What is the guidance for step four trading?
Earlier this week (Monday 12 July), the Government confirmed step four of the roadmap could be reached on 19 July and promised guidance for businesses.
This has now been unveiled, providing an overview of the measures pubs should consider when trading.
The announcement reaffirms many of the same practices which were set out in the mandatory guidance for operating last year, but are now advised rather than compulsory measures. The guidance is available here.
The Morning Advertiser has distilled the guidelines into segments:
Risk assessments
The guidance begins by stating by law, employers must protect workers and others from risks to their health and safety, which includes risks from Covid-19 as it calls the virus a “workplace hazard” and should be treated the same as other “workplace hazards”.
It mentions this includes completing a “suitable and sufficient assessment of the risks of Covid-19 in the workplace” and “identifying control measures to manage that risk”.
It goes on to emphasise that those who do not carry out a sufficient and suitable risk assessment and do not put sufficient control measures in place may be considered to be breaching health and safety law.
This suggests that while conducting a risk assessment is not a legal requirement for operating during the pandemic, as it was previously, those who do not could face a health and safety breach.
Risk assessments do not have to be written down if a business has fewer than five workers.
Test and Trace
From 19 July, pubs are no longer legally required to collect customer data but are encouraged to. If they wish to do so, they can use the NHS QR code poster and have a system in place to record details for people who do not have the app.
However, operators do not have to ask guests to check in or refuse entry if they do not do so.
Social distancing
Legal limits on social distancing are being lifted from 19 July meaning there is no mandated requirement for social distancing.
However, the guidance does suggest operators continue to use screens at points of service, reduce the number of surfaces touched by guests and staff and encourage contactless payments.
Face coverings
Another legal change is the use of face coverings. From next Monday, coverings will no longer be mandatory for customers or staff however, the guidance states the Government is recommending they continue to be worn in enclosed and crowded spaces.
It also says if staff choose to wear a face covering, employers should support them in doing so.
The Government goes on to suggest when businesses are deciding whether to ask customers and employees to wear face coverings, they will need to “consider the reasonable adjustments needed for staff and clients with disabilities. You will also need to consider carefully how this fits with other obligations to workers and customers arising from the law on employment rights, health and safety and equality legislation”.
Table service
While the table service mandate will be lifted, the guidance is asking operators to encourage guests to use contactless ordering such as via an app, to consider using screens at points of service as well as discourage customers to self-serve and ensure staff are cleaning frequently touched surfaces regularly.
In addition, it also advises contact between kitchen workers and front of house staff should be minimised and suggests using zones where delivery drivers can collect food items.
Signage
The guidance also calls on operators to consider providing clear guidance for guests upon entry, encouraging hand washing.
Toilets
Signage should also be used in toilet facilities to encourage guests about hand hygiene and operators should ensure hand sanitiser is available on entry and increased frequency of cleaning overall with a visible cleaning schedule.
Vaccine passports
While Covid-status certification scheme isn’t mandatory, in the guidance it urges operators to consider the use of the NHS Covid Pass.
It says the Government will work with organisations that operate large, crowded settings (such as nightclubs) where guests are likely to be in close contact to a large number from other households to use the Covid Pass as a condition of entry.
Ventilation
The information urges operators to use ventilation in a bid to mitigate the risk of aerosol spread of coronavirus in enclosed spaces.
It suggests opening windows, air vents and doors to help with natural ventilation, using mechanical ventilation that maximise fresh arm and minimise air recirculation as well as identifying any poorly ventilated spaces as part of the risk assessment.
The guidance goes on to say operators can “encourage the use of outside space where practical, in particular for higher risk activity such as exercise or when people are singing or raising their voices”.
Tests and vaccinations
The only mention for businesses with regards to tests and vaccinations is to encourage operators to continue putting measures in place to reduce the risk of Covid-19 spreading even if workers have received a negative test result, had either one or two doses of the vaccine or have natural immunity (based on proof of a positive PCR test in the past 180 days).
It also outlines that if testing is being provided on site, it should be carried out safely and with control measures in place to manage the risk of the spread during the testing process, which could include frequent cleaning, good hygiene and adequate ventilation. This is in addition to urging operators to ensure an appropriate setting is available for those waiting for their test to be processed.
Furthermore, the guidance signposts where tests are available for those with Covid-19 symptoms, information regarding lateral flow tests and guidance on options for workplace testing.
Dance floors
Venues that have dance floors should look into using a CO2 monitor to help check ventilation levels and if they are poor, consider steps to improve the fresh air flow.
