely. For example: reducing the time workers are exposed to hazards (eg by job rotation); prohibiting use of mobile phones in hazardous areas; increasing safety signage, and performing risk assessments.
  5. Personal protective clothes and equipment - Only after all the previous measures have been tried and found ineffective in controlling risks to a reasonably practicable level, must personal protective equipment (PPE) be used. For example, where you cannot eliminate the risk of a fall, use work equipment or other measures to minimise the distance and consequences of a fall (should one occur). If chosen, PPE should be selected and fitted by the person who uses it. Workers must be trained in the function and limitation of each item of PPE.

An illustration of what these proposed measures to reduce risk of exposure would do is available from the Institute of Occupational Health.

There are interactive tools available to support you from the Health and Safety Executive (HSE) at Managing risks and risk assessments at work.

Risk assessments must reflect the current Welsh Government legislation and guidance.

Your local authority can provide advice to support risk assessments. Public protection departments have the role of supporting businesses as well as enforcement action and advice for the public as consumers. Council officers can provide risk assessment templates, guidance notes and checklists.

Everyone needs to assess and manage the risks of COVID-19. As an employer, you also 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.

The risk assessment will help inform decisions and control measures. Guidance and examples of risk assessments are provided by the HSE.

Employers have a duty to consult employees on health and safety. Workers should be involved in assessing workplace risks and the development and review of workplace health and safety policies in partnership with the employer, supported by their trade union or other representative organisation where appropriate. If the workforce aren’t unionised, you must consult with a representative chosen by workers. As an employer, you cannot decide who the representative will be.

Employees should be encouraged to identify, speak up and feedback on risks and control measures, so they can be adapted.

When thinking about risk, some key principles include:

  • the need to demonstrate a formal, consistent, and proactive approach to assessing risk and taking appropriate action
  • risk assessments should be ‘live’ documents and regularly reviewed
  • assessing risks should consider harms to both the physical and mental health of staff, volunteers and customers
  • minimising the need for work related journeys and face to-face contact
  • how you need to take into consideration the age profile of the workforce
  • a need to consider the minimum safe level of staffing – for example to maintain the specific COVID-19 protocols or in the event of a member of staff or volunteer becoming unwell, or needing to isolate repeatedly. This may determine customer capacity on site
  • on staffed sites, what arrangements need to be put into place in the event of someone becoming unwell whilst on the premises?

All risk assessments should recognise that communication, training, and appropriate equipment are significant factors in reducing risk.

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 will consider taking 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 HSE can take include the provision of specific advice to employers through to issuing enforcement notices to help secure improvements.

Managing risk

All risks must be assessed, with meaningful discussion with staff and/or their recognised trade union, before re-commencing work. Risk assessments should include those working from home. If you are required by law to have a written risk assessment (where there are five or more employees) then significant findings must be written down and control measures put in place.

In the context of COVID-19 this means working through these steps in order:

  • In every workplace, increasing the frequency of handwashing and surface cleaning.
  • Employers must comply with the physical distancing duties, both in relation to their employees and to users of their services. There may be a very limited number of work circumstances where measures cannot reasonably be taken to ensure 2 metres distance between people.
    • If it is genuinely essential that the operation should continue, then other measures need to be introduced. Where the measures cannot reasonably be taken, in relation to a particular activity, businesses should consider whether that activity needs to continue for the business to operate, and if so, take all the mitigating actions possible to reduce the risk of transmission between their staff and all those who may be on the premises.
    • It may be necessary to consider moving some equipment to allow for distancing on access routes. Owners and operators should also consider the numbers of people using equipment at a time and introduce measures to manage this where necessary.
  • Consider how people travel safely to and from work. You should show flexibility on this issue, including allowing workers to work from different locations where possible, looking at different start and finish times, and supporting workers getting to and from the workplace.
    • If employees are spending significant time on crowded public transport, this increases the risk of the virus entering the workplace. Staff should be reminded of the rules regarding the use of face coverings on public transport. Car pools or other arrangements for sharing vehicles to travel to work with individuals not within the employee’s household or extended household,  should be avoided where possible.  Anyone that is car pooling will be a contact if one of those people is notified as positive.

