New regulations, the Health Protection (Coronavirus restrictions) (No. 2) (Wales) Regulations, were made on 10 July 2020. Part 3 of the regulations imposes obligations on persons responsible for premises open to the public, or for work being carried out at any premises, for the purpose of minimising risk of exposure to coronavirus at the premises.
Regulation 12 requires:
- all reasonable measures to be taken to ensure that a distance of 2 metres is maintained between persons on the premises
- any other reasonable measures to be taken – for example to limit close face to face interaction and maintain hygiene, and
- information to be provided to those entering or working at premises about how to minimise risk of exposure to coronavirus.
Regulation 13 provides for guidance to be issued about the practical application of the requirements imposed by regulation 12, and those subject to the requirements must have regard to that guidance.
For these purposes premises includes vehicles used as taxis and for public transport.
There are requirements on businesses that are open including public transport to take all reasonable measures to ensure 2 metres physical distancing between people on premises, as well as waiting to enter premises. This includes any location where work may be carried out and can include outdoor spaces.
Vehicles are now included in the definition of premises, but operators will owe other legal obligations to employees and passengers in order to ensure their safety.
The law in Wales will continue to make the 2 metre distance the default position because that is the safest way to protect people’s health. However, there are some situations and places where 2 metres cannot reasonably be maintained. Our regulations require businesses to put in place a set of additional measures to minimise the risk of the virus spreading in these exceptional situations where 2 metres cannot be maintained. This includes taking reasonable steps to minimise close face-to-face contact and maintain hygiene.
The Welsh Government has issued guidance to all those to whom the physical distancing duties apply, and to which they must have regard, which can be found here: taking all reasonable measures to maintain physical distancing in the workplace.
Failing to comply with the physical distancing duty is an offence, which on conviction may lead to a fine. It is therefore important that businesses are fully aware of that statutory guidance. The guidance in this document does not override that guidance, but is intended to supplement it within the context of transport.
This additional guidance on restarting public transport is issued to operators of public transport under regulation 13 of the new regulations and operators of public transport must have regard to it.
The Welsh Ministers must review the need for the requirements and restrictions in the regulations every 21 days.
In the document Unlocking our Society and Economy: continuing the conversation published by the Welsh Government on 15 May, the First Minister set out a traffic light roadmap setting out how Wales could exit the coronavirus lockdown and since then gradual easement has taken place.
However, capacity on public transport remains limited so you are still encouraged to help control coronavirus, travel safely and leave public transport for those for whom it is essential by:
- only travelling by public transport if it is essential
- working from home where possible
- shopping locally and less often
- considering all other forms of transport such as cycling and walking before using public transport
- avoiding the busiest times and routes
- keeping your distance when you travel where possible
- washing and sanitising your hands regularly
- wearing a 3 layer face covering when using public transport.
This guide will help organisations, agencies and others (such as self-employed transport providers) understand how to provide safer workplaces and services for themselves, their workers and passengers across all modes of private and public transport as they develop plans to restart public transport in Wales. It outlines measures to assess and address the risks of coronavirus (COVID-19) in the transport sector across Wales. It will continue to be kept under review as the current arrangements for lockdown are themselves kept under review and revised as public transport restarts and in the light of experience.
Each transport provider is recommended to translate the principles and examples in this guidance into specific actions. It must be considered alongside legal duties and other guidance produced by the government and the relevant transport regulator for your transport sector including assessing the impact of the arrangements on disabled people and the need to make reasonable adjustments as well as having regard to equality impacts, insofar as operators are bound by the public sector equality duty.
Transport providers should remain mindful of their obligations under both health and safety and employment legislation. The integrated nature of the public transport system makes it important that transport providers try to co-ordinate their planning and their actions with other providers.
Guidance is also being issued to the public on how to travel safely on public transport.
The recommended spacing for physical distancing is 2 metres. This is set in regulations for workplaces where employers and those responsible for workplace management are required to take ‘reasonable measures’ to comply with the physical distancing requirement of 2 metres. It is set out in guidance for other situations including for public transport.
Maintaining 2 metres distance remains the best distance for persons not from the same household or extended household to stay apart to minimise the risk of transmission of the virus. Wherever this guidance mentions households or people you share a home with this should be taken also to include extended households.
However, where it is difficult or not possible to maintain 2 metres distancing on public transport consideration can be given to reducing physical distancing provided that adequate additional mitigations are put in place to avoid the transmission of the virus.
