INDOOR PLAY AREAS FOR CHILDREN OPERATIONAL GUIDANCE FOR SOFT PLAY EQUIPMENT
This document sets out guidance on how to open indoor play (including indoor soft play) areas safely while minimising the risk of spreading COVID-19. It gives practical considerations for how guidance can be applied in the workplace and at these locations. The following is included:
This document is to help employers, employees and the self-employed working in England understand how to work as safely as possible and protect their customers during the COVID-19 pandemic. This takes into account broader applicable guidance, such as the recommended social distancing and face coverings guidance.
While this guidance applies to England, you should always consider whether there are local restrictions in place in your area. If you live, work or volunteer in an area that is experiencing a local COVID-19 outbreak and where local restrictions have been imposed, different guidance and legislation will apply. Please consult the local restrictions pages to see if any restrictions are in place in your area.
Each business will need to adapt this into the specific actions it needs to take, depending on the nature of their business, including the size of business, how it is organised, operated and managed. A site-by-site approach is essential and COVID-19 risk assessment for premises will be unique. Therefore, this guidance should be used to translate to whatever areas are relevant to your business and any measures that are taken should fit safely with any operational needs.
This guidance does not supersede any legal obligations relating to health and safety, employment or equalities and it is important that as a business or an employer you continue to comply with your existing obligations, including those relating to individuals with protected characteristics. It contains non-statutory guidance to take into account when complying with these existing obligations. When considering how to apply this guidance, take into account agency workers, contractors and other people including guests, as well as your employees.
To help you decide which actions to take, you need to carry out an appropriate COVID-19 risk assessment, at a business and site level, just as you would for other health and safety related hazards. This risk assessment must be done in consultation with unions or workers.
COVID-19 is a public health emergency. To reopen a premises, operators must undertake a risk assessment to identify, assess and manage the risks of COVID-19, and in particular businesses should consider the risks to their workers, volunteers and customers. As an employer, you also have a legal responsibility to protect workers and others from risk to their health and safety. This means you need to think about the risks they face and do everything reasonably practicable to minimise them, recognising you cannot completely eliminate the risk of COVID- 19.
You must make sure that the risk assessment for your business addresses the risks of COVID-19, using this guidance to inform your decisions and control measures. A risk assessment is not about creating huge amounts of paperwork, but rather about identifying sensible measures to control the risks in your workplace and making a record of the significant findings. However, if you have fewer than five workers, or are self-employed, you don’t have to write anything down as part of your risk assessment. Your risk assessment will help you decide whether you have done everything you need to. There are interactive tools available to support you from the Health and Safety Executive (HSE).
Employers have a duty to consult their people on health and safety. In a small business, you might choose to consult your workers directly. Larger businesses may consult through a health and safety representative, chosen by your employees or selected by a trade union. You can do this by listening and talking to them about the work and how you will manage risks from COVID-19. The people who do the work are often the best people to understand the risks in the workplace and will have a view on how to work safely. Involving them in making decisions shows that you take their health and safety seriously. You must consult with the health and safety representative selected by a recognised trade union or, if there isn’t one, a representative chosen by workers. As an employer, you cannot decide who the representative will be.
At its most effective, full involvement of your workers creates a culture where relationships between employers and workers are based on collaboration, trust and joint problem solving. As is normal practice, workers should be involved in assessing workplace risks and the development and review of workplace health and safety policies in partnership with the employer.
Employers and workers should always come together to resolve issues. If concerns still cannot be resolved, see below for further steps you can take.
Where the enforcing authority, such as the HSE or your local authority, identifies employers who are not taking action to comply with the relevant public health legislation and guidance to control public health risks and risks to employees, they will consider taking a range of actions to improve control of workplace risks. For example, this would cover employers not taking appropriate action to socially distance, where possible. The actions the HSE can take include the provision of specific advice to employers through to issuing enforcement notices to help secure improvements.
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Employers have a duty to reduce workplace risk to the lowest reasonably practicable level by taking preventative measures. Employers must work with any other employers or contractors sharing the workplace so that everybody’s health and safety is protected. In the context of COVID-19, this means protecting the health and safety of your workers and customers by working through these steps in order:
The recommendations in the rest of this document are ones you must consider as you go through this process.
If you have not already done so, you should carry out an assessment of the risks posed by COVID-19 in your workplace as soon as possible. When a building or space is repurposed - for example when there is any change in use or type or use or other circumstance - there needs to be a fire risk assessment. More information can be found on the Health and Safety Executive website.
You should consider the security implications of any changes you intend to make to your operations and practices in response to COVID-19, as any revisions may present new or altered security risks or issues with accessibility which may need mitigations.
Whilst the risk to health from COVID-19 is at the forefront of everyone’s minds, the threat of terrorism nonetheless remains substantial. It is essential that businesses and other organisations remain cognisant of these threats as they look to adjust their operations, ensuring that security measures are proactively adapted to support and complement other changes.
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, could constitute a breach of health and safety law. The actions the enforcing authority can take include the provision of specific advice to employers to support them to achieve the required standard, through to issuing enforcement notices to help secure improvements. Serious breaches and failure to comply with enforcement notices can constitute a criminal offence, with serious fines and even imprisonment for up to two years. There is also a wider system of enforcement, which includes specific obligations and conditions for licensed premises.