Further mitigating actions include:

  • increasing the frequency of hand washing and surface cleaning including disinfection of high footfall areas or common touchpoints
  • keeping the activity time where physical distancing cannot be maintained as short as possible
  • using screens or barriers to separate people from each other
  • using back to back or side-to-side working (rather than face to face) whenever possible
  • reducing the number of people each person has contact with by using ‘fixed teams or partnering’ (so each person works with only a few others).

Finally, if people must work face to face 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. No one should be forced to work in an unsafe work environment.

In your assessment you should have particular regard to whether the people doing the work are at increased risk from or extremely vulnerable to COVID-19. Risk assessments are a legal requirement for pregnant women, no matter the size of the business. More information can be found on the Royal College of Obstetricians and Gynaecologists website in the COVID-19 virus infection and pregnancy publication.

Consideration will need to be given for people in these categories to work from home if possible or to have adjustments of duties if necessary so they are not exposed to risk of the virus on front-line services, for example.  A workforce risk assessment tool is available for this purpose .  Further information for employers and employees is also available in this workplace guidance.

You should also 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.

Sharing the results of your risk assessment

You should share the results of your risk assessment with your workforce. There may also be other industry standards or marks that you can use to demonstrate to any visitors, guests and customers that you have thought carefully about risk.

 

Who should go to work?

Where working from home is not possible, employers must comply with the physical distancing duty.

Steps that will usually be needed:

  • Considering who is essential to be on the premises; for example, back of house workers should work from home if at all possible.
  • Planning for the minimum number of people needed on site to operate safely and effectively.
  • Monitoring the wellbeing of people who are working from home and helping them stay connected to the rest of the workforce, especially if the majority of their colleagues are on site.
  • Keeping in touch with off site workers on their working arrangements including their welfare, mental and physical health and personal security.
  • Providing equipment for people to work from home safely and effectively, for example, remote access to work systems.

Protecting people who are at increased risk or extremely vulnerable

Individuals at increased risk of serious illness or extremely vulnerable -(formerly shielding) from COVID-19 should be offered the option of the safest available on site roles, ensuring that they maintain the required distance away from others. If they have to spend time within this distance of others, 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. As for any workplace risk you must take into account specific duties to 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. 

Steps that will usually be needed:

  • Discussion with employees who are at increased risk or extremely vulnerable, and undertaking risk assessments with them.  A workforce risk assessment tool is available for this purpose.  Further information for employers and employees is also available in this workplace guidance.
  • Providing support for workers around mental health and wellbeing. This could include advice or telephone support.

People who need to self-isolate

Individuals who are advised to stay at home under the Welsh Government’s self-isolation guidance should not physically come to work. This includes individuals who have been tested positive for COVID-19, or those who have symptoms of COVID-19 as well as those who live in a household with someone who has symptoms or been tested positive, and those who are advised to self-isolate as part of the government's  Test -, Trace Protect service. People in any of these categories should stay home, apply for a test (if symptomatic) and remain self-isolating for the appropriate time period as set out in the self-isolation guidance. -.

Steps that will usually be needed:

Equality in the workplace

In applying this guidance, employers should note their duty of care to be aware 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 such as age, ethnicity, sex or disability.

In addition, employers also have particular, statutory responsibilities towards disabled workers and those who are new or expectant mothers.

Steps that will usually be needed:

  • Understanding and taking into account the particular circumstances of those with different protected characteristics. 
  • Involving and communicating 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.
  • Considering whether you need to put in place any particular measures or adjustments to take account of your duties under the equalities legislation.
  • Making reasonable adjustments to avoid disabled workers being put at a disadvantage and assessing the health and safety risks for new or expectant mothers.
  • Understanding and responding to the concerns of those who consider themselves at increased risk.
  • Making sure that the steps you take do not have an unjustifiable negative impact on some groups compared to others, for example those with caring responsibilities or those with religious commitments.

Physical distancing at work

All reasonable measures should be taken to maintain 2 metre physical distancing- including while arriving at and departing from work, while in work and when travelling between sites.

There may be a very limited number of work circumstances where it is not possible to fully enforce physical distancing or amend working practices. If it is genuinely essential that the operation should continue then other reasonable measures need to be introduced. Where the physical distancing measures cannot be followed in full, in relation to a particular activity, businesses should consider whether that activity needs to continue for the business to operate, and if so, take all the mitigating actions possible to reduce the risk of transmission between their staff:

  • Further increasing the frequency of hand washing and surface cleaning, including disinfecting of heavy footfall and frequent touch points.
  • Keeping the activity time involved as short as possible.
  • Using back to back or side-to-side working (rather than face to-face) whenever possible.
  • Reducing the number of people each person has contact with by using ‘fixed teams or partnering’ (so each person works with only a few others).
  • Using screens or barriers to separate people from each other. These are particularly appropriate where an individual cannot maintain physical distancing and is in contact with a high volume of people such as ticket office staff.

