Welsh Government’s Alert Level 0 guidance can be found here.
Please be aware that the regulations continue to change, and you should check gov.wales/coronavirus-law for the latest updates.
Whilst some of the external references were created for different sectors and working environments they have been included because they may also apply to your scenario.
PERMITTED NUMBERS INDOORS AND OUTDOORS
- There are no longer any limits on the number of people that may gather indoors or outdoors. However, the organiser of the activity must comply with section 3 below.
- It is important to be aware that the regulations apply to both the owner of the centre (hiree) and those undertaking the activity (hirer).
- The person responsible for the centre and the person organising the activity must carry out a risk assessment that would satisfy the requirements of Regulation 3 of the Health and Safety at Work Regulations 1999(1). Also, see RISK ASSESSMENT for further information.
and
- Reasonable measures must be undertaken. Community centres are considered to be ‘regulated premises’ according to the regulations. Therefore, it is a legal requirement that reasonable measures are undertaken to minimise exposure to coronavirus within the regulated premises. You should familiarise yourself with the REASONABLE MEASURES section.
RISK ASSESSMENT
Prior to reopening your community centre, you must undertake a specific coronavirus risk assessment in addition to any risk assessment you may already have in place. Your risk assessment must satisfy the requirements set out in Regulation 3 of the Health and Safety at Work Regulations 1999(1), regardless of whether you are subject to the regulations or not.
Where a regulated gathering is being held at the community centre, the person responsible for organising the gathering must complete and produce a risk assessment of that gathering. The person responsible for the centre should be in receipt of that assessment and should be comfortable that the organiser has complied with the requirements of the regulations to minimise the risk of exposure to attendees.
The person responsible for the regulated premises must provide information to persons working or volunteering at the premises about the assessment of the risk of exposure to Coronavirus. They must also advise them about the measures they have taken to minimise the risk.
See here for a specific coronavirus risk assessment template and guidance published by Welsh Government If you are unfamiliar with completing risk assessments, please see here for some examples.
It is important to be aware that the regulations apply to both the owner of the centre (hiree) and those undertaking the activity (hirer).
Publishing your plans and risk assessment may help to reassure staff, volunteers, the public and stakeholders and will clearly set out the changes and your expectations. For example, changing from booking in person to booking online and not accepting cash payments.
You are reminded to pay particular attention to Regulation 3 of the Health and Safety at Work Regulations 1999(1).
REASONABLE MEASURES
For the purposes of minimising the risk of exposure to or the spread of coronavirus, the person(s) responsible and the organiser of the activity must comply with the requirements set out in the regulations. The person responsible must:
- Undertake a specific assessment of the risk of exposure to coronavirus at the premises and must also consult those working on the premises or their representatives.
- Provide information to those entering or working at the premises about how to minimise the risk of exposure to coronavirus, including information to those working at the premises about the risk of exposure to coronavirus identified in the risk assessment, and the measures that will be taken to minimise the risk.
See this useful guidance from the HSE on talking to your workers about coronavirus.
- Take all reasonable measures to mitigate the risk of exposure to coronavirus that arises where persons gather on the premises, such as:
- prevent any person who has tested positive for coronavirus in the previous 10 days from being present at the premises
- prevent any person who has had close contact in the previous 10 days with a person who has tested positive for coronavirus from being present at the premises
- prevent any person experiencing symptoms associated with coronavirus from being present at the premises
- Ensure that persons gathering at the premises gather outdoors where this is practicable
- Limit close face to face interaction between persons on the premises, in particular face to face interaction, for example by
- changing the layout of the centre including the location of furniture and workstations (if applicable)
- controlling use of entrances, passageways, stairs and lifts
- controlling use of shared facilities such as toilets and kitchens
- controlling the use of or access to any other part of the premises
- installing barriers or screens
- Limiting the duration of time for which persons may be present on the premises
- Seeking to ensure that the premises are well ventilated see guidance on VENTILATION
- Maintaining good hygiene on the premises
- Providing or requiring the use of PPE
In addition, information must be provided to those entering the community centres on how to minimise the risk of exposure, such as safety and physical distancing signs.
