Risk assessment/staff training

Employers have a legal responsibility to protect people from harm. This includes protecting your workers and customers from the coronavirus.

This information will help you to think about all the areas that you need to work on to be COVID-secure for everyone while running your business.

Here is a checklist on what you need to do to carry out a risk assessment:

  • identify what activity or situation might cause the spread of the virus
  • think about who could be at risk
  • decide how likely it is that someone could be exposed
  • remove the activity or situation, or if this isn’t possible, control/reduce the risk
  • contact your insurance company - some are requiring businesses to have their risk assessment written down as part of their cover

If you have less than 5 employees, you do not have to write anything down, but it might help if you do. You can use this basic risk assessment template.

Find an example Covid risk assessment and risk assessment guidance.

Training

Staff must be well trained on the plans you have in place and be regularly reminded and supervised. Posters may also be helpful.

Please see the posters and visual guides:

Who should go to work

You should plan for the minimum number of people needed at your premises for it to work safely and effectively. Any staff that are ‘extremely vulnerable’ or ‘vulnerable’ must be individually risk assessed.

You are required by law to report if a member of staff has tested positive for COVID-19 on the Health and Safety Executive’s website.

Curfews

All hospitality and leisure businesses must abide by the national curfew. 

Restricted businesses are to close at 10pm until 5am.

Delivery can take place after 10pm and/or food can be given to a person in a car so long as the person in the car does not leave the car.

Cinemas, theatres and concert halls – performances can carry on at, or after, 10pm to allow a performance to finish which began before 10pm, but food and drink supply must stop at 10pm.

Find a list of restricted businesses or services and exemptions.

Face coverings

Clarification on a Face Covering – “a face covering is something which safely covers the nose and mouth” and “must securely fit round the side of the face”. Unfortunately, a visor does not count as a face covering.

It is still imperative that social distancing is observed wherever possible even when face coverings are being worn.

Staff and customers of venues that provide food and drink are now required by law to wear a face covering, unless they have an exemption. The face covering must be worn before entering any of these settings and must keep it on until leaving or if there is a reasonable excuse for removing it. 

Businesses must remind customers and staff to wear a face covering where required (for example by displaying posters).

Face coverings for staff

It is compulsory for retail, leisure and hospitality staff to wear a face covering in areas that:

  • are open to the public 
  • where they come, or are likely to come, within close contact of a member of the public

This includes shops, supermarkets, bars, pubs, restaurants, cafes, banks, estate agents, post offices and the public areas of hotels and hostels.

The new requirement for hospitality staff to wear face coverings only applies to consumer-facing staff and not ‘back of house’ kitchens or office areas of hospitality premises. Staff working ‘back of house’ will only have to put on a mask if they move into public customer-facing areas of the business e.g. staff will need to wear a face covering when moving from the back kitchen into the seating area where customers may be present.

If businesses have taken steps in line with Health and Safety Executive guidance for COVID-19 secure workplaces to create a physical barrier, such as a plastic screen, between workers and members of the public then staff behind the barrier will not be required to wear a face covering. However, you are urged to discuss the installation of any screens/barriers with your inspecting officer before you spend money on something that may not be suitable.

Businesses already have legal obligations to protect their staff under existing employment law. This means taking appropriate steps to provide a safe working environment, which may include providing face coverings where appropriate, alongside other mitigations such as screens and social distancing.

Businesses should advise workers how to use face coverings safely.

This means telling workers:

  • wash your hands thoroughly with soap and water for 20 seconds or use hand sanitiser before putting a face covering on, and before 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 or if you’ve touched it
  • continue to wash your hands regularly
  • change and wash your face covering daily
  • if the material is washable, wash in line with manufacturer’s instructions, if it’s not washable, dispose of it carefully in your usual waste
  • practise physical distancing wherever possible

Please be mindful that the wearing of a face covering may inhibit communication with people who rely on lip reading, facial expressions and clear sound.

For other indoor settings not mentioned above, employers should assess the use of face coverings on a case by case basis depending on the workplace environment, other appropriate mitigations they have put in place and whether reasonable exemptions apply.

Face coverings for customers

Customers must wear a face covering at all times when in premises providing hospitality (bars, pubs, restaurants, cafes), except when seated at a table to eat or drink.

Businesses should take reasonable steps to encourage customer compliance for example through in-store communications or notices at the entrance. If necessary, police can issue fines to members of the public for non-compliance. Businesses will not be required to provide face coverings for their customers.

Some people don’t have to wear a face covering including for health, age or equality reasons. No one who is exempt from wearing a face covering should be denied entry if they are not wearing one.

Find the full guidance on face coverings.