Physical distancing applies to all parts of a premises where business is conducted, not just the place where people spend most of their time, but also entrances and exits, break rooms, staging sites and store rooms, canteens and similar settings. These are often the most challenging areas to maintain physical distancing.

Coming to and leaving work

Consider how people get to and from work and look to provide support to ensure staff are not spending significant periods of time on congested public transport. You should show flexibility on this issue, including allowing workers to work from different locations where possible, looking at different start and finish times, and supporting workers getting to and from the workplace.

Steps that will usually be needed:

  • 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 where possible.
  • Reducing congestion, for example, by having more entry points to the workplace in larger businesses. 
  • Using markings and introducing one way flow at entry and exit points which are back of house or employee-only and where appropriate, taking into account premises structure, style of operation and customer profile.
  • Providing handwashing facilities (or hand sanitiser where not possible) for workers at entry and exit points. 
  • Providing alternatives to touch based security devices such as keypads.
  • Defining process alternatives for entry and exit points where appropriate, for example, deactivating pass readers at turnstiles in favour of showing a pass to security personnel at a distance.

Moving around buildings

Steps that will usually be needed for people moving around buildings:

  • Reducing movement by discouraging non-essential trips within buildings and sites, for example, restricting access to some areas, encouraging use of radios or telephones, where permitted. These items require cleaning between users if multi-use.
  • Introducing more one way flow through buildings. Providing floor markings, where appropriate, and signage should remind both workers and customers to follow social distancing wherever possible.
  • Reducing maximum occupancy for lifts, providing hand sanitiser for the operation of lifts and encouraging use of stairs wherever possible.
  • Making sure that people with disabilities are able to access lifts.
  • Regulating use of high traffic areas including stairwells, corridors, lifts, turnstiles and walkways to maintain social distancing and increasing the frequency of cleaning -and disinfection of these areas.
  • High-touch areas such as door handles, countertops and handrails should be thoroughly cleaned regularly.
  • Hand sanitiser stations should be provided at entrances and exits.

Workplaces and workstations

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

Workstations should be assigned to an individual as much as possible. If they need to be shared, they should be shared by the smallest possible number of people whilst maintaining physical distancing and cleaned at each changeover.

If it is not possible to keep workstations 2m apart then businesses should consider whether that activity needs to continue for the business to operate, and if so, take all mitigating actions possible to reduce the risk of transmission.

Steps that will usually be needed:

  • Reviewing layouts to allow workers to work further apart from each other.
  • Using floor tape or paint to mark areas, where appropriate, to help people keep their distance, or using signage or other communication measures taking into account building characteristics, trading style and customer profile. 
  • Avoiding people working face to face. For example, by working side by side or facing away from each other. 
  • Using screens to create a physical barrier between people.
  • Using a consistent pairing system if people have to work in close proximity. For example, cleaning hotel rooms or servicing equipment at an indoor attraction.
  • Minimising contacts around transactions, for example, considering using contactless payments and encouraging online booking and pre-payment where appropriate.
  • If using cash, encouraging increased handwashing and introducing more handwashing facilities for workers and customers or providing hand sanitiser where this is not practical.

Accidents, security and other incidents

In an emergency, for example, an accident, provision of first aid, fire or break in, people should not have to stay the recommended distance apart if it would be unsafe.

People involved in the provision of assistance to others should pay particular attention to sanitation measures immediately afterwards including washing hands.

Steps that will usually be needed:

  • Reviewing your incident and emergency procedures to ensure they reflect the physical distancing requirements as far as possible.

