Considering risk assessments and compliance ahead of unlocking England’s leisure sector
Risk Assessments are processes used to identify and control risks. Keebles’ Risk and Compliance Partner and Head of Personal Injury Owen Brown discusses risk assessments applicable to health and safety, particularly in the workplace within the leisure sector amid Covid-19.
The coronavirus pandemic has introduced a serious new set of risks to the country. The initial response to this, repeated widely across the world, was to introduce a lockdown to keep people at home where possible to minimise the risk of transmission and infection.
As the perceived risk has reduced the UK government, and the devolved administrations, have gradually eased the lockdown to reopen the economy and as part of a slow return to normal.
One of the latest sectors the government intends to reopen in England and Wales is that of indoor gyms and swimming pools on the proposed date of 25 July 2020. Outdoor gyms and swimming pools have been able to reopen since 4 July 2020.
In recent months, the difficulties facing the government have been to balance the increase risk associated with reopening the economy with the need to try to return the country to some sort of normality. As with other sectors that have been allowed to reopen the government has published detailed guidance to help the sector reduce that risk.
On 11 July 2020 the Department for Digital, Culture, Media and Sport published detailed guidance for indoor gyms and swimming pools. The guidance was prepared in consultation with trade bodies, ukactive and the Sport and Recreation Alliance and with Sport England and other sports bodies, and in consultation with Public Health England and the Health and Safety Executive.
It is a requirement of reopening that gyms and swimming pools can operate with social distancing in place. The guidance covers this and the need to enhance cleaning and consider protective personal equipment where appropriate.
At the heart of the guidance is the need for gyms and swimming pools to carry out a formal Covid-19 Risk Assessment. The guidance is in addition to existing legislation, such as workplace health and safety regulation. These already require detailed risk assessments to be carried out to ensure the health and safety of employees, visitors and others.
The aim of any risk assessment should be to reduce the risk of infection to the lowest level reasonably practicable and the guidance makes clear that this applies to an organisation’s Covid-19 Risk Assessment.
As with guidance for other sectors that have been reopened this guidance covers increased cleaning, the need for social distancing to be maintained, the installation of barriers or screening and, as a last resort, the provision of suitable personal protective equipment.
The guidance includes specific recommendations to limit group sizes, to introduce pre-booking of sessions to help avoid this and to encourage users to travel to and from the facility in their gym kit and to shower at home to avoid use of showers and changing rooms. The guidance also recommends avoiding the playing of music at levels which would require people to raise their voices to speak as this reduces the risk of aerosol and droplet transmission.
Employees and customers will need to be educated and given guidance on the measure implemented so that they know where, for example, a one-way system has been introduced to help maintain social distancing.
Considerations for businesses
In preparing their Covid-19 Risk Assessment organisations should also consider the wealth of general Covid-19 specific guidance that has been issued by the government and various trade bodies.
It is always good practice to make health and safety Risk Assessments available to those affected, such as by providing employees with a copy. The general position with the Covid-19 specific guidance issued in the last few months is that a Risk Assessment should be published on the organisation’s website and this particular guidance makes clear that the government would expect this to be done for all employers with 50 or more employees.
As life, hopefully, begins to return to normal, Risk Assessments will be at the heart of allowing employees and others to return safely to work.