Last reviewed 16 July 2020
The Government has issued further guidance for employers to enable food businesses to carry out their activities while keeping employees and others, such as customers, safe. Louise Dawkes considers the specific guidance for restaurants, bars and cafés, giving practical suggestions for workplace safety and other sources for help, advice and support.
An employer must protect the health, safety and wellbeing of workers as well as others who are affected by the business such as customers, delivery personnel, enforcement officers, etc.
It is important to remember that health and safety and food safety laws and regulations are still in place and the Covid-19 regulations are in addition to these. The local authority is responsible for enforcing the Covid-19 regulations and will therefore be checking that there is legal compliance in all areas. Non-compliance is likely to lead to advisory improvement notices, but serious breaches could result in formal actions.
The first step is to carry out a coronavirus risk assessment; this is the same as normal risk assessments but using guidelines to cover the specifics of this novel infection. The risk assessment will identify measures to reduce the risk of infection to the lowest reasonably practicable level.
Risk assessments must be made in conjunction with workers and unions where appropriate and cover all people who will be affected. It is worth noting that there are high levels of anxiety about returning to work and employers must therefore be mindful of this when discussing risk assessments with workers.
The risk assessment does not need to create extensive or complex documentation and if there are fewer than five workers in the organisation or you are self-employed it does not need to be recorded. It is, however, beneficial to keep records and for businesses with more than five workers this is a legal requirement — even if not all five will be on duty at the same time
The main provisions for working safely and securely in the pandemic are well documented, but to summarise:
always apply social distancing where possible — 2m or 1m+ with mitigating actions
ensure frequent and effective handwashing and surface cleaning and disinfecting
where social distancing cannot be achieved use other mitigating measures to reduce risk
ensure workers understand the need to report signs and symptoms of Covid-19 in themselves and household members and the need to self-isolate where necessary
personal protective equipment (PPE) is the last resort for managing the risk of Covid-19 in a food business — there are specific guidelines about appropriate and effective use.
Ideally use signage, markers, and posters to support measures — these are available from the local authority or Health and Safety Executive. Covid-19 is transmitted person-to-person either directly or indirectly and is not transmitted in food. The mitigating measures reduce the risk of person-to-person infection and sit alongside food safety controls already in place to control food hazards.
It is recommended that all businesses display a notification of the steps taken to ensure safety and security in a prominent place. The “5 steps to safer working together” notice is available for download from GOV.UK.
Keeping customers and visitors safe
The opening up of food businesses is being supported by NHS Test and Trace. To assist this service, businesses should keep a temporary record of customers and visitors for 21 days, in a way that is manageable for the business, and assist NHS Test and Trace with requests for that data if needed. This could help contain clusters or outbreaks. Many businesses such as restaurants that take bookings, have systems for recording their customers and visitors, but cafés and pubs will need to implement this; Track and trace is designed in line with data protection legislation, and further guidance can be found on the Government website.
Indoor gatherings should only be occurring in groups of up to two households (including support bubbles) while outdoor gatherings should only be occurring in groups of up to two households (or support bubbles), or a group of, at most, six people from any number of households.
At the moment venues are not allowed any live performances in front of a live audience. All venues must also take steps to avoid people needing to shout at each other, which includes playing music at a volume that makes normal conversation difficult. This is to reduce the potential for aerosol transmission.
Practical steps to minimise risk and comply with regulations
As the Government guidance explains, various practical measures can be effectively introduced at minimal cost. During the risk assessment process, the workers can be encouraged to discuss these to ensure co-operation and inclusion in the safe return to work. Many people are keen to get back to work but are understandably nervous about the risk to themselves and their families. This must not be underestimated.
Before opening the food business for trading, a deep clean and maintenance check should be carried out. See our feature Deep cleaning the workplace.
Check for any signs of pests as there have been reports of a significant increase in rats and mice in some places.
Ventilation is essential in a food business but is also useful for reducing the risk of Covid-19 — deep-clean ventilation systems and if doors and windows need to be opened, ensure these are adequately screened against flying insects. Outside eating areas that are covered must also be well ventilated.
The following are the 5 steps to safer working together.
Carry out a Covid-19 risk assessment.
Provide cleaning, handwashing and hygiene facilities in line with guidance.
Take all reasonable steps to help people work from home.
Take all reasonable steps to maintain a 2m distance in the workplace.
Where people cannot maintain a 2m distance, ensure a 1m distance and taking all mitigating actions possible to manage transmission risk.