Other measures that you could consider are:
- Not carrying out certain activities
- Closing a part of the premises
You must allow your staff/volunteers to isolate due to testing positive for coronavirus or having had close contact with somebody who has tested positive for coronavirus, for a period of time specified by the Welsh Ministers or a contact tracer.
You should collect contact information from each person at the premises and retain this information for 21 days. You should also try to make sure the information provided to you is accurate. For more information see TEST, TRACE, PROTECT.
See here for specific Welsh Government guidance on reasonable measures.
SELF-ISOLATION
As of 7 August 2021, fully vaccinated adults who received the vaccine in the UK and those aged under 18 will no longer have to self-isolate if they are close contacts of someone who has tested positive for COVID-19. They will be asked to take PCR tests on day 2 from the last contact with the positive case (or as soon as possible) and on day 8. The individual should take the tests even if they feel well.
The individual should also:
- Try to reduce contact with others and avoid crowds and especially indoor settings.
- They should consider using lateral flow tests on a daily or more regular basis for the time they would have otherwise been self-isolating.
- They should not visit vulnerable people such as those in care homes or hospitals.
- Work from home if they are not already doing so.
- Inform their employer that they are a contact of a case of COVID-19.
- Practise good hygiene and respiratory etiquette by regular washing of hands and wearing a face covering.
It is a legal requirement for a person aged over 18 to self-isolate if they have been asked to do so by a contact tracer.
Here are some suggested reasonable measures you may wish to consider implementing:
- Prevent people who are legally required to self-isolate from being present at the premises
- If the individual identified as a close contact is a worker or volunteer at your premises, you could consider whether that individual should be present at the premises. This depends on a number of factors including whether the work can be carried out elsewhere (such as from home); the impact the worker being away from the premises would have on the service being provided; and the risk the individual could pose to vulnerable persons should they continue to work at the premises.
- You could encourage employees and volunteers to notify you if they are identified as a close contact of a positive case. In order for you to consider reasonable adjustments such as physical distancing and the use of PPE or face coverings.
- Consider whether alternative duties may be appropriate to reduce the risk of transmission.
- Reinforce the importance of day 2 and 8 PCR tests as well as the use of lateral flow tests.
- Identify colleagues considered to be clinically extremely vulnerable and seeking to avoid contact with the close contact and avoid them working in close proximity.
- Consider whether to advise others of a close contact of a positive case. In this instance, you should try and avoid identifying the individual, where possible. Also, you should not provide any more information than is necessary. For further information see here for guidance from the Information Commissioner’s Office.
This is not an exhaustive list and other reasonable measures not referred to above may be appropriate.
PHYSICAL/SOCIAL DISTANCING
Physical/social distancing measures are actions taken to reduce interactions between individuals/households in order to minimise transmission of coronavirus. The specific requirement to maintain two metre distancing has been removed. Whilst, it is no longer a legal requirement, it is an effective measure and perhaps one of the easiest and most obvious measures to take.
Some other examples of reasonable measures may include staggering shifts/activities and reducing the number of people in the premises at any one time. WCVA recommends that you retain details of the steps you have taken to ensure ‘reasonable measures’ have been implemented and details of the adjustments you have made to comply with this requirement.
Changing the layout of premises, controlling use of entrances, passageways, stairs and lifts, toilets and kitchens, floor markings, one-way routes, removing or cordoning off furniture, setting out designated areas and safe queue management systems are some of the measures you could consider. Please note these are only suggestions of potential approaches and do not constitute a check list: each setting and scenario is different.
VENTILATION
Ensuring effective ventilation at premises has always been a legal requirement, but it is now even more essential as it plays an important role in reducing transmission of the virus. Your considerations around ensuring adequate ventilation should form part of your risk assessment.
You should be maximising fresh air through:
- natural ventilation, by opening windows, doors and air vents
- mechanical ventilation, by using fans or ducts
- a combination of natural and mechanical ventilation
- opening windows/doors before attendees arrive when they leave and between activities
Further guidance is available here from the Health and Safety Executive.
