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Following changes to the law we are updating this guidance. The practical advice in this guidance is still considered useful however you must consider the regulations.

Introduction

The Welsh Government introduced the Coronavirus Regulations imposing strict restrictions on gatherings, the movement of people, and the operation of businesses (some of which have been required to close temporarily).   Incrementally, because of regular review of the Regulations, an increasing number of these are allowed to open again.

Businesses that are permitted to operate, and premises that are allowed to open, must do so safely in a way that complies with the Regulations, in addition to other legal obligations imposed on employers (such as health and safety legislation). To support businesses and others to work safely, the Welsh Government has adopted five key principles:

  • Care: our health and well-being comes first
  • Comply: the laws that keep us safe must be obeyed
  • Involve: we will share responsibility for safe work
  • Adapt: we all need to change how we work
  • Communicate: we must all understand what to do

Further guidance on the key principles is available on the Welsh Government website.

This document is to help employers, employees, and the self-employed and others (such as volunteers) working in retail (where the work does not require close physical contact) to understand how to work safely, taking reasonable measures to minimise the risk of exposure to COVID-19, keeping as many people as possible 2 metres apart from those who are not from the same household or extended household.

How to use this guidance

This guidance aims to help retail business operate safely and gives practical considerations of how safe practices can be applied in your business or operation. Each business will need to translate these into the specific actions it needs to take, depending on the nature of its business, including the size and type of business, how it is organised, operated, managed and regulated.

The Welsh Government has issued Statutory Guidance on taking all reasonable measures to minimise exposure to coronavirus in workplaces and premises open to the public. This document builds on these requirements with practical advice as well as signposting other sector-specific and other relevant guidance.  It gives practical considerations of how safe practices could be applied when working in someone’s home.  Each business or worker must have regard to the Coronavirus Regulations and the Statutory Guidance and should use this document to help them decide what specific actions they should take to operate safely, depending on the nature of the business or work including the size and type of business, how it is organised, operated, managed and regulated.

In the event of any discrepancy between this guidance and the Statutory Guidance, you should have regard to the Statutory Guidance. 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 document contains 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, agency workers and contractors, and anyone else on premises.

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.

It is important to note that indoor shopping centres and indoor shopping arcades are included as part of these restrictions under Part 4 Schedule 1 of the Coronavirus Regulations. A person responsible for carrying on a business, or providing a service in these contexts is also subject to the same duties as other retail businesses which are allowed to open. Welsh Government has issued guidance for the safe management of public spaces.

The guidance is based on the experience of the Welsh Retail Consortium/British Retail Consortium’s and Usdaw’s food retail members who have been operating physical distancing effectively in stores for a number of weeks. These are non-exhaustive and it is the responsibility of each business to decide the most appropriate methods to implement physical distancing and other COVID-19 control measures in their business or on their premises. Over and above these specific recommendations there should be open dialogue with colleagues to reassure them and discuss any concerns about the safety of their role.

1. Managing risk

1.1 Overview

Key point: To reduce the risk of exposure to COVID-19 in the workplace to the lowest reasonably practicable level by taking preventative measures.

All those responsible for work, and premises open to the public, must take reasonable measures to minimise the risk of exposure to COVID-19

The most effective way to minimise exposure to COVID-19 in the workplace is to enable some or all of your staff to work from home, some or all of their time.  There is an expectation that employers should be as flexible as possible and make adjustments wherever that is possible. This may include issuing staff with laptops or mobile phones and facilitating communication from wherever members of staff may be. 

It is recognised that many people who work in retail cannot work from home.  Where staff have to attend a workplace you should take all reasonable measures to ensure that a distance of 2m is maintained between any persons on the premises. The requirement to maintain 2m distance does not apply to persons from the same household or an extended household, or between a carer and the person being assisted by the carer.

In addition, you must take all other reasonable measures to minimise exposure to COVID-19 in the workplace, for example, by:

  • Limiting the level of face-to-face interactions
  • Using physical barriers.
  • Increased, environmental cleanliness and providing reminders about their importance.
  • Washing hands well for 20 seconds with soap and drying thoroughly, or using alcohol based hand gels, before and after close contact.
  • Minimising loud noises which will require people to shout over them.
  • Wearing personal protective equipment (PPE) where sector specific guidance says it is necessary.
  • Recording the provision of lead names and contact details to support Test, Trace and Protect (TTP) and undertaking any necessary TTP actions required by employers.
  • Ensure that those with COVID-19 type symptoms are not present on the premises.

