On 14 May, further amendments were published to the Health Protection (Coronavirus Restrictions) (No. 5) (Wales) Regulations 2020. The consolidated version of the Regulations including all amendments had not been published at the time of publishing this Update.
The main purpose of the changes is to move Wales from Level 3 restrictions to Level 2 restrictions (Schedule 2 of the Regulations) from Monday 17 May. The main implications are as follows:
- All outdoor and indoor visitor attractions can open, with appropriate safety measures in place
- All cafés and similar facilities can re-open indoors as well as outdoors, with safety measures in place (such as table service only for food and drink; restricting to 6 the number at each table unless they are members of the same household; ensuring 2m between each household at all times; wearing face coverings when not sat at table; keeping records for Test Trace Protect and so on). Welsh Government’s full guidance for cafés and visitor attractions can be found here and useful guidance from UK Hospitality for cafés here.
- Lifting the prohibition on the use of community centres for entertainment purposes, such as operating as a cinema, bingo hall, bowling alley, indoor play centre, for gambling, as a theatre, concert hall or indoor visitor attraction, including acting as a museum or art gallery, as such places are now permitted to open. But the sale of alcohol remains prohibited in licensed entertainment venues where live or recorded music is played. When using a community centre as a theatre or concert hall, or when arranging such performances in a place of worship, the Welsh Government’s updated guidance for the performing arts should be followed closely.
- Organised group activities can be held for up to 30 people indoors and up to 50 outdoors, that number not counting children under 11 nor those working or providing voluntary services (by leading, stewarding, etc) at the event. Comprehensive safety measures must be in place. The guidance for organised activities, indoors and outdoors, for children aged up to 18 (age as of 31 August 2020) has been updated.
Where an activity is starting afresh, or re-starting after a pause, a full risk assessment must be prepared (or updated) in the light of the current regulations. Further information about this can be found on Cytûn’s website or the website of the Health and Safety Executive.
The opportunity has been taken in these amended regulations to clarify that the maxima of 30 indoors and 50 outdoors do not apply to religious services, provided that a service held indoors is held in premises ordinarily used for that purpose. This means that it is no longer permitted to hire a building not ordinarily used for worship in order to hold an indoor service with a congregation greater than 30. (Cytûn presumes that where a secular building is hired regularly for worship with over 30 people present, that this is still permitted, but is seeking clarification from the Welsh Government).
The Welsh Government has updated its guidance for places of worship and for community centres – but the guidance in its current form does not take full account of the move to Level 2, and there is therefore some contradiction and ambiguity in applying the guidance to the Regulations. Cytûn understands that these guidance notes will be updated shortly. The most obvious place where the guidance is not tailored to Level 2 is regarding serving refreshments in places of worship and community centres. Following discussion with officials from Welsh Government, Cytûn is for now recommending the following:
- Where a community centre or place of worship has formal café facilities, then these can be opened following the current guidance. This guidance must be followed in full even when food and drink is served free of charge or for a donation, for example following a service. Informal mixing is not permitted. A full risk assessment must be completed before providing food and drink.
- Where a centre or place of worship holds a current Food Hygiene Certificate, and a full general risk assessment has therefore been carried out (perhaps pre-Covid) and the location is known to the authorities, then food and drink may be served (for payment, for a donation or free of charge) if the centre can be arranged and operated as a café – table service only; restricting to 6 the number at each table unless they are members of the same household; ensuring 2m between each household at all times; wearing face coverings when not sat at table; keeping records for Test Trace Protect; and so on, in line with the guidance for cafés. A full risk assessment must be undertaken before doing so.
- Where no Food Hygiene Certificate is held, or where it is not possible to set out the centre in café format or follow the guidance, then food and drink should not be served at the present time. If those attending an activity in the centre wish to eat or drink, they should bring their own food and drink, which should not be shared between households.
The guidance for places of worship includes an updated section on ventilation. This provides a summary of the latest scientific information which emphasises the need for good ventilation when people from different households meet indoors. Unfortunately, this section is rather technical and difficult to interpret. In preparing a risk assessment, therefore, and preparing to open, Cytûn recommends instead using the more user-friendly summary of the same information in the guidance for community centres (scroll down) or the guidance from the Health and Safety Executive, especially the practical suggestions in sections 4-6. If the summer brings good weather, the simplest solution will be to keep external doors and windows (other than fire doors) open during services and events, but a full risk assessment should be prepared.
There is currently no update regarding congregational singing nor playing wind instruments indoors, but Cytûn understands that the Welsh Government has commissioned further scientific advice on this.
Cytûn hopes to receive further clarification of these matters from the Welsh Government, and Cytûn’s website will be updated regularly. It will also be updated to include clarified information regarding baptising and blessing children and regarding pastoral visiting.
In its announcement on May 14, the Welsh Government indicated that it hopes to move to Level 1 restrictions on June 7. This would permit organised activities for up to 50 people indoors and up to 100 outdoors where space and safety precautions permit. However, the Government also warned that the situation regarding the Indian variant of coronavirus means that there is no guarantee that such a step can be taken on that date.
[With thanks, as always, to the Revd Gethin Rhys.]