Managing your customers, visitors and contractors

In determining how people visiting your business will be able to do so safely there are a number of top level considerations you should take into account:

  • Assess the number of customers, or crowd density, which can reasonably enable 2 metre physical distancing within any space. This will vary depending on layout or usage. This will require taking into account the total floor space as well as pinch points and busy areas.
  • Consider limiting the number of customers or adjusting the crowd density at any time by implementing timed ticketing or asking customers to book ahead where possible.
  • Consider how customers and employees will move in congestion areas, for example doorways between adjacent indoor and outdoor spaces.
  • Review how customers move through and around the venue (indoors and outdoors) and considering how you could adjust the flow of customers and employees to reduce congestion and contact; for example, queue management or one way flow, where possible.
  • Create clear signage for customers explaining the provisions in place, reminding of physical distancing (including distancing from employees) and promoting the use of contactless payment.
  • Manage queues to ensure they do not cause a risk to individuals or other businesses, for example by introducing queuing systems, using barriers and having staff direct customers. This may include using outside premises for queuing where available and safe, for example some car parks. Have contingency plans in place for periods of poor weather.
  • Ensure any changes to entry, exit and queue management take into account reasonable adjustments for those who need them, including disabled customers.
  • Encourage customers to use hand sanitiser or handwashing facilities as they enter the premises and frequently whilst they are on the premises to reduce the risk of transmission by touching products or surfaces.
  • Remind customers that they are responsible for supervising their children at all times and should follow physical distancing guidelines. Young children (those of primary school age or younger) are no longer required to rigidly socially distance outside, and it is generally understood that very young children find social distancing more difficult to understand. Increased hand washing and respiratory hygiene measures are important here and you may want to refer to the guidance on the safe operation of childcare settings. Adults, even when accompanied by young children, are still required to distance from one another. 
  • Work with your local authority or landlord to take into account the impact of your processes, including queues, on public spaces such as high streets and public car parks and fire escapes outside and within the public realm. 
  • Work with your immediate, local community to take account of the impact of your activities.
  • Have clearly designated positions from which employees can provide assistance to customers whilst maintaining a 2 metre distance.
  • Work with neighbouring businesses and local authorities to consider how to stagger the number of people arriving throughout the day; for example, by staggering opening hours which could help reduce the demand on public transport at key times and avoid overcrowding.

Children and social distancing: a clarification

  • In circumstances where young children mix with others, it may not be practical to attempt to maintain continual 2 metre distancing (between children, or even between children and adults). This is in part because it is harder for younger children to understand the concept of physical distancing, and in part because appropriate support from carers will often require closer contact.
  • For young children (those of primary school age or younger), it is in any case less essential to attempt to rigidly maintain continual 2 metre distance between them, or between the children and any adults outside their household or extended household. Studies have found that young children are less likely to transmit the virus, whether to other children or to adults, and the virus appears to take a milder course in children than in adults for most cases. 
  • However as young children can still transmit the virus, parents 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.
  • For more detailed information on the current restrictions on young children and adults, refer to the Coronavirus FAQs

Maintaining records of staff, customers and visitors

Coronavirus will be with us until an effective vaccine is available or there is enough immunity among the population. As lockdown restrictions ease, general rules around social distancing and handwashing will remain important in reducing the risk of transmission. Our Test, Trace, Protect strategy will be key in controlling the spread of new outbreaks, particularly as public spaces start to re-open. As people increasingly come into greater contact with others, there is a higher risk of transmitting COVID-19 in some sectors. This is because customers and visitors will spend a longer time on these premises than in other surroundings, and will potentially come into close contact with people outside of their household.

Important new policy guidance from the Welsh Government has been published which describes the important role these businesses play in keeping records to support contact tracing and keeping Wales safe.

Whilst indoor play (soft play) areas are not considered high risk, it is recommended that providers should collect contact information of individuals who attend the premises.

ICO guidance to businesses collecting personal data for contact tracing: As businesses start to reopen the Information Commissioner’s Office (ICO) has issued initial guidance for businesses asked to record and maintain personal data of customers, staff and visitors in support of the NHS Wales Test, Trace, Protect service.

Overarching security considerations

Adapting to COVID-19 measures will inevitably result in changes to operating policies, processes and procedures. Any changes should always be considered alongside security implications. If you have a security department or manager, they should be consulted to help ensure good security is maintained as far as possible and that there are no unintended security consequences as a result of changes. This should be achieved by conducting a security risk assessment.

Specific examples of where security implications may arise are: queueing, search and screening (where this has been directed by a wider government policy on security) maintaining vigilance for potential threats and access controls. There may be others that your organisation will need to consider.