You must also provide information to those entering or working at the premises about how to minimise the risk of exposure.

All those identified as being at high risk of severe illness from COVID-19 (due to a serious underlying health issue) have been advised to shield by the Chief Medical Officer for Wales.  Shielding helps to protect people who are extremely vulnerable by reducing their contact with other people, and therefore the risk of being exposed to COVID-19. From the 16 August 2020, the Welsh Government will pause shielding.  This means that everyone on the shielding list  will  be able to, for example, go to work or go shopping.  They may also choose to have work carried out in their homes which means workers may need access to these home environments.  Further guidance on the practical steps you could take when working in homes where people are currently, or have been, shielding is provided in Subsection 2.3 below.

In addition, there is another wider group of people people at increased risk of serious illness from COVID-19 who are advised to closely follow social and physical distancing measures  at all times. 

No work should be carried by anyone who:

  • Has COVID-19 symptoms, however mild;
  • Is a confirmed case and still within their  self-isolation period from onset of symptoms as set out in the guidance;
  • Is a confirmed case and has self-isolated according to the guidance, but still has a fever, or has had a fever within the last 48 hours; or
  • Has been in recent close contact with a confirmed case of COVID-19, and therefore has been advised to self-isolate (and is currently within the recommended self-isolation period).

1.2 Thinking about Risk

Key point: That a COVID-19 risk assessment is carried out.

You must assess and manage the risks of COVID-19 in the workplace, including working in someone else’s home, and take measures to minimise exposure to the virus.  Additionally, if you are a business operator or employer, you also have a legal responsibility to protect employees and contractors; and anyone else on the premises, from risk to their health and safety. 

Your risk assessment must address the risks of COVID-19, having regard to the Coronavirus Regulations and the Statutory Guidance and using this document to inform your decisions and control measures, recognising you cannot completely eliminate the risk of COVID-19. 

A risk assessment is not about creating huge amounts of paperwork, but rather about identifying sensible measures to control risks. Your risk assessment will help you decide whether you have done everything you need to. There are interactive tools available to support you from the Health and Safety Executive (HSE) at Managing risks and risk assessments at work.

If you employ people then you have a duty to consult your staff on health and safety with meaningful discussion with them and/or their recognised trade union (if one exists), before commencing work.  At its most effective, full involvement of your staff creates a culture where relationships between employers and workers are based on collaboration, trust and joint problem solving. You can do this by listening and talking to them about the work and how you will manage risks from COVID-19. The people who do the work are often the best people to understand the risks and will have a view on how to work safely. Involving them in making decisions shows that you take their health and safety seriously. You must consult with the health and safety representative selected by a recognised trade union or, if there isn’t one, a representative chosen by workers. As an employer, you cannot decide who the representative will be.

If you are required by law to have a written risk assessment (if you have five or more employees) then significant findings must be written down and control measures put in place. Risk assessments are a legal requirement for pregnant women, no matter the size of the business, and further guidance is available for employers of pregnant women.

Your assessment should have particular regard to whether anyone doing the work are especially vulnerable to COVID-19.  The online COVID-19 Workforce Risk Assessment Tool is a two-stage risk assessment for NHS and Social Care workers, which is suitable for use for all staff who are extremely vulnerable (shielding) or at increased risk of contracting COVID-19, including people from Black, Asian and Minority Ethnic (BAME) backgrounds.

Employers and workers should always come together to resolve issues. If concerns still cannot be resolved, then employees can take the following further steps:

How to raise a concern

  • Contact your employee representative
  • Contact your trade union or association if you have one.
  • Use the HSE form available here

If an individual is concerned about the safety measures in any premises where a work is undertaken or that is open to the public, then they can report this to the Public Protection services of the relevant local authority (which include environmental health and health and safety).

Where the enforcing authority - such as the local authority - identifies that those responsible for work 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 not taking all reasonable measures to ensure the 2m distancing requirements in the work place.

1.3 Sharing your risk assessment

Key Point: Letting others know about your risk assessment reassures everyone involved in the work.

We encourage all businesses to demonstrate to their workers and customers that they have properly assessed their risk and taken appropriate mitigating actions. You should share your actions with your workforce. If possible, you should publish this information on your website, particularly where you are an employer with over 50 workers. Use ‘Five key steps to keep wales safe at work’ that you may wish to share with your workforce and/or customers.