For more detailed advice on complying with the law around face coverings, please contact the police on: 101 and ask for Police Licensing, or send an email to brighton.licensing@sussex.pnn.police.uk.

Physical distancing rules apply to staff and customers

You must maintain physical distancing wherever possible throughout the premises.

This includes:

  • customer areas
  • front of house
  • back of house
  • staff areas

2 metres is the goal. If this is not achievable, 1m plus is acceptable as long as you have extra controls to prevent the spread of COVID-19.

Please consider the following to maintain physical distancing:

  • work out what is a safe number of people in your premises to allow physical distancing throughout
  • you should not allow people to:
    • gather indoors or outdoors in groups of more than 6 people (unless from one household/support bubble)
    • interact socially with anyone outside the group they are attending a place with, even if they see other people they know
  • staff could be asked to arrive and leave at different times, especially if they need to get changed
  • think about leaving enough time between bookings for customers to come and go without meeting each other - phone and online bookings are recommended
  • arrange for goods to be delivered at different times and when you are closed to customers
  • queuing should be avoided as much as possible - if it cannot be avoided, then it must be managed to allow physical distancing
  • walk routes around the business, paying attention to narrow and busy areas

Customer seating

Customer seating (inside and outside) must be physically distanced. Measure the distance from customer to customer as seated, not from table to table. See our COVID-19 safe-seating visual guides.

It is important to note that it is now illegal to meet up socially with more than 6 people who are not within the same household/bubble, even if social distancing is undertaken. This applies inside and outside.

Restaurants and hospitality venues can still host larger numbers in total, but groups of up to 6 must not mix or form larger groups.

Table service

Restricted businesses that serve alcohol for consumption on the premises must ensure:

  • the food or drink is ordered by, and served to, a customer who is seated on the premises
  • they take all reasonable steps to ensure that the customer remains seated while consuming the food or drink on the premises

Restricted business that do not serve alcohol for consumption on the premises, must takes all reasonable steps to ensure that the customer remains seated while consuming the food or drink on the premises.

Taking orders can be done in a few ways, having an app could be one option.

When you are serving customers and clearing away, you could think about placing a tray on the table for the customers place their used crockery onto, or place a trolley or foldaway table at the end of the table. Tables should not be pre-laid with cutlery, glasses or condiments.

Limit the number of staff working in the kitchen/servery/bar and limit staff movement by giving them permanent areas to work in. Think about back to back or side to side working and communication when staff need to move around.

Put up signs for customers and staff as a reminder about physical distancing.

If you use staff to manage queues or entry points, please ensure they do not block or partially block these areas so that customers can pass by using physical distancing.

Find a list of restricted businesses or services and exemptions.

Ventilation

Good ventilation can help reduce the risk of coronavirus spreading.

Look to improve ventilation throughout the whole premises:

  • back of house including stock rooms and so on
  • front of house, including toilets, corridors and so on
  • staff areas

Natural ventilation

Where possible, think about ways to increase the supply of fresh air by opening windows and doors. Think about fixing fly screens where they may pose a risk to food/food surfaces or equipment.

Mechanical ventilation

You can use most types of air conditioning as normal. However, if you use a ventilation system that circulates air to different rooms you should consider turning off recirculation and use a fresh air inlet supply.

Try to improve the circulation of outside air in occupied spaces by using things like ceiling fans, desk fans or opening windows.

You do not need to adjust air conditioning systems that mix some of the extracted air with fresh air and return it to the room, as this increases the fresh air ventilation rate.

You do not need to adjust systems in individual rooms or portable units as these operate on 100% recirculation.

With mechanical ventilation, take care you do not direct air flow at other seated customers to reduce the risk of them breathing in droplets excreted by infected people.

If you’re unsure, ask the advice of your heating ventilation and air conditioning (HVAC) engineer or adviser.

Find further guidance on air conditioning and ventilation

Cleaning/disinfection

You must keep your venue clean to prevent the spread of coronavirus through touching contaminated surfaces.

Surfaces that touch food (food contact surfaces)

Carry out two-stage cleaning on all food contact surfaces, as is usual good hygiene practice. This means cleaning first and then disinfecting/sanitising afterwards (leaving the chemical on the surface for the time recommended by the manufacturer (this may be on the back of the bottle). 

The chemical disinfectant you use must meet British Standards: EN 1276 or 13697

A quick acting disinfectant/sanitiser (for example, 30 seconds) is best.

Plates, cups and cutlery

Please remember to disinfect/sanitise plates, cups and cutlery to prevent the spread of COVID-19.

This can be done with the use of:

  • an effective dishwasher
  • a chemical disinfectant/sanitiser  
  • hot water not lower than 60C - this temperature will not kill bacteria, only viruses

If you are using condiments in bottles, these must also be adequately cleaned between customers. 

