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Published 26 June 2020
The world around us slowly relaxes as we creep towards the lifting of restrictions that have affected our daily lives for the last few months. On 4th July cafes, restaurants and pubs that play such an important role in our collective social life, will be allowed to reopen: Independence Day for many who have feared for their livelihoods, cancelled orders and events and reluctantly furloughed loyal staff.
Atmosphere plays a large part in the draw of a food venue. A new landscape awaits, with restaurants and cafes once again able to invite the public to dine in but with rigorous safety restrictions. For some this presents a challenge, for others an opportunity.
Business owners and managers have been grappling with the challenge of balancing customer safety, employee safety and food hygiene against job retentions and bank balances. For many, the reduction of the recommended safe distance from 2 metres to “1 metre plus” will be the difference between being able to balance those competing interests and not being able to reopen at all.
The restaurant trade will come bouncing back, albeit looking very different to the one that closed its doors in mid-March, and there are undeniably hard times ahead. If the queues which formed upon the opening of non-essential shops tells us one thing it is this: people are longing to return to normal (and goodness knows we deserve a treat)! The hospitality industry can provide just that. Its welcoming interior is what people want, what people crave and the comfort people have been denied.
My prediction is this: people will come. After all, these venues are more than a place to grab a bite to eat: they are gathering spaces, community hubs, lifelines to many. The public will tolerate reduced menus, increased prices, slower service, queues and physical barriers in the name of safety and social distancing. They will even forgive teething troubles: we are in this together.
There will be many, however, no doubt led by the ever hungry media, who will seize on any news of a localised outbreak of Covid-19 following a relaxation of the lockdown.
In planning to open, members of the hospitality trade must abide by Government guidance to ensure that they can open safely. The guidance is detailed and should be read thoroughly. Here, we set out a few tips and consider the likely starting points as venues prepare to unlock their doors.
Government guidance sets out its five steps to working safely that underpin every piece of more detailed sector guidance for returning to work. The five steps comprise:
Guidance relating to on-premises food service has now been released. Where guidance is followed, that will usually mean that a business is doing the right thing but businesses will need to bear in mind that guidance is not the law. There is no one-size-fits-all approach and each business will need to consider carefully whether it can put in place appropriate controls to manage the risks enabling it to reopen its doors to the public.
Horror stories abound: waiting staff in full hazmat suits? Each table to be contained within a little Perspex greenhouse? Self-service hatches for collection with excitable diners, let off the leash and in full celebratory swing perhaps lacking the finer skills of balance…?
Perhaps not. From the guidance above, the following points are key to reopening restaurants, bars and cafes.
A hygienic work environment is second nature to any establishment serving food. The new challenge here, unique to the food sector, is managing the interface between the food, employees and the public. After all, we have all been warned repeatedly not to touch our faces and here we are, selling a product which, by its very nature, is to be ingested!
Perhaps inevitably, it all comes down to risk assessment. Employers have a duty to conduct and suitable and sufficient assessment of arising out of their business activities and, where there are 5 or more employees, to record the significant findings. It is good practice to consult with the workforce and to communicate the findings of the risk assessment. In order to manage the risk of transmission of Covid-19, existing risk assessments will need to be reviewed to ensure that businesses are, to coin the phrase of the moment, “Covid-secure”.
Risk assessments must be shared with employees and the duty to risk assess applies to individuals themselves. Food businesses must identify those employees who are at higher risk or who live with someone who is and control measures, specific to those employees, must be implemented.
The FSA provides a very handy checklist for reopening which stresses that, in planning to reopen a premises, businesses must ensure that basic safety standards are met as well as planning for increased hygiene with Covid-19 in mind. Businesses must ensure that all surfaces and food storage areas are disinfected and a full risk assessment is undertaken and recorded. The checklist is lengthy and is largely based upon current good practice and HACCP principles.
Of note are the following requirements, easily overlooked and relevant to the current context:
This will already be a fundamental safety procedure of any food business. The FSA has stated that the risk to the public remains low, does not recommend anything over and above existing food hygiene practice, but this depends on good hygiene.
Employers will, however, need to consider the risk of transmission between customers or from customers to staff. Control measures might include measures such as reducing the use of cash and installing hand cleaning facilities for customers. Cleaning regimes will be heightened and any measures that can reasonably be taken to reduce contamination by touch must be taken.
Businesses will want to consider, where practicable, ensuring that employees who handle cash or cards do not handle or serve food. If that is unavoidable, hand hygiene will be critical.