2. Working Safely – Practical steps to ensure that colleagues and customers are protected

Together with Usdaw, the Welsh Retail Consortium and the British Retail Consortium have developed practical guidance for customers and retailers to minimise exposure to COVID-19.

Key point: Ensuring that staff understand what they need to do.

Ensure all staff are aware that the Coronavirus Regulations require businesses that are open to the public minimise exposure to COVID-19 by:

  1. Taking all reasonable measures to ensure that a distance of 2m between all persons is maintained on particular premises.
  2. Ensuring that other reasonable measures are taken to minimise risk of exposure to the virus, in particular by limiting close face-to-face interaction and by improving hygiene.
  3. Providing information to those entering or working at premises about how to minimise risk.
  • Staff, including agency workers and contractors, should be made aware and trained on how they should support these measures being observed. Remind staff that physical distancing applies in all areas of the premises, including non- customer facing areas.
  • Ensuring all staff are aware of changes to cleaning regimes and are clear about what is expected of them.
  • Providing regular, accessible and visible written or verbal communication of key messages regarding coronavirus.
  • Providing frequent reminders using the following: additional signage to ask staff not to turn up for work if they have symptoms, written communication, verbal communication, posters and informational signs, daily reminders to all staff via noticeboard and/or intranet.

2.1 Limiting spread of COVID-19 on your premises

Key point: To limit the spread of COVID-19 in any premises where the business is carried out or the service is provided.

Taking all reasonable measures to ensure that a distance of 2m is maintained between people on your premises.

  • Taking all reasonable measures to ensure that persons are only admitted to the premises in sufficiently small numbers to make it possible to maintain distance.
  • Assess the size of the premises and its layout, this will enable you to calculate the number of customers who can reasonably follow 2m physical distancing.
  • Providing regular and visible written/ verbal communications to your staff and customers.
  • Staggering staff shift start, end and break times to avoid crowding.
  • Arranging shifts to maintain same staff working together, where possible.
  • Considering how staff security checks can be managed while maintaining physical distancing.

Ensuring that other reasonable measures are taken to minimise risk of exposure to the virus, in particular by limiting close face-to-face interaction and by improving hygiene and cleaning operations, such as:

  • Providing daily reminders about hand washing and correct coughing etiquette using the following: additional signage, written communication, verbal announcements posters and informational materials.
  • Providing hand sanitiser in high traffic/ customer interaction areas such as: entrance and exit points, till points, changing rooms (if open), staff rooms, backdoor for staff and delivery drivers.
  • Reviewing the cleaning regime – especially around high use areas and multi-person contact points, including door handles, keypads. Toilets, if open, should be cleaned regularly throughout the day and at the end of the day.
  • Providing additional pop-up handwashing stations or facilities if possible. Provide soap, water, paper towels and hand sanitiser, if available.
  • Facilitating regular handwashing breaks for all staff.
  • Introducing frequent deep cleaning of work areas, with attention to multi contact points – for example, between shifts, staff change overs and/or during breaks.
  • Encouraging the use of disinfectant wipes to clean all equipment before and after each use and ensure there are sufficient waste disposal points for waste generated. Consider alternative tasks for staff where concerns are raised.
  • Providing sufficient gloves and/or visors for those colleagues who require them. If you supply re-useable visors ensure colleagues are reminded to clean them regularly during use, and before and after each use.
  • Reminding staff not to share items for example, pens when signing in or out.

2.2 Areas outside the store (including customer areas, deliveries and public areas)

Key point: Managing outside areas effectively.