It is mandatory for operators of public transport to have regard to this guidance in order to depart from the 2 metre requirement while ensuring they minimise exposure to the virus and minimise the risk of transmission.
Additional mitigations need to be considered in the light of a risk assessment for different situations and all employers should carry out a COVID-19 risk assessment or multiple assessments for different scenarios within a business. This guidance sets out aspects of how to approach a Cv risk assessment in public transport and some of the additional mitigations what could be taken where 2 metres physical distancing is difficult or not possible.
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.
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.
The diagram below illustrates the potential transmission routes for COVID-19.
- Infected individual
- Susceptible individual
- Large particles or droplets
- Large droplets settle to ground in a few seconds
- Medium particles or droplets
- Risk of transmission through direct exposure to respiratory droplets and contact with surface
- Small droplets and aerosols
- Small droplets evaporate to become aerosols (droplet nuclei) in this zone
- Aerosols carried in air currents for minutes to hours
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.
- Elimination - Redesign the job or substitute a substance so that the hazard is removed or eliminated.
- Substitution - Replace the material or process with a less hazardous one.
- Engineering controls - for example consider using screens to separate passengers and passengers from staff. Give priority to measures which protect collectively over individual measures.
- 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.
- Personal protective clothes and equipment - PPE such as face coverings should be selected and fitted by the person who uses it including for staff taking account of the advice of their employers. Workers must be trained in the function and limitation of each item of PPE. Where clinical grade or industrial grade PPE is not appropriate other equipment should be used such as the recommendation to wear face coverings on public transport.
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 may also be able to 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 may be able to provide risk assessment templates, guidance notes and checklists.
Everyone needs to assess and manage the risks of COVID-19. As an operator of public transport, you also have a legal responsibility to protect workers, customers 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 are not 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 pro-active 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, customers and others
- 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 passenger becoming unwell, or needing to isolate repeatedly. This may determine customer capacity on site
- On staffed sites, consider 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.
How to raise a concern:
- Contact your employee representative, if your workplace has one
- Contact your trade union if you have one
- Use the HSE form.
- Contact HSE by phone on 0300 003 1647
Operators have a duty to reduce workplace risk to the lowest reasonably practicable level by taking preventative measures, in order of priority. All risks must be assessed, with meaningful discussion with staff and/or their recognised trade union. 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
- Operators should so far as is reasonably practicable, enable working from home. Where working from home is not reasonably practicable, employers must comply with the physical distancing duties
- There may be a very limited number of circumstances where measures cannot reasonably be taken to ensure 2 metres distance between people. If it is genuinely essential that the activity should continue then other measures need to be introduced. Where the measures cannot reasonably be taken, in relation to a particular activity, operators should consider whether that activity needs to continue for the service to operate, and if so, take all the mitigating actions possible to reduce the risk of transmission between their staff, customers and others who may be on the premises
- Consider how people get to and from work. If employees are spending significant time on crowded public transport, this increases the risk of the virus being transmitted. You should show flexibility on this issue, for example allowing back office staff to work from different locations where possible, looking at different start and finish times, and supporting workers getting to and from the workplace
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)
- One-way systems
- Automatic doors
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 especially 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.
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.
The recommendations in the rest of this document are ones you should consider as you go through this process. You could also consider any advice that has been produced specifically for your sector, for example by trade associations or trade unions.
As restrictions are lifted, and more passengers start to travel, you should carry out an assessment of the risks posed by COVID-19 in your workplace and vehicles as soon as possible. If you are currently operating, you are likely to have gone through a lot of this thinking already. We recommend that you use this document to help identify any further improvements you should make in order to meet the new mandatory requirements.
You should 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 or issues with accessibility which may need mitigations.
Whilst the risk to health from COVID-19 is at the forefront of everyone’s minds, the threat of terrorism nonetheless remains substantial. It is essential that operators remain aware of these threats as they look to adjust their operations, ensuring that security measures are proactively adapted to support and complement other changes.
Sharing the results of your risk assessment
You should share the results of your risk assessment with your workforce. If possible, you should consider publishing the results on your website, a dedicated employee website or employee communications portal (and we would expect all employers with over 50 workers to do so). 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.
