How to make your hotels and guest accommodation COVID-19 Secure
The government has published guidance for people who work in or run hotels and other guest accommodation which allows them to re-open from Saturday 4 July 2020, provided they have followed the guidance (the “guidance”). We highlight some of the key points in our update below.
Who does this guidance apply to and the “one-metre plus” rule?
In the biggest easing of lockdown in the England yet, the Prime Minister has also announced that the 2m social-distancing rule will be replaced with a “one-metre plus” rule. This means people should stay at least 2m apart where possible, but otherwise remain at least 1m apart while taking steps to reduce the risk of transmission, including some of the steps outlined below.
The guidance applies to hotels and other guest accommodation including hostels, motels, inns, pubs, student accommodation, holiday parks, B&Bs, short term serviced accommodation, guest houses, caravans, campsites, chalets etc.
Where there are additional facilities attached to the guest accommodation, for example restaurants, bars, leisure facilities or retail shops; then it is critical that you check whether those facilities can reopen under current government guidelines (spas and indoor gyms must currently remain closed).
Managing and assessing risk
The guidance sets out practical steps for hoteliers on the management and assessment of risk. You should implement this in readiness to re-open on 4 July 2020.
Manage risk – businesses must assess and manage the risks of COVID-19, including the risk to your workers, volunteers and customers. As an employer, you have a legal responsibility to protect workers and others from risks to their health and safety recognising the routes of virus transmission and the steps that you can take to eliminate or control this. You cannot completely eliminate the risk of COVID-19 but you should take reasonable steps to control it. Remember the hazard is the spread of the virus within your property and you are taking steps to reduce the risk of this occurring, so protecting your staff, guests and contractors;
Carry out a COVID-19 risk assessment, in consultation with workers or trade unions – the guidance operates within current health and safety, employment and equalities legislation. Employers must carry out a COVID-19 risk assessment in consultation with their workers or trade unions, to establish and regularly review what control measures to put in place. If you have fewer than 5 workers, or are self-employed, you do not have to have a written risk assessment but doing so will be useful if someone challenged your approach; and
2m or one-metre plus risk mitigation – you should consider the building; its physical layout and your business model. What additional controls for staff, and guests, could you include to reduce or eliminate transmission of the virus: (i) increasing the frequency of handwashing or hand sanitising and surface cleaning (such as disinfection of high footfall or common touchpoints and toilets), (ii) use back-to-back or side-by-side working (rather than face-to-face) wherever possible, (iii) reduce the number of people each person has contact with by using fixed teams or partnering and (iv) using fixed screens or barriers to separate people from one another.
Industry specific guidance
You should consider how you turn around your rooms as guests leave. Will this be on the same day? You need to factor in the additional staff time required to carry out an enhanced disinfection regime. Or whether you want to take used rooms ‘off line’ to enable effective cleaning. Remembering that you need to train your staff with your new hygiene standards.
Various organisations such as UKHospitality, the Meetings Industry Association and Association of Event Organisers have published specific guidance to assist with hotel operations including corporate events.
A downloadable COVID-19 Secure notice is available, which employers should display in their workplaces, and on their website to show their employees, customers and other visitors that they have followed the Government’s guidance.
Local authorities are empowered to take a range of actions to control workplace risks. For example, this could require the employer taking action to ensure social distancing in reception and bar areas, perhaps by using staff to patrol the area.
Failure to complete a risk assessment which takes account of COVID-19 or completing a risk assessment but failing to put in place sufficient measures to manage the risk of COVID-19 would constitute a breach of health and safety law. The enforcing authority may issue enforcement notices to prohibit dangerous activities and secure improvements. Serious breaches and failure to comply with enforcement notices can constitute a criminal offence, with significant fines and even imprisonment for up to two years.
If you require urgent help in the meantime or have any questions relating to this guidance and how it applies to your business, please get in touch.
This update is for general purposes and guidance only and does not constitute legal or professional advice. You should seek legal advice before relying on its content. For advice, get in touch with your usual Greenwoods GRM contact or scroll down to complete our enquiry form.