  • Taking all reasonable measures to ensure that a distance of 2m is maintained between people on your premises or between people waiting to enter your premises.
  • Limiting the number of entry and exit points into and out of the premises. Consider having separate entrance and exit points if possible.
  • Using a colleague to meet customers, explain the physical distancing requirements and control the number of customers entering the premises at any one time. In some circumstances, that colleague may need to be SIA licensed.
  • Considering whether temporary barriers should be available in case it is necessary to stop people joining a queue.
  • Placing clear signage outside the premises explaining the physical distancing measures in place that customers should follow
  • Arranging clear signage to remind people that anyone experiencing symptoms of COVID-19 should be following government guidance and should not be entering the premises but should be at home self-isolating.
  • Placing markings outside the premises to assist correct queue spacings.
  • Encouraging customers to shop alone wherever possible. Please bear in mind that this is not always possible, for example where people need to be accompanied by carers.
  • Working with neighbouring businesses and local authorities to consider how to spread the number of people arriving throughout the day for example by staggering opening hours; this will help reduce demand on public transport at key times and avoid overcrowding.
  • Speaking with neighbouring businesses and relevant partners such as local authorities, landowners, shopping centre managers and BIDs (where they exist) to determine the best way to avoid congestion for queues outside shops. In the event of a dispute between business owners over a contested outside space, we suggest the business owner discusses the issue with their local authority or landlord to help resolve any dispute.
  • Considering whether additional security staff may be required to support staff.
  • Scheduling deliveries to avoid crowding in delivery areas. Consider non-contact stock deliveries.
  • Providing cleaning stations at the front of your premises including: hand sanitiser, if available and disinfectant wipes or spray and tissue for trolley/basket handles.
  • Identifying and regularly cleaning key touch points e.g. door handles, lift buttons, keypads, stair/escalator hand rails.

Providing information to those entering or working at premises about how to minimise risk

  • Considering a variety of communication methods to ensure that signage and information outside the building/premises is fully accessible

For guidance relevant to indoor shopping centres and arcades refer to guidance for the safe management of Safer Public Spaces.

2.3 The shop floor and till areas

Key point: Managing specific areas within your premises effectively.

Taking all reasonable measures to ensure that a distance of 2 metres between all persons is maintained on particular premises.

  • Using floor markings inside to facilitate compliance with the 2m physical distancing requirements outlined above, particularly in the most crowded areas and where queuing is likely.
  • Reviewing the layout of the store to ensure aisles/walkways are as clear as possible to accommodate 2m physical distancing, including the removal of promotional fixtures if necessary.
  • Considering one-way systems using floor markings and signage to highlight system and direction.
  • Setting customer order collection points to ensure 2m distancing either by floor markings or by limiting the number of customers that can wait at a time.
  • Limiting the number of customers in enclosed spaces such as lifts.

Ensuring that other reasonable measures are taken to minimise the risk of exposure to the virus, in particular by limiting close face to face interaction and by improving hygiene and cleaning operations.

  • Erecting physical barriers at till points using flexi-plastic to provide a barrier for those working on the tills.
  • Considering using staff to manage the flow of customers to checkouts if necessary.
  • Considering closing every other till point where till points are close together. Assess whether this is also necessary for self-scan tills.
  • Leaving non-essential doors open to minimise the number of people who touch them. This does not apply to fire doors.
  • Removing promotions and features where customers are likely to congregate, such as product demonstrations.
  • Considering restocking/replenishing only outside opening hours. If replenishment must be done in opening hours, assess how this can be done without compromising employee or customer safety.
  • Encouraging cashless purchases.
  • Including physical barriers at till points in cleaning programmes.
  • Regularly wiping self-checkout touch screens/keypads – If these remain in operation. Ideally do this between each use.
  • Facilitating handwashing breaks.
  • Cleaning till points between staff using usual cleaning products.

Providing information to those entering or working at premises about how to minimise risk.

  • Making regular announcements to remind staff and customers to follow physical distancing advice.
  • Placing clear signage throughout the premises, reminding customers of the physical distancing measures and asking them to follow these rules.

2.4 The handling of goods, merchandise and other materials

Key point: Safely managing the handling of goods, merchandise and other materials.

Taking all reasonable measures to ensure that a distance of 2 metres between all persons is maintained on particular premises.

  • Staggering collection times for customers collecting items, with a queuing system in place to ensure a distance of 2m.

Ensuring that other reasonable measures are taken to minimise risk of exposure to coronavirus, in particular by limiting close face to face interaction and by improving hygiene and cleaning operations.

  • Encouraging increased handwashing and introducing more handwashing facilities (access to automatic soap dispensers, water and paper towels where possible) for workers and customers or providing hand sanitiser where this is not practical.
  • Limiting customer handling of merchandise, for example, through different display methods, new signage or rotation, or cleaning of high touch stock with your usual cleaning products.
  • Putting in place picking-up and dropping- off collection points where possible, rather than passing goods hand-to-hand.
  • Setting up return procedures where customers take return goods to a designated area.
  • Encouraging card/contactless purchases and refunds, where possible.
  • Storing items that have been returned, donated or brought in for repair in a container or separate room for 48 hours, or cleaning such items with usual cleaning products, before displaying them on the shop floor. Materials used for cleaning can be disposed of normally.
  • Considering placing protective coverings on large items that may require customer testing or use, for example, furniture, beds or seats. Ensuring frequent cleaning of these coverings between uses, using usual cleaning products.
  • Cleaning touchpoints after  each customer use or handover. For some examples, such as rental equipment, and test drive and rental vehicles,  interior and exterior touchpoints should be considered.