All existing non-coronavirus related health and safety requirements also continue to apply. The Health and Safety Executive and other transport regulators can help you comply with health and safety legislation. 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 trades union or other representative organisation where appropriate. Employees should be encouraged to identify, speak up and feedback on risks and control measures.
We recommend you consider the following when conducting a coronavirus risk assessment:
- risks to workers, passengers, customers and the public along with the control measures required
- the impact of control measures and whether they result in additional, different risks or non-compliance with other requirements (for example health and safety or equalities legislation)
- applying the hierarchy of controls set out in the Management of Health and Safety at Work Regulations 1999
- consultation with workers, or bodies representing workers and the public
- the visibility of the results of any risk assessment
Equality and diversity
Service providers have duties to ensure individuals with protected characteristics for example disabled people, the elderly and pregnant women, are able to access transport networks particularly if plans introduce arrangements that impact some people more than others, for example, extended queuing.
All equality and discrimination law continues to apply. Equality impact assessments are a legal requirement for public bodies and a useful tool for others to ensure the consideration of the likely impact of proposed arrangements as is engagement with protected groups. Transport operators should seek to ensure that the actions taken meet the requirements of different groups as well as not impacting disproportionately on those with protected characteristics.
- You must consider the rights of those with protected characteristics and how they can continue to safely access your facilities / services
- You must consider how you will continue to comply with Welsh language duties when implementing any changes in your activities / services
- Remember that some people do not have internet access. You should make provision for them to be able to make bookings / enquiries offline
Ensure everyone in your workplace has equal opportunities and is treated fairly:
- 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 and passengers 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 or travellers 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
- Making provision for both customers and staff with different protected characteristics
Who should be at work
People are being asked to continue working from home if they are able to do so.
When deciding who can work from home, organisations could consider:
- who is essential to be on site; for example, office workers should work from home if possible
- the minimum number of people needed in vehicles, on site and/or in the office to operate safely and effectively
- the wellbeing of people working from home and how to help them stay connected
- keeping in touch with off-site workers on their working arrangements including their welfare, mental and physical health and personal security
- providing equipment to enable working from home safely and effectively
- looking at what roles and tasks can be done from home and supporting workers to do this where possible, for example, administrative tasks or customer communications
- reallocating tasks between workers, to increase the opportunity for home working
- regularly reviewing how different working arrangements are impacting workers, and how to improve the arrangements
- let workers know in advance if they are required to travel or not
- whether support workers are needed to make their transport networks and vehicles/carriages accessible (for example to operate ramps or lifts)
Protecting people who are at higher risk:
- consider the guidance on clinically extremely vulnerable and clinically vulnerable people at work
- employers should offer support to their workers, particularly around wellbeing and mental health
Organisations could consider:
- re-deploying clinically vulnerable people into roles where they can work from home.
- if clinically vulnerable individuals cannot work from home, they and their employer should consider the level of risk, both on their journey to work and in line with the wider risk assessment of their working situation, as set out in the guidance for employers
- if re-deployment would mean not having enough people on-site to run the operations, move vulnerable workers into lower risk activities where they have the highest chance of remaining 2 metres away from others, where possible
- providing support for workers around mental health and wellbeing. This could include guidance or telephone support for example
People who need to self-isolate:
- workers who have symptoms of coronavirus or workers living in a household with someone showing symptoms of coronavirus should self-isolate and stay at home
- Enable people to work from home while self-isolating if appropriate. See current guidance for employees and employers relating to statutory sick pay due to coronavirus
- Ensure that individuals stay at home for 7 days from when symptoms started. After 7 days if there is no high temperature there is no need to continue to self-isolate. If there is still a high temperature, self-isolate until temperature returns to normal. If living with others and the individual is the first in the household to have symptoms of coronavirus, then they must stay at home for 7 days, but all other household members who remain well must stay at home and not leave the house for 14 days. The 14-day period starts from the day when the first person in the household became ill
- Encourage workers to apply for a coronavirus test if symptomatic if they are eligible
- Ensure there are processes in place if someone attending the workplace shows symptoms or is infected
Physical distancing, face coverings and PPE (Personal Protective Equipment)
There is a requirement set out in regulations in Wales for employers to ensure they take reasonable measures to maintain a distance of 2 metres between people in the workplace. This also now applies in law to vehicles. Passengers and people working on the transport network should therefore keep their distance from people outside their household or extended household. The risk of infection increases the closer you are to another person with the virus and the amount of time you spend in close contact. Public Health Wales (PHW) recommends trying to keep 2 metres away from people, where possible, as a precaution. In Wales this is set out in regulations for work settings as set out in the introduction.
