Re-opening hospitality venues after lockdown has caused many headaches. Apart from the obvious ones of staffing level, restocking there has been the major problem of dealing with Risk Assessments for premises.
To help with this Public Health England have published a number of downloadable guides. You can access these here. The guides are split into a wide range of sectors and we would recommend considering these guides and putting a copy with your Risk Assessment. It would also be sensible to provide a copy to managers and staff so they are aware of their contents.
With recent localised lockdowns often being tracked back to pubs this is a very relevant issue. The position across the UK varies, but Welsh Minister Eluned Morgan was reported recently as saying that businesses must continue to keep all measures in place to remain COVID-19 safe. The Minister said:
“I’d like to finish by saying this to the small minority of people and businesses who aren’t. We will take action to enforce the rules in Wales. Ignoring the legal requirements to minimize the risk of spreading coronavirus on premises cannot be an option.”
It is clear that closure and the loss of Premises Licence is a real and present danger for those found to be ignoring guidance and ending up a hot spot.
COVID-19 risk assessments have been necessary for most venues on re-opening, and now, where a new licence is being applied for, Environmental Health are often asking to see this during the application process.
The assessments have to cover a wide range of areas, including:
- Dealing with the risks of contracting COVID-19 from direct and indirect contact with customers / visitors / staff and avoiding transmission whilst serving and preparing food and drinks (including takeaways) and the general use of the premises.
- Dealing with these risks involves not only the headline issues of collecting customer details, limiting sizes of bookings and spacing of tables. You need to also drill down on procedures in kitchens, service areas and front of house to avoid transmission. Perspex screens at the tills and bars, and stickers on the floor about social distancing, are only a very small part of the answer.
- Cleaning arrangements of premises are a major factor, and in particular the cleaning of toilets and washing facilities. What notices do you want to put up to remind people of the problems and what you are doing to minimise risk and what customers can do to help.
- Venues have needed to consider possible one way systems, ordering from tables via apps, limiting waiting staff to certain areas and many more. You may want to have a staff member assigned to the door to deal with customers who come in - what do you do if they haven’t booked?
- Don’t forget the use and washing of plates, cutlery, even the condiments on the table?
- How are you taking payment? Cash seems to be non-existent as a means of payment nowadays.
- The guidance state only two households should meet - how are you covering this? What about supervising children to stop them moving around?
- Takeaways can cause particular problems, should customers wear face masks, where will they wait for collection. What if they ask for a drink while they are waiting?
- There are many issues to consider, and the risks should not be ignored.
We hope that this note is helpful. Do contact a member of our Licensing team if we can assist with any specific queries.
The law is constantly changing and the position set out in this note may not be current. You should not rely on this note as a comprehensive statement of the law. Please contact us if you require specific legal advice on your situation.