Providing information to those entering or working at premises about how to minimise risk

  • Providing guidance to how workers can safely assist customers with handling large item purchases.

2.5 Changing rooms, customer seating and special assistance

Key point: Safely managing changing rooms, customer seating and special assistance services.

Ensuring that other reasonable measures are taken to minimise risk of exposure to the virus, in particular by limiting close face-to-face interaction and by improving hygiene and cleaning operations.

  • Considering keeping changing rooms closed. If this is not possible, you should have a member of staff in place at all times to ensure physical distancing is maintained. Provide hand sanitiser in these areas.
  • Where customers require specialist advice/assistance, ensure colleagues giving the advice have a clearly designated position, ideally with a secure barrier as provided at till points.
  • Removing or limiting customer seating in store. If seating is provided, space out appropriately.
  • If you provide in-store products for customers to trial prior to purchase e.g. TVs, headphones, computers these must be set up to enable physical distancing rules to be followed and provide hand sanitiser in these areas. Consider whether it is better for staff to demonstrate instead of customers touching the item, or stop all services which require direct physical interaction with customers.
  • Specialised make-up and skincare advice can be provided if  strict hygiene and physical distancing protocols are followed.
  • If your business chooses  not to assist customers with large purchases e.g. 60” TV to their car, it is advisable to highlight this prior to purchase. If your business is  providing this service they should provide suitable protection and advice for this to be conducted safely.
  • Specialised fitting and measuring services can be provided if  strict hygiene and physical distancing protocols are followed.

2.6 Customer cafes and toilets 

Key Point: Make all public areas and conveniences safe.

Ensuring that other reasonable measures are taken to minimise risk of exposure to the virus, in particular by limiting close face to face interaction and by improving hygiene and cleaning operations.

  • If customer toilets are open ensure they cleaned regularly, including  manual multi-person touch points such as door handles, wash hand basis, flushes, taps etc.
  • Ensure physical distancing within the toilets where possible closing off every other toilet and every other wash hand basin.
  • Baby changing facilities should be available but increase the frequency of cleaning.

The Welsh Government has produced guidance for tourism and hospitality businesses that includes practical information for cafes and restaurants.

2.7 Staff areas

Key point: Keep workers safe in every part of the workplace.

Workplace cafes/canteens may remain open where both (1) there is no practical alternative for staff at  that  workplace to obtain food; and (2) all reasonable measures are taken to ensure that a distance of 2m is maintained between any person using the canteen. Where possible, staff should be encouraged to bring their own food.

Taking all reasonable measures to ensure that a distance of 2 metres between all persons is maintained on particular premises.

  • Permitting staff to use rest areas if they apply physical distancing measures.
  • Reminding  staff that go outside the store for a break to maintain physical distancing from any colleagues or members of the public.
  • Introducing a staggered or extended break rota to avoid crowding.
  • Spacing out chairs and tables to comply with the 2 mtr distancing rules, for example, by removal or marking as “do not use”.

Ensuring that other reasonable measures are taken to minimise risk of exposure to the virus, in particular by limiting close face to face interaction and by improving hygiene and cleaning operations.

  • Promoting hand hygiene and physical distancing via notices placed visibly in these areas.
  • Taking all reasonable measures to ensure that a distance of 2m is maintained.
  • Removing sofas from break areas.
  • Considering providing a takeaway service to avoid crowding in the canteen.
  • Permitting food consumption or breaks to be taken outside of usual areas.
  • Restricting the number of people using designated smoking areas at one time. Also consider increasing the number of designated areas or asking staff to smoke off-site.
  • Providing hand sanitiser at entry/exit points.
  • Canteen staff should wash their hands often with soap and water for at least 20 seconds and before and after handling food.
  • If possible, increasing the number of hand washing stations available.
  • Cutlery trays should be avoided. Cutlery and condiments can be issued to the person when they purchase any food.
  • Frequently cleaning and disinfecting surfaces that are touched regularly, using your standard cleaning products.