It is a requirement for employers to put all reasonable measures for physical distancing in place in premises including vehicles. In addition, employers should advise staff and passengers on ways of maintaining physical distancing when travelling and take practical steps to facilitate this, for example closing off seats. However, there may be situations where this may be difficult, for example when boarding or alighting, during security checks, on busier services, busier times of day, when walking through interchanges and when undertaking maintenance work that requires two people for the task. Where physical distancing is difficult or not possible try to minimise the time spent within 2 metres of others, and keep groups of workers in teams that are as small as possible and consider additional mitigations to control the spread of the virus as set out in this guidance. Risk assessments should consider the implications for physical distancing for different scenarios that may occur in the transport environment.
Organisations could consider:
- creating and agreeing a single, clear approach to physical distancing for all workers and passengers
- agreeing and maintaining clear rules for workers and passengers that meet physical distancing guidelines
- clear rules for interacting with passengers, receiving goods, and testing equipment.
- support individual workers who choose to use face coverings in situations where physical distancing is not possible
- organising the workspace and how people work in a single space to follow physical distancing guidelines, such as
- separating workspaces 2 metres apart from one another, where possible
- use of screens or barriers
- eliminating face-to-face seating, for example, shift to ‘bench’ style
- repositioning workspaces to allow for optimal ventilation
- reducing occupancy of group interaction spaces, including spaces shared with other organisations
- adjustments for those with specific needs or protected characteristics, for example disabled people, the elderly and pregnant women. Consider groups of people who process information differently or who may not be able to distance from others
Personal Protective Equipment (PPE)
The Chief Medical Officer for Wales issued a statement on 12 May about face coverings and PPE.
There can be confusion between the need for higher specification PPE which exists for example, in health care and similar situations and other forms of protection such as face coverings in non-clinical settings. Workplaces should not encourage the unnecessary use of higher specification PPE to protect against coronavirus outside clinical settings. However, employers should carefully risk assess the appropriate level of protective equipment that may be needed in any given situation in conjunction with their employees. Requirements may vary from situation to situation within the transport network.
Where you are already using PPE in your work activity to protect against non-COVID-19 risks, you should continue to do so.
There are some circumstances when wearing a face covering may be beneficial as a precautionary measure, for example it may protect others if you are infected but have not yet developed symptoms. A face covering is not the same as the surgical masks or respirators used by healthcare and other workers as part of PPE. PPE should continue to be reserved for those who need them to protect against risks in their workplace, such as health and care workers, and those in industrial settings, like those exposed to dust hazards.
On Friday 5 June the World Health Organisation (WHO) updated its advice on non- medical face coverings. It was clear that the widespread use of non-medical face coverings by healthy people in the community setting is not yet supported.
However the WHO recommended that governments encourage the public to wear 3 layer non-medical face coverings in specific settings where other more effective measures were not possible.
Welsh Government is following this advice and recommending people in Wales wear three layer face coverings. On public transport as capacity increases this may mean that physical distancing is difficult or not possible.
A homemade or purchased 3 layer face covering might reduce transmission from one person to another if made, worn, handled and disposed of properly. Some face coverings could be washable and reusable.
This is only the case for non-symptomatic people. People who are symptomatic must continue to self-isolate for 7 days and get a test.
Do not let wearing a face covering give you a false sense of security. Wearing a face covering cannot be an excuse for ignoring physical distancing measures. Maintaining physical distancing wherever possible is a more effective measure than wearing a face covering but both together where physical distancing is difficult or not possible may be of benefit.
It is important to use face coverings properly and wash hands before putting them on and taking them off. And it is important not to derive a false sense of security from using a face covering: hygiene, washing hands and using hand sanitiser and observing 2 metre distancing remain important.
If workers are wearing face coverings, you should support them in using face coverings safely. For example:
- 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
- continue to wash your hands regularly
- change and wash your face covering daily if it is reusable
- if the material is washable, wash in line with manufacturer’s instructions. If it’s not washable, dispose of it in your usual waste
- practise physical distancing
Protecting workers arriving at and leaving the workplace
When arriving and leaving the workplace, there may be occasions when workers are in the same space or are using entrances and exits at the same time. You should consider opportunities to reduce risk in these situations.