You should also remove all table cloths and thoroughly clean and disinfect the table between customers.

Surfaces frequently touched by hands (hand contact surfaces)

All hand contact surfaces in the business (customer and staff areas) must be adequately cleaned and disinfected/sanitised. Think about high traffic areas and items that are being handled like: 

  • laminated menus
  • light switches
  • handles
  • tills
  • pens
  • beer pull handles

If your menus cannot be cleaned, then opt for disposable ones or hands-free menus such as chalk boards.

All customers should be encouraged to pay with a card or through an app. However, where this is not possible staff should follow this guidance:

  1. The till operator should wear a glove to take money - assume the money is contaminated
  2. Put the money into a quarantine box and leave it there untouched for 3 days - the virus can survive for 3 days on money - or disinfect the money
  3. Remove the glove and give change from the till using your hand
  4. Place the money in a dish and push it towards the customer - disinfect the dish at the beginning and end of each day
  5. Remove the glove when not at the till - “easy glove” is good for this 

Use the same disinfectant/sanitiser chemical as used on the food contact surfaces in the kitchen or you can use a diluted bleach spray.

Find cleaning and disinfection advice

Toilets

Public toilets should be kept open to promote good hygiene but kept clean and allow physical distancing.

Suggestions include, but are not limited to:

  • encourage physical distancing – limit the number of customers allowed into the toilet at one time, like using one in one out, and use floor markers to show where customers may queue
  • make hand sanitiser pumps available at entry/exit points to the toilet
  • ensure hot water, liquid soap and hygienic hand drying facilities are available, like paper towels - avoid the use of fabric reusable towels
  • keep the toilet well ventilated by fixing windows open and, where privacy is not affected, doors too
  • clean the areas more regularly, set clear guidance for staff, have a cleaning schedule on display
  • empty bins more often/provide more waste bins
  • use signs/poster to show good handwashing technique

Collecting customer information/data gathering

It is mandatory for hospitality businesses to help the NHS ‘Test and Trace’ service by keeping a temporary record of your customers and visitors for 21 days. 

You are required by law to register for and display the NHS Covid app QR code.

You are now required by law to help the NHS ‘Test and Trace’ system to identify and notify people who may have been exposed to the virus. 

You must:

  • ask at least one member of every party of customers or visitors - up to 6 people - to provide their name and contact details
  • keep a record of all staff working on their premises and shift times on a given day and their contact details
  • keep these records of customers, visitors and staff for 21 days and provide data to NHS Test and Trace if requested
  • register for an official NHS QR code and display the official NHS QR poster, so that customers and visitors can ‘check in’ using this option as an alternative to providing their contact details
  • adhere to General Data Protection Regulations by keeping only the information required, storing it safely so no one else can see it and destroying it after 21 days

Hospitality venues must also refuse entry to those who refuse to participate.

For an explanation on how the NHS app works, watch these short videos:

For a wealth of resources including posters and leaflets on how the NHS app works and how to register for and create a QR code please see:

Download and print resources to support visitors at your local business or organisation.

Bad weather plans

Have a plan in place for when the weather turns bad. Customers seated outside may try to move inside when there is no room to do so safely.

You could advise customers on arrival, that if the weather turns bad, they will not be able to move from their outside seating to other areas of the premises without first checking with a member of staff. The member of staff will assess if there is room to safely move.

Entertainment

Maintain physical distancing when providing entertainment and discourage raised voices, shouting, singing, dancing or chanting.

Consider things like:

  • not playing loud music or broadcasts that encourage raised voices shouting, singing, dancing or chanting
  • encouraging online or phone booking and tickets
  • communicating the arrangements for, and limits on, entertainment to customers in advance or with posters
  • have staff supervising customers

As of 15 August physically distanced indoor and outdoor performances can take place in line with this guidance, though we encourage organisations to continue to work outdoors wherever possible. 

Find government advice on entertainment.

For further advice on this please email the Licensing Team at ehl.safety@brighton-hove.gov.uk.

Off sales

A new law is due to come into force at the end of July, which will allow any premises with an ‘on sales’ only licence to add ‘off sales’ to their licence for a temporary period, until September 2021.

If you already have on and off sales on your licence, you may need to check your conditions to ensure that you don’t have restrictions which make it difficult to work to your new model of operation. Email the Licensing Team for advice on variations at ehl.safety@brighton-hove.gov.uk.

Alongside the new law there will be a streamlined process for placing table and chairs on the pavement outside your premises (pavement licence).

Find more information about pavement licences.

Government guidance and other useful links

Contact information

Food and Health & Safety Team

Thank you for acting responsibly and enabling the city to reopen safely

Download the checklist.