Providing information to those entering or working at premises about how to minimise risk.

  • Placing notices promoting hand hygiene and physical distancing visibly in these areas.
  • Reminding staff to wash their hands regularly using soap and water for 20 seconds before and after eating, or using hand sanitisers.

2.8 Delivery networks

Key point: Protecting the health of employers, contractors and customers when undertaking deliveries or off-site services.

The Welsh Government has produced detailed guidance for working in or from a vehicle

Taking all reasonable measures to ensure that a distance of 2 metres between all persons is maintained on particular premises.

  • Restricting all non-essential visitors to sites/hubs/warehouses.
  • Offering non-contact deliveries, where the nature of the product allows.
  • Customer order collection points should be set up to ensure the 2m separation either by floor markings or by limiting the number of customers that can enter at a time.

Ensuring that other reasonable measures are taken to minimise risk of exposure to the virus, in particular by limiting close face to face interaction and by improving hygiene and cleaning operations.

  • Where delivery staff must enter customer homes e.g. delivery of large items, contact the customer on the day of the delivery to ensure that they are not self-isolating or experiencing symptoms. If they are, cancel and reschedule the delivery.
  • Requiring staff to maintain a 2m distance when entering customer homes and asking customers to do likewise whilst delivery staff are on their premises.
  • Hands should be washed with soap and water on arrival and departure. Hand sanitiser should be supplied  for situations where hand washing  is not possible.
  • Sanitiser and wipes should be provided in all delivery vehicles and at entry/exit points to sites.
  • Ensuring vehicle cabs are cleaned regularly especially between shifts and at the end of day.

2.9 Regular review and compliance checking

It is important that any of the measures put in place are regularly checked to ensure customer and colleagues’ understanding and compliance. As part of the ongoing assessment of risk,  retailers should review their in-store and out-of-store security measures and requirements on a regular basis and should encourage feedback from staff about how customers and members of the public are complying with control measures.

Public facing retail staff could be faced with difficult situations when trying to manage physical distancing measures and other requirements (e.g. non-compliance). Staff should be supported when trying to implement control measures. It is important that it is made clear to customers to treat staff who are implementing control measures with respect. This can be done through increased signage and the appropriate action where necessary. Business owners and operators have a duty of care towards their staff and must protect them from verbal and physical abuse from customers, with clear measures in place to protect staff and deal with abusive customers.

2.10 What to do in case of an emergency

Key point: Physical distancing may not be appropriate in an emergency, if it would be unsafe for people to stay 2m apart.

In an emergency (an accident or a fire), it would not be reasonable for people to stay 2m apart if it would be unsafe. If anyone is involved in giving assistance to others, they should make sure they comply with the usual sanitation advice immediately afterwards (fully washing hands, safely disposing of any gloves or other PPE).

St John's Ambulance have updated their guidance on emergency assistance during the pandemic. They recommend that first aiders do not perform rescue breaths on anyone requiring cardiopulmonary resuscitation (CPR).

For more information, make sure you have checked the St John's Ambulance emergency advice.

Test, Trace, Protect

Key point: Employers have a responsibility to help the Test, Trace, Protect programme

Guidance has been published that explains how employers in Wales can play their part in helping to deliver Wales’ Test, Trace, Protect (TTP) strategy to slow the spread of the virus, protect our health and care systems and save lives. This covers their responsibilities to employees and contractors associated with the operation of their business and includes relevant information for the self-employed.  The following steps will usually be needed:

  • Recording and retaining the lead names and contact details to support TTP and undertake any necessary TTP actions required by employers.
  • The Welsh Government has published guidance on keeping records on staff, customers and visitors, in order to help track COVID-19 infections and contain outbreaks. This applies to certain sectors including hospitality, tourism and leisure, close contact services, and facilities provided by local authorities.
  • This is personal data and, under the GDPR you are a data controller for that data. This means you have certain legal obligations in handling that data and you will need to be satisfied that you are complying with the GDPR to protect the privacy of your staff, customers and visitors. This section and more detailed Information Commissioner’s Office (ICO) Guidance sets out the manageable steps that you can take to comply in a way that does not impact detrimentally on your business.
  • As part of your risk assessment, ensuring you have an up to date plan in case there is a COVID-19 outbreak within your workforce. This plan should nominate a single point of contact (SPOC) where possible who should lead on contacting local Public Health teams.
  • If there is more than one case of COVID-19 associated with your workforce, you should contact the PHW health protection team to report the suspected outbreak.
  • If the PHW health protection team declares an outbreak, you will be asked to provide your TTP records and details of symptomatic staff.  You will be provided with information about the outbreak management process, which will help you to implement control measures, assist with communications to staff, and reinforce prevention messages.