Organisations could consider:
- staggering arrival and departure times at work where possible to reduce crowding on routes to and from the workplace
- reducing queues, for example by having more entry points to the workplace
- providing more storage for workers for clothes and bags
- managing queues, for example through floor markings, signs and introducing one-way flow at entry and exit points, considering the impact on public spaces, and working collaboratively with other operators and local authorities
- hand sanitation at building entry/exit points and not using touch-based security devices (such as keypads)
- reviewing workplace access points and entry requirements (for example deactivating turnstiles requiring pass checks in favour of showing a pass to security personnel at a distance). Organisations need to make sure that alternative checks provide the same level of security
- limiting passengers in business vehicles (for example, work minibuses), leaving seats empty
- collaborating with other organisations that share the premises to minimise people on site
- assigning fixed groups of workers to the same transportation routes where sole travel is not possible
- providing additional safe facilities for runners/walkers/cyclists as well as alternative means of transport such as coaches
Protecting workers in the workplace
Where workers are unable to work from home, you should be taking reasonable measures to reduce transmission from face-to-face interaction and enable physical distancing in the workplace. This includes taking reasonable measures to comply with the 2 metre distancing requirement set out in the Regulations.
Organisations could consider:
- making workforce travel plans in advance of workers returning to work
- 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
- where shift patterns are not already in place, consider introducing these to enable more workers to work during a 24-hour period while having as few workers as possible on-site at any one time
- identifying areas where people must pass things directly to each other (for example documents, spare parts, cargo, raw materials) or share tools/equipment, and look for ways to remove direct contact through use of drop-off points or transfer zones
- using remote working tools to avoid meetings with lots of people
- if meetings are necessary, keeping all attendees 2 metres apart, ensure they do not share objects, such as pens and paper, and have hand sanitiser accessible.
- using digital means to communicate shift patterns
- staggering break times to reduce pressure on break rooms or canteens
- designating outside areas as common areas if safe to do so
- creating additional space from other parts of the work site or building freed up by remote working
- using protective screening for workers in reception or similar areas
- using packaged meals or similar to avoid opening canteens
- reconfiguring seating and tables to optimise spacing and reduce face-to-face situations
Organisations could also consider:
- encouraging workers to stay on-site during working hours
- using floor tape or paint to mark areas to help workers keep to a 2 metre distance
- avoiding use of hot desks where possible. Otherwise cleaning workstations and shared equipment between different occupants
- limiting use of high-touch items and shared office equipment (for example, printers, whiteboards)
- only essential meeting participants should attend
- providing hand sanitiser in workspaces
- reducing job and location rotation
- updating first aid training.
Queues and protecting passenger flows
Protecting passenger flows
To protect passengers and workers on the transport network, it is essential, as far as possible, to enable physical distancing. It is a statutory requirement in Wales that persons responsible for work take all reasonable measures to ensure that 2 metres distance is maintained between people on premises where work is being carried out. These measures should therefore cover different types of work place including car parks, service areas, airports, bus stations, station concourses and platforms as well as considering how people act in different circumstances (for example consider wet weather, indoor, outdoor, security procedures).
Transport operators are also advised to consider and mitigate the security implications of any temporary interventions to support physical distancing.
Particular attention should be given to queues that may occur, including at interchanges and busy times of day, or when there are unanticipated delays. It is important that passengers can queue safely (observing physical distancing where possible) and that workers stay safe while passengers queue.
Bear in mind that people with particular needs, for example disabled people may be impacted differently by different measures to manage queues and protect passenger flows and may need particular help to enable them to access public transport and information about the services that are available.