Employers are expected to respond to any advice or notices issued by enforcing authorities rapidly and are required to do so within any timescales imposed by the enforcing authorities. The vast majority of employers are responsible and will join with the UK’s fight against COVID- 19 by working with the government and their sector bodies to protect their workers and the public. However, inspectors are carrying out compliance checks nationwide to ensure that employers are taking the necessary steps.
You must share the results of your risk assessment with your workforce. If possible, you should publish the results on your website (and we would expect all businesses with over 50 workers to do so).
We would expect all businesses to demonstrate to their workers and customers that they have properly assessed their risk and taken appropriate measures to mitigate this. You should do this by displaying a notification in a prominent place in your business and on your website, if you have one.
You should display the following notice in your workplace to show you have followed this guidance: Staying COVID-19 Secure in 2020. There may also be other industry standards or marks that you can use to demonstrate to any visitors, guests and customers that you have thought carefully about risk.
Cleaning regimes should be reviewed before reopening. An enhanced cleaning routine must be established, documented, trialled and practiced to ensure all surfaces can be effectively cleaned before reopening the business.
For general hygiene precautions, centres should follow HSE guidance for cleaning. For additional cleaning after a suspected case of coronavirus, centres should follow government guidance on cleaning in non-healthcare settings outside the home
Steps that will usually be needed:
There are several products on the market which provide ongoing protection keeping treated areas contamination free between cleaning cycles. These products form an antimicrobial coating on surfaces by forming an environment which makes it difficult for bacteria, viruses, fungi, spores and mould to reproduce.
These products should conform with the relevant British standards such as EN1276, EN1650, EN14476.
Steps that will usually be needed:
From 8 August 2020, it is now mandatory for visitors to indoor settings to wear face coverings. The Government has produced guidance on when to wear a face covering and how to make your own. Children under the age of 11 and those who have health, age, equality or disability reasons may be exempt from wearing face coverings.
The opening up of the economy following the COVID-19 outbreak is being supported by NHS Test and Trace. You should assist this service by keeping a temporary record of your customers and visitors for 21 days, in a way that is manageable for your business, and assist NHS Test and Trace with requests for that data if needed. This could help contain clusters or outbreaks.
Many businesses that take bookings already have systems for recording their customers and visitors – including restaurants, hotels, and hair salons. If you do not already do this, you should do so to help fight the virus. We have worked with industry and relevant bodies to design this system in line with data protection legislation, and further guidance can be found here.
You should maintain social distancing in the workplace wherever possible. Social distancing applies to all parts of a premises where business is conducted, not just the place where people spend most of their time, but also entrances and exits, break rooms, staging sites and store rooms, canteens and similar settings. These are often the most challenging areas to maintain social distancing.
Operators will have to reduce capacity before reopening to enable social distancing whilst within our facilities. Steps that will usually be needed include:
Where the social distancing guidelines cannot be followed in full in relation to a particular activity, businesses should consider whether that activity needs to continue for the business to operate, and, if so, take all the mitigating actions possible to reduce the risk of transmission between their staff. These include:
In order to keep the virus under control, it is important that people work safely. Working from home remains one way to do this. However, the risk of transmission can be substantially reduced if COVID-19 secure guidelines are followed closely.
Employers should consult with their employees to determine who can come into the workplace safely taking account of a person’s journey, childcare responsibilities, protected characteristics, and other individual circumstances. Extra consideration should be given to those people at higher risk.
Businesses should consider the impact of workplace reopening on local transport, and take appropriate mitigating actions (e.g. staggered start and finish times for staff). When it is decided that workers should come into their place of work then this will need to be reflected in the COVID-19 risk assessment and actions taken to manage the risks of transmission in line with this guidance. It is vital employers engage with workers to ensure they feel safe returning to work, and they should not force anyone into an unsafe workplace. Steps that will usually be needed include:
Clinically extremely vulnerable individuals may be advised not to work outside the home if the prevalence of disease in the community is very high.
Clinically vulnerable individuals, who are at higher risk of severe illness (for example, people with some pre-existing conditions), have been asked to take extra care in observing social distancing and should be helped to work from home, either in their current role or in an alternative role.
If clinically vulnerable (but not extremely clinically vulnerable) individuals cannot work from home, they should be offered the option of the safest available on-site roles, enabling them to stay at the recommended distance away from others. If they have to spend time within this distance of others, you should carefully assess whether the activity should continue. If so, further mitigating actions should be taken to reduce the risk of transmission between individuals.
As for any workplace risk you must take into account specific duties to those with protected characteristics, including, for example, expectant mothers who are, as always, entitled to suspension on full pay if suitable roles cannot be found. Particular attention should also be paid to people who live with clinically extremely vulnerable individuals. Steps that will usually be needed include:
If you have symptoms of COVID-19—a high temperature, new and persistent cough or anosmia, however mild, you should self-isolate for at least 10 days from when your symptoms started OR if you are not experiencing symptoms but have tested positive for COVID-19 you should self- isolate for at least 10 days starting from the day the test was taken.