Personal Protective Equipment (PPE)

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/coverings.

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

At the start of this document we described the steps you need to take to manage COVID-19 risk in the workplace. This includes working from home and taking all reasonable measures to maintain 2m physical distancing on your premises.

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, and needs to be managed through physical distancing, 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. For example, first responders and immigration enforcement officers. If you are in one of these groups you should refer to the advice on the NHS Wales website.

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. 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).

Face coverings

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.

A face covering can be very simple and may be worn in enclosed spaces where physical distancing is not possible. It just needs to cover your mouth and nose. A face covering is not the same as the surgical masks or respirators used by healthcare and other workers as part of higher specification PPE. Similarly, face coverings are not the same as the PPE used to manage risks like dust and spray in an industrial context. Supplies of PPE, including face masks, must 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.

It is important to know that face coverings are not a replacement for the other ways of managing risk, including minimising time spent in close contact, using fixed teams and partnering for close-up work, and increasing hand and surface washing. These other measures remain the best ways of managing risk in the workplace and the Welsh Government would therefore not expect to see employers relying on face coverings as risk management for the purpose of their health and safety assessments.

Wearing a face covering is optional and is not required by law, including in the workplace. However, from 27 July 2020, it is mandatory to wear a face covering on public transport.

A three-layer face covering is recommended for the public for short-term use where other controls, such as social and physical distancing, are not possible, and in poorly ventilated environments.

If worn, effective face coverings should have a water repellent outer layer if possible, and are comprised of 3 layers of different fabrics, which are non-stretchy. They should fit well with no air gaps around sides and under chin. They are not a substitute for other preventative measures, such as social distancing. Where 2m physical distancing can be maintained in Wales we do not recommend wearing a face covering. We do not recommend that they are compulsory; however, we do support the public’s right to choose whether or not to wear them.

Employers should support their workers in using face coverings safely if they choose to wear one. This means reminding them of the following information:

  • Wash your hands thoroughly with soap and water for 20 seconds, (or use hand sanitiser) and dry thoroughly before putting a face covering on, and after removing it.
  • When wearing a face covering, avoid touching your face or the face covering as you could contaminate them with germs from your hands.
  • To not hang a face covering from the neck or pull down from the nose
  • Change your face covering if it becomes damp or damaged.
  • Wash your hands regularly.
  • Change and wash or discard (as applicable) your face covering daily. 
  • If the material is washable, wash in line with manufacturer’s instructions.
  • After wearing a reusable face covering, it should be placed inside a plastic bag prior to it being washed to prevent onwards contamination from the used face covering.
  • If it is not washable, dispose of it carefully in your usual waste and help keep Wales tidy.
  • Practicing social and physical distancing and frequent and thorough washing of hands is the most effective way of reducing the transmission of COVID-19.

You can make face-coverings at home and can find guidance on how to do this and use them safely on Face coverings: COVID-19.

Communications

You are required by the Coronavirus Regulations to provide information to those entering or working at premises about how to minimise exposure to COVID-19. 

It is therefore essential that there is clear, precise and constant communication between employers, employees, the self-employed, trade unions (if one exists), and households, and anyone else on the premises, about the reasonable and proportionate actions being taken.

It is important that everyone has the same message and same instruction. Employers and business operators should ensure that communications are accessible for all. The aim is to give clear communications and assurance of the management of COVID-19 risks and to minimise exposure to the virus.

Air Conditioning

  • 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.
  • Workplaces such as warehouses, however, tend to be open spaces and beyond the typical general ventilation that the size of warehouses bring, we would not require specific controlled ventilation to manage the virus.
  • 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 (Regulation 6 covers ventilation) 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.

The HSE has further information on Air Conditioning and Ventilation during the Coronavirus outbreak

Mains Water

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.

Health and Safety Executive: legionella risks during the coronavirus outbreak.  

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

Drinking Water Inspectorate: Guidance on drinking water supply operations in Response to Coronavirus (CoViD-19)

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