Organisations could consider
- displaying messages, signs and making announcements to discourage non-essential trips and that where possible people should work from home
- promoting other active travel modes (for example walking, cycling) or other demand management techniques
- communicating with passengers through social media and websites to help passengers prepare for their journeys and know what to expect
- making sure that information is available and accessible to people who may be hearing impaired, visually impaired, do not have access to electronic media or whose first language is not Welsh or English
- anyone that cannot work from home and does need to travel to work can use public transport if they need to but they should consider using other forms of travel such as cycling or walking if they can
- undertaking joint planning with other transport organisations at transport interchanges to ensure aligned approaches
- identifying areas where there is increased risk of congestion or crowding due to reduced capacity because of physical distancing requirements and identifying mitigations with other operators and local authorities. Following guidance on public places and considering arrangements that other shops and business may need to implement for their circumstances and how these plans interact
- identifying in advance areas where queues may occur. In these and surrounding areas, consider physical infrastructure, passenger signage, road safety signage, communications and other controls to achieve safe queuing. For example, operators could introduce floor markings, signs and one-way flow at entry and exit points
- providing guidance for workers assisting people with protected characteristics, for example with protracted queuing by disabled people, the elderly and pregnant women
- for security searches, PHW recommends that passengers be asked if they have a new, continuous cough or a high temperature prior to the search. PHW further recommends that staff consider wearing gloves for each search and wash their hands as frequently as possible
- Consider whether queues can be moved to locations with more space for safe queues. Liaise as appropriate with other bodies (such as other transport operators, landlords and local authorities) to safely manage queues and any impact on public spaces. Consider how to provide passengers and services users with information on the service
- If services, concourses or interchanges become too crowded, or queues become too long, operators should consider the full range of operational responses available, recognising the knock-on effects on other transport modes in making these decisions
- Use social media, apps and other digital methods to alert passengers before they leave home, and to help passengers stay away or disperse until there is sufficient capacity available
Physical distancing in vehicles and at service areas, bus and railway stations, stops, ports and airports:
- rearranging, limiting or removing seating to try and ensure physical distancing is observed and that it can be cleaned regularly using a rota or some other tracker. This may include:
- blocking off seats that are in close proximity to a driver or other workers and passengers
- removing face-to-face seating
- maximising separation for example by sitting in back left hand seat of a car
- using floor tape, signs or paint in passenger areas to help people keep 2 metres apart
- using screens to create a physical barrier between people where appropriate, such as in ticket offices
- introducing more one-way flow through areas and by vehicles
- revising maximum occupancy for lifts and ways of operating lifts
- making arrangements for monitoring compliance to assist with further planning (for example appointment of physical distancing marshals as in supermarkets)
- keeping in mind particular needs of workers and passengers who have protected characteristics, for example with protracted queuing by disabled people, the elderly and pregnant women
Ensure that your emergency procedures are clear and are followed during an emergency or situation requiring an evacuation. You should consider how to maintain physical distancing in these situations, recognising that people may not always be able to stay 2 metres apart. Review and update existing queuing, crowd management and emergency plans and the situations when these are instigated.
What to do if someone develops symptoms of coronavirus in a transport setting
If anyone becomes unwell with the symptoms of coronavirus in a transport setting they should be sent home and advised to follow the self-isolation guidance.
If they need clinical advice, they should go online to NHS 111 Wales (or call 111 if they don’t have internet access). In an emergency, call 999 if they are seriously ill or injured or their life is at risk. They should not visit a GP, pharmacy, urgent care centre or hospital.
Touch points (for example buttons to open doors, hand rails) across the transport network should be particular areas of focus for increased cleaning. Organisations should follow guidance on cleaning and waste disposal and implement cleaning protocols to limit coronavirus transmission and consider who will carry out the cleaning activity.
Cleaning before increasing capacity or re-opening
Organisations should ensure that any site or location that has been closed or kept partially open during the coronavirus outbreak, is assessed and appropriate steps taken to prepare for restart or ongoing operation.
Organisations should consider health and safety and other legal obligations which might include:
- Conducting a working environment assessment for all sites that have been closed, before restarting work
- Carrying out cleaning procedures, providing hand sanitiser, adjusting ventilation before restarting work
- Using Heating, Ventilation and Air Conditioning (HVAC) systems and/or opening windows and doors to encourage ventilation, where possible and safe to do so
- Defining and communicating consistent procedures for standard and deep cleaning
Keeping public and private areas and modes of transport clean
Keep public and private areas and vehicles clean and prevent the transmission of coronavirus as a result of touching contaminated surfaces.