If you have tested positive whilst not experiencing symptoms but develop symptoms during the isolation period, you should restart the 10 day isolation period from the day you develop symptoms.
Steps that will usually be needed:
In applying this guidance, employers should be mindful of the particular needs of different groups of workers or individuals. For instance, employers have a duty to make reasonable adjustments to avoid disabled workers being put at a disadvantage compared to non-disabled people in the workplace.
Employers also have particular responsibilities towards disabled workers and those who are new or expectant mothers.
Steps that will usually be needed include:
The Government advises that when managing the risk of COVID-19, additional PPE (beyond what you usually wear) is not beneficial. This is because COVID-19 is a different type of risk to the risks you normally face in a workplace, and needs to be managed through social distancing, hygiene and fixed teams or partnering, not through the use of PPE. Workplaces should not encourage the precautionary use of extra PPE to protect against COVID-19 outside clinical settings or when responding to a suspected or confirmed case of COVID-19. The Government advises that unless you are in a situation where the risk of COVID-19 transmission is very high, your risk assessment should reflect the fact that the role of PPE in providing additional protection is extremely limited.
Ventilation is an important part of mitigating against the transmission of COVID-19. Ventilation into the building should be optimised to ensure a fresh air supply is provided to all areas of the facility and increased wherever possible. Particular attention should be given to areas where high intensity exercise activity takes place.
To achieve this, specific measures should be implemented:
You should also consider:
Further guidance is provided in the CIBSE COVID-19 Ventilation guidance.
Guest communications and resulting guest behaviours will play a large part in the relaunch of our centres. The use and operating culture of centres will need to be reviewed and assessed in line with the new social distancing protocols we now live with.
Changes in use and operation of the soft play centre should be communicated to visitors prior to planning a visit, at the main point of entry, and throughout your facility in key points. This should include information on:
Furthermore communication throughout the entire guest journey will assist with the day to day operation and compliance with new centre procedures and customer guidance. When communicating safety messages owners/operators should ensure they are able to reach those with hearing or vision impairments. Consideration should also be given on how to assist those with disabilities with complying with the changes
Steps that will usually be needed:
Steps that will usually be needed:
Additional measures that can reduce the risk COVID-19 transmission in playgrounds and outdoor gyms focus on promoting responsible behaviour by children, parents, carers and guardians.
For example, owners and operators should consider putting up signs to make clear to users, parents, guardians and carers that:
Owners and operators should provide clear information to parents to set clear expectations about how children should behave when using playgrounds during COVID-19. This may be through one or more of: signs adjacent to the playground, online (e.g. operator websites or community message boards), or through leafleting.
Owners and operators may wish to consider reminding parents of the owner/operator’s legal obligations towards the playground users such as signs stating that allowing children to use playground equipment is done at their own risk where appropriate.
It is vital to ensure staff information, instruction and training is reviewed, updated and refreshed at this time of reopening. The team may have been out of the business for some time and only seeing any centre updates via social media. Retraining your staff on your new protocols and listening to any concerns or inputs they have; they will be the front line in your operations. Staff may have a lot of questions when returning to work and may be nervous about crowds. Ensure that your staff are fully prepared and have all the skills, knowledge and necessary information.
Time should be allocated prior to opening to reintroduce operating protocols to provide safe places of work for them to be able to return to and perform their role in providing a safe place for our customers.
Devise a system to allow you to establish staff who may have illnesses, any health concerns regarding Covid-19, and any team members who may have been in contact with someone with Covid-19 prior to their work. More information on protecting clinically vulnerable and clinically extremely vulnerable individuals can be found in the Visitor Economy guidance.
Staff in all departments of our businesses may have had extended time away from their job roles resulting in a loss of competence. Centres should apply policies and procedures on relaunch as at any other time. If amendments are to be made to current policy and procedure, then approach this on a risk assessed basis. Each department will have different complexity of tasks and the staff members completing the most complex of tasks should at minimum be reassessed. Suggestions on training and assessment:
Owners/operators must take into account the requirements of children with additional needs. Issues that are likely to be specific to this group include:
Prior to re-opening all normal protocols need to be carried out for food and beverage areas in accordance with Environment Health standards. Facilities should only be opened in line with government regulations.
Centres should follow Government guidance on Restaurants, Pubs and Takeaways. Centres should review protocols to best deliver the safest food service operations to our guests, whilst also ensuring social distancing measures. This may include a reduced service or re-structuring how the traditional cafe servery operates and is laid out.
Public toilets, portable toilets and toilets inside the premises should be kept open and carefully managed to reduce the risk of transmission of COVID-19.
Steps that will usually be needed:
Many attractions within our facilities may have been sitting for lengthy periods with little or no operation. These attractions will need to have a detailed assessment before being put back into public use. There is an array of issues that could occur during an extended closed period including corrosion, change in characteristics of lubricants, rodents, excess dust to name just a few. Many planned preventative checks would have been missed during this period including daily, weekly, bi-weekly, monthly checks etc. It will be essential that your maintenance program is reviewed and missed checks either completed or risk assessed.
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