If your premises has been closed for some time, check to make sure you are still able to open the windows.
Also, see the advice available below:
Always consider health and safety and security implications, for example, fire doors must remain closed.
SAFETY AND PHYSICAL DISTANCING SIGNS
Welsh Government has created several bilingual signs that might be useful to you, see here. These signs can be printed and displayed at your premises. There are other options available on signage, including a wide variety of posters, labels and floor signage: please email rpgenquiries@wcva.cymru if you require information on suppliers.
HYGIENE
You should make arrangements for enhanced hand hygiene to prevent the risk of infection. Washing hands with soap and water for at least 20 seconds will help to kill viruses that may be on your hands. In the absence of soap and water, you should provide alcohol-based hand gel/rub. Washing hands is particularly important upon entering or exiting the premises, after the use of toilets and when moving within different rooms/locations within the premises. Posters and signs should be used to encourage individuals to wash their hands. Instructions on how to wash hands could be positioned near wash hand basins, a variety of illustrations and posters are available for you such as this. You should also ensure sufficient supplies and access to soap and water and should consider using lidded bins.
Good respiratory etiquette will minimise the transmission of coronavirus. ‘Catch it, bin it, kill it’ posters should be visible to remind individuals to continue good levels of hygiene. Bilingual printable posters available from the Public Health Wales website can be found here.
FACE COVERINGS
It is still a legal requirement to wear face coverings in all public spaces. Except where the person is aged ten or under or where the person has a reasonable excuse not to wear a face covering, or if they temporarily need to remove it for the reasons outlined below. You may wish to display this poster at your premises.
A community centre is identified as a premise in which, a person must wear a face covering. Visitors at your premises may have some questions about the use of face coverings, the following information may be of assistance.
A reasonable excuse not to wear a face covering is defined as, the person:
- is not able to put on or to wear a face covering because of a physical or mental illness, or because of a disability or impairment;
- is accompanying somebody who relies on lip reading where they need to communicate; or
- is escaping from a threat or danger and doesn’t have a face covering
You should not ask for proof as to why a person is exempt from wearing a face covering as not all disabilities are visible to others. However, the person should ensure they do have a reasonable excuse otherwise they risk being fined for not complying with the requirements. Some people may feel comfortable showing something that says they do not have to wear a face covering such as an exemption card, badge, lanyard or a home-made sign. This is a personal choice and not a legal requirement. Some useful examples of exemption cards and notes are available via the Welsh Government and Transport for Wales.
Face coverings should be worn at all times, and they must be worn correctly. However, the individual may have a reasonable excuse to temporarily remove the covering and some examples are as follows:
- to take medication
- to eat or drink
- to avoid harm or injury, either to the individual themselves or to others, such as alerting another individual to danger
If using a face covering or mask, you must not take it off and leave it on surfaces and you must not leave a face covering/mask below your nose or hanging off your chin. It is important that you are aware of how to wear and care for your face covering safely, see here for guidance from Welsh Government.
There are a limited number of cases where face coverings will not be required. For example, when you are seated to eat or drink. Face coverings must be worn when entering the premises and while waiting to be served at a counter (if applicable, for example) or to be seated; they must also be worn when moving around, such as when going to toilets or when leaving. Another example is if you are exercising. However, if you are preparing to exercise, changing or undertaking any activity that isn’t strenuous, especially when in close contact with other people, you will need to wear a face covering.
LATERAL FLOW TESTS
In Wales, people who cannot work from home, including volunteers are encouraged to test themselves twice a week, 3 to 4 days apart, using Lateral Flow Tests. Refer to this document for further information: COVID-19 workplace testing framework.
Lateral Flow Tests can be obtained online or in person, see below for details:
For an overview of lateral flow tests and instructions on how to take a lateral flow test, see here: https://gov.wales/lateral-flow-testing-people-without-symptoms.