Organisations should consider:
- identifying higher risk areas such as areas that are touched more regularly
- supplying appropriate products for regular cleaning and making sure there are adequate disposal arrangements for used cleaning products
- cleaning regularly-touched objects and surfaces (like door handles, handrails and ticket machines) more often than usual using appropriate cleaning products
- clearing workspaces, removing and appropriately disposing of waste and removing belongings from the work area at the end of each shift
- cleaning all workstations, shared vehicles, hand tools, controls, machinery and equipment after use and between each shift and user
- encouraging a reduction in paper-based processes and replacing these with digital forms of communication where possible
- encouraging workers to wash hands before boarding vehicles
- retaining sufficient quantities of hand sanitizer/wipes within vehicles to enable workers to clean hands after each journey, delivery or drop-off
- using wipes to clean fuel pumps before and after use
- cleaning vehicle keys before and after handling
- regular cleaning of work areas consistent with published guidance
Where possible transport operators should use anti-viral cleaning products that will kill the COVID-19 virus such as ones manufactured to British Standard BS EN 1276 or BS EN 13697.
Hygiene – handwashing, sanitation facilities, toilets and showers
To help workers and passengers maintain good hygiene, organisations could consider:
- use signs and messages to build awareness of good handwashing technique and other hygiene behaviours for example around coughing and sneezing
- providing paper towels in hand washing facilities
- sufficient provision of hand sanitiser onsite in addition to washrooms, and for those working away from hand washing facilities
- configuration of toilet and shower facilities to ensure they are kept clean, with physical distancing where possible and with best practice handwashing followed between each use
- retaining sufficient quantities of hand sanitizer/wipes in vehicles/carriages where practical and safe for the use of passengers at the start and end of their journeys
- enhanced cleaning for facilities that are heavily used
- keeping showers and changing rooms closed until clear use and cleaning guidance is set
- minimising use of portable toilets
- providing more waste facilities and more frequent rubbish collection and disposal
Organisations should consider how to increase ventilation and air flow. Where possible, transport operators and businesses should ensure that a fresh air supply is consistently flowing through vehicles, carriages, transport hubs and office buildings.
To achieve this, organisations could consider:
- air conditioning, most air conditioning systems do not need adjustment, however where systems serve multiple buildings or you are unsure, advice could be sought from HVAC engineers
- fresh ventilation systems can operate as normal, but recirculating air systems including in vehicles may require adjustments to increase fresh air flow
- high-Efficiency Particulate Air (HEPA) filtration
- opening doors and windows where possible and safe to do so
Communications and training
Transport operators should keep workers and passengers informed of the latest coronavirus related safety procedures. Organisations should share the government’s most recent guidance to all workers and organise training sessions on how to work or interact safely with colleagues and the public. Operators and businesses should carefully consider the best ways to share advice on how to travel safely and physical distancing guidelines to passengers.
For workers, organisations could consider:
- engaging with workers through unions, work councils and other workers’ bodies to quickly explain and agree any changes in working arrangements
- let workers know in advance if they are required to travel or not, ensuring where possible workers continue to work at home
- clear and regular communication to improve understanding and consistency of how ways of working are applied
- communication and training materials on new procedures. Some of these may need to be delivered online to maintain physical distancing between workers
- using posters and announcements to remind workers to wash their hands often and follow general hygiene advice
- awareness and focus on the importance of mental health at times of uncertainty
- the use of visual and digital communications (for example whiteboards, signs, websites, intranets, emails) to explain changes to schedules, breakdowns, materials shortages without the need for face-to-face communications
- you should think about how you can organise your work area so that you can keep people 2 metres apart, where possible
For passengers and travellers, organisations could consider:
- communicating with passengers through social media and websites to help passengers prepare for their journeys and what to expect
- providing passengers with information on timetables, expected journey times, expected capacity (accounting for physical distancing), delays and changes to normal routes
- using posters and announcements to remind travellers and passengers to wash their hands often and follow general hygiene advice
- promoting online ticket purchases
- signs and announcements to help passengers understand what they need to do to travel safely and maintain physical distancing when entering or exiting a site or vehicle, in consultation with other operators and local authorities for public highways and thoroughfare.