Where practicable, it is advisable for employers to implement shift patterns or working teams such that staff work on rotas with the same groups. This means that if one employee is required to self-isolate, the number of colleagues they have come into contact with will be easily traceable. If one staff member develops symptoms, this should limit the number of staff with whom they will have come into contact and who are therefore also required to self-isolate.
The ever-thorny question of PPE will need to be addressed here as well. To manage any risk of transmission it may be sensible to issue staff with facemasks and gloves. Again, this is a matter of risk assessment and requires a rigorous risk assessment. If wearing a Perspex mask, for example, gives rise to the risk of limited visibility in a hot kitchen environment, it may not be an appropriate control measure.
The objective here is: to maintain social distancing (ideally of 2 metres but certainly of 1 metre plus) wherever possible, including while arriving at and departing from work, while in work and when travelling between sites. Businesses will need to consider how to remove person-to-person contact or reduce it to the lowest possible level.
In the kitchen this may mean reducing the number of staff, designated drop-off and pick-up points or back-to-back (as opposed to face-to-face) workstations. As with all considerations this will need to be risk assessed and if altering the layout of a kitchen would increase the risk of harm from, for example, a deep fat fryer, or be otherwise impracticable, alternative measures are likely to be more appropriate.
In public areas this may mean screens between staff and customers, distancing the tables so as to leave a gap between the persons seated and any passers-by (remembering that the minimum distance will need to be adhered to either side of the passer-by) or one-way systems. Avoiding pinch points at doors or during a “rush” at particular times of day should be risk assessed and planned for, perhaps with the co-operation of other local businesses.
Table sharing, diner-style, and seats at the bar will be obvious casualties. Short of booths or Perspex screens, it is hard to envisage a way in which social distancing can be achieved in such a setting.
It is extremely likely that drastic changes will be made to the way in which food is ordered and delivered in order to achieve social distancing. The newly-published guidance makes certain suggestions but a risk-based approach is likely to result in designated ordering points, staff and customer one-way systems, reducing the time spent away from the table by means of telephone or app ordering and reducing the contact between waiting staff and diners. The return of the trolley service may prove to be an effective way to provide food to diners while maintaining a safe distance.
Chefs may wish to consider reducing or altering menus in order to allow themselves to operate with fewer staff or a different kitchen layout.
Once again, basing any revisions on a detailed risk assessment, businesses may need to alter the way in which goods are delivered or sent out. Measures which should be considered might include one-way systems, contactless deliveries, reducing the frequency of deliveries and single-staffing them where possible. Businesses will need to consult with employees and suppliers to ensure that systems are both effective and practicable.
Importantly, businesses will need to ensure that welfare and handwashing facilities are available for delivery drivers, and to satisfy themselves that their suppliers are managing their own Covid risks. Due diligence here will be essential.
Although beset with delay, the Government has been clear that the lifting of lockdown restrictions will depend on the availability of robust contact tracing systems. It is no surprise, then that food business have been asked to implement a system to ensure that customers register their details on entry.
Businesses should plan for an efficient and effective way of achieving this. Staff in customer-facing roles may need to be provided with training to enable them to answer questions and empower them to deal with any opposition and policies will almost certainly need to be drawn up and publicised.
Pooled knowledge, in an evolving situation such as this, is crucial. Share ideas . Involve your staff: remember, they will far more willingly engage in a process when they have had an input and understand the rationale. Speak to other businesses of a similar size, layout or style.
There will be cost implications to the measures that are required, and this is unavoidable. However, businesses can bulk buy or consider teaming up with others to place orders or appoint contractors at favourable rates.
Now is the time to check in with those consultants you keep on a retainer and don’t quite get round to consulting! Check your insurance policy to see whether any advisory services are offered in the small print.
Perhaps most importantly, consider whether you can make the most of your local Environmental Health department, as they will know what other businesses in the local area are doing and ready knowledge could be priceless in the time it will save you. The last thing they want is the headache of a local spike in infections.
Do exercise caution, though. If you have a good relationship with them and are prepared to implement their recommendations this will work well, but bear in mind that they are the people who will be first to respond to a complaint from a concerned member of the public or to be tasked with investigating in the event of a local outbreak.
Be sure to risk assess and document any departure from recommendations made, but remember that it could serve you very well indeed to have received the blessing of the very person later sent to investigate the problem…
At DAC Beachcroft, we are recognised specialists in supporting all aspects of the hospitality industry. If you would like to know more about how we can support our clients in the hospitality sector, or for further advice on any of the topics discussed above, please contact Bridget Sanger in the Safety, Health and Environment team or Victoria Kennedy, Sector Lead for Leisure and Hospitality.
+44 (0) 117 366 2867
London - Walbrook
+44(0)20 7894 6857
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