What is this?
This action card relates to the measures nightclubs, music venues and adult entertainment venues must take, by law, in response to the coronavirus pandemic.
Those responsible for these venues 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 nightclubs, in particular, pose a high risk of spreading coronavirus. This is why they were required to be closed, and have been the last types of venue to re-open. It is important that businesses which operate venues of this nature appreciate that the pandemic is not over, and that re-opening 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 monitoring the impact of re-opening these venues very closely.
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;
- increased humidity from physical exertion through dancing;
- potential for poor ventilation, particularly problematic given the limited scope for natural ventilation and the impact of people spending prolonged periods together (indoors) in these venues.
What 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 venues of this nature, 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).
NHS COVID Pass
- From 07:00 on Monday 11 October, nightclubs and other places that serve alcohol, play (live or recorded) music for dancing and are open any time between midnight and 5 a.m. are required to take reasonable measures to ensure that all adults on the premises show proof of a ‘COVID pass’.
- The requirement to have a COVID pass applies to such premises at any time, including times outside these hours, if they are open and are providing music for people to dance. Refer to guidance for businesses and events for more detail.
- This requirement also applies to certain premises where an event is being held. If you hold events at your premises, please also consult the Events Action Card.
- Assets are available to download for you to use as part of your communications with customers.
Reduce the chance of coronavirus being present
- Requiring staff and (where feasible) customers to take a 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.
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.
- Limiting numbers or controlling movement of people so that where possible customers can safely distance themselves from others. For example limit capacity on dancefloors, 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.
- Controlling entry and exit points to prevent people coming together.
- In music venues, ensuring that people are spread out and not crowding close to the stage.
- In adult entertainment venues, ensuring separation between performers and customers.
- If other ways of mitigating risk aren’t practical, despite it not being a general legal obligation in these settings, requiring use of face coverings for customers and staff in certain areas.
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
- 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.
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
- Lowering the volume of music to reduce the need for people to shout or bring their faces close together to talk.
Look after your staff
- Implementing systems to minimise contact 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 PPE.
- Erecting screens to protect staff, for example in the bar area or where people pay.
- 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.
Help Test, Trace, Protect
- Understanding the role the NHS Wales Test, Trace, Protect system has in monitoring and controlling the virus.
- Keeping records of staff, customers and visitors to support the NHS Wales TTP Service.
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 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.