What is this?
This action card should be used in conjunction with current Welsh Government guidelines.
Its purpose is to the highlight those reasonable measures that are key to controlling COVID-19 infection in the performing arts sector
This action card relates to the measures theatres, concert halls and cinemas must take, by law, in response to the coronavirus pandemic.
In addition, this action card also sets out reasonable measures that those responsible for these venues should consider to minimise the risk of people being exposed to coronavirus, and spreading the virus, at their premises.
As a basis for deciding what measures should be taken, they must also carry out a specific assessment of the risk posed by the coronavirus. This should be reviewed periodically, especially when relevant regulations or guidance are updated.
The action card highlights risks generally associated with these venues and considers what reasonable measures could to be taken to mitigate those risks.
This is not an exhaustive list and other reasonable measures not referred to below may be appropriate.
If you have questions or concerns please seek advice from your local authority’s environmental health department as soon as possible. Please be aware and respectful of the fact that their role is to ensure that appropriate reasonable measures are taken so that your venue can operate as safely as possible. However, it is not their role to approve your risk assessment.
Specific risks for the sector/activity
Where venues are indoors and see large numbers of people congregating closely together for prolonged periods of time, this does pose a high risk of spreading coronavirus. The longer large numbers of people are close together, especially indoors, the greater that increased risk of transmission becomes.
While risks will vary from venue to venue, and will depend on the activities being undertaken at the venue and the number of people present, the following risks will be typical:
- close physical interaction, including:
- queuing in close proximity to others before entry and while inside
- sitting closely next to people that you do not live with
- increased likelihood of mixing and face to face interaction;
- raising of voices over loud music increasing risk of aerosol transmission;
- potential for poor ventilation, particularly problematic given the limited scope for natural ventilation and the impact of people spending prolonged periods together (indoors) in these venues.
What reasonable measures should I consider taking to minimise the risk of exposure to coronavirus?
While it is unlikely to be possible to mitigate the risks completely in all premises, some measures are reasonable to take, so must be taken.
NHS COVID pass
- Theatres, Concert Halls and Cinemas must, by law, take reasonable measures to ensure that all adults (18 and over) on the premises show proof of a ‘COVID pass’:
- The requirement to have a COVID pass applies to such premises at any time. Refer to guidance for businesses and events for more detail.
- Assets are available to download for you to use as part of your communications with customers.
Remember face coverings
- Ensure that people present, both employees and customers (when not actively eating or drinking), comply with their legal obligation to wear a face covering, unless exempt.
You should consider whether the following measures are also reasonable to take. The measures you take should be informed by your assessment of the risk of coronavirus spreading at your premises and tailored to your specific circumstances. The Welsh Government has produced a standard template for coronavirus risk assessments, and there is further information available to support you provided by the Health and Safety Executive (HSE).
Reduce the chance of coronavirus being present
- Requiring staff to take a lateral flow test before they come to work, if the test is positive they should not attend work.
- Encouraging and facilitating staff to receive a vaccination / booster; e.g. by allowing time during the day for staff to attend vaccination appointments or walk-in centres.
- Promoting the booster vaccination to all staff as it plays a critical role in the defence against Covid-19, especially the omicron variant. Informing customers and staff that anyone who is symptomatic, has tested positive, is awaiting a test result or has been advised to self-isolate by NHS Wales Test, Trace, Protect must not enter the event.
The best way of preventing spread of coronavirus in any premises is to reduce the risk of the virus being on the premises in the first place.
- Limiting numbers or controlling movement of people so that where possible customers can safely distance themselves from others. For example use one way systems to walk around the premises and control the movement of people coming together in confined areas such as toilets and bars.
- Controlling entry and exit points to prevent people coming together.
- Ensuring customers comply with the requirement to wear a face covering (unless they have a reasonable excuse not to wear a face covering) in all indoor public places.
Limit your capacity
- When attendees are booking in groups they should be limited to up to 6 people from up to 6 different households, or one household of up to 6 people (or more, if they are all from the same household), when meeting in Theatres, Concert Halls and Cinemas.
- All reasonable measures should be taken to ensure 2m social distancing between individual attendees, groups of up to 6 and household groups, when seated for a performance or screening.
- Audiences for an entertainment performance should be limited to no more than 200 people when indoors (this does not apply to the showing of a film).
- Where this is economically viable, reducing the number of people who may be inside your premises at any one time. Limiting numbers will reduce the extent to which close physical interaction will occur, in particular by reducing the potential for crowding.
- Spreading people evenly across the venue so that they don’t gather in disproportionate numbers in one room or space.
Improve your ventilation
- Enhancing airflow by opening windows and propping open internal doors (but not fire doors) where possible and consider maximum capacities.
- If there is a lack of natural ventilation, ensuring mechanical ventilation systems provide 100% fresh air and do not recirculate air from one space to another.
- Make sure mechanical ventilation systems are effectively maintained and have been serviced.
- Monitoring CO2 levels to identify areas where ventilation may be poor.
Keep your premises clean
- Minimising the number of surfaces and objects people can touch. For example, limit contact with menus, use apps to order and pay for food or drink, use contactless technology.
- Thorough and regular cleaning using disinfectant in high footfall areas and in high contact touchpoints such as counter tops, tables and door handles.
- Placing hand sanitisers in multiple locations, particularly at entry points and elsewhere at key touchpoints, and providing automated soap dispensers, water and paper towels in washrooms.
Keep the noise down
- Lowering the volume of music to reduce the need for people to shout or bring their faces close together to talk.
Look after your staff
- Enable staff to work from home where reasonably practicable, in accordance with the current legal requirement.
- Implementing systems to minimise contact between staff. For example, stagger staff shifts, break times and deliveries; set a maximum number for kitchens, staff rooms, changing rooms and areas such as smoking shelters.
- Providing staff with PPE.
- Allowing staff time off for vaccinations / boosters.
- Erecting screens to protect staff, for example in the bar area or where people pay.
- Facilitating (and not preventing) members of staff that have symptoms or test positive to self-isolating). Self-isolating when a person has tested positive is required by law.
Help Test, Trace, Protect
- Understanding the role of the NHS Wales Test, Trace, Protect system has in monitoring and controlling the virus.
- Keeping records of staff and work patterns to support the NHS Wales TTP Service.
What reasonable measures should I consider taking when specific activity compromises 2m distance between people who do not live together (including between staff and customers)
You have a legal obligation to provide information to those entering or working at your premises about how to minimise the risk of exposure to coronavirus. This includes, in particular, information to all those present about their risk of exposure to coronavirus identified in the risk assessment and the measures to be taken at the premises to minimise this risk.
This could include clear signage (e.g. signs, floor tape or paint) for limits on the number people present in a particular area or room, queuing systems and one way systems.
Links to other relevant guidance
- General guidance on taking reasonable measures to minimise the risk of spreading coronavirus
- Public premises and workplace COVID-19 risk assessment
- Alert level 2: guidance for employers, businesses and organisations
- COVID Pass: guidance for businesses and events
- Self-isolation guidance
- Keeping records of staff, customers, and visitors: test, trace, protect
- Risk assessment during the coronavirus (COVID-19) pandemic on HSE.GOV.UK
- Ventilation during the coronavirus (COVID-19) pandemic on HSE.GOV.UK