If you get a positive test, you must self-isolate immediately for ten days and take a PCR test at a test centre within 24 hours. You can book a test online on GOV.UK, or by calling 119 between the hours of 7am to 11pm (calls are free) or via the NHS COVID-19 app.
TEST, TRACE, PROTECT
To control the spread of the virus WCVA recommends that you keep a record of attendees at your premises to cooperate with Welsh Government’s Test, Trace, Protect (TTP) strategy. You should also ensure those hiring the venue retain records for the same purposes.
The type of contact information you should obtain are as follows:
- the individual’s name
- telephone number
- the date and time at which the individual was at the premises
This information should be held securely and retained for 21 days and may be provided to the Welsh Ministers or contract tracers, upon their request.
Please note that Data Protection legislation does not preclude the sharing of data where there is an overriding public interest. However, you must ensure you inform individuals about how their data will be used. For example, plan for the likelihood that you may have to pass on their information to the Test Trace Protect scheme should they need their contact tracers to get in touch with the individual. We have been made aware of some instances where individuals leaving their details for Test, Trace, Protect have been contacted for other reasons, this is not permitted. It is important to leave the tracing aspect to the TTP team. Please also ensure that personal details of individuals are not openly on display for others to see.
You should review your privacy notices to ensure they are still compliant given the changes in circumstances. You are also encouraged to present the privacy notice directly to the individual (whether verbally or via a printed privacy notice) at the point when you collect their details. If you need help on drafting a privacy notice, the ICO has created a template which can be found here. Note that the lawful basis for collecting the data will not be legal requirement, because it is not a legal requirement for community centres to collect this information. However, it is a reasonable measure that you would be expected to undertake.
The ICO has also produced some useful guidance about collecting customer and visitor details which can be found here. See here for Welsh Government’s guide on keeping records of staff, customers, and visitors.
Note that it is an offence to provide false or misleading information to a contact tracer.
NHS COVID-19 APP
On Thursday 24 September 2020, the NHS COVID-19 app was launched in England and Wales. Welsh Government encourages organisations to display NHS QR posters on entry so that those who downloaded the app can use their phones to check in. Further information from Welsh Government can be found here and guidance here.
To create a QR code for display at your venue see here.
WCVA recommends that you also keep a register of attendees.
THE PERSON(S) RESPONSIBLE
The regulations reference a range of responsibilities for persons responsible. For clarity, the regulations contain the following definition:
‘The “person responsible for carrying on a business” includes the owner, proprietor, and manager of that business’.
ENFORCEMENT
An Enforcement Officer is defined in the regulations as a constable or police community support officer or a person designated by the Welsh Ministers, a local authority. The enforcement officer may:
- Issue a premise improvement notice where there are reasonable grounds for suspecting a contravention to the regulations
- Enter the premises where there are reasonable grounds for suspecting a contravention to the regulations
- Issue a premises closure notice where the requirements outlined in the compliance notice have not been met
For further information on enforcement, Welsh Government has published guidance for enforcement officers which can be found here.
VULNERABLE PEOPLE
Employers are under a statutory duty to ensure, as far as reasonably practical, the health, safety and welfare at work of their employees and volunteers, as well as owing them a duty of care. It is important to note that during this crisis a significant proportion of your employees/volunteers may have been or may currently be suffering with stress and anxiety and you should ensure support is in place. The Public Health Wales ‘How are you doing?’ campaign provides some useful resources here.
Some individuals may be worried that they are at a higher risk of developing more serious symptoms if they come into contact with coronavirus. In this case, WCVA recommends you undertake a specific risk assessment using this tool: Covid-19 Workforce Risk Assessment. It provides very useful guidance for both the individual and the employer. Further information about the tool can be found here.
You should also be aware of those individuals identified as being at an increased risk of coronavirus, as this group is advised to pay particular attention to the guidance on social distancing and hand hygiene.
The Healthy Working Wales website contains useful information and advice to support employers and employees and can be found here.
Welsh Government also encourages individuals to work from home where possible stating ‘employees should not be required or placed under pressure to return to a workplace setting if there is not a clearly demonstrated business need for them to do so’. See here for further information.