For all food businesses where customers will be entering the business premises, calculate the maximum number of customers that can reasonably follow social distancing guidelines (2m or 1m with risk mitigation). It is important to identify how changes, such as queues will impact on the outdoor areas and neighbouring businesses. Ensure that clear guidance on ‘”house rules”’ for social distancing are displayed prominently. It will be necessary to train workers to ensure they are confident and competent to deal with customers queries and concerns and to challenge breaches of social distancing. Toilet areas must also be risk assessed with mitigating actions to reduce the risk of infection transmission.
See the feature How to make your toilet facilities coronavirus-safe.
The following are examples of measures and mitigating actions that a food business can use to reduce the risk of Covid-19 transmission, in no particular order:
update workers on handwashing and hand hygiene and encourage them to be ambassadors for good hygiene
provide hand cleansing stations for customers: a handwash basin with soap (if possible) and hand sanitiser
increase frequency of handwashing and surface cleaning, ensuring sanitisers or disinfectants are effective against bacteria and viruses
provide hand conditioner for staff as increased use of hand sanitiser and handwashing can cause dry skin and can lead to eczema or dermatitis
for handwashing, paper towels should ideally be provided (with a bin)
limit numbers in toilets areas, ensure regular and thorough cleaning and disinfecting and place hand sanitiser close to entrance/exit of toilets
ensure customers with children supervise social distancing
create zones using screens or barriers (eg a table) to achieve social distance
use posters, signage, and markers on the ground, regulate queues and limit numbers allowed in the business to collect food
be clear and confident in communicating rules to workers and customers as this helps people feel secure
use a one-way system or continuous forward flow and separate entrance/exits
encourage phone/email/app orders and ask people to wait in their cars if possible
stagger food collections
laminate menus to provide a cleansable surface, or use single use menus
keep menus simple and structure prices to reduce the need to give change if cash sales are essential, eg £1.99 requires 1p change, £2.00 reduces need for an interaction
implement table service to encourage people to stay at their table, eliminate self-service (eg cutlery and condiments)
use Perspex screens at order and payment points to reduce contact surfaces
use an open cash box for cash deposits and wash and disinfect cash as it is removed
use contactless payment where possible
for chip and PIN provide single-use disposable covers to prevent hand contamination of machine
use single use disposables where possible, eg condiments
provide extra capacity for waste, ie paper towels and other disposable items
keep staff in separate areas: dishwash/front of house/kitchen
limit access to walk-in areas such as chiller/fridge/freezer/storeroom to certain staff
where working together, if 2m distance cannot be achieved, stand side-by-side or back-to-back rather than face-on
minimise contact with all external people including delivery drivers (both incoming stock and outgoing meals)
schedule regular deep cleans and increase maintenance cleaning.
Information and support
There is much advice available to help and support. The Food Standards Agency (FSA) at www.food.gov.uk has detailed information for food businesses. The FSA advises all food businesses which are reopening or have made changes to how they work to review and, where necessary, update their Hazard Analysis and Critical Control Point (HACCP) procedures or system (such as Safer food, better business (SFBB) packs). The FSA also provides additional opening and closing checklists for this time that may be a useful resource.
Check that any changes made to procedures or workplace layouts have not introduced any additional, unexpected hazards. Before opening:
document any changes made
document the start-up checks undertaken
inform the local food authority when restarting the food business, and of any changes to registerable activities; this includes the introduction of a new delivery or takeaway service.
The Chartered Institute of Environmental Health (CIEH) at www.cieh.org has launched “HospoSafe” to support food businesses back to work during the Covid-19 restrictions. This is a volunteer service delivered by food safety and public health specialists; the aim of this initiative is to support the hospitality community and help them trade safely and protect public health. It has also produced a useful video on the use of personal protective equipment (PPE) in the workplace.
The hospitality industry has been affected beyond measure by this crisis and it is an essential part of returning to the new normal that food businesses start to trade again. This must be done in a way that protects the health, safety and wellbeing of workers and customers. It is achievable, and there is plenty of support available — but it will require thought and determination.
Mitigating actions to reduce risk will be most effective if people understand what they need to do to maintain safety. It is therefore important for all food businesses to communicate clearly what is expected of customer behaviour. Customers need to know that services will not be provided if rules are not followed and that failure to comply could result in action by police or local authority officers.
The Government's guidance for people who work in or run food businesses can be found at GOV.UK.