Queues and physical distancing

Whilst dense crowding is unlikely if physical distancing is operating correctly, the revised layout of spaces may present new security risks, particularly where multiple queues are created. Considerations include:

  • try and organise queuing within existing protected areas. 
  • do NOT remove any security features or useful street furniture items without considering protective security in the round.
  • if queuing is only possible outside of protected areas then consider and mitigate the vulnerabilities by: routing queues behind permanent physical structures (e.g. street furniture, bollards, trolley parks and bike racks) to provide a visual deterrent and delay; closing off vehicle access to shared spaces; adjusting servicing and delivery times; reducing the opportunities for vehicles (including potentially hostile vehicles) to interact with pedestrians; erecting robust barriers; introducing a reduced speed limit or traffic calming measures.
  • be careful to avoid giving credible, detailed information that could help a hostile identify an attractive target and carry out an attack. In particular, this should not be included in detailed risk assessments published on public websites. Be mindful of messaging, both at the site and particularly on-line, which covers detailed information about queue locations and times, the number of people expected, and suggesting removal of security features such as street furniture, bollards etc.

Restricted entry points

Restricted access entry points, such as those facilitated by keypad, biometrics and/or passes should remain fully in operation. They should not be deactivated.

Pin pads and biometrics should be highlighted as ‘touch points’ and cleaned regularly (note: generally, they are touched less than door handles).

Access control (staff) proximity cards will work up to 10 cm from the reader. Staff can be informed that there is no need to physically touch the card on the reader.

Parties and gatherings

A gathering is defined by the Health Protection (Coronavirus Restrictions) (No.2) (Wales) Regulations 2020/72   as when 2 or more people are in the same place in order to do something together. Gatherings of up to 30 people are now permitted outdoors with appropriate social and physical distancing between different household/extended household groups. However, such gatherings are not allowed indoors. When taking bookings or admitting visitors, you will need to refer to the guidance on leaving your home, which currently does not allow young children (those of primary school age or younger), to gather freely indoors.  

While families can go to indoor play centres, they should not be arranging to meet with people from outside of their household or extended household at them. This means that children’s parties which involve members of other households or extended households are not permitted. 

For young children (those of primary school age or younger), it is less essential to attempt to rigidly maintain continual 2 metre distance between them, or between the children and any adults outside their household or extended household. Studies have found that young children are less likely to transmit the virus, whether to other children or to adults, and the virus appears to take a milder course in children than in adults for most cases. 

However as young children can still transmit the virus, parents 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.

Cleaning the workplace

Before reopening

To make sure that any site or location that has been closed or partially operated is clean and ready to restart, you should undertake an assessment for all sites, or parts of sites, which have been closed, before restarting work.

Cleaning procedures and providing hand sanitiser, before restarting work.

Steps that will usually be needed:

  • 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.

Keeping the workplace clean

Steps that will usually be needed:

  • Frequent cleaning of work areas and equipment between uses by using your usual cleaning products.
  • Frequent cleaning of objects and surfaces that are touched regularly, machines or staff handheld devices, and making sure there are adequate disposal arrangements for cleaning products.
  • Clearing workspaces, removing waste and belongings from the work area at the end of a shift.
  • If you are cleaning after a suspected or confirmed case of COVID-19 then you should refer to the specific guidance.

Looking specifically at the equipment and facilities which will be used by children or other customers:

Play with sand, water, plasticine or play dough and cookery and other messy play activities should not be offered due to the difficulty of cleaning after ever changing customer base.

Equipment, toys and surfaces, including toilets, sinks, taps and changing areas, tables and handles should be cleaned and disinfected frequently. This should include additional cleaning of touch points during sessions, as well as before and after.  Play frames should be cleaned at the start and end of the day with a fogging machine.
Remove soft toys and toys that are hard to clean (such as those with intricate parts). Outdoor equipment and entrance gates should also be cleaned and disinfected frequently. Some equipment must not be used even with stringent measures. This includes ball pits and soft foam pits, which are harder to clean.

All pieces of equipment should have one entrance point.  This should be manned, with a mandatory sanitisation point for users to access. 

Cleaning routines including times, dates, and name of person responsible for the cleaning should be recorded to meet the requirements. 