VOLUNTEERS
Organisations have a duty of care to volunteers, who must be afforded the same level of protection as any employee. See here for further information from WCVA and this guidance on volunteering after lockdown.
INSURANCE
It is very important to keep your insurance company informed of your activities. Your insurance company will require you to follow and adhere to all recommendations and guidelines issued by Welsh Government. You will need to inform your insurance company that you will be resuming services and discuss any new requirements you must consider, to ensure you comply with your insurance policy.
Thomas Carroll insurance brokers have produced guidance for organisations resuming their services, which can be located here and here.
TRUSTEES AND GOOD GOVERNANCE
Trustees have an important role to play, and you must take action to minimise the potential for spreading coronavirus amongst individuals within your premises and grounds. You must retain all documents on assessments made and minute all decisions taken.
In terms of governance arrangements during the pandemic, trustees are advised to familiarise themselves with the guidance made available by the Charity Commission, and keep abreast of changes and updates. For example, in June 2020, the Charity Commission produced guidance on reporting serious incidents during the coronavirus pandemic, further information can be found here.
It may be that you must adjust the nature of your services due to the coronavirus outbreak. If so, refer to your charity objectives in your governing documents to ensure any new services are in line with your objects.
If you decide to hold your board or committee meetings virtually, you may find this good practice guidance from The Chartered Governance Institute to be a helpful resource.
CONTRACTS AND HIRING OUT CENTRES
It is important to consult with those hiring out your centre, particularly those that hire regular slots. It may be, for example, that they require a larger room than they usually would as part of the reasonable measures they are undertaking.
You should also consider whether it is a requirement of the hirer to clean surfaces and equipment or whether this is something you will control. You must be confident that the cleaning is undertaken to the higher level now required and that the individuals are undertaking the rigorous requirements and following guidance on cleaning. See the section on CLEANING for further information.
It is recommended that you provide alcohol-based hand rub/gel/sanitiser at entrances/exits and in meeting rooms. You should also record the last time and date that cleaning was undertaken, and you could consider displaying this to reassure visitors to your venue.
You should give priority to essential services during the re-opening phase. Where the centre has several bookings, you may need to leave a longer period of time between the bookings to allow cleaning to take place and to prevent bottlenecks in footfall as people enter and leave rooms/the premises. You should also ensure that supplies such as sanitiser and cleaning materials are replenished.
You could consider issuing hirers with new conditions in light of coronavirus, in writing and attached to the usual hire agreement. The new conditions must be accepted by the hirer in writing (via a signature). Dolmans Solicitors, have kindly agreed to prepare some draft terms and conditions for organisations to use, they can be found here. You may choose to use some, or all of these terms, they are not compulsory for you to use but may help if you haven’t already revised your terms and conditions. It is very important that you read through the terms to determine which are the most appropriate for your organisation. You must also ensure that you and the hirer understand and abide by the terms, they apply to both parties. Please also note that the terms may need to be updated from time to time, to reflect any changes in legislation.
You should provide your hirer with a copy of your risk assessment. In addition, you must obtain a copy of the hiree’s risk assessment.
Those hiring your centre should be encouraged to bring their own food and drink as opposed to making food and drink at the premises, reducing cleaning required in the kitchen. Hirers bringing in their own equipment should also be encouraged to use their own sanitiser and wipes.
CLEANING
It is highly likely that your premises has been closed for some time and therefore you should undertake a general health and safety check before reopening. Legionella growth, for example, is an increased risk because water has been left stagnant. You should undertake a thorough deep clean and disinfection of the premises before re-opening. See HSE advice on legionella risks here.
Scouts Cymru has created a very useful checklist, which can be found here and may be used in conjunction with government guidance, not as a substitute.
Cleaning protocols should be put in place: you will need to decide how often cleaning/regular decontamination takes place and this will be based on your risk assessment. You should also record and display when cleaning has taken place. If the cleaning duties are not discharged to the hirers, you will need to ensure the individual responsible, e.g., the caretaker, has a clear schedule of hires and sufficient time is allocated to cleaning duties.