- information on provision and any changes to assistance services for those with protected characteristics, for example with protracted queuing by disabled people, the elderly and pregnant women, and how they can continue to access transport in a safe way
- the use of simple, clear and accessible messaging to explain guidelines using images and clear language, with consideration of groups whose first language may not be Welsh or English or where alternative formats may be required
- providing clear information to the public on how this guidance is being implemented
Additional mitigations in public transport where 2 metre physical distancing is difficult or not possible
Mitigation: current situation
Regulations require ‘reasonable measures’ to comply with 2m physical distancing rule in workplaces
General guidance to operators and passengers to keep 2 metres apart where possible
Recommendation to wear a 3 layer face covering
Working from home
Advice not to travel
Staggered working hours
Screens for bus drivers and station staff
Use of the TfW “Travel Safer” messaging on buses and trains:
o Only travel if essential and don’t travel if you’re unwell, even with mild symptoms.
o Avoid busy periods – try not to touch surfaces like buttons, doors or your face and avoid eating and drinking.
o Follow our latest travel advice - stay 2 metres apart, wash your hands regularly and wear a face covering.
o Exercise while you travel – walk or cycle for short journeys if you can
o Respect our staff and other passengers at all times
Examples of additional mitigations from Monday 13 July
- Pay contactless where possible
- No passengers standing on public transport vehicles while travelling
- Do not stand up in public transport until ready to get off
- Revenue protection on board trains to be suspended (ie. by guards)
- Notices advising to turn away from other people in confined spaces
- Not using seats that are side to side or face-to-face
- Rounded fares to reduce cash handling
- Provide additional buses in areas of high demand to spread demand across vehicles and avoid potential crowding at stops or on board
- One-way systems in stations, on trains and buses where possible
- Blocking off seats not to be used and near drivers/other staff (except for single/extended households/carers) taking account of the needs of disabled people including sight and hearing impaired persons
- Enhanced ventilation (all windows on trains and buses to be left open at all times where possible)
- Enhanced cleaning including ‘touch points’, train and other table and lavatories for public use which need to be kept open and clean (at each end of every journey)
- Adjust recirculating air systems
- Keep moving within stations
- Additional screens, barriers, floor markings and segregated entrances/exits in stations and on trains/buses
- Reduce queuing at ticket barriers (entering/leaving) in railway stations
- Increase availability of non-spill hand sanitiser on public transport
- Increase litter collections in and around public transport to remove potentially contaminated materials safely (need to protect staff)
- Confine use of lifts to only those with mobility issues and reduce the number of people per lift and face away from other people while being alert to the needs of people with hidden impairments
- Notices about queuing and which seats to use
- Enhance “Travel Safer” messages to “Work Remotely” where possible
- Messaging around keeping 2m apart in transport hubs, on platforms and within carriages/buses where possible
- Travel in relative silence - no ‘loud’ activities in public transport (like singing) (this would be to reduce potential aerosol transmission)
- Do not use mobile ‘phones for talk on public transport except in an emergency (aerosol transmission)
- No running in transport hubs (aerosol transmission)
- Don’t run for the bus (aerosol transmission) – drivers to be alert and wait
- No newspapers
- Do not consume food or drink on public transport (except for example on medical grounds)
- Enhance training for bus drivers and cleaning staff about how to clean their vehicles more effectively.
- Booked seats only available (generally trains: buses and coaches where possible) – enforced by security staff (not transport staff)
- People to wear a 3 layer face covering when on public transport
- Symptom and temperature checks on entering rail system at major interchanges as condition of carriage
- Enhanced hygiene training for railway staff who assist less mobile passengers on and off trains
Cross border travel
If you are undertaking cross-border travel within the UK, particularly between Wales and England take care to have regard to and follow the regulations and travel guidance which may be in place in in the different countries of the UK ensuring you take necessary precautions on public transport.
If travelling abroad is essential, make sure you check the latest Foreign and Commonwealth Office (FCO) advice (on GOV.UK) before travelling. Check with your airline, ferry or train operator on specific rules for each route and destination.
Bear in mind that quarantine rules may apply.
Legal requirements and enforcement: physical distancing and gatherings
The requirement in the Coronavirus Regulations in Wales to take all reasonable measures to ensure a distance of 2 metres is maintained between persons on premises in railway stations, bus stations and airports and now to vehicles. Additional advice may be provided by transport staff and others employed for the purpose as many of us will have seen at supermarkets where physical distancing is being effectively managed.
It is not the intention of the regulations to make queuing for a bus unlawful but the public need to be clear about their responsibility to maintain physical distancing in these circumstances.
Furthermore, employers have an overarching duty to their workers under the Health and Safety at Work Act. This will have an increased relevance for staff in the public transport system as demand increases.
Part 5 of the regulations sets out the arrangements for enforcement of these regulations including by whom and offences and penalties. However, in the first instance, the approach will be to inform and encourage people to observe the regulations and other mitigations to control the spread of the virus.