Hygiene: handwashing, sanitation facilities and toilets

Steps that will usually be needed:

  • Using signs and posters to build awareness of good handwashing technique, the need to increase handwashing frequency, 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 and washing your hands immediately afterwards.
  • Ensuring adults in charge of children understand the necessity of their children adhering to handwashing and respiratory hygiene requirements.
  • Providing regular reminders and signage to maintain handwashing and respiratory hygiene standards.
  • Providing hand sanitiser in multiple locations in addition to washrooms, particularly entrances and exits.
  • Setting clear use and cleaning guidance for toilets to ensure they are kept clean and physical distancing is achieved as much as possible.
  • Enhancing cleaning for busy areas and common touch points.
  • Use of portable toilets should be minimised and special care should be taken for cleaning of portable toilets where they are in place.
  • Use of physical distance marking for other common areas such as toilets, showers, lockers and changing rooms and in any other areas where queues typically form.
  • Providing more waste facilities and more frequent rubbish collections.
  • Providing hand drying facilities, either paper towels or electrical dryers.

Handling goods, merchandise and other materials

Steps that will usually be needed:

  • Steps that will usually be needed:
  • Encouraging increased handwashing and introducing more handwashing facilities for workers and customers or providing hand sanitiser where this is not practical.
  • Putting in place picking-up and dropping-off collection points where possible, rather than passing goods hand to hand.
  • Cleaning exterior and interior touchpoints for example, theme park rides and attractions. Also considering the introduction of hand sanitiser stations immediately before and after customer use.
  • Keeping returns separate from displayed merchandise and stock to reduce the likelihood of transmission through touch.

Personal Protective Equipment (PPE) and face coverings

PPE protects the user against health or safety risks at work. It can include items such as safety helmets, gloves, eye protection, high-visibility clothing, safety footwear and safety harnesses. It also includes respiratory protective equipment, such as face masks.

Where you are already using PPE in your work activity to protect against non COVID-19 risks, you should continue to do so.

When managing the risk of COVID-19, additional PPE beyond what you usually wear is not recommended. This is because COVID-19 is a different type of risk to the risks you normally face in a workplace. It needs to be managed through physical distancing, hand washing and respiratory hygiene and fixed teams or partnering, not through the use of PPE. The exception is clinical settings, like a hospital, or a small handful of other roles for which Public Health Wales advises use of PPE. 

Unless you are in a situation where the risk of COVID-19 transmission is very high, your risk assessment should reflect the fact that the role of PPE in providing additional protection is extremely limited. Note, using PPE does not prevent you from becoming a contact for the purposes of contact tracing as per the NHS Wales Test, Trace, Protect service.  However, if your risk assessment does show that PPE is required, then you must provide this PPE free of charge to workers who need it. Any PPE provided must fit properly.

More information on PPE in Wales: Coronavirus and personal protective equipment (PPE). Welsh Government has published guidance on the Coronavirus and personal protective equipment (PPE), this guidance should be followed and will be updated as required.

The Welsh Government’s FAQs on face coverings provide the necessary details.  The evidence remains clear that the most effective way to protect yourself and others from infection is to follow social distancing rules, avoid touching surfaces and your face, and wash your hands regularly.

Face coverings are not a substitute for these measures, but in some circumstances where it might be difficult to stay 2 metre away from others, we are advising the use of three-layer, non medical face coverings as set out by the World Health Organization. They are not a form of PPE and have a different purpose to that of PPE.

There are some circumstances when wearing a face covering may be marginally beneficial as a precautionary measure. The 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.

Employers should support their workers in using face coverings safely if they choose to wear one. 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 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.  Face coverings of either type should be put in a plastic bag until the covering can be washed or disposed of as appropriate.
  • Practise physical distancing wherever possible.

If you are considering asking visitors to wear face coverings, please remember that very young children may not be able to do so easily.  There is no requirement for children under 11 to wear face coverings on public transport.  Nor are they required in primary schools or childcare.

Workforce management

Shift patterns and working groups

Steps that will usually be needed:

  • As far as possible, where workers are split into teams or shift groups, fixing these teams or shift groups so that where contact is unavoidable, this happens between the same people.
  • Identifying 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.

Communications and training

You should make sure all workers understand COVID-19 related safety procedures.

Steps that will usually be needed:

  • Providing clear, consistent and regular communication to improve understanding and consistency of ways of working.
  • Engaging with workers and worker representatives through existing communication routes to explain and agree any changes in working arrangements.
  • Developing communication and training materials for workers prior to returning to site, especially around new procedures for arrival at work.

You should make sure all workers are kept up to date with how safety measures are being implemented or updated.

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