When considering your cleaning regime, you should refer to the guidance available from the Health and Safety Executive, outlined here. You should identify frequently touched surfaces such as door handles, light switches, etc, as these will need more regular cleaning than usual as well as reminding people to wash their hands. The guide suggests two approaches to cleaning: deep cleans and periodic cleaning. It also suggests that you limit movement and reduce people’s needs to touch objects and contains some helpful tips.
Where an individual shows symptoms of coronavirus, or has tested positive, waste must be put in a plastic rubbish bag and tied when full, placed in a second bin bag, tied and put into a suitable and secure refuse container for at least 72 hours before it is collected along with usual waste.
Unless the individual shows symptoms of coronavirus or has tested positive, you do not need to segregate waste and may dispose of waste as you normally do.
Note that mobile devices must also be cleaned, see here for more information.
This guide on decontamination-in-non-healthcare-settings also provides further useful information.
CLEANING PRODUCTS
Inevitably your demand for cleaning products will increase. If your usual supplier is unable to assist you, please email rpgenquiries@wcva.cymru if you require information on suppliers.
For information on choosing surface disinfectants see here from the Health and Safety Executive.
PERSONAL PROTECTIVE EQUIPMENT (PPE) SUPPLIES
PPE consists of items such as facemasks, aprons, gloves, visors, shoe coverings, etc. Surges in demand for PPE since coronavirus has seen a huge amount of counterfeit and non-compliant products enter the market: it is vital that you only purchase correctly certified products.
Your organisation may not require PPE, and this should be determined through your risk assessment and the latest available guidance. Public Health Wales advises there is no requirement for the use of PPE, except when providing direct personal/clinical care within two metres or where being within two metres of an individual cannot be avoided. Further and more detailed information can be found here.
If you decide that PPE is a requirement, it is important to note that in order for it to be effective, you must ensure you know how to use the PPE. It will only prevent the spread of infection if it is:
- Used and changed at the right time
- Accompanied by good hand hygiene
and
- Respiratory etiquette is applied
If using gloves and aprons for example, they are single use items only. Hands should be washed or gelled between service users and after removing gloves.
Self-contamination is very common when removing (doffing) PPE. Guidance for donning (putting on) and doffing (taking off) PPE is available here.
If you encounter any difficulties sourcing PPE, please email rpgenquiries@wcva.cymru. For public sector organisations please contact NPSCorporateServices@gov.wales.
EQUALITIES
Your strategy to resume services must recognise the needs and rights of individuals. For example, any new physical barriers that individuals may encounter, communication barriers, etc, should not impede the movement of people using walking sticks or wheelchairs, should be clearly visible and should not provide a hazard to people with sensory impairments. You could also consider, for example, providing a bag nearby for immediate disposal of tissues where individuals may need assistance with respiratory secretions.
USING THE VENUE FOR CHILDCARE USE
Centres that provide childcare or nursery provision should follow the relevant guidance made available by Welsh Government here.
SYMPTOMS
Please remember that if you develop one of the following symptoms:
- a high temperature: this means you feel hot to touch on your chest or back (you do not need to measure your temperature)
- a new, continuous cough: this means coughing a lot for more than an hour, or 3 or more coughing episodes in 24 hours (if you usually have a cough, it may be worse than usual)
- a loss or change to your sense of smell or taste: this means you’ve noticed you cannot smell or taste anything, or things smell or taste different to normal
You should follow the self-isolation guidance and apply for a coronavirus test.
There are different support arrangements available for each county. If you already have a liaison contact in your local authority and/or county voluntary council, we recommend that you remain in regular contact with them for practical support and changes in regulations and guidance.
Contact details are available here for local authorities and here for the local county voluntary councils.
This guidance has been written by Wales Council for Voluntary Action (WCVA) in response to enquiries from the voluntary sector in Wales. With thanks to Welsh Government, The Welsh Local Government Association (WLGA), One Voice Wales, Scouts Cymru and Ceredigion Association of Voluntary Organisations for their